USA v. CAO et alMOTION For An Independent ReviewS.D. Ind.October 11, 2013IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION UNITED STATES OF AMERICA, Plaintiff v. GUOQING CAO, Defendant ) ) ) ) ) ) ) ) ) Cause No: 1:13-cr-00150 WTL-TAB-01 MOTION FOR AN INDEPENDENT REVIEW Defendant Guoqing Cao, by counsel and pursuant to 18 U.S.C. §3145(b), respectfully moves the Court for an independent review of the order of detention issued by the magistrate judge, and in support states: 1. Mr. Cao was arrested and charged first by indictment and subsequently by a superseding indictment with theft of trade secrets, conspiracy, and aiding and abetting in the same. 2. Following a hearing before U.S. Magistrate Judge Dinsmore on October 9, 2013, Mr. Cao was ordered detained without bond. 3. Mr. Cao requests that this Court make an independent determination regarding the issue of his pretrial release. See, United States v. Portes, 786 F.2d 758, 761 (7th Cir. 1985). The motion shall be determined promptly. 18 U.S.C. §3145(b). 4. Mr. Cao will submit a brief in support of his request for pretrial release as expeditiously as the Court requires. Case 1:13-cr-00150-WTL-TAB Document 40 Filed 10/11/13 Page 1 of 2 PageID #: 153 WHEREFORE, defendant Guoqing Cao requests that the court conduct an independent review of the detention order and enter an order releasing Mr. Cao subject to conditions established by the Court. Dated: October 11, 2011 Respectfully submitted, /s/ David J. Hensel David J. Hensel, Attorney No. 15455-49 PENCE HENSEL LLC 135 N. Pennsylvania Street, Suite 1600 Indianapolis, Indiana 46204-2428 Telephone: (317) 833-1111 Fax: (317) 833-1199 Alain Leibman (pro hac vice pending) FOX ROTHSCHILD LLP Princeton Pike Corporate Center 977 Lenox Drive, building 3 Lawrenceville, NJ 08648-2311 Telephone: (609) 895-6743 Fax: (609) 896-1469 Attorneys for Guoqing Cao CERTIFICATE OF SERVICE I hereby certify that on the 11th day of October, 2013, I electronically filed the forgoing with the clerk of the court by using the CM/ECF system. Notice of this filing will be sent to the following parties by operation of the Court’s electronic filing system. Parties may access this filing through the Court’s system. Cynthia A. Ridgeway Assistant United States Attorney Cynthia.ridgeway@usdoj.gov Scott C. Newman Attorney at Law scott@scottnewmanlaw.com _/s/ David J. Hensel______ Case 1:13-cr-00150-WTL-TAB Document 40 Filed 10/11/13 Page 2 of 2 PageID #: 154
