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COUNTY COURT, EIGHTEENTH JUDICIAL

CIRCUIT CRIMININAL JUSTICE DVIVISION


IN AND FOR CHARLOTTE COUNTY FLORIDA
CASE NO. 1401-005571
STATE OF FLORIDA,
Plaintiff,
v.
WILLIAM GOLLADAY,
Defendant,
____________________________________/
Motion To Set Bail
COMES NOW the Defendant William Golladay, by and through the undersigned
attorney and pursuant to Rule 3.131(a), Florida Rules of Criminal Procedure would move this
Honorable Court to set bail for $1,000.

Facts
1. On January 11, 2014 at 6:24 pm Officer Kathy Kayers (Kayers) responded to the
Walmart located at 5001 Taylor Rd. Charlotte County, Florida in reference to a
disturbance.
2. Upon arrival, Kayers met with the manager of Walmart and an off duty CCSO Deputy
Cpl. C. Brandon who had the Defendant outside.
3. Kayers informed the Defendant she was conducting an investigation and that is why he
was being detained.
4. Kayers spoke to the alleged victim, Malherbe who was upset. She observed slight
redness on his right elbow.
5. Malherbe claimed he was in the express lane when the Defendant began counting his
items and proceeded to get loud when the items exceeded 20.
6. The Defendant, William Golladay who is a 74 year old military veteran with no priors is
alleged to have committed battery on a person 65 years or older.
7. The Defendant, because of his military background believes it is his duty to be honest at
all times and saw Malherbes exceeding items as being dishonest.

Law
8. According to Rule 3.131(a), Florida Rule of Criminal Procedure, unless charged with a
capital offense or an offense punishable by life imprisonment and the proof of guilt is
evident or the presumption is great, every person charged with a crime or violation of
municipal or county ordinance shall be entitled to pretrial release on reasonable
conditions.
9. The Defendant has no priors, has lived in Punta Gorda for 47 years with his wife, and is a
military veteran. While reviewing the amount set for bail, these important factors should
be taken into consideration.

WHEREFORE, the Defendant requests this Honorable Court to enter its Order to set bail
for $1,000.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of this foregoing has been
furnished by the U.S.Mail to the Office of the State Attorney, 100 E. 1
st
Street, Sanford,
Florida this ______ day of January, 2014.





______________________________
MARIAH CONEY
Florida Bar No. 1234567
Law Office of Mariah Coney, P.A.
P. O. Box 669036
Punta Gorda, Florida 31254-7624
(786)312-4073