STATE OF LOUISIANA

CRIMINAL DISTRICT COURT

VERSUS

PARISH OF ORLEANS

JOHNQUELL BIBBINS

CASE NO. 523-972 “F”

MOTION AND ORDER FOR MATERIAL WITNESS BOND
NOW INTO COURT, through the undersigned Assistant District Attorney for the Parish
of Orleans, comes the State of Louisiana, who respectfully requests that an Order be issued
placing under bond one, KEITH MCGUIRE (hereinafter referred to as “MCGUIRE”),
D.O.B. 9/11/56, 708 PARKWAY AVENUE, NEW ORLEANS, LA, 70121 as a material
witness in the above captioned case. This order is requested for the following reasons:
I.
The testimony of MCGUIRE is essential to the prosecution of the above entitled case.
He is the named victim of the charge of second degree battery.
II.
The State has reason to fear MCGUIRE will not appear in Court pursuant to a subpoena
as he has failed to at the District Attorney’s Office pursuant to subpoena on Friday, March 03,
2017. (See State’s Exhibit 1, a copy of the subpoena).
III.
On March 3, 2017, MCGUIRE contacted Investigator Corey Porter and indicated that he
was refusing to meet with the undersigned ADA and would never come to court on the case.
MCGUIRE indicated that he has been in prison three times prior, and does not care if he is
arrested. MCGUIRE indicated that the State would need to arrest him if need be, but he would
not come to court willingly. The State recorded MCGUIRE on this phone call and can provide
a copy of the recording to the court if needed.
IV.
On March 6, 2017, MCGUIRE failed to appear in Section F of Criminal District Court
pursuant to a subpoena that he signed for. (See State’s Exhibit 2, a copy of the subpoena).
V.
The conduct of MCGUIRE is a reasonable basis for the undersigned to attest that
KEITH MCGUIRE will not honor a subpoena and appear for trial.
VI.
The State recommends that bail be set in the amount of One Hundred Thousand Dollard
($100,000.00) to insure the appearance of the witness on the scheduled date of trial.
WHEREFORE, the State of Louisiana prays that a capias be issued in accordance with
Louisiana Revised Statute 15:257, commanding the arrest of MCGUIRE as a material witness

 in this case, and alternatively, that bail be fixed in the amount of One Hundred Thousand
Dollars ($100,000.00).

Respectfully submitted,
___________________________
Assistant District Attorney

O R D E R

IT IS HEREBY ORDERED BY THE COURT, that a capias be issued for the arrest of
KEITH MCGUIRE (black male, DOB: 9/11/56), residing at, 708 Parkway Avenue, New
Orleans, LA , as a material witness and that bail be fixed in the amount of $ _____________.

NEW ORLEANS, LOUISIANA, this the ___ day of ________________, 20_____.

___________________________
Judge Robin D. Pittman
Criminal District Court
Parish of Orleans

 AFFIDAVIT
STATE OF LOUISIANA
PARISH OF ORLEANS
BEFORE ME, the undersigned authority, appeared Assistant District Attorney Tiffany
Tucker, to me personally known, who, after being duly sworn, did depose and say:
1. That she is an Assistant District Attorney for the Parish of Orleans;
2. That she has reviewed the foregoing motion thereto and that the allegations contained
therein are truthful.

SWORN TO AND SUBSCRIBED
BEFORE ME, THIS THE _____
DAY OF

, 20

.

___________________________
NOTARY PUBLIC