Criminal Defense
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Defendant’s Proposed Questions for Voire Dire
Defendant’s proposed jury selection questions, for the US District Court for the District of Arizona
Defendant’s Trial Memorandum Re: Necessity
Defendant’s memorandum on the model jury instructions concerning a necessity defense. US District Court for the District of Arizona.
Motion to Unseal Docket Entries in Preparation for Appeal
Defendant seeking to unseal docket entries prior to filing an appeal. US District Court for the District of Arizona
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
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 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.
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 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.
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.
Objections to Presentence Report
Defendant’s objections to a pre-sentence report, primarily based on differences in State vs. Federal Definitions regarding the crime charged. US District Court for the District of Arizona.
Motion to Strike Alias & Memorandum in Support
MOTION TO STRIKE ALIAS, AND MEMORANDUM IN SUPPORT
Defendant’s Motion to Strike Aliases
DEFENDANTS’ MOTION TO STRIKE ALIASES
Defendant’s Motion to Preserve Severance
DEFENDANTS MOTION TO PRESERVE SEVERANCE MOTION
Motion to Exclude Prior Crimes
MOTION TO EXCLUDE EVIDENCE OF OTHER CRIMES OR WRONGS, OR ALTERNATIVELY, FOR NOTICE BY THE GOVERNMENT OF ITS INTENTION TO INTRODUCE AND RELY UPON Fed.R.Evid. 404(b) EVIDENCE, AND MEMORANDUM IN SUPPORT
MOTION TO DISMISS INDICTMENT
MOTION TO DISMISS INDICTMENT DUE TO THE DESTRUCTION OF EXCULPATORY EVIDENCE/ IN
THE ALTERNATIVE REQUEST FOR SPOLIATION INSTRUCTION