Councilman Devyn Keith New Trial Date Set

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DOCUMENT 25

ELECTRONICALLY FILED
5/8/2023 5:57 PM
47-DC-2023-000916.00
DISTRICT COURT OF
MADISON COUNTY, ALABAMA
DEBRA KIZER, CLERK
IN THE DISTRICT COURT FOR MADISON COUNTY, ALABAMA

STATE OF ALABAMA, )
)
Plaintiff, )
)
v. )CASE NO. DC-23-916, DC-23-917,
) DC-23-918, DC-23–919
DEVYN S. KEITH, )
)
Defendant. )

MOTION TO CONTINUE

COMES NOW, the undersigned attorney and would file this motion to continue and for

cause would state the following:

1. That the undersigned attorney did receive discovery from the State of Alabama.

2. That the discovery was at the Madison County District Attorney’s web site

provided to defense attorneys.

3. That the videos for this case located there had to be viewed and downloaded in

such a way to make it unclear what incident the video was related to.

4. That the undersigned provided the Madison County District Attorney’s office a

thumb drive in order to have the videos placed there so that the attorney could control the view

and the ability to start, stop and repeat the flowing video for clarity.

5. That the Madison County District Attorney’s office not only did provide the

videos in question on the thumb drive but also provided CD’s with the videos located on them.

6. That the undersigned attorney when attempting to view the videos discovered they

would not play on the computer because of software issues.

7. The undersigned then took the videos to other computers in an attempt to view the

videos and discovered the videos would play on an older computer which had Window Media
DOCUMENT 25

Player and that Windows Media Player is no longer provided on newer versions of Windows

software such as Windows 11.

8. That while the undersigned attorney has viewed the videos he has not viewed

them with the Defendant.

9. That the Defendant has not previously requested a continuance.

10. That the undersigned attorney communicated the above to the Assistant District

Attorney assigned to this case and she did say she was not opposed to a continuance and gave the

undersigned permission to inform this Honorable Court in this motion that she was not opposed.

WHEREFORE the premises considered the undersigned requests that this case be

continued.

/S/ John Taylor


JOHN TAYLOR,
Attorney for Defendant

OF COUNSEL:
John Taylor (TAY038)
COULTAS TAYLOR P.C.
2610 Memorial Parkway, NW
Huntsville, Alabama 35810
(256) 539-8880
elawfirm@gmail.com

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing has been served on the Madison County
District Attorney, Madison County Courthouse, Huntsville, AL 35801 by electronic filing, this
the 8th day of May , 2023.

/S/ John Taylor


JOHN TAYLOR

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