Leonard Martinez
- Colorado, United States (US)
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DEFENDANT’S EMERGENCY MOTION FOR TELEPHONIC HEARING
Defendant’s counsel certifies that he has attempted to contact plaintiff’s counsel several times and received no response prior to filing this motion. Defendant filed a motion in Limine regarding hypothetical settlement scenarios.Â
DEFENDANT’S COMBINED REPLY IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT, MOTION FOR DETERMINATION OF LAW, AND MOTION FOR PARTIAL SUMMARY JUDGMENT AS TO THE CONDUCT
Defendant’s combined reply in support of motions for summary judgment, motion for determination of law, and motion for partial summary judgement as to the conduct of a person.Â
COMPLAINT AND JURY DEMAND
Plaintiff’s complaint against defendant and plaintiff’s jury demand.Â
ANSWER AND JURY DEMAND
Defendant’s answer to Plaintiff’s complaint and defendant’s jury demand.Â
Unopposed Motion for Stay of Execution of Sentence
Defendant’s attorney requests the court to enter an order staying the execution of the sentence in this matter until such time as the merits of the appeal at all levels has been determined.Â
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE OPENING BRIEF
Defendant’s attorney files an unopposed motion for extension of time to file opening brief.Â
RESPONSE TO SHOW CAUSE ORDER
Defendant’s response to the Show Cause Order
REQUEST FOR COMPENTENCY EVALUATION PURSUANT TO C.R.S. 16-8.5-103 [10]
REQUEST FOR COMPENTENCY EVALUATION PURSUANT TO C.R.S. 16-8.5-103 [10] |
PEOPLE’S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE ANSWER BRIEF
People’s unopposed motion for enlargement of time to file answer brief.Â
PEOPLE’S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE ANSWER BRIEF
People’s unopposed motion for enlargement of time to file answer brief.Â
PEOPLE’S OBJECTION TO COMPTENCY EVALUATION AS INADEQUATE AND REQUEST FOR PAYMENT OF SECOND EVALUATION
District Attorney respectfully objects to the evaluation done pursuant to a competency evaluation request by the defense and requests this Honorable Court find the evaluation inadequate and order payment of the second evaluation.
PEOPLE’S MOTION FOR PROTECTIVE ORDER UNDER RULE 16 III (d)
PEOPLE’S MOTION FOR PROTECTIVE ORDER UNDER RULE 16 III (d)Â
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NOTICE OF APPEAL PURSUANT TO C.R.Cr.P. RULE 37 AND DESIGNATION OF RECORD
NOTICE OF APPEAL PURSUANT TO C.R.Cr.P. RULE 37 AND DESIGNATION OF RECORD
MOTION TO SUPRESS AUTOPSY AS A SANCTION [14]
Defendant’s motion to suppress autopsy because the defense counsel was allowed to present during the autopsy in this matter, violating the order of the court, the Colorado Bar Association Ethics Opinion, and violating C.R.C.P. 16.Â
MOTION TO SUPPRESS: THE WARRANT
MOTION TO SUPPRESS: THE WARRANT RELIED UPON TO SEARCH DEFENDANT’S HOME WAS UNCONSTITUTIONAL BECAUSE IT WAS AUTHORIZED WITHOUT PROBABLE CAUSE, DID NOT IDENTIFY THE OBJECT OF THE SEARCH NOR THE PREMISES TO BE SEARCHED WITH SPECIFICITY, AND WHILE EXECUTING THE WARRANT, THE POLICE WENT BEYOND THE SCOPE ALLOWED BY THE SEARCH WARRANT, AND COLLECTED NUMEROUS ITEMS NOT AUTHORIZED BY THE WARRANT [16]. |
MOTION TO SUPPRESS EVIDENCE, OBSERVATIONS AND STATEMENTS OBTAINED IN VIOLATION OF — RIGHT TO DUE PROCESS [DEF – 7]
MOTION TO SUPPRESS EVIDENCE, OBSERVATIONS AND STATEMENTS OBTAINED IN VIOLATION OF — RIGHT TO DUE PROCESS      [DEF – 7] |
MOTION TO SUPPRESS EVIDENCE AND OBSERVATIONS OBTAINED AS A RESULT OF VIOLATIONS OF — RIGHT TO BE FREE FROM UNREASONABLE SEARCHES AND SEIZURES [DEF – 5]
MOTION TO SUPPRESS EVIDENCE AND OBSERVATIONS OBTAINED AS A RESULT OF VIOLATIONS OF — RIGHT TO BE FREE FROM UNREASONABLE SEARCHES AND SEIZURES [DEF – 5] |
MOTION TO SUPPRESS ALL EVIDENCE SEIZED PURSUANT TO DEFFECTIVE ARREST WARRANT [17]
MOTION TO SUPPRESS ALL EVIDENCE SEIZED PURSUANT TO DEFFECTIVE ARREST WARRANT [17] |
MOTION TO SEVER POSESSION OF A WEAPON BY A PREVIOUS OFFENDER FROM THE OTHER CHARGES [DEF – 1]
Defendant seeks an order severing the Possession of a Weapon Count from the other counts of Driving Under the Influence, Lane Usage Violation, Possession of a an Illegal Weapon, Prohibited Use of a Weapon, and Possession of Alcohol in a Motor Vehicle.