Criminal Defense
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Motion for Leave to Use Stand In Counsel
Motion for Defense Counsel to use stand-in counsel at an upcoming hearing, and a waiver of (out of state) defendant’s appearance at that hearing.
Defendant’s Motion and Brief in Support of Pre-Trial Release
US District Court for the District of Arizona. Motion and supporting brief in support of defendant’s pre-trial release.
Defendant’s Motion In Limine Re: Initial Contact
Defendant in an Immigration case seeking to exclude the reasons for, and facts that, he was in jail when ICE agents made contact with him.
Defendant’s Motion In Limine Re: Statements Within Immigration
Immigration Defendant seeking to exclude statements made to ICE and other government agents in prior contacts with ICE and other law enforcement regarding his immigration status (Defendant exercised the 5th in this case). US District Court for the District of Arizona.
Motion to Continue Trial and Motion to Extend Pre-Trial Motion Deadline (1st Request)
Defendant’s 1st request to continue trial and extend motions deadline, in the US District Court for the District of Arizona. Defense reasons was more time needed to investigate.
Defendant’s Motion to Designate Case Complex
Criminal defendant’s motion to designate the case as complex, in the US District Court for the District of Arizona
Defendant Motion in Limine
Plaintiff’s witnesses should be ordered to refrain from offering any evidence as to Defendants’ state of mind, and witness and counsel should be ordered not to introduce any evidence and argument that Defendants acted willfully, wantonly, purposefully, heedlessly, recklessly, consciously, callously, without regard to the consequences, or the like.
Motion in Limine Expert opinion
DEFENDANT MOTION TO EXCLUDE EXPERT REPORT AND TESTIMONY OF — REGARDING CERTAIN OPINIONS ON LIABILITY, CAUSATION, AND DAMAGES
Defendant’s Motion to Dismiss or in the Alternative, For Appropriate Sanctions
DEFENDANT’S MOTION TO DISMISS OR IN THE ALTERNATIVE, FOR APPROPRIATE SANCTIONS PURSUANT TO C.R.Cr.P 16(III)(g)
MOTION FOR DISCOVERY OF PRIOR BAD ACTS
MOTION FOR DISCOVERY OF PRIOR BAD ACTS
MOTION FO DISCOVERY AND IN CAMERA REVIEW
MOTION FO DISCOVERY AND IN CAMERA REVIEW
DEFENDANT’S MOTION TO MODIFY CONDITIONS OF BOND AND/OR PRE-TRIAL SERVICES PURSUANT TO §16-4-109 C.R.S.
DEFENDANT’S MOTION TO MODIFY CONDITIONS OF BOND AND/OR PRE-TRIAL SERVICES PURSUANT TO §16-4-109 C.R.S.
MOTION FOR PRODUCTION OF NEGATIVE EXCULPATORY STATEMENTS UNDER BRADY
MOTION FOR PRODUCTION OF NEGATIVE EXCULPATORY STATEMENTS UNDER BRADY