Free Motion for Reconsideration - District Court of Connecticut - Connecticut

Case 3:03-cr-00222-PCD

Document 63

Filed 08/10/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA v. WILLIAM KING

: : : Crim. No. 3:03CR222(PCD) August 10, 2005

GOVERNMENT'S MOTION TO RECONSIDER RULING ON DEFENDANT'S MOTION TO EXONERATE BOND The United States of America, by and through the undersigned Assistant United States Attorney, hereby requests that the Court reconsider its ruling granting the defendant's motion to exonerate the bond in this case. In support of this motion the government states as follows: 1. Shortly after the defendant filed a motion to exonerate the bond, the undersigned counsel contacted defense counsel to seek clarification on the source of the $1,000 posted as security on the defendant's bond. It had always been the government's understanding that this sum was posted by the defendant's father, also known as William King. Defense counsel believed that the money was posted by the

defendant, but indicated he would confirm that point. The undersigned counsel explained to defense counsel that the government would likely not object to returning these funds to the defendant's father, if he indeed post the bond; however, to the extent the funds were posted by the defendant, then the government objected to the request and indicated that it would seek forfeiture of the bond based upon the defendant's repeated violations of his conditions of release.

Case 3:03-cr-00222-PCD

Document 63

Filed 08/10/2005

Page 2 of 3

2.

This morning, August 10, 2005, the government received an electronic notification that the Court granted the defendant's motion and ordered that the $1,000 be returned to the defendant. Plainly, the Court entered this order without knowing that there existed unresolved issues on this matter.

3.

The government urges the Court to vacate its order and to permit the parties to determine which William King posted the monies. To the extent, the monies were posted by the defendant, the government will seek forfeiture of those funds based upon the defendant's repeated bond violations and general contempt for the entire judicial system. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY /s/ MARK D. RUBINO ASSISTANT UNITED STATES ATTORNEY 157 Church Street New Haven, Connecticut 06510 Tel. (203) 821-3732 Federal Bar No. CT03496

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Case 3:03-cr-00222-PCD

Document 63

Filed 08/10/2005

Page 3 of 3

CERTIFICATION OF SERVICE This is to certify that the foregoing has been sent via fax and U.S. mail this 10th day of August 2005, to:

Tom Belsky, AFPD 2 Whitney Avenue, Suite 300 New Haven, CT 06510

/s/ MARK D. RUBINO ASSISTANT UNITED STATES ATTORNEY

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