Library of Motions
- SARBANES-OXLEY
- PARALLEL PROCEEDINGS
- FEDERAL DISCOVERY LETTER
- COMPARISON BETWEEN STATE AND FEDERAL CRIMINAL PRACTICE (DOC)
- MOTION TO INSPECT EVIDENCE
- ATTORNEY-CLIENT PRIVILEGE PROTECTION ACT OF 2006 (PDF)
- DEFENDANT’S BRIEF IN SUPPORT OF DEFENDANT’S MOTION TO SUPPRESS EVIDENCE
- MOTION FOR HEARING ON VOLUNTARINESS OF ANY ADMISSION OR CONFESSION
- MOTION TO SUPPRESS EVIDENCE SEIZED WITHOUT A WARRANT
- MOTION TO SUPPRESS EVIDENCE
- MOTION TO SUMMON OUT-OF-STATE WITNESS AND FOR ADVANCE FOR EXPENSES
- MOTION TO SHUFFLE JURORS
- REQUEST FOR NOTICE UNDER RULE 404(b)
- MOTION FOR PRODUCTION OF WITNESS STATEMENTS
- MOTION FOR PRE-TRIAL HEARING
- ORDER GRANTING MOTION TO SUPPRESS
- MOTION FOR THE COURT TO DIRECT THE COURT REPORTER TO TAKE VOIR DIRE EXAMINATION OF THE JURY AND ALL FINAL ARGUMENTS IN THE ABOVE-STYLED AND NUMBERED CAUSE
- MOTION TO SUPPRESS
- MOTION TO LIST STATE’S WITNESSES
- MOTION IN LIMINE REGARDING VOIR DIRE EXAMINATION ON FIFTH AMENDMENT RIGHTS
- MOTION IN LIMINE – EXTRANEOUS MATTERS
- MOTION IN LIMINE REGARDING APPLICATION FOR PROBATION
- DEFENDANT’S MOTION TO ELECT THE JURY TO ASSESS PUNISHMENT
- MOTION FOR PRODUCTION AND INSPECTION OF GRAND JURY MINUTES
- MOTION TO DISMISS INDICTMENT FOR IMPROPER GRAND JURY PROCEDURES
- MOTION TO REVEAL WITNESSES AND EXTRANEOUS OFFENSES
- MOTION FOR THE PRODUCTION OF EXCULPATORY AND MITIGATING EVIDENCE
- MOTION FOR EARLY RELEASE FROM PROBATION
- MOTION FOR DISCOVERY OF WITNESSES
- MOTION FOR DISCOVERY AND INSPECTION OF EVIDENCE
- MOTION FOR DISCOVERY
- MOTION TO DISCOVER CRIMINAL RECORDS OF WITNESSES
- MOTION TO DISCLOSE EXPERT WITNESSES
- DESIGNATION OF RECORD ON APPEAL
- DEFENDANT’S MOTION TO ELECT THE COURT TO ASSESS PUNISHMENT
- MOTION WITH REFERENCE TO ARRAIGNMENT OF THE ACCUSED
- APPLICATION FOR PROBATION
- DEFENDANT’S REPLY TO GOVERNMENT’S RESPONSE TO DEFENDANT AGEE’S MOTION FOR NOTIFICATION OF DATES OF BIRTH FOR THREE CO-DEFENDANTS
- COMBINED MOTION AND MEMORANDUM IN SUPPORT FOR BILL OF PARTICULARS
- MOTION TO DISMISS OR TRANSFER BASED UPON VENUE
- DEFENDANT’S REQUEST FOR A MINIMUM SENTENCE PURSUANT TO 18 U.S.C. SECTION 3553(a) FACTORS & MOTION FOR DOWNWARD DEPARTURE PURSUANT TO U.S.S.G 5K2.0
- MOTION TO QUASH INDICTMENT AND EXCEPTION FOR FAILURE TO PROVIDE SUFFICIENT NOTICE OF CRIMES CHARGED
- MOTION TO QUASH INDICTMENT AND EXCEPTIONS FOR FAILURE TO PROVIDE SUFFICIENT NOTICE OF CRIMES CHARGED
- DEFENDANT LEWIS’S MOTION AND INCORPORATED MEMORANDUM FOR PRODUCTION AND INSPECTION OF BRADY MATERIAL AND/OR INFORMATION WHICH MAY LEAD TO EVIDENCE
- DEFENDANT’S MOTION TO REMOVE ELM AS CONDITION OF BOND
- DEFENDANT’S TRIAL BRIEF ON STATE’S FAILURE TO AMEND THE INDICTMENT
- COMPARISON BETWEEN STATE CRIMINAL PRACTICE AND FEDERAL CRIMINAL PRACTICE
- CRAWFORD UPDATE
- ATTACKING HGN
- FUNDING MOTION FOR INVESTIGATOR/MITIGATION SPECIALIST
- RIECKI SENTENCING (DOC)
Phone Numbers
Office: (214) 538-6629
Office Location
Dallas
