DOCUMENT 188

ELECTRONICALLY FILED
3/6/2020 4:33 PM
44-CC-2019-000476.00
CIRCUIT COURT OF
LIMESTONE COUNTY, ALABAMA
BRAD CURNUTT, CLERK

IN THE CIRCUIT COURT OF LIMESTONE COUNTY, ALABAMA

STATE OF ALABAMA,

PLAINTIFF,

vs. CASE NO. CC19-476

BLAKELY, MICHAEL ANTHONY,

DEFENDANT.

MOTION TO CONTINUE

Comes now the defendant, Mike Blakely by and through counsel and moves this Honorable
Court to continue the trial of the above referenced case. As grounds defendant states as
follows:

1. The Defendant is charged with Theft and Ethics violations in a 13-count Indictment.

2. Defendant’s Trial is scheduled for March 9, 2020.

3. That Defendant is currently in Room 209 of Athens - Limestone Hospital and has a serious
respiratory condition.

4. Defendant is diagnosed with acute respiratory failure and asthma. Defendant is currently
being tested for Corona Virus (COVID-19).

5. That a Doctor has admitted Defendant on Friday, March 6, 2020 and expects a hospital stay
for at least two (2) to three (3) days. The Doctor does not expect Defendant to be available for
Trial on Monday, March 9.

6. Doctor will re-evaluate Defendant’s status on Monday to determine when he will be

medically available to withstand a 2 week trial.

7. In the interest of Justice and due to medical necessity, Counsel requests a continuance of this
case. A Doctor’s letter regarding this matter is attached as Exhibit A.

WHEREFORE, the Defendant respectfully requests that this Trial be continued.

 DOCUMENT 188

Respectfully submitted this 6th day of March, 2020.

/s/ Robert B. Tuten /s/ Marcus Helstowski

ROBERT B. TUTEN (TUT002) MARCUS HELSTOWSKI
ASB # asb-4036-e56r Co-Attorney for Defendant
Attorney for Defendant 223 Eastside Square
TUTEN LAW OFFICES Huntsville, Alabama 35801
256-536-6009 256-534-3018
Alafilerbt@tutenlaw.com mhelstowski@yahoo.com

Of Council:
Mark McDaniel
McDaniel and McDaniel, LLC
223 Eastside Sq
Huntsville, AL 35801
256-534-3018
CERTIFICATE OF SERVICE

This document has been filed electronically and served upon opposing counsel pursuant
to the Administrative Procedure for Filing Signing and Verifying Documents by Electronic
Means in the Alabama Judicial System. For any opposing counsel or unrepresented parties who
are not registered to file electronically, a copy of this pleading shall be served via the U.S. mail,
postage pre-paid, to the litigant’s address as maintained in the office of the Circuit Clerk.

Done this 6th day of March, 2020.

/s/ Robert B. Tuten

ROBERT B. TUTEN