On September 30, 2011 a
Motion-Secondary
was filed
involving a dispute between
State Of Ohio,
and
Eric Demetrus Chase,
for 30-SEP-11
in the District Court of Montgomery County.
Preview
.
(yittonara
COURT OF CORON
PLEAS
20120CT -5 PH Iz: ye
GREGORY A, BRUSH
OF COURTS
MCNTGOM ERY CO. OHIO
IN THE COMMON PLEAS COURT OF MONTGOMERY COUNTY
CRIMINAL DIVISION
State of Ohio Case No. ul CR. pe
Plaintiff, Judge Gregory Singe
-Vs- MOTION IN RESPONSE TO
REVOKE BOND
Eric D Chase
Defendant.
Now comes Defendant, Eric Chase, by and through counsel, and requests this
Honorable Court not to revoke his bond. Defense counsel filed a praecipe in this court to
have a transcript prepared at the State’s cost on August 14, 2012, which is attached
hereto. The clerk’s office informed counsel this would be sent to the court of appeals and
that nothing additional needed to be filed. Once the State filed its motions, counsel
contacted the Second District Court of Appeals to inquire as to the progress on
completing the record. That is when Counsel learned an additional motion must be filed
with the court of Appeals as well. All necessary motions and now been filed with the
Second District Court of Appeals. There will not be any further issues that could cause
the delay of the appeal.
Mr. Chase respectfully requests this honorable not revoke his bond due to the
delay being through no fault of us. Mr. Chase has been in constant contact with counsel
and he understands the appellate process is not to be abused due using it as a delay tactic.
.
Respectful subi fed,
Elizabeth ff. Scott #0076045
Attomey; t Defendant
120 W. $¢cond Street, Suite 703
Dayton. hio 45402
(937) 222-7552
(937) 222-7558 (f)
ElizabethScottesq@yahoo.com
Certificate of Service .
[hereby certify that a copy of the foregoing was served upon the prosecutor by asking
to deliver a copy to the prosecutor same date as filing.
Gf
Elizabeth C. Scot
.
COURT OF CoNMON
PLEAS
2012 AUG 14 PH 2: Gt,
GREGURY A, BRUS
CLERK OF Cou; R
MONTGOMERY
IN THE COMMON SreNe COURT OF MONTGOMERY COUNTY, OHIO
CRIMINAL DIVISION
State of Ohio Case No. 11 CR 3364
Plaintiff/Appellee Judge Gregory F Singer
-VS-
Eric D Chase PRAECIPE TO COURT
REPORTER
Defendant/Appellant.
TO THE COURT REPORTER:
Please prepare the transcript of Defendant/Appellant, Eric D Chase, of the motion to
suppress held in this matter on March 6, 2012, before Judge Gregory F Singer. This should be
done at the State’s expense due to the fact Mr. Chase is indigent, his affidavit is attached hereto.
Elizabet}WC. Scott 76045
Attol 'y for fengént
120 est treet, Suite 703
Dayt > © 45402
(937) 222-7552
(937) 222-7588 — fax
Certificate of Service
lhereby certify that a copy of the foregoing was served upon th: s office by
utor
requesting the Clerk leave a copy in the Prosecutor’s mailbox and gporter for Judge
Huffman via hand delivery on the same date as filed.
Elizabeth C. Scott
Document Filed Date
October 05, 2012
Case Filing Date
September 30, 2011
Status
913 HILE LANE, ENGLEWOOD, OH 45322
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. (yittonara COURT OF CORON PLEAS 20120CT -5 PH Iz: ye GREGORY A, BRUSH OF COURTS MCNTGOM ERY CO. OHIO IN THE COMMON PLEAS COURT OF MONTGOMERY COUNTY CRIMINAL DIVISION State of Ohio Case No. ul CR. pe Plaintiff, Judge Gregory Singe -Vs- MOTION IN RESPONSE TO REVOKE BOND Eric D Chase Defendant. Now comes Defendant, Eric Chase, by and through counsel, and requests this Honorable Court not to revoke his bond. Defense counsel filed a praecipe in this court to have a transcript prepared at the State’s cost on August 14, 2012, which is attached hereto. The clerk’s office informed counsel this would be sent to the court of appeals and that nothing additional needed to be filed. Once the State filed its motions, counsel contacted the Second District Court of Appeals to inquire as to the progress on completing the record. That is when Counsel learned an additional motion must be filed with the court of Appeals as well. All necessary motions and now been filed with the Second District Court of Appeals. There will not be any further issues that could cause the delay of the appeal. Mr. Chase respectfully requests this honorable not revoke his bond due to the delay being through no fault of us. Mr. Chase has been in constant contact with counsel and he understands the appellate process is not to be abused due using it as a delay tactic. . Respectful subi fed, Elizabeth ff. Scott #0076045 Attomey; t Defendant 120 W. $¢cond Street, Suite 703 Dayton. hio 45402 (937) 222-7552 (937) 222-7558 (f) ElizabethScottesq@yahoo.com Certificate of Service . [hereby certify that a copy of the foregoing was served upon the prosecutor by asking to deliver a copy to the prosecutor same date as filing. Gf Elizabeth C. Scot . COURT OF CoNMON PLEAS 2012 AUG 14 PH 2: Gt, GREGURY A, BRUS CLERK OF Cou; R MONTGOMERY IN THE COMMON SreNe COURT OF MONTGOMERY COUNTY, OHIO CRIMINAL DIVISION State of Ohio Case No. 11 CR 3364 Plaintiff/Appellee Judge Gregory F Singer -VS- Eric D Chase PRAECIPE TO COURT REPORTER Defendant/Appellant. TO THE COURT REPORTER: Please prepare the transcript of Defendant/Appellant, Eric D Chase, of the motion to suppress held in this matter on March 6, 2012, before Judge Gregory F Singer. This should be done at the State’s expense due to the fact Mr. Chase is indigent, his affidavit is attached hereto. Elizabet}WC. Scott 76045 Attol 'y for fengént 120 est treet, Suite 703 Dayt > © 45402 (937) 222-7552 (937) 222-7588 — fax Certificate of Service lhereby certify that a copy of the foregoing was served upon th: s office by utor requesting the Clerk leave a copy in the Prosecutor’s mailbox and gporter for Judge Huffman via hand delivery on the same date as filed. Elizabeth C. Scott