IN THE CIRCUIT COURT OF DALLAS COUNTY, MISSOURI
ASSOCIATE CIRCUIT DIVISION
STATE OF MISSOURI, )
) Case Number 06H6-CR00971
SUGGESTIONS IN SUPPORT OF DEFENDANT’S
MOTION FOR CHANGE OF VENUE
COMES NOW Defendant and in support of her Motion for Change of Venue states as follows:
- Rule 32.03 (2006) requires that when a court transfers venue from one county to another, the new county shall be one that is “convenient to the parties”.
- Among the counties in the Thirtieth Judicial Circuit (herinafter “Circuit”), Benton County, Polk County and Webster County are convenient to the parties in this cause of action.
- Defendant resides in Cameron, Missouri, which is located substantially closer to Benton County than any other county in the Circuit.
- Defendant’s attorney maintains an office in Springfield, Missouri, which is closer to Polk County and Webster County that any other county in the Circuit.
- Patrolman Duane White, a potential witness in this case, resides and works in Dade County, which is closer to Polk County than any other county in the Circuit.
- Patrolman Robert Garrett and Corporal Bierer reside and work in Dallas County, which is as close to Webster County and Polk County as it is to any other county in the Circuit.
- The Complainant’s attorney, Barbara Viets, is located in Dallas County, which is as close to Webster County and Polk County as it is to any other county in the Circuit.
THE SMITH LAW FIRM, LLC
Neil Smith, Bar Number 56789
320 East Walnut, Suite 210
Springfield, Missouri 65806
CERTIFICATE OF SERVICE
I certify that a copy of the foregoing was hand-delivered, on October 13, 2006, to Barbara Viets, attorney for Complainant.