PRE-TRIAL MOTIONS & RESPONSES 47
- Brief in Support of Admissibility of DNA Evidence
- Brief in Support of State’s Motion to Exclude Defense Expert
- Brief Opposing Taint Hearing
- Child Hearsay Notice
- Comprehensive Trial Brief – Various Issues
- Constitutionality of Statute Extending Statute of Limitations for DNA Cases
- DNA Chain of Custody Brief
- Memorandum in Opposition to Defendant’s Motion for Psychological Evaluation of Victim
- Memorandum in Support of Age Appropriate Questions
- Memorandum in Support of Age Appropriate Questions and Support Persons in Courtroom
- Memorandum in Support of Bindover
- Memorandum in Support of Compelled Blood Test for HIV
- Memorandum in Support of Motion to Allow Testimony via Video
- Memorandum in Support of Precluding Competency Inquiry and Foregoing Oath
- Motion for Age Appropriate Questions
- Motion for Special Procedures during Child Testimony
- Motion in Limine Regarding Prior Accusations by Victim
- Motion to Allow Child Witnesses to Testify via Videotape
- Motion to Allow Parents in Courtroom as Support Person
- Motion to Allow the Victim to be Examined in Front of Jury Box
- Motion to Amend Information
- Motion to Consolidate Multiple Cases for Trial
- Motion to Exclude Canine DNA
- Motion to Exclude Testimony of Defense Expert on Issues of Memory and Suggestibility
- Motion to Preclude Competency Inquiry and Administer Oath
- Motion to Preclude Evidence of Past Sexual Behavior of Victim
- Motion to Preclude Past Sexual Behavior of Victim Pursuant to Rape Shield
- Motion to Restrict Somebody Else Did It Defense without Proper Showing and Rape Shield Motion
- Objection to Defendant’s Motion for Psychological Evaluation of Victim
- Objection to Defendant’s Motion to Reconsider Psychological Evaluation of Victim
- Opposition Brief to Defendants Rape Shield Motion
- Opposition to Admission of Victim’s Prior Sexual History Pursuant to Rape Shield
- Opposition to Defense Motion to Exclude Testimony of Child Victim
- Opposition to Defense Motion to Quash Bindover
- Response Brief on Use of Term “Victim” at Trial
- Response to Defendants Motion to Elect
- Rule 702 Response Brief Abusive Head Trauma
- Sample Document
- State’s Motion to Compel Test for Gonorrhea
- State’s Notice of Intent to Introduce Prior Consistent Statements
- State’s Notice of Intent to Use Learned Treatises
- State’s Response to Defendant’s Motion to Dismiss Charges Based on Lack of Specificity
- State’s Response to Defendant’s Request for a Bill of Particulars
- State’s Response to Defense Motion to Dismiss John Doe DNA Warrant
- State’s Trial Brief Assorted Issues
- Support Brief in Opposition to Motion to Dismiss Charges Based on Lack of Specificity
- Trial Brief – Assorted Issues