Professional Documents
Culture Documents
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IN THE
APPELLATE COURT OF THE STATE OF ILLINOIS
THIRD JUDICIAL DISTRICT
DREW PETERSON,
) Honorable Stephen D. White
Defendant-Appellee. ) Judge Presiding
REBBLEni RELEASE
tR
NOW COMES the Defendant Drew Peterson, by all counsel of record, and renews
Supreme Court Rule 604(a)(3). People it Beaty, 351 111App.3d 717 (2004) and
2. The Defendant's trial in the underlying case was set to begin on July 8, 2010.
However, on July 7, 2010 the State filed the instant appeal, which suspended
the Defendant's statutory right to a speedy trial. (Sup. Crt. Rule 604(a)(3))
4. The Defendant has now been denied his constitutional and statutory rights to
6. The Defendant does not wish to hurry this court in making its decision, and
wants the Justices to take all the time necessary for them to make their
speedy trial and incarcerated at the same time while this appeal is pending.
7. This court is in a better position to order the Defendants release now that it
interlocutory appeal.)
freedom lost when the prosecution was commenced" Wells, id. "604(a)(3)
favors release. Its paramount aim is to guarantee protection from the power
granted the State under Supreme Court Rule 604(a)(1)." Wells, id. "A
10. There is nothing to suggest that Drew Peterson would be a danger to anyone
if released. Regardless of whatever the general perception may be, or any gut
feelings regarding his past activities may be, the fact remains that he was a
11. At best there has never been more than a mere finding of probable cause that
he committed any criminal act This is, at this point, a case without any
physical evidence tying the Defendant to any crime, (if in fact any crime was
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committed - a matter of contention), and without any confession. It is
12. Defendant Drew Peterson is 56 years old and is a life long resident of Illinois.
Will County, Illinois since 1977, and before that lived in Lombard, Illinois.
13. A military veteran, having served in the United States Army from 1974 to
1976, Drew was based in Washington D.C., and served in the Military Police
unit out of Arlington, VA. Part of his duties was to provide security for
Peterson provided security for President Gerald Ford. Mr. Peterson was
14. Since 1977, Drew has lived in Bolingbrook, Will County, Illinois. His current
15. Drew has extensive family contacts in the Will County, and Northern, Illinois
16. Drew's six (6) children, (1) grandchild, and four (4) nieces and nephews, all
live in Northern, Illinois. There are Lacy, age 5, Anthony, age 6, Kristopher,
age 16, and Thomas, age 18 who live at his Bolingbrook address. Then there
is his son Stephen Peterson, age 30, who lives in Oak Brook, Illinois, with his
wife and child (who is Defendant Peterson's grandchild). Drew's oldest son,
Eric, is 31. Drew's mother, Betty, is 86 years old and lives in Westmont,
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Illinois. His sister Laura, lives in Naperville, Illinois, and his brother, Paul,
lives in Montgomery, Illinois, with his wife and four (4) children (the
17. Drew owns real estate, a single-family residence at 6 Pheasant Chase Court,
Bolingbrook, Will County, Illinois. The residence is paid for, and is not the
owed. Drew does not own any other real estate. Drew has owned homes in
18. Drew is currently retired, and his only source of income is his pension from
19. Drew worked in Will County, Illinois since 1977 as a law enforcement officer.
Sergeant in 1997. He was police officer of the year in 1979, and received
Further, in the 1980's, for a five (5) year period, Mr. Peterson was assigned to
the Metropolitan Area Narcotics Squad (MANS), where he put his life on the
received a department commendation for his drug arrests. Also during this
undercover operations.
20. As shown above, Drew is not a flight risk He was the publicly announced
subject of an investigation into the death of Kathleen Savio, the alleged victim
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in the above-referenced indictment, for eighteen (18) months. Drew, and
most of the public, knew that the Will County State's Attorney's office
expected to bring charges. During this period, Drew traveled to Los Angeles,
California (approximately 100 miles from Mexico), New York, which borders
with Canada, and Florida (from which several Caribbean, and Central
21. Drew is a U.S. Citizen, and is not a citizen of any other country. His U.S.
Passport is in the custody of the Illinois State Police, having been taken when
he was arrested. He does not want it back until after this case is resolved.
WHEREFORE, for all of the foregoing reasons, Defendant requests that this Court
grant his for Motion to Release, and for such further and other relief as this Court deem
just.
Respectfully submitted,
Drew Peterson, Defe dant
By:
e of His Attorneys
AFFIDAVIT
I, Joel A. Brodsky, certify under penalties of perjury that the statements set forth in
the foregoing Renewed Motion For Release, are true and correct ex ept as to matter
therein stated to be on information and belief and as to such m s the unders ed
certifies as aforesaid that he verily believes the same to true.
.Aaj •
aelri
eA. Brodsky Plir
Signed and Sworn to before me
this day of June 3, 2011
"OFFICIAL SEAL* I
Notary Public Lae P Paws
smetare dans.
IMI7/11012
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Steven A. Greenberg Joel A. Brodsky
Steven A. Greenberg, Ltd. Attorney for Defendant Appellee
Attorneys for Defendant-Appellee 8S. Michigan Avenue, Suite 3200
820W. Jackson, Suite 310 Chicago, Illinois 60603
Chicago, Illinois 60607 (312) 541-7000
(312) 879-9500
Joseph R. Lopez Ralph Meczyk
Lisa Lopez Darryl Goldberg
Attorneys for Defendant-Appellee Attorneys for Defendant-Appellee
53 W. Jackson Boulevard, Suite 1122 111 W. Washington Street, Suite 1025
Chicago, Illinois 60603 Chicago, Illinois 60602
(312) 922-2001 (312) 332-2853
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