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STATE OF MARYLAND 7 IN THE CIRCUIT COURT v. ; FOR HOWARD COUNTY SHAAN KHAWAJA, - Crim, No: 13-K-14-54428 Defendant * * ‘ * * * MOTION TO REVOKE BOND, ‘NOW COMBS the State of Maryland, by and through its attomeys, Lisa L, Broten and Colleen E. MeGuinn, Senior Assistant State's Attorneys for Howard County, pursuant to Maryland Rule 4-216 and does hereby move this Honorable Court to revoke the Defendant's current bond of $50,000 (fifty thousand dollars), 100% acceptable on the above referenced case and in support thereof does hereby state the following: 1. Onor about April 15, 20014, the Defendant Shaan Khawaja, was arrested on the charges of Sexual Solicitation of a’Minor, Attempted Third Degree Sexual Offense and Displaying Obscene Matter to a Minor, 2, Although the Defendant is a resident of Staten Island, New York, the alleged sexval crimes occurred on March 30, 2014, while he was staying at the home of a family member in Howard County, Maryland. 3. The Defendant was arrested in New York City on April 15, 2014, thanks to a collaborative effort between Howard County police and New York law enforcement. 4, After his arrest, detectives in the Howard County Police Department's ‘Warrants Division had to travel to New York and transport the Defendant back to Maryland on April 24, 2014 to be processed and advised of his charges. 5. The Commissioner set a bail of $50,000 (fifty thousand dollars), 100% acceptable, which was posted by the Defendant's furnily and he was released from custody on April 25, 2014, before a bail review could be conducted in cour. 6. The Defendant was allowed to retumn to New York where he was residing, and attending medical school, 7, This case was originally set for trial on October 21,2014, but was postponed until February 3, 2015 because of discovery issues involving DNA. 8. The Defendant was originally represented by Tonya Kelly, Esquire. On December 22, 2014, Joseph Murtha, Esquire entered his appearance, joining Ms. Kelly in ‘he representation of the Defendant. 9. The trial was reset for a Motions hearing on April 24, 2015 and trial on Tune 9, 2015, to give counsel time to prepare for trial and finalize any issues with DNA. discovery and testing, 10. On February 4, 2015, the State leamed from the lead detective on this case, Cpl. Erike Heavner, that the Defendant was arrested in Staten Island, New York on Sunday February 1, 2015 on charges of displaying pomographie material to a minor. See attached news release. 11. Inthe State’s case 13-K-14-54428, the Defendant is charged with displaying pomographic videos on his cell phone fo two young girls, ages 6 and 7. In this case, the victims were family friends of the Defendant and the display of the pornographic material was done in the home of a Defendant’s family member. 12, The allegations in New York are virtually identical, with the exception that the Defendant has perpetrated his crime against an unknown 7 year old female victim in a public place, fo wit: a Target store. 13, Inlight of these new charges, the State believes that the Defendant poses a serious and significant risk to public safety, especially to young girls, some of the most ‘vulnerable members of society. 14. Although he has eppeared each time required to do so previously, the State bas serious concems that the Defendant now poses a much greater flight risk, as he is already out of the State of Maryland and with these new charges, has more incentive not 10 show for his court dates. 15. Based upon the above stated factors, the State believes that the Defendant's current bond of $50,000 (fifty thousand dollars), 100% acceptable is completely inappropriate, Due to the serious nature of the charges, the public safety risk posed by the Defendant, especially to the minor children, and the potential flight risk given the Defendant's out of state residence and pending charges in New York, the State respectfully asks this Honorable Court to revoke or in the altemative substantially increase his bond. WHEREFORE, the Siate respectfully requests this Court to revoke or snbstantially inerease the Defendant's current bond and set in a hearing on these matters as soon as practicable. CERTIFICATE OF SERVICE, THEREBY CERTIFY that on this 1% day of February, 20015, «copy of the {foregoing State's Motion to Inctease Bond was sent by electronic mail and mailed first class, postage prepaid to Tonya Kelley, Esquire, 201 North Chatles Street, Suite 2600, Baltimore, ‘Maryland 21201 and Joseph Murtha, Esquire, Heaver Plaza, 1301 York Road, Suite 200, Lutherville, Maryland 21093, counsel for the Defendant. g sroten vk £05 Suwa PLAN PRON Ar yh wink eben nate na Man, 28, showed pornographic video to 7-year-old at Staten Island Target, police allege John M. Annese | By John M. Annese | Follow on Twitter on February 03, 2015 at 5:51 PM, updated February 03, 2015 at 5:53 PM : ile man ig» Sh80n Khawaja, 28, is accused of showing a pornographic video to a STATEN ISLAND, N.Y. ~ A Rossville man is jyear-old gil inside the Target store at 2900 Veterans Ra, West on accused of showing a pornographic video Sunday, Feb. 1, 2015, to a 7-year-old girl inside a South Shore chain store - ‘The scene unfolded at 5:50 p.m. Sunday, by the underwear section of the Target store at 2900 Veterans Rd West In Charleston, police allege. Shaan Khawaja, 28, of Selkitk Street, approached the young girl, then began playing an Indecent video on his cell phone, according to, police. He turned his phone toward the girl and whistled, and the girl ran off, police allege. “The gitl's mother contacted police, and officers tracked Khawaja to his home that evening, arresting him shortly after 9:30 p.m. (On Sunday and Monday, word of the incident had spread an Facebook, with parents worrled that the incident was an “attempted kidnapping.” No attempt at kidnapping is alleged by authorities. ‘Khawaja is charged with second-degree disseminating indecent material to a minor, and endangering the welfare of a child, according to information from District Attorney Dante! Donovan's office. if convicted at trial on the top count, he could face a maximum sentence of year and a half to four years in prison. Khawaja was slated to be arralgned in Stapleton Criminal Court Tuesday. Messages left at his home phone were not immediately returned Tuesday evening. © 2015 All rights reserved. news/print.html?entry=/2015/02/man_28_showed_pomographi... 2/4/2015

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