The Honorable Richard E. Jordan granted the unprecedented and extraordinary relief requested by this office to dismiss the Indictment against our client for pre-indictment delay. No court in the United States had granted such relief without state action being the cause of the pre-indictment delay. Our client was unaware of any allegations against him for approximately 26 years, from the date of the allegations. The Complaining Witness did not report, for approximately 26 years, any inappropriate contact between herself and her former boyfriend to the police for reasons only known to the Complaining Witness. Our client had moved from the Washington Metropolitan area to the Southern regions of the United States. Our client made no attempt to contact the Complaining Witness for approximately 26 years. The Complaining Witness was encouraged to try to call our client to get him to inculpate himself. However, try as the police might have, our client never in any sense admitted to any inappropriate contact in the recorded telephone sting orchestrated by the Police Department. Our client was arrested and extradited to Maryland only on the statements of the Complaining Witness without the slightest corroboration of her clearly stale allegations. Our client spent a considerable amount of time incarcerated in the Montgomery County Detention Center before he was referred to us for relief. We secured our client an immediate bond hearing and he was released by the Circuit Court for Montgomery County pending trial.
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