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Defendant’s Proposed Questions for Voire Dire
Defendant’s proposed jury selection questions, for the US District Court for the District of Arizona
Motion To Strike Paragraph in Complaint
Motion to strike certain paragraphs in the complaint
Defendant’s Trial Memorandum Re: Necessity
Defendant’s memorandum on the model jury instructions concerning a necessity defense. US District Court for the District of Arizona.
Defendant’s Motion to Designate Case Complex
Criminal defendant’s motion to designate the case as complex, in the US District Court for the District of Arizona
Motion to Continue Trial and Motion to Extend Pre-Trial Motion Deadline (1st Request)
Defendant’s 1st request to continue trial and extend motions deadline, in the US District Court for the District of Arizona. Defense reasons was more time needed to investigate.
Defendant’s Motion In Limine Re: Initial Contact
Defendant in an Immigration case seeking to exclude the reasons for, and facts that, he was in jail when ICE agents made contact with him.
Defendant’s Motion and Brief in Support of Pre-Trial Release
US District Court for the District of Arizona. Motion and supporting brief in support of defendant’s pre-trial release.
Motion for Leave to Use Stand In Counsel
Motion for Defense Counsel to use stand-in counsel at an upcoming hearing, and a waiver of (out of state) defendant’s appearance at that hearing.
Objections to Presentence Report
Defendant’s objections to a pre-sentence report, primarily based on differences in State vs. Federal Definitions regarding the crime charged. US District Court for the District of Arizona.
Answer to Title VII Complaint
Defendants answer to complaint for title VII
Motion to Strike Alias & Memorandum in Support
MOTION TO STRIKE ALIAS, AND MEMORANDUM IN SUPPORT
Defendant’s Motion to Strike Aliases
DEFENDANTS’ MOTION TO STRIKE ALIASES
Defendant’s Motion to Preserve Severance
DEFENDANTS MOTION TO PRESERVE SEVERANCE MOTION
Motion to Exclude Prior Crimes
MOTION TO EXCLUDE EVIDENCE OF OTHER CRIMES OR WRONGS, OR ALTERNATIVELY, FOR NOTICE BY THE GOVERNMENT OF ITS INTENTION TO INTRODUCE AND RELY UPON Fed.R.Evid. 404(b) EVIDENCE, AND MEMORANDUM IN SUPPORT
MOTION TO DISMISS INDICTMENT
MOTION TO DISMISS INDICTMENT DUE TO THE DESTRUCTION OF EXCULPATORY EVIDENCE/ IN
THE ALTERNATIVE REQUEST FOR SPOLIATION INSTRUCTION
DEFENDANTS MOTION TO DISMISS BASED ON FAILURE TO STATE AN OFFENSE AND BRIEF IN SUPPORT
DEFENDANTS MOTION TO DISMISS BASED ON FAILURE TO STATE AN OFFENSE
AND BRIEF IN SUPPORT
Motion to Continue
Motion to Continue and motion to extend discovery deadlines
DEFENDANT’S MOTION IN LIMINE RE VICTIM TERMINOLOGY
DEFENDANT’S MOTION IN LIMINE RE VICTIM TERMINOLOGY
Motion in limine other act
DEFENDANT asserts that the Government should be precluded from eliciting any testimony regarding the alleged incidents and deemed inadmissible.
MOTION FOR TRANSPORTATION EXPENSES AND SUBSISTENCE
Thedefendan t is indigent and financially unable to provide the necessary
transportation to attend Court and is therefore requesting that this Court enter an
order as allowed under Title 18 U.S.C. § 4285.
MOTION FOR SPECIAL JURY VERDICT FORM
MOTION FOR SPECIAL JURYVERDICT FORM