JOHN VINCENT SAYKANIC, ESQ.

N.J. BAR ID NO.: 045801984

1135 CLIFTON AVENUE
CLIFTON, NEW JERSEY 07013
TEL: (973) 779-1124
FAX: (973) 614-0386
E-MAIL: JohnVincentEsq@aol.com

_________________________
:
THE STATE OF NEW JERSEY, : SUPERIOR COURT OF NEW JERSEY
: APPELLATE DIVISION DOCKET
v. : NO. A-002811-16T6
:
EDWARD FORCHION, : CRIMINAL ACTION
aka NJ WEEDMAN, :
: MERCER COUNTY INDICTMENT
Defendant-Appellant. : NO. 17-02-0105I
_________________________:
ON APPEAL FROM AN ORDER OF THE
SUPERIOR COURT OF NEW JERSEY,
LAW DIVISION, MERCER COUNTY,
ORDERING THE PRE-TRIAL DETENTION
OF THE DEFENDANT-APPELLANT

SAT BELOW:

Hon. Peter E. Warshaw, Jr., J.S.C.

AMENDED BRIEF AND APPENDIX ON BEHALF OF

DEFENDANT-APPELLANT EDWARD R. FORCHION
IN SUPPORT OF HIS APPEAL OF THE
IMPOSITION OF PRE-TRIAL DETENTION

John Vincent Saykanic, Esq. and THE DEFENDANT IS CONFINED

Edward R. Heyburn, Esq.
On the Brief
 TABLE OF CONTENTS
Page No.

PROCEDURAL HISTORY AND STATEMENT OF FACTS . . . . . . . . . . 1

LEGAL ARGUMENT

POINT I

MR. FORCHION RESPECTFULLY SUBMITS THAT

THE ORDER OF PRETRIAL DETENTION SHOULD
BE REVERSED SINCE THE SCORING IS TOTALLY
INACCURATE AND THE REAL MOTIVATION OF
THE STATES APPLICATION IS TO PUNISH MR.
FORCHION FOR HIS POLITICAL ACTIVISIM;
MR. FORCHION SHOULD BE RELEASED FORTHWITH . . . . . . . 3

CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . 8

INDEX TO APPENDIX

Indictment No. 17-02-0105-I (filed February 28, 2017) . . Da1-2

Complaints Warrants . . . . . . . . . . . . . . . . . . Da3-12
Pretrial Detention Motion Order (dated March 7,
2017) . . . . . . . . . . . . . . . . . . . . . . . . Da13-15
Public Safety Assessment Recommendation to Court . . . . Da16
Criminal and Court History . . . . . . . . . . . . . . . Da17-20
Order to Unseal Indictment (filed March 6, 2017) . . . . . Da21
Notice of Motion Pretrial Detention (dated March 4,
2017) . . . . . . . . . . . . . . . . . . . . . . . . . . Da22
Certification in Support of Pretrial Detection . . . . . . Da23

i
 PROCEDURAL HISTORY AND STATEMENT OF FACTS

The genesis of this appeal is the long-running battle

between Mr. Forchion (a long-time pro-marijuana, civil rights,

and First Amendment activist known as NJ Weedman) and the City

of Trenton (and Police Department) concerning Mr. Forchions

operation of his restaurant, NJ Weedmans Joint and an adjacent

cannabis church on East State Street in Trenton. The Trenton

Police Department has unfairly harassed Mr. Forchion and his

patrons, contending that an 11:00 p.m. residential zone curfew

applied (instead of a 2:00 a.m. Business Administration zone

curfew: City Ordinance 146-22A). As early as December, 2015,

the police have tried to close the restaurant/temple.

The pending Mercer County Indictment (No. 16-08-6771)

relates to marijuana-related charges stemming from a raid by the

Mercer County Narcotics Task Force on April 27, 2016. The raid

was spurred by a supposedly confidential informant (CI).

Mr. Forchion was released on bail on the pending marijuana

charges and, while on bail, became involved in a public battle

with the Prosecutors Office to obtain relevant discovery.

During a police raid on April 27, 2016 law enforcement seized

DVRs and a computer hard drive which contain surveillance

footage (proving police harassment, violations of civil and

First Amendment rights, and police lying about a supposed

1
February 28, 2016 fight. On March 9, 2016, Mr. Forchion filed a

federal civil rights suit against the Trenton Police (and

others) presently pending before the Honorable Peter G.

Sheridan, U.S.D.J. (Liberty Bell Temple III et al v. Trenton

City Police Department, et al, 3:16-cv-01399-PGS-LHG).

Mr. Forchion is entitled to the identity of the CI (now

public knowledge), whom Mr. Forchion believes was videotaped by

his surveillance system. He intends to raise an entrapment

defense. Upon receipt of the repeatedly requested and long-

delayed Affidavit in Support of the Search Warrant, Mr. Forchion

knew the CIs identity and began requesting CI information from

the public on the Internet (never posting threats or threatening

images). In August of 2016 Prosecutor Stephanie A. Katz sought

a restraining order preventing release of the name of the CI.

In September 2016, Edward Heyburn, Esq., filed a state

civil action alleging police and prosecutorial misconduct (and

also publicly naming the CI as a defendant). Mr. Forchion is

thus entitled to information relevant to his civil action,

including discoverable information as to the defendant CI.

On December 19, 2016, Mr. Heyburn argued the restraining

order before the Honorable Anthony M. Massi, J.S.C. (Mr.

Forchion, however, was only provided with a redacted brief). On

January 6, 2017, Judge Massi stated he would rule in 12 days but

2
did not, however, issue his ruling barring Mr. Forchion from

releasing the name of the CI until February 27, 2017.

Accordingly, there was no Court Order/Gag Order in place when

Mr. Forchion purportedly violated the Court Order (the CIs name

was already public knowledge). Mercer County Indictment No. 17-

02-0105I (witness tampering) was filed on February 28, 2017.

LEGAL ARGUMENT

POINT I

MR. FORCHION RESPECTFULLY SUBMITS THAT

THE ORDER OF PRETRIAL DETENTION SHOULD
BE REVERSED SINCE THE SCORING IS TOTALLY
INACCURATE AND THE REAL MOTIVATION OF
THE STATES APPLICATION IS TO PUNISH MR.
FORCHION FOR HIS POLITICAL ACTIVISIM;
MR. FORCHION SHOULD BE RELEASED FORTHWITH

Per N.J.S.A. 2A:162-20 [Pretrial detention], the Court

should consider in pretrial detention:

the protection of the safety of any other

person or the community, or that the
eligible defendant will not obstruct or
attempt to obstruct the criminal justice
process . . . (emphasis supplied).

The State moved for detention with regard to the third

prong of the triad, that would be obstructing, a criminal

justice process (T15-24 to 6-1): [a]nd his goal in this case is

jury nullification. Again, that is obstructing the

1 T - transcript of detention hearing dated March 7, 2017.

3
administration of justice. (T35-7 to 9). Jury nullification

should not be grounds (an unconstitutional prior restraint)

for denying freedom. It is Mr. Forchions First Amendment Free

Speech right to advocate the theory of jury nullification.

The Court quoted the Affidavit which quoted a newspaper

article purportedly quoting Mr. Forchion: If you ask me

straight up would you do 7 years or let this guy get shot in the

head, I would let him get shot in the head. My concern is

beating this case by any means necessary. (T43-22 to 25). Mr.

Forchion testified this quote is distorted and when the reporter

asked if he cared if someone shot the CI in the head: I told

him that wasnt my problem, I care about me. (T18-19 to 22).

The Court cited: mailings sent to family members of the

witness discussing seeing him in Court and how it will be a bad

time for this person. (T45-4 to 7). Mr. Forchion admitted

sending mailings to the witness (where he lived with his wife

and children). (T27-4 to 20). Mr. Forchion served not only the

witness but the prosecutor and judge with a copy of the federal

civil action (which named the CI as a defendant). (T27-24 to 28-

18). Mr. Forchion explained: nothing that I mailed to him was

any threat. Not one single thing was a threat, actually it was

an invitation to come to Court. (T28-21 to 23). Mr. Forchion

actually, constantly encouraged him to come to Court. I was

4
looking forward to a Court hearing. (T18-1 to 3). Mr. Forchion

has not had physical contact with the witness since his arrest

in April of 2016; never called or threatened him (the witness

called him) (T14-19 to 23; T15-1 to 3; T17-9 to 12); never

encouraged anybody to harm him (T17-16 to 17); in fact, [j]ust

the opposite. (T22-9 to 13). He never intended to prevent the

witness from testifying: just the opposite. I repeatedly said

that, that I wanted him to come and testify. I felt that his

testimony was positive to me. (T22-20 to 22). He has no intent

to obstruct justice: No, I look forward to it. (T24-16 to 20).

As counsel explained: the PSA actually recommends that Mr.

Forchion be released with conditions of weekly reporting. (T30-

11 to 13). Counsel offered an additional gag order with

respect to discussing any potential witnesses publically (sic).

(T33-10 to 13). The Court stated:

I dont think he used this phraseology but

essentially that some of this is a free
speech element. That he has a right to say
certain things that he chooses to say,
particularly about jury nullification
issues. And those are complicated issues
which have to be, you know, perhaps
evaluated in greater depth at another time.
(T45-15 to 22; emphasis supplied).

The right to free speech and, arguably, a form of jury

nullification are not only complicated but legitimate issues

and should not be utilized to detain. The Court concluded:

5
 Tampering with a witness just doesnt
involve trying to cause somebody to withhold
testimony or elude process or fail to appear
to give testimony, it also involves efforts
to get somebody to testify falsely. And
this Court is satisfied that the only way to
prevent further intimidation of witnesses or
tampering with witnesses is to detain this
defendant. (T49-9 to 16; emphasis
supplied).

There is no evidence Mr. Forchion ever sought for the

witness to testify falsely. The Court stated: I am more

concerned about the nature and risk of his obstruction and his

attempts to obstruct the criminal justice process. And the

belief that he will simply continue to do as he pleases. (T51-

13 to 16). Mr. Forchion never attempted to obstruct the legal

process. A constitutionally protected three-time author and

blogger, he has publicly exercised his Free Speech rights and

speaking about his cases (and jury nullification) for decades.

There was no order preventing him from revealing the

witness/CI, and any prosecution related to that is a violation

of the Ex Post Facto Clause. He never threatened any individual

nor ordered nor encouraged any other person to threaten any

individual. Mr. Forchion is that rare defendant who actually

wants to be tried in a court of law and to prepare his pro se

defense. He relishes a trial and was only seeking information

about the CI to prepare his entrapment defense. Any suggestion

6
that Mr. Forchion, a pacifist, encourages violence is incorrect.

Mr. Forchion has a Sixth Amendment right to represent

himself and to present all defenses, including entrapment. The

identity of an informant is not absolute. As stated in Roviaro

v. United States, 353 U.S. 53, 60-61 (1957):

Where the disclosure of an informers

identity, or of the contents of his
communication, is relevant and helpful to
the defense of an accused, or is essential
to a fair determination of a cause, the
privilege must give way.

Mr. Forchion has previously won a very similar First

Amendment case against the State in Forchion v. Intensive

Supervised Parole, et al., 240 F.Supp.2d 302 (D.N.J. 2003). The

Court held that Mr. Forchions conduct, while participating in

the pretrial release program (ISP), in speaking to the press,

protesting and handing out pamphlets outside of the courthouse,

running a website, and producing and appearing in television

commercials, all in favor of the legalization of marijuana, was

conduct protected by the First Amendment, for the purposes of

determining whether his participation in the release program was

unconstitutionally terminated in retaliation for his activities

while on release. The State infringes not only Mr. Forchions

First Amendment Free Speech rights, but Sixth Amendment right to

effective counsel, to present a defense (entrapment), and Due

7
Process rights. Mr. Forchion was, through the Internet, only

seeking information about the defendant CI in his civil case.

Mr. Forchion is part-owner and director of NJ Weedmans

Joint and Liberty Bell Temple III. He supports one child, age 9

years old, with payments of $250 per month, and financially

assists two children in college. He collects social security

disability (terminated if jailed). More importantly, he needs

medical treatment for his bone cancer and C-cell tumor in his

right knee (with a possible tumor in his left hip). This life-

saving medical treatment will be cut off if he is jailed.

Mr. Forchions FTA is from Municipal Court (careless

driving); answered in 5 days. Criminal history is non-violent,

marijuana-related with DP convictions for resisting, theyre

old. (T31-4 to 6). The Court stated: Im familiar with the

fact that he does not have a violent conviction. (T40-7 to 9).

CONCLUSION

This laws denial of bail violates the United States and

New Jersey Constitutions. U.S. Const. Amend. VIII; N.J. Const.

(1947), Art. I, Para. 12; Stack v. Boyle, 32 U.S. 1 (1951). Mr.

Forchion is no danger to the public nor any witness and he will

always appear. He agrees to Judge Massis gag order.

Respectfully submitted,

s/ John Vincent Saykanic s/ Edward Heyburn

NJ BAR ID NO: 045801984 NJ BAR ID NO: 024161997
8
;:

MERCER~OUNTYPROSECUTOR SUPERIOR COURT OF NEW JERSEY

240 WEST STATE STREET MERCERCOUN'IY
TRENTON, NEW JERSEY LAW DIVISION- CRIMINAL
Telephone (609) 989-6305
INFO. FILE NO. 16..0016 pf"'S . f:-<1~ /Jo 17- O/S"3
INDICTMENT NO.

TilE STATE OF NEW JERSEY STATED SESSION

V. TERM

EDWARD FORCHION aka NJ Weedman,

DEFENDANT

COUNT!
WITNEssTAMPERING
(SECOND DEGREE)

The Grand Jurors of the State of New Jersey, for the County of Mercer, upon their oaths,

presentthat EDWARD FORCIITON between the dates of April 27, 2016 and February 10,

2017, in the City of Trenton, in the County aforesaid, and within the jurisdiction of this Court,

did, beli~ving that an official proceeding or investigation was pending or had been instituted,

knowingly engage in conduct that could cause a witness or informant to testify falsely ~dlor

witbhold testimony and/or elude legal process summoning him to testifY or supply evidence

and/or absent himself from any proceeding or investigation to which he has been lega]ly

summoned, by employing threat of force, contrary to the provisions ofN.J.S. 2C:28-5a; 2C:2-6,

and against the peace of this State, the Government and dignity of the same.

FILED
FEB 28 2017
SUPcHiOk .,;ouRT OF NJ
MERCER VICINAGE
CRIMfNAl DIVISION

Da1
.... .:.:.. -..

COUNT ll WITNESS TAMPERING (THIRD DEGREE)

The Grand Jurors of the State of New Jersey, for the County of Mercer, upon their oaths,

present that EDWARD FORCHION between the dates of April 27, 2016 and February 10,

2017, in the City of Trenton, in the County aforesaid, and within the jurisdiction of this Court,

did, believing that an official ])!.'Oceeding or investigation was pending or had been instituted,

knowingly engage in conduct that could cause a witness or informant to testify falsely and/or

withhold testimony and/or elude legal process summoning him to testify or supply evidence

and/or absent himself from any proceeding or investigation to which he bas been legally

summoned, contrary to the provisions ofN.J.S. 2C:28-5a, and against the peace of this Stat~ the

Government and dignity of the same.

ENDORSED AS A TRUE BILL;

/~~orepersoil
/ .

DATE: ~/OJ--r/r 2
I

FILED
FEB 28 2017
SUPtKIUK ~vurt 1 OF NJ
MERCER VICINAGE
CRIMINAL DIVISION

Da2
 THE STATE OF NEW JERSEY
vs.
EDWARD R FORCHION
ADDRESS 322 EAST STATE STREET

NJ 08608-0000

NAME:

or on ant says that to the best his/her knowledge, mformation and belief the named
defendantonorabout03/03/2017 in TRENTON CITY , MERCER County,NJdid:
BELIEVING THAT AN OFFICIAL PROCEEDING OR INVESTIGATION WAS PENDING OR HAD BEEN
INSTITUTED, KNOWINGLY ENGAGE IN CONDUCT THAT COULD CAUSE A WITNESS OR INFORMANT
TO TESTIFY FALSELY AND/OR WITHHOLD TESTIMONY AND/OR ELUDE LEGAL PROCESS
SUMMONING HIM TO TESTIFY OR SUPPLY EVIDENCE AND/OR ABSENT HIMSELF FROM ANY
PROCEEDING OR INVESTIGATION TO WHICH HE HAS BEEN LEGALLY SUMMONED, BY EMPLOYING
THREAT OF FORCE, CONTRARY TO THE PROVISIONS OF N.J.S . 2C:28-5A; 2C :2-6 , ON
FEBRUARY 27, 2017 DEFENDANT WAS INDICTED ON THIS CHARGE 2ND DEGREE

BELIEVING THAT AN OFFICIAL PROCEEDING OR INVESTIGATION WAS PENDING OR HAD BEEN

INSTITUTED, KNOWINGLY ENGAGE IN CONDUCT THAT COULD CAUSE A WITNESS OR INFORMANT
TO TESTIFY FALSELY AND/OR WITHHOLD TESTIMONY AND/OR ELUDE LEGAL PROCESS
SUMMONING HIM TO TESTIFY OR SUPPLY EVIDENCE AND/OR ABSENT HIMSELF FROM ANY
PROCEEDING OR INVESTIGATION TO WHICH HE HAS BEEN LEGALLY SUMMONED, CONTRARY TO
THE PROVISIONS OF N.J.S. 2C:28 - 5A; ON FEBRUARY 27, 2017 DEFENDANT WAS INDICTED
in violation of:
Original Charge 1) 2C: 28-SA 2) 2C: 28 -SA

CERTIFICATION: I certify that the foregoing statements made by me are t rue. I am aware that if any of the foregoing statements mado by mo are willfully false, I am subject

YOLANDA M WARD Date: 03/03/2017

will be notified of your Central First Appearance/CJP date to be held at the Superior Court in the county of MERCER
at the following address: MERCER COUNTY SUPERIOR CT
00 SOU'rH WARREN STREET TRENTON NJ 08608-0000
Date of Arrest: 0 31 0 3 0 17 Appearance Date: Time: Phone: 6 0 9-5 71- 4 0 0 0
PROBABLE CAUSE DETERMINATION AND ISSUANCE OF WARRANT
0 Probable cause IS NOT found for the issuance of this complaint.

lfi Probable cause IS found for the issuance of this complaint. TASHESIA HICKMOND JUDICIAL OFFICER03/03/2017
Signature and TiUe of Judicial Officer Issuing Warrant Date
TO ANY PEACE OFFICER OR OTHER AUTHORIZED PERSON: PURSUANT TO THIS WARRANT YOU ARE HEREBY COMMANDED TO ARREST THE
NAMED DEFENDANT AND BRING THAT PERSON FORTHWITH BEFORE THE COURT TO ANSWER THE COMPLAINT.

0 Domestic Violence- Confidential

0

Special conditions of release:

0 No phone, mail or other personal contact w/victim
0 No possession firearms/weapons
0 Other (specify):

Da3
 EDWARD R FORCHION
ON THIS CHARGE 3RD DEGREE

Original Charge

Charge

Da4
 EDWARD R
by:

Amended Charge
Waiver lndt!Jury

Plea/Date of Plea Plea: Date: Plea: Date: Plea: Date:

Finding Finding Finding

Adjudication ("see code) Code: Date: Code: Date: Code: Date:

Jail Term

Probation Term
Cond. Discharge Term

Community Service

D/L Suspension Term

Fines/Costs Fines: Costs: Fines: Costs: Fines: Costs:

VCCB/SNSF VCCB: SNSF: VCCB: NSF: VCCB: SNSF:

DEDR/Lab Fee DEDR: LAB: DEDR: LAB: DE OR: LAB:

CD Fee/Drug Ed Fnd CD: DAEF: CD: DAEF: CD: DAEF:

DV Surch/Other Fees DV: Other: DV: Other: DV: Other:

Restitution
BenefiCiary:

Miscellaneous Information, Adjournments, Companion Complaints, Co-Defendants, Case Notes: 1 - Guilty

2- Not GuUty
3- Dismissed - 0 1her
4- Guilty but Merged
5 - Dismissed-Rule
6 - Dismissed Lack or Prosecution
7 - Dismissed - Pros MotionNic Req
8 - Conditional Discharge
Relat ed Traffic Tickets and Complaints: D - Dismissed- Prosecutor Discretion
M- Dismissed Mediation
P Dismissed-Plea Agreement
S - Disposed at Superior
W - Dismissed-False ID

DATE

Da5
 EDWARD R
by:

Amended Charge
Waiver lndt!Jury

Plea/Date of Plea Plea: Date: Plea: Date: Plea: Date:

Finding Finding Finding

Adjudication ( see code) Code: Code: Date: Code: Date:

Jail Term

Probation Term

Community Service

0 /L Suspension Term

Fines/Costs Fines: Costs: Fines: Costs: Fines: Costs:

VCCB/SNSF VCCB: SNSF: VCCB: SNSF: VCCB: SNSF:

DEDR!Lab Fee DEDR: LAB: DEDR: LAB: DEDR: LAB:

CD Fee/Drug Ed Fnd CD: DAEF: CD: DAEF: CO: DAEF:

DV Surch/Other Fees DV: Other: DV: Other. DV: Other:

Restitution
Beneficiary:

Notes: F inding
1 - Guilty
2- N ot Guilty
3 - Dismissed - Other
4 - Guilty but Merged
5- Dismissed-Rule
s - Dismissed Lacl< of Prosecution
7- Dismissed - Pros MotionNic Req
Related Traffic Tickets and Complaints: 8 - Conditional Discharge
D - Dismissed- Prosecutor Discretion
M - Dismissed- Mediation
P - Dismissed-Plea Agreement
S - Disposed at Superior
W- Dismissed-False ID

DAT E

Da6
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THE STATE OF NEW JERSEY

EDWARD R FORCHION
vs.
EAST STATE STREET

NJ 08608-0000

By certification or on oath, the complainant says that to the best of his/her knowledge, and belief the named
defendant on or about 03/03/2017 in TRENTON CITY , MERCER County, NJ did:
BELIEVING THAT AN OFFICIAL PROCEEDING OR INVESTIGATION WAS PENDING OR HAD BEEN
INSTITUTED, KNOWINGLY ENGAGE IN CONDUCT THAT COULD CAUSE A WITNESS OR INFORMANT
TO TESTIFY FALSELY AND/OR WITHHOLD TESTIMONY AND/OR ELUDE LEGAL PROCESS
SUMMONING HIM TO TESTIFY OR SUPPLY EVIDENCE AND/OR ABSENT HIMSELF FROM ANY
PROCEEDING OR INVE~TIGATION TO WHICH HE HAS BEEN LEGALLY SUMMONED, BY EMPLOYING
THREAT OF FORCE, CONTRARY TO THE PROVISIONS OF N.J.S . 2C:28-SA; 2C :2 -6, ON
FEBRUARY 27, 2017 DEFENDANT WAS INDICTED ON THIS CHARGE 2ND DEGREE

BELIEVING THAT AN OFFICIAL PROCEEDING OR I NVESTIGATION WAS PENDING OR F~D BEEN

INSTITUTED, KNOWINGLY ENGAGE IN CONDUCT THAT COULD CAUSE A WITNESS OR INFORMANT
TO TESTIFY FALSELY AND/OR WITHHOLD TESTIMONY AND/OR ELUDE LEGAL PROCESS
SUMMONING HIM TO TESTIFY OR SUPPLY EVIDENCE AND/OR ABSENT HIMSELF FROM ANY
PROCEEDING OR INVESTIGATION TO WHICH HE HAS BEEN LEGALLY SUMMONED, CONTRARY TO
THE PROVISIONS OF N.J.S. 2C:28-5A; ON FEBRUARY 27, 2017 DEFENDANT WAS I NDICTED
in violation of:
Original Charge 1) 2) 2C: 28-SA 3)

CERTIFICATION: I c:ortify that tho foregoing statements made by me are true. I am aware that If any of the foregoing statements made by me are willf ully false, 1am subject
to punishment
Signed: YOLANDA M WARD Date: 03/03/2017
will be notified of your central. First Appearance/CJP date to be held at the Superior Court In the county of MERCER
at the following address: MERCER COUNTY SUPERIOR CT
TRENTON NJ 08608 - 0000
609-571-4000

0 Probable cause IS NOT found for the issu ance of th is complaint.

~ Probable cause IS found.forthe issuance of this complaint. TASHESIA HICKMOND JUDICIAL OFFICER 03/03/2017
Signature and TiUe of Judicial Officer Issuing Warrant Date
TO ANY PEACE OFFICER OR OTHER AUTHORIZED PERSON: PURSUANT TO THIS WARRANT YOU ARE HEREBY COMMANDED TO ARREST THE
NAMED DEFENDANT AND BRING THAT PERSON FORTHWITH BEFORE THE COURT TO ANSWER THE COMPLAINT.

' 0
0 Domestic Violence -Confidential
Special conditions of release:
0 No phone, mail or other personal contact w/victim
0 No possession firearms/weapons
0 Other (specify):

Da7
 vv-,v lr - vv I lv""t- I I I 1 U..:J/VvU. V 1/ O.VV.V"- r"IVI r-y 0 Ul IV lli:UI:S IU: IVIv>:>LU I fO'd 100

EDWARD R FORCHION
ON THIS CHARGE 3RD DEGREE

Original Charge

Amended Charge

Da8
 vv-.c..v IJ-VV I h.l"i"-1 I I I VvfV.,Jf;C..V I f V.VV.VL r iVI rl:l I VI IV I ldll~ IL.I. IVI\J,;)LV I I OCO IOv

THE STATE OF NEW JERSEY

vs.
EDWARD R FORCHION
ADDRESS:
322 EAST STATE STREET

TRENTON NJ 08608-0 000

DEFENDANT IN
1-::--::-:-::-:-:-:c-:-:-:-:----'------'-_;;;_--='--':...:_-----~

NJ 08607

To any Law Enforcement Official of New Jersey, You are commanded to transport
this defendant to the Warden of this county who is required to keep the defendant
in custody until a release or detention decision is made.

Offense Aux Offense Drug Code Degree Offense Description

1. 2 C : 2 8- SA ( 1} 2 WITNESS TAMPER!

2. 2C: 28- SA (1) 3 WITNES.S TAMPERI

3.

4.

Commitment Reason: Criminal Justice Reform

will be notified of your Central First Appearance/CJP date to be held at the Superior Court in the county of MERCER
at the following address: MERCER COUNTY SUPERIOR CT
400 SOUTH WARREN STREET TRENTON NJ 08608-0000

Date of Arrest: 03I 0 3/2 0 17 Phone: 609-571-4000

TASHESIA HICKMOND JUDICIAL OFFICER 03/03/2017

Signature and Title of Judicial Officer Issuing Warrant Date

Da9
 - - --- ---- - . . ... I ::I- V I IV t I Gill I~ ILl. IVI\JQLU J JO~ 100

THE STATE OF NEW JERSEY

EDWARD R FORCHION
vs.
ADDRESS:
322 EAST STATE STREET

NJ 08608-0000

NJ 08607

Purpose: This Affidavit/Certification is to more fully describe the facts of the alleged offense so that a judge or au thorized judicial officer may determine
probable cause.

1. Description of relevant facts and circumstances wh ich support probable cau s e

that ( 1) the offense(s) was committed and (2) the defendant i s t h e one who
committed it: ---
On February 28, 2017, the Grand Jury returned an indictment charging Edward Forchion
aka NJ Weedman, with second degree tampering with a witness /informant and third
degree tampering with a witness or informant. The defendant published ~ myriad of
personal information about a person he believes to be a witness/informant in a
criminal case which is pending in the Mercer County Superior Court against hLm. The
information included the full name of this person, addresses where he has lived or
where the defendant currently believes him to live, information regarding his family
members including his children and his father, cars that he and his wife drive, phone
numbers where to reach this alleged witness and his family members. Moreover, the
information was posted despite a pending State motion requesting a protective order
regarding the name, address and likeness of the actual witness. In these
publications, the defendant referred to this individual as a "rat" or a "snitch."
Numerous people commented on the social media sites with depictions of hanging mice,
"snitches get stitches, and of one individual hitting the other over the head with a
bat. The defendant commented to the press when referring to this person that "I
don't care what happens to him." "If you ask me straight up would you do seven years
or let this guy get shot in the head, I'd let him get shot in the head. My cpncern is
beating this case, by any means necessary."
Likewise on September 8, 2016, he posted the following on Facebook: "I'm not
concerned with outing him . . . In fact, I plan on doing it in a very public way . . Mercer
County Prosecutor's Office, Mrs. Kay has fil.ed a "restraining order motion" i.n hopes
of keeping me from doing so . LOL It hasn't been signed by any judge yet and even if
it was I'd ignore it." Forchion posted a video on September 8, 2016 in which he
announced he would be releasing the name of the individual he believed to .be the
confidential informant. Forchion further indicated he was releasing the name and the
image of the cooperating witness before the Judge could issue his order regarding the
protective order . {Continued below)

Da10
 -~. , vv, v- , , , , v-.~tv-.Jt &.v, 1 u . vv .v&.. r 1v1 r~ -o Ul IU II <::Ill~ 1u : IVIv;::)LV ' I/O~:noo

THE STA TE OF NEW JERSEY

vs.
EDWARD R FORCHION

2. I am aware of the facts above because: (Included, but not limited to: your observations,statements
of eyewitnesses, defendant's admission, etc.)

(Continued from above) The defendant repeated this theme regularly on his
website and his social media postings. The repeated theme was he was
publishing all of this information to make "the State's Motion moot"
regardless of the Court's ruling on i t . Forchion regularly addresses his
desire to utilize jury nullification practices in his trial , addressed
potential jurors and indicated that he will continu e to affect the jury pool
as much as possible . He also published both t he J u dge's phone number and
that of the prosecutor asking people to reach out to both to affect his case .
Forchion also sent mailings to family members of the person he b e liev ed t o be
the witness/informant including his father and relativ es out of State calling
him a "rat" and/or "snitch" a n d discussing "seeing h im i n cour t " and how i t
wi ll be a bad time for this person .
Subsequent to the Court ruling in favor of the State on the protective order
on February 27 , 2017 , the defendant continu es to scoff at the

3 . If victim was injured , p r ovi de the ext ent of the i njur y:

Cert i fi c ation:
I c ertify that the f o regoing s tat ements made by me are true. I am aware that i f
a ny of t he fore go i n g s t a tements ma de by me are willfully fa l se, I am s ubject to
puni s hment .

signed : YOLANDA M WARD LAW ENFORCEMENT OFFICER Da t e : 03 / 03/2017

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 . . - -- .- - - - - ~ - ~~-~-. , ~ '" v rv a11;:, ILJ. tVIuOL:U 1 10::1100

THE STATE OF NEW JERSEY

VS.
EDWARD R FORCHION
ADDRESS:
322 EAST STATE STREET
NJ 08607-0000
MERCER NJ 08608-0000
POLICE CASE #:
S -17- 2 0
I--;;:-;:::-:-:=-..,.-;-:-~=-Y-'0-LAND--A--M-'-W-AR_D
_ _ _ _ _ _ _ _ _---1
NAME: 225 NO CLINTON AVE
ATTN: WARRANTS
TRENTON NJ 08607
Purpose: The Preliminary Law Enforcement Incident Report (PLEIR) is designed to be appended to, and is expressly incorporated by
reference in, the Affidavit of Probable Cause. It Is intended to document basic (nformation known to the officer at the time of Its preparation. It is
recognized that additional relevant Information will emerge as an Investigation continues. The PLEIR shall be In addition to, not in lieu of, any regular
police arrest, incident, or investigation reports. Note that the PLEIR is specific to each defendant charged in an investigation.

Cortification:
I certify that t he foregoing statements made by me are true. I am aware that if any of the foregoing statemonts made by me are willfully false, 1am
subject to punishment.
Signod: ______________________________________________________________

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 State of New Jersey Superior Court ofNew Jersey
Law Div ision: Criminal Part
v. Mercer County

_E_D_W_A
_R__
D_R.;.;..._F..O.;.;..
.::. R....::.
C....::.H::.;_TO
-"--
N_ __ _ , Defendant Pretrial Detention Motion Order
SBI Number: ..:.1""'-9_,_,73=2=0=B"------ - Complaint/Jnd. #: W -2017-001 I 34-1 I I I
Date ofBirth: 07/23/1964 Complaint/Incl. #: _ _ _ _ _ _ _ __
Complaint/Lnd. #: _ _ _ _ _ _ _ __

Findings

The State having filed a motion for pretrial detention, and after conducting a hearing,
1. Probable Cause
0 The Court finds that the State has established probable cause that the eligible defendant
committed the charged offense(s) based on
0 The testimony of , AND/OR
0 The probable cause affidavit or preliminary Jaw enforcement incident report marked as
ExhibitS- , AND/OR
0 Other evidence--- -- - - - - - - -- - - - - - - - - - - -' OR
~efendant has been indicted for the described offense(s) AND
.TPlJIC!.MG~ -r- )Jr.:) /7 o Z- OJotJ-
2. 0 The court finds by clear and convincing evidence that no amount of monetary bai I, non-
monetary conditions or combination of monetary bail and conditions would reasonably
assure:
0 defendant's appearance in court when required, AND/OR
~~tion ofthe safety of any other person or the community AND/OR
B'that the defendant will not obstruct or attempt to obstruct the criminal justice process
AND THEREFORE PRETRIAL DETENTION OF THE DEFENDANT IS HEREBY
ORDERED.

3. 0 THE MOTION FOR PRETRIAL DETENTION IS DENIED. Based upon the reasons set
f01th on the record, the cotut does not find by clear and convincing ev idence that no amount
of monetary bail, non-monetary conditions or combination of monetary bail and conditions
will reasonably assure: (a) defendant's appearance in court when required, (b) the protection
ofthe safety of any other person or the community and (c) that the defendant will not obstruct
or attempt to obstruct the crimina l justice process. THE DEFENDANT IS HEREBY
ORDERED RELEASED AS SET FORTH IN THE PRETRIAL RELEASE ORDER.

Reasons for Pretrial Detention, if Ordered

ET"" The nature and circumstances of the offense charged. "/)
0"' Offense(s) charges /c.!; :r.tC/{::5 ~ J/i-M t#(:71UN(S - Jcc c?....:. ~ E/.&~o k o.. . ~
16'1'58rticular circumstances S'~C... -;::r;t;L :?
------------------------------------------------

Effective 01/01/2017, Promulgated by A.l Memo (12/27/2016), CN 12081 (Pretrial Detention Motion Order) page I of3

Da13
State ofNew Jersey v.EDWARD R. FORCHION S.B.I. Number: 197320B

~e weight of the ev idence against the defendant, considering the admissibility of any evidence
sought to be excluded
~sonal observation of law enforcement officer(s) - - - - - - -- -- -- - -
0 Statements ofwitness(es) - - - -- -- -- - - - - - - 0 Recorded
0 Statements of defendant - -- - - - - -- - - - - - - 0 Recorded
0 Video
0 Aud io
0 Physical evidence (specify):

ErThe history and cha racteristics of the defendant, including the defendant's:
0 character, physical and mental condition, family ties, employment, financial resomces, length
of residence in the community, community ties, past conduct, history relating to drug or
alcohol abuse.

G'Ciiminal history as reflected in the PSA

0 record concerning appearance at court proceedings as reflected in the PSA
s -At the time of the offense or arrest, the defendant was on the following:
0 probation for offense(s) - - - - - - - - -- - -- -
0 parole for offen se(s) - - - - -- - - - - -- - -
0 other release pending trial, sent~ ng, appeal or completion of sentence for offense(s)
1).: r<:...J~.,,') .....-r (..,V{'r1 C),-._} . ,_.-:1-2... - Ttt-t tK_ } 2 ~ CL -1-::l' r.: 0 , ..J z--v I? J '- T .x..r<.. -..-.
pU~.-1$.(.-.-.s. /C. /o -077 F r /(, - Oi--Ot;t..' (
GJ-ihe nature and seriousness of the danger to any other person or the community that would be
posed by the defendant's release, if applicable.

~nature and seriousness of the risk of obstructing or attempting to obstruct the criminal justice
process that would be posed by the defendant's release, if applicable.
~tial for witness intimidation - - - - - - - -- - -- - - -
0 Potential destruction of evidence - - - - - - - - - -- -- - -
0 Other: - - -- - -- - - -- - - - -- -- -- - - - -- -- -
W'The release recommendation of the pretrial serv ices program obtained using a risk assessment
instrument.
0 Release not recommended
ra-other: ftF-t.u>d!:<: /1- Jtit:
/7tr:J Cou-1--1" ;::ire c ~ ~J tf{JC-<-c-..
a
J}.t<::F
AJ ,A}C /f Jc,?c
}.:).//7 if .fl7
cr

Effecti ve 01 /01 /2017, Promulgated by AJ Memo ( 12/27/20 16), CN 12081 (Pretrial Detent ion Motion Order) page 2 of 3

Da14
State of New Jersey v. EDWARD R. FORCHION S.B.l. Number: 197320B

State represented by: f . /LifT 2

Defendant represented by: { . uG Y/:?v/(_ r)

Attachments:

0 Complaint-Wanant (CDR2) (also available in case jacket)

If Pre~ention Is Ordered,
~The Court has directed that defendant be afforded reasonable opportun ity for private
consultation with counsel.

~endant has been advised of his/her right to appea l this Order within 7 days pursuant to
R. 2:9-13.

Date:
l~lhc_h 7, 2<.J r ?
rt/f'' ....~.~'-------
--------- -_ -_ _ __ __ , J.S.C.

Effective 01/01/2017, Promu lgated by AJ Memo (12/27/20 16), CN I 208 I (Pretrial Detention Motion Order) page 3 of3

Da15
 New Jersey Judiciary
...;:aw-orv Assessment

RECOMMENDATION TO COURT
RELEASE WITH CONDITIONS -WEEKLY REPORTING + HD/EM

New VIolent Criminal Activity Flag: No

2.
Violent Offense and 20 Years Old or Younger: No
3. Charge at the Time of Offense: Yes
4.
5.

6.
7. Failure to Appear Pretrial in Past 2 Years: 1

8. Failure to Appear Pretrial Older Than 2 Years: .Yes

9. Sentence to Incarceration (14 Days or More): Yes

2C:28-5A(1) WITNESS TAM PERING-TO

03/0312017 3 NO NO ACS
CAUSE FALSE TESnMONY
2C:3510A(3) POSS CDS-> 50G
03/03/2017 4 NO NO ACS
MARIJUANA, 5G HASHISH

2C:35-5B(1 1) CDS- MANU/DIST/PWID-

03/03/2017 3 NO NO ACS
MARIJ=/>1OZ<5LB, HASH=/>5G<1 LB

2C:35-10A(3) POSS CDS-> SOG

0310312017 4 NO NO ACS
MARIJUANA, SG HASHISH

2C:35-58(11) CDS MANUIDIST/PWID

03/03/2017 3 NO NO ACS
MARIJ=/>10Z<5LB, HASH"/>5G<1 LB

Date: 0310412017 09:3 9AM Page 1 of 1

Da16
[I] New Jersey Judiciary
___ Criminal and Court History
- - - - - --------

Complaint Number: W 2017 0011341111 PSA Run Date: 03/04/2017 09:39AM

2C:33-1 2B MAINTAIN NUISANCEMAINT

SF 2016134017 111 1 03/22/2017 06/11/2016 0 NJ ACS
PLACE PPL GATH FOR UNLAW CONDUC

2C:33-12A MNNTAIN A NUISANCE

SF 2016 1272061111 03/22/2017 09/17/2016 CREATEIMAJNTAIN COND ENDANG D NJ ACS
SAFETY

2C:36-2 USEIPOSS W/INTENT TO USE P/G,

MER-16-<l01706-001 01/06/2017 04127/2016 D NJ
DRUG PARAPHERNALIA CCH

MER-16-{)01706-001 01/06/2017 2C:3510A(3) POSS CDS> SOG PIG,

4 NJ
MARIJUANA. 5G HASHISH CCH

01/06/2017 2C:35-10A(3) POSS COS-> 50G PIG.

MER-16-001706-001 4 NJ
MARIJUANA, 5G HASHISH CCH

2C:35-10A(3) POSS COS- > 50G P/G,

MER-16-001706-{)01 01/06/2017 04/27/2016 4 NJ
MARIJUANA, 5G HASHISH CCH

20:35-4.1 C FORTIFY CDS MANU/DIST P/G,

MER-16-001706-001 01/06/2017 04/27/2016 3 NJ
FACILITY CCH

2C:35-5B(11) CDS MANU/DIST/PWID

2C:35-5A(1) MANUF/DISTR CDS PIG.
MER-16-001706-001 01/06/2017 04/2712016 MARIJ:/>10Z<5LB, 3 NJ
I HEROIN/METH/LSD <1/20ZJETC CCH
HASH:/>5G<1 LB

2C:35-7A CDS/ANALOG- DISTRIBUTE 2C:355A(1) MANUF/DISTR CDS OR P/G,

MER-16-<l01706-<l01 01/06/2017 04/27/2016 3 NJ
ON/NEAR SCHOOL PROPERTY/BUS INTENT TO MANUF/DISTR CDS CCH

2C:36-3 OIST/POSS/PWID DRUG PIG,

MER16-<l01706-<l01 01/06/2017 04/27/2016 4 NJ
PARAPHERNALIA CCH

24:2121A(6) PROHIBITED ACTS PIG,

MER-16-001706-{)01 01/06/2017 04/2712016 INVOLVING CDS..STORAGE IN SHOP, 3 NJ
CCH
CAR, ETC

2C:35-10A(3) POSS COS> 50G P/G,

MER-16-001706-<l01 01/0612017 04/27/2016 4 NJ
MARIJUANA, 5G HASHISH CCH
2C:355B(11) CDS- MANU/DIST/PWIO
2C:355A(1) MANUF/DISTR CDS- P/G,
MER-1 6-001706-001 01/06/2017 04/27/2016 - MARIJ:/>10Z<5LB, 3 NJ
HEROINIMETH/LSO <1/20ZJETC CCH
HASH=/>5G<1 LB

2C:35-7A CDS/ANALOG - DISTRIBUTE 2C:35-5A(1) MANUF/DISTR CDS OR PIG.

MER-1 6-001706-<l01 01/06/2017 04/27/2016 INTENT TO MANUF/DISTR CDS
3 NJ
CCH
ON/NEAR SCHOOL PROPERTY/BUS

2C:33-4.1A(2) CYBER HARASS

MER-16-001833-001 12/07/2016 05/10/2016 SEND/POST OBSCENE MATER! W !NTEN 4 NJ PIG
HARM/FEAR

Published: 0 1/2017, CN: 11972 {PSA) PSA Run Date: 03/0412017 09:39 AM Page 1 of 4

Da17
 ....

2C:35-10A(4) POSS CDS-< 50G ACS,

s 1998 000082 0418 02/2912000 0412711998
MARIJUANA, 5G HASHISH
D NJ
CCH

2C:35-10A(4) POSS CDS-< SOG ACS,

s 1998 000931 0412 02123/2000 04/2811998
MARIJUANA, SG HASHISH
D NJ
CCH

2C:29-9B CONTEMPT- VIOLATE

FO-o3-o00317-99 07/2111999 11/1611998 DOMESTIC VIO ~ENCE RESTRAINING D NJ FACTS
ORDER

2C:35-10A(3) POSS CDS - > SOG

BUR-1 O-Q01082-001 10118/2012 0410112010 4 NJ PIG, CCH
MARIJUANA. 5G HASHISH

MANUAL,
CAM-00-005889-Q01 12/01/2000 0912112000 2C:20-3 THEFT BY UNLAW TAKING NJ
PIG

2C:35-5A(1) MANUF/DISTR CDS OR

CAM-Q0-001271-Q01 0912012000 2C:5-2 CONSPIRACY 2 NJ PIG, CCH
INTENT TO MANUF/DISTR CDS

2C:20-7 RECEIVING STOLEN

CAM-OO-Q05866-Q01 09/20/2000 PROPERTY-VAL $500-74999/MV/GUN 3 NJ PIG, CCH
ETC

2C:35-5B(10) CDS- MANU/DISTIPWID- 2C:35-5A(1) MANUF/DISTR CDS OR

CAM-97-007963-Q01 0912012000 1112411997 2 NJ PIG, CCH
MARIJ- =/> 5LB, HASH- =l>iLB INTENT TO MANUF/DISTR CDS

Published: 0112017, CN: 11972 (PSA) PSA Run Date: 03/04/201 7 09:39AM Page2 of4

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 2C:20-T RECEIVING STOLEN
CAM-00-005886-001 12/01/2000 004Y OOM 0000 PROPERTY-VAL 3 NJ P/G, CCH
$500-74999/MV/GUN ETC

2C:35-5B(10) CDS-
CAM-97-007983-001 12/01/2000 010Y OOM 0000 MANU/OIST/PWIO MARIJ- =/> 5LB, 2 NJ P/G, CCH
HASH =/>1LB

MANUAL,
CAM-00-005889-001 12/01/2000 004Y OOM OOOD 2C:20-3 THEFT BY UNLAW TAKING .I NJ
P/G

Supplemental Information (Not Included in PSA Calculation)

P-ublished: 01/2017, CN: 11972 (PSA) . . . .~------PsA Run Date: 03t04i2o1709:39 AM Page 3of4

Da19
Acts Committed:
ASSAULT
Relief Results:
F-PROH CONTACT VIC
F-PROH CONTACT OTH
F-PROH FUTURE DV
F-RESTR DEF FROM LOC
F..f>ROH HARAS COM V IC
F-PROH STALKING VIC
F-PROH HARAS COM OTH
FPROH STALKING OTH
FV-BUR-001656-97 ACTIVEFO 05/06/1997 05/06/1997 05/ 13/ 1997 05/13/ 1997
Acts Committed:
HARASSMENT
Relief Results:
E-PROH RET TO SCENE
F-PROH CONTACT VIC
F-COND VISIT DEF
F-PROH CONTACT OTH
FPROH FUTURE DV
F RESTR DEF FROM LOC
F..f>ROH HARAS COM VIC
F-PROH WEAPON POSS
F-PROH STALKING VIC .
. F-PROH HARAS COM OTH
F-PROH STAU<ING OTH
FV-CAM-001 95694 ACTIVE AMENDED FO 02/0411 994 NONE 02/14/1994 NONE
Acts Committed:
HARASSMENT
TERRORISTIC THREATS
ASSAULT
Relief Results:
FCOND VISIT DEF
F-MON CHILD EMER SUP
F-POSS PLNT/ALT HOUS
E- POSS PLNT/ALT HOUS
F-CHILD CUST
E-GHILO CUST
F PROH HARAS COMMUN
EPROH HARAS COMMUN
E-PROH RET TO SCENE
E-PROH FUTURE OV
F-PROH FUTURE DV
E-PROH CONT FAMILY
FPROH CONT FAMILY
E-PROH CONT VICTIM
F-PROH CONT VICTIM

Published: 01/2017, CN: 1197Z (PSA)

- -- - - - --PSA
------- --------
Run Date: 03/04/2017 09:39 A M Page 4 of 4

Da20
 FILED
MAR 06 2011
ANGELO J. ONOFRI
MERCER COUNTY PROSECUTOR SUPERIOR COURT OF NJ
MERCER VICINAGE
240 WEST STATE S1EET CRIMtNAL OMSION
TRENTON, NJ 08650
609-989-6351

STATE OF NEW JERSEY Superior Court of New Jersey

Law Division- Criminal Part

v. FILE NO. 17-0753

IND. NO. 17..02-0105

EDWARD FORCHION
ORDER TO UNSEAL INDICTMENT

Upon application of the State of New Jersey. represented by Deputy First

Assistant Prosecutor Stephanie A. Katz. to the Court for an Order Unsealing Indictment;

On February 27, 2017, an indictment was issued charging the defendant with

second and third degree witness tampering pursuant to N.J.S.A. 2C:28-5a;

And the defendant having been arrested on March 3~ 2017 on the warrant of

indictment relating to indictment 17..02-0105;

And the Court having been satisfied that the State's application requires granting

this application, there being no further purpose for the indictment to remain sealed;

And for good cause shown.

The Court ORDERS the following:

The indictment shall be unsealed by the Clerk of the Court.

/".~ /.).... ( - l

/~ ~'r-:..4:.
Hon. Robert Binghaiii U, J.S.C.
Judge of the Superior Court

51
Da21
 .... ~- 4' vv I lV"""T - I I I I V'-'IV '"'ti..::..V II I V ..::..V.!JI f""'\tVI - ~ I V I l lldll~ ll...l . Vr\ IVILU I f ( lV I L

ANGELO J ONOFRI

MERCER COUNTY PROSECUTOR

3RD FLOOR COUNTY COURTHOUSE PO BOX 8068

TRENTON, NJ 086500068

STATE OF NEW JERSEY

SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: CRIM1NAL PART
Plaintiff, MERCER COUNTY
CDR Number: W-2017-001134-1 111
v.
CRIMlNAL ACTION

EDWARD R FORCH10N
NOTICE OF MOTION
Defendant PRETRIAL DETENTION

To: MERCER COUNTY COURT

400 SOUTH WARREN STREET

TRENTON, NJ 086080000

PLEASE TAKE NOTICE that on a date to be determined by the Court, the State shall move for
Pretrial Detention on the above matter pursuant to N .J.S.A. 2A:162-19.

DATE: 03/04/2017 Is/ STEPHANIE ANN KATZ

ASSISTANT PROSECUTOR

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 - - - --- - . . ~~~T-v" ov.<..v.vr '""'ovo ,-8 t VI I lli:III~IU.vri.IVILUI// . 1..)/L

ANGELO J ONOFRI

MERCER COUNTY PROSECUTOR

3RD FLOOR COUNTY COURTHOUSE PO BOX 8068

TRENTON, NJ 086500068

STATE OF NEW JERSEY

SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: CRIMINAL PART
Plaintiff, MERCER COUNTY
CDR Number: W-2017-001134-1111
v.
CRIMINAL ACTION

EDWARD R FORCHION
CERTIFICATION IN SUPPORT OF
Defendant PRETRIAL DETENTION

I, STEPHANIE ANN KATZ, being of full age, upon my oath depose and state:

1. The defendant is charged with a crime and there is a serious risk that:
* the defendant will not appear in court as required;
* the defendant will pose a danger to any other person or the community; and/or
* the defendant will obstruct or attempt to obstruct justice, or threaten, injure, or intimidate, or
attempt to threaten, injure, or intimidate, a prospective witness or juror.
2. There is probable cause to believe that the defendant has committed a new crime while on
pretrial release.

The defendant is charged with second degree witness tampering and has repeatedly indicated that he will
not abide by Court Orders.

I hereby certify that to the best of my knowledge, the foregoing above statements made by me are true.
am aware that if any statements are willfully false, I am subject to punishment.

Is/ STEPHANIE ANN KATZ

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