Two motions were filed on Tuesday in the Douglas Perlitz ’92 case in preparation for his detention hearing on Wednesday Oct. 28.

Memorandum in Further Support of Release on Bond

The first motion, filed by Perlitz’s lead attorney, William F. Dow III, submits a revised proposal for Perlitz’s release. The initial proposal included a bond secured by four parcels of real estate owned by Perlitz’s mother, brother and step-father, appraised at a value between $1.9 and $2.3 million.

In the memorandum filed Oct. 27, Dow says: “Defendant has secured commitments from approximately 19 additional individuals or couples … Most of these commitments are for $100,000; some are considerably higher, as high as $325,000. The total of the commitments from Connecticut residents is approximately $1.1 million; the total of the commitments from out-of-state residents is approximately $1.8 million.”

Dow also says they are prepared to submit paperwork “demonstrating that these individuals are people of fine standing within the community, as well as of sufficient financial means that their commitments are meaningful.” However, he asks the court to keep the information private.

At the first hearing, Anthony and Laura Sirianni volunteered to become third-party custodians for Perlitz if he were to be released. Dow now proposes a group of “back-up” custodians who would be called upon if the Siriannis had to leave their home.  A member of the local bar has also volunteered to serve as the coordinator for this group.

Dow concludes by writing, “Defendant submits that this custodial monitoring arrangement, coupled with the other monitoring – both electronic and GPS-based – to be ordered by the Court will provide sufficient assurance that Mr. Perlitz will not flee if released, or otherwise pose any threat to any member of the community.”

Government’s Supplement Memorandum in Support of Motion to Detain

The government responded with a motion of its own to refute the notion that Perlitz should be released.

“In short, Douglas Perlitz should remain detained because there are simply no set of conditions that can ensure that he will not be a danger to the community or that he will not flee prior to the trial,” the memorandum submitted by United States Attorney Nora. R. Dannehy and by Assistant United States Attorney Krishna R. Patel.

The government refuted the additional money raised by Perlitz because they would be executing a non-surety bond, which allows a signature alone to guarantee the amount.  The government wants each individual to post collateral so that the government is able to place liens on the property or money.

The government also objected to the use of 12 back-up custodians to the Siriannis. The government’s memorandum said, “The government understood that the Court was requesting additional guardians to supplement – not act as back-up guardians – for the Sirrianis [sic].” The government would also like to see the Siriannis post some collateral so they have incentive to monitor Perlitz. It also argued that the use of 12 rotating back-ups was “absurd.”

The memorandum goes on to says: “The Government has provided the Court with information that the defendant was: (a) telephonically communicating with individuals in Haiti up until his arrest; (b) that he was wiring money to individuals in Haiti which the Government believes was done to buy the silence of additional children; and (c) that defendant instructed other individuals here in the United States to assist by taking actions to frustrate the Haiti Fund’s investigation of Perlitz’s conduct.”

The government also argues that there has never been a case involving federal charges of hands-on abuse where the defendant was released in this District.

The government also provided additional information for the Court to consider in making the decision whether or not to release Perlitz. Attached to it memorandum was “Exhibit A,” which features very preliminary findings by an ICE forensic examiner relating to a computer found from Perlitz at the time of his arrest in Colorado.

Perlitz visited websites such as:

Also, the document stated, “Numerous (over 100+) image files depicting nude black males were recovered. Many of these files depicted younger-looking black males engaged in graphic homosexual activity (e.g. oral and anal sex.)”

Check back tomorrow for updated coverage after the hearing in New Haven, CT at 11 a.m.

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