Miscellaneous Criminal Defense Motions

COMES NOW the Defendant, (name), by and through his undersigned attorney, pursuant to State Rules of Criminal Procedure 3.131, and Article 1, Section 14 of the State Constitution, and respectfully moves this Honorable Court to set a bond in the above-styled cause. As grounds therefore, the Defendant states as follows:…

COMES NOW the Defendant, by and through his undersigned counsel, pursuant to Rule 3.800(c), Florida Rules of Criminal Procedure, and hereby respectfully requests that this Court enter an order, confirming the Defendant may live with his parents, in their home, in Florida (upon the Defendant’s [date] release from prison), and…

COMES NOW the Defendant, by and through his undersigned attorney, pursuant to Fla. R. Crim. P. 3.220(h)(1)(D), and respectfully moves the Court for an order permitting the depositions of three Category A witnesses, and in support thereof, states as follows: 1. On December 24, the Defendant was arrested and charged…

COMES NOW the Defendant, by and through his undersigned attorney, pursuant to Fla. R. Crim. P. 3.220(h)(1)(D), and respectfully renews his motion for an order to take the depositions of officers A and B, who are designated by the State as Category A witnesses, and in support thereof, states the…

(1) MOTION TO RECONSIDER AND ADMIT CHARACTER EVIDENCE TESTIMONY (2) RESPONSE TO COURT REPORT REGARDING CPL. COHILL (3) SUMMARY ARGUMENT AND INCORPORATED MEMORANDUM OF LAW COMES NOW the Defendant, by and through his undersigned attorney, and respectfully (1) moves this Honorable Court to reconsider its ruling that character evidence is…

COMES NOW the Child, by and through his undersigned counsel, and hereby respectfully requests this Honorable Court to (1) amend the Child’s release to straight release to his parents, (2) permit the child to attend school,(3) if the high school permits, permit the Child to attend meetings and extra curricular…

MEMORANDUM OF LAW COMES NOW the Defendant, by and through his undersigned counsel, and hereby files this Memorandum of Law, and in support thereof, states as follows: 1. Burglary Tools Florida Statute 810.06, entitled Possession of Burglary Tools, states the following: Whoever has in his or her possession any tool,…

VERIFIED MOTION TO DISQUALIFY AND INCORPORATED MEMORANDUM OF LAW COMES NOW the Defendant, by and through his undersigned counsel, pursuant to Rule 2.330, Florida Rules of Judicial Administration, and hereby files this Verified Motion to Disqualify and Incorporated Memorandum of Law, and in support thereof, states as follows: Rule 2.330,…

COMES NOW the Defendant, by and through his undersigned counsel, and hereby files this Motion to Exclude Williams Rule Evidence. In support thereof, defendant states as follows: FACTS 1. The Client is charged with two counts of sexual battery and one count of lewd and lascivious molestation. 2. A trial…

COMES NOW the Defendant, by and through his undersigned attorney, pursuant to Rule 3.131, Florida Rules of Criminal Procedure, and Article 1, Section 14 of the Florida Constitution, and respectfully moves this Honorable Court to grant bail in a reasonable amount in the above-styled cases. As grounds therefore, the Defendant…