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Filed19February18P4:25

MarilynBurgess-DistrictClerk
HarrisCounty
EA001_249730
By:DSANCHEZ
CAUSE NO. 1620385; 1620384; 1620726

STATE OF TEXAS § IN THE 230th DISTRICT COURT


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v. § OF
§
JARED TREVINO § HARRIS COUNTY, TEXAS

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STATE’S MOTION FOR HIGH BOND AND BOND HEARING

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TO THE HONORABLE JUDGE OF SAID COURT:

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COMES NOW THE STATE OF TEXAS, by and through its ASSISTANT DISTRICT

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ATTORNEY, SEAN TEARE, in the above styled and numbered cause, and files this Motion for

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High Bond and Bond Hearing based on the following:

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The defendant, Jared Trevino, is currently charged with the following offenses:
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1) Class A Misdemeanor Burglary of a Motor Vehicle in Cause Number 2245580,
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2) Second Degree Felony Burglary of a Habitation in Cause Number 1620385,


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3) State Jail Felony Unauthorized Use of a Motor Vehicle in Cause Number 1620384, and
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4) First Degree Felony Murder in Cause Number 1620726.


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On February 3, 2019, the defendant broke into William Bingham’s truck that was sitting in his
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driveway in order to use the garage door opener in the truck to gain access to Mr. Bingham’s
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residence. The defendant then entered Mr. Bingham’s residence without his knowledge and
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consent and stole the keys to Mr. Bingham’s Honda Accord. The defendant then took Mr.
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Bingham’s Honda Accord without his knowledge or consent.


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While operating Mr. Bingham’s Honda Accord without his consent, the defendant ran the red
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light at Spencer Highway and Preston Road, striking Lorenzo Gomez’s Cadillac Deville. Mr.
Gomez was transported to Bayshore Medical Center for skull fractures, rib fractures, and a brain
bleed. Mr. Gomez remained intubated and in critical condition until doctors at Bayshore
Medical Center declared Mr. Gomez brain dead on February 5th.
Mr. Gomez’s family made the decision to take Mr. Gomez off life support on Wednesday
February 6th and Mr. Gomez was declared deceased at 6:30PM on February 6th.

The Pasadena Police Department has the following extraneous offense reports involving the
defendant, Jared Trevino, and is summarized as follows:

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1) Case number 17-025503: On November 24, 2017, the defendant, 17 years old at the time,

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stole a Nissan Sentra, belonging to Felipe Chavajay (an employee of the defendant’s

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mother at the time), that was parked in the defendant’s driveway and crashed into a

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Chevrolet Silverado truck belonging to Vanessa Castillo. The defendant then fled the

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scene in the Nissan Sentra and then crashed into a Ford Ranger belonging to Jorge

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Garcia.

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2) Case number 17-026177: On December 3, 2017, the defendant, 17 years old at the time,
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stole his neighbor William Bingham’s Honda Accord, the same Honda Accord used in
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the present offense, and crashed into the back of trailer at a red light. The defendant
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admitted to breaking into Bingham’s house and taking the keys to the car off his kitchen
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counter. The defendant’s mother admitted to Pasadena police officers that the defendant
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has autism, but only takes medications for ADHD. The defendant’s mother also stated
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that the defendant has taken vehicles in the past that had the keys readily available.
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3) Case number 18-005269: On March 11, 2018, the defendant 17 years old at the time, was
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transported to Bayshore Hospital to prevent him from causing harm to himself or other
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under an Emergency Detention Order.


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The State has further extraneous offenses, submitted as Exhibit A, that the State would like the
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Court to consider in camera and will remain under seal in the Clerk’s File.
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The aforementioned incidents indicate a lack of adequate supervision which would ensure the
defendant would comply with his bond conditions.

The State has sincere concern for the safety of the public. Pursuant to this concern and also U.S.
v. McConnell, 842 F.2d 105, the State requests a high bond in order to secure the defendant’s
presence at trial and also for public safety concerns. The State also requests a hearing on the
bond in the above-entitled Cause Numbers so that the State may call witnesses and present the
Court with evidence in support of its position for a high bond.

WHEREFORE PREMISES CONSIDERED, THE STATE PRAYS that the Honorable

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Court set a high bond for this defendant and/or set this case for a hearing regarding the bond in

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the above-entitled Cause Number.

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Respectfully submitted,

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/s/ Sean Teare
Bu Sean Teare
Assistant District Attorney
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Harris County, Texas
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P: 713-274-5658
Teare_sean@dao.hctx.net
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State Bar No. 24054113


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The undersigned Assistant District Attorney, Sean Teare, solemnly swears that the
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allegations contained in the foregoing Motion are true and correct.


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/s/ Sean Teare


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Sean Teare
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Assistant District Attorney


Harris County, Texas
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P: 713-274-5658
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Teare_sean@dao.hctx.net
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State Bar No. 24054113


CERTIFICATE OF SERVICE

I, the undersigned attorney, hereby certify that a true and correct copy of the above
foregoing motion was sent via facsimile, email, certified mail and/or hand delivery to Defense
Counsel, JOE VINAS, on this 18th day of February 2019.

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/s/ Sean Teare

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Sean Teare
Assistant District Attorney

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Harris County, Texas

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P: 713-274-5658
Teare_sean@dao.hctx.net

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State Bar No. 24054113

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CAUSE NO. 1620385; 1620384; 1620726

STATE OF TEXAS § IN THE 230th DISTRICT COURT


§
v. § OF
§
JARED TREVINO § HARRIS COUNTY, TEXAS

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ORDER

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Having duly considered the foregoing Motion for High Bond and Bond Hearing, said

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Motion is hereby GRANTED. It is also ordered that the above cause be continued for the reason

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therein stated.

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SIGNED on the ______ day of ______________________, 2019.
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__________________________________
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Honorable Judge
230th District Court
of

Harris County, Texas


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