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A22M-CR12-0146066-5 STATE OF CONNECTICUT
GEOGRAPHICAL AREA#22 AT MILFORD JUNE 20,2012
MOTION TO INCREASE BOND
The State respectfully requests this Court increase the bond in the abovecaptioned matter Pursuant to Connecticut Practice Book Section 38-19 et seq. for the following reasons:
Defendant was arrested in the Town of Shelton and was charged with lllegal
possession of a Narcotic Substance,.lllegal Possession of a Prescription Not in a Container, Use and Possession of Drug Paraphernalia, and two counts of lllegal
g,2011, prior to a Possession of a Controlled Substance. The facts allege that on May 1
pre-termination hearing regarding Defendant's employment with the Shelton Police Department, Police personnelwere assigned to clean out and inventory a locker
assigned to Defendant. Personnelfound inside said Iocker (8) "Vicoden ES" pills in a clear unlabeled plastic bag, a glass vial tabeled "testosterone 50", two syringes filled
with liquid, and a crushed glass vial. Each item was tested at the Connecticut
Department of Public Safety Scientific Services Laboratory and yielded the following results: The eight pills are Hydrocodone (schedule Ill controlled substance); The broken glass vial contained residue of Testosterone Propionate (Schedule !!! controlled
substance) and Testosterone lsocaproate (Schedule lll controlled substance); The
syringes contained Testosterone Propionate (Schedule lll controlled substance) and
Testosterone, Testosterone lsocaproate, Testosterone Decanoate and Testosterone Phenylpropionate (all Schedule lll controlled substances).
Defendant was ordered to participate with AIC by her Honor, Keegan,
defendant's first report dated May
,2012 indicates the following:
1. 2. 3. 4. 5. 6.
During his appointment for scheduled assessments on April 26, defendant stated he would not submit to random urine specimens at AIC or participate in any AIC services. On April 26, the defendant failed to render a urine specimen. Defendant attended a second appointment for scheduled assessments and reported as scheduled. Defendant failed to attend his scheduled feedback on May 8. Defendant attended a rescheduted appointment for feedback on May 10. He was referred to the Reasoning and Rehabilitation class and was scheduled to begin on May 30. Defendant informed the AIC representative, again, that he was unwilling to render random urine specimens at AIC.
The State filed a Motion to tncrease Bond May 14,2012. As the result of pre-trial discussions with the Court, Ronan, J., the defendant was permitted to submit to
urinalysis at Quest Diagnostics. This was the only modification of defendant's condition
that he participate with AlC. The Motion to lncrease Bond was not pursued in tight of the Court's modification of said condition.
On June 4,2012, defendant's AIC report indicated defendant failed to attend AIC
because he had a dentist appointment. After further discussion'with counset, the
defendant's job, daughter's graduation, and graduation party interfered with his ability to
attend his AIC appointments. The most current AIC reportl indicates the following:
Dated 6/20/12, received by this prosecutor on 612l/12, and faxed to Counsel of record 6/21/12 upon receipt of said See attached copy.
Since Defendant's last court date defendant has been in NONCOMPLIANCE with AlC. 2. Defendant was removed from Reasoning and Rehabilitation due to lack of attendance on June 6. 3. Defendant failed to attend mse management on June 7 because he had to bring his daughter to college orientation. 4. AIC left a voicemailfor defendant on June 11 directing defendant to contact her. Defendant called the writer back on June 13 and informed her he was NOT willing to comply with AIC rules and regulations. The writer offered defendant 1X1 individual sessions of Reasoning and Rehabilitation which he declined. 5. Defendant failed to report for case management on June 19.
It is the State's position that the Defendant is in violation of the Court Order that defendant participate with AIC. He was accommodated in that he was able to render urines with an outside agency. He was not excused from case management and has
made it abundantly clear he has better things to do. Defendant was unwilling to participate in individual counseling sessions which was yet another attempt to accommodate Mr. Casertano.
WHEREFORE, the State asks this Court to increase the bond in the Defendant's matter in light of his willful failure to comply with the Court-ordered condition "participate
Assistant State's Attorney