.....

J-

SUPERIOR COURT of! tAWoru1JA COUNTY OF LOS ANOllLN8 .
1

h'fI.JiB

2
3 4 5

STEVE COOLEY DISTRICT ATTORNEY DAVID WALGREN DEPUTY DISTRICT ATTORNEY 210 W. TEMPLE STREET, 17th FLOOR LOS ANGELES, CA 90012 (213) 974-3992

FEa 0 8 ~UlO
JOM A, el!w~!! :II:~~utii't! OM08fIClerk ~
By ~ ~ .Deputy

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES

6 7 8
9

PEOPLE OF THE STATE OF CALIFORNIA, Plaintiff, vs. Conrad Murray, Defendant.

Case No: SA073164 PEOPLE'S MOTION IN SUPPORT OF BAIL DEVIATION

10
11 12 13 14 15 16

The People hereby request that this Court deviate from the presumptive bail of $25,000 and set bail at the amountof$3@O,OOO ..

17
18 19

INTRODUCTION Defendant is charged with one count of Involuntary Manslaughter in violation of Penal Code section 192(b). This charge is premised on the alleged facts that Conrad Murray acted

20
21 22

with gross n~gJigenceinhis "care" of Michael Jackson. More specifically, this charge is
premised on the alleged fact that Conrad Murray directly caused the death of Michael Jackson by administering Propofol and other narcotics that directly caused the victim's death.

23 24 25

--

-_._---_._-_

..... _._-------

POINTS AND AUTHORITIES 2 3
4 5

Penal Code section 1275 directs the court to consider the following factors in setting, reducing or denying bail: the protection of the public, the seriousness of the offense, the previousrecord6f the defendant, and the probability of the defendant's appearing at trial or

hearing of the case. Thus, the court may set bail in an amount in deviation of the presumptive bail schedule when circumstances warrant such a deviation. The presumptive bail for the. crime of Involuntary Manslaughter is $25,000. Due to the

6 7 8 9 10 11 12
13

unique circumstances of this case, as outlined in the attached declaration by counsel, the People respectfully request that the court deviate from the bail schedule and set bail in the ammJl1Itof$'300,OOO so as to ensure the defendant's presence at all future court appearances.

Respectfully submitted,

14 15 16 By:
17

STEVE COOLEY DISTRICT ATTORNEY

18 19 20 21
22 23 24

David Walgren Deputy District AU rney

25

2

Declaration of Counsel
2

I, David Walgren, declare as follows: 1. I am the Deputy District Attorney assigned to handle the case of People v. Conrad As such, I am familiar with the details surrounding the

3 4
5

Murray, case number SA073164.

investigation into the death of Michael Jackson. 2. I am informed and believe that it is appropriate to deviate from the scheduled bail

6
7

schedule so as to ensure the defendant's appearance at all future court hearings. This belief is based on the below listed facts.

8

9
10
11

3.

I am informed and believe that Conrad Murraywas born In Grenada and that he may still

hav,efamily ties to that country.

4.

I am informed and believe that Conrad Murray has family ties to Trinidad, where Conrad

12
13 14 15 16 17

Murray'fol:aiOlsa child;" I am further informed and beheve Conrad Murray has traveled out of the country in recent years. These travels have included a trip to Trinidad.

5.

I am informed and believe that Conrad Murray has previously violated valid court orders

related to Conrad Murray's obligation to provide child support payments.

6.

I am informed and believe that in multiple licensing applications, completed under
misstated-his date of birth, onlytc correct it months later. Nevada, but also

penalty of perjury, QPfll18Jj Murraynas

18 19 20
21

7.

I am informed and believe that Conrad Murray resldesin-Las-Vsgas,

dweUsjn Houston, Texas,

and Santa Monica, California.

8.

I am informed and believe that Conrad Murray has previously been threatened with the

issuance of a court authorized bench warrant based on his failure to abide by court mandated child support obligations in-Las Vegas, Nevada.

22
23

9.

I am informed and believe that as recently as last week a default judgment was entered

24 25

against Conrad Murray as a result of his failure to appear in court in a pending civil lawsuit.

3

....

10. 2 3
4 5

I am informed and believe that Conrad Murray has repeatedly defaulted on his financial of liens, lawsuits, and evictions due to his failure to take

obligations and has been thesqbject responsibility for his financial actions. 11.

I am informed and believe that Conrad Murray faces a prison sentence of four years in

state prison if convicted of the count of Involuntary Manslaughter. 12. The presumptive bail for one count of Penal Code-section 192{b),lnvoluntary

6 7 8 9 10 11
12 13

Manslaughter, is $25,500. 13. The presumptive bail amount is insufficient due to the aforementioned facts and namely that the defendant leads an irresponsible and financially unstable life, ties both to that country and Trinidad, bench warrant,thedefendant

circumstances,

the defendant was born in a foreign\COl;lntfyandm~lintains

the defendant has previo.usly.beenthreatenedwithacourt.:issued has previously violated courtQr~,~f~J@ndJhedefendant defaults, and evictions due to his!JQwiUimgnesstoaccept ·14.

has been the subject of multiple liens, responsibility for his actions.

14
15

To ensure the defendant will make all future court appearances, the People respectfully

request that bail be set in the amountof·$30f);.()OO~ Additionally, the People request the immediate surrender of the defendtitllfspassportamf travel restrictions sh~!;Jldthedefendant request thatthecourt impose appropriate

16 17 18 19 20 21 22 23 24 25

be discharged upon bail.

4

I swear under penalty of perjury under the laws of the State of California that the foregoing is 2 3 4
5 6

true and correct to the best of my knowledge.

Executed on this 8th day of February, 2010, at Los Angeles, California,

7 8
9 10 11 12 13 14

15 16 17 18 19 20
21

22 23
24

25

5

Sign up to vote on this title
UsefulNot useful