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IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA COMMONWEALTH OF PA Plaintiff, v.

Tanuja Singh Murray (incorrectly capitioned as Tanuja Sungh Murray Defendant. ) ) ) ) ) ) )

CRIMINAL DIVISION

DEFENDANTS OMNIBUS PRE-TRIAL MOTION FOR RELIEF WITH CITATIONS TO AUTHORITY AND NOW COMES the Defendant, Tanuja Singh Murray, a member of THE THOROUGHBRED TEAM which was engaged in a contract with another legal entity (as per contract terms and as party p ayable by the alleged bad check in question), by herself pro se and as an attorney not admitted to this states bar but a member of the National Patent Bar and formerly the state bars of NJ and NY, hereby files the following pre-trial motions, stating in support thereof as follows:

INTRODUCTION
On _____, a Criminal Complaint was filed against defendant, based upon affidavit of Mike Jester, owner of Penn Ridge Farms. Despite the numerous defects upon the face of this private criminal complaint, it has proceeded to this point, and since the Magistrate court evidenced extreme bias and prejudice in this matter (pronouncing the bounced check as a bad check within one minute of the initial preliminary hearing and ignoring mitigating evidence and information that would cause any reasonable person to re-examine the validity of the alleged crime). STANDING NO DEBT NO INJURY NO ENRICHMENT CHECK FROM LLC TO LLC PRECLUDES INDIVIDUAL (Jester) FROM FILING COMPLAINT AGAINST MEMBER POST DATED CHECK JURISDICTION INCOMPLETE PRIVATE COMPLAINT LACK OF DUE PROCESS / INVESTIGATION SPECIFICITY S.O.L. DA DATING OF APPROVAL INCORRECT IDENTIFICATION OF INDIVIDUAL INCORRECT INDIVIDUAL INCORRECT VENUE CHOICE OF LAW AND VENUE CLAUSE CONFLICT OF PLAINTIFF (Real Party Of Interest) The complaint alleged a bad check with NO EVIDENCE or BILL OF PARTICULARS

MOTION FOR BILL OF PARTICULARS


The defense requests the following particulars with respect to each count of the Information: The dates, times and locations of each act in furtherance of the charged offenses and the nature of bad check The purposes of the bill of particulars are to enable a defendant to prepare for trial, to avoid surprise, and to enable the defendant to interpose the defenses of double jeopardy and the statute of limitations to this and future prosecutions. See Commonwealth v. Chambers, 528 Pa. 558, 580, 599 A.2d 630 (1991); Commonwealth v. Simione, 447 Pa. 473, 291 A.2d 764 (1972). Each of these purposes necessitates a bill of particulars in this case. To defend against these charges,Defendant is entitled to know which crime he committed and the specific date that crime was to have allegedly occurred. Under this set of facts, it will be difficult to defend against the charges I will have to prepare a defense that covers a one- or two-year spanit is unclear which. This cannot be done and the case cannot be defended against unless the defense knows the specific dates on which alleged t is an abuse of process and discretion, offenses are to have occurred. The Commonwealth is unfairly attempting to hide its proof problems caused by the unreliability of the sole witness y an absurd procedure is extremely prejudicial to the defendant and constitutes a fatal pl eading error in the Commonwealths Information. For the reasons set forth above, the defendant respectfully requests that Counts One through Five be dismissed for failing to specify a date of commission and for duplicity. Respectfully submitted, _____________________________ Tanuja Singh Murray, PRO SE Defendant

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