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.
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. FILED
COURT OF COMMGN PLEAS
20120CT -5 PM jo: 46
GREGORY A, BRusH
CLERK OF Coy
MONTGOMERY 20° bo
IN THE COMMON PLEAS COURT OF MONTGOMERY COUNTY
CRIMINAL DIVISION
State of Ohio . : Case No. 11 CR
Plaintiff, : Judge Greg
_ cVS- : 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 praccipe 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.Respectfully submpitted,
Elizabeth ff. Scott #0076045
Attorney/for Defendant
120 W. $gcond Street, Suite 703
Dayton{Mhio 45402
(937) 282-7552
(937) 222-7558 (f)
ElizabethScottesq@yahoo.com
Certificate of Service *
I 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.
Elizabeth C. Scoti F Eo
COURT OF COMMON PLEAS
MI2AUG 14 PH 2:44
IN THE COMMXIN TEMG 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
Defendant/Appellant. REPORTER
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.
Non
[Sy
>
(937) 222-7552
(937) 222-7588 - fax
Certificate of Service
I hereby certify that a copy of the foregoing was served upon th: utor’s office by
requesting the Clerk leave a copy in the Prosecutor’s mailbox and thé Court Rgporter for Judge
Huffman via hand delivery on the same date as filed.
>.
Elizabg C. Scot
Document Filed Date
October 05, 2012
Case Filing Date
September 30, 2011
Status
913 HILE LANE, ENGLEWOOD, OH 45322
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. FILED COURT OF COMMGN PLEAS 20120CT -5 PM jo: 46 GREGORY A, BRusH CLERK OF Coy MONTGOMERY 20° bo IN THE COMMON PLEAS COURT OF MONTGOMERY COUNTY CRIMINAL DIVISION State of Ohio . : Case No. 11 CR Plaintiff, : Judge Greg _ cVS- : 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 praccipe 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.Respectfully submpitted, Elizabeth ff. Scott #0076045 Attorney/for Defendant 120 W. $gcond Street, Suite 703 Dayton{Mhio 45402 (937) 282-7552 (937) 222-7558 (f) ElizabethScottesq@yahoo.com Certificate of Service * I 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. Elizabeth C. Scoti F Eo COURT OF COMMON PLEAS MI2AUG 14 PH 2:44 IN THE COMMXIN TEMG 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 Defendant/Appellant. REPORTER 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. Non [Sy > (937) 222-7552 (937) 222-7588 - fax Certificate of Service I hereby certify that a copy of the foregoing was served upon th: utor’s office by requesting the Clerk leave a copy in the Prosecutor’s mailbox and thé Court Rgporter for Judge Huffman via hand delivery on the same date as filed. >. Elizabg C. Scot