MOTION FOR LEAVE TO AMEND FIRST AMENDED COMPLAINT TO ADD A CLAIM FOR EXEMPLARY DAMAGES
A motion for leave to amend a complaint to add a claim for exemplary damages.
MOTION FOR DISCOVERY ON ATTORNEY FEES
A motion for discovery on a request for attorney fees.
Defendants Motion in Limine Related to Limitations Period
A sample motion by defendant limiting testimony for claims made outside the statue of limitations.
Motion Requesting Notice of Prosecution’s Intent to Introduce Alleged Similar Evidence
A sample Motion requesting notice of prosecution’s intent to introduce alleged similar transaction evidence. Well written request for the Court to order the prosecution to specify any instances of alleged prior evidence.
Entry of Appearance and Motion for Preliminary Hearing
A sample of an Entry of Appearance and Motion for Preliminary Hearing. A well written form for an appearance for defendant.
Unopposed Motion to Continue Jury Trial
A sample of an unopposed motion to continue jury trial. A well written unopposed motion by the defense counsel to continue the scheduled jury trial which is without objection from the People.
Motion to Suppress Unconstitutionally Obtained Convictions
Sample of a Motion to suppress unconstitutionally obtained convictions. A well written motion to suppress convictions based on the convictions being obtained without counsel.
Defense Objection to People’s Motion to Continue Jury Trial
Sample of the Defense objection to people’s motion to continue jury trial. A well written defense objection based on a witness’s unavailability and the People not providing further information to support their motion to continue.
Motion in Limine to Preclude the Prosecution’s Proposed Expert Testimony
Sample of a motion to preclude the prosecution’s proposed expert testimony. A well written motion to object against the prosecution’s expert witness’s testimony.
Motion to Suppress Defendants Statement during Custodial Interrogation
Sample to suppress Defendant’s statements while in custody without proper Miranda advisement. Well written motion to exclude evidence from an unlawful interrogation
UNOPPOSED MOTION TO CONVERT DEFERRED JUDGMENT AND SENTENCE TO UNSUPERVISED DEFERRED JUDGMENT AND SENTENCE
UNOPPOSED MOTION TO CONVERT DEFERRED JUDGMENT AND SENTENCE TO UNSUPERVISED DEFERRED JUDGMENT AND SENTENCE
UNOPPOSED MOTION TO PERMIT ADDITIONAL PERIOD OF OUT OF STATE TRAVEL FOR EXCHANGE OF CHILDREN FOR PARENTING TIME
UNOPPOSED MOTION
TO PERMIT ADDITIONAL PERIOD OF OUT OF STATE TRAVEL FOR EXCHANGE OF CHILDREN FOR PARENTING TIME
The Court had previously granted a client on bond time to travel out of state, this motion was filed to ask court for extended time to exchange the children for parenting time.
Motion for 404B Notice
the motion requests that the Court Order the prosecution to provide notice in advance of trial that conforms to the standards set forth in People v. Spoto. Further, if the prosecution seeks to introduce such evidence, the Defendant moves that a hearing on the admissibility of such evidence be held sufficiently in advance of trial in order to afford counsel adequate time to confront the proffered evidence.
MOTION FOR OUT-OF-STATE WITNESS TO APPEAR BY PHONE
MOTION FOR OUT-OF-STATE WITNESS TO APPEAR BY PHONE
MOTION FOR SPECIFIC DISCOVERY: DUI Case
MOTION FOR SPECIFIC DISCOVERY: TROOPER EVIDENTIAL BREATH ALCOHOL TEST (EBAT) OPERATOR
CERTIFICATION