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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
CRIMINAL NO: 16-20008
v
HON. MATTHEW F. LEITMAN
JARED PATRICK LOCKWOOD,
a.k.a.
JLocke
Defendant.

GOVERNMENTS MOTION TO REVOKE

DEFENDANT LOCKWOODS BOND
The United States of America respectfully submits this motion to revoke
defendant Jared Lockwoods 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;

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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 Defendants 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.
2

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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 Pedophiles 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.

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On the date of the search warrant, the Defendant was not forthright. He told
officers that he did not download or view child pornography and would not take a
polygraph. It is true that he has since accepted responsibility for his possession of
child pornography.
Several of the images and videos the Defendant possessed depicted little
children being bound and tortured and/or bestiality. Many files were advertised
based on the age of the victim, 5yo, 7yo, and 9yo to name a few. Others
were advertised based on the sexual acts depicted, using explicit terms to indicate
that they contained videos of little girls being anally raped. Still others were
advertised based on incest, sister brother . . . suck . . . dog . . . GREAT. The
Defendant had numerous videos that were over five minutes in length. The nature
and circumstances of the offense and weight of the evidence show that the
Defendant is both a flight risk and a danger to the community.
B.

History and Characteristics of the Defendant

The Defendant has several prior convictions, all of them recent, including a

conviction for felony uttering and publishing and larceny in a building in 2012, and
for possession of a controlled substance in 2015. The offense conduct underlying
the 2015 offense involved yet another instance of Mr. Lockwood blatantly lying to
law enforcement. Police asked him if he had any drugs, and he said no. It turned
out he was carrying a plastic bag of heroin in his waistband. See Govt. Ex. B,

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Heroin Police Report. The Defendants girlfriend was present and reported that the
adderall1 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
Defendants 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 friends 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 friends computer on at

Adderall is a prescription drug and is used to treat conditions like narcolepsy and
ADHD. 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, blurred
vision, weakness, headache, and confusion. Taking MAO inhibitors while taking
adderall may cause a serious (potentially fatal) drug interaction.

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

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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 friends 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 friends 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 friends house a total of five
times, but the tether data and the Defendants friend confirm that he has been over

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

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to his friends 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 Defendants detention,
especially now that he has entered a guilty plea. The Defendants 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.
Lockwoods 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

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

BARBARA L. McQUADE
United States Attorney
s/April N. Russo
April N. Russo
Assistant United States Attorney
211 W. Fort Street, Suite 2001
Detroit, MI 48226
Phone: (313) 226-9129
E-Mail: april.russo@usdoj.gov

Dated: May 11, 2016

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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 ONeill
Attorney for Jared Lockwood
Federal Defenders Office
513 Abbott Street, 5th Floor
Detroit, MI 48226

s/April N. Russo
April N. Russo
Assistant United States Attorney
211 W. Fort Street, Suite 2001
Detroit, MI 48226
Phone: (313) 226-9129
E-Mail: april.russo@usdoj.gov

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INDEX OF EXHIBITS
Exhibit:

Description

A
B
C
D
E

Handbook Excerpt (filed under seal)

Heroin Police Report
Def. Amazon Account
May 9 Police Report
April 18-May 9 Tether Summary

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EXHIBIT A

FILED UNDER SEAL

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