STATE OF LOUISIANA CRIMINAL DISTRICT COURT VERSUS PARISH OF ORLEANS CASE OPPOSITION TO MOTION TO LIFT PROBATION HOLD 0R SET PROBATION BOND NOW INTO COURT, through the undersigned Assistant District Attorney, comes the State of Louisiana, and respectfully requests that this Honorable Court deny the defendant?s motion to reduce bond, based upon the following jurisprudence and argument: I. FACTS AND PROCEDURAL HISTORY The defendant is charged with Theft Under $1000. The defendant is on probation in Section I for case number 545-399 where he plead guilty to Possession with the Intent to Distribute Heroin. During that case, he failed to appear twice. While on probation, the defendant was arrested for new charges represented in the instant case. On January 8, 2019 Agent?Filed a Motion to Revoke the Defendant?s probation. On March 16, 2020, the defendant ?led a motion to reduce bond, citing the recent outbreak of COVID-19, also known as the Coronavirus. The State?s opposition follows. 11. LAW AND ARGUMENT The defendant has failed to provide any medical documentation in support of his argument that he will be at risk of contracting Coronavirus in the Orleans Justice Center. For the reasons set forth below, the defendant?s motion to reduce bond should be denied. 1. The defendant has failed to show that the Orleans Justice Center is not adequately equipped to handle the Coronavirus outbreak, nor has be shown that he will be medically at risk of contracting the Coronavirus if he remains incarcerated. The defendant has ?led a boilerplate motion arguing that his bond should be reduced due to the Coronavirus outbreak. However, he has failed to provide any speci?c facts in support of this argument. The defendant has failed to show that the Orleans Justice Center is not taking all necessary precautions to prevent the spread of Coronavirus to its inmates. Moreover, the defendant has not provided any medical documentation that shows that he is immunocompromised or otherwise has an increased susceptibility to contracting the Coronavirus. The defendant?s bond has previously been set after consideration of a large number of factors, including the facts of his case, the seriousness of the offense, his prior criminal record, potential danger to the community and ?ight risk, community and family ties, his employment history, and any other relevant facts. The State submits that his bond is reasonable based upon the above factors. Without making the above two showings, that a medical reason exists which makes him more susceptible to catching the Coronavirus and that the Orleans Justice Center cannot control the spread of the Coronavirus, the defendant failed to show cause to lift the probation hold. If the defendant is able to produce medical documentation in support of his claim, the State is entitled to present evidence or testimony regarding the measures that the Orleans Justice Center is taking to prevent the spread of the Coronavirus into and within jail facilities. II. The defendant poses a threat to the community if he is released. Pursuant to La. the trial court may consider ?the nature and seriousness of the danger to any other person or to the community that would be posed by the defendant?s release? when setting a defendant?s bond. The defendant has failed to show that, if released on bond, he will have a residence to stay in while the city battles the Coronavirus outbreak. Nor has he demonstrated that he will adhere to any curfews and other safety measures set in place by city of?cials. If the defendant is released on bond during the Coronavirus outbreak and goes into public places, it will pose a threat to the general public by potentially spreading the virus to others and increasing the rate at which others are exposed to the virus. IV. The defendant would pose a ?ight risk if released on bond. Pursuant to La. Art. 316(9), the trial court may consider ?any other circumstances affecting the probability of defendant's appearance? when setting a defendant?s bond. Agent ?indicated that Probation and Parole will object to the defendant?s release. The defendant never reported to Probation and Parole and has been arrested three times since beginning probation. As such, the defendant presents a ?ight risk if released on bond. CONCLUSION AND PRAYER WHEREFORE, the State of Louisiana prays that the defendant?s motion to reduce bond be denied. The defendant has failed to produce any evidence in support of his claim that he is at risk of contracting the Coronavirus if he is not released on bond, nor has he shown that the Orleans Justice Center is not adequately equipped to protect against the Spread of the virus within its facilities. Without making these two particularized showings, the defendant?s motion should be denied. Respectfully submitted, ak?ow Assistant District Attorney, Orleans Parish District Attorney?s Of?ce CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing ?ling has been served upon defense counsel, by hand, e-mail, facsimile, and/or United States Postal service this the day of WW 2020. Assistant District Attorney STATE OF LOUISIANA CRIMINAL DISTRICT COURT VERSUS PARISH OF ORLEANS CASE OPPOSITION TO MOTION FOR BOND REDUCTION NOW INTO COURT, through the undersigned Assistant District Attorney, comes the State of Louisiana, and respectfully requests that this Honorable Court deny the defendant?s motion to reduce bond, based upon the following jurisprudence and argument: I. FACTS AND PROCEDURAL HISTORY The defendant is charged with RS 14:62.2 relative to Carjacking. On September 17, 2019 the defendant was found incompetent. On February 27, 202 the State received an evaluation indicating the defendant has been restored to competency. However the defendant has yet to be deemed competent by the courts. On March 16, 2020 the defendant ?led a motion to reduce bond, citing the recent outbreak of COVID-19, also known as the Coronavirus. The State?s opposition follows. II. LAW AND ARGUMENT The defendant has failed to show cause why hiss bond should be reduced. The State submits that the defendant?s bond, currently set at $25,000, is appropriate based upon the factors set forth by La. Art. 316. which have been previously considered in setting his bond. Furthermore, the defendant has failed to provide any medical documentation in support of his argument that he will be at risk of contracting Coronavirus in the Orleans Justice Center. For the reasons set forth below, the defendant?s motion to reduce bond should be denied. 1. The defendant has failed to show that the Orleans Justice Center is not adequately equipped to handle the Coronavirus outbreak, nor has be shown that he will be medically at risk of contracting the Coronavirus if he remains incarcerated. The defendant has ?led a boilerplate motion arguing that his bond should be reduced due to the Coronavirus outbreak. However, he has failed to provide any speci?c facts in support of this argument. The defendant has failed to show that the Orleans Justice Center is not taking all necessary precautions to prevent the spread of Coronavirus to its inmates. Moreover, the defendant has not provided any medical documentation that shows that he is immunocompromised or otherwise has an increased susceptibility to contracting the Coronavirus. The defendant?s bond has previously been set after consideration of a large number of factors, including the facts of his case, the seriousness of the offense, his prior criminal record, potential danger to the community and ?ight risk, community and family ties, his employment history, and any other relevant facts. The State submits that his bond is reasonable based upon the above factors. Without making the above two showings, that a medical reason exists which makes him more susceptible to catching the Coronavirus and that the Orleans Justice Center cannot control the spread of the Coronavirus, the defendant failed to show cause for a bond reduction. If the defendant is able to produce medical documentation in support of his claim, the State is entitled to present evidence or testimony regarding the measures that the Orleans Justice Center is taking to prevent the spread of the Coronavirus into and within jail facilities. II. The defendant poses a threat to the community if he is released. Pursuant to La. Art. 316(5), the trial court may consider ?the nature and seriousness of the danger to any other person or to the community that would be posed by the defendant?s release? when setting a defendant?s bond. The defendant has failed to show that, if released on bond, he will have a residence to stay in while the city battles the Coronavirus outbreak. Nor has he demonstrated that he will adhere to any curfews and other safety measures set in place by city of?cials. If the defendant is released on bond during the Coronavirus outbreak and goes into public places, it will pose a threat to the general public by potentially spreading the virus to others and increasing the rate at which others are exposed to the virus. Additionally, the defendant has yet to be restored to competency by a judicial body. The defendant is currently awaiting a mental competency hearing in Section I. The defendant is facing extremely serious charges. Pursuant to La. Art. 316(1), one of the factors that the trial court may consider when setting a defendant?s bond is ?the seriousness of the offense against the defendant, including but not limited to whether the offense is a crime of violence or involves a controlled dangerous substance.? Here, the defendant is charged with Carjacking, a crime of violence. As such his current bond adequately addresses the IQ seriousness of the offense. IV. The defendant would pose a ?ight risk if released on bond. Pursuant to La. Art. 316(9). the trial court may consider ?any other circumstances affecting the probability of defendant's appearance? when setting a defendant?s bond. Again, the defendant has yet to be restore to competency by a judicial body. It cannot be said if the defendant will continue to appear to upcoming court settings or have the mental capacity to do so. Thus the defendant may present a ?ight risk. CONCLUSION AND PRAYER WHEREFORE, the State of Louisiana prays that the defendant?s motion to reduce bond be denied. The defendant has failed to produce any evidence in support of his claim that he is at risk of contracting the Coronavirus if he is not released on bond, nor has he shown that the Orleans Justice Center is not adequately equipped to protect against the spread of the virus within its facilities. Without making these two particularized showings, the defendant?s motion should be denied. Respectfully submitted, Assistant District Attorney, Orleans Parish District Attorney?s Of?ce CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing ?ling has been served upon defense counsel, by hand, e-mail, facsimile, and/or United States Postal service this the Pr day of EYE EA 2020. Assistant District Attorney STATE OF LOUISIANA CRIMINAL DISTRICT COURT VERSUS PARISH OF ORLEANS CASE OPPOSITION TO MOTION FOR BOND REDUCTION NOW INTO COURT, through the undersigned Assistant District Attorney, comes the State of Louisiana, and respect?rlly requests that this Honorable Court deny the defendant?s motion to reduce bond, based upon the following jurisprudence and argument: I. FACTS AND PROCEDURAL HISTORY The defendant is charged with Carjacking. On January 30, 2020 the defendant plead guilty to Carjacking. The Defendant was previously charged Armed Robbery, however the Statement amended the charge to Carjacking. The Defendant is currently awaiting sentencing. On March 17, 2020 the defendant ?led a motion to reduce bond, citing the recent outbreak of COVID-19, also known as the Coronavirus. The State?s opposition follows. 11. LAW AND ARGUMENT The defendant has failed to show cause why (his/her) bond should be reduced. The State submits that the defendant?s bond, currently set at $50,000 is appr0priate based upon the factors set forth by La. Art. 316, which have been previously considered in setting his bond. Furthermore, the defendant has failed to provide any medical documentation in support of his argument that he will be at risk of contracting Coronavirus in the Orleans Justice Center. For the reasons set forth below, the defendant?s motion to reduce bond should be denied. 1. The defendant has failed to show that the Orleans Justice Center is not adequately equipped to handle the Coronavirus outbreak, nor has be shown that he will be medically at risk of contracting the Coronavirus if he remains incarcerated. The defendant has ?led a boilerplate motion arguing that his bond should be reduced due to the Coronavirus outbreak. However, he has failed to provide any speci?c facts in support of this argument. The defendant has failed to show that the Orleans Justice Center is not taking all necessary precautions to prevent the spread of Coronavirus to its inmates. Moreover, the defendant has not provided any medical documentation that shows that he is immunocompromised or otherwise has an increased susceptibility to contracting the Coronavirus. The defendant?s bond has previously been set after consideration of a large number of factors, including the facts of his case, the seriousness of the offense, his prior criminal record, potential danger to the community and ?ight risk, community and family ties, his employment history, and any other relevant facts. The State submits that his bond is reasonable based upon the above factors. Without making the above two showings, that a medical reason exists which makes him more susceptible to catching the Coronavirus and that the Orleans Justice Center cannot control the spread of the Coronavirus, the defendant failed to show cause for a bond reduction. If the defendant is able to produce medical documentation in support of his claim, the State is entitled to present evidence or testimony regarding the measures that the Orleans Justice Center is taking to prevent the spread of the Coronavirus into and within jail facilities. 11. The defendant poses a threat to the community if he is released. Pursuant to La. Art. 316(5). the trial court may consider ?the nature and seriousness of the danger to any other person or to the community that would be posed by the defendant?s release? when setting a defendant?s bond. The defendant has failed to show that, if released on bond, he will have a residence to stay in while the city battles the Coronavirus outbreak. Nor has he demonstrated that he will adhere to any curfews and other safety measures set in place by city of?cials. If the defendant is released on bond during the Coronavirus outbreak and goes into public places, it will pose a threat to the general public by potentially spreading the virus to others and increasing the rate at which others are exposed to the virus. The defendant is facing extremely serious charges. Pursuant to La. Art. 316(1). one of the factors that the trial court may consider when setting a defendant?s bond is ?the seriousness of the offense against the defendant, including but not limited to whether the offense is a crime of violence or involves a controlled dangerous substance.? Here, the defendant is awaiting sentencing for Carjacking, a crime of violence. IV. The defendant would pose a ?ight risk if released on bond. Pursuant to La. Art. 31612), the trial court may consider ?any other circumstances affecting the probability of defendant's appearance? when setting a defendant?s bond. The defendant is currently awaiting sentencing is this case where they have already plead guilty. The minimum sentence for the crime is two-years. The Defendant has confessed their guilt to this crime and would not be granted release if sentencing had already occurred. CONCLUSION AND PRAYER WHEREFORE, the State of Louisiana prays that the defendant?s motion to reduce bond be denied. The defendant has failed to produce any evidence in support of his claim that he is at risk of contracting the Coronavirus if he is not released on bond, nor has he shown that the Orleans Justice Center is not adequately equipped to protect against the spread of the virus within its facilities. Without making these two particularized showings, the defendant?s motion should be denied. Respectfully submitted, Assistant District Attorney, Orleans Parish District Attorney?s Office CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing ?ling has been served upon defense counsel, by hand, e-mail, facsimile, and/or United States Postal service this the day of mm, 2020. Assistant District Attorney STATE OF LOUISIANA CRIMINAL DISTRICT COURT VERSUS PARISH OF ORLEANS CASE OPPOSITION TO MOTION TO LIFT PROBATION HOLD OR SET A PROBATION BNOD NOW INTO COURT, through the undersigned Assistant District Attorney, comes the State of Louisiana, and respectfully requests that this Honorable Court deny the defendant?s motion to reduce bond, based upon the following jurisprudence and argument: I. FACTS AND PROCEDURAL HISTORY The defendant is charged with Illegal Possession of Stolen Thing, Forgery and Bank Fraud. The defendant plead guilty as charged on August 19, 2019. On March 2, 2020 Probation Of?cer ??led a Motion and Order for a Hearing to Revoke Probation. On March 16, 2020 the defendant ?led a motion to reduce bond, citing the recent outbreak of also known as the Coronavirus. The State?s opposition follows. 11. LAW AND ARGUMENT The defendant has failed to show cause why his probation hold should be lifted. The defendant has failed to provide any medical documentation in support of his argument that he will be at risk of contracting Coronavirus in the Orleans Justice Center. For the reasons set forth below, the defendant?s motion to reduce bond should be denied. 1. The defendant has failed to show that the Orleans Justice Center is not adequately equipped to handle the Coronavirus outbreak, nor has he shown that he will be medically at risk of contracting the Coronavirus if he remains incarcerated. The defendant has ?led a boilerplate motion arguing that his bond should be reduced due to the Coronavirus outbreak. However, he has failed to provide any speci?c facts in support of this argument. The defendant has failed to show that the Orleans Justice Center is not taking all necessary precautions to prevent the spread of Coronavirus to its inmates. Moreover, the defendant has not provided any medical documentation that shows that he is immunocompromised or otherwise has an increased susceptibility to contracting the Coronavirus. The defendant?s bond has previously been set after consideration of a large number of factors, including the facts of his case, the seriousness of the offense, his prior criminal record, potential danger to the community and ?ight risk, community and family ties, his employment history, and any other relevant facts. The State submits that his bond is reasonable based upon the above factors. Without making the above two showings, that a medical reason exists which makes him more susceptible to catching the Coronavirus and that the Orleans Justice Center cannot control the spread of the Coronavirus, the defendant failed to show cause to lift the probation hold. If the defendant is able to produce medical documentation in support of his claim, the State is entitled to present evidence or testimony regarding the measures that the Orleans Justice Center is taking to prevent the spread of the Coronavirus into and within jail facilities. II. The defendant poses a threat to the community if he is released. Pursuant to La. Art. 316(5), the trial court may consider ?the nature and seriousness of the danger to any other person or to the community that would be posed by the defendant?s release? when setting a defendant?s bond. The defendant has failed to Show that, if released on bond, he will have a residence to stay in while the city battles the Coronavirus outbreak. Nor has he demonstrated that he will adhere to any curfews and other safety measures set in place by city of?cials. If the defendant is released on bond during the Coronavirus outbreak and goes into public places, it will pose a threat to the general public by potentially spreading the virus to others and increasing the rate at which others are exposed to the virus. IV. The defendant would pose a ?ight risk if released on bond. Pursuant to La. Art. 316(9), the trial court may consider ?any other circumstances affecting the probability of defendant's appearance? when setting a defendant?s bond. The State spoke with Probation Officer Bercegeay who indicated that he would oppose lifting the defendant?s probation hold because the defendant is a ?ight risk. Of?cer ?'ndicated that he would seek a warrant for the defendant?s arrest is he were to make a bond. Of?cer ?informed the State that if released, the defendant will not be able to live with family and will likely be homeless. Prior to the court closure, Of?cer?and Court Intervention Services were seeking to ?nd a program from the defendant to enter. Without such a program in place, the defendant presents a ?ight right if released on bond. CONCLUSION AND PRAYER WHEREFORE, the State of Louisiana prays that the defendant?s motion to reduce bond be denied. The defendant has failed to produce any evidence in support of his claim that he is at risk of contracting the Coronavirus if he is not released on bond, nor has he shown that the Orleans Justice Center is not adequately equipped to protect against the Spread of the virus within its facilities. Without making these two particularized showings, the defendant?s motion should be denied. Respectfully submitted, Assistant District Attorney, Orleans Parish District Attomey?s Of?ce CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing ?ling has been served upon defense counsel, by hand, e-mail, facsimile, and/or United States Postal service this the day of .MAQ 2020. Assistant District ARomey STATE OF LOUISIANA CRIMINAL DISTRICT COURT VERSUS PARISH OF ORLEANS CASE OPPOSITION TO MOTION FOR BOND REDUCTION NOW INTO COURT, through the undersigned Assistant District Attorney, comes the State of Louisiana, and requests that this Honorable Court deny the defendant?s motion to reduce bond, based upon the following juriSprudence and argument: I. FACTS AND PROCEDURAL HISTORY The defendant is charged with Aggravated Battery. On December 4, 2018, the defendant was found incompetent. On March 3, 2020 the defendant was found to have the mental capacity to proceed by forensic He was discharged to OJC on March 6, 2020. On March 13, 2020, the defendant ?led a motion to reduce bond, citing the recent outbreak of also known as the Coronavirus. The State?s opposition follows. II. LAW AND ARGUMENT The defendant has failed to show cause why his bond should be reduced. The State submits that the defendant?s bond, currently set at $7,500 is appropriate based upon the factors set forth by La. Art. 316. which have been previously considered in setting his bond. Furthermore, the defendant has failed to provide any medical documentation in support of his argument that he will be at risk of contracting Coronavirus in the Orleans Justice Center. For the reasons set forth below, the defendant?s motion to reduce bond should be denied. 1. The defendant has failed to show that the Orleans Justice Center is not adequately equipped to handle the Coronavirus outbreak, nor has he shown that he will be medically at risk of contracting the Coronavirus if he remains incarcerated. The defendant has ?led a boilerplate motion arguing that his bond should be reduced due to the Coronavirus outbreak. However, he has failed to provide any speci?c facts in support of this argument. The defendant has failed to show that the Orleans Justice Center is not taking all necessary precautions to prevent the Spread of Coronavirus to its inmates. Moreover, the defendant has not provided any medical documentation that shows that he is immunocompromised or otherwise has an increased susceptibility to contracting the Coronavirus. Although the defense did provide a copy of the defendant?s most recent evaluation, this does not demonstrate a physical susceptibility to the Coronavirus. The defendant?s bond has previously been set after consideration of a large number of factors, including the facts of his case, the seriousness of the offense, his prior criminal record, potential danger to the community and ?ight risk, community and family ties, his employment history, and any other relevant facts. The State submits that his bond is reasonable based upon the above factors. Without making the above two showings, that a medical reason exists which makes him more susceptible to catching the Coronavirus and that the Orleans Justice Center cannot control the spread of the Coronavirus, the defendant failed to show cause for a bond reduction. If the defendant is able to produce medical documentation in support of his claim, the State is entitled to present evidence or testimony regarding the measures that the Orleans Justice Center is taking to prevent the spread of the Coronavirus into and within jail facilities. 11. The defendant poses a threat to the community if he is released. Pursuant to La. Art. 316(5), the trial court may consider ?the nature and seriousness of the danger to any other person or to the community that would be posed by the defendant?s release? when setting a defendant?s bond. The defendant has failed to show that, if released on bond, he will have a residence to stay in while the city battles the Coronavirus outbreak. Nor has he demonstrated that he will adhere to any curfews and other safety measures set in place by city of?cials. If the defendant is released on bond during the Coronavirus outbreak and goes into public places, it will pose a threat to the general public by potentially spreading the virus to others and increasing the rate at which others are exposed to the virus. Additionally, the defense contend that the defendant is ?unable to perform basic tasks for himself? such as washing his hands. If released, the defendant will pose a health risk to the greater community during this emergency. The defendant is facing extremely serious charges. Pursuant to La. Art. 316(1), one of the factors that the trial court may consider when setting a defendant?s bond is ?the seriousness of the offense against the defendant, including but not limited to whether the offense is a crime of violence or involves a controlled dangerous substance.? Here, the Defendant is charged with Aggravate Battery which is a crime of violence. CONCLUSION AND PRAYER WHEREFORE, the State of Louisiana prays that the defendant?s motion to reduce bond be denied. The defendant has failed to produce any evidence in support of his claim that he is at risk of contracting the Coronavirus if he is not released on bond, nor has he shown that the Orleans Justice Center is not adequately equipped to protect against the spread of the virus within its facilities. Without making these two particularized showings, the defendant?s motion should be denied. Respectfully submitted, Assistant District Attorney, Orleans Parish District Attorney?s Of?ce CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing ?ling has been served upon defense counsel, by hand, e-mail, facsimile, and/or United States Postal service this the day Mm, 2020. Assistant District Attorney STATE OF LOUISIANA CRIMINAL DISTRICT COURT VERSUS PARISH OF ORLEANS CASE OPPOSITION TO MOTION FOR BOND REDUCTION NOW INTO COURT, through the undersigned Assistant District Attorney, comes the State of Louisiana, and respectfully requests that this Honorable Court deny the defendant?s motion to reduce bond, based upon the following jurisprudence and argument: I. FACTS AND PROCEDURAL HISTORY The defendant previously plead guilty to violations of Aggravated Flight from an Of?cer and Possession of a Control Dangerous Substance. On October 4, 2018 the defendant plead guilty as charged. On December 1, 2019 the State ?led a warrant for a defendant based on his new arrest. The defendant was arrested on December 1, 2019 on the capias. The defendant currently has a new case in _where his is charged with violation of Purse Snatching and Possession of Cocaine. On March 17, 2020, the defendant ?led a motion to lift the defendant?s probation hold or set a probation bond, citing the recent outbreak of also known as the Coronavirus. The State?s opposition follows. II. LAW AND ARGUMENT The defendant has failed to show cause why his probation hold should be lifted. Furthermore, the defendant has failed to provide any medical documentation in support of his argument that he will be at risk of contracting Coronavirus in the Orleans Justice Center. For the reasons set forth below, the defendant?s motion to reduce bond should be denied. I. The defendant has failed to show that the Orleans Justice Center is not adequately equipped to handle the Coronavirus outbreak, nor has he shown that he will be medically at risk of contracting the Coronavirus if he remains incarcerated. The defendant has ?led a boilerplate motion arguing that his hold should be lifted due to the Coronavirus outbreak. However, he has failed to provide any speci?c facts in support of this argument. The defendant has failed to show that the Orleans Justice Center is not taking all necessary precautions to prevent the spread of Coronavirus to its inmates. Moreover, the defendant has not provided any medical documentation that shows that he is immunocompromised or otherwise has an increased susceptibility to contracting the Coronavirus. Without making the above showings, that a medical reason exists which makes him more susceptible to catching the Coronavirus and that the Orleans Justice Center cannot control the spread of the Coronavirus, the defendant failed to show cause to lift the probation hold. If the defendant is able to produce medical documentation in support of his claim, the State is entitled to present evidence or testimony regarding the measures that the Orleans Justice Center is taking to prevent the spread of the Coronavirus into and within jail facilities. II. The defendant poses a threat to the community if he is released. Pursuant to La. Art. 316(5), the trial court may consider ?the nature and seriousness of the danger to any other person or to the community that would be posed by the defendant?s release? when setting a defendant?s bond. The defendant has failed to show that, if released on bond, he will have a residence to stay in while the city battles the Coronavirus outbreak. Nor has he demonstrated that he will adhere to any curfews and other safety measures set in place by city officials. If the defendant is released on bond during the Coronavirus outbreak and goes into public places, it will pose a threat to the general public by potentially spreading the virus to others and increasing the rate at which others are exposed to the virus. The defendant is has plead to extremely serious charges. Pursuant to La. Art. 316(1), one of the factors that the trial court may consider when setting a defendant?s bond is ?the seriousness of the offense against the defendant, including but not limited to whether the offense is a crime of violence or involves a controlled dangerous substance.? Here, the defendant has previously plead guilty and is on probation for Aggravated Flight from an Of?cer, a crime of violence. While on probation, the defendant picked up new charges. IV. The defendant would pose a ?ight risk if released on bond. Pursuant to La. Art. 316(9). the trial court may consider ?any other circumstances affecting the probability of defendant's appearance? when setting a defendant?s bond. The defendant previously failed to appear for court in Section I on December 1, 2019. CONCLUSION AND PRAYER WHEREFORE, the State of Louisiana prays that the defendant?s motion to reduce bond be denied. The defendant has failed to produce any evidence in support of his claim that he is at risk of contracting the Coronavirus if he is not released on bond, nor has he shown that the Orleans Justice Center is not adequately equipped to protect against the spread of the virus within its facilities. Without making these two particularized showings, the defendant?s motion should be denied. Respect?illy submitted, Assistant District Attorney, Orleans Parish District Attorney?s Of?ce CERTIFICATE OF SERVICE I hereby certify that a c0py of the foregoing ?ling has been served upon defense counsel, by hand, e-mail, facsimile, and/or United States Postal service this the day of m, 2020. Assistant District Attorney