Motion to Dismiss – Sex Trafficking
Motions the Court to dismiss the above captioned.
Renewed Motion For New Trial Or Reconsideration Of The Denial Of His Motion For A New Trial – Sex Crimes Case
Renewed Motion For New Trial Or Reconsideration Of The Denial Of His Motion For A New Trial – Sex Crimes Case
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Motion and Memorandum in Support of Motion to Compel Discovery – Pornography
Moves the Court for an Order Compelling material in discovery.
Motion to Allow Defendant to Use Victim’s Prior Allegations
Motion to Allow Defendant to Use Victim’s Prior Allegations
Motion for Disclosure of All Attorney Files & Records
Motion for Disclosure of All Attorney Files & Records
Motion for Access to Physical Evidence in Possession of the State
Motion for Access to Physical Evidence in Possession of the State
Defendant’s Motion to Introduce Evidence (Sex Crimes)
A Motion to peirce/overcome the Colorado Rape Shield Motion. Sets forth specific facts that a defendant may seek to introduce at trial, but that pursuant to the Colorado Rape Shield Motion is otherwise excluded at trial. Motion must be submitted with the accompanying affidavit under seal at least 35 days prior to trial. – Pursuant to 18-3-407 CRS
Criminal Motion for Protective Order
Legal arguments on arguing a protective order limiting reenactment or demonstrative presentation at a deposition. The legal argument that good cause exist to limit an attorney use of video or pictures for reenactment or to demonstrate at a deposition is included in this document. Guidelines set forth in the United States supreme court case Emerson Elec. Co, which includes protection for unwarranted annoyance and embarrassment is included. Protection Order argument is for civil cases.
Special Victims Voir Dire Questions
Used these sexual assault of a child voir dire questions in defending a highly publicized sexual assault case in October of 2015. Result of trial was a hung jury. Voir dire is the process used by the parties to select a fair and impartial jury. During voir dire, the jury panel is questioned by both parties’ lawyers. The questions are intended to help the lawyers in the jury selection process.