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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS


SAN ANGELO DIVISION
______________________________________

UNITED STATES OF AMERICA

v. No. 6:14-CR-009-C

WILLIAM J ASON KELCY

MOTION TO DISMISS INDICTMENT

The United States of America files this motion to dismiss the pending indictment
against William J ason Kelcy, defendant, and would show the Court as follows:
1. Shortly after this case was continued, the defendant was diagnosed with stage IV
metastatic melanoma. He underwent treatment in Abilene, Texas, and last week
transferred to hospice care.
2. The defendant died at his home in Early, Texas, on Sunday, May 25, 2014. The
defendants wife called the United States Probation Office to report his death,
which was also reported in the local newspaper. The United States Probation
Office confirmed the defendants death with the Early Police Department, which
responded to the home following his death.




Case 6:14-cr-00009-C-BG Document 22 Filed 05/27/14 Page 1 of 2 PageID 57


Based on the forgoing, the government respectfully requests that the Court dismiss
the indictment.

Respectfully submitted,

SARAH R. SALDAA
UNITED STATES ATTORNEY

/s/ Amanda R. Burch
AMANDA R. BURCH
Assistant United States Attorney
Texas State Bar No. 24031900
1205 Texas Avenue, Suite 700
Lubbock, Texas 79401
Telephone: 806.472.7351
Facsimile: 806.472.7394
E-mail: amy.burch@usdoj.gov

CERTIFICATE OF CONFERENCE
I certify that I conferred with David Sloan, attorney for the defendant, regarding
this motion, and he is not opposed.
/s/ Amanda R. Burch
AMANDA R. BURCH
Assistant United States Attorney


Case 6:14-cr-00009-C-BG Document 22 Filed 05/27/14 Page 2 of 2 PageID 58

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