IN THE JUVENILE COURT OF ______________ COUNTY
STATE
OF GEORGIA
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In the interest
of: ]
CASE NO.
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MOTION
TO APPOINT ADDITIONAL COUNSEL
Defendant
moves this court, pursuant to the Sixth, Eighth and Fourteenth
Amendments to the United States Constitution and similar provisions
of the Georgia Constitution, and similar provisions of the
Georgia Constitution, for the Appointment of an additional
counsel at the county's expense in order to assist in the
defense of this case. As grounds for this Motion, the Defendant
states the following:
The Defendant is currently charged with murder. Undersigned
counsel has been previously appointed by this Court to represent
the Defendant. The Defendant is indigent and counsel accordingly
will be paid by the county.
Counsel has thoroughly reviewed the limited information known
to date and has reached the conclusion that the appointment
of co-counsel is absolutely essential if the Defendant is
to be represented properly and with the effective assistance
of counsel. Specifically, the following aspects of this case
mandate the appointment of additional counsel.
(a) There
is a significant number of witnesses to be interviewed for
both the built-innocence phase and the sentencing of trial.
(b) An extensive
amount of scientific and other expert evidence is anticipated
and must be analyzed.
(c) "Other
crimes" evidence will be offered at the penalty phase,
necessitating
a thorough investigation of each criminal episode involved.
(d) Numerous
motions must be researched and filed that are specifically
related to a capital prosecution.
(e) Extensive
preparation must be made for the sentencing phase of trial.
(f) Counsel
must supervise and assimilate facts developed by investigators.
The Defendant, as a result of his indigency, is unable to
pay for an additional counsel; quite obviously, a defendant
of means would employ additional counsel in a capital case
of this nature in order to obtain an effective presentation
of his case.
WHEREFORE,
for reasons stated in the above, Defendant requests that he
be appointed counsel.
Respectfully
submitted,
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