IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF GEORGIA

ROME DIVISION

UNITED STATES OF AMERICA )

)

v. ) CRIMINAL ACTION

)

xxxxxxxxxxxxxx. ) NO. xxxxxxxxxx (HLM)

______________________________)

MOTION TO ADOPT AND CONFORM APPLICABLE

MOTIONS OF EACH AND EVERY OTHER CO-DEFENDANT

AND MEMORANDUM IN SUPPORT THEREOF

COMES NOW Defendant, xxxxxxxxxxxx., by and through undersigned counsel, and respectfully moves to adopt, conform and have the benefit of applicable motions filed by any co-defendant indicted in the above-styled action. As grounds for this motion, defendant states as follows:

(1)

Defendant is charged in this case with five other defendants. Counsel for defendant is aware that counsel for co-defendants will file motions that may well be applicable to each defendant.

(2)

So as to reduce the burden on this Court and with respect to repetitive pleadings, defendants hereby adopts all applicable motions of any co-defendant. Defendant will conform them, if necessary, and, if appropriate, will add supplemental memoranda in support thereof. If defendant does not intend to adopt a motion of a co-defendant, the Court will be notified promptly. Otherwise, defendant will have been presumed to have adopted all motions of his co-defendants, not inconsistent with defendant's position.

(3)

Discovery proceedings are still in progress. Due to the complexity of this case and the nature of the charges and indictment, the above relief is necessary in the interest of justice, for due process of law, and for effective assistance of counsel.

WHEREFORE, defendant respectfully requests that this Motion to Adopt and Conform Applicable Motions of Other Defendants be granted.

Dated: This ___ day of October, 1994.

Respectfully submitted,

__________________________________

GREGORY S. SMITH

ATTORNEY FOR

STATE BAR NO. 658375

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