USA v. LOWERESPONSED.D.C.February 23, 2007UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA, : : v. : 06-CR-178 (CKK) : CHAT LOWE : : Defendant. : DEFENDANT’S OPPOSITION TO PROBATION OFFICE’S REQUEST FOR WARRANT Mr. Chat Lowe, the defendant, through undersigned counsel, respectfully requests that this Honorable Court deny the United States Probation Office’s request for a warrant. In support of this request, counsel states: 1. Mr. Lowe’s probation officer has informed undersigned counsel that the Probation Office has asked the Court to issue a warrant for Mr. Lowe based on allegations that he is not in compliance with the conditions of his supervised release. 2. Mr. Lowe respectfully submits that he is in compliance with his supervision. 3. Mr. Lowe is living at the Broward Outreach Center, in Hollywood, Florida, as ordered by the Court. 4. Undersigned counsel has not yet seen the basis for the Probation Office’s request, but believes that the request is based on an allegation that Mr. Lowe is not taking medication that has been prescribed. 5. Mr. Lowe respectfully submits that he has complied with the mental health conditions (and the other conditions) imposed Case 1:06-cr-00178-CKK Document 22 Filed 02/23/2007 Page 1 of 2 -2- by the Court. Moreover, the issue raised by the Probation Office can be resolved without the issuance of a warrant or bringing Mr. Lowe back to the District of Columbia. Rather than bringing Mr. Lowe back to the District of Columbia, the Court could resolve the issues raised by the Probation Office at a hearing where counsel could appear on his behalf and Mr. Lowe could appear by telephone. WHEREFORE, for the foregoing reasons, and such other reasons as may be presented at a hearing in this matter, Mr. Lowe respectfully requests that the Court deny the Probation Office’s request for a warrant and schedule a hearing in this matter at which Mr. Lowe could appear by telephone. Respectfully submitted, A.J. KRAMER FEDERAL PUBLIC DEFENDER /s/ _______________________________ MARY MANNING PETRAS Assistant Federal Public Defender /s/ _______________________________ KETANJI BROWN JACKSON Assistant Federal Public Defender 625 Indiana Avenue, N.W. Suite 550 Washington, D.C. 20004 (202) 208-7500 Case 1:06-cr-00178-CKK Document 22 Filed 02/23/2007 Page 2 of 2
