Defense Proposed Order To Admit Immigration Status Under ER 413 – New Rule

Motion To Dismiss-Detainers Act Violation

Trial Objections Checklist

Evidence Rules Reference Guide

MOTION TO ADMIT IMMIGRATION STATUS UNDER NEW RULE ER 413 – Dec. 2022

Sheri M. Oertel’s Winning ER 413 Motion under the new rule. This is Sheri M. Oertel’s (SMO) successful motion used in private practice. The court ruled that the immigration status of the complaining witness and his mis...

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