Criminal Defense
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Motion to Continue Jury Trial Due to COVID
A Motion to Continue Criminal Trial due to Concern over the pandemic. In a case where jury pool is hard to come by, a motion to continue the jury trial until pandemic slows down and the jury pool grows.
MOTION CHALLENGING PROBABLE CAUSE IN SUPPORT OF WARRANTLESS ARREST
A motion filed in court to challenge whether the police had probable cause to stop and arrest defendant. Motion should be used early in the case and filed prior to preliminary hearing.
Colorado Court of Appeals Motion for Enlargement COVID-19
A brief Motion to Enlarge Time to file an Opening Brief with the Colorado Court of Appeals, due to COVID-19 complications
Closing Argument Power Point
Recently used this power point in a case where my client was being charged with Sexual Assault against a Child, Sexual Assault as part of a Pattern of Sexual Abuse and Sexual Assault by A Person of Trust. Client was find not guilty of all charges. The Power Point allowed me to push my theory of the case on the jury and provides a great outline of the closing argument. Not as in depth as my other (Martinez) power point but just as effective in my Closing Arguments.
Voir Dire with Cases Involving Claimed Vulnerable Victims
This product states how to win in the beginning of Voir Dire, find if there is any “vulnerable victims” in evidence or among the prospective jurors, and how to talk to prospective jurors about “vulnerable victims”, and example Voir Dire questions.
Voir Dire in White Collar Cases
This product gives example of Voir Dire questions in a white collar case.
The Colorado Method of Voir Dire
This product states the overview of the Colorado method of Voir Dire, which includes, a discussion of indictment, emotionally difficult nature of the evidence and allegations, learning prospective jurors’ views about life and death, re-stripping the prospective juror, questioning to challenge, exploring unique aspects of decision-making, and factual determination versus moral decision.