1. That on July 26, 2001, a detention hearing was held by the Honorable , Senior Trial Referee. At that hearing the Child plead not true to the charge of a probation violation. Judge ... set the matter for trial. The Child's counsel was informed that the trial of this matter had been set before Judge on August 9, 2001 at 9:00 AM.
2. That the Child remains in the G. Ross Bell Youth Detention Center (GRBYDC) awaiting trial on a probation violation.
3. That if the Child remains in GRBYDC until her trial date of September 13, 2001, she will have been incarcerated for some 49 days.
4. That at the time of the scheduled trial date, the Child will be some 32 days from reaching the age of 19.
5. That the release of the Child would present neither a real and substantial threat of serious harm to the Child, nor to the person or property of another.
6. That it is in the best interest of the Child to release her from GRBYDC pending her trial, or in the alternative, to move her trial forward to an earlier setting.
WHEREFORE, PREMISES CONSIDERED, the Child prays that this Honorable Court will release the Child from Detention pending trial, or in the alternative, to set this cause for an Immediate Hearing to consider the Child's Motion to Release from Detention.
