Motion written after a juvenile was brought into a locked courtroom in shackles based on "policy."…more
In the Matter of Odd Duck
This past week, I've had to crank out three motions under quite tight timeframes resulting in my pulling not one, but TWO "all-nighters" (thankfully, not in a row).
This brief demonstrates what my work looks like under…more
A Not Very Nice Guy v. A Nice Lady
This is different from my normal submissions. I was hired by an attorney to write a Reply to a Response that had been filed on a Motion for Attorney Fees and Costs.
It's also different in that this Reply ended up not being…more
In a regular courtroom when the defense makes an objection, there is the potential for "argument" on the issue. The defense may explain the basis for his objection. The prosecutor will argue for why the objection should be…more
After losing in the trial court on the motion for unmonitored contact visits, I filed a Petition for Peremptory Writ of Mandate and Request for Immediate Stay in the Fifth Appellate District Court.
The postcard denial which…more
This is the Declaration in Support of Motion for Unmonitored Contact Visits which was filed with the Motion…more
While admitted to jail to visit my client, I noted that the room contained an intercom. There was no way to know if anyone was listening on the intercom. I felt that to honor my duty of confidentiality under California Rules…more
This is a motion I wrote while assisting attorney Erin Ormonde in a trial for home invasion robbery in Fresno, California. While she was busy at trial adapting to the shifting sands of various inconsistent rulings, I often left…more
Once in awhile, I get involved in a case where the procedures and rulings of the court just about drive me over the edge. I will occasionally write a motion which, based on the prior rulings, I know is nearly certainly going to…more
While awaiting my bar results, I was approached by the family of a man charged with a gang murder. It was a death penalty case at the time, but I had reason to believe the DA's office would soon take death off the table. (They…more
While still a student, I "sat second chair" on a special circumstances murder case. My job was to keep out prejudicial gang evidence. Along the way, I wrote and argued several motions, conducted an Evidence Code section 402…more
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