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Oklahoma and Federal Criminal Law Motions Brief Bank

Motion for Bond Reduction on Felony Charge

Defense Response to State's Request to Increase Defendant's Felony Bond

Prelim Discovery Request

Demurrer to Information

Motion to Supress Grand Jury Evidence and Defense Reply to States Response

Motion to stop Illegal Grand Jury Investigation

Application to Determine Defendant's Competency

Motion for Transcripts

Motion in Limine--Bad Acts

Motion for Daubert Hearing

Motion to Quash

Motion to Prohibit Unduley Suggestive Line-up

Attorney's Fees Motion

Alibi Evidence Motion

Petition for Writ of Habeas Ad Testificandum and Writ of Habeas Ad Testificandum.

Motion to Exclude Jailhouse informant's testimony

TPD 911 Subpoena

Motion to Supress Evidence Derived from the Illegal Siezure of Attorney-Client Communications

Motion for DHS Records and DHS production Order.

Motion to Exclude Co-Defendant Statements/Motion for Severance

Kastigar Motion I have also included my Supplemental Kastigar Motion filed after the Court granted an evidentary hearing on the issue.

Speedy Trial Waiver

Notice of Intent to Appeal. The blank form can also be located on the Oklahoma Court of Criminal Appeals website by clicking here.

Advisory Proposition of Errors

Designation of Record

Petition for Expungment and Order Expunging Record

(Motion to Dismiss/Demurrer)

"How to Writ the Trial Court" CLE materials written by John Echols.

Petition for Writ of Prohibition

Motion for New Trial in accordance with Title 22 O.S. § 952 based upon the Tulsa County District Attorney's office use of its  peremptory challenges in a racially discriminatory manner, the trial court's improper denial of the defendant's demurer and the defendant being denied a fair trial because she is entitled to a fair and impartial trial judge.

Appeal Brief in United States of America v. Melvin Bailey, Jr. The appeal challenges the denial of the motion to suppress at the trial level, improper admission of the testimony of officer Jeff Henderson and prosecutorial misconduct for threatening to prosecute a defense witness.

10th Circuit Appeal Brief in the United States of America v. DeMarco Williams arguing that the trial court denied Williams the ability to make a meaningful challenge to the search warrant and his ability to effectively cross-examine Tulsa Police Officer Jeff Henderson by denying him access to and the ability to introduce impeachment material to which he was Constitutionally entitled. The appeal was denied but it is a good brief.

A winning Motion to Supress the fruits of a search warrant based upon Franks v. Delaware. You can also read the Order. This motion District of Oklahoma.

A winning Motion to Suppress Defendant's Statements obtained without advising the Defendant of her Miranda Rights. This motion was filed in Federal Court for the Northern District of Oklahoma.

A winning Motion to Arrest Judgement used to set aside a jury verdict.

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I try to respond to all inquires as quickly as possible. If you need immediate assistance you can call my office (918) 582-1313. If you are in need of emergency assistance feel free to call my cell phone anytime either day or night.