I am writing to you to request a deviation on behalf of my client Philip Reynolds. The current plea offer is for Mr. Reynolds to plead guilty to DUI Impaired to the slightest degree, and under other terms to serve three days in prison.
Based on my client’s background and the circumstances of this case, Philip is respectfully asking that the State amend its current plea offer and allow him to serve only one day in jail.
Philip is a single father of three minor children. His wife abandoned the family in 2011. Philip petitioned for a divorce in 2011. His wife did not participate in the divorce and Philip was awarded sole legal decision-making and parenting time of his children. For the last six years Philip has been trying to provide for his family by working full-time as long-haul trucker, while at the same time raising his children as a single parent. It would be a substantial hardship for Philip and his children if he were forced to serve three days in jail. The children would then be separated from their father for three consecutive days. Their father is the only person they know and trust as their guardian. In order for the children not to be separated from him, for such a long period of time, Philip is respectfully requesting to serve only one day in jail.
The charges in this matter stem from the traffic stop
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He will not be able to provide for his family as a single parent, and he will have to find a new job that will not require him to drive. The bottom line is that Philip has three children to support and for whom he has to take care. Furthermore, he has been a productive member of society and a law-abiding citizen with no prior DUIs or other