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Motion to Reduce Sentence (Title 18 U.S.C. § 3582(c)(2))
Motion to Reduce Sentence (Title 18 U.S.C. § 3582(c)(2))
No “Unavoidable Accident” Defense, Motion in Limine
Motion in limine to preclude an affirmative defense of unavoidable accident
Closing Argument Power Point
Recently used this power point in a case where my client was being charged with Sexual Assault against a Child, Sexual Assault as part of a Pattern of Sexual Abuse and Sexual Assault by A Person of Trust. Client was find not guilty of all charges. The Power Point allowed me to push my theory of the case on the jury and provides a great outline of the closing argument. Not as in depth as my other (Martinez) power point but just as effective in my Closing Arguments.
Motion for a New Trial – DUI Case File
Motion for new trial regarding DUI case on grounds identification was not requested before arresting defendant.
Motion to Quash and Traverse Search Warrant – Criminal Defense
Motion to quash and transverse search warrant. This results in suppressing all evidence and all fruits thereof related.
Appellant Brief on Whether an Illegal Stop Can Affect a License Revocation
Whether or not the exclusionary rule applies in driver’s license revocation proceedings, the express consent statute does not allow the Department of Revenue to revoke a driver’s license pursuant to section 42-2-126 on the basis of a search that itself is the product of an illegal stop and arrest. In this case we argued that, The court of appeals erred in holding that a driver cannot rely on the exclusionary rule to raise the illegality of initial police contact as a defense in a driver’s license revocation proceeding conducted pursuant to section Colorado Law,
Note statute has changed this since the appeal.
Defendant’s Emergency Motion for Temporary Release to Attend Funeral
Defendant’s Emergency Motion for Temporary Release to Attend Funeral
Plaintiff’s Response to Defendant’s Motion in Limine RE: Defendant’s Injuries
PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION IN LIMINE RE: DEFENDANT’S INJURIES
MOTION FOR MODIFICATION OF CONDITIONS OF DEFENDANT’S BOND
MOTION FOR MODIFICATION OF CONDITIONS OF DEFENDANT’S BOND
Declaration of Custodian of Records
For use for when authenticating business records or documents – such as local governments, vital records, medical, churches, business or organization archives etc.
Motion in Limine Inadmissable Rule 404(B) Evidence – legal document
Motion by Defendant to exclude Plaintiffs from offering evidence founded upon inadmissible evidence under inadmissible evidence. In the past, the Plaintiff, their counsel, and their witnesses have frequently made references.