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DOCKET NO. FST CR19-0148553-) SUPERIOR COURT DOCKET NO. FST CRi9-0167364-T DOCKET NO. FST CR20-0241178-T STATE OF CONNECTICUT J.D. OF STAMFORD-NORWALK, Vs. AT STAMFORD. MICHELLE TROCONIS JANUARY 19, 2021 The defendant, Michelle Troconis, by and through her attorney, Jon L. Schoenhorn, pursuant to §§ 38-4, 38-13, 38-14, 38-17 and 38-18 of the Connecticut Practice Book; Conn. Gen. Stat. §§ 54-64a and 54-69; the fourth, eighth and fourteenth amendments to the United States Constitution; and Article J, §§ 7, 8, and 9 of the Connecticut Constitution, moves this Court to modify her conditions of release, specifically to terminate the 24/7 electronic and GPS monitoring. This motion incorporates by reference the defendant's memorandum in support of modification of nonfinancial conditions of release filed August 21, 2020. In support hereof, the defendant states as follows: 1. The defendant was first arrested on June 1, 2019 pursuant to an arrest warrant by the Superior Court (Blawie, J.) on Docket No. CR19-0148553-T, and held without bond. On June 3, 2019, she posted a $500,000 bond with surety, and was ordered to comply with special conditions of release that included being fitted with an electronic ankle bracelet and 24/7 GPS monitoring, 2. On September 5, 2019, the defendant presented herself at the Connecticut State Police in Bridgeport on a second warrant signed by the Superior Court (Blawie, J.) on Docket No. CR19-0167364-T and posted the court-ordered bond of $100,000 with surety and was released. ‘The same nonfinancial conditions of release remained in effect. The defendant was arrested a third time on January 7, 2020, pursuant to arrest warrant issued by the Superior Court (Blawie, J.) in Docket No. CR20-0241178-T, held without bail, and subsequently arraigned on January 8, 2020. On this latter date, the Court added an additional $1.5 million monetary bond, which the defendant posted through surety on January 9, 2020. In addition to the previously imposed! GPS condition, the court imposed mandatory drug test participation in the CSSD Alternative Incarceration Program, weekly probation meetings, and 24/7 house arrest with limited exceptions for church, medical appointments, court, and attorney visits, all with prior permission by a probation officer. 4. The $1.5 million is secured with real estate belonging to the defendants mother and sisters. 5. All three cases arise from the same underlying investigation and involve the same alleged acts over the same few days in May of 2019. In every relevant respect, it is one single case charged in three separate multiplicitous criminal informations. 6. InSeptember 2020, the court (Blawie, J.) removed the conditions of house arrest and curfew, but Ieft in place electronic and GPS monitoring and the requirement of prior approval for interstate travel. 7. At all times the defendant has remained compliant with the court’s conditions, including while traveling outside of Connceticut with the court’s prior approval, to be with her family. 8. Pretrial electronic and GPS monitoring serves no further bail purpose at this time, and constitutes both punishment and an unreasonable search and seizure, without due process of Jaw, in violation of the aforesaid federal and Connecticut constitutional provisions. In particular, the defendant is an internationally-rated competitive water skiier and has been prohibited from participating in that sport because the bracelet is not waterproof. In addition, the defendant’s minor daughter is a competitive teenage Alpine Slalom ski athlete and the defendant is unable to accompany her daughter to the race location or ski with her because a ski boot will not fit over the bracelet. 9. Continued electronic and GPS monitoring of the defendant’s whereabouts by CSSD while on pretrial release constitutes an unreasonable search and seizure. 10, The nonfinancial condition of electronic and GPS monitoring is excessive within the meaning of the aforementioned constitutional, statutory and Practice Book provisions. WHEREFORE, the defendant requests this motion be granted and that the electronic and GPS THE ae — MICHELLE TROCONIS. By: Joh L. Schoenhom in L. Schoenhorn & Associates, LLC (08 Oak Street, Hartford, CT 06106 Tel: (860) 278-3500 Fax: (860) 278-6393 Juris No. 101793 casemanagement@schoenhorn.com monitoring condition of release be terminated. ORDER The foregoing motion having been heard by the Court, it is hereby ORDERED, this __ day of » 2021, that the motion be GRANTED / DENIED. BY THE COURT: Superior Court Judge Assistant Clerk CERTIFICATION Thereby certify that a copy of the foregoing was mailed and/or electronically transmitted on the date of this pleading to the following: State's Attomey Bail Services Stamford Superior Court - Part A. Stamford Superior Court 123 Hoyt Street 123 Hoyt Street Stamford, CT 06905 Stamford, CT 06095 Fax: (203) 965-5791 Fax (203) 965-5790