IN THE DISTRICT COURT FOR POLK COUNTY

STATE OF IOWA, CRIMINAL ACTION NO. 00-1234568

Plaintiff,
v.
APPLICATION FOR BOND REVIEW
JASON DOETING, AND BOND REVIEW HEARING

Defendant.

The defendant asks the court to review his bond and set this matter for a bond review

hearing. A bond review is warranted by the following facts:

1. The defendant was charged with one count of Involuntary Manslaughter under Iowa

Code Section 707.5. Bond in this matter has been set at $7,500, cash-only.

2. The defendant’s household consists of himself, his girlfriend, and their 6-month-old son.

3. The defendant is the sole provider for his household. His girlfriend does not work.

4. The defendant is currently employed through a temp agency at Work A Man, earning $10

per hour.

5. The defendant’s household expenses consist of $450/month rent and $50/month utilities,

plus other necessary living costs for him, his girlfriend, and their infant son.

6. The defendant also has $2,500 in credit card debt and a $1,500 car loan.

7. The defendant and his girlfriend have no bank accounts and no more than $2,000 in

liquid assets.

8. If the defendant is not able to post bond, his girlfriend and infant son will lose the

apartment and be forced to move in with the defendant’s mother, who already supports

two other sons in her household, and has no extra bedrooms.

1
 9. The defendant has significant ties to the community through his girlfriend, their infant

son, his mother, and two brothers, and is not a flight risk.

10. The inability to post the current cash-only bond of $7,500 will cause substantial hardship

to the defendant, his girlfriend, their infant son, and his mother’s household.

11. In these circumstances, the nature of the charged crime does not warrant the current bond

amount.

Conclusion

WHEREFORE, the defendant asks this court to reduce or alter bond conditions to a level

that would allow the defendant to post a cash or surety bond, and asks the court to set this matter

for a hearing.

Respectfully submitted,

Exam # 169
Attorney for the State

Copy to the defendant.