The motion lists six different instances prosecutors allege show that Melton and Recio knew they were violating the law when they took part in a police-style raid on a Ridgeway Street duplex Aug. 26, 2006.
The incidents cited in the motion are:
Melton allegedly “attempted to bribe law enforcement officials whom he believed had been subpoenaed to testify before a federal grand jury” investigating him, Recio and fellow bodyguard Marcus Wright;
In July 2005, Melton allegedly ordered police to kick in the door of a hotel room “when no legal justification existed for the warrantless entry”;
In August 2006, Melton allegedly ordered city officials to burn vacant houses on Congo and Campbell streets after being told doing so would be in violation of state and federal environmental laws;
In 2007, Melton allegedly ordered a contractor to demolish an unoccupied Cohea Street house that was not approved for destruction through the city;
In March 2006, Melton and Recio allegedly ordered the towing of a vehicle without probable cause and that Recio filed a false report “to obscure this illegal act”; and,
In April 2006, Melton allegedly filed a false affidavit to obtain an arrest warrant for Albert “Batman” Donelson.