Criminal Law
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Motion to Return Property
Client was arrested and charged with illegal possession of a firearm and drug possession. Police also confiscated $4,000.00 in cash. We filed motion to return the cash as it is not relevant to the charges. further client needs money to help his defense.
Defendant’s Motion for County to Pay for Statement of Facts
DEFENDANT’S MOTION FOR _______________ COUNTY TO PAY FOR STATEMENT OF FACTS
Motion for Deposition (Criminal)
A Motion under CRCP 15 for a deposition of an invaluable witness to preserve testimony. As can be seen, the alibi witness was elderly and in very poor health, so we needed to preserve her testimony. Did not actually get to that point as the DA made a very favorable offer, which was accepted, after this motion was filed.
Complaint for Auto Accident – New York
Complaint against USPS federal agency for injuries from an auto accident
Complaint for Auto Accident Federal Torts Claim
Complaint for damages from auto accident and federal tort claims act
Complaint for Auto Accident – Federal Law
Auto Accident filed in federal cour based on diversity
Motion In Limine for Brief Non-Argumentative Statement Prior to Jury Selection
Motion seeking to give a brief, non-argumentative, opening statement to a jury panel prior to voire dire. Includes constitutional language as well as direction form Chief Justice Directives on such practices.
Motion to Compel Attendance of Out of State Witness
A Motion, filed by the prosecution, asking court certification to compel attendance by an out of state witness.
Objection to Court Scheduling Order
A written objection to a pre-trial scheduling Order compelling the defense to disclose witness and exhibit lists well in advance of trial. Includes Rule 16 citations and constitutional arguments against the Order.
Motion for Discovery of Oral Statements
A motion attempting to secure the disclosure of certain oral statements made to investigators, allegedly, by both the defendant and the alleged victim. These statements would, if true, be exculpatory in nature.
Motion to Preclude Use of the Term Victim
Somewhat standard Motion to precude referring to the accuser/complaining witness as “victim” at trial. Added language includes preclusion of using the term “defendant” in reference to the defendant at trial.
Motion for a Fair and Impartial Jury
Motion to specify and/or modify a judge’s standing voire dire procedure to allow for a more fair and impartial jury selection.
Complaint of For Negligence Auto Accident
Complaint filed in Federal Court based on diversity for auto accident
Motion for Summary Judgment – Auto Injury
MOTION FOR for summary judgment as it relates to the family car doctrine
