#-COA-Petitioner-Emergency-Motion-to-Shorten-Time&Expedite-Review-Redacted

Court of Appeals Motion to Shorten Time & Expedite Review: Primarily used for interlocutory appeals/discretionary review when trial has already been set and the court won’t allow further continuances. Can be modified to ...

Defense Motion for Reconsideration of Court Denial to Vacate Blake Conviction

This motion discusses what Blake actually stood for, and what it held was the statute was unconstitutional and void since inception. Therefore, a trial court lacks any authority or discretion to analyze on a case by case basis whe...

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