Defendant’s Motion to Reopen Detention Hearing and Proposed Order — No. 4:22-cr-00090 (Dkt. 32, E.D. Mo.)

Summary

A defendant's motion to reopen the detention hearing filed in the U.S. District Court for the Eastern District of Missouri in United States v. Chuny Reed, Case No. 4:22-cr-090-AGF-SRW, docketed as 4:22-cr-00090, as filing 32. Reed asks the Court to reopen her detention hearing under 18 U.S.C. § 3142(f) because of material information learned after the hearing, and then to find that conditions exist to assure her appearance and public safety. A criminal complaint was filed against her on February 8, 2022, she was arrested the same day, and she was ordered detained on February 14, 2022; on July 13, 2022 she had a medical episode that drastically affected her health. The proposed order, dated the 15th day of July, 2022, would release her on condition that she report to Pretrial Services within 72 hours of leaving the hospital.

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“Defendant’s Motion to Reopen Detention Hearing and Proposed Order — No. 4:22-cr-00090 (Dkt. 32, E.D. Mo.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/defendant-s-motion-to-reopen-detention-hearing-and-proposed-order-no-4-d4f904ddfb/, SHA-256 583fc2209454cd22e3eab187cc6d3e44ba1d808ca782b4ec7997b2a1beab5ed9.

Full text

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION

UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
v. ) Case No. 4:22-cr-090-AGF-SRW
)
CHUNY REED, )
)
Defendant. )

DEFENDANT’S MOTION TO REOPEN DETENTION HEARING

AND PROPOSED ORDER

Defendant, Chuny Reed, seeks to reopen her detention hearing pursuant to 18 U.S.C.

§ 3142(f) due to material information the defense learned after Ms. Reed’s hearing, which

was not available to defense counsel at the time of the hearing. After reopening Ms. Reed’s

detention hearing, this Court should find there are conditions that will assure Ms. Reed’s

appearance and the public’s safety to allow for her release.

Procedural History

On February 8, 2022, a criminal complaint was filed against Ms. Reed. Dkt. No. 1.

Ms. Reed was arrested the same day and the government moved for detention. Ms. Reed

was ordered detained on February 14, 2022.

Argument

Under § 3142(f), this Court may reopen Ms. Reed’s detention hearing after the

defense learned about “information . . . that was not known to [the defense] at the time of

the hearing and that has a material bearing on the issue whether there are conditions of
release that will reasonably assure” public safety and Ms. Reed’s appearance. 18 U.S.C. §

3142(f).
On July 13, 2022, Ms. Reed had a medical episode that has drastically impacted her

health and substantially changed her public safety risk factors. This information is

materially new information that changes the balance as to detention. The government has

no opposition to Ms. Reed’s release on bond in light of the change in circumstances. Pretrial

also has recommended Ms. Reed be released on bond.

The Court should also find Ms. Reed is not a flight risk and that conditions can be

fashioned to assure her appearance. Counsel requests she be released immediately with

the condition to report to pretrial within 72 hours of release from the hospital.

Conclusion

Based on the above, this Court should reopen Ms. Reed’s detention hearing and find

there are conditions that will assure the public’s safety as well as her appearance at future

court proceedings.

Dated: July 15, 2022

Respectfully submitted,

/s/Diane L. Dragan
DIANE L. DRAGAN, #73591MO
Assistant Federal Public Defender
1010 Market Street, Suite 200
St. Louis, Missouri 63101
Telephone: (314) 241-1255
Fax: (314) 421-3177
E-mail: Diane_Dragan@fd.org
ATTORNEY FOR DEFENDANT

CERTIFICATE OF SERVICE

I hereby certify that on July 15, 2022, the foregoing was filed electronically with the Clerk of the Court to
be served by operation of the Court’s electronic filing system upon Erin Granger, Assistant United States
Attorney.

2
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION

UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
v. ) Case No. 4:22-cr-090-AGF-SRW
)
CHUNY REED, )
)
Defendant. )

ORDER

Based on information newly available to the Court, the Court concludes that at this time

Defendant is neither a flight risk nor a danger to the community.

Accordingly,

IT IS HEREBY ORDERED that Defendant’s Motion to Reopen the Detention Hearing is

GRANTED.

IT IS FURTHER ORDERED that the defendant is to be released on bond with the condition to

report to Pretrial Services within 72 hours of release from the hospital.

___________________________________
UNITED STATES MAGISTRATE JUDGE

Dated this 15th day of July, 2022

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SHA-256: 583fc2209454cd22e3eab187cc6d3e44ba1d808ca782b4ec7997b2a1beab5ed9
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