the purpose of executing and attempting to execute a scheme and artifice to defraud and to obtainmoney, as set forth below, did knowingly cause to be deposited, for the purpose of being sent anddelivered by Federal Express, a commercial interstate carrier, according to the direction thereon,an envelope addressed to Platinum Title Partners, 5325 Katy Freeway, #2, Houston , TX 77007,containing a check in the amount of $18,000, payable to the order of Platinum Title Partners.7. Under Title 18, United States Code, Section 3148(c), if there is probable cause to believe that, while on release, the defendant committed a Federal, State, or local felony, arebuttable presumption arises that no condition or combination of conditions will assure that thedefendant will not pose a danger to the safety of any other person or the community.
In view of the foregoing, the government requests the Court to issue a warrant for thearrest of defendant Eric Rulack Farmington Jr., ordering that he be brought before the court for a proceeding in accordance with Title 18, United States Code, Section 3148(b) and that after suchhearing, if the court finds that (1) there is probable cause to believe that the defendant hascommitted a Federal, State, or local crime while on release and (2) that there is no condition or combination of conditions of release that will assure that the defendant will not flee or pose adanger to the safety of any other person or the community or is unlikely to abide by any conditionor combination of conditions of release, that the court enter an order of revocation and detentionand that the defendant be held without bond pending the transfer to a designated institution soserve his sentence.
Government's Motion for Revocation of Release - Page 3
Case 3:08-cr-00153-L Document 666 Filed 07/06/11 Page 3 of 4 PageID 9564