Resources

Trial Issues

Motion to Admit Evidence of Immigration Status Under ER 413

This motion argues that a trial court must admit evidence of a noncitizen complaining witness’ immigration status if the complaining witness’ testimony makes it more likely that s/he may be eligible for lawful permanen...

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Stipulation to Prior Conviction – Old Chief

In this sample stipulation, the defendant stipulates to a prior conviction sufficient to suspend defendant’s right to possess a firearm.

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Objection To Government Presenting Video Testimony By David Iannotti

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Motion in Limine- “Gang” evidence (2012)

Brief in support of motion in limine to exclude reference to gang membership or purpose of any actions relating to gang membership (thanks to Susan Ogleby)

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Other Suspect Brief

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Trial Memorandum (Template)

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Prosecutorial Misconduct

CLE Materials -contains a sample pre-trial mtn to prevent improper argument

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Mtn to Exclude Testimony _Lavaris

Challenging the State from calling its own witness solely to impeach her own statement.

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Motion For Seperate Jury Pools

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Right To Cross Examine On Bias

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