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Filing # 144966796 E-Filed 03/03/2022 09:30:03 AM
`
`IN THE COUNTY COURT OF THE FIFTEENTH JUDICIAL CIRCUIT,
`IN AND FOR PALM BEACH COUNTY, FLORIDA
`CRIMINALDIVISION “DVTD”
`
`State of Florida,
`
`VS.
`
`Delmis Nathaly Manzaneira
`Defendant.
`
`/
`
`CASE NO.’s: 21MM005673AMB
`21MM006218AMB
`
`Motion to Reinstate Manzaneira’s Bond and Release Her on SOR Level IV
`
`Delmis Nathaly Manzaneira movesfor her release on SOR Level IV pursuant to Florida
`
`Rule of Criminal Procedure 3.131(d). Manzaneira is in custody becausesheis held no bond. The
`
`State cannot prove that no bondis neccesarry.
`
`Facts
`
`Manzaneira remains in jail because her bond was revoked. The police arrested her on
`
`October 22, 2021 for Disorderly Intoxication, Possession of Cocaine, Trespass, and Carrying a
`
`Concealed Weapon!. The State, however, only filed an infromation for Possession of Cocaine and
`
`Unlicensed Carrying a Concealed Weapon.
`
`On November3rd, 2021, the State filed a Motion to Revoke Bond. Then, on December6,
`
`2021, the Court granted the State’s motion and revoked Manzaneira’s bond in case numbers
`
`21MMS5673 and 21MM6218. About three monthslater, on March 2nd, 2022, Manzaneira pled out
`
`time served to Posession of Paraphanelia and Unlicensed Carrying of a Concealed Weapon — both
`
`first degree misdemeanors’.
`
`1 See Case Number 2021-CF-008680.
`
`2 See Court Event Form, Docket Entry Number 114in the above felonycase.
`
`FILED: PALM BEACH COUNTY,FL, JOSEPH ABRUZZO, CLERK, 03/03/2022 09:30:03 AM
`
`

`

`Argument
`
`Manzaneira is entitled to pretrial release on reasonable conditions. Fla. R. Crim. P.
`
`3.131(a). The State cannot prove that no bondis necessary to achieve her presenceattrial or at
`
`other proceedings, to protect the community from risk of physical harm,to assure her presenceat
`
`trial, or to assure the integrity of the judicial process. See § 907.041(3)(a), Fla. Stat.
`
`Manzaneira Has Ties to The Community
`
`Manzaneira is 24 years old and a mother of two children — a four year old daughter and a
`
`one year old son. She lived in Palm Beach County since 2016. She graduated from Forest Hill
`
`Highschool in 2017. Before the police arrested her, she worked for a cleaning company around
`
`Palm Beach County. She had that job for about a year. She also attended beauty school so that she
`
`can become a nail techinician. Her stepmother lives in Lake Worth and her son’s father lives in
`
`Palm Beach Gardens.
`
`Manzaneira is a Loving and Caring Mother
`
`Back on October, 2021, DCF assessed that both children are “safe in the care of the mother
`
`... and has sufficient caregiver protective capacities to ensure the children’s safety and wellbeing.”
`
`See Attached DCF Report. Furthermore, DCF submitted another report dated March 2nd, 2022,
`
`which concluded that “[t]he children ... [are] safe to be in the mother Delimis’s care”. Jd. The
`
`report also shines light on the alleged victim.
`
`

`

`Manzaneira Respects the Integrity of the Judicial Process
`
`Manzaneira has not missed a single court date. She appeared when a warrant was issued
`
`for her arrest? and when the State filed their Motion to Revoke Bond*. This showsthat she can
`
`follow court instructions andis not a flightrisk.
`
`Conclusion
`
`The State cannot show that no bondis necessary to assure Manzaneira’s presence in court,
`
`to protect the community from risk of physical harm, or to assure the integrity of the judicial
`
`process. Because sheis entitled to pretrial release on nonmonetary conditions, she requests this
`
`Court reinstate her bond and release her on SOR LevelIV orin the alternative set a monetary bond
`
`plus SOR LevelIV.
`
`Respectfully submitted,
`
`CAREY HAUGHWOUT
`Public Defender
`Fifteenth Judicial Circuit
`421 Third Street
`West Palm Beach, FL 33401
`(561) 355-7500
`
`
`
`
`
`Isai Bonilla
`Assistant Public Defender
`Bar No.: 1028212
`
`3 See Docket Entry # 64, Case Number 2021-MM-005673.
`
`4 See Docket Entry #66, Case Number 2021-MM-005941.
`
`

`

`CIRCUIT 15 Judicial -DOMESTIC VIOLENCEDiVISION-
`
`_
`
`INFORMATION AS REQUESTEDFROM THEDEPARTMENTOFCHILDREN
`AND FAMILIES.
`
`seo eeVacccsecsosaccoces
`
`HEARING: Motn. to Mod. NCO- MANZANEIRA
`Case No.ZINIMOOEZIS
`Hearing Date: lobeser
`
`PETITIONERRELMNS,NAa
`RESPONDENT: MAQURICEALEXANDER
`Children:
`NLM.po. 3-24-2017
`
`D.O.B..$6.21!4G70
`| D.O.B..2:.28:.1984...
`“
`€.:A:.....D.0.B 5:.05:2020
`
`ievernveveeteseee D/OLB.cesseseessseess a vanneeeenneees D.O.B,.wees ceeees
`
`4h
`=<
`DCF case: opened onulyZ>.202).
`
`DCF Recommendations:
`
`Closed
`DCF case status: Seeh.22nd.202)
`Zo2i- 22333}
`
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`
`hth eee hddteat OSITLL LALIT TTSTETTTT Treen
`
`SealadsaSS__
`/ Neela Dass-DCF-DV Liaison/ 561 662 3682
`~neelasass@muflCamilieSeCom
`
`

`

`CIRCUIT 15 Judicial -DOMESTIC VIOLENCE DIVISION-
`=
`
`
`INFORMATION AS REQUESTEDFROM THEDEPARTMENTOFCHILDREN
`AND FAMILIES.
`Date: Man.2ri.2022
`
`HEARING: Motn. to Mod. NCO- Manizaneiea
`_ Case No.zAMMeRS673...
`Hearing Date: iund]y..
`;
`Advi
`
`D.O.B....J4:.Bi.IALT
`PETITIONERAPELIYANS,PIANZANEIRA
`D.0.B..4:.08.1484,
`RESPONDENT: TARMRICE,.LMCAS
`Not Bio~- Fa chn) a
`Children:
`;
`NM_.p.0.8 Bu207TD.O.B sesssssssssneseee
`
`HeeDOB
`
`aceeeneeneee D.O.B. coccscecsecseeees
`
`DCF case: opened ontttly24,2021
`
`DCF case status:2PT.2%.2021
`
`hn
`
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`Some time. Maurice cid this To Erovolse “Delmis-on purpose.
`Maurice is nor the bio-father fe the children.
`WeelaDdass
`/ Neela Dass-DCF-DV Liaison/ 561 662 3682
`~neelaslass@muFlCamilieSaCom
`
`

`

`CERTIFICATE OF SERVICE
`
`I certify I served this motion to Samuel Farot, Assistant State Attorney, Division “DVTD”
`
`ORthe Assistant State Attorney currently assigned in STACatthe time offiling, via the STAC
`
`case management exchange on this 2nd day of March, 2022.
`
`
`
`
`
`Isai Bonilla
`Assistant Public Defender
`
`

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