Sample complaint for fraudulent transfer in California
mtaylorbailmotion
1. Howard, Fine & Howard
Larry Fine, Esquire
Attorney ID# 28018
1700 Market Street, 12th Floor
Philadelphia, Pennsylvania 19103
215-905-9456
_______________________________________
:
COMMONWEALTH OF PENNSLYVANIA
v.
Avi Panzer
:
: PHILADELPHIA COUNTY
: MUNICIPAL COURT
:
: CRIMINAL TRIAL DIVISION
:
:M.C. No. 51-CR0012345-2010.
_______________________________________ :
ORDER
AND NOW, this 28th day of October, 2015 upon consideration of Defendant’s motion to
reduce bail and the response thereto it is hereby ORDERED ADJUDGED AND DECREED that
Defendant’s motion is granted and that bail is hereby reduced to _____________________.
BY THE COURT:
__________________________
J.
2. Howard, Fine & Howard
Larry Fine, Esquire
Attorney ID# 28018
1700 Market Street, 12th Floor
Philadelphia, Pennsylvania 19103
215-905-9456
_______________________________________
:
COMMONWEALTH OF PENNSLYVANIA
v.
Avi Panzer
:
: PHILADELPHIA COUNTY
: MUNICIPAL COURT
:
: CRIMINAL TRIAL DIVISION
:
:M.C. No. 51-CR0012345-2010.
_______________________________________ :
MOTION TO REDUECE BAIL
TO THE HONORABLE, THE JUDGES OF THE SAID COURT:
Defendant, Avi Panzer, and his attorney Larry Fine, Esquire, move this court to reduce
bail, and represent:
1. On or about August 12, 2010, the defendant was arrested and a complaint was filed charging
him with robbery.
2. The issuing authority set bail at $75,000.00.
3. The bail is excessive and unnecessary for the following reasons:
a. Defendant is 22 years old and lives at 300 Valley Drive, Philadelphia, Pennsylvania
19105;
b. Defendant is a lifelong resident of Philadelphia County;
3. c. Defendant denies the charges against him and will plead not guilty at trial;
d. There is no evidence that defendant represents a physical danger to the community;
e. There is no evidence of risk of flight; and
f. At the hearing, the robbery charge, with a bail guide line range of $5,000.00 to
$18,000.00, was dropped and replaced with a charge of theft.
4. The defendant is unable to post $75,000.00 bail and he is therefore denied release because of
his economic status.
5. The bail guidelines for the current change against the defendant range from $1,000.00 to
$3,000.00.
WHEREFORE, the defendant Avi Panzer respectfully requests that a hearing be set on
this motion and that after hearing bail be reduced to the guideline range from $1,000.00 to
$3,000.00.
Respectfully submitted,
__________________________
Larry Fine
Attorney for Defendant
4. VERIFICATION
I, LARRY FINE, Esquire verify that the statements made in the within pleading are true
and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.
C.S. Section 4904 relating to unsworn falsification to authorities.
__________________________
LARRY FINE
DATED: __________________________