The pleadings listed below are provided for the $150 per
case charge, when you provide the information requested in
the PDF
Pleading Request.
If I am providing the case set for the criminal case, a
DMV set is $25.00 additional.
Every Criminal
Case
Case Template (Caption w/
Certificate of Service) in Word™
Entry of Appearance (with or
without Plea or PH Demand)
Motion for Expert Discovery (w/
Order)
Motion In Limine With Respect
To The Testimony Of Prosecution Witnesses With
Respect To Specialized Training And Experience
Motion to Suppress (Fourth
Amendment)
Motion to Suppress Statements
Motion With Respect To The Use
Of Demonstrative Exhibits At Trial
Notice Pursuant to §
16-3-309(5), Colorado Revised Statutes
Request for Notice of Judicial
Notice
Request pursuant to Rule
404(b), Colorado
Rules of Evidence
DUI Blood (In
Addition to the Pleadings shown above for every case)
Motion To Bar Expert
Designation Based Upon Standardized Field Sobriety
Test Training Or Drug Recognition Expert Training
Motion To Declare §
42-4-1301(6)(F), Colorado Revised Statutes 2014,Unconstitutional
As A Violation Of Defendant’s Right To Due Process
Of Law Pursuant To The Fourteenth Amendment To The
Constitution Of The United States And Article Ii,
Section 25, Constitution Of Colorado
Notice Of Trial Efficiency –
Trial May Take Two Or More Days
Notice With Respect To
Discovery Pursuant To Rule 16(I)(A)(1)(Iv),
Colorado Rules Of Criminal Procedure, And
Defendant’s Invocation Of The Fifth Amendment
Objection To The Use Of
Testimonial Hearsay At Trial
DUI Breath (In Addition to the
Pleadings shown above for every case)
Motion To Bar Expert
Designation Based Upon Standardized Field Sobriety
Test Training Or Drug Recognition Expert Training
Motion To Declare §
42-4-1301(6)(F), Colorado Revised Statutes 2014,
Unconstitutional As A Violation Of Defendant’s
Right To Due Process Of Law Pursuant To The
Fourteenth Amendment To The Constitution Of The
United States And Article Ii, Section 25,
Constitution Of Colorado
Notice Of Trial Efficiency –
Trial May Take Two Or More Days
Notice With Respect To
Discovery Pursuant To Rule 16(I)(A)(1)(Iv),
Colorado Rules Of Criminal Procedure, And
Defendant’s Invocation Of The Fifth Amendment
Objection To The Use Of
Testimonial Hearsay At Trial
Objection,
Pursuant To Rule 702, Colorado Rules of
Evidence, To Expert Testimony Providing
Retrograde Extrapolation From An Intoxilyzer
9000 Result
* By Separate
subscription: Motions Directed to the Use of an
Intoxilyzer 9000 by the People
DUI Refusal (In
Addition to the Pleadings shown above for every case)
Motion To Bar Expert
Designation Based Upon Standardized Field Sobriety
Test Training Or Drug Recognition Expert Training
Motion to Declare §
42-4-1301(6)(d), Colorado Revised Statutes2014,
Unconstitutional
Motion To Declare §
42-4-1301(6)(F), Colorado Revised Statutes 2014,Unconstitutional
As A Violation Of Defendant’s Right To Due Process
Of Law Pursuant To The Fourteenth Amendment To The
Constitution Of The United States And Article II,
Section 25, Constitution Of Colorado
Notice Of Trial Efficiency –
Trial May Take Two Or More Days
Notice With Respect To
Discovery Pursuant To Rule 16(I)(A)(1)(Iv),
Colorado Rules Of Criminal Procedure, And
Defendant’s Invocation Of The Fifth Amendment
Objection To The Use Of
Testimonial Hearsay At Trial
Proposed Jury Instruction on
the Failure of the Officer to Obtain a Search
Warrant
On a case by case basis, pleading support provided
includes all initial notices and case appropriate motions,
including suppression. I will provide this in .doc,
.docx or .pfd, as requested. ($150
per case if you provide the data and are not asking for
case evaluation.)
This service is designed for licensed Colorado Attorneys
only. Pro se defendants, you need an
attorney; you will not be permitted to register to use
this service. You may locate a Qualified Colorado
Criminal Defense Attorney at the Colorado Criminal
Defense Barweb site.
All registrations are confirmed against the Colorado Supreme
Court Attorney Registration database and all pleadings
produced by ColoradoWrits are personalized to the attorney.
