Case: 5:20-cr-00482-SO Doc #: 31 Filed: 08/12/21 1 of 3.

PageID #: 143

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF OHIO
EASTERN DIVISION

UNITED STATES OF AMERICA ) CASE NO.: 5:20-CR-482

)
Plaintiff, ) JUDGE SOLOMON OLIVER JR.
)
)
JOE L. FLETCHER III ) DEFENDANT’S MOTION FOR
) PERMISSION TO ATTEND
Defendant. ) HIS DAUGHTER’S
) FUNERAL SERVICES
)

Now comes the Defendant, Joe L. Fletcher III, by and through the undersigned counsel, and

respectfully requests this Honorable Court to enter an order allowing the Defendant to attend the funeral

services of his daughter, Jabrayla Fletcher. Jabrayla Fletcher regrettably passed away on August 6, 2021.

As grounds for this motion, Defendant states the following relevant history:

On or about June 24, 2020, in the Northern District of Ohio, Eastern Division, the Defendant is

alleged to have illegally possessed a firearm and consequently was charged with Felon in Possession of

a Firearm and Ammunition, in violation of 18 U.S.C. §§922(g)(1) and 924 (A)(2). On the same date,

the Government further alleges that the Defendant Possessed with Intent to Distribute a Controlled

Substance, 28 grams or more of a mixture and substance containing a detectable amount of cocaine base

(crack), in violation of 21 U.S.C. §841(A)(1) and (b)(1)(B). Lastly, the Government claims that the

same firearm in Count 1 was Possessed in Furtherance of a Drug Trafficking Offense, in violation of 18

U.S.C. §924 (c)(1)(A)(i), On September 3, 2020, the Defendant was indicted on the above charges,

subsequently, a superseding indictment was filed on September 24, 2020, realleging the Felon in

Possession charge, however, on a different date. There are no allegations of violence associated with

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 Case: 5:20-cr-00482-SO Doc #: 31 Filed: 08/12/21 2 of 3. PageID #: 144

any of the counts.

On August 6, 2021, the Defendant's mother, Ms. Asonya Alexander-Frye, contacted the

undersigned and explained that the Defendant's daughter had passed on the above date. The death of the

Defendant’s daughter was not expected, she died from carbon monoxide poisoning, the source believed

to be a leaky hot water heater. The Defendant is hopeful that this Honorable Court will allow the

Defendant to attend his daughter's funeral services. The funeral arrangements have been set, and the

viewing and funeral will be held on Wednesday, August 18, 2021, from 12:00p.m. – 3:00 p.m., at the

Rhoden Memorial Home, 1101 Palmetto Ave, Akron, OH, 44306 (Obituary to be furnished when ready).

The repass will be held at Good Year Local Hall, 501 Kelly Avenue #A, Akron, Ohio, 44306 from 4:00

p.m. – 8:00 p.m.

The Defendant is requesting this Honorable Court allow him to be furloughed from NEOCC.

The Defendant’s mother is willing to transport the Defendant to and from the funeral and assures the

court that the Defendant will return to NEOCC without detour. The Defendant maintains that he is not a

flight risk and eager to defend against the charges within the indictment. Alternatively, if the court is

willing to furlough the Defendant, the Defendant asks if feasible that the U.S. Marshall transport the

Defendant to the funeral home and return the Defendant to NEOCC when visitation is completed.

Wherefore, the Defendant respectfully requests that this Honorable Court enter an order granting

the Defendant’s motion to attend funeral services.

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Respectfully submitted;

FERNANDO MACK, L.P.A.

/s/ Fernando Mack, Esq.

FERNANDO MACK (#0062937)
1220 West 6th Street
The Bradley Building, Suite 203
Cleveland, Ohio 44113
(216) 556-9610
(855) 320-8107 Fax
losmacks@msn.com

CERTIFICATE OF SERVICE

I hereby certify that on August 12, 2021, a copy of the foregoing was filed electronically.

Notice of this filing will be sent to all registered parties by operation of the Court’s electronic

filing system. Parties may access this filing through the Court’s system. All other parties will be

served by regular U.S. mail.

/s/ Fernando Mack, Esq.

FERNANDO MACK, ESQ. (#0062937)
Attorney for Defendant