Choctaw Nation of Oklahoma,
Plaintiff,
VS.
Douglas Dry,
Rosie Lee Burlison, and
Juanita McConnell,
Defendants.
No. CR-95-03, 05
To the Honorable Judge of Said Court:
COMES NOW Juanita McConnell, Defendant in the above styled and numbered cause, by and through her attorney of record, Scott Kayla Morrison, and moves for severance from co-defendants Douglas Dry and Rosie Lee Burlison and in support thereof would show the Court as follows:
Defendant Douglas Dry has been charged with a separate and distinct crime of assaulting a police officer from co-defendant Juanita McConnell. Defendant McConnell will suffer prejudicial harm by evidence introduced to prove Dry's quilt or innocence.
Regardless of the trial court's instructions to the contrary, the jury will consider the co-defendant's alleged acts and declarations against Defendant McConnell, causing prejudice. II.
Defendant Rosie Lee Burlison has been charged with a separate and distinct crime of resisting arrest from co-defendant
Juanita McConnell. Defendant McConnell will suffer prejudicial
harm by evidence introduced to prove Burlison's guilt or
innocence. Regardless of the trial court's instructions to the
contrary, the jury will consider the co-defendant's acts and declarations
against Defendant McConnell, causing prejudice.
WHEREFORE, PREMISES CONSIDERED, the Defendant Juanita McConnell prays that her case be severed from that of codefendants Douglas Dry and Rosie Lee Burlison and that she be tried alone.
STATE OF OKLAHOMA
COUNTY OF LATIMER
BEFORE ME, the undersigned authority, appeared on the 2nd day of October, 1995, and who being by me duly sworn did depose and state on her oath the following:
"My name is Juanita McConnell. I am the defendant in the above entitled and numbered cause. I have read the foregoing Motion for Severance and swear that it is true and correct."
SUBSCRIBED AND SWORN TO before me this 2nd day of October,
1995.
My Commission Expires: 12-18-96
I certify that I mailed first class postage prepaid the above and foregoing Motion for Severance to Robert L. Rabon on this 13th day of October, 1995.