ELECTRONICALLY FILED 4/13/2012 11:18 AM CC-2011-002417.00 CIRCUIT COURT OF MADISON COUNTY, ALABAMA JANE C.

SMITH, CLERK

IN THE CIRCUIT COURT OF MADISON COUNTY, ALABAMA STATE OF ALABAMA, PLAINTIFF,

VS.
HAMMAD MEMON, DEFENDANT.

CASE NO: CC11 – 2417 KKH

MOTION TO REVOKE BOND Comes now the State of Alabama, by and through its Assistant District Attorney, Tim Gann, and requests that this Honorable Court revoke Defendant’s b d and for cause would show unto this Honorable Court the following: (1) Defendant, HAMMAD MEMON, is charged with MURDER. (2) The Defendant was released on a $75,000.00 bond with special conditions because he was a 14 year old and a citizen of Pakistan. (3) One of the special conditions of the Defendant’s bond was that he surrenders his passport and not be allowed to leave the United States. (4) On 4-11-12 Express Mail delivered a package to Hammad Memon care of his mother Safia Memon. The package was sent from the Embassy of Pakistan. (5) The package appeared to contain a passport according to the Express Mail carrier and the Defendant signed for the package. (6) The Defendant is a Pakistani citizen and could apply for a Pakistani passport. There would be no way for local authorities to be notified. (7) Hammad Memon is an extreme flight risk because he is facing a possible life sentence and a citizen of Pakistan. (8) Hammad Memon is a danger to the public based upon the serious nature of the crime that he is charged with.

WHEREFORE, the State respectfully requests that Defendant’s bond be revoked and the Defendant be held in custody until such date as a hearing can be scheduled and these matters be heard in front of this Honorable Court.

RESPECTFULLY SUBMITTED this the 13th day of April, 2012 .
ROBERT L. BROUSSARD DISTRICT ATTORNEY BY: s/Timothy R. Gann Timothy R. Gann (GAN-016) Assistant District Attorney Madison County District Attorney’s Office 100 North Side Square Huntsville, Alabama 35801 Telephone: (256)327.3886 Fax: (256)327.3857

CERTIFICATE OF SERVICE

I hereby certify that I electronically filed the foregoing with the Clerk of the Madison County District Court which will send notification of such filing to the following, Bruce Gardner, Attorney for the Defendant on this the 13th day of April, 2012 .
s/Timothy R. Gann Timothy R. Gann (GAN-016) Assistant District Attorney

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