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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.
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.
Ex Parte Motion – Funds for Investigative Assistance
A motion for court payment of investigator
Ex Parte Motion for Funds for Expert Assistance
An ex parte motion to ask federal district court for payment of defendants expert witness fee.
Motion for the Court to Direct the Court Reporter t take Voir Dire Examination
MOTION FOR THE COURT TO DIRECT THE COURT REPORTER
TO TAKE VOIR DIRE EXAMINATION OF THE JURY AND
ALL FINAL ARGUMENTS IN THE ABOVE STYLED AND NUMBERED CAUSE
Motion In Limine to Preclude Events
MOTION IN LIMINIE TO PRECLUDE EVENTS