COLLIER IS UNABLE TO COUNT BEYOND THE NUMBER OF FINGERS ON HIS HAND!

During the September 4, 2009 session of the protracted suppression hearing, Defense Counsel raised the issue of the unspecified “criminal offense” SALISBURY charged in the indictment.


During those proceedings, the COLLIER ordered Salisbury to provide the defense with “a list of underlying criminal offenses” which Salisbury intended to present to the jury. 


This was a none too subtle message from COLLIER to SALISBURY to provide MULTIPLE UNDERLYING ALLEGED CRIMINAL OFFENSES to the defense, intended to thwart the Defendant’s preparation for trial, intentionally done by COLLIER to benefit the prosecutor. 

SALISBURY did not timely comply with COLLIER’S order to provide the defense with “a list of underlying criminal offenses.” 

Therefore, on September 24, 2009, Defense Counsel filed a Motion For An Order To Show Cause Why The Assistant Prosecutor Should Not Be Held In Contempt Of Court And Subject To Sanctions.

FOLLOWING IS AN EXCERPT TAKEN FROM THE MOTION TO SHOW CAUSE, WHICH IS 7 PAGES IN LENGTH AND CANNOT BE PUBLISHED HERE IN ITS ENTIRETY:

     "It is axiomatic that the Due Process Clause of the 14th Amendment requires that certain steps be followed before a person's "life, liberty, or property" can be taken away.  Procedural Due Process that the states afford an accused proper notice and a meaningful opportunity to be heard.  Nothing can be more basic and necessary than for Defendant, or any any accused person, to have knowledge of the charge against him.  The record of the case demonstrates that the prosecution has utilized every scheme and device to withhold and deny due process to Defendant.  SALISBURY'S recent disregard of the court's express mandate to identify the charged offense is but one example of the government's denial of due process.

     Therefore, the Defendant respectfully moves the court for an Order to Show Cause Why Assistant County Prosecutor Scott B. Salisbury Should Not Be Held in Contempt of Court and Subject to Sanctions, for violating the court's Order of September 4, 2009, by refusing to identify, in writing to the defense, by September 11, 2009, the "criminal offense" alleged, but not specified, in the Indictment." 

IT IS PERFECTLY CLEAR THAT THE PROVISIONS OF THE 14TH AMENDMENT TO THE UNITED STATES CONSTITUTION WERE EXPLAINED IN VERY FUNDAMENTAL TERMS TO COLLIER, TERMS THAT EVEN HE SHOULD BE ABLE TO UNDERSTAND.


Unfortunately, since the 14th Amendment is numbered well beyond the number of fingers on his hands, COLLIER fails to comprehend the concept of a Constitutional Amendment so highly numbered above 10.


Of course, Defense Counsel filed this motion prior to having become fully aware that COLLIER TAKES HIS ORDERS FROM HOLMAN AND SALISBURY!


MUCH MORE TO COME ....