Scribd Logo
Upload

Welcome to Scribd!

  • 174 views

    Delphi Verified Motion To Extend Discovery Deadline

    Uploaded by

    Grizzly Docs
    Delphi Murders Case | 2024-03-07 | Verified Motion to Extend Discovery Deadline | Richard Allen, Delphi, Indiana, Carroll County, Allen Superior Court, Michael K. Ausbrook, Bradley Rozzi, Andrew Baldwin, Nicholas McLeland, James Luttrell, Judge Frances C. Gull, Abigail Williams, Liberty German

    Copyright:

    Public Domain
    Download as PDF, TXT or read online from Scribd

    Delphi Verified Motion To Extend Discovery Deadline

    Uploaded by

    Grizzly Docs
    174 views3 pages
    Delphi Murders Case | 2024-03-07 | Verified Motion to Extend Discovery Deadline | Richard Allen, Delphi, Indiana, Carroll County, Allen Superior Court, Michael K. Ausbrook, Bradley Rozzi, Andrew Baldwin, Nicholas McLeland, James Luttrell, Judge Frances C. Gull, Abigail Williams, Liberty German

    Original Title

    Delphi Verified Motion to Extend Discovery Deadline

    Copyright

    © Public Domain

    Available Formats

    PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    Delphi Murders Case | 2024-03-07 | Verified Motion to Extend Discovery Deadline | Richard Allen, Delphi, Indiana, Carroll County, Allen Superior Court, Michael K. Ausbrook, Bradley Rozzi, Andrew Baldwin, Nicholas McLeland, James Luttrell, Judge Frances C. Gull, Abigail Williams, Liberty German

    Copyright:

    Public Domain
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    174 views3 pages

    Delphi Verified Motion To Extend Discovery Deadline

    Uploaded by

    Grizzly Docs
    Delphi Murders Case | 2024-03-07 | Verified Motion to Extend Discovery Deadline | Richard Allen, Delphi, Indiana, Carroll County, Allen Superior Court, Michael K. Ausbrook, Bradley Rozzi, Andrew Baldwin, Nicholas McLeland, James Luttrell, Judge Frances C. Gull, Abigail Williams, Liberty German

    Copyright:

    Public Domain
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 3

    Filed: 3/7/2024 8:13 AM

    Carroll Circuit Court


    Carroll County, Indiana

    STATE OF INDIANA ) IN THE CARROLL CIRCUIT COURT


    ) ss:
    COUNTY OF CARROLL ) CAUSE NO. 08C01-2210-MR-000001

    STATE OF INDIANA )
    Plaintiff )
    v. )
    )
    RICHARD ALLEN, )
    Accused )

    VERIFIED MOTION TO EXTEND DISCOVERY DEADLINE

    Comes now counsel for Attorneys Baldwin and Rozzi and respectfully move to extend

    the discovery deadline of March 7, 2024. In support thereof counsel states:

    1. On February 22, 2004, the Court issued an order stating in pertinent part

    “…now orders counsel for the defense attorneys to provide to the State of Indiana all the exhibits

    intended to be introduced at the hearing on March 18, 2024, on or before March 7, 2024. The

    Court did not issue a reciprocal order for the State to provide their exhibits expected to be

    introduced.

    2. However Mr. McLeland and undersigned have cooperated in reciprocal discovery.

    Undersigned has provided expected exhibits to Mr. McLeland as they have become available.

    The undersigned believes Mr. McLeland has provided all expected exhibits available to him

    prior to March 1, 2024.

    3. On March 1, 2024, counsel conducted depositions of most of the State’s identified

    witnesses. At that time, it was learned that the ISP report provided to Mr. McLeland then the

    undersigned did not contain the attachments. Mr. McLeland pledged to obtain them and share.

    4. Also during the depositions it was learned that Sgt. Holeman had conducted recorded

    interviews with pertinent people. It is not yet known if those were the omitted attachments to the

    report. Again, Mr. McLeland assured the undersigned they would be produced.
    5. On March 5, 2024, at 8:24 a.m. Mr. McLeland communicated to undersigned that he

    had the attachments and would collect the interviews and provide them through discovery that

    day. Then on March 6 at 9:23 p.m. Mr. McLeland advised that due to time constraints he would

    be unable to provide those materials until March 7, 2024.

    6. Upon review of the State’s additional discovery the undersigned may have additional

    exhibits. It will be impossible to determine that until the new materials are reviewed which, due

    to counsel’s schedule, cannot be done before late in the afternoon of March 7, 2024.

    7. On February 29, 2024, and March 1, 2024, the defense was contacted by two separate

    individuals who claimed to have documents pertinent to leaks. Despite diligent efforts the

    defense has not yet obtained these documents to be able to assess their credibility and reliability.

    Upon doing so the defense may have additional exhibits, which of course will be provided to the

    State as all others have been.

    8. Time is certainly not of the essence because everything the State complains of

    happened months ago, and was fully vetted. The Sate did not file its allegations of contemptible

    conduct until after the Indiana Supreme Court reinstated Attorneys Baldwin and Rozzi. The issue

    of contempt is not an urgent matter.

    9. Mr. McLeland objects to an extension.

    10. Undersigned requests an extension of one week.

    WHEREFORE, counsel respectfully prays the Court to extend the submission of exhibits

    deadline to March 14, 2024.

    Respectfully Submitted,

    /s/David R. Hennessy
    VERIFICATION

    I swear, under penalties for perjury, that the foregoing representations are true to the best

    of my knowledge and belief.

    /s/David R. Hennessy

    CERTIFICATE OF SERVICE
    The undersigned hereby certifies that a copy of the foregoing was served upon all counsels

    of record at the time of filing.

    /s/ DAVID R. HENNESSY

    DAVID R. HENNESSY
    Attorney at Law
    11715 Fox Road
    Suite 400 #180
    Indianapolis, IN 46236
    (317) 636-6160
    Attorney No. 8216-49
    hen@indylaw4all.com

    You might also like