DOCUMENT 410

ELECTRONICALLY FILED
8/3/2021 1:49 PM
44-CC-2019-000476.00
CIRCUIT COURT OF
LIMESTONE COUNTY, ALABAMA
BRAD CURNUTT, CLERK
IN THE CIRCUIT COURT OF LIMESTONE COUNTY, ALABAMA

STATE OF ALABAMA,

PLAINTIFF,

vs. CASE NO. CC19-476

MICHAEL ANTHONY BLAKELY,

DEFENDANT.

_________________________________________________________________________

RESPONSE TO STATE’S OPPOSITION TO BOND

_________________________________________________________________________

COMES NOW Michael Anthony Blakely, and responds to the State’s

Opposition to Bond which was filed on this date, and, respectfully shows unto the Court

as follows:

1. Contrary to the State’s position, it is customary for convicted individuals to

remain on bond, or to be given a new bond subsequent to finding of guilt,
and prior to the sentencing of a defendant in Limestone County, Alabama.

2. Specifically, in State v. Patterson, CC2019-729, Mr. Patterson entered a plea

of guilty to the crimes in which he was charged. Upon his plea of guilt, Mr.
Patterson was convicted of the crimes in which he was charged. Mr.
Patterson was not immediately taken into custody. Mr. Patterson was
allowed to remain on bond, pending the sentencing which was held at a
later date. Specifically, Mr. Patterson entered a plea of guilty on or about
October 30, 2020, and was subsequently sentenced on or about December 8,
2020. Subsequent to the plea, and prior to the sentencing, Mr. Patterson was
afforded the opportunity to remain on bond, and was not taken into
custody.

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 DOCUMENT 410

WHEREFORE, PREMISES CONSIDERED, the Defendant prays this Honorable

Court will deny the State’s Opposition to Bond, and grant him bond in this matter.
Respectfully submitted on this the 3rd day of August, 2021.

/s/ Robert Tuten /s/ Nickolas R. Heatherly

_________________________________
ROBERT TUTEN (TUT002) NICKOLAS R. HEATHERLY (HEA042)
Attorney for Defendant Attorney for Defendant
223 East Side Square 223 East Side Square
Huntsville, AL 35801 Huntsville, AL 35801
Telephone: (256) 536-6009 Telephone: (256) 534-5049

/s/ Marcus Helstowski /s/ Nicholas D. Lough

_____________________________
MARCUS HELSTOWSKI (HEL024)
Attorney for the Defendant
223 East Side Square
Huntsville, AL 35801
Telephone: (256) 534-3018
___________________________________
NICHOLAS D. LOUGH (LOU005)
Attorney for the Defendant
223 East Side Square
Huntsville, AL 35801
Telephone: (256) 432-7573

CERTIFICATE OF SERVICE

I certify that I have filed the foregoing with the Clerk of the Court using the
Alabama Judicial System electronic filing system which will send notification of such filing
to those parties of record who are registered for electronic filing, and further certify that
those parties of record who are not registered for electronic filing have been served by mail
by depositing a copy of same in the United States mail, first class postage prepaid and
properly addressed, on this the 3rd day of August, 2021.

/s/ Marcus Helstowski

________________________
Marcus Helstowski

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