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)
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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 |