IN THE JUVENILE COURT OF ______________COUNTY
STATE
OF GEORGIA
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In the interest
of: ] CASE NO.
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MOTION
FOR CONTINUANCE
Comes now
the defendant in the above styled and number case and by and
through his attorney, moves the Court to continue the trial
of this case until the next term of Court, and as grounds
shows the following:
1.
Counsel
was appointed to represent this defendant on .
This case
was completely inactive until , when met with the Assistant
District Attorney to discuss this case. Attorney handled this
case until she left the Public Defender's office on . Due
to the number of state witnesses and the complexity of the
case, counsel has been unable to complete an investigation
of this case and interview said witnesses.
2.
The defendant
is guaranteed a right to effective counsel by the Sixth and
Fourteenth Amendments to the United States Constitution and
by Article I, Section I, Paragraph XIV of the 1983 Georgia
Constitution.
3.
Defendant
is accused of Aggravated Assault and faces severe punishment
if convicted.
4.
Counsel
for defendant would not be prepared to render effective representation
if the case proceeds to trial as now scheduled.
WHEREFORE,
defendant moves the Court to continue the trial of this case
to the next trial term.
Respectfully
submitted,
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