II. MOTION FOR CHANGE OF VENUE/VENIRE
6. Defendant incorporates by reference the allegations contained in Paragraphs 1-5, inclusive of this Motion as if same were fully set forth herein at length.
7. There has been extensive, inflammatory, sensational and highly inculpatory publicity about this incident and the arrest of Cuadra from the day of the incident to the present. Copies of newspaper articles, magazine articles and television broadcasts from The Citizen’s Voice, The Times Leader, WNEP, WBRE and Google are attached collectively hereto and incorporated by reference as Exhibit “A”.
8. Due to the aforesaid pre-trial publicity, it will be impossible to select a fair and impartial jury and to receive a fair trial.
9. Cuadra’s right to a fair trial and opportunity to select an impartial jury has been further hampered by the Commonwealth’s intentional filing and publication of more than 200 pages of discovery in response to Cuadra’s Motion To Compel an Answer to Cuadra’s Request For A Bill of Particulars.
6. Defendant incorporates by reference the allegations contained in Paragraphs 1-5, inclusive of this Motion as if same were fully set forth herein at length.
7. There has been extensive, inflammatory, sensational and highly inculpatory publicity about this incident and the arrest of Cuadra from the day of the incident to the present. Copies of newspaper articles, magazine articles and television broadcasts from The Citizen’s Voice, The Times Leader, WNEP, WBRE and Google are attached collectively hereto and incorporated by reference as Exhibit “A”.
8. Due to the aforesaid pre-trial publicity, it will be impossible to select a fair and impartial jury and to receive a fair trial.
9. Cuadra’s right to a fair trial and opportunity to select an impartial jury has been further hampered by the Commonwealth’s intentional filing and publication of more than 200 pages of discovery in response to Cuadra’s Motion To Compel an Answer to Cuadra’s Request For A Bill of Particulars.
WHEREFORE, Harlow Cuadra, respectfully requests this Honorable Court to enter an Order granting Cuadra a change of venue or venire.
