Criminal Defense
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Unopposed Motion to Continue Re-Arraignment
UNOPPOSED MOTION TO CONTINUE RE-ARRAIGNMENT
Motion for Discovery of Corroborative Evidence
MOTION FOR DISCOVERY OF CORROBORATIVE EVIDENCE TO ACCOMPLICE TESTIMONY
Motion Regarding Application for Community Supervison
MOTION IN LIMINE REGARDING APPLICATION FOR COMMUNITY SUPERVISION
Motion to Inspect, Examine & Test Physical Evidence
MOTION TO INSPECT, EXAMINE AND INDEPENDENTLY TEST PHYSICAL EVIDENCE
Motion to Limit Jury Argument at Punishment Stage
MOTION TO LIMIT JURY ARGUMENT OF STATE AT THE PUNISHMENT STAGE
Agreed Motion to Modify & Extend Conditions of Probation
AGREED MOTION TO MODIFY AND EXTEND CONDITIONS OF PROBATION
Motion to Compel Additional Discovery – Criminal Law
MOTION TO COMPEL ADDITIONAL DISCOVERY
Motion for Downward Departure from Sentencing Guidelines
MOTION FOR DOWNWARD DEPARTURE FROM SENTENCING GUIDELINES
Motion to Suppress Evidence & Accompanying Memorandum of Law
The grounds for this motion are that all of the aforementioned evidence was illegally seized without a warrant by virtue of an unlawful seizure and detention of the Defendant in violation of the Fourth Amendment of the United States Constitution
Motion to Suppress – Traffic & DUI
There was no probable cause for a traffic stop for a violation of Florida Statute § 316.089(1) as Officer — did not see Defendant place any other vehicles in danger nor did Officer — observe a driving pattern giving rise to a suspicion of impairment. As such, all evidence seized as a result of the illegal traffic stop must be suppressed as fruit of the poisonous tree.
Defendant’s Motion to Suppress
JURISDICTION AND UNDER COLOR OF LAW COMMUNITY CARETAKING FUNCTION Probable Cause
Motion to Quash Warrant & Motion to Dismiss Violation of Probation
MOTION TO QUASH WARRANT & MOTION TO DISMISS VIOLATION OF PROBATION
Motion for Approval For Independent Trace Residue Analysis
DEFENDANT’S MOTION FOR APPROVAL OF EXPENDITURE FOR INDEPENDENT TRACE RESIDUE ANALYSIS
Motion to Suppress Statements – Florida
MOTION TO SUPPRESS Statements
Motion for Evidence Favorable to the Defendant
MOTION FOR EVIDENCE FAVORABLE TO THE DEFENDANT