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'.
FEDERAL COURT MOTIONS
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
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