Criminal Defense
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Motion for Production of Tape Recorded Evidence
MOTION FOR PRODUCTION OF TAPE RECORDED EVIDENCE
Motion to Suppress Evidence – Hotel Room
The grounds for this motion are that all of the aforementioned evidence was illegally seized without a warrant by virtue of an unlawful search of the Defendant’s hotel room in violation of the Fourth Amendment of the United States Constitution
Unopposed Motion to Permit Business Travel
Unopposed Motion to Permit Business Travel
Motion to Require Disclosure of Confidential Informers
MOTION TO REQUIRE DISCLOSURE OF CONFIDENTIAL INFORMERS IDENTITY
Post-Conviction Motion to Withdraw Plea
Post-Conviction Motion to Withdraw Plea Criminal Law – Wisconsin
Motion to Suppress DUI Breath Test
MOTION TO SUPPRESS BREATH TEST
Motion to suppress breath test on notion road side tests were taken illegally and arrest were warrantless.
Implied consent laws generally require all drivers lawfully arrested for a DUI to submit to chemical testing (normally, a breath or blood test). However, many states make prearrest PAS tests optional—meaning, there’s no legal consequence for a driver who refuses a PAS test.
Motion for Exoneration by Surety
MOTION FOR EXONERATION
COME NOW the Sureties, by and through their attorney, hereby
Move this honorable court to enter an order of exoneration herein, as grounds therefore, state as follows:
1. That the Defendant herein failed to appear on or about Marc _, 2016 on the bond Posted Feburary _, 2016 in the amount of $3,000.00; the statutory stay of execution expires July _ 2016.
2. That the Defendant is currently in custody in the Pueblo County Jail with various other warrant and bonds (attached as Exhibit A
3. That pursuant to C.R.C 16-4-114(5)(b)(V)(B) and (C) the Sureties are entitled to exoneration as they have shown that the Defendant is in custody in another jurisdiction within the state within 91 days after entry of judgment. WHEREFORE, the Sureties prays this Honorable court grant their Motion for Exoneration.
Motion for Preliminary Ruling on Admissibility of Victim’s Past
MOTION FOR PRELIMINARY RULING ON ADMISSIBILITY OF EVIDENCE OF THE VICTIM’S VIOLENT CHARACTER
Defendant’s Motion to Suppress Evidence
Defendant’s Motion to Suppress Evidence
Motion to Suppress Evidence (defective warrant)
Notice of Motion and Motion to Supress Evidence (defective warrant)
Motions to Suppress Confidential Informant
Motions Fed-CI Suppress Wisconsin
Joint Brief of the Defendants in Support of Pretrial Motions
Joint Brief of the Defendants in Support of Pretrial Motions