NOTICE OF MOTION FOR SENTENCE REDUCTION

Douglas Wade Williamson

Federal Correctional Complex

3000 Old Hwy

Butner, NC 27509

Defendant in pro per

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF SOUTH CAROLINA

AIKEN DIVISION

NOTICE OF MOTION FOR SENTENCE REDUCTION UNDER 18 U.S.C. § 3582(c)(1)(A) (Compassionate Release)

You are notified that on Insert Date, at Insert Time¸ or as soon thereafter as the Defendant can be heard, in Courtroom ___ of the United States District Court for the District of South Carolina, the Defendant will bring on for hearing his Motion for Sentence Reduction under 18 U.S.C. § 3582(c)(1)(A) (Compassionate Release) for the reasons stated in the attached Motion.

Dated this ____ day of January, 2022.

Respectfully Submitted,

___________________________________

Douglas Wade Williamson,

Defendant in pro per

Douglas Wade Williamson

Federal Correctional Complex

3000 Old Hwy

Butner, NC 27509

Defendant in pro per

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF SOUTH CAROLINA

AIKEN DIVISION

MOTION FOR SENTENCE REDUCTION UNDER 18 U.S.C. § 3582(c)(1)(a) (Compassionate Release)

NOW COMES Douglas Wade Williamson, Defendant, and brings this Motion for Sentence Reduction under 18 U.S.C. § 3582(c)(1)(A) (Compassionate Release), and for cause would show this Honorable Court as follows:

1. Defendant was sentenced on Insert Date to a term of Insert Prison Term Imposed. As of the filing of this Motion, Defendant had served Insert Time Already Served.
2. 18 U.S.C. § 3582(c) provides as follows: “The court may not modify a term of imprisonment once it has been imposed except that – (1) in any case (A) the court, upon motion of the Director of the Bureau of Prisons, or upon motion of the defendant after the defendant has fully exhausted all administrative rights to appeal a failure of the Bureau of Prisons to bring a motion on the defendant’s behalf or the lapse of 30 days from the receipt of such a request by the warden of the defendant’s facility, whichever is earlier, may reduce the term of imprisonment (and may impose a term of probation or supervised release with or without conditions that does not exceed the unserved portion of the original term of imprisonment), after considering the factors set forth in section 3553(a) to the extent that they are applicable, finds that – (i) extraordinary and compelling reasons warrant such a reduction; or (ii) the defendant is at least 70 years of age, has served at least 30 years in prison, pursuant to a sentence imposed under section 3559(c), for the offense or offenses for which the defendant is currently imprisoned, and a determination has been made by the Director of the Bureau of Prisons that the defendant is not a danger to the safety of any other person or the community as provided under section 3142(g).”
3. Defendant wrote letters to the warden and regional warden asking them to process his release. They replied and informed Defendant that they would be processing his release. 
4. On December 1, 2021, the regional warden informed Defendant that his case had met the required criteria for early release pursuant to the Coronavirus Aid, Relief, and Economic Securities (CARES) Act. However, Defendant has not yet been released.
5. Extraordinary and compelling reasons exist to warrant the reduction of Defendant’s sentence. 
6. It is common knowledge that the Covid-19 pandemic has forced us to exercise social distancing as one of the ways to contain its spread. That has not been possible in the facility where Defendant is currently imprisoned. 
7. On December 29, 2021, all inmates were asked to return to the Butner Prison Camp. They were tested for fever and 10 people within the unit where Defendant is housed in were taken to the hospital for suspected Covid-19 symptoms. 
8. As a result of the Bureau of Prisons’ doubling of the population of inmates at the facility where Defendant is currently detained, many inmates have displayed symptoms of Covid-19. There is no fresh air in the cells. 
9. On December 30, 2021, inmates were instructed to go work in the warehouses. That increased the chances of the spread of Covid-19. There was an outbreak of Covid-19 in 2020 within the prison as a result of a similar directive issued by the prison administration. 
10. Information from the World Health Organization reveals that the people who are at the highest risk of succumbing to Covid-19 are people with underlying medical conditions. Defendant is diabetic and has heart problems. His continued confinement in prison is detrimental to his overall health and may be fatal. 
11. Defendant has met all requirements for home confinement. His behavior level is care level 3, the least risky behavior level. The warden and regional warden agree that Defendant should be released but for some reason unknown to Defendant, that has not happened. 
12. During his time in prison, Defendant has not received any writeups. He has completed various courses while in prison, the latest being the N.C. State Horticulture course. He has also done an outside college course for 28 months and worked as a clerk in the garage.
13. Defendant poses no threat to the safety of other people. He has acquired skills that will enable him to earn a living when released. 

REASONS WHEREFORE, Defendant respectfully requests this Honorable Court to grant this Motion for Sentence Reduction under 18 U.S.C. § 3582(c)(1)(A) (Compassionate Release) and subsequently issue an order for Defendant’s release.

Dated this ___ day of January, 2022.

Respectfully Submitted,

___________________________________

Douglas Wade Williamson

Defendant in pro per

VERIFICATION

I, Douglas Wade Williamson, say that I am the Defendant in the above action, that I have read the foregoing Motion for Sentence Reduction under 18 U.S.C. § 3582(c)(1)(A) and know the contents thereof. I declare under penalty of perjury that the facts stated in this Motion are true and correct.

__________________________________

Douglas Wade Williamson

Defendant in pro per

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