IN THE CIRCUIT COURT OF MAYCOMB COUNTY, ALABAMA

STATE OF ALABAMA,	*

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v.	*	Case No. CC-00-0000

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JOE CLIENT.	*

MOTION FOR PERMISSION TO FILE OTHER MOTIONS

Joe Client respectfully moves this Court for permission to file additional motions in this case. In support of this motion, Mr. Client submits the following:

1.	Joe Client has been indicted for capital murder. The State is seeking the death penalty.

2.	It may be necessary to file additional motions after the deadline for filing pretrial motions as issues develop during the remaining pretrial investigation and litigation, and as issues arise due to new decisions from the Alabama Court of Criminal Appeals, the Alabama Supreme Court, and the United States Supreme Court.

3.	Rule 15.3(b) of the Alabama Rules of Criminal Procedure provides that "[f]or good cause shown, the court may extend . . . the time of filing [pretrial] motions."

4.	Because this is a capital prosecution, the Fifth, Sixth, Eighth, and Fourteenth Amendments to the United States Constitution, the Alabama Constitution and Alabama law require that exacting standards be met to ensure the fairness and reliability of these proceedings. "Death, in its finality, differs more from life imprisonment than a 100-year prison term differs from one of only a year or two. Because of that qualitative difference, there is a corresponding difference in the need for reliability in the determination that death is the appropriate punishment in a specific case." Woodson v. North Carolina, 428 U.S. 280, 305 (1976); see also Ex parte Monk, 557 So. 2d 832, 836-37 (Ala. 1989) ("The hovering death penalty is the special circumstance justifying broader [pretrial orders] in capital cases.").

For these reasons, Mr. Client respectfully moves this Court to enter an order allowing Mr. Client to file other motions after the deadline for filing pretrial motions.

Respectfully submitted,

/s/ Linda Lawyer

Linda Lawyer

123 Main Street

Maycomb, AL 54321

(334) 987-6543

lawyer@email.com

Counsel for Joe Client

[CERTIFICATE OF SERVICE]

[MOTION UPDATED ON 10/03/17]