Motion & Order to Admit Past Sexual Conduct (Rape Shield)

Motion & Order to Admit Past Sexual Conduct (Rape Shield) This motion sought to admit past sexual conduct of the alleged victim which was both recent in time and similar enough to the alleged conduct to be relevant to the iss...

Motion To Dismiss-Detainers Act Violation

Right to Present a defense (8.2017)

Juvenile Restitution Individual -2015 law

This brief argues the court should convert joint and several liability to individual liability pursuant to the 2015 YEAR act. Thanks to Lawrence Larson.

Insanity Defense_St v. Haq

Appellate Brief (COA) in State v. Naveed Haq arguing (1) unconstitutional to require defendant to carry burden of proof in insanity defense and (2)10.77.020(5) violates sepearation of powers doctrine.

Notice of Self Defense (Reimburse)

Duress- State must prove lack of duress BRD

2010 – Appellants Opening Brief in St v. Dow

Burden of Proof- Element Negating Defenses

2011 Writ to the US Supreme Court in Pickering v. Colorado- arguing the prosecution must disprove an element-negating defense with proof beyond a reasonable doubt.

Duress Defense Plus Evedentiary Issues – Trial Brief

Notice Of Self Defense