Anne Arundel Circuit Court
Docket: 6/6/2019 1:40 Submission: 6/6/2019 1:40 PM

STATE OF MARYLAND IN THE CIRCUIT COURT
OF MARYLAND FOR
JARROD RAMOS ANNE ARUNDEL OUNTY
CASE NO. C-02-CR-18-001515

MOTION TO BIFURCATE TRIAL

The Defendant, by undersigned counsel, respectfully requests, pursuant
to the Fifth, Sixth, Eighth, and Fourteenth Amendments of the United States
Constitution, Articles 16the Maryland Declaration of
Rights, Md. Code Ann., Crim. Proc. Art. 3-101, 3-109, and 3-110, Maryland
Rules 4-242 and 4-314 and all other applicable federal and state law, and moves
this Honorable Court for a bifurcated trial in the above captioned case in which
the issue of criminal responsibility will be heard and determined separately from
the issue of guilt and in support of this Motion, Defendant states as follows:

1. The Defendant is charged with ?ve (5) counts of first degree murder
and related offenses in this matter. The State has ?led five (5) separate Notices
of Intention to Seek a Penalty of Life Without the Possibility of Parole.

2. The Defendant has entered pleas of Not Guilty and Not Criminally
Responsible, pursuant to Maryland Code, Criminal Procedure Article 3-101 et
seq and Maryland Rule 4-242.

3. Maryland Code, Criminal Procedure Article 3-110 and Maryland
Rule 4-314 provide for a bifurcated trial in which the issue of criminal

responsibility is heard and determined separately from the issue of guilt.

 

Court:

WHEREFORE, Defense Counsel respethully requests that this Honorable

A. Grant the Defendant?s Motion to Bifurcate Trial;
B. Bifurcate the trial in the above Captioned matter such that the

issue of criminal responsibility is heard and determined

separately from the issue of guilt;
C. Conduct the trial pursuant to Maryland Code, Criminal
Procedure Article 3-110 and Maryland Rule 4-314; and

D. Hold a hearing and/or grant such additional relief as the nature

of this case may require.

Respectfully submitted,

/sNVil iam M. Davis

William M. Davis - 9106200054
District Public Defender

Of?ce of the Public Defender
1700 Margaret Ave

Annapolis, Md. 21401
410-295?8800
wdavis@opd.state.md.us

ls/ Elizabeth Palan

Elizabeth W. Palan 9712180285
Deputy District Public Defender
Of?ce of the Public Defender
1700 Margaret Ave

Annapolis, Md. 21401
410-295-8800
epalan@opd.state.md.us

Katy C. O?Donnell

Katy C. O'Donnell - 8501010456
Division Chief, Major Crimes Complex
Litigation

 

Office of the Public Defender
6 St. Paul Street, Suite 1400
Baltimore, MD 21202
410-767-9852

FAX: 410-333-8496
kodonnoll@opd.state.md.us

POINTS AND AUTHORITIES

United States Constitution, Amendments IV, V, VI, and XIV
Maryland Declaration of Rights, Articles 16, 21, 23, 24, and 25
Maryland Code, Criminal Procedure Article 3-101 et seq.

Maryland Rules 4-242 4-314

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 6th day of June, 2019, a copy of
the foregoing Defendant?s Motion to Bifurcate Trial was delivered to the Of?ce of

the State's Attorney for Anne Arundel County, Anne Colt Leitess and James
Toumey via electronic filing.

William M. Davis
William M. Davis