Schabusiness Motion For Continuance

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Case 2022CF000363 Document 211 Filed 07-03-2023 Page 1 of 1

FILED
07-03-2023
Clerk of Circuit Court
Brown County, WI
2022CF000363

STATE OF WISCONSIN CIRCUIT COURT BROWN COUNTY


BRANCH II

STATE OF WISCONSIN,

Plaintiff,

vs. CASE NO. 22-CF-363

TAYLOR D. SCHABUSINESS

Defendant.

MOTION FOR CONTINUANCE

TO: BROWN COUNTY DISTRICT ATTORNEY

PLEASE TAKE NOTICE THAT the defendant, Taylor D. Schabusiness, formally appears by and through her
attorney, Christopher T. Froelich, in this action, and hereby makes a motion for continuance of the jury trial set for
July 24, 2023 - July 28,2023 at 8:15 a.m. before the Honorable Thomas Walsh, Branch II, for the following reasons:

1. Adjourn the jury trial so that the defendant can undergo another independent competency evaluation by
the Wisconsin Forensic Unit.

2. Determine if there will be a need to have a Daubert hearing regarding Dr. Diane Lytton’s NGI evaluation.

3. Allow the Court to determine if a competency evaluation will need to be conducted of the defendant in
light of the NGI evaluation and allow the Court time to address the defense motion.

4. Defense does not have all jail records requested of the defendant which request was made weeks ago.
The defense wants to examine all jail records to the present time to assess as part of the ongoing
investigation in this case.

Dated at Green Bay, Wisconsin, this 3rd day of July, 2023.

FROELICH LA:

By:
Christopher T. Froelich #01000834)
Attorney for Defendant
Address:
125 South Quincy Street
Green Bay, WI 54301
(920) 430-9640

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