Motions & Briefs

Below are numerous examples of criminal motions and briefs in various state courts throughout Texas and many federal jurisdictions.

At Broden & Mickelsen, LLP, we take pride in our knowledge of the law, and our written work helps share this knowledge. We believe our written work sets us apart from most criminal lawyers and proudly make many of our motions and legal pleadings available for potential clients to review and for other lawyers to use.

You may download any brief by right-clicking on the following links.

Practice Materials

• Fifth Amendment Issues
• Defending an Obscenity Claim
• Paper on Detention Hearings and Probable Cause Hearings in Federal Court
• Motion to Return Property Rule 41(g)

Federal Pretrial Materials

• Motion to Revoke Detention Order
• Ex Parte Motion for Authorization to Retain Expert
• Federal Case Checklist For Attorneys
• Sample Discovery Request Letter
• Sample Federal Trial Brief in Fraud Case

Federal Court Motions

Dismissal Motions

• Motion to Dismiss for Deportation of Witnesses
• Motion to Dismiss as Multiplicitous
• Motion To Dismiss For Speedy Trial Act Violation

Suppression Motions

• Motion to Suppress Bus Terminal Search
• Motion to Suppress Stale Warrant
• Motion to Suppress Stale and Overbroad Warrant
• Request For Trial Witness’s PSR
• Motion to Suppress (Lack Of Consent To Search)
• Motion to Suppress Statements Taken in Violation of Miranda

Other Motions

• Motion for Judgment of Acquittal (Tax Fraud)
• Addendum to Motion to Withdraw Plea
• Motion to Sever Gun Count
• Motion to Disqualify District Judge
• Supplemental Memorandum in Support of Motion to Withdraw Plea
• Motion to Withdraw Guilty Plea
• Motion for a Bill of Particulars
• Hyde Amendment Motion for Reimbursement of Attorney Fees
• New Trial Motion (Issues: 404(B); Incredible Informant)
• Declaration Necessary to Subpoena Department of Justice Employee
• Ex Parte Subpoena Request
• Motion to Terminate Supervised Release
• Sample Motion In Limine Federal Court
• Motion for Release Pending Appeal
• Motion in Sex Offender Notification and Registration (SORNA) case.

State Court Motions

• Motion to Obtain Court-Appointed Expert in Retained Case
• Request for Taint Hearing In Child Sexual Assault Case
• Motion In Limine Regarding Allowable Testimony in Child Sexual Assault Case
• Motion Regarding Defense Expert in Child Sexual Assault Case
• Motion on the Abel Assessment
• Double Jeopardy Motion
• Motion to Exclude Evidence in DWI Case
• Request for Fair Cross Section Jury in Dallas
• Memorandum Regarding Fair Cross Section Jury in Dallas
• Motion to Identify Hidden Discovery
• Motion to Allow Jury Questionnaire
• Motion to Disqualify District Attorney
• Motion for Change of Venue
• Motion for New Trial-Jury Misconduct; Attorney Conflict of Interest
• Motion to Hold District Attorney in Contempt
• Sample Motion In Limine State Court
• Sample Public Information Act Request
• Motion to Recuse Trial Judge
• Motion for Free Appellate Transcript
• Sample Jury Questionnaire (Murder Case)
• Sample Jury Questionnaire (Sex Assault Case)

Federal Sentencing Materials

• Sample Objections to Pre-sentence Report
• Sentencing Memo in Child Pornography Case (Client With Asperger’s Syndrome)
• Sentencing Memorandum – Pornography Case
• Sentencing Memorandum
• Objections to PSR in Environmental Fraud Case

Criminal Appeals

Federal Criminal Appeals

• Appellate Brief: Money Laundering
• Appellate Brief: Right to Counsel
• Appellate Brief: Bank Fraud Case
• Motion for Free Transcript on Appeal
• Appellate Brief: Suppression Based Upon Lack Of Consent To Search And Illegal Arrest
• Federal Court Writ of Mandamus
• Appellate Brief: Failure to Grant Continuance; Improper Closing Argument
• Appellate Brief-Wire Tap Issues; Interpreting Drug Codes

Texas Criminal Appeals

• Appellate Brief: Child Sexual Assault Case
• Appellate Brief: Failure to Elect in a Sexual Assault Case
• Appellate Brief: Dallas Fake Drug Case
• Appellate Brief-First Amendment Issue
• Motion for Free Appellate Transcript

Post-Conviction Relief

Federal Court

• Memorandum of Law in Support of Movant’s Petition Under 28 U.S.C. 2255: Failure to File Suppression Motion
• Memorandum of Law in Support of Movant’s Petition Under 28 U.S.C. 2255: Ineffective Assistance in Child Pornography Case
• Petition For Writ Of Certiorari in Death Penalty Case
• Memorandum of Law in Support of Movant’s Petition Under 28 U.S.C. 2255: Ineffective Assistance of Counsel; Improper Jury Instructions; Witness Perjury

State Court

• State Habeas Petition Based Upon Ineffective Assistance of Counsel
• State Habeas Petition Based Upon Actual Innocence Due to Recanting Witness
• State Habeas Petition Based Upon Misadvice From Attorney