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Legal Pleadings

Miscellaneous Criminal Defense Motions

Motion to Take Depositions

By Fallgatter Catlin & Varon, P.A.

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…

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Renewed Motions To Take Depositions

By Fallgatter Catlin & Varon, P.A.

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…

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Motion To Permit Character Evidence

By Fallgatter Catlin & Varon, P.A.

(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…

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Motion To Modify Conditions of Release

By Fallgatter Catlin & Varon, P.A.

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…

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Memorandum of Law – Burglary

By Fallgatter Catlin & Varon, P.A.

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,…

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Motion to Recuse Judge

By Fallgatter Catlin & Varon, P.A.

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,…

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Motion to Exclude Williams Rule Evidence

By Fallgatter Catlin & Varon, P.A.

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…

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Motion to Set and Reduce Bond

By Fallgatter Catlin & Varon, P.A.

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…

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Motion for Reduction of Bond

By Fallgatter Catlin & Varon, P.A.

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 reduce bond and grant bail in the above-styled cause. As grounds therefore, the Defendant states…

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Motion to Supress Searches & Seizures – Return of Property

By Fallgatter Catlin & Varon, P.A.

MOTION TO SUPPRESS SEARCHES AND SEIZURES AND MOTION FOR RETURN OF PROPERTY Defendants (“D. Defendants”), by and through their undersigned counsel, hereby move to suppress evidence obtained from any/all searches and seizures in this case, and in support thereof, state as follows: TABLE OF CONTENTS Topic Page A. Introduction 2…

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