Evidence
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Motion to Suppress Evidence of the Arrest
MOTION TO SUPPRESS EVIDENCE OF THE ARREST BASED ON LACK OF PROBABLE CAUSE BASED ON VIDEOTAPE AS PRESENTED IN WHITELEY V. WARDEN, WYOMING STATE PENITENTIARY
Motion to Suppress Illegally Seized Evidence
MOTION TO SUPPRESS ILLEGALLY SEIZED EVIDENCE
Motion to Produce Exculpatory and Mitigating Evidence Against Defendant of Sexual Assault
MOTION TO PRODUCE EXCULPATORY AND MITIGATING EVIDENCE IN REGARD TO ALLEGATIONS AGAINST DEFENDANT OF SEXUAL ASSAULT OF A CHILD OR INDECENCY WITH A CHILD
Motion for Notice of Plaintiff Intention to use Specific Rule 404(b) Evidence
MOTION FOR NOTICE OF PLAINTIFF INTENTION TO USE SPECIFIC RULE 404(b) EVIDENCE
Motion to Suppress Wiretape Evidence
MOTION TO SUPPRESS WIRETAP EVIDENCE AND MOTION FOR FRANKS HEARING
Motion to Suppress Evidence Obtained through Electronic Surveillance
FIRST MOTION TO SUPPRESS EVIDENCE OBTAINED THROUGH ELECTRONIC SURVEILLANCE and REQUEST FOR FRANKS HEARING
Plaintiff’s Motion in Limine to Exclude Evidence of Prior Felony
PLAINTIFF’S MOTION IN LIMINE TO EXCLUDE EVIDENCE OF PRIOR FELONY
Plaintiff’s Motion in Limine to Exclude Evidence of Traffic Citation and Conviction
PLAINTIFF’S MOTION IN LIMINE TO EXCLUDE EVIDENCE OF TRAFFIC CITATION AND TRAFFIC CONVICTION
Motion for Discovery of Corroborative Evidence
MOTION FOR DISCOVERY OF CORROBORATIVE EVIDENCE TO ACCOMPLICE TESTIMONY
Motion to Inspect, Examine & Test Physical Evidence
MOTION TO INSPECT, EXAMINE AND INDEPENDENTLY TEST PHYSICAL EVIDENCE
Plaintiff’s Motion in Limine: Evidence & Testimony on Defendant’s Alleged Damages
PLAINTIFF’S MOTION IN LIMINE: EVIDENCE AND TESTIMONY ON THE DEFENDANT’S ALLEGED DAMAGES
Motion to Suppress Evidence & Accompanying Memorandum of Law
The grounds for this motion are that all of the aforementioned evidence was illegally seized without a warrant by virtue of an unlawful seizure and detention of the Defendant in violation of the Fourth Amendment of the United States Constitution
Motion to Suppress – Traffic & DUI
There was no probable cause for a traffic stop for a violation of Florida Statute § 316.089(1) as Officer — did not see Defendant place any other vehicles in danger nor did Officer — observe a driving pattern giving rise to a suspicion of impairment. As such, all evidence seized as a result of the illegal traffic stop must be suppressed as fruit of the poisonous tree.
Motion for Evidence Favorable to the Defendant
MOTION FOR EVIDENCE FAVORABLE TO THE DEFENDANT
Motion for Production of Tape Recorded Evidence
MOTION FOR PRODUCTION OF TAPE RECORDED EVIDENCE