Criminal Law
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Notice of Motion to Permit the Inspection and Copying of Items
NOTICE OF MOTION TO PERMIT THE INSPECTION AND COPYING OF ITEMS COVERED BY TEXAS CODE OF CRIMINAL PROCEDURE ARTICLE 39.14
404B objection
Motion to deny the People’s Notice of Intent to Introduce Res Gestate Evidence or, In the Alternative, of Other Transactions, Pursuant to C.R.S. § 16-10-301 and C.R.E. 404(b).
Motion In Limine for Brief Non-Argumentative Statement Prior to Jury Selection
Motion seeking to give a brief, non-argumentative, opening statement to a jury panel prior to voire dire. Includes constitutional language as well as direction form Chief Justice Directives on such practices.
Objection to Court Scheduling Order
A written objection to a pre-trial scheduling Order compelling the defense to disclose witness and exhibit lists well in advance of trial. Includes Rule 16 citations and constitutional arguments against the Order.
Memorandum of Law in Support of Motion to Allow Defendant to Use Victim’s Prior Allegations of Sex Abuse
Memorandum of Law in Support of Motion to Allow Defendant to Use Victim’s Prior Allegations of Sex Abuse
Murder(no death penalty) JUROR QUESTIONNAIRE
A jury questionnaire used in a murder case with no death penalty issue.
Rule 16 Self Defense
Criminal Defense disclosure for self defense and defense of property
Notice of Alibi
Required Notice of Alibi under the Colorado Rules of Criminal Procedure.
Defendant Request for Notice of 404B
Defendant Request for Notice of 404B
Request and Order to Recall Warrant
Request and Order to Recall Warrant
Plea Form, With Explanations and Waiver of Rights-Felony
Plea Form, With Explanations and Waiver of Rights-Felony