UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA v. ROBEL PHILLIPOS

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Crim. No. 13-MJ-2162-MBB

JOINT MOTION TO CONTINUE PROBABLE CAUSE HEARING The parties jointly move to continue the probable cause hearing, which is currently scheduled for 2:00 p.m. on May 6, 2013, to May 16, 2013 or thereafter. the parties state the following: (1) On May 1, 2013, defendant ROBEL PHILLIPOS (the “defendant” or “PHILLIPOS”), a United States citizen, was charged by complaint with making false statements during a terrorism investigation. An initial appearance was held on that date at which time the government moved for detention under 18 U.S.C. § 3142(f)(2)(A) on the grounds that PHILLIPOS posed a serious risk of flight. (2) Since the initial appearance, the parties have conferred extensively and now agree that the Court can fashion strict conditions of release that will reasonably assure the defendant’s appearance at future proceedings. Specifically, the parties recommend that In support of this motion,

the Court impose the following conditions: (a) home

confinement at the residence of a third-party custodian; (b) defendant shall be monitored for 24 hours a day on an electronic bracelet; and (c) his release will be secured by a secured bond in the amount of $100,000. (3) On this date, the government has provided the defendant early discovery, which the defendant requires time to review. Additionally, the parties request additional

time to confer about how this matter should proceed and therefore, request a continuance until May 16, 2013 or thereafter.

Respectfully submitted, CARMEN M. ORTIZ United States Attorney By: /s/ B. Stephanie Siegmann B. STEPHANIE SIEGMANN JOHN A. CAPIN Assistant U.S. Attorneys By: ROBEL PHILLIPOS Defendant /s/ Derege B. Demissie DEREGE B. DEMISSIE Counsel for defendant

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