NORTH CAROLINA

GUILFORD COUNTY

IN THE GENERAL COURT OF JUSTICE
SUPERIOR COURT DIVISION
97 CrS 39580

STATE OF NORTH CAROLINA,
vs.
RONNIE KIMBLE,
Defendant.

MOTION FOR THE COURT TO SET TERMS OF PRETRIAL RELEASE 15A-533(c) and 534

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 arrest.

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.

7. The 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 repay them.

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 maintenance.

9. Although the defendant's guilt or innocence is not an issue in this motion, the defendant respectfully points out to the court the following:

(a) The defendant and his family have fully cooperated with the investigation of the case and have given complete statements to the investigators;
(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 else.

10. If 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 difficult period.

This the 4th day of April, 1997.
 

HATFIELD & HATFIELD

By:  /signature/

John B. Hatfield, Jr.

Attorney for Defendant

219 W. Washington Street

Greensboro, NC 27401
(910) 273-0589

Consented to:

/signature/

Ronnie Kimble

CERTIFICATE OF SERVICE

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.

District Attorney
Guilford County Courthouse

Greensboro, NC
 

This the 18th day of April, 1997.

/signature/

John B. Hatfield, Jr.

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