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...

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.

Objection To Government Presenting Video Testimony By David Iannotti

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)

Other Suspect Brief

Trial Memorandum (Template)

Prosecutorial Misconduct

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

Mtn to Exclude Testimony _Lavaris

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

Motion For Seperate Jury Pools

Right To Cross Examine On Bias