Dean Wullenwaber
Wullenwaber Law Firm
P.O. Box 452
Lewiston, ID 83501
Telephone: (208) 743-8981
Facsimile: (208) 743-9442
Idaho State Bar No. 2506Mark T. Monson, P.A.
Attorney at Law
P.O. Box 8456
Moscow, ID 83843
Telephone: (208) 882-0588
Facsimile: (208) 882-0589
Idaho state Bar No. 6165Attorneys for Defendant
IN THE DISTRICT COURT OF THE SECOND JUDICIAL DISTRICT
OF THE STATE OF IDAHO IN AND FOR THE COUNTY OF LATAHSTATE OF IDAHO
Plaintiff,v.
STEVEN JAMES SITLER
Defendant.Case No. CR-2005-2027
MOTIONS RE: CHAPERONES AND
IMPLEMENTING SAFETY PLANFollowing up on the Hearing conducted on September 1, 2015, and particularly following up the colloquy between the Court and Counsel at that time regarding Defendant’s wife and parents, the Defendant respectfully moves the Court for the following Orders:
- Reinstating Katie Sitler as a chaperone;
- Adopting the safety plan as outlined by Valley Treatment Specialties, LLC (VTS) received by the Court on April 29, 2016;
- Allowing Steven Sitler to reside with his family in the family home as set out in the VTS plan; and
- Reinstating Dave Sitler as a chaperone, as Roxanne Sitler was reinstated last January.
A true copy of the April 7, 2016, letter from VTS to the IDOC is attached hereto as Exhibit A. On April 25, 2016, VTS submitted a “safety plan” to the Court with a “received” date stamp of April 29, 2016, a copy of which is attached hereto as Exhibit B.
These motions are based in part on the Affidavits of Mark Monson; and of Katie Sitler; and the Declaration of Gregory L. Wilson, Ph.D., all filed contemporaneously with these Motions.
These motions are further based in part on the disclosures made by the State on July 26, 2016, and received by counsel for Defendant on July 28, 2016, consisting of approximately 1,000 pages of documents generated by or received by the IDOC District 2 office relating to Steven Sitler since last December. Particular pages of these state documents likely will be referenced in connection with Defendant’s motions in the next several business days.
DATED: August 3, 2016
Mark T. Monson
Co-counsel for Defendant