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I. Pretrial Motions | Pretrial Motions: Motions in Limine | Pretrial Motions: Pretrial Discovery | II. DWI Motions | III. Sexual Assault Motions | IV. Post-Trial Motions | Post-Trial Motions: Art. 64 DNA Testing | Post-Trial Motions: Writ-invalid use of prior DWI | Miscellaneous
I. Pretrial Motions Affidavit for Non-Prosecution Application for Bench Warrant Bond Reduction Checklist Brief-Motion to Quash for Vagueness Brief-Reconsider Suppression Search Invalid Permission Brief-Suppression Bad Stop (2) Brief-Suppression Bad Stop (3) Brief-Suppression Bad Stop Brief-Suppression Illegal Detention and Search Brief-Suppression Illegal Entry(2) Brief-Suppression Illegal Entry Brief-Suppression Invalid Search Warrant Brief-Suppression of Search and Statement Brief-Suppression Search of Person Brief-Suppression Statement Business Records Affidavit Before Challenge to the Constitutionality of Juvenile Transfer Proceeding Constitution Cross-Reference Daubert Type Motion Defendant’s Acknowledgement of the Plea Bargain Offer Defendant’s Acknowledgment of Plea Bargain Defendant’s Application For Community Supervision Defendant’s Election as to Punishment Defendant’s Motion for Additional Funding (testing drugs) Defendant’s Motion for Approval of Expenditure for Independent Forensic Analysis (drugs) Defendant’s Motion for Approval of Expenditure for Independent Trace Residue Analysis Defendant’s Motion to Require Election by State Defendant’s Motion Requiring Notice of Prosecution’s Intent to Use Copies of Writing Defendant’s Request for Court Reporter Defendant’s Request for Notice of Extraneous Offenses Defendant’s Written Objections to Admission of Extraneous Offenses Ex Parte Motion for Appointment of Investigator Ex Parte Motion for Court Approval for Reimbursement of Defense Costs (ID expert) Ex Parte Motion for Experts Ex Parte Motion for Funds Funding Motion for Mitigation Specialist (ex parte) Habeas Corpus for Bond Reduction Individual Affidavit for Non-prosecution Jury Questionnaire Motion for Additional Time to Conduct Voir Dire Motion for Appointment of Expert Motion for Appointment of Interpreter Motion for Appointment of Mitigation Specialist (ex parte) Motion for Competency Exam Motion for Continuance Motion for Disclosure of Expert Witnesses and Data Relied Upon Motion for Disclosure under Brady and Kyles Motion for Examination and Re-Weighing of Physical Evidence Motion for Hearing on Admissibility of Enhancement Motion for Hearing on Voluntariness of Any Admission or Confession Whether Written or Oral Motion for Hearing Pursuant to Rule 705 Motion for Hearing Regarding Out of State Witness Motion for Hearing to Determine Competency Motion for Hearing to Test Qualifications of Prosecution Witness Motion for HIPAA Order for Medical Records Motion for ID hearing Motion for In Camera Inspection for Brady Material Motion for Pre-trial Hearing Motion for Substitution of Counsel Motion for Transcription of Examining Trial Motion to Adopt Pleadings Motion to Allow Additional Motions for Pre-trial Hearings Motion to Arraign Defendant Out of Presence of Jury Motion to Consider Unadjuducated Offenses Motion to Consolidate Motion to Defer Adjudication Motion to Discover Criminal Histories of Witnesses Motion to Dismiss Prosecution With Prejudice Motion to Exclude Testimony of Gang Affilliation Motion to File Additional Motions Motion to Keep Prosecutors from Talking to Jurors Post Verdict Motion to Preclude Use of Prejudicial Terms Motion to Quash Indictment Motion to Reduce State Jail Felony Motion to Release Because of Delay Motion to Suppress Evidence of the Arrest—Lack of Probable Cause Motion to Suppress Identification Motion to Suppress Illegally Seized Evidence Motion to Test Qualifications of Prosecution Reputation Witness Motion to Withdraw (ethical considerations) Motion Requesting Court to Schedule Examining Trial Petition for Writ of Habeas Corpus Ad Testificandum Plea Offer Letter to Client Pretrial Index Request Under Art. 37.07 §(3)(g) Stipulation of Evidence Subpoena for medical records
Pretrial Motions: Motions in Limine Defendant’s Motion in Limine (Name Calling by Prosecution) Motion in Limine (extraneous offenses and bad acts) Motion in Limine (Extraneous Offenses, Wrongs or Acts) Motion in Limine (Other Proceedings) Motion in Limine (Prior Criminal Record) Motion in Limine (Prior Trials) Motion in Limine (Regarding Matters Not Within Personal Knowledge of a Witness) Motion in Limine (Statements Made While Under Arrest) Motion in Limine (Trial Conduct) Motion in Limine and Objections to Admission of Extraneous Offenses Motion in Limine, For Hearing to Determine Relevancy and Reliability of Expert Testimony Motion in Limine Regarding Application for Community Supervision Motion to Limit Jury Argument of State Motion to Limit Jury Argument of State (2) Motion to Limit Jury Argument of State at the Punishment Stage Motion to Limit Jury Argument of State at the Punishment Stage (2) Motion to Suppress Improper Prosecutorial Conduct (is another witness lying)
Pretrial Motions: Pretrial Discovery Defendant’s Motion to Require Prosecution to Reveal any Agreement Defendant’s Request to the State for Notice of Extraneous Offenses Motion for Authority For State’s Witness to Discuss Facts Motion for Discovery and Inspection of Evidence Motion for Discovery of Corroborative Evidence Motion for Evidence Favorable to the Defendant Motion for Independent Examination of Evidence (DNA) Motion for List of State’s Witnessess Motion for Order for Release of Medical Records Motion for Production of Evidence for Expert Evaluation Motion for Production of Tape Recorded Evidence Motion for Production of Witness Statements Motion to Inspect Evidence Motion to Inspect, Examine and Independently Test Physical Evidence Motion to Inspect Scene Motion to Preserve Evidence Motion to Require Disclosure of CI Identity Motion to Reveal the Deal Pretrial Discovery Index
II. DWI Motions Brief-DWI Suppression—anonymous tip Brief-DWI Suppression-blood test Brief-DWI Suppression-breath test consent DWI Motion to Suppress Motion to Exclude Extrapolation Motion to Preclude Police Officer Testimony on Reliability
III. Sexual Assault Motions Motion for Additional Voir Dire Motion for Affirmative Finding Pursuant to Art. 42.017 CCP Motion for Exemption from Sex Offender Registration Motion In Limine-Recovered Memories, Rule 404(b) Motion to Permit Inspection and Copying of Items Covered by Motion to Produce Exculpatory and Mitigating Evidence in Regard to Allegations against Defendant of Sexual Assault of a Child or Indecency with a Child Motion to Suppress Hearsay Statement of Child Witness Motion to Suppress Outcry Statement
IV. Post-Trial Motions Agreed Motion to Modify Probation Application for Sealing of Juvenile Records Application for Writ of Habeas Corpus Application for Writ of Habeas Corpus (conviction based upon void indictment) Defendant’s Motion for ________ County to Pay for Statement of Facts Motion for DNA Test of Sperm Evidence—Art. 64.01 Motion for Expunction of Criminal Records Motion for Imposition of Sentence of Shock Probation Motion for Nondisclosure of Criminal History Motion for Nondisclosure of Criminal History (Misdemeanor) Motion for Prompt Revocation Hearing Motion for Reasonable Bail Pending Appeal Motion to Set Aside Felony and Entry of Misdemeanor Motion to Discharge Community Supervision Petition for Expunction of Criminal Records
Post-Trial Motions: Art. 64 DNA Testing DNA Testing Motion Appendix Motion for DNA Testing (Art. 64) Motion for DNA Testing (Art. 64) (2) Amended Motion for DNA Testing (Ch.64) (2) Post Conviction DNA Test—Art. 64.01
Post-Trial Motions: Writ-invalid use of prior DWI Application for Writ of Habeas corpus (invalid use of prior DWI conviction) Memorandum and Order (regarding invalid use of prior DWI convictions) Proposed Findings of Fact and Conclusions of Law (regarding invalid use of prior DWI conviction)
Miscellaneous Defendant’s Motion for Directed Verdict of Acquittal Motion for the Court to Hold Cellular Phones of Jurors During Deliberation Motion for Release on Personal Recognizance (Attorney Contempt) Preserving Error for Appellate Review
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