Blakely Amended Motion For Bond Pending Sentencing

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DOCUMENT 408

ELECTRONICALLY FILED
8/3/2021 1:39 PM
44-CC-2019-000476.00
CIRCUIT COURT OF
LIMESTONE COUNTY, ALABAMA
IN THE CIRCUIT COURT OF LIMESTONE BRAD CURNUTT, CLERK
COUNTY, ALABAMA

STATE OF ALABAMA,

PLAINTIFF,

vs. CASE NO. CC19-476

BLAKELY, MICHAEL ANTHONY,

DEFENDANT.

AMENDED MOTION FOR BOND PENDING SENTENCING

Comes now the Defendant, BLAKELY, MICHAEL ANTHONY, in the above-stated case
and by and through his attorney petitions this Honorable Court to set a Bond for petitioner pending
sentencing. As grounds for this petition the Defendant states as follows:

1. Defendant was arrested on a charges of Theft and Ethics violations.

2. Defendant was found guilty of Theft and Using office for Personal Gain.

4. Defendant respectfully requests a bond pending his sentencing.

5. Defendant has had no other violations and never charged with any other offenses.

7. Defendant has been a lifelong resident of Limestone County, has strong ties and family in
the community. Defendant is not a flight risk. Defendant’s sentencing has yet to be set.

Wherefore, Defendant respectfully requests that this Honorable Court set a bond pending
his sentencing.

Respectfully submitted, this the 2nd day of August, 2021.

/s/ Robert B. Tuten /s/ Marcus Helstowski


ROBERT B. TUTEN (TUT002) MARCUS HELSTOWSKI
ASB # asb-4036-e56r Co-Attorney for Defendant
Attorney for Defendant 223 Eastside Square
TUTEN LAW OFFICES Huntsville, Alabama 35801
256-536-6009 256-534-3018
[email protected] [email protected]











DOCUMENT 408

/s/ Nick Heatherly /s/ Nick Lough


Nick Heatherly Nick Lough
ASB # asb-4036-e56r Co-Attorney for Defendant
Attorney for Defendant 223 Eastside Square
TUTEN LAW OFFICES Huntsville, Alabama 35801
256-534-5049 256-331-1191
[email protected] [email protected]

Of Council:
Mark McDaniel
McDaniel and McDaniel, LLC
223 Eastside Sq
Huntsville, AL 35801
256-534-3018

CERTIFICATE OF SERVICE

This document has been filed electronically and served upon opposing counsel pursuant
to the Administrative Procedure for Filing Signing and Verifying Documents by Electronic
Means in the Alabama Judicial System. For any opposing counsel or unrepresented parties who
are not registered to file electronically, a copy of this pleading shall be served via the U.S. mail,
postage pre-paid, to the litigant’s address as maintained in the office of the Circuit Clerk.

Done this 2nd day of August, 2021.

/S/ Robert B. Tuten


ROBERT B. TUTEN

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