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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
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
3. That on September 11, 2008 the defendant was arrested at the house address she
4. That on September 11, 2008 Magistrate Judge James P. O’Hara sustained the
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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
6. That the settlement amount will ensure that she can remain in appropriate contact
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
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
10. That the interests of justice require that this request be granted.
WHEREFORE, the defendant prays that this court schedule a hearing to reconsider
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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: PDARCY@KC.RR.COM
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
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