Criminal Defense
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Motion for Sanctions for Failure to Provide Discovery
Motion for Sanctions under discovery rules (Rule 16 in Colorado), for prosecution’s repeated failure to provide specific police reports as required. The case settled prior to litigating this issue, though the plea agreement was much better than it could have been largely because of this issue.
Notice of Alibi
Required Notice of Alibi under the Colorado Rules of Criminal Procedure.
Motion for State Witnesses to Discuss Facts with Defense Counsel
MOTION FOR AUTHORIZATION FOR STATE’S WITNESSES TO DISCUSS FACTS OF THE CASE WITH DEFENSE COUNSEL
Response to motion to Dismiss
A Response to motion to Dismiss in a Title VII employment discrimination case. Filed in Colorado US District Court
Entry of Appearance, Motion for Discovery, Waiver of Arraignment, Request for Pre-trial Conference
COMES NOW, Martinez Law Firm, LLC, who enters their appearance on behalf of Defendant, Marisa Aranda, and hereby waives arraignment/first appearance set for March 11, 2015, requests a pretrial conference with the Arapahoe County District Attorney at a mutually agreeable time, and requests an Order directing the prosecuting attorney to immediately provide discovery of the following material relevant to this case:
Motion in Limine (Victim)
DEFENDANT’S MOTION IN LIMINE TO PROHBIT THE USE OF THE TERM VICTIM AT TRIAL
Motion to Suppress Warrantless Entry
DEFENDANT’S MOTION TO SUPPRESS and TO QUASH ARREST
Motion for Immunity CO Make My Day Law
DEFENDANT’S MOTION FOR IMMUNITY PURSUANT TO §18-1-704.5 C.R.S.
Defendant Request for Notice of 404B
Defendant Request for Notice of 404B
Death Penalty Voir Dire Questions
Voire Dire Question used in a death penalty case. 8 pages of questions both in word format and in PDF