Fill and Sign the Filing a Motion in a Maryland Circuit Courtthe Maryland Peoples Form

IN THE CIRCUIT COURT OF_________ COUNTY, ____________ STATE OF ) ) PLAINTIFF ) ) NO. V. )) NAME OF DEFENDANT ) ) MOTION FOR CONTINUANCE Comes now _________________, by and through her attorney, and files this her Motion for Continuance and would show unto the Court the following: 1. That said ___________________ was indicted by the Grand Jury empaneled for the _____________________ Term of the _______ County Circuit Court on a charge of Murder and Carrying a Concealed Weapon by a Convict. 2. That the defendant has filed a Petition for Writ of Error Coram Nobis in ______ County, _____________, asking that her conviction be set aside as shown by Exhibit "A". 3. That the Petition should be heard during the __________ Term of Circuit Court in ___________, ___________. 4. The defendant believes and hence alleges that at her trial the State will attempt to introduce evidence, make reference to, or otherwise leave the jury with the impression that she has been involved as a perpetrator, defendant, and subsequently convicted in previous cases charging the defendant with the offense of Manslaughter, with the defendant having been convicte
D and having been sentenced for the offense of manslaughter, that the defendant having been convicted and sentenced in the prior cases and having since the time of her conviction and sentence been convicted and sentenced for other offenses, that the defendant has been sentenced to death twice on separate occasions, ) ) , that she has suffered physical injuries to persons ) in an incident involving the infliction or attempted infliction of serious physical injuries to another person, that the defendant has in the course of her employment as a law enforcement agent or otherwise been employed in positions of trust, authority, accountability, and responsibility for the safety of persons, that she is presently on active duty with the United States military and that the defendant, having been arrested and incarcerated, was not free to leave the prison without the permission of the prison warden or the authority of the prison warden that during her jail term the defendant, in and out of the jail, has been and is a ward of the state, a ward of the city or city and county of. , and a dependent of the grand lor family and is a resident of . . . . , that the defendant has been sentenced to a prison term from time to time but that the sentence is not life and no death penalty has ever been imposed, that the defendant has the right to appeal from the decision of the court in this case that the defendant has not been required to be present at the court in this case, in the circuit court of . , to make a timely and adequate motion requesting that the judgment rendered in this case be set aside by the court for the reason that its ruling violated her constitutional guarantees of due process and of the right to due process. In his motion for additional time, defendant stated that she has had sufficient time. To prepare an argument to be submitted to the court at the time of the hearing in this case, and she indicated that she intends to use this opportunity to discuss the reasons why this court should set aside the judgment and to present her views in the form of an argument. Upon the court's request for a response from the defendant, the defendant's attorney 3. The petition was filed by the defendant on the day . 5 days after the date upon which the jury returned a verdict of guilty. (motions for continuance have the right to be filed within the time specified for such purpose in r. C. .) ) the petitioner on or about . 6 days after the date upon