IN THE DISTRICT COURT IN AND FORTULSACOUNTY

STATE OF OKLAHOMA

STATE OF OKLAHOMA,)

)

Plaintiff,)

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v.)Case No. CF-2003-4213

) )

GORDON TODD SKINNER.)

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Defendant.)

Motion to Waive Right to Speedy Trial Under

The interstate Agreement on Detainers Act

COMES NOW the Defendant Gordon Todd Skinner. By and through his attorney, Kevin Adams, and moves this Court to grant the Defendant’s waiver of his right to a speedy trial under the Interstate Agreement and Detainers Act, Title 22 O.S. § 1347. In support of this Motion, Defendant, Gordon Todd Skinner, alleges and states the following:

  1. Defense Counsel Kevin D. Adams has just entered his appearance in the above styled matter.
  2. There are numerous pages of discovery and numerous video tapes for defense counsel to review. Furthermore there are complicated issues of law that needs to be researched and evaluated by the Defendant’s new Defense Counsel.
  3. Presently this matter was set for a Kastigar Hearing for today January 25, 2005 however, defense counsel has not had an opportunity to prepare for that hearing.
  4. Currently this matter is set for Jury trial February 14, 2005. However, because defense counsel has just entered the case, the volume of discovery and complexity of the issues would not allow defense counsel to be adequately prepared for trial of this matter by that date.
  5. The Defendant, Gordon Todd Skinner, has been advised that the State must bring him to trial within 120 days under the Interstate Agreement on Detainers Act.
  6. Because of the complex legal nature of this case and the above stated reasons, the Defendant, Gordon Todd Skinner, contends that his counsel cannot prepare and adequate defense within the original 120 time frame or by present trial date February 14, 2005.

WHEREFORE, Defendant, Gordon Todd Skinner, asks this Court to grant his Motion and allow him to waive his right to a speedy trial under the Interstate Agreement on Detainers Act, Title 22 O.S. § 1347. Respectfully Submitted,

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Kevin D. Adams, OBA# 18914

1717 S. Cheyenne

Tulsa, OK74119 (918) 587-8100

Approved as to form and Substance:

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Gordon Todd Skinner, Defendant

CERTIFICATE OF HAND DELIVERY

I hear by certify that a copy of the foregoing instrument was hand delivered on January 25, 2005 to the office of the following:

Dave Robertson

Tulsa County District Attorney’s Office

500 S. Denver

Tulsa, OK74103

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Kevin D. Adams