Jared Lockwood Court Documents

8/17/2019 Jared Lockwood Court Documents

1/35

UNITED STATES DISTRICT COURTEASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

UNITED STATES OF AMERICA,

Plaintiff,CRIMINAL NO: 16-20008

vHON. MATTHEW F. LEITMAN

JARED PATRICK LOCKWOOD,a.k.a.“JLocke”

Defendant.

GOVERNMENT’S MOTION TO REVOKEDEFENDANT LOCKWOOD’S BOND

The United States of America respectfully submits this motion to revoke

defendant Jared Lockwood’s bond.

On December 17, 2015, Lockwood was charged in a complaint with receipt,

possession, and access with intent to view child pornography. (R. 1). The

following day, the Defendant was released on bond with a tether. (R. 7). He was

ordered by Magistrate Judge Anthony Patti to comply with the following

conditions, amongst others:

• Continue to actively seek employment;

• Not possess a firearm, destructive device, or other dangerous weapon;

2:16-cr-20008-MFL-DRG Doc # 25 Filed 05/11/16 Pg 1 of 9 Pg ID 88


2/35

2

• Not use or unlawfully possess a narcotic drug or other controlled substance

unless prescribed by a licensed medical practitioner;

• Abide by curfew set by Pretrial Services;

• Submit to Location Monitoring and travel only to locations set by Pretrial

Services;

• Not allow the use of computers or connected devices at home or for

employment purposes at any location;

• Not access the Internet.

The Defendant entered a guilty plea and was convicted of possession of child

pornography on March 24, 2016. (R. 19). The Government has since discovered

evidence that the Defendant has violated each of the above court-ordered

conditions. For that reason and the reasons that follow, the Government requests

that the Defendant’s bond be revoked. The Government concurs with Pretrial

Services’ determination that the Defendant poses a danger to the community and is

a flight risk.

Section 18 U.S.C. § 3143 requires that a person who has been found guilty

of an offense and who is awaiting imposition of a sentence be detained unless the

Court finds, by clear and convincing evidence, that the person is not likely to flee

or pose a danger to the safety of any other person or the community if released.



3/35

3

The Defendant cannot make this showing. The factors the Court considers to

determine whether a Defendant poses a danger and is a flight risk include: the

nature and circumstances of the offense, the weight of the evidence, and the history

and characteristics of the Defendant.

A. Nature and Circumstances of the Offense

Here, the nature and the circumstances of the offense are serious, and the

weight of the evidence is strong (the Defendant has already entered a guilty plea).

The Defendant used the dark web to access and view child pornography. He

possessed 122 images and 73 videos of child pornography. He also downloaded

The Pedophile’s Handbook, a handbook which details “escape” plans for child

exploitation offenders should they get caught by law enforcement. See Govt. Ex.

A, Handbook Excerpt, filed under seal. One of the chapters in the book is entitled

“Security,” and a subsection of that chapter is entitled “Escape Planning.” Id. In

the “Escape Planning” section, the author advises fleeing to the woods if caught.

He writes: “A hidden camp in the woods is a great safe location, and a great

addition to a secret room in your home, being a nice place to hide a fugitive kit

along with even more equipment.” Id. The author also describes how to store

items in “hidden compartments” so that law enforcement will not be able to find

them. Id.



4/35


5/35

5

Heroin Police Report. The Defendant’s girlfriend was present and reported that the

adderall 1 on her person was given to her by the Defendant. Id. Police observed

that it was packaged in a way consistent with sale. Id.

1. Recent Events

Within the last two weeks, authorities learned from two different identified

sources, that the Defendant has been purchasing adderall on a regular basis, while

on pretrial supervision. Pretrial Services reports that 10 out of the last 17 of the

Defendant’s urine samples have been diluted. This is yet another example of

dishonesty and disrespect for the Court.

Furthermore, evidence has surfaced that the Defendant told a known

individual, a friend, that he was going to purchase or had purchased over 500

dollars of camping equipment on Amazon in order to evade authorities and was

planning to fake his own death. In fact, he used that friend’s computer (which he

was prohibited from doing) to look for the equipment. See Ex. C, Screenshots of

Def. Amazon Account. 2 The Defendant used that same friend’s computer on at

1 Adderall is a prescription drug and is used to treat conditions like narcolepsy andADHD. Possible side effects include, but are not limited to: rapid heartbeat, chest

pain or discomfort, anxiety, dry mouth, stomach pain, nausea, vomiting, fever,depression, aggression, mood swings, teeth grinding, numbness, seizures, blurredvision, weakness, headache, and confusion. Taking MAO inhibitors while takingadderall may cause a serious (potentially fatal) drug interaction.

2 At a hearing on May 10, 2016, the Defendant told the Court and said that he hadonly a few items on a “wish list” in his Amazon account.



6/35

6

least three other occasions during the past month to access the internet. He also

told that friend and another acquaintance, known to the Court and to law

enforcement, that he was creating a pipe bomb. He explained that he was going to

plant the pipe bomb at another friend’s home and then tell federal authorities about

the pipe bomb to make it look like he was cooperating and get a lesser sentence.

He threatened to kill them if they told anyone about this. See Govt. Ex. D, May 9

Police Report. 3

Meanwhile, the Defendant was also terminated from his job and failed to

inform Pretrial Services. Because Pretrial Services did not know about the

termination, his curfew hours remained the same. When he finally did tell Pretrial

Services, he asked for permission to work at a friend’s residence on Lance Lane.

He convinced his friend to sign receipts showing he had worked, when in fact, he

had not done any work, nor had he been paid to work there. He then fraudulently

submitted those receipts to Pretrial Services. The Defendant told the Court at a

hearing on May 10, 2016 that he had been to his friend’s house a total of five

times, but the tether data and the Defendant’s friend confirm that he has been over

3 The friend and acquaintance provided specific details about the pipe bomb. Thefriend had seen the Defendant with a PVC pipe with end caps. The Defendant hadasked the acquaintance about black powder for the pipe bomb and had stolen hishack saw. When he confronted the Defendant about why he borrowed the hacksaw without permission, the Defendant said he was using it to cut PVC pipes.



7/35

7

to his friend’s residence a minimum of twelve times in the last month. See Ex.

Govt. Ex. E, Tether Data Summary.

The offense conduct itself is enough to warrant the Defendant’s detention,

especially now that he has entered a guilty plea. The Defendant’s Guidelines are

87-108 months, and the parties have agreed on a 36 month floor. Despite his

criminal history and the lengthy sentence he is facing, the Court took a chance on

this Defendant and gave him the opportunity to spend the months leading up to

sentencing at home. Instead of taking advantage of that opportunity, the Defendant

has squandered it in every way possible. He has not been honest with Pretrial

Services, the Court, or law enforcement. He has purchased prescription drugs

(with potentially fatal side effects if used incorrectly), frequented locations where

he was not permitted to be, used electronic devices to access the internet, and made

plans to escape. Worse, he has admitted that he is plotting to frame a friend for

possessing a pipe bomb that he himself has either designed or plans to design.

Lockwood’s end-goal was to mislead law enforcement and the Court into thinking

he provided valuable cooperation and prevented an imminent threat from

materializing.

The witnesses that have come forward to reveal this information to the

Court, and to provide the tangible evidence that is attached to this motion, have put

themselves at risk in order to prevent greater harm to the public. The Defendant



8/35

8

poses a danger to each one of them, to himself, and to the community. He is also

clearly a flight risk. The Government requests that his bond be revoked.

Pursuant to the local rule, the government sought defense counsel’s

concurrence in this motion, but was unable to obtain it.

BARBARA L. McQUADEUnited States Attorney

s/April N. Russo

April N. RussoAssistant United States Attorney211 W. Fort Street, Suite 2001Detroit, MI 48226Phone: (313) 226-9129E-Mail: [email protected]

Dated: May 11, 2016



9/35

Certificate of Service

I hereby certify that on May 11, 2016, I electronically filed the Motion to

Revoke Bond with the Clerk of the Court of the Eastern District of Michigan using

the ECF system which will send notification of such filing to the following via

electronic mail. I also certify that I mailed a copy of the sealed exhibit A to the

following:

Richard O’NeillAttorney for Jared Lockwood

Federal Defender’s Office513 Abbott Street, 5 th FloorDetroit, MI 48226

s/April N. RussoApril N. RussoAssistant United States Attorney211 W. Fort Street, Suite 2001Detroit, MI 48226Phone: (313) 226-9129E-Mail: [email protected]



10/35

INDEX OF EXHIBITS

Exhibit: Description

A Handbook Excerpt (filed under seal)B Heroin Police ReportC Def. Amazon AccountD May 9 Police ReportE April 18-May 9 Tether Summary

2:16-cr-20008-MFL-DRG Doc # 25-1 Filed 05/11/16 Pg 1 of 1 Pg ID 97


11/35

EXHIBIT A

FILED UNDER SEAL



12/35



13/35



14/35



15/35



16/35



17/35



18/35



19/35



20/35



21/35



22/35



23/35



24/35



25/35



26/35



27/35



28/35



29/35



30/35



31/35



32/35



33/35



34/35



35/35


Jared Lockwood Court Documents

Documents

Transcript of Jared Lockwood Court Documents