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Case: 25CI1:16-cr-00176-JAW

Document #: 13

Filed: 08/30/2016

Page 1 of 4

Case: 25CI1:16-cr-00176-JAW

Document #: 13

Filed: 08/30/2016

Page 2 of 4

Case: 25CI1:16-cr-00176-JAW

Document #: 13

Filed: 08/30/2016

Page 3 of 4

Case: 25CI1:16-cr-00176-JAW

Document #: 13

Filed: 08/30/2016

Page 4 of 4

Case: 25CI1:16-cr-00176-JAW

Document #: 11

Filed: 08/17/2016

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IN THE CIRCUIT COURT OF HINDS COUNTY MISSISSIPPI


FIRST JUDICIAL DISTRICT
STATE OF MISSISSIPPI
VS.

CAUSE NO.: 16-0-176

ANDRE KENNEDY

DEFENDANT

UNOPPOSED MOTION FOR CONTINUANCE


Andre Kennedy, by and through his counsel, Christopher S. Routh of the Office of the
Hinds Public Defender files this Motion for Continuance and asks that this court continue his currently
scheduled trial date and in support thereof would show the following:
1. Mr. Kennedys case is currently set for trial on October 10th, 2016.
2. Mr. Kennedys Attorney, Christopher S. Routh, will be out of the state attending a
Continuing Legal Education seminar from approximately September 5th, 2016 to
approximately October 1st, 2016;
3. Mr. Routh will be out of the state in the weeks immediately preceding the scheduled trial
date of this matter, when trial lineups for any given trial week are generally announced.
Mr. Routh will not have adequate time to meet any required deadlines in this case and to
prepare this case for trial;
4. This case has been assigned to Mr. Routh by the Office of the Hinds County Public
Defender. Mr. Routh has entered an appearance in this case and is the attorney of
record. As such, no other attorneys from the Office of the Hinds County Public
Defender will be able to act as counsel for Mr. Kennedy. Additionally, other attorneys in
the Office of the Hinds County Public Defender have full caseloads and will not be
available to act as counsel in this case;

Case: 25CI1:16-cr-00176-JAW

Document #: 11

Filed: 08/17/2016

Page 2 of 3

5. This continuance will not affect any case assigned to Attorney Eric Brown, the other
Assistant Hinds County Public Defender assigned to this court, or any other attorney
assigned a case on this trial week. In fact, Mr. Routh has another case set for trial as a
priority setting on October 10th. Mr. Routh expects no delay in that trial as he is already
aware of its setting and is preparing accordingly;
6. The State has represented that they do not oppose this continuance and have signed and
submitted and agreed order to that effect;
7. As Mr. Kennedy has a right under the United States and Mississippi Constitutions to
counsel, Gideon v. Wainwright, 372 U.S. 335 (1963) and as Mr. Kennedys counsel will be
unavailable on his currently scheduled trial date, the Defense respectfully requests that
this court continue Mr. Kennedys trial date to the next available term.
WHEREFORE PREMISES CONSIDERED, Andre Kennedy respectfully moves that
this court grant the herein requested relief and continue this cause to the next available trial term.
Respectfully Submitted, this the 17th day of August, 2016.
ANDRE KENNEDY
/s/ Christopher S. Routh
BY: ____________________________________
Christopher S. Routh (Miss. Bar No. 104579)
Assistant Public Defender
Office of the Hinds County Public Defender
499 S. President Street
P.O. Box 23029
Jackson, Mississippi 39225
(601) 948-2683 Telephone
(601) 948- 2687 Fax
crouth@co.hinds.ms.us

Case: 25CI1:16-cr-00176-JAW

Document #: 11

Filed: 08/17/2016

Page 3 of 3

CERTIFICATE OF SERVICE
I, CHRISTOPHER ROUTH, attorney for the Defendant, do hereby certify that I have this
day electronically or hand delivered a true and correct copy of the foregoing Motion for Continuance to
Brad McCulloch, Assistant District Attorney at his usual and customary place of business, namely
the Office of the Hinds County District Attorney.
SO CERTIFIED this the 17th day of August, 2016.

/s/ Christopher S. Routh


_______________________________________________
CHRISTOPHER ROUTH (Miss. Bar No. 104579)

Case: 25CI1:16-cr-00176-JAW

Document #: 1

Filed: 02/26/2016

Page 1 of 1

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