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Strategies & Market Trends : Conversion Solutions Holdings Corp. - A Scam?

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To: scion who wrote (4440)1/29/2010 1:41:53 PM
From: scion   of 4624
 
01/29/2010 73 MOTION to Adopt Defendant Rufus Paul Harris's Motion for Bill of Particulars by Darryl Horton. (Waldrop, Thomas) Modified on 1/29/2010 to update text to more accurately reflect e-filed pleading (alc). (Entered: 01/29/2010)

Doc 73 PDF file
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MOTION TO ADOPT DEFENDANT RUFUS PAUL HARRIS’S MOTION FOR BILL OF PARTICULARS

COMES NOW, DARRYL HORTON, through undersigned counsel, and
moves the Court pursuant to LcrR 12.1(c) for leave to adopt the codefendant Rufus Paul Harris’s Motion for Bill of Particulars [R67].

1.
Co-Defendant Rufus Paul Harris’s Motion for Bill of
Particulars was filed on or about January 28, 2010.

2.
Like Co-Defendant Mr. Harris, Mr. Horton is named in Counts
One through Seven. As noted in Mr. Harris’ motion, the information
sought is integral to the defense not only of Mr. Harris, but also
Mr. Horton. It relates to specifics left out of Count One. The
Defendant’s request to adopt this motion filed by Mr. Harris is
warranted and permissible and serves to avoid burdening the court
with repetitive and duplicative pleadings.

3.
This motion to adopt should be granted in the interest of
justice. Moreover, this motion to adopt his co-defendant’s motion
assures Mr. Horton of receiving effective assistance of counsel and
due process of law.

WHEREFORE, Darryl Horton respectfully requests that he be
given leave to adopt the above referenced motion of his codefendant,
Mr. Harris.

Respectfully submitted, this 29th day of January, 2010.

Respectfully submitted,
s/ Jake Waldrop
JAKE WALDROP
GEORGIA STATE BAR NO. 731117
ATTORNEY FOR DARRYL HORTON
Federal Defender Program, Inc.
Suite 1700, The Equitable Building
100 Peachtree Street, N.W.
Atlanta, Georgia 30303
(404) 688-7530
Jake_Waldrop@fd.org
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