P. 1
IL v. Annabel Melongo bail documents, April 2010, case 08-CR-10502

IL v. Annabel Melongo bail documents, April 2010, case 08-CR-10502

|Views: 691|Likes:
Published by nkjembxiujgmns
p1: 4/20/10 Petition for hearing on violation of bail bond conditions

p2-4: 5/5/10 Motion to reduce bond from $500,000 to $100,000 filed by attorney Nicholas Alburkerk on behalf of Annabel Melongo.

p5: 5/5/10 Judge's order granting motion to reduce bail to $300,000.
p1: 4/20/10 Petition for hearing on violation of bail bond conditions

p2-4: 5/5/10 Motion to reduce bond from $500,000 to $100,000 filed by attorney Nicholas Alburkerk on behalf of Annabel Melongo.

p5: 5/5/10 Judge's order granting motion to reduce bail to $300,000.

More info:

Published by: nkjembxiujgmns on Jul 14, 2010
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

10/25/2012

pdf

text

original

STATE OF ILLINOIS

)

) SS.
COUNTY OF COOK ) IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS MUNICIPAL DIVISION - FIRST DISTRICT PEOPLE OF THE STATE OF ILLINOIS ) ) PENDING IND/INF #_

f/£
OdtdloSoZ-

VS.

PRELIMINARY HEARING COMPLAINT # . BRANCH

AA/AJH0^C

K./nezorito

(RESPONDENT- PRETRIAL RELEASE)

PETITION FOR A HEARING ON VIOLATION OF BAIL BOND CONDITIONS AND APPLICATION TO INCREASE AMOUNT OF BAIL PURSUANT TO 725 ILCS 5/110-S(a)&(e)
NOW COME the People of the State of Illinois, by their attorney, ANITA ALVAREZ, State's Attorney of Cook County, and move this Honorable Court, to file INSTANTER this petition for the above named Respondent-Pretrial Releasee, and that this petition be transferred instanter to call of the Honorable Judge ^ ^ 0 $ N J A L ^ A » ^ for a prompt hearing. In support thereof, the People state as follows: 1) The Defendant is presently free on bail in case number OoC-fZlO<$03^ t wherein he is charged with the felony offense of £oft\ftr]t?£. T&/A/&&4HS matter is presently pending on the trial call of the Honorable Judge £ & S t J A r ^ , U at 10 '.QOAov^ for fif&lU 2o 20jO__. 2) While free on said bail, the defendant violated a condition of bail, in that he/she on or about. 2A4JA 4 <LA X Q y i 6 - 0 , Cook County, Illinois, . A <^On^/Oi i X7&V -ak&~ 0 „,at fp&&i3~C)l>

-WA-oi, ri£ n k r QDOVL ^dj/ory Caufcr ftgftgna&s &cc>vc& mmfag-A ^&t^s.^jr
MO \k$&P Aft 0WULLC&D Sti^d- 7/0Ca£<nAT)0^> /M V/S l4?HtwO OP

>2e \i-cs

s/jw-2(a,w60,

WHEREFORE, the btate moves the Court to tile this petition and issue a warrant or set a bail thereon and transfer the iFORt, the State moves the Court to file this petition and issue a warrant or set a bail th .for a hearing. matter to Judge fi&S/UAtiAr/J on flflg|LlS) , 20 J& at /OiOOi^yy After being duly sworn, the affiant states on reasonable information and belief that the facts are true and correct. SUBSCRIBED AND SWORN TO BEFORE ME this day of , 20 ANITA ALVAREZ Cook County

Leave is granted to the State to file this petition, Bail is Judge 3&>SAJAtJAAJ .on. H^i DATE:.
WHITE GREEN YELLOW PINK GOLD

s£w^ _. This petition is here by transferred to

4-/V- ZO/o
ORIGINAL: 1 8t COPY: 2nd COPY: 3rd COPY: 4th COPY:

.ENTER:
PRELIMINARY HEARING COUR CRIMINAL DIVISION IND./INF. ASA TRIAL COURT DEFENDANT PRELIMINARY HEARING FILE

/ ??/

STATE OF ILLINIOS IN THE CIRCUIT COURT OF COOK COUNTY, CRIMINAL DIVISI PEOPLE OF THE STATE OF ILLPNOIS Maintiff, No. 08 CR 1050201 v. ANNABEL MELONGO Defendant. MOTION TO REDUCE BOND

mio,
MAY o 5 2010

ANNABEL MELONGO, by and through his attorney, ALBUKERK AND ASSOCIATES moves this Court to reduce his bail. This motion is based on the Eighth Amendment to the United States Constitution, ILCS Const. Art. 1 Sec. 9 and the following reasons: 1. ANNABEL MELONGO was arrested and charged with the offense of

Computer Tampering in May of 2006 . 2. ANNABEL MELONGO was issued an I bond because she had no

criminal record and the offense was not one that was violent. 3. ANNABEL MELONGO was arrested on or about April 20, 2010 on the

charge of Eavesdropping in that she recorded a phone conversation of a Court Reporter because that Reporter had erroneously wrote in a transcript that Ms. Melongo was present at her arraignment when she was not. If the Court Reporter had done this intentionally it would constitute a crime. 4. On the same date that the charge for Eavesdropping was announced, Ms.

Melongo was also charged with Violation of her bail bond in that the new charge of

I
Eavesdropping constituted a violation of her bond, which stated that she could not get charged with any other offenses while out on the I Bond granted in the Computer Tampering case. 5. The total bonds set in the above cases are 500,000 D and 30, 000 D bond

meaning that Ms. MELONGO must come up with $53,000 to get out of prison on a nonviolent offense where no pecuniary interests were harmed. 6. The Eighth Amendment to the United States Constitution and Article 1

Section 9 of the Illinois Constitution provide that excessive bail shall not be required. U.S. Const., Am. VIII; ILCS Const. Art. 1 Sec. 9. 7. Bail that is set at an amount higher than an amount reasonably calculated

to give adequate assurance that the accused will stand trial and submit to sentence if guilty is excessive under the Eighth Amendment. See Stack v. Boyle, 342 U.S. 1, 5, (1951). 8. Reduction of ANNABEL MELONGO's bail is appropriate because: a. ANNABEL MELONGO's ties to the community are well established and she has attended every Court date since being arrested, four years worth of Court dates. b. The new offense for which she has been charged is a Felony in only four States, meaning that few jurisdictions see Ms. Melongo's activity of recording a conversation as criminal. c. The offense of Eavesdropping is not a violent crime or one in which anyone's interests were negatively effected. In fact a full

reading of the Statute strongly implies that the only reason for the Statute is political. d. The Defendant, ANNABEL MELONGO, has no Felony criminal convictions. For the foregoing reasons, ANNABEL MELONGO respectfully requests that the Court grant her motion for bail reduction to a reasonable amount no more than a 100,000 "D" bond.

J. Nicolas Albukerk 111 E. Wacker, Suite 555 Chicago IL 60601 773 847 2600 Fax: 773 847 0330 Attorney # 37955

3

IN THE CIRCUIT COURT OF C O O K COUNTY, ILLINOIS CRIMINAL DIVISION / MUNICIPAL DEPARTMENT-DISTRICTPEOPLE OF THE STATE OF ILLINOIS vs.
HELONGO, ANNABEL K

LINE No. 16

Nn SID. IR_

08CR1050201

ADDENDUM TO PREVIOUS ORDER SETTING BAIL AND COMMITTING THE DEFENDANT TO THE COOK COUNTY DEPARTMENT OF CORRECTIONS FOR FAILURE TO DEPOSIT BAIL. ORDER THIS MATTER COMING BEFORE THE COURT AND THE COURT BEING FULLY ADVISED IN THE PREMISES, IT IS HEREBY ORDERED: , /

VvAu^

1-WU 5VJ-

hoo.(jt>i>t\.

ENTERED%[ m 0 5 21 & 00
terowstian'181,1
DISPOSITION(S) MUST REFLECT WHICH COUNT(S) T ER(S) IS/ ARE APPLICABLE TO.

ENTERED DEPUTY CLERK PAGE 1 OF J L _ PAGES DOROTHY BROWN

SNAHAN

JUDGE ROOM/BRANCH JQ2
AT9;30 A M AM / PM

No.

CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS CR-MIS707-220M-7/10/02(25291398)
COURT FILE

You're Reading a Free Preview

Download
scribd
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->