MOTION TO REVOKE BOND
Defendant, L.T., by and through the undersigned attorneys and pursuant to Rule 3.131(f), Washington DC Rules of Criminal Procedure, hereby files this Motion to Revoke Bond in the above-captioned case. As grounds, Defendant states as follows:
1. On or about January 18, 2017, Defendant was arrested in the above case in connection with two charges of Grand Theft (F3).
2. On January 19, 2017, Defendant posted a surety bond in the amount of $15,003.00, and was subsequently released from custody.
3. At the time of Defendant’s arrest in this case, Defendant was on probation in County Court Case Number 16-2016-MM-XXX-AXXX-MA.
4. On February 6, 2017, the County Court judge issued a capias for Defendant’s arrest on the basis of an alleged violation of probation (VOP).
5. On March 14, 2017, Defendant turned herself in on the VOP warrant and was remanded into custody.
6. Defendant’s bond does not appear to have been revoked in the present case, and, and in the absence of a State stipulation, revocation is required for Defendant to accumulate credit for time served on the instant charges.
7. Revocation is in the interests of justice, as Defendant anticipates resolving both the VOP and the present case pursuant to a global resolution.
WHEREFORE, Defendant, L.T., respectfully requests that this Court enter an Order revoking the bond referenced herein.
[signature and certificate of service omitted]