STATE OF ILLINOIS )

COUNTY OF COOK )
) SS.
f/£
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
MUNICIPAL DIVISION - FIRST DISTRICT

PEOPLE OF THE STATE OF ILLINOIS ) PENDING IND/INF #_

OdtdloSoZ-
)
VS. PRELIMINARY HEARING COMPLAINT # .

AA/AJH0^C K./nezorito BRANCH

(RESPONDENT- PRETRIAL RELEASE)
PETITION FOR A HEARING ON VIOLATION OF BAIL BOND CONDITIONS AND
APPLICATION TO INCREASE AMOUNT OF BAIL PURSUANT TO
725 ILCS 5/110-S(a)&(e)
NOW COME the People of the State of Illinois, by their attorney, ANITA ALVAREZ, State's Attorney of Cook
County, and move this Honorable Court, to file INSTANTER this petition for the above named
Respondent-Pretrial Releasee, and that this petition be transferred instanter to call of the Honorable
Judge ^ ^ 0 $ N J A L ^ A » ^ for a prompt hearing.
In support thereof, the People state as follows:
1) The Defendant is presently free on bail in case number OoC-fZlO<$03^ t wherein he is charged with the
felony offense of £oft\ftr]t?£. T&/A/&&4HS matter is presently pending on the trial call of the Honorable
Judge £ & S t J A r ^ , U at 10 '.QOAov^ for fif&lU 2o 20jO__.

2) While free on said bail, the defendant violated a condition of bail, in that he/she on or about. „,at
2A4JA 4 <LA X Q y i 6 - 0 , Cook County, Illinois, . A <^On^/Oi i X7&V -ak&~ 0 fp&&i3~C)l>

-WA-oi, ri£ n k r QDOVL ^dj/ory Caufcr ftgftgna&s &cc>vc& mmfag-A ^&t^s.^jr

MO \k$&P Aft 0WULLC&D Sti^d- 7/0Ca£<nAT)0^> /M V/S l4?HtwO OP
>2e \i-cs s/jw-2(a,w60,
WHEREFORE, the btate
iFORt, the State moves
moves the
the Court
Court to
to tile
file this
this petition
petition and
and issue
issue aa warrant
warrant or
or set
set a
a bail
bail thereon
th and transfer the
matter to Judge fi&S/UAtiAr/J on flflg|LlS) , 20 J& at /OiOOi^yy .for a hearing.

After being duly sworn, the affiant states on reasonable ANITA ALVAREZ
information and belief that the facts are true and correct. Cook County
SUBSCRIBED AND SWORN TO BEFORE ME this
day of , 20

Leave is granted to the State to file this petition, Bail is s£w^ _. This petition is here by transferred to
Judge 3&>SAJAtJAAJ .on. H^i

DATE:. 4-/V- ZO/o .ENTER: / ??/

WHITE ORIGINAL: PRELIMINARY HEARING COUR
GREEN 1 8t COPY: CRIMINAL DIVISION IND./INF.
YELLOW 2nd COPY: ASA TRIAL COURT
PINK 3rd COPY: DEFENDANT
GOLD 4th COPY: PRELIMINARY HEARING FILE
 STATE OF ILLINIOS
IN THE CIRCUIT COURT OF COOK COUNTY, CRIMINAL DIVISI

PEOPLE OF THE
mio,
STATE OF ILLPNOIS MAY o 5 2010
Maintiff,
No. 08 CR 1050201
v.

ANNABEL MELONGO
Defendant.

MOTION TO REDUCE BOND

ANNABEL MELONGO, by and through his attorney, ALBUKERK AND

ASSOCIATES moves this Court to reduce his bail. This motion is based on the Eighth

Amendment to the United States Constitution, ILCS Const. Art. 1 Sec. 9 and the

following reasons:

1. ANNABEL MELONGO was arrested and charged with the offense of

Computer Tampering in May of 2006 .

2. ANNABEL MELONGO was issued an I bond because she had no

criminal record and the offense was not one that was violent.

3. ANNABEL MELONGO was arrested on or about April 20, 2010 on the

charge of Eavesdropping in that she recorded a phone conversation of a Court Reporter

because that Reporter had erroneously wrote in a transcript that Ms. Melongo was present

at her arraignment when she was not. If the Court Reporter had done this intentionally it

would constitute a crime.

4. On the same date that the charge for Eavesdropping was announced, Ms.

Melongo was also charged with Violation of her bail bond in that the new charge of
 I
Eavesdropping constituted a violation of her bond, which stated that she could not get

charged with any other offenses while out on the I Bond granted in the Computer

Tampering case.

5. The total bonds set in the above cases are 500,000 D and 30, 000 D bond

meaning that Ms. MELONGO must come up with $53,000 to get out of prison on a non-

violent offense where no pecuniary interests were harmed.

6. The Eighth Amendment to the United States Constitution and Article 1

Section 9 of the Illinois Constitution provide that excessive bail shall not be required.

U.S. Const., Am. VIII; ILCS Const. Art. 1 Sec. 9.

7. Bail that is set at an amount higher than an amount reasonably calculated

to give adequate assurance that the accused will stand trial and submit to sentence if

guilty is excessive under the Eighth Amendment. See Stack v. Boyle, 342 U.S. 1, 5,

(1951).

8. Reduction of ANNABEL MELONGO's bail is appropriate because:

a. ANNABEL MELONGO's ties to the community are well

established and she has attended every Court date since being

arrested, four years worth of Court dates.

b. The new offense for which she has been charged is a Felony in

only four States, meaning that few jurisdictions see Ms. Melongo's

activity of recording a conversation as criminal.

c. The offense of Eavesdropping is not a violent crime or one in

which anyone's interests were negatively effected. In fact a full

 reading of the Statute strongly implies that the only reason for the

Statute is political.

d. The Defendant, ANNABEL MELONGO, has no Felony criminal

convictions.

For the foregoing reasons, ANNABEL MELONGO respectfully requests that the

Court grant her motion for bail reduction to a reasonable amount no more than a 100,000

"D" bond.

J. Nicolas Albukerk
111 E. Wacker, Suite 555
Chicago IL 60601
773 847 2600
Fax: 773 847 0330
Attorney # 37955
 3

IN THE CIRCUIT COURT OF C O O K COUNTY, ILLINOIS LINE No.

CRIMINAL DIVISION / MUNICIPAL DEPARTMENT-DISTRICT- 16

Nn 08CR1050201
PEOPLE OF THE STATE OF ILLINOIS

vs. SID.
HELONGO, ANNABEL K IR_

ADDENDUM TO PREVIOUS ORDER SETTING BAIL AND COMMITTING THE DEFENDANT TO THE COOK
COUNTY DEPARTMENT OF CORRECTIONS FOR FAILURE TO DEPOSIT BAIL.

ORDER

THIS MATTER COMING BEFORE THE COURT AND THE COURT BEING FULLY ADVISED IN THE PREMISES, IT
IS HEREBY ORDERED: , /

VvAu^ 1-WU 5VJ- hoo.(jt>i>t\.

ENTERED%-
[ m 0 5 2010 &
terowstian'181,1
DISPOSITION(S) MUST REFLECT WHICH COUNT(S) T ER(S) IS/ ARE APPLICABLE TO.

ENTERED SNAHAN
JUDGE No.

DEPUTY CLERK ROOM/BRANCH JQ2

PAGE 1 OF J L _ PAGES AT9;30 AM AM / PM

DOROTHY BROWN
CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

CR-MIS707-220M-7/10/02(25291398) COURT FILE