Commonwealth v. Potts

I concur in the result, only.

The issue raised is whether the trial court erred in granting the Commonwealth’s Petition to Extend under Pa.R. Crim.P. 1100 because of its untimely filing. As discussed below, I consider this issue waived and would therefore affirm the judgment of sentence without reaching appellant’s Rule 1100 claim.

The trial transcript discloses that appellant’s counsel made oral post-verdict motions at the conclusion of the stipulated waiver trial. Those motions were denied immediately after presentation.

The presentation of oral post-verdict motions, however, is not adequate…