In the Athens County Municipal Court, Athens Ohio
Case Numbers 2011 CRA 01852; 2011 CRB 02185-1; 2011 CRB 0218-2; 2011 CRB 02125
State of Ohio
Chadwick Kister, defendant
in the Athens Municipal Court
Chad Kister, pro-se; 4592 Bessemer Rd.; Nelsonville, OH 45764
Special Prosecutors Randall Ullom and Andrew S. Makoski
Chad Kister asks for all due leniency from the court because he is not an attorney.
Motion to Continue
This is a motion to continue the final pre-trial to March because of the failure of the Prosecutor to comply with Kister's discovery requests, and their refusal to even return one of Kister's numerous calls. Furthermore, the continuance is necessary to grant Defendant time to find an attorney who does not have a conflict of interest as a critical need for his right to a fair trial. Adam Baker should have declared his conflict of interest from the beginning.
The Defendant suffered severe pain and permanent damage to the area where his inguinal hernia was repaired because he had to take a bus and walk to court in December, and he continues to suffer severe pain, which interferes with his ability to prepare for trial. Also, the Plaintiff has yet to return a single call to Chad Kister. Thus it is critical to give the defendant more time to prepare for trial.
Without the discovery that the defendant has requested, how can he
possibly have a fair trial?
WHEREFORE, Defendant, Chad Kister respectfully requests this Honorable Court to grant Defendant's request for a continuance, as is critically needed for his right to a fair trial.
Chad Kister, pro-se
Certificate of Service
Copies have been served by fax to the Prosecutors office (fax: 740-592-3350) and to the municipal court (740-592-3331).
4592 Bessemer Rd.; Nelsonville, OH 45764; 740-753-3888; 740-753-3000 or firstname.lastname@example.org