Motions & Briefs
Below are numerous examples of criminal briefs in various state courts throughout Texas as well as many federal jurisdictions. At Broden and Mickelsen, we take pride in our knowledge of the law and our written work product. We believe our written work product sets us apart from most lawyers and proudly make many of our motions available for potential clients to review and for other lawyers to use.
You may view each brief either as a web page or you may download it by right-clicking on 'PDF'.
PRACTICE MATERIALS
Defending an Obscenity Claim • PDF
Paper on Detention Hearings and Probable Cause Hearings in Federal Court•
Motion to Revoke Detention Order (2005) • PDF
Ex Parte Motion for Authorization to Retain Expert (2003) • PDF
Federal Case Checklist For Attorneys • PDF
DISMISSAL MOTIONS
Motion to Dismiss for Deportation of Witnesses (2002) • PDF
Motion to Dismiss as Multiplicitous (2002) • PDF
Motion To Dismiss For Speedy Trial Act Violation (1993) • PDF
SUPPRESSION MOTIONS
Motion to Suppress Stale Warrant (2005) • PDF
Motion to Suppress Stale and Overbroad Warrant (2002) • PDF
Request For Trial Witness's PSR (1999) • PDF
Motion To Suppress Based Upon False Affidavit By Dallas Police Officer (1992) • PDF
Motion to Suppress (Lack Of Consent To Search) (1994) • PDF
OTHER MOTIONS
Motion for Judgment of Acquittal (Tax Fraud) (2005) • PDF
Motion to Withdraw Plea (2005) • PDF
Motion to Sever Gun Count (2005) • PDF
Motion to Disqualify District Judge (2005) • PDF
Motion to Withdraw Plea (2003) • PDF
Motion for a Bill of Particulars (2003) • PDF
Hyde Amendment Motion for Reimbursement of Attorney Fees (2000) • PDF
New Trial Motion (Issues: 404(B); Incredible Informant) (1997) • PDF
Declaration Necessary to Subpoena Department of Justice Employee (2000) • PDF
Request for Taint Hearing In Child Sexual Assault Case (2007) • PDF
Motion In Limine Regarding Allowable Testimony in Child Sexual Assault Case (2007) • PDF
Motion Regarding Defense Expert in Child Sexual Assault Case (2007) • PDF
Motion on the Abel Assessment (2007) • PDF
Double Jeopardy Motion (2006) • PDF
Motion to Exclude Evidence in DWI Case (2005) • PDF
Request for Fair Cross Section Jury in Dallas (2000) • PDF
Memorandum Regarding Fair Cross Section Jury in Dallas (2000) • PDF
Sample Character Letter to be Used in Connection with a Federal Sentencing • PDF
Sample Objections to Presentence Report • PDF
Sentencing Memorandum in Child Pornography Case (2008) • PDF
Sentencing Memorandum (2007) • PDF
Objections to PSR in Environmental Fraud Case (2007) • PDF
Motion For A Downward Departure (Overrepresented Criminal History/Diminished Capacity) (1996) • PDF
Motion For A Downward Departure (Overrepresented Criminal History) (1999) • PDF
Motion For A Downward Departure (Medical Condition/Age) (1995) • PDF
Motion For A Downward Departure (Lesser Harms) (1994) • PDF
FEDERAL APPEALS
Appellate Brief: Right to Counsel (2007) • PDF
Appellate Brief: Bank Fraud Case (2005) • PDF
Motion for Free Transcript on Appeal (2005) • PDF
Appellate Brief: Suppression Based Upon Lack Of Consent To Search And Illegal Arrest (1994) • PDF
Federal Court Writ of Mandamus (1994) • PDF
Appellate Brief: Failure to Grant Continuance; Improper Closing Argument (2003) • PDF
STATE APPEALS
Appellate Brief: Failure to Elect in a Sexual Assault Case (2004) • PDF
FEDERAL COURT
Memorandum of Law in Support of Movant's Petition Under 28 U.S.C. 2255: Failure to File Suppression Motion (2006) • PDF
Petition For Writ Of Certiorari in Death Penalty Case (2005) • PDF
Memorandum of Law in Support of Movant's Petition Under 28 U.S.C. 2255:Ineffective Assistance of Counsel; Improper Jury Instructions; Witness Perjury (2002) • PDF
STATE COURT
State Habeas Petition Based Upon Actual Innocence Due to Recanting Witness (2007) • PDF
State Habeas Petition Based Upon Misadvice From Attorney (2007) • PDF
State Habeas Corpus Petition in Death Penalty Case Based Upon a Claim of Mental Retardation (2003) • PDF
