Iau e e tucks CAUSE NO. F-107)385, IN THE 29TST JUDICIAL, .. THE STATE OF TEXAS. } } iy sy vs. } DISTRICT COURT OF } nen EMILY MICHAEL ANTHONY MANOS, } DALLAS COUNTY, TEXAS MOTION TO REDUCE BOND ‘10 THE HONORABLE JUDGE OF SAID COURT: NOW COMES Michac! Anthony Manos, Defendant in the above numbered and entitled ‘cause, by and through his attomey of record, CRAIG M. PRICE, and moves the Court to reduce the amount of the bond herein, and in support of same would show the Court as follows: L Defendant has been charged with the felony offense of Fal-Stmt-Prop/CR $20K. n. Defendant has been incarcerated in the Dallas County Jail since January 20, 2011. HL Defendant's current bond is set at $50,000.00 for cach of three cases, including two state jail felonies and one third degree felony. Defendant moves this Court to lower his bond to an amount that is reasonable. According to Texas Code of Criminal Procedure Art. 17.15, the amount of bail required in a particular case is to be govemed by the Coun’s discretion and considering the Constitution and the following rules: (1) The bail shall be sui will be complied with. ently high to give reasonable assurance that the undertaking(2) The power to require bail is not to be so used as to make it an instrument of oppression (3) The nature of the offense and the circumstances under which it was committed are to be considered, (4) The ability to make bail is to be regarded, and proof may be taken upon this point. (5) The future safety of a victim of the alleged offense and the community shall be considered Defendant is an eighteen-year-old high school student who, at the time of his arrest, was enrolled at Texas Can Academy high school. He tums nineteen on October 16, 2009, and has remained incarcerated since May 30, 2009, which has precluded him from earning any money for his defense or for bail Defendant hopes to return to his high school and complete the remaining semester so that he may graduate on time. However, if he is not able to post a reasonable bond soon, he will not be able to complete the semester and will have to commence the remainder of his senior year at a later date. Defendant's family cannot afford to pay for his attorneys and the bond, as currently set, so Gavin will remain in custody unless his bond is lowered to a reasonable amount Although the factors to be considered in establishing a defendant's bond de not require the Court to address the defendant’s own safety should he be forced to remain in custody, Defendant asserts that his safety is in danger, and the Court should consider that fact when assessing the amount of Defendant's bond. Specifically, Defendant has been attacked by other inmates within the past ten (10) days, and Defendant’s safety is a very real concern for him and his family. According to his book-in sheet, Defendant is approximately 5° 6” in height and weighs approximately 145 pounds. As a result, Defendant's diminutive size makes him particularly vulnerable to other inmates, such as the selldescribed white racists who allegedly targeted Defendant for his fratemization with African American inmates. Defendant has been charged in two separate indictments for an aggravated robbery arising out of the same criminal episode: the alleged robbery of a convenience store in The Colony, Texas. Asa result, in order to post bond and obtain his release, Defendant will have to post a bond in each of the two matters against him, For these reasons, Defendant requests that a bond in the amount of $5,000.00 be set so that Defendant will have a realistic chance of posting bond in this case WHEREFORE, PREMISES CONSIDERED. Defendant prays that this honorable Court will seta bond in an amount that the defendant can post, an amount of $5,000.00 or less. Respectfully Submitted, a Cup Craig M. Pri State Bar No. 16284170 2220 San Jacinto Blvd... Ste. 220 Denton, Texas 76205 Telephone No. (940) 383-9300 Facsimile No. (940) 383-8000 Attomey for DefendantIC, OF SERVI A true and correct copy of the above and foregoing Motion to Reduce Bond has been delivered via telecopy to the Office of the Criminal District Attomey for Dallas County, Texas, in accordance with the Texas Rules of Criminal Procedure. CRAIG M. PRIGE.