Supplementary Motion for Bill of Particulars
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 Prosecutor Randall Ullum
Chad Kister asks for all due leniency from the court because he is not an attorney.
Motion For a Bill of ParticularsThe Defendant, Representing himself, does hereby request a Bill of Particulars from the Prosecutors, with a response to include, but not necessarily be limited to, the identification of precisely what statements attributed to the Defendant the prosecution contends prove the State’s prima facie case of both counts of Aggravated Menacing and the count of Telephone Harassment. These motions are filed pursuant to Ohio Criminal Rule of Procedure 7(E), which provides:
"When the defendant makes a written request within twenty-one days after arraignment but not later than seven days before trial, or upon court order, the prosecuting attorney shall furnish the defendant with a bill of particulars setting up specifically the nature of the offense charge and of the conduct of the defendant alleged to constitute the offense. A bill of particulars may be amended at any time subject to such conditions as justice requires."
The time limits show why the jury trial needs to be postponed, pursuant with Kister's continuance motion. Because Kister just received the advice of council after filing within the 7-day limit was possible, it is crucial that if the jury trial is not postponed, that the Bill of Particulars still be fulfilled.
The discovery requested is crucial to the defendant's defense in
WHEREFORE, Defendant, Chad Kister respectfully requests this Honorable Court to grant Defendant's request for Discovery to uphold the Defendant's critical right to a fair trial.
Chad Kister, pr-se
Certificate of Service
Copies have been served by fax to the Prosecutors office in person and to the Athens County Municipal Court, 8 East Washington St.; Athens, OH 45701.
4592 Bessemer Rd.; Nelsonville, OH 45764; 740-753-3888; 740-753-3000 or email@example.com