Charles Sprinkler Sent Charlie to court with this at 4:34 pm Monday, August 11, 2003.
1273 Rice Road #48 They filed it with minutes to spare. Charlie is back at 5:11 pm.
Ojai CA 93023
640 0439
In Pro Per with assistance from www.lawyerdude.8m.com
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Combined Superior and Municipal Court of California
800 S. Victoria, Ventura CA 93003
People
v
Charles Sprinkler
Case # 2002: 013, 441
Document #5925 Demand to withdraw not guilty plea and hear 995 Motion. In folder #536. 11th for Sprinkle.
Motion to continue
Declaration of Charles Sprinkle regarding emptiness of the Floppy disk where I expected the transcripts to be.
Current Trial date:
Document #5899 version 1.4
This is the 2nd defense document.
Demurrer and Demand for immediate dismissal.
Notice of Defendant’s concurrent Demands as follows:
I make no waivers. Any oral waivers are void.
Demand for effective assistance of counsel.
Demand for judge who has passed the bar - and not a commissioner.
Demand for copy of Judge’s oath. Demand for court reporter.
Demand for prompt (within a week) written transcript of every hearing, past, present, and future (as they become available)
Demand for jury trial. Demand for Discovery.
Demand for indictment by grand jury. Demand to suppress the writing.
Demand for full panoply of criminal due process procedures and rights.
Demand for proposed jury instructions a month in advance of trial.
Notice of Concurrent Motions to be filed as follows:
#5902 Motion to Suppress Evidence. Ready to file August 4.
#5904 Discovery Motion including Brady Demand.
#5905 Demand for Re-arraignment.
#5906 Dombrowski Motion.
#5907 Quo Warranto Motion.
#5908 Overbreadth Motion.
#5909 Demand to Strike Hearsay statement of James Kilfoyle
#5910 Gerstein Motion.
#5911 Motion to Dismiss.
#5912 Motion to Continue
Supporting Declarations. Memorandum of Law.
Proof of Service by fax.
Proof of Service
Date: Tuesday 12 August 2003
Place: Court 14.
Time: 9 a.m.
Notice of Continuance Motion.
To District Attorney Greg Totten and his employees: Be advised that at the venue indicated or at such other venue as the court shall prescribe the defendant will for a continuance based on unavoidable delay.
_______________________ Charles Sprinkle. Monday, August 11, 2003
Motion to continue this case 4 weeks until Tuesday September 9th at 9 a.m. in this courtroom.
I ask to continue this case in order to permit me to obtain the transcript on floppy. As set forth in the following declaration, Marty put the transcript on floppy for me - or so he thought. However, when put the floppy in my machine, the floppy disk appeared to be empty. I put in a request to Marty Heckerman, RPR, CSR, for another floppy and I am sure that he will have it soon.
This delay is for all intents and purposes, unavoidable. There was a delay in obtaining the transcript. I ordered them promptly. The delay was in the court reporter’s office. And I am sure there was a good reason there. _______________ Charles Sprinkle
Declaration of Charles Sprinkle Regarding the emptiness of the Floppy disk
where I expected the transcripts to be.
I, Charles Sprinkle declare the following under penalty of perjury: On our about 23 June Marty Heckerman mailed a floppy diskette to my lawyer. Thereafter, some time in July my lawyer delivered the cassette to me. Only then did I discover that there is nothing on the cassette. I thereafter called 662-6652, Marty’s number and left a message asking him to re-copy the floppy. I expect to receive a replacement floppy within a week.
I did not receive the transcripts in time to write anything for the appellate department.
I will either do a motion in this trial court or an appeal in the appellate department or a writ at the court of appeal – but I need a transcript to do any of these. We are making progress. I have a paper copy but I need a copy that I can copy and insert into my briefs.
_____________________ Charles Sprinkle.
Proof of Service
I, Jan Tegard, declare the following under penalty of perjury. I served this Motion #5924 on the district attorney by hand delivering it to the receptionist at his office on the 3rd floor of the court house at 800 S. Victoria, Ventura CA 93003 on this day Signed Jan Tegard ________________. Date Monday, August 11, 2003_______________