Stacy Barnes Motion For Release2
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Case 2:08-cr-20001-KHV
Document 38
Filed 11/03/2008
Page 1 of 3
IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS
UNITED STATES OF AMERICA, Plaintiff, vs. STACT LYN BARNES-CATLETT, Defendant.
) ) ) ) ) )
Case No. 08-20001-001-KHV
DEFENDANT BARNES-CATLETT’S MOTION FOR HEARING TO RECONSIDER APPROPRIATENESS OF DETENTION
COMES NOW defendant Stacy Lyn Barnes-Catlett, by and through her attorney, Patrick E. D’Arcy, and respectfully moves this court for a hearing to consider the appropriateness of her continued detention. In support of said motion, the defendant asserts as follows: 1. That on July 21, 2008 the defendant plead guilty and was released from detention. 2. That the defendant, upon her release, continued to reside at the address she provided but her cellular phone broke and she did not have the resources to replace it until just before her arrest. Furthermore, she did not receive a letter from the Probation Office, causing her to fail to maintain appropriate contact and thereby violated her Conditions of Release. In addition, she herself signed up for appropriate treatment but failed to attend the first appointment because she had injured her head in a fall and was not functional for three days. 3. That on September 11, 2008 the defendant was arrested at the house address she had provided upon her release. 4. That on September 11, 2008 Magistrate Judge James P. O’Hara sustained the
1
Case 2:08-cr-20001-KHV
Document 38
Filed 11/03/2008
Page 2 of 3
government’s motion to revoke the defendant’s bond while leaving open the option for the defendant to petition for reconsideration once appropriate plans had been made for her release. 5. That on September 11, 2008 the defendant had a scheduled Settlement Hearing in Johnson County, Kansas that would have resolved her Workers’ Compensation case and resulted in a net award, to her, of $4,038.75 (please see attachment), but she could not attend due to her arrest. Her Johnson County Settlement Hearing has been rescheduled for November 7, 2008 at 11:00 a.m.. 6. That the settlement amount will ensure that she can remain in appropriate contact and otherwise meet her Conditions of Release. 7. That the defendant agrees to stay in a half-way house until she finds approved housing, to wear an electronic bracelet, to undergo drug and alcohol counseling, and to meet the rest of her Conditions of Release. 8. That the defendant requires medical attention that is not being provided to her at C.C.A.. 9. That the government does not oppose the defendant’s release as long as certain conditions are met. 10. That the interests of justice require that this request be granted. WHEREFORE, the defendant prays that this court schedule a hearing to reconsider her continued detention and release her under appropriate conditions.
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Case 2:08-cr-20001-KHV
Document 38
Filed 11/03/2008
Page 3 of 3
Respectfully submitted,
s/ Patrick E. D’Arcy ______________________ Patrick E. D’Arcy KS SC No. 13339 623 Tauromee Avenue Kansas City, KS 66101 (913) 269-1401 FAX: (913) 371-1983 e-mail: [email protected]
CERTIFICATE OF SERVICE I hereby certify that on November 3, 2008 I electronically filed the foregoing with the clerk of the court using the CM/ECF system, which will send a notice of electronic filing to the attorneys of record including Marietta Parker, Assistant Untied States Attorney.
s/ Patrick E. D’Arcy ______________________ Patrick E. D’Arcy
3
Case 2:08-cr-20001-KHV
Document 38-2
Filed 11/03/2008
Page 1 of 2
Case 2:08-cr-20001-KHV
Document 38-2
Filed 11/03/2008
Page 2 of 2
Document 38
Filed 11/03/2008
Page 1 of 3
IN THE UNITED STATES DISTRICT COURT DISTRICT OF KANSAS
UNITED STATES OF AMERICA, Plaintiff, vs. STACT LYN BARNES-CATLETT, Defendant.
) ) ) ) ) )
Case No. 08-20001-001-KHV
DEFENDANT BARNES-CATLETT’S MOTION FOR HEARING TO RECONSIDER APPROPRIATENESS OF DETENTION
COMES NOW defendant Stacy Lyn Barnes-Catlett, by and through her attorney, Patrick E. D’Arcy, and respectfully moves this court for a hearing to consider the appropriateness of her continued detention. In support of said motion, the defendant asserts as follows: 1. That on July 21, 2008 the defendant plead guilty and was released from detention. 2. That the defendant, upon her release, continued to reside at the address she provided but her cellular phone broke and she did not have the resources to replace it until just before her arrest. Furthermore, she did not receive a letter from the Probation Office, causing her to fail to maintain appropriate contact and thereby violated her Conditions of Release. In addition, she herself signed up for appropriate treatment but failed to attend the first appointment because she had injured her head in a fall and was not functional for three days. 3. That on September 11, 2008 the defendant was arrested at the house address she had provided upon her release. 4. That on September 11, 2008 Magistrate Judge James P. O’Hara sustained the
1
Case 2:08-cr-20001-KHV
Document 38
Filed 11/03/2008
Page 2 of 3
government’s motion to revoke the defendant’s bond while leaving open the option for the defendant to petition for reconsideration once appropriate plans had been made for her release. 5. That on September 11, 2008 the defendant had a scheduled Settlement Hearing in Johnson County, Kansas that would have resolved her Workers’ Compensation case and resulted in a net award, to her, of $4,038.75 (please see attachment), but she could not attend due to her arrest. Her Johnson County Settlement Hearing has been rescheduled for November 7, 2008 at 11:00 a.m.. 6. That the settlement amount will ensure that she can remain in appropriate contact and otherwise meet her Conditions of Release. 7. That the defendant agrees to stay in a half-way house until she finds approved housing, to wear an electronic bracelet, to undergo drug and alcohol counseling, and to meet the rest of her Conditions of Release. 8. That the defendant requires medical attention that is not being provided to her at C.C.A.. 9. That the government does not oppose the defendant’s release as long as certain conditions are met. 10. That the interests of justice require that this request be granted. WHEREFORE, the defendant prays that this court schedule a hearing to reconsider her continued detention and release her under appropriate conditions.
2
Case 2:08-cr-20001-KHV
Document 38
Filed 11/03/2008
Page 3 of 3
Respectfully submitted,
s/ Patrick E. D’Arcy ______________________ Patrick E. D’Arcy KS SC No. 13339 623 Tauromee Avenue Kansas City, KS 66101 (913) 269-1401 FAX: (913) 371-1983 e-mail: [email protected]
CERTIFICATE OF SERVICE I hereby certify that on November 3, 2008 I electronically filed the foregoing with the clerk of the court using the CM/ECF system, which will send a notice of electronic filing to the attorneys of record including Marietta Parker, Assistant Untied States Attorney.
s/ Patrick E. D’Arcy ______________________ Patrick E. D’Arcy
3
Case 2:08-cr-20001-KHV
Document 38-2
Filed 11/03/2008
Page 1 of 2
Case 2:08-cr-20001-KHV
Document 38-2
Filed 11/03/2008
Page 2 of 2
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