IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

UNITED STATES OF AMERICA, )

)

Plaintiff, )

 V. ) No. 20 CR 309-1

LARRY JONES, )

) Judge Virginia M. Kendall

Defendant. )

DEFENDANT LARRY JONES’ MOTION TO PLEAD GUILTY ON 

JANUARY 19, 2023 AND REMAIN ON BOND AND SELFSURRENDER OR DELAY THE ACCEPTANCE OF HIS GUILTY 

PLEA UNTIL MAY 1, 2023 OR TO CONTINUE THE DATE FOR HIS 

GUILTY PLEA UNTIL MAY 1, 2023

 Defendant Larry Jones, by his attorney, Phillip A. Turner, respectfully 

requests that this Court either allow him to plead guilty on January 19, 2023 

and remain on bond and self-surrender or allow him to plead guilty and 

delay the acceptance of his guilty plea until May 1, 2023 or to continue the 

date for his guilty plea until May 1, 2023. In support of this motion, 

defendant Larry Jones states the following:

1. Larry Jones has a plea agreement with the government and is scheduled 

to plead guilty on January 19, 2023. 

2. Mr. Jones has a legitimate job working for 1 City United with offices at 

5219 West Lake Street Chicago, Illinois. 1 City United has contracts with 
2

the City of Chicago to clean up blighted areas on the west and south sides of 

Chicago. Larry Jones has become a supervisor of one of the organization’s 

cleaning and clearing groups. Attached is a letter from Larry Hardimon, 

Vice-President of 1 City United, describing the organization and its mission. 

Also, the letter sets forth the need to have Larry Jones available until May 1, 

2023.

3. The letter indicates the nature of the organization and the salutary effect 

that this organization is attempting to have on the communities on the west 

and south sides of Chicago.

4. As indicated in the letter, Larry Jones has done good and valuable work 

for this organization and the community. In addition, he is needed by the 

organization to complete contracts which the organization has obtained.

5. The pretrial services officer assigned to Larry Jones has visited Larry 

Jones at his work site. Larry Jones has been on home confinement. He 

leaves his home to go work and church. There have not been any violations.

6. Larry Jones realizes that it is likely that when he pleads guilty to the 

narcotics offense in this case, that this Court will take him into custody. He

would like to help the organization get started on the projects for the new 

year and assist in training his replacement before he is in custody. In 

addition, Larry Jones wants to leave his family with as much money as 
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possible. Larry Jones has explained to his son that he engaged in criminal 

conduct and that he must be accountable for his conduct. He is trying to be 

responsible to an employer who gave him an opportunity and make certain 

that his son does not repeat the same wrongful conduct. He is aware that the 

neighborhood from which he comes often leads to a future of being 

murdered or going to prison. Larry Jones has learned and is hopeful to avoid 

this fate for his son. 

i

 Wherefore, defendant Larry Jones respectfully requests that this Court 

enter an order allowing him to plead guilty on January 19, 2023, and remain 

on bond and self-surrender or delay acceptance of the guilty plea until May 

1, 2023 or continue the date for defendant Larry Jones to plead guilty to May 

1, 2023.

Respectfully submitted,

/s/Phillip A. Turner

Phillip A. Turner

Attorney for defendant

20 North Clark Street

Suite 3300

Chicago, Illinois 60602

312-899-0009

 pturner98@sbcglobal.net
4

CERTIFICATE OF SERVICE

 The undersigned attorney hereby certifies that in accordance with Fed. 

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

the following document:

DEFENDANT LARRY JONES’ MOTION TO PLEAD GUILTY ON 

JANUARY 19, 2023 AND REMAIN ON BOND AND SELF 

SURRENDER OR DELAY THE ACCEPTANCE OF HIS GUILTY 

PLEA UNTIL MAY 1, 2023 OR TO CONTINUE THE DATE FOR HIS 

GUILTY PLEA UNTIL MAY 1, 2023

was served pursuant to the district court’s ECF system as to ECF filers.

 Respectfully submitted,

 /s/Phillip A. Turner 

 Phillip A. Turner

 Attorney for defendant

 20 North Clark Street

 Suite 3300

 Chicago, Illinois 60603

 312-899-0009

 pturner98@sbcglobal.net

i Some of the judges in this district have taken the position that the United States Bureau 

of Prisons remains under pandemic restrictions at many facilities because of the indoor

and congregate living arrangement. Even the least-restrictive Bureau of Prisons facilities, 

at level one, still require masking. As a result, judges have interpreted the ongoing 

restrictions as an “exceptional reason” under 18 U.S.C. Section 3145(c) allowing for 

continued pre-surrender release and self-surrender.