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DEFENDANT BILL OF COSTS

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DEFENDANT’S PROPOSED JURY INSTRUCTIONS

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Petition Pursuant to 28 U.S.C. §2255 Based on Johnson V. United States

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Request for Review of Pre-Trial Detention

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Objection to Resentence Report

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Motion to Reconsider Release into Inpatient Treatmen

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Defendant's Request for Pretrial Disclosure from Government

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Waive of Rights to Speedy Trial

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Defendant's Supplemental Motion to Suppress

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Motion to Suppress- Unconstitutional Arrest

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Motion to Suppress Search Warrant

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Defendant's Brief in Support of Motion to Suppress and Dismiss

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MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF NOTICE OF MOTIONS IN LIMINE

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Plaintiff’s First Amended Draft Jury Instructions and Verdict Forms

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TRIAL MEMORANDUM RE: NECESSITY

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Motion in Limine to Exclude Summary Witness

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Motion for Downward Departure

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Motion for a 90-Day Unopposed Ends-of-Justice Continuance and Brief in Support

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Defendant's Motion and Brief in Support to Enlarge Time for Filing Motions

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Defendant's Proposed Voir Dire

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Defendant's Motion for Extension of Time to File Motions

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Defendant's Motion to Sever

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Consent to Adjournment

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Defendant's Brief in Support of Motion to Sever

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Brief in Support of Motion to Suppress Statements

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Memorandum in Suport of Motion in Limine to Exclude Summary WItness

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Unopposed Motion to Travel

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Notice to Use 404B

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Motion to Request Notice 608

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Motion for Judgement of Acquittal Notwithstanding the Verdict, or Alternatively, for New Trial

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Defendant's Motion for Immediate Disclosure of Favorable Evidence

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Defendant's Proposed Additional Voir Dire Questions

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Defendant's Motion to Preserve Law Enforcement Notes

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Defendant Memorandum in Response to United States Trial Motion for Mandatory Detention

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Request for a Court Order to Conduct Arraignment via Video Conference and (Proposed) Order

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Notice of Expert for Sentencing Domestic Violence

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Motion on Shortened Time as Friend of the Court for Appointment of Counsel

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Motion to Decrease Defendant's Offense Level Under U.S.S.G. 3B.1.2

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Unopposed Motion to Declare Case Complex and Unusual

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