Criminal Law
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Defendant’s Sentencing Position Paper
Defendant’s Position memorandum on sentencing in a federal criminal case, Central District of California.
Petition for Recusal Pursuant to 28 USC Sec. 144 and 18 U.S.C. Sec. 455
Defendant’s Petition for judicial recusal based on bias.
Government’s Motion to Admit Evidence of Defendant’s UCC Filings in 2011 and 2012
Federal prosecutor’s motion to admit specific acts of a criminal defendant. US District Court for the Central District of California.
Defendant’s Unopposed Motion to Modify Bond Terms
Unopposed Motion to Modify Bond Conditions previously set by the Court. Specifically, to modify/correct the name of a surety on the bond.
Defendant’s Notice and Motion to Dismiss Counts One and Two
Defendant’s Notice and Motion to Dismiss two specific Counts in a federal criminal prosecution, on Constitutional Grounds. For the US District Court for the Western District of California.
Defendant’s Motion In Limine to Exclude Improper Opinion Testimony
Defendant’s Motion in Limine to exclude specific improper opinion testimony. Filed in the US istrict Court for the Western District of California, the motion, with exhibits, seeks to exclude improperly disclosed (or undisclosed) and otherwise impermissible opinion testimony under Rule 16(G).
Defendant’s Motion In Limine to Preclude Evidence of Uncharged Tax Years
Motion by a criminal defendant in the US District Court for the Western District of California to preclude the inclusion of specific evidence. In this case, to exclude evidence of tax filings for ax years not included in the Government’s charges.
Brief in Support of Bond and Pre-Trial Release by Defendant
Brief in Support of a motion to release a criminal defendant to Bond and Pre-Trial Release. Federal District Court for the Western District of California.
Defendants Company Trial Brief on Improper Argument of Defendant’s ongoing Employment
DEFENDANT COMPANY TRIAL BRIEF ON IMPROPER ARGUMENT OF DEFENDANT’S ONGOING EMPLOYMENT in auto accident case
Defendant Company Trial Brief Re: Negligent Entrustment Claim
DEFENDANT COMPANY TRIAL BRIEF RE: NEGLIGENT ENTRUSTMENT CLAIM in auto accident
Entry of Apperance, Request for Discovery, Verification of Advisement, Waiver of First Appearance
ENTRY OF APEARANCE, REQUEST FOR DISCOVERY, VERIFICATION OF ADVISEMENT, WAVIER OF FIRST APPEARANCE
Defendant’s Motion to Dismiss the Complaint/Information
Defendant’s Motion to Dismiss the Complaint/Information
Defendant’s Memorandum in Opposition to State’s Motion in Limine for a Preliminary Ruling on the Use of Prior Testimony
Defendant’s Memorandum in Opposition to State’s Motion in Limine for a Preliminary Ruling on the Use of Prior Testimony
Motion to Withdraw Guilty Plea Pursuant to Sec. 971.08(2), Stats
Motion to Withdraw Guilty Plea Pursuant to Sec. 971.08(2), Stats