Вы находитесь на странице: 1из 73
(COMMONWEALTH OF MASSACHUSETTS Worcester, 88 Frrcupuc Distaicr Court DOCKET No. 14l6CROO21]7 COMMONWEALTH v. ConstonwEAL-TH's PROPOSED EXHIBIT LisT FOR DANGEROUSNESS HEARING ‘The Commonwealth respectfully submits to this Court list of intended exhibits atthe scheduled ML. 276 § 58A Dangerousness Hearing forthe above-captioned Defendant: Exhibit: All police reports elated tothe ahoverteferenced docket; Exhibit2: Defendant's Board of Probation Record; Exhibit: Docket # 1221CR001652 with statement of fcts; Exhibitd: Docket # 1116CR000980 with related police reports Exhibit: Docket # 0961CR001283 with related police report; [EXLIbiLG: Docket # 0961 CR000462 with related police reports, photos, and writen statement by vctin; Exhibit7: Docket # 0961CR0002S7 wits related police reports, photos, and written statements by victim and witnesses; Exhibit: Docket # 0861CROG2288 with related police report and loss prevention report; Exhibit: Docket # 0861CR002028 with relsed police report; and Exhibit 10: Docket # 0861CRO01466 with related police report. ‘As grounds therefore, the Commonvwealth stats that the above-referenced matesils are ‘sdizsble as relevant information in determining the Defendants dangerousness. Moreover, hearsay shall be considered in SBA heazings, citing M.G.L.276 § SBAC). ‘Moreover, the Commonwealth requests tht Evhibit 2 be sealed or kept in probation’ file, as its contents ae statutorily privileged under ML. 6 § 172(). Dave: SEPTEMBER 28,2014 Respectfily submitted, (COMMONWEALTH OF MASSACHUSETTS JOSEPH D. EARLY, J. Distaict ATTORNEY For WoxcesTER COUNTY “Tireavey A. MAYKEL, BBO # 684491 ASSISTANT DISTRICT ATTORNEY FITCHBURG DistRICT CouRTHOUSE 100 ELM Stazer| FITCHBURG MA 01420 1-774-317-2160 |F (978) 343-4828 E TUEEANV.AMAYKEL@STATE MALS ‘COMMONWEALTH OF MASSACHUSETTS Worcester, SS Frcusunc Disraicr Coun DOCKET No. 1616CRO01690 COMMONWEALTH v. (CoMMONWEALTH'S PROPOSED EXHIBIT LIST FOR DANGEROUSNESS HEARING ‘AND MOTION TO IMPOUND CERTAIN EXHIBITS. ‘The Commonwealth respectfully submits to this Court a list of intended exhibits atthe scheduled M.GL. 276 § 58A Dangerousness Hearing forthe above-captioned Defendant: Exhibit: Complaint, Police Reports, Writen Statements, Domestic Violence Dangerousness Sheet, Strangulation Worksheet, and related Restraining Order ATfidavits related to above-referenced case; Exhibic2: Defendant's Board of Probation Record & Interstate Identification Index; ‘Exit: Complaint for Docket 1616CROOIS83, Accident Report, and Police Report and Citation For Leaving the Scene of Property Damage; Exhibit: Fitchburg Police Report Incident # 16-17532-OF re: Traffickiog Heroin; Exhibit: Fitchburg Police Report Incident # 11-32952-AR re: A&B 00 a PO. ‘As grounds therefore, the Commonwealth tte thatthe above-referenced materials are admissible as relevant information in determining the Defendant's dangerousness. Moreover, hearsay shall be coasidered in 58A hearings, cling M.G.L. 276 § SBA(4), Furthermore, atthe close ofthe hearing, the Commonwealth seeks impoundment of Exhibit 2, as ‘contains privileged information about the Defendant's criminal record. Respectfully submited, ‘COMMONWEALTH OF MASSACHUSETTS JOSEPH D. EARLY. JR DistRict ATTORNEY FoR WORCESTER COUNTY TIFFANY A. MAYKEL, B50 #684491 ASSISTANT DISTRICT ATTORNEY FITCHBURG DisTRICT COURTHOUSE 100 Eus Srneet | FrrcBuRG MA 01420 7 774-317-2160 | (978) 342-4928 E Date: (COMMONWEALTH OF MASSACHUSETTS Worcester, SS Frrempurc Distauct Court Docker No. 1716CR001252 COMMONWEALTH TO ComMONWEALTH'S PROPOSED EXHIBIT List FOR DANGEROUSNESS HEARING ‘AND MOTION TO IMPOUND CERTAIN EXHIBITS ——— ‘The Commonwealth respectfully submits to this Cour alist of intended exhibits atthe scheduled M.GLL. 276 § 58A Dangerousness Hearing forthe above-captioned Defendant: Exhibitt: Complaint and potice-epor related to above-referenced Assault & Battery with a Dangerous ‘Weapon; Exhibit2: Defendan’s Board of Probation Record and Sealed Record, Exhibit2: Defendant's Iuerstate Identification Index; Exhibit: 209A Order and Affidavit related to 1716RO0383; [ExhibiLS: Leominster Police Report Incident # 17-25734-OF re: A&B on/sbout 6/20/2017; Exhibit: 209A Application and Affidavit elated to 1761RO0190; Exhibit 7: Leominster Police Repors Incident # 17-15633-OF re: incident on 4/10/2017; Exhibit: Worcester Police Report Incident # 2012-63908 re: violation of petal stay awey no contact ‘order on 7/15/2012; Exhibit: Worcester Police Report Incident #201 1-69904 re: Assauk witha Machete on 7/21/2011; ExhibiCl0: Worcester Police Report Incident #2010-104302 re: A&B with same victim on 10/24/2010; EqhibiCLL: Worcester Police Report Incident #2009-31354 re: A&B on 04/14/2009; ‘ExhBILI2: Worcester Police Report Incident #2008-119956 re: A&B on 12/26/2008; EXHBILII: Worcester Police Report Incident #2008-101782 re: Marijuana charges and hiding a fugitive on 10/30/2008; Exhibit 14: Worcester Police Report Incident #2007-1 14102 re: A&B on 12/10/2007; Exhibit15: Worcester Police Report Incident #200S-71314 re: Hit and Run on 8/2/2005; [EghBiLIG: Worcester Police Report Incident #2001-20153 re: Trespassing on 2/18/2001 [ExhBILIZ: Worcester Police Report Incident #1998-136126 re: Trespassing on 11/25/1998; Exhibit 18: Worcester Police Repor Incident #1998-134543 re: Faure to Stop for Police on 1121/1998; [Exhibit 19: Worcester Police Report Incident #1998-638 re: Malicious Destruction of Property on 12998; Exhibit 20: Worcester Police Report Incident #1994-68216 re: Unauthorized Use of a Motor Vehicle on 9728/1994. ‘As grounds therefore, the Commonwealth sates that the above-referenced materials are ‘admissible as relevant information in determining the Defendant's dangerousness. Moreover, hearsay shall be considered in 584 hearings, citing M.G.L. 276 § SBA(4). A +

Вам также может понравиться