Local Court Rules of the Thirteenth Judicial Circuit

MOTION FOR NEW TRIAL

IN THE CIRCUIT COURT OF COUNTY,

Comes now and files this Motion for New Trial herein and in support thereof would show unto the Court that the Defendant is entitled to a new trial for the following reasons:

1). The State mentioned in closing arguments statements concerning the projected use of a dog if a consent to search was not granted by the Defendant and there was no testimony of same before the jury;

2). The State mentioned in their testimony before the Jury the "Cartel" and how they package, deliver drugs and how much they bring in to the United States which was not relevant to the issues in this trial for which a mistrial was requested;

3). The State attempted to raise in their case that circles on the map were known "Drug Cities" through the testimony of Officer and managed to get part of that information before the Jury before the Court sustained the Objection;

4). The Court allowed the State to testify in rebuttal testimony as to what had happened to the Marijuana, when no question was asked to any of the defendant's witnesses about what happened to the Marijuana.

5). The State continuously lead their witnesses placing the defendant in the Catch "22" possession of continuously objecting and alienating the jury or not objecting and allowing the leading questions to influence the jury.

Wherefore premises considered, because of the total circumstances herein, Defendant prays for a New Trial.

Respectfully Submitted.

BY:

CERTIFICATE OF SERVICE

I, attorney for the defendant herein, do hereby certify that I hand- delivered a true and correct copy of the above and foregoing Motion for New Trial to

This the day of