Criminal Defense
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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.
Petition for Recusal Pursuant to 28 USC Sec. 144 and 18 U.S.C. Sec. 455
Defendant’s Petition for judicial recusal based on bias.
Defendant’s Memorandum in Opposition to State’s Motion in Limine for a Preliminary Ruling on the Use of Prior Testimony
Defendant’s Memorandum in Opposition to State’s Motion in Limine for a Preliminary Ruling on the Use of Prior Testimony
Defendant’s Postconviction Motion to Modify Sentence filed under Sec. 809.30
Defendant’s Postconviction Motion to Modify Sentence filed under Sec. 809.30 Stats
Motion to Quash Warrant & Motion to Dismiss Violation of Probation
MOTION TO QUASH WARRANT & MOTION TO DISMISS VIOLATION OF PROBATION
Notice of Motion
AFFIRMATION IN SUPPORT OF CPL 330.30 [1] MOTION
MATERIAL TESTIMONY WAS ERRONEOUSLY EXCLUDED AS INADMISSIBLE HEARSAY
THE COURT FAILED TO PROVIDE THE JURY WITH DEFINITIONS OF
“DEPR IVE” AND “APP ROPR IATE”
THE COURT ERRONEOUSLY ADMITTED ANDREA BANKEMPLOYEE’ S CERTIFICATION OF BANK RECORDS INTO EVIDENCE
Petition for Writ of Habeas Corpus AD Testificandum
PETITION FOR WRIT OF HABEAS CORPUS AD TESTIFICANDUM
MOTION FOR APPOINTMENT OF INTERPRETER
MOTION FOR APPOINTMENT OF INTERPRETER
[INDIVIDUAL] AFFIDAVIT FOR NON-PROSECUTION
[INDIVIDUAL] AFFIDAVIT FOR NON-PROSECUTION
MOTION IN LIMINE NO. _____ (EXTRANEOUS OFFENSES, WRONGS OR ACTS)
MOTION IN LIMINE NO. _____
(EXTRANEOUS OFFENSES, WRONGS OR ACTS)
MOTION FOR FORENSIC DNA TESTING PURSUANT TO ART. 64.01 OF THE TEXAS CODE OF CRIMINAL PROCEDURE
MOTION FOR FORENSIC DNA TESTING PURSUANT TO ART. 64.01 OF THE TEXAS CODE OF CRIMINAL PROCEDURE
Ex Parte Motion for Funds for Expert Assistance
An ex parte motion to ask federal district court for payment of defendants expert witness fee.
Motion for Expert Assistance
A motion for expert paid for by the State