USA v. Applebury et al

District of Alaska, akd-3:2017-cr-00121-58433


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BRYAN SCHRODER United States Attorney RETTA-RAE RANDALL Assistant United States Attorney Federal Building & U.S. Courthouse 222 West Seventh Avenue, #9, Room 253 Anchorage, Alaska 99513-7567 Phone: (907) 271-5071 Fax: (907) 271-1500 Email: Attorneys for Plaintiff IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ALASKA UNITED STATES OF AMERICA,) Case No. 3:17-cr-00121-TMB) Plaintiff,) UNITED STATES' MOTION FOR) BAIL HEARING AND OTHER vs.) RELIEF) JILL DIANE APPLEBURY, aka "Jill) [Filed On Shortened Time] Wetzsteon",)) Defendant.) COMES NOW the United States of America, by and through undersigned counsel, and hereby moves the Court for a hearing on Defendant Jill Applebury's (Defendant) bail status. In short, the United States has become aware that the defendant has violated the Court's order setting conditions of release in this matter in that she has violated federal, state, or local law while on release. See Doc. 158. The facts in support of this motion are set forth in the Declaration of Assistant United States Attorney Retta-Rae Randall, as well as Exhibits 1 - 4, filed concurrently herewith. Accordingly, the United States asks for a prompt hearing at which Defendant should show cause why her bail should not be revoked. This motion is filed on shortened time because the government understands that the Defendant wishes to return to Montana and the family is concerned about her doing so. RESPECTFULLY SUBMITTED on January 11, 2019, in Anchorage, Alaska. BRYAN SCHRODER United States Attorney s/ Retta-Rae Randall RETTA-RAE RANDALL Assistant United States Attorney United States of America CERTIFICATE OF SERVICE I hereby certify that on the filing date a copy of the foregoing is being served electronically, via the Court=s CM/ECF system, on: James A. Wendt, Esq. s/ Retta-Rae Randall Assistant United States Attorney United States v. Karjala 3:17-cr-00063-TMB Page 2 of 2