Criminal Defense
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MOTION TO SUPPRESS: THE WARRANT
MOTION TO SUPPRESS: THE WARRANT RELIED UPON TO SEARCH DEFENDANT’S HOME WAS UNCONSTITUTIONAL BECAUSE IT WAS AUTHORIZED WITHOUT PROBABLE CAUSE, DID NOT IDENTIFY THE OBJECT OF THE SEARCH NOR THE PREMISES TO BE SEARCHED WITH SPECIFICITY, AND WHILE EXECUTING THE WARRANT, THE POLICE WENT BEYOND THE SCOPE ALLOWED BY THE SEARCH WARRANT, AND COLLECTED NUMEROUS ITEMS NOT AUTHORIZED BY THE WARRANT [16]. |
MOTION TO SUPRESS AUTOPSY AS A SANCTION [14]
Defendant’s motion to suppress autopsy because the defense counsel was allowed to present during the autopsy in this matter, violating the order of the court, the Colorado Bar Association Ethics Opinion, and violating C.R.C.P. 16.Â
PEOPLE’S MOTION FOR PROTECTIVE ORDER UNDER RULE 16 III (d)
PEOPLE’S MOTION FOR PROTECTIVE ORDER UNDER RULE 16 III (d)Â
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PEOPLE’S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE ANSWER BRIEF
People’s unopposed motion for enlargement of time to file answer brief.Â
PEOPLE’S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE ANSWER BRIEF
People’s unopposed motion for enlargement of time to file answer brief.Â
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE OPENING BRIEF
Defendant’s attorney files an unopposed motion for extension of time to file opening brief.Â
Unopposed Motion for Stay of Execution of Sentence
Defendant’s attorney requests the court to enter an order staying the execution of the sentence in this matter until such time as the merits of the appeal at all levels has been determined.Â
Motion to Declare Defendant Indigent for Purposes Other Than Attorney Fees
Motion to declare the defendant indigent for cost for reasons other than attorneys fees. – Criminal Law Legal Document – Experts and Evidence
Attorney’s fee is a chiefly United States term for compensation for legal services performed by an attorney for a client, in or out of court. It may be an hourly, flat-rate or contingent fee.
If you win the case the owner filed against you, you can then collect the attorneys’ fees you spent from the responsible subcontractor. You can also recover your attorneys’ fees for pursuing a lawsuit you had to file because of someone else’s mistake.
Motion for Preliminary and Reduced Bond – Criminal Defense Legal Document
Motion for preliminary trial, in which probable cause and conditions for release are discussed. Conditions for release can include reduction of bond, in the case it was set too high initially.
Renewed Motion for a Personal Recognizance Bond in the Case – Criminal Defense Legal Document
Document entails a motion for personal recognizance bond, which is granted by the Court once the individual case and criminal history have been reviewed and completed.
Motion and Notice to Reduce or Modify Bond – Criminal Defense Legal Document
Document in which the Defendant can request to lower bond when initial amount set too high.
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 CHALLENGING PROBABLE CAUSE IN SUPPORT OF WARRANTLESS ARREST
A motion filed in court to challenge whether the police had probable cause to stop and arrest defendant. Motion should be used early in the case and filed prior to preliminary hearing.
Motion to Continue Jury Trial Due to COVID
A Motion to Continue Criminal Trial due to Concern over the pandemic. In a case where jury pool is hard to come by, a motion to continue the jury trial until pandemic slows down and the jury pool grows.
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.