FILED Aye 042 DEPUTY CLERK OF COURT ‘CADDO PARISH STATE OF LOUISIANA * DOCKET NOS.: 350977 & 351006 VERSUS - 18" JUDICIAL DISTRICT COURT BING BING LI AND LINAN TIAN * CADDO PARISH, LOUISIANA MOTION TO REDUCE BAIL NOW INTO COURT, through undersigned counsel, comes the defendants, BING BING LI, “LI” AND LINAN TIAN “TIAN”, and move this court for a bail reduction for the following reasons. 1 “Li? and “Tian” are owners of Palm Massage on East 70% Street in Shreveport, Louisiana. On July 21,2017, they were arrested by agents from the Louisiana State Police and each were charged with two counts in violation of LA. R.S. 14:46.2. In addition, agents seized all of the assets of “LI” and “TIAN”. This action left them destitute and unable to post any substantial bail without assistance of family members living in China. 2 “Tian” is a United States Citizen and “Li” is the holder of a green card allowing her presence in the United States. 3 Neither “Tian” or “Li” have ever been arrested for any crime either in China or the United States. They have no prior convictions. 4 “Tian” and “Li” are married and have been in the massage parlor business for several years, ‘They moved their business to Shreveport last year and have developed a customer base that can and will attest to the good character of “Tian” and “Li”.5. The agents also seized all business documents of “Tian” and “Li”, These documents including instructions for employees; contracts of employment; purchases from vendors; tax documents and other materials that establish the validity of the business operated by “Tian” and “Li”. 6 “Tian” and “Li” have no history of illicit drug use. 2. “Tian” and “Li” are not flight risks. They live in this community and currently own two businesses. 8. Neither “ jan” and “Li” present a threat of danger to the community. Both are hardworking individuals, who regularly send a large portion of their carnings back to their families in China in order financially to support them. They are assets to this, community; hard working tax payers who ask nothing more than to be able to work and carn a decent living." 9 The employees of that work establishment of “Tian” and “Li”, Aihua Tang, Yan Quing Yin, Liu Ying Wei and Xve Mei Wang, all have a least 720 hours of training and are licensed in several other states. ‘These are professionals and do not engage in criminal activity. Though characterized as “victims”, the state seized their assets rendering them completely indigent and without funds to live. 10. ‘The next court date is August 28, 2017. The defendants are financially unable to make the current bail. Counsel requests that a bail reduction hearing be set without undue delay and, after due hearing, the bail be reduced to $20,000 for each of the defendants. 1 Asa result of the agents seizure of their assets, both businesses are closedCounsel further prays for all full and equitable relief, as may be necessary in the premises, Respectfully submitted, STROUD, CARMOUCHE & BUCKLE P.L.L.C. By: 7B Cd a ‘AM Stroud, Ill, Bar #12548 7330 Fern Avenue, Suite 903 Shreveport, La. 71105 Phone: (318) 629-0014 Fax: (318) 404-1571 ATTORNEY FOR BING BING LI AND LINAN TIANCERTIFICATE OF SERVICE 1 HEREBY CERTIFY that a copy of the above and foregoing has been this date emailed and placed in the United States mail, properly addressed, with proper postage > affixed, to Caddo Parish District Attorney, 501 Texas Street, Shreveport, LA 71101 rs »STATE OF LOUISIANA * DOCKET NOS.: 350977 & 351006 VERSUS - 18T JUDICIAL DISTRICT COURT BING BING LI AND LINAN TIAN * CADDO PARISH, LOUISIANA ORDER ‘The foregoing Motion to Reduce Bail having been considered, IT IS HEREBY ORDERED that the State of Louisiana show cause on 017 at a.m./p.m., as to why the bail of BING BING LI AND LINAN TIAN should not be reduced, THUS DONE AND SIGNED in Shreveport, Caddo Parish, Louisiana, on this day of , 2017 FIRST JUDICIAL DISTRICT JUDGE