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Brief in Support of Motion to Suppress Statements

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Memorandum in Suport of Motion in Limine to Exclude Summary WItness

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Unopposed Motion to Travel

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Notice to Use 404B

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Motion to Request Notice 608

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Motion for Judgement of Acquittal Notwithstanding the Verdict, or Alternatively, for New Trial

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Defendant's Motion for Immediate Disclosure of Favorable Evidence

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Defendant's Proposed Additional Voir Dire Questions

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Defendant's Motion to Require Notice of Intention to Use Expert Witnesses

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Defendant's Motion to Preserve Law Enforcement Notes

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Defendant Memorandum in Response to United States Trial Motion for Mandatory Detention

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MEMORANDUM IN SUPPORT OF MOTION TO SUPPRESS EVIDENCE; REQUEST FOR A FRANKS HEARING;

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MEMORANDUM IN SUPPORT OF MOTION TO SUPPRESS AUDIO RECORDINGS OF CONVERSATIONS BETWEEN FBI INFORMANT AND DEFENDANT

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MEMORANUM IN SUPPORT OF MOTION TO REQUEST HEARING PURSUANT TO FEDERAL RULE OF EVIDENCE 104

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MEMORANDUM IN SUPPORT OF DEFENDANT’S MOTION TO DISMISS COUNTS 1 AND 2 OF THE THIRD SUPERSEDING INDICTMENT ON THE GROUNDS THAT 18 U.S.C. § 1512(f)(1), AS IT IS BEING APPLIED IN THIS CASE, VIOLATES THE EX POST FACTO CLAUSE OF THE UNITED STATES CONSTITUTION AND IT VIOLATES DEFENDANT’S RIGHT TO PROCEDURAL DUE PROCESS

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MEMORANDUM IN SUPPORT OF DEFENDANT’S MOTION TO DISMISS ALL COUNTS OF THE INDICTMENT ON THE GROUNDS THAT THIS FEDERAL PROSECUTION VIOLATES THE DOUBLE JEOPARDY CLAUSE OF THE FIFTH AMENDMENT TO THE UNITED STATES CONSTITUTION

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MEMORANDUM IN SUPPORT OF DEFENDANT MOTION FOR PRODUCTION OF GRAND JURY TRANSCRIPTS

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MEMORANDUM IN SUPPORT OF DEFENDANT MOTION FOR JUDICIAL REFERRAL TO THE DEPARTMENT OF JUSTICE, OFFICE OF ENFORCEMENT OPERATIONS, FOR REVIEW OF THIS PROSECUTION TO DETERMINE WHETHER IT SHOULD BE DISMISSED FOR FAILURE TO COMPLY WITH DEPARTMENT OF JUSTICE POLICIES REGARDING DUPLICATIVE PROSECUTIONS

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MEMORANDUM IN SUPPORT OF MOTION FOR BILL OF PARTICULARS

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NOTICE OF MOTION AND MOTION TO ALLOW FOR TRAVEL OUTSIDE OF THE DISTRICT

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DEFENDANT'S MOTION TO MODIFY ORDER OF DETENTION

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MOTION TO DISMISS VIOLATES DEFENDANT’S RIGHT TO PROCEDURAL DUE PROCESS

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MEMORANDUM IN SUPPORT OF MOTION TO DISMISS COUNT ONE AS DUPLICITOUS

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MOTION TO DISMISS COUNTS ONE AND TWO OF THE THIRD SUPERSEDING INDICTMENT

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DEFENDANT’S MOTION TO DISMISS ALL COUNTS OF THE INDICTMENT DOUBLE JEOPARDY

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MOTION IN LIMINE TO PREVENT THE PROSECUTION AND ITS WITNESSES FROM USING THE TERM “RAPE KIT”

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MOTION IN LIMINE TO PREVENT INTERPRETATION OF EVIDENCE THAT IS SELF-EXPLANATORY

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MOTION IN LIMINE TO EXCLUDE CO-DEFENDANT’S OUT-OF-COURT STATEMENTS

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DEFENDANT’S MOTION FOR SEVERANCE

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MOTION FOR PRODUCTION OF GRAND JURY TRANSCRIPTS

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MOTION FOR JUDICIAL REFERRAL TO THE DEPARTMENT OF JUSTICE,

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MOTION FOR DISCOVERY AND INSPECTION OF CO-DEFENDANT (S) PRESENTENCE REPORT

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DEFENDANT’S MEMORANDUM OF LAW IN SUPPORT OF HIS MOTION FOR SEVERANCE

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MEMORANDUM IN SUPPORT OF MOTION TO SUPPRESS ADMISSION OF VIDEO FROM BAR

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MEMORANDUM IN SUPPORT OF MOTION TO DISMISS COUNTS ONE AND TWO OF THE THIRD SUPERSEDING INDICTMENT

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MEMORANDUM IN SUPPORT OF MOTION TO COMPEL

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MEMORANDUM IN SUPPORT OF MOTION IN LIMINE TO PREVENT INTERPRETATION OF EVIDENCE THAT IS SELF-EXPLANATORY

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MEMORANDUM IN SUPPORT OF MOTION IN LIMINE TO EXCLUDE CO-DEFENDANT OUT-OF-COURT STATEMENTS

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MEMORANDUM IN SUPPORT OF MOTION IN LIMINE TO PREVENT THE PROSECUTION AND ITS WITNESS FROM USING THE TERM “RAPE KIT”

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MEMORANDUM IN SUPPORT OF MOTION IN LIMINE TO PRECLUDE REFERENCE TO ANY CO-CONSPIRATORS

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MEMORANDUM IN SUPPORT OF MOTION IN LIMINE TO LIMIT THE TESTIMONY OF PROSECUTION EXPERT DR.

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Request for a Court Order to Conduct Arraignment via Video Conference and (Proposed) Order

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Notice of Expert for Sentencing Domestic Violence

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Motion on Shortened Time as Friend of the Court for Appointment of Counsel

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Defendant’s Motion to Obtain BOP Records

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Motion to Decrease Defendant's Offense Level Under U.S.S.G. 3B.1.2

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Unopposed Motion to Declare Case Complex and Unusual

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Motion on Shortened Time for Order for Transportation

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Waiver of Preliminary Hearing

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Waiver of Detention Hearing

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Reply to United States' Response to Defendant's Motion to Suppress

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Notice of Intent to Plead Guilty

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