Professional Documents
Culture Documents
Pam Hupp Trial Delay Request
Pam Hupp Trial Delay Request
Pam Hupp Trial Delay Request
CHARLES
STATE OF MISSOURI
STATE OF MISSOURI. )
Plaintiff, )
) Cause No. 1611-CR004519-01
v. )
) Division V
PAMELA HUPP, )
Defendant. )
COMES NOW Defendant, Pamela Hupp, by and through her counsel, and
requests a continuance of the trial setting in the above styled cause. In support of her
1. Pamela Hupp is charged in the above styled cause with murder in the first
degree wherein the State has filed Notice of Intent to Seek the Death Penalty.
2. Pamela Hupp was arraigned on January 30, 2017 and the State filed Notice of
3. The case is now set for trial on April 10, 2018 with a jury to be selected from
4. The States discovery is not yet completed. Defense counsel was informed on or
about October 26, 2017 that the State was processing discovery that is very large.
Defendant has not yet received or reviewed that discovery. Defendant anticpates that
after discovery is concluded that she will need time to conduct additional investigation.
1
5. Defendant has also not yet completed investigation regarding potential
mitigation, including documents and testimony that could support the finding of statutory
mitigating circumstances.
6. Defense counsel believes that additional time is necessary to fully review and
investigate the case in accordance with its obligations under the Sixth Amendment to the
selecting the jury from Clay County and sequestering them in St. Charles County. As of
todays date, having not received, reviewed or investigated all of the States discovery
nor completed the mitigation investigation, defendant cannot say with certainty that she
that discovery and investigaiton are fully completed prior to trial. Pamela Hupps request
for a continuance is in the interest of justice and is not intended to vex or delay the Court.
WHEREFORE, defendant Pamela Hupp requests that this Court continue her trial
date from the Courts docket of April 10, 2018 and for any additional relief that the Court
Respectfully Submitted,
/s/___Kim Freter________________________
Kim C. Freter #47777
Attorney at Law
225 S. Meramec, Ste 1100
2
Clayton, MO 63105
Phone: (314) 721-6565
Fax: (314) 269-1042
kimstate@freterlaw.com
Certificate of Service
I do hereby certify that a copy of the foregoing was filed with the Courts
electronic filing system and thereby served to all parties on this _7th____ day of
_____Nov________ 2017.
/s/___Kim Freter________________________
Kim Freter