IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

UNITED STATES )

 ) 02 CR 200-22

v. ) 

) Judge Rebecca Pallmeyer

ANDRE LAWRENCE ) 

MOTION FOR LEAVE TO FILE INSTANTER 

AMENDED MOTION FOR REDUCED SENTENCE UNDER

SECTION 404 OF THE FIRST STEP ACT

The defendant, ANDRE LAWRENCE, by the Federal Defender 

Program and its attorney, Amanda Penabad, respectfully requests that this 

Honorable Court grant him leave to file instanter an amended motion for 

a reduced sentence under Section 404 of the First Step Act, and also to 

formally appoint the Federal Defender Program to represent Mr. Lawrence 

in this matter.

1. The First Step Act was signed into law on December 21, 2018.

2. On January 7, 2019, Mr. Lawrence filed a pro se motion to 

reduce his sentence pursuant to the First Step Act. Doc. 1855. 

3. This Court’s General Order 19-0003, dated January 23, 2019, 

ordered that the Federal Defender Program for the Northern District of

Illinois is appointed generally for all cases arising in this District under 

Section 404 of the Act where the defendant desires appointment of counsel 

and financially qualifies for such appointment.

Case: 1:02-cr-00200 Document #: 1861 Filed: 03/14/19 Page 1 of 4 PageID #:7534
4. Mr. Lawrence has communicated to undersigned counsel that 

he desires the Federal Defender Program to be appointed to represent him 

on his requested relief under the Act.

5. Mr. Lawrence is currently incarcerated in the BOP, so it 

appears that he also financially qualifies for the appointment of the Federal 

Defender Program.

6. Upon undersigned counsel’s review of Mr. Lawrence’s pro so 

filing, she believes that filing an amended motion would best represent Mr. 

Lawrence and also assist the Court in ruling on his requested relief. 

Therefore, the defense is now seeking leave to file an amended motion 

instanter.

7. The government has no objection to the defense filing an 

amended motion instanter.

Case: 1:02-cr-00200 Document #: 1861 Filed: 03/14/19 Page 2 of 4 PageID #:7534
WHEREFORE, based on the foregoing, Mr. Lawrence respectfully 

requests that this Court grant him leave to file instanter an amended 

motion for a reduced sentence under Section 404 of the First Step Act, and 

also to formally appoint the Federal Defender Program to represent Mr. 

Lawrence in this matter.

Respectfully submitted,

FEDERAL DEFENDER PROGRAM

John Murphy,

Executive Director

By: /s/ Amanda G. Penabad

Amanda G. Penabad 

AMANDA G. PENABAD

FEDERAL DEFENDER PROGRAM

55 E. Monroe, Suite 2800

Chicago, IL 60603

(312) 621-8340

Case: 1:02-cr-00200 Document #: 1861 Filed: 03/14/19 Page 3 of 4 PageID #:7534
CERTIFICATE OF SERVICE

The undersigned, Amanda G. Penabad, an attorney with the Federal 

Defender Program hereby certifies that in accordance with FED. 

R.CIV.P5,LR5.5, and the General Order on Electronic Case Filing (ECF), 

the following documents(s):

MOTION FOR LEAVE TO FILE INSTANTER 

AMENDED MOTION FOR REDUCED SENTENCE UNDER

SECTION 404 OF THE FIRST STEP ACT

Was served pursuant to the district court’s ECF system as to ECF filing, if 

any, and were sent by first- class mail/ hand delivery on March 14, 2019

to counsel/ parties that are non-ECF filers. 

By: s/ Amanda G. Penabad

Amanda G. Penabad 

FEDERAL DEFENDER PROGRAM

55 E. Monroe St., Suite 2800

Chicago, Illinois 60603

(312) 621-8340

Case: 1:02-cr-00200 Document #: 1861 Filed: 03/14/19 Page 4 of 4 PageID #:7534