Opinion
Criminal No.: 3:10-CR-0260(30)
03-19-2012
UNITED STATES OF AMERICA v. MOHAMMED AMALLE
Judge
MOTION TO ALLOW PARALEGAL ASSISTANCE AT COUNSEL TABLE DURING
TRIAL
Comes now the Defendant, Mohammed Amalle, by and through the undersigned counsel, and moves this Honorable Court for permission to allow paralegal assistance at counsel table during trial. In support thereof counsel would show that:
1. Counsel for Defendant Amalle fractured his right hand (5th metatarsal) on March 5, 2012. In order to set the fractured bone properly, doctors re-fractured, set and cast the hand twice on March 15, 2012. The estimated time of recovery is six weeks.
2. Counsel for Defendant Amalle is right-handed. The injury and cast severely impair counsel's ability to write and take notes during trial. Accordingly, counsel is in need of such assistance once the trial commences on March 20, 2012. Counsel's paralegal is very familiar with this case and is needed to assist counsel at counsel table in the representation of Defendant Amalle.
Respectfully submitted this the 16th day of March, 2012.
Signed
R. LANCE MILLER, BPR No. 25875
Attorney for Defendant
420 Madison Street, Suite B4
Clarksville, Tennessee 37040
Telephone: (931) 802-6180
Fax: (931) 802-6182
lance@lancemillerlaw.com