STATE OF MARYLAND + INTHE E
vs. . DISTRICT COURT
JAN LT AL O02
PHILLIP WEST * FOR
CASENO: 0n02386602 . BALTIMORE CITY (i
‘STATE'S MOTION TO REVOKE BAIL.
[Now comes the State of Maryland, by Marilyn J, Mosby, State's Attorney for Baltimore
City, and Traci Robinson, Assistant State's Attorney for Baltimore City, seeking to have the
Defendant's bail be revoked pursuant to Maryland Rule 4-216.3 pending the outcome of his trial
and submits the following in support ofthis application:
1. On January 14,2019, Phillip West (hereafter the Defendant) tured himself'in and was
arested and charged under 0362386692 with the First Degree Murder of Rodney
‘Beamon and related firearms offenses stemming from a homicide that occurred inside the
Blamey Stone Pub located at 704 South Broadway Street in Baltimore, Maryland on
December 21, 2018, The Defendant was initially held without Bail
2, On4anuary 16,2019, the Defendant was preset for his intial Bail Review in the
Baltimore City District. He was represented by attomey Kenneth Ravenell. The Matter
‘was heard infront ofthe Honorable Michac! Studdard.
3. On January 16,2019, Judge Studdard changed the Defendant's No Bail status and set @
‘ail amount of $100,000 and ordered if released the Defendant mus stay atthe home of
his mother under private ASAP Home Monitoring and he would not be allowed to leave
hishome,
4, The case is currently scheduled fora preliminary hearing on February 14, 2019,
5. Pursuant to Maryland rule 4-216-3 the State seeks an amendment ofthe pretrial release
‘order and revocation of bil.
‘6. In support ofthis motion the State argues that Judge Studdard didnot adequately address
the requirements under Maryland Rule 4-216.) in asessing the Defendants tsk to public
safety.
7. The State contends thatthe Defendant is a risk to public safety based onthe facts ofthe
‘ase, On December 21, 2018, the Defendant and victim were inside the Blemey Stone
Pub with numerous other patrons. After briefly exiting the pub both men retum and an
argument ensued. The Defendant pulled out a handgun and sho the victim multiple
t‘times. As the Defendant was leaving a witness heard im say that he would not be
Aisiespecied. The Defendant then fed the area.
8. “The Defendant was convicted in the US, District Court for Naryland for Conspiracy to
Distribute and Possess with Intent to Distribute Narcotics. He received nine year
sentence. The result ofthis conviction prohibits his possession of «handgun. Yet, the
Defendant on December 21, 2018 was in possession ofa henigun.
9. The State believes these factors weight heavily in considering the Defendants risk to
public safety.
10. The Court outlined the Defendants flight isk, prior eiminal history, and nature of
evidence and nature of charges but did not address the Defendant's risk to pubic safety."
However the State respectfilly disagrees withthe determination ofthe Court thatthe
‘Defendant is not alight risk. While it is true the Defendant tamed himself'in that was
‘done nearly a month fier he murdered Rodney Beamon.
5. Barter, the evidence is this ease is overwhelming. Witnesses observed the Defendant
pubficly execute Rodney Beamon, The Defendant was identified ina photo array(s) and
there is surveillance video which shows the Defendant at the aub along with the victim.
Further, the Defendant is facing a Life sentence upon convicton for First Degree Murder.
He is every reason to fee to avoid prosecution.
WHEREFORE, the State respectfully requests thatthe Defendant's bail be revoked in this matter
and no bail status be set immediately.
‘Respecflly Submited,
‘Marilyn J. Mosby
Sines atiomey or Balinore City
/ 4”
‘Trl. Robinson
Assistant State's Attorney
Homicide Unit
120 Bast Baltimore Sree, 9th Floor
Baltimore, MD 21202
(443) 98446032
‘TRobinson@StAtomev.ory
"fudge Star ound a thea High sk weighed athe Defendants favor while his previous criminal
story, th enze of ti evizoce apn the Defendant and ie paue of charges fled weighted opin te
Defendant
2RTTEICATI
ER
THEREBY CERTIFY that on this 17° day of January, 2019, a copy ofthe foregoing
State's Motion to Revoke Bail was mailed to counsel for the Defendant
Kenneth Ravenell
‘TU St.Paul Steet
Baltimore, MD 21202
Respectfilly Submited,
Matityn J. Mosby
States for Baltimore City
ahr:
Tra LR
‘Assistant States Attorney
Homicide Unit
120 East Baltimore Street, 9th Floor
Baltimore, MD 21202
(443) 984-6032
‘TRobinson@istAttomey.orz