Appellant’s Opening Brief
Appellant’s opening brief concerning the case where the appellant is charged with driving under the influence of alcohol, careless driving, resisting arrest and obstruction of police.
MOTION TO SEVER POSESSION OF A WEAPON BY A PREVIOUS OFFENDER FROM THE OTHER CHARGES [DEF – 1]
Defendant seeks an order severing the Possession of a Weapon Count from the other counts of Driving Under the Influence, Lane Usage Violation, Possession of a an Illegal Weapon, Prohibited Use of a Weapon, and Possession of Alcohol in a Motor Vehicle.
MOTION TO SUPPRESS ILLEGAL STOP, INVOLUNTARY ROADSIDE TESTS, WARRANTLESS ARREST, STATEMENTS AND INVOLUNTARY BREATH TEST
MOTION TO SUPPRESS ILLEGAL STOP, INVOLUNTARY ROADSIDE TESTS, WARRANTLESS ARREST, STATEMENTS AND INVOLUNTARY BREATH TEST
Defendant’s Motion in Limine to Preclude Evidence Pertaining to Impairment Ratings
DEFENDANT’S MOTION IN LIMINE TO PRECLUDE EVIDENCE PERTAINING TO IMPAIRMENT RATINGS
Motion to Suppress DUI Breath Test
MOTION TO SUPPRESS BREATH TEST
Motion to suppress breath test on notion road side tests were taken illegally and arrest were warrantless.
Implied consent laws generally require all drivers lawfully arrested for a DUI to submit to chemical testing (normally, a breath or blood test). However, many states make prearrest PAS tests optional—meaning, there’s no legal consequence for a driver who refuses a PAS test.
Plaintiff’s Response to Defendant’s Motion in Limine: Marijuana use
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION IN LIMINE RE: MARIJUANA USE
Motion to Dismiss for Lack of Jurisdiction
COMES NOW, Martinez Law Firm, LLC, behalf of Defendant, Marisa Aranda, and hereby submits this Motion to Dismiss for Lack of Jurisdiction by stating as follows:
1. On January 5, 2015, Defendant, Marisa Aranda was issued a Uniform Summons and Complaint or Penalty Assessment alleging driving under the influence, DUI per se, failure to present insurance and failure to obey a traffic signal. See attached Exhibit 1. In the Summons the officer states the offenses as alleged occurred in Arapahoe County, CO. The Colorado State Patrol Case Report also states the alleged offenses occurred in Arapahoe County, See attached Exhibit 2.
Motion for Reduction of Sentence
Client was sentenced to one year of jail, client finished a inmate jail program and now wants his jail reduced.
Government Response to Motion to Suppress and Exclude – McNeely Memo
Government response to motion to suppress and exclude blood sample evidence on the grounds it was obtained illegally without a warned from the hospital.
Motion To Suppress Search And Seizure – DUI Case
Motion to suppress search and seizure on regards evidence pertained towards the search was obtained illegally and unwarranted.
MOTION FOR OUT-OF-STATE WITNESS TO APPEAR BY PHONE
MOTION FOR OUT-OF-STATE WITNESS TO APPEAR BY PHONE
MOTION FOR SPECIFIC DISCOVERY: DUI Case
MOTION FOR SPECIFIC DISCOVERY: TROOPER EVIDENTIAL BREATH ALCOHOL TEST (EBAT) OPERATOR
CERTIFICATION
MOTION FOR PRODUCTION OF WITNESSES PURSUANT TO § 16-9-203, COLORADO REVISED STATUTES 2016
MOTION FOR PRODUCTION OF WITNESSES PURSUANT TO § 16-9-203, COLORADO REVISED STATUTES 2016