Filing# 29562347 E-Filed 07/13/2015 01:29:49 PM

IN THE CfRa.JIT en.Rf OF THE THIRD JUDICIAL CIROJIT

IN Af\O FCR DIXIE ca.MY, FLCRIDA

l Case No.:

STATE OF FLCRIDA,

2014-201CF

v.
TEFRf G. TRUSSELL,
Defendant.

l\OTIO'J FCR a:NTINLLAN:E OF PRE-TRIAL

The Defendant, TERRY G. TRLBSELL, by and through his undersigned

counsel , pursuant to 3.190(f), Florida Rules of Civil Procedure, hereby
files the fo I lowing Mot ion for Conti nuance of Pr -T ial Conference set
for July 15 , 2015, and as grounds therefore wou d shovv::

Cn or about May 27, 2015, the eourt se1 a Pretr ia I Conference

1.

for July 15, 2015 at 10:30 a .m . t rough a No ice ot

The undersigned counse I has jus

2.

bar by the Defendant

As

th

ppearance.

been retained on the case at

Court

Knows,

t is

is

a case of

first

impress ion

arising under Florida Statute 834 . 0855(2)-(4), which were enacted in

Cktober 2013.
with the

Tqis 1s r8 14 Count Information involving those sections

potent~1

4.
case file

of significant penalties and prision time.

The undersigned counsel needs additional time to obtain the

fran the prior counsel seeking to withdraw,

to review the

discovery files, and the investigative the files in order to be prepared

for a Pretrial Conference .
5.

Additionally, the undersigned counsel resides a good distance

f rem Dixie County and needs to make arranganents far t rave I and chi Id
care of a minor ch ii d.

Electronically Filed Dixie Case # 14000201CFAXMX 07/13/2015 01:29:49 PM

6.

The undersigned

William Meggs on this

counsel

has

contacted The State Attorney

issue, and on the secondary issue also set for

prior counsel to withdraw. There is no objection to the prior counsel

being allowed to withdraw without having to attend the hearing due to
the

filing of the Notice of Appearance of the undersigned. H()Never,

Neggs did not agree to the Pre-Trial Conference being continued at that
time. fv'leggs will

be contacted again on

today's date

for

his

final

posit ion .
7.

The undersigned counsel further certifies that this motion is

l1"E::1e in good faith and is not in tended for the pu,q:mse of de lay but in
order to allow Trussell to have effect've assistance of counsel.
~.

requests

this

the
Court

Defendant,
to

through

enter

an

undersigned

Order

counsel ,

granting_ the

hereby

Motion

for

Continuance and to reset the Pretrial Dae for a date not less than 30
days frcm the date of th is Mot ion.

CEiRT1FIGA1E OF SEFMCE
that a true and correct copy of the above mot ion
has been served tis 1'3th day of July, 2015 to all parties listed on the
following Se vice List in accordance with Rule 1 .080, Florida Rules of
Civil

Procedure

and

Rule

2 .516,

Florida

Rules

of

Adninistrative

Procedure.
Respectfu 1ly sutmitted,
Inger Garcia, Esq .
Attorney for Trussel I
P .0. Box 11933
Fort Lauderdale , FI or ida 33339
Tel.: (954) 894-9962
Fax: (954) 446~1635
Serv iceE-Mai I :at torne~ingergarc ia .can
By: /Is// Inger Garcia
Inger Gare ia, Esq .

(FBN:0106917)

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