Defense Motion for the Court to set terms
of Pretrial Release for Ronnie Kimble
IN THE GENERAL COURT OF JUSTICE
SUPERIOR COURT DIVISION
97 CrS 39580
STATE OF NORTH CAROLINA,
MOTION FOR THE COURT TO SET TERMS OF PRETRIAL RELEASE 15A-533(c) and
COMES NOW the defendant, through the undersigned, his privately
retained counsel, and respectfully shows the court the following:
I. The defendant is charged with capital murder and has entered a
plea of not guilty.
2. The defendant is a life-long resident of Guilford County and was
on active duty in the United States Marine Corps at the time of his
3. The defendant has no criminal record and has led an exemplary
life since he married his wife, Kimberly Stump Kimble.
4. The defendant is a sincere and active member of a church and was
assigned to the chaplain's office at Camp Lejeune, North Carolina,
where many of his coworkers recognized his good nature, kindness,
sense of responsibility and reliability.
5. The defendant and his wife own a mobile home in which the
defendant can live pending trial. The mobile home is in close
proximity to the home of his mother and father in law, James and
Judy Stump. Mr. and Mrs. Stump are able and willing to assist the
court in a partial custodial release of the defendant to them.
6. If the defendant is granted terms of pretrial release, and if the
defendant is deemed ineligible to return to active duty in the
Marine Corps, the defendant has substantial gainful employment
available to him in Guilford County.
defendant is indigent within the meaning of the law and has accepted
retained counsel provided by James and Judy Stump. The defendant
owes a tremendous debt to the Stumps and desires to begin trying to
8. The defendant's wife, Kimberly Stump Kimble, has recently learned
that she is pregnant and it would be helpful to her if the defendant
could live with her and work so that he can assist in her care and
9. Although the defendant's guilt or innocence is not an issue in
this motion, the defendant respectfully points out to the court the
defendant and his family have fully cooperated with the
investigation of the case and have given complete statements to
(b) The defendant has remained of general good behavior during
the period of the investigation of this case;
(c) The defendant has a credible alibi for his whereabouts at
the time the decedent was murdered;
(d) The defendant had no motive whatsoever to commit this crime
and was not in need of money from the codefendant or anyone
granted pretrial release, the defendant would willingly submit to
electronic monitoring, a curfew, drug testing and other
restrictions. The defendant desires to exercise his constitutional
right to assist in the preparation of this defense. The defendant
has developed a good working relationship with his counsel, John B.
Hatfield, Jr., and desires to continue to assist him.
WHEREFORE, the defendant respectfully prays that the court set a
reasonable secured bond together with appropriate restrictions to
permit the defendant to live with and assist his wife during this
This the 4th
day of April, 1997.
I hereby certify that a copy of the foregoing Motion was served upon
the State by hand-delivering a copy thereof to:
Mr. Horace M. Kimel, Jr.
Guilford County Courthouse
18th day of April, 1997.
John B. Hatfield, Jr.