Criminal Defense
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MOTION TO SEVER POSESSION OF A WEAPON BY A PREVIOUS OFFENDER FROM THE OTHER CHARGES [DEF – 1]
Defendant seeks an order severing the Possession of a Weapon Count from the other counts of Driving Under the Influence, Lane Usage Violation, Possession of a an Illegal Weapon, Prohibited Use of a Weapon, and Possession of Alcohol in a Motor Vehicle.
MOTION TO CONTINUE TRIAL
District Attorney submits a motion to continue the jury trial.
MOTION TO AMEND
District Attorney respectfully moves this Court to Amend Count XII, Assault in The First Degree, C.R.S. §18-3-202(1)(a), of the information filed against the defendant to be Assault in the First Degree, C.R.S. §18-3-202(1)(b).
MOTION FOR NOTICE PURSUANT TO C.R.E. 404(B) [DEF – 4]
Defendant’s request the Court order the prosecution to give notice of intent to admit evidence pursuant to C.R.E. 404(b).
MOTION FOR NOTICE OF 404(b) EVIDENCE [11]
Counsel moves for advance notice of any 404(b) evidence, and objects to the introduction of any such evidence at trial and requests a hearing
MOTION FOR NON-TESTIMONIAL IDENTIFICATION EVIDENCE
 MOTION FOR NON-TESTIMONIAL IDENTIFICATION EVIDENCE
MOTION FOR EXPERT ENDORSEMENT AND DISCLOSURES [DEF – 3]
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MOTION FOR EXPERT ENDORSEMENT AND DISCLOSURES [DEF – 3] |
DEFENSE REQUEST FOR IN-PERSON TESTIMONY PURSUANT TO U.S. CONST. AMEND. VI AND C.R.S. §16-3-309(5) REGARDING TESTING AND CHAIN OF CUSTODY [DEF – 2]
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DEFENSE REQUEST FOR IN-PERSON TESTIMONY PURSUANT TO U.S. CONST. AMEND. VI AND C.R.S. §16-3-309(5) REGARDING TESTING AND CHAIN OF CUSTODY [DEF – 2] |
Appellant’s Opening Brief
Appellant’s opening brief concerning the case where the appellant is charged with driving under the influence of alcohol, careless driving, resisting arrest and obstruction of police.
Criminal defense retainer agreement
Basic criminal defense attorney fee agreement. Allows for client to make two payments. Pretrial is due before engagement and second part is due once a trial is set.
Waiver of Extradition as a Condition of Bail Bond
Sample of a waiver of extradition as a condition of bail bond. Well written and filled out form of a condition of bail bond.
Motion Requesting Notice of Prosecution’s Intent to Introduce Alleged Similar Evidence
A sample Motion requesting notice of prosecution’s intent to introduce alleged similar transaction evidence. Well written request for the Court to order the prosecution to specify any instances of alleged prior evidence.
Entry of Appearance and Motion for Preliminary Hearing
A sample of an Entry of Appearance and Motion for Preliminary Hearing. A well written form for an appearance for defendant.
Unopposed Motion to Continue Jury Trial
A sample of an unopposed motion to continue jury trial. A well written unopposed motion by the defense counsel to continue the scheduled jury trial which is without objection from the People.
Motion to Suppress Unconstitutionally Obtained Convictions
Sample of a Motion to suppress unconstitutionally obtained convictions. A well written motion to suppress convictions based on the convictions being obtained without counsel.