IN THE FIFTIETH JUDICIAL DISTRICT, PARISH OF PEINE DE MORT
STATE OF LOUISIANA
No. _____

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STATE OF LOUISIANA, Plaintiff
v.
JOHN CLIENT, Defendant

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MOTION TO ADJOURN AT A REASONABLE TIME

COMES NOW, JOHN CLIENT, by counsel, and moves this Court pursuant to the Fourth, Fifth, Sixth, Eighth and Fourteenth Amendments to the United States Constitution, and Article 1, Sections 2, 3, 5, 13, 14, 16, 17, 19, 20, 22, and 24 of the Louisiana Constitution to adjourn at a reasonable time during trial. In support of his motion, Mr. CLIENT states as follows:
1. This is a capital case. Mr. CLIENT, an indigent, faces the death penalty. He is represented by overworked and underpaid attorneys.
2. Defense counsel anticipate that the trial could last two to three weeks. A traditional work day consists of eight hours. Each evening throughout this trial, counsel must prepare to confront or present the case the next day. Counsel must consult with Mr. CLIENT concerning each day's developments and the strategy to be pursued on the next day. Counsel must research legal questions which arise in the trial, make arrangements for witnesses' travel, and confer with them prior to their testimony. An excessive work schedule would prohibit Mr. CLIENT from receiving effective representation.
3. The Louisiana Supreme Court has previously noted with approval a case in which, "[b]y way of pretrial motion the defendant requested that the court adjourn at a reasonable time, and the judge agreed." State v. Loyd, 489 So. 2d 898, 903 (La. 1986). The same should be done in this case.
WHEREFORE, Mr. CLIENT moves that his motion be granted, and that Court be adjourned each day at a reasonable time.
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