IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT-CRIMINAL DIVISION

PEOPLE OF THE STATE OF ILLINOIS, )

Plaintiff, )
VS. ) Nos. 18 CR 5373 and
) 19 CR 14487
CHARLES THOMAS, )
Defendant. )

MOTION TO SET BAIL BOND

Now comes defendant, Charles Thomas, by and through his attorney,

Alexander Weaver, and in support of his motion to set bail bond pursuant to 725
ILCS 5/110-5, et seq., states as follows:
1. Charles was charged with aggravated assault, damage to property and
escape stemming from psychiatric episodes in April of 2018.
2. All of the alleged offenses are probational.
3. Charles earned an International Baccalaureate Diploma and received a
National Merit Program Achievement Award, as well as other honors, in
high school.
4. Charles was a senior undergraduate student at the University of Chicago
with a GPA of 3.4 and on its rowing team at the time of the first incident.
5. Charles was only first diagnosed with Bipolar 1 Disorder, Manic with
Psychotic Features at Northwestern Hospital immediately after the first
incident.
6. The first incident was his first manic episode.
7. His outpatient psychiatric treatment continued at Northwestern Medicine’s
Mental Health Intensive Outpatient Program.
8. Charles has a history of compliance with his psychiatric treatment plan.
9. However, his medication was not sufficiently effective in October of 2019,
resulting in a second psychiatric episode and incident.
10.The dosage of Charles’ medication was subsequently adjusted.
11. Charles is now stable with medication.
12. His psychiatric conditions are in remission with medication.
13.Charles continues to be compliant with his mental health treatment.
14.There is nothing in Charles’ records to suggest that he is a risk to himself.
15. Charles can reenter Northwestern Medicine’s Mental Health Intensive
Outpatient Program.
16. Charles’ parents have a two-bedroom apartment on the north side of
Chicago in which his father, who works in Chicago, resides and where his
mother frequently stays.
17.Charles’ father is an LPN with an extensive practical professional nursing
background that includes, but is not limited to, caring for patients with
respiratory illnesses.
18. Charles can live in that apartment.
19. Charles never touched anyone or physically harmed anyone.
20. Sheriff Tom Dart recently stated in a Tribune article dated March 17, 2020,
that COVID-19 can easily spread in a confined area.
21.COVID-19 did indeed spread through Cook County Jail.
22.Over one hundred detainees are now infected.
23.The media has reported very bad and medically dangerous conditions.
24.Charles has symptoms of infection by COVID-19 that include, but are not
limited to: a dry cough, fever, loss of taste, loss of smell, and difficulty
breathing.
25.Charles can isolate himself in a spare bedroom within his parents’
apartment.
26.His father, a licensed professional nurse, can care for Charles around the
clock.
27.Charles will be supervised at all times.
28.Charles’ mother is willing to come to Chicago and live with Charles and his
father.
29. Charles does not pose a threat to anyone, including himself, and is not a
flight risk.
 Wherefore, defendant, Charles Thomas requests this honorable court to set
a bail bond that is not oppressive and to grant further just and appropriate
relief, including any reasonable conditions that the court may require.

Respectfully submitted,

_________________________________
Attorney for Charles Thomas, Defendant

Alexander Weaver
Attorney No. 53748
410 S. Michigan Ave., No. 628
Chicago, IL 60605
312-588-5005
violaw@rcn.com