Petitioner is asking for, and evidence set forth demands, 1. Immediate vacating of sentence and release from custody (or)  2. Immediate release from custody (or)  3. Immediate release from custody to prepare for evidentiary hearing.


Petitioner is not a flight risk.


Over the course of time from arrest, Petitioner:

1. Voluntarily turned himself in for arrest
2. Never violated rules of probation in any way
3. Always showed up on time for every court action
4. Never violated rules of house arrest.

Over course of time from arrest to trial, Petitioner:

1. Had bail reduced by court from $100,000 secured to $100,000 unsecured.
2. Had travel restrictions to limits of Lackawanna County increased to Commonwealth of PA to no travel restrictions
3. Had check-in to probation office daily reduced to check-in or call once per month
4. Had no violations of any kind during period.

Petitioner is not a flight risk; his only goal is to be cleared of these heinous crimes he did not commit.