Case 2:11-cr-02294-RB Document 402

Filed 01/29/13 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO UNITED STATES OF AMERICA, Plaintiff, vs. ) ) ) ) ) ) ) ) ) ) )

CRIMINAL NO. 11-CR-2294 RB

RICK REESE and RYIN REESE, Defendants.

UNITED STATES= SECOND SUPPLEMENT TO RESPONSE TO DEFENDANTS MOTION FOR RELEASE ON CONITIONS PENDING SENTENCING (DOC. 383) The United States hereby supplements its release on conditions pending sentencing response, (Doc. 383), with the attached Affidavit of Special Agent Jose Ramon Martinez. In the affidavit, Agent Martinez details portions of recent jail recordings in which Defendants Rick and Ryin Reese express their views about persons involved in their prosecution and certain members of law enforcement. These statements are relevant to the motion for release on conditions pending sentencing because they highlight that the Defendants release still pose a danger to the community. The statements also show the Defendants are not likely to follow any Court

imposed orders or conditions. Respectfully submitted, KENNETH J. GONZALES United States Attorney Electronically Filed 01/29/2013 MARIA Y. ARMIJO Assistant United States Attorneys 555 S. Telshor Blvd., Ste. 300 Las Cruces, NM 88011 (575) 522-2304

Case 2:11-cr-02294-RB Document 402

Filed 01/29/13 Page 2 of 2

I HEREBY CERTIFY that I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send electronic notification to defense counsel of record on this date. /s/ MARIA Y. ARMIJO Assistant United States Attorney

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