IN THE CIRCUIT COURT FOR THE COUNTY OF ST.

CHARLES
STATE OF MISSOURI

STATE OF MISSOURI. )
Plaintiff, )
) Cause No. 1611-CR004519-01
v. )
) Division V
PAMELA HUPP, )
Defendant. )

DEFENDANTS MOTION FOR CONTINUANCE

COMES NOW Defendant, Pamela Hupp, by and through her counsel, and

requests a continuance of the trial setting in the above styled cause. In support of her

Motion, defendant states as follows:

1. Pamela Hupp is charged in the above styled cause with murder in the first

degree wherein the State has filed Notice of Intent to Seek the Death Penalty.

2. Pamela Hupp was arraigned on January 30, 2017 and the State filed Notice of

Aggraviting Circumstances on March 16, 2017.

3. The case is now set for trial on April 10, 2018 with a jury to be selected from

Clay County and transported to St. Chales County.

4. The States discovery is not yet completed. Defense counsel was informed on or

about October 26, 2017 that the State was processing discovery that is very large.

Defendant has not yet received or reviewed that discovery. Defendant anticpates that

after discovery is concluded that she will need time to conduct additional investigation.

1
 5. Defendant has also not yet completed investigation regarding potential

mitigation, including documents and testimony that could support the finding of statutory

mitigating circumstances.

6. Defense counsel believes that additional time is necessary to fully review and

investigate the case in accordance with its obligations under the Sixth Amendment to the

United States Constitution.

7. Defense counsel is aware of logistical constraints that are involved with

selecting the jury from Clay County and sequestering them in St. Charles County. As of

todays date, having not received, reviewed or investigated all of the States discovery

nor completed the mitigation investigation, defendant cannot say with certainty that she

will be prepared for trial on April 10, 2018.

8. Defendant therefore requests a continuance of the current trial setting to ensure

that discovery and investigaiton are fully completed prior to trial. Pamela Hupps request

for a continuance is in the interest of justice and is not intended to vex or delay the Court.

WHEREFORE, defendant Pamela Hupp requests that this Court continue her trial

date from the Courts docket of April 10, 2018 and for any additional relief that the Court

deems just and proper.

Respectfully Submitted,

/s/___Kim Freter________________________
Kim C. Freter #47777
Attorney at Law
225 S. Meramec, Ste 1100

2
 Clayton, MO 63105
Phone: (314) 721-6565
Fax: (314) 269-1042
kimstate@freterlaw.com

ATTORNEY FOR DEFENDANT

Certificate of Service
I do hereby certify that a copy of the foregoing was filed with the Courts
electronic filing system and thereby served to all parties on this _7th____ day of
_____Nov________ 2017.
/s/___Kim Freter________________________
Kim Freter