IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT - CRIMINAL PEOPLE OF THE STATE OF ILLINOIS, ) ) Plaintiff, } v ) No. 19 CR 2758 ) 2759 | os ROBERT KELLY, ) 2760 | 2 » 276) 2 Set » Defendant. ) & Ea 3 o B 2 zs eo FOR WORK 3 NOW COMES the Defendant, Robert Kelly, by the undersigned counsel, and moves this Honorable Court to allow him to travel for work, to Dubai, in order to perform on April 17-19, 2019. In support of this request he states the following: | 1. Defendant is charged in these cases with aggravated criminal sexual assault. In each of the cases he is eligible for probation, or from 2-5 years of incarceration. He has been free on bond since his arrest. 2. Before he was arrested Mr. Kelly had signed a contract to perform between 3-5 shows in Dubai, U. in April 2019. a He requests permission to travel to Dubai for the shows. While there he is supposed to meet with the Royal Family | 4. Defendant is not a fight risk. | 5. Mr. Kelly voluntarily surrendered on a no bond warrant. He did not flee before then, when he knew he was being investigated. 6 During his previous matter he traveled out of the country several times10. and always returned, Indeed, during the six years the matter was pending he never missed or was late for a court appearance. ‘Mr. Kelly has a job that requires he be allowed to travel. He cannot work, and consequently cannot make a living if he is confined to Illinois, or even. the United States. Although he is presumed innocent, he is being denied the opportunity to perform here, “The organizers of the Spring Break Jam concert, set to take place in April [2019] at the Illinois State Fairgrounds with the embattled R&B singer as “host,” had their application denied ‘Thursday because of security concerns, according to officials.” https‘//www.chicagotribune. Ws al/breaking/ct-met-r-kelly- springfield-concerts -20190111-story.html. “R. Kelly's upcoming performance at the UIC Pavilion [May 2018] has been canceled after more than 1,300 students and staff at the University of Illinois at Chicago signed a petition to prevent the controversial singer from performing at the college.” https'//www.nbechicago.com/news/local/uic-students-staff-demand-r- elly-concert-cancellation-481105031.html. ‘Some streaming services have removed his songs, and his record company has canceled his contract. As has been well publicized, Mr. Kelly needs to generate income. He has struggled of late to pay his child support and other child related expenses. Denying him the opportunity to work would be a hardship on his1. 12. 13. 14. 15. children, Ifhe is allowed to travel he will be able to pay the balance of any arrearage and he has offered to pay upcoming support prospectively. Beyond that, Mr. Kelly fell behind on his studio rent and owes a judgment. Mr. Kelly needs to pay his day to day living expenses. ‘Mr. Kelly needs income to pay his legal fees, for this case, and in pending civil cases, ‘The law should not differentiate when it comes to the ability to work between those who have locally based jobs and those whose work requires them to travel elsewhere. Frankly, the requirement that someone remain tied to the state of Illinois simply because an accusation has been made against them is unnecessary in light of modern technology. This is not a situation where someone can simply disappear and not be found. Technology has evolved to the point where it is impossible for one to disappear. It would be impossible for someone of Mr. Kelly's stature to disappear. These cases are going to take time to resolve themselves, whether through trial or otherwise. There are substantial pretrial issues that must be addressed with respect to each. Generally, all of the cases rest upon a smorgasbord of different statutes of limitations. In each the prosecution has relied upon one or more sections to extend otherwise expired statutes. With respect to each, challenges will be filed.