IN THE CIRCUIT COURT OF MADISON COUNTY, ALABAMA
STATE OF ALABAMA,))Plaintiff,))VS.)CASE NUMBER:CC2011-2417 KKH)HAMMAD AHMAD MEMON,))Defendant.)
MOTION TO CONTINUE TRIAL DATE
COMES NOW the Defendant, by and through counsel, and most respectfully showsunto this Honorable Court:1.Trial of this case is presently set for June 18, 2012.2.The Defendant is in custody at the present time. This Court revoked theDefendant’s pretrial bond as a result of the Defendant’s apparent attempt to flee the jurisdiction.3.Undersigned counsel has spent considerable time with the Defendant since hisreturn from Texas. These discussions have led counsel to the good faith belief that theDefendant is presently not competent to stand trial.4.In addition, counsel is of the belief that the Defendant suffers from a severemental illness. Further, counsel is of the belief that, at the time of the alleged incident, theDefendant suffered from a severe mental illness.5.The Defendant’s severe mental illness has worsened as a result of the recentevents in the case and his subsequent incarceration.6.The Defendant is in need of additional time to prepare for a defense of notguilty by reason of mental disease or defect.7.The Defendant intends to retain his own experts, and is not seeking a court-ordered mental health evaluation.
ELECTRONICALLY FILED5/3/2012 4:13 PMCC-2011-002417.00CIRCUIT COURT OFMADISON COUNTY, ALABAMAJANE C. SMITH, CLERK