Appeal Briefs

• Amended Initial Brief – Stalking #2

• Answer Brief – Counterfeit Identification Card

• Answer Brief of Appellee – Driving Under The Influence

• Initial Brief – Violation of Injunction for Protection against Domestic Violence

• Initial Brief Final – Murder

• Recollection of Events

• Reply Brief – Child Pornography

• Reply Brief – Free Speech

• Reply Brief – Youth Offender

• Reply Brief of Appellant

Juvenile Resentencing

• Motion To Correct Illegal Sentence

• Motion To Declare Florida State Unconstitutional

Miscellaneous Criminal Defense Motions

• Memorandum of Law – Burglary

• Motion for Leave to Take Deposition – DUI

• Motion for Reduction of Bond

• Motion to Confirm Defendant May Live with Parents

• Motion to Exclude Williams Rule Evidence

• Motion To Modify Conditions of Release

• Motion To Permit Character Evidence

• Motion to Recuse Judge

• Motion to Set and Reduce Bond

• Motion to Set Bond

• Motion to Supress Searches & Seizures – Return of Property

• Motion to Take Depositions

• Petition for Writ of Certiorari

• Renewed Motions To Take Depositions

Motions for Discovery

• Motion for Discovery

• Motion to Compel Discovery – Jail Video

Motions to Dismiss

• Amended Initial Brief – Stalking #1

• Arrest on Wrong Statute

• Double Jeopardy and Multiplicity

• Failure to Seek Medical Care

• Motion to Dismiss

• Motion To Dismiss – BOLEO

• Motion to Dismiss – Factually Innocent

• Motion to Dismiss – Identity

• Motion To Dismiss – Injunction

• Motion To Dismiss – Jurisdiction and Statute of Limitations

• Motion to Dismiss – Mortgage Fraud

• Motion to Dismiss – Pre-Indictment Delay & Absence of Allegation

• Motion to Dismiss – Traffic Citation

• Motion to Dismiss – Traffic Infraction

• Second Motion To Dismiss

Motions to Release

• Motion to Release Pending Appeal

Motions to Strike

• Motion to Strike – Restitution Claims

• Motion to Strike and Dismiss

• Motion to Strike and Supplement to Motion In Limine and Incorporated Memorandum of Law

• Motion to Strike State’s Witness

• Motion to Strike Traverse and For Hearing On Demurrer

Motions to Suppress Evidence

• Motion to Exclude Blood Analysis Results

• Motion To Exclude Retrograde

• Motion to Reconsider – Child Pornography

• Motion to Suppress – Bad Stop

• Motion To Suppress – Dog Sniff

• Motion to Suppress – DUI – Actual Physical Control

• Motion to Suppress – DUI – Recollection of Incident

• Motion to Suppress – DUI – Unlawful Detention

• Motion to Suppress – Field Sobriety Test

• Motion To Suppress – Search and Bad Stop

• Motion to Suppress & Memorandum of Law – DUI

• Motion to Suppress Digital Media

• Motion to Suppress Evidence – All Evidence Seized & Obtained

• Motion to Suppress Evidence – Controlled Calls

• Motion to Suppress Evidence – Possession of Cocaine

Motions to Suppress Statements

• Suppress Statements – Illegally Obtained Statements

• Suppress Statements: Illegal Confession

Motions to Withdraw

• Motion to Withdraw, Set Aside, and/or Vacate Plea and Judgment

• Vacate Plea and Judgment

• Withdraw Plea- Challenge Illegal Search

Pre-Trial Motions

• Motion in Limine – Hearsay Statements

• Motion to Compel Statement of Particulars for Sanctions & Strike & Dismiss

• Motion to Reinstate Pretrial Conditions

Post-Trial Motions

• Motion for Order for Rule to Show Cause

• Motion for Return of Property

• Post Hearing Memorandum of Law