Motion in Limine to Exclude Evidence
By failing to object to the timeline stated in the agreed to presumptive Case Management Order, Plaintiff is barred from introducing any evidence or calling any witnesses not disclosed prior to the October 19, 2008 discovery cut-off date
Opposition to Plaintiff’s Motion to Strike Defendant’s Affirmative Defense
DEFENDANT SECOND SUPPLEMENT TO OPPOSITION TO PLAINTIFF’S MOTION TO STRIKE DEFENDANT’S AFFIRMATIVE DEFENSE OF NONPARTY AT FAULT AND TO PRECLUDE INADMISSIBLE EVIDENCE CONCERNING ALLEGED NEGLIGENCE OR FAULT
Motion to Exclude any Evidence of Medical Payments from Collateral Source
MOTION IN LIMINE TO EXCLUDE ANY EVIDENCE OF MEDICAL EXPENSE PAYMENTS FROM ANY COLLATERAL SOURCE
Motion to Strike Defendant’s Affirmative Defense & Preclusion of Inadmissable Evidence
PLAINTIFF’S MOTION TO STRIKE DEFENDANT’S AFFIRMATIVE DEFENSE OF NONPARTY AT FAULT AND TO PRECLUDE INADMISSABLE EVIDENCE CONCERNING ALLEGED NEGLIGENCE OR FAULT OF UNIVERSITY OF COLORADO PROVIDERS
Motion to Suppress DUI Breath Test
MOTION TO SUPPRESS BREATH TEST
Motion to suppress breath test on notion road side tests were taken illegally and arrest were warrantless.
Implied consent laws generally require all drivers lawfully arrested for a DUI to submit to chemical testing (normally, a breath or blood test). However, many states make prearrest PAS tests optional—meaning, there’s no legal consequence for a driver who refuses a PAS test.
Brief in Support of Defendant’s Motion to Suppress Evidence
DEFENDANT’S BRIEF IN SUPPORT OF DEFENDANT’S MOTION TO SUPPRESS EVIDENCE
Motion to Suppress Evidence – Hotel Room
The grounds for this motion are that all of the aforementioned evidence was illegally seized without a warrant by virtue of an unlawful search of the Defendant’s hotel room in violation of the Fourth Amendment of the United States Constitution
Motion for Production of Tape Recorded Evidence
MOTION FOR PRODUCTION OF TAPE RECORDED EVIDENCE
Motion for Evidence Favorable to the Defendant
MOTION FOR EVIDENCE FAVORABLE TO THE DEFENDANT
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 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
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
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 Inspect, Examine & Test Physical Evidence
MOTION TO INSPECT, EXAMINE AND INDEPENDENTLY TEST PHYSICAL EVIDENCE
Motion for Discovery of Corroborative Evidence
MOTION FOR DISCOVERY OF CORROBORATIVE EVIDENCE TO ACCOMPLICE TESTIMONY