Resources

Discovery

Motion to Compel In-Person Interview or Deposition (3.2020)

This brief supports the defense motion to compel when the witness refuses to participate in an in-person defense interview, the witness is a critical witness and the only witness to the alleged crime. Thanks to Emily Gause.

MORE

Motion to Compel In Person Interview or Deposition (2009)

This brief supports the defense motion to compel in person interview or deposition when the witness lives out of state and the prosecutor refuses to pay for travel to permit a defense interview well in advance of trial.

MORE

Defense Objection to Protection Order for Child Forensic Interview Recording (3.2019)

This brief argues that RCW 26.44.186, which requires a court to issue a protection order governing the dissemination and use of audio and video recording of a "child forensic interview" is unconstitutionally vague, violates separa...

MORE

Order Denying Protection Order for Child Forensic Interview Recording FOF/COL (4.2019)

This sample court order denies the state's request for a protection order for the child forensic interview recording and the court enters findings of fact and conclusions of law holding RCW 26.44.186 is unconstitutional as it viol...

MORE

Declaration of Counsel in Support of Motion to Photograph Defendant (2016)

MORE

Motion to Photograph Defendant in Jail (2010)

Sample motion and order to allow defendant to be photographed in jail by defense attorney or investigator in presence of correction staff. Thanks to Edwin Aralica.

MORE

Motion to Preserve Evidence (2010)

This sample motion argues the court should order a repo company to preserve a vehicle for defense inspection. Thanks to Edwin Aralica.

MORE

Motion for CPS Records (2016)

MORE

Motion to Compel Jail Phone Dump

This motion asks the court to order the prosecutor to identify jail calls they will use at trial (when they dump a large volume of calls on defense counsel). Thanks to Shoshana Page.

MORE

Order -Denying State Motion to Compel Redactions to PRA records

Defense sought records from the prosecutor pursuant to the PRA. The prosecutor argued that CrR 4.7(h)(3) applied and the material should only be provided after redactions. Trial court denied the state’s motion. Thanks to Van...

MORE