Motions, Forms and Brief Bank

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4th Amendment

๐Ÿ’ผ4th Amendment Motions Primer for Digital Evidence - OUTLINE
๐Ÿ’ผDeclaration In Support Of Motions
๐Ÿ’ผMotion For Full Discovery Regarding The Facts And Circumstances Underlying Surveillance
๐Ÿ’ผMotion For Rule 17 Subpoena - Crash Data
๐Ÿ’ผMotion For Suppression And New Trial Based on Intro of Evidence from Unlawful Electronic Surveillance
๐Ÿ’ผMotion For Vacation Of Conviction And Alt Remedies Of Dismissal, Suppression Of Evidence, And New Trial
๐Ÿ’ผMotion In Limine To Exclude Unreliable Statements
๐Ÿ’ผMotion to Compel Discovery Re Facial Recognition Information edited
๐Ÿ’ผMotion to Disclose Sealed Portions of Affidavit re Search Warrant
๐Ÿ’ผMotion To Suppress Evidence Obtained From Surveillance Under FISA, Motion For Discovery
๐Ÿ’ผMotion to Suppress Evidence_ Memorandum of Points of Authority - US v.Keys
๐Ÿ’ผRenewed Motion to Dismiss for Outrageous Government Conduct_ Request for Evidentiary Hearing
๐Ÿ’ผReply To Opposition To Motion To Suppress
๐Ÿ’ผSample Declaration in Support of Motion to Get Police Misconduct Records

Bill of Particulars

๐Ÿ’ผDefendantsโ€™ Joint Notice Of Motion And Motion For Bill Of Particulars
๐Ÿ’ผMemo Of Law In Support Of Motion To Dismiss Or In The Alternative For A Bill Of Particulars
๐Ÿ’ผMotion for Bill of Particulars
๐Ÿ’ผSample Motion for Bill of Particulars

Brady Motions

๐Ÿ’ผBrady Letter and Motion
๐Ÿ’ผBrady Motion - For DUI cases
๐Ÿ’ผBrady Motion - STANDARD - No Case Law
๐Ÿ’ผBrady Motion Attachment - Memorandum For Department Prosecutors
๐Ÿ’ผBrady Motion
๐Ÿ’ผMotion To Compel Discovery Pursuant To Brady V. Maryland And Request For Evidentiary Hearing
๐Ÿ’ผMotion to Compel Production of Exculpatory and Impeachment Evidence
๐Ÿ’ผMotion to Disclose PC - Villa Munoz
๐Ÿ’ผSample Motion for Pretrial Discovery and Brady Materials

Capital Cases

๐Ÿ’ผContinuance Denied (reversal) - Pennsylvania
๐Ÿ’ผEx Parte Motion for Funds to Secure Services of a Mitigation Specialist
๐Ÿ’ผMemorandum Addressing Failure To Preserve Evidence
๐Ÿ’ผMotion for Discovery - Capital Cases
๐Ÿ’ผMotion Preclude The Death Penalty As A Sentencing Option - Reduced Capacity Due To Mental Illness
๐Ÿ’ผMotion to Authorize the Services of a Defense-Based Victim Liaison - Ex Parte and Under Seal
๐Ÿ’ผMotion To Disclose Any Prior Info In Held by The Sheriffโ€™s Office And Dept Of Homeland Security
๐Ÿ’ผMotion To Preclude The Death Penalty As A Sentencing Option - Reduced Mental Capacity Due to Low IQ
๐Ÿ’ผMotion To Preclude The Death Penalty As Sentencing Option - Reduced Mental Capacity - Fetal Alcohol Synd
๐Ÿ’ผMotion To Preclude The Govt From Seeking The Death Penalty Against A Severely Mentally Ill Defendant
๐Ÿ’ผSample Continuance Motion

Digital Evidence

๐Ÿ’ผMotion To Suppress Evidence Seized From Laptop Computer And The Fruits Of Such Evidence
๐Ÿ’ผMotion to Quash Law Enforcement Subpoena Duces Tecum (SDT) for Social Media Content
๐Ÿ’ผMotion in Limine to Exclude Expert Testimony and Cellular Analysis Report of FBI Agent
๐Ÿ’ผMotion For Reconsideration of Denial To Suppress Evidence Seized From Laptop Computer
๐Ÿ’ผEx Parte Motion To Compel Compliance With Subpoena For Records
๐Ÿ’ผDiscovery Motions for Call Detail Records
๐Ÿ’ผCorrected Opinion Historical Cell Site
๐Ÿ’ผCell Site Location Info Motion - Opposition to Govt Application under 18 U.S.C.Section 2703(D)

Drug Cases

๐Ÿ’ผDeclaration In Support Of Opposition To The Govt Motion To Quash FedExโ€™s Rule 17 (C) Subpoena
๐Ÿ’ผDeclaration In Support Of The FedEx Defendantsโ€™ Motion For Rule 17(C) Subpoenas
๐Ÿ’ผFedex Defendantsโ€™ Motion For The Issuance Of Rule 17(C) Subpoenas To The FDA, FBI, U.S. Customs
๐Ÿ’ผMotion Challenging Face of the Indictment - US v. Ulbricht
๐Ÿ’ผMotion for Bill Particulars
๐Ÿ’ผMotion for Departure at Sentencing
๐Ÿ’ผMotion for Disclosure and Discovery of Informants 9.3.13
๐Ÿ’ผMotion for Disclosure and Discovery Re Informants
๐Ÿ’ผMotion for Rule 17 (C) Subpoena Crash Data Statistics
๐Ÿ’ผMotion for Severance - US v King
๐Ÿ’ผMotion for Severance - US v Kozina
๐Ÿ’ผMotion to Compel Discovery Canine Searches
๐Ÿ’ผMotion To Compel Production Of Discovery
๐Ÿ’ผMotion to Continue Trial Date and Pretrial Motions Deadline
๐Ÿ’ผMotion to Disclose Sealed Portions of Affidavit in Support of Search Warrant
๐Ÿ’ผMotion to Dismiss and Request for Canine Handler
๐Ÿ’ผMotion to Dismiss for Vagueness - Amended
๐Ÿ’ผMotion To Dismiss Indictment And Bar Prosecution On Double Jeopardy Grounds
๐Ÿ’ผMotion To Dismiss Rico Conspiracy Charge Because 18 U.S.C. ยง 1962(D) Is Vague As Applied
๐Ÿ’ผMotion To Produce Medical Records And Personnel File
๐Ÿ’ผMotion to Quash and Traverse Search Warrant
๐Ÿ’ผMotion To Suppress Wiretap Evidence
๐Ÿ’ผMotions To Suppress, Order Production Of Discovery, For A Bill Of Particulars, And To Strike Surplusage
๐Ÿ’ผNotice of Motion to Sever
๐Ÿ’ผOmnibus Motion To Suppress Evidence And For Return Of Property
๐Ÿ’ผOpposition to Motion to Quash 17(c) Subpoena to DEA
๐Ÿ’ผOrder re Motion to Continue Discovery and Case Schedule
๐Ÿ’ผReply to Govt Opposition to Motion Challenging Face of Indictment - US v.Ulbricht
๐Ÿ’ผReply to Govt Opposition to Pretrial Motions - US v.Ulbricht
๐Ÿ’ผResponse To Governmentโ€™s Motion To Reconsider Portions Of Order Regarding Discovery
๐Ÿ’ผSample Motions - Pretrial Release, Evidentiary Hearing, Sever, Suppress Evidence, Disclose Informant

DUI Cases

๐Ÿ’ผGovt Response to Motion to Suppress and Exclude - McNeely Memo
๐Ÿ’ผLegal Writing for Motions OVERVIEW OUTLINE
๐Ÿ’ผMcNeely Memo
๐Ÿ’ผMcNeely Reply Memo
๐Ÿ’ผMemorandum In Support Of Motion To Suppress Search And Seizure
๐Ÿ’ผMotion Discovery of Autopsy Evidence - Medical Examiner
๐Ÿ’ผMotion for a New Trial
๐Ÿ’ผMotion for Discovery - Laboratory and Scientific Evidence - DNA Expanded
๐Ÿ’ผMotion for Discovery DNA and Laboratory Scientific Evidence
๐Ÿ’ผMotion for Discovery Fingerprint Evidence
๐Ÿ’ผMotion for Discovery of Laboratory Evidence - Toxicology
๐Ÿ’ผMotion for Frye-Mack Hearing
๐Ÿ’ผMotion In Limine To Exclude Evidence Of Communications Involved In Substance Abuse Treatment
๐Ÿ’ผMotion In Limine To Exclude Specific Instances Of Conduct Of A Witness - 608(b)
๐Ÿ’ผMotion to Suppress - Blood Draw - Cross Examination Questions
๐Ÿ’ผMotion To Suppress Search And Seizure
๐Ÿ’ผNotice of Motions
๐Ÿ’ผSample Motions in DUI Cases and Other Pleadings

Experts and Evidence

๐Ÿ’ผAlberico Motion And Request For An Evidentiary Hearing To Exclude Testimony Of Expert
๐Ÿ’ผEx Parte Motion for Funding for Expert Assistance Psychiatrist as Expert
๐Ÿ’ผGovernmentโ€™s Memorandum In Opposition To Defendantโ€™s Motion To Admit Expert Testimony
๐Ÿ’ผMotion and Memo to Admit NIJ Guidelines into Evidence
๐Ÿ’ผGovt Motion To Exclude Defendants Proposed Expert Witness
๐Ÿ’ผMotion Compelling Plaintiff To Identify Expert Witness and Serve Summary Of Testimony
๐Ÿ’ผMotion for Testing of Recovered Evidence
๐Ÿ’ผMotion In Limine Re Testimony Offered By Govt Witness During The Trial Of This Matter
๐Ÿ’ผMotion In Limine Regarding Proposed Testimony Of Govt Expert
๐Ÿ’ผMotion In Limine To Exclude Plaintiffโ€™s Expert From Offering Opinions Or Evidence
๐Ÿ’ผMotion In Limine To Preclude Testimony Of Medical Examiner - Tyler Motion
๐Ÿ’ผMotion To Admit Expert Testimony Under Federal Rule Of Evidence 702
๐Ÿ’ผMotion To Allow Inspection of Crime Scene and Photographically Preserve Evidence
๐Ÿ’ผMotion to Compel DEA Discovery or to Dismiss - Exhibits - Redacted
๐Ÿ’ผMotion to Compel DEA Discovery or to Dismiss - Redacted
๐Ÿ’ผMotion To Compel Discovery Related To Drug Analysis And Memo - DEA
๐Ÿ’ผMotion to Declare Defendant Indigent for Purposes Other Than Attorney Fees
๐Ÿ’ผMotion to Dismiss - Destruction of Evidence
๐Ÿ’ผMotion To Dismiss For Loss Of Exculpatory Evidence
๐Ÿ’ผMotion To Exclude Any Evidence Relating Clothing Destroyed By State, Dismiss Murder Charge
๐Ÿ’ผMotion to Exclude DEA Analysis - Exhibits - redacted
๐Ÿ’ผMotion To Exclude DEA Analysis Of Seized Substance Pursuant To Frye
๐Ÿ’ผMotion To Proceed Ex Parte For Expenses
๐Ÿ’ผMotions To Dismiss Pursuant To CrRLJ 8.3(B) And Due To Spoliation Of Evidence
๐Ÿ’ผNotice And Motion For Release Of Court Funds For Expert Assistance
๐Ÿ’ผNotice of Motion In Limine to Exclude Govt Expert Testimony
๐Ÿ’ผOpposition to Government_s Motion for Protective Order
๐Ÿ’ผOpposition To The Governmentโ€™s Motion To Exclude Defendantsโ€™ Proposed Expert Witnesses
๐Ÿ’ผResponse to Government_s Motion in Limine to Exclude Expert Testimony
๐Ÿ’ผResponse to Govt Reply to Defense Opposition to Government_s Motion for Protective Order
๐Ÿ’ผSample Motion in Limine to Prevent Defenses and Defense Evidence
๐Ÿ’ผUSA_s Motion in Limine for Daubert Hearing Regarding Two of the Defendants Experts

General Motions

๐Ÿ’ผEmergency Motion to Disqualify Prosecutor and Request for Appointment of Special Prosecutor
๐Ÿ’ผJoint Motion Seeking Order To Comply With Grand Jury Subpoena Dated
๐Ÿ’ผMotion for Change Of Venue And Incorporated Memorandum Of Law
๐Ÿ’ผMotion for Continuance Until Critical Evidence Is Disclosed and Produced
๐Ÿ’ผMotion for Dismissal With Prejudice Under The Due Process Clause
๐Ÿ’ผMotion for Formal Bail Hearing and Order Releasing Defendant on Own Recognizance or Bail Reduction
๐Ÿ’ผMotion for Meaningful Grand Jury Proceeding
๐Ÿ’ผMotion for Removal and Request for a Hearing - Criminal Freddie Gray Case
๐Ÿ’ผMotion for Severance - US v King
๐Ÿ’ผMotion for Severance - US v Kozina
๐Ÿ’ผMotion for Speedy Trial or Dismissal of Pending Charges
๐Ÿ’ผMotion to Compel Interview

Voir Dire Issues

๐Ÿ’ผEmergency Motion to Disqualify