5.  About the Accused

  Each motion should contain a section that pictures the accused favorably.  Sometime this can be accomplished by describing the accused, although this is not the only way to picture the accused favorably.  In a motion to exhume the body of the victim we once used the section about the accused to express his sympathy with the victim and to distant the accused from the acts of counsel in seeking to have the body of the victim exhumed.
 This section about the accused in that motion seeking to have the body of the victim exhumed reads as follows.

Examples of About the Accused  (Note, this is only a thumbnail)


155.  Counsel for Douglas Palmer prepared this amended and consolidated motion and gave a copy to Douglas Palmer.  He also has received a copy of the District Attorney's motion to disqualify Judge Pirtle and the answer to this motion filed by his counsel.

156. Douglas Palmer was asked about changes or suggestions to these legal papers and Douglas Palmer has requested his counsel add this section.  He wants counsel to say to the family and friends of Mr. Merriman that he regrets not only what happened to Mr. Merriman, but he regrets that his counsel are finding it necessary to disturb Mr. Merriman's remains from their final resting place.

Douglas Palmer, in his words, wishes to say, "I'm sorry, I'm sorry about all of this."
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