| 2255 Petitions |
2255 Procedural Default Sample Reply Descamps ACCA (D. Md. 2014) |
| 2255(h)(2) Descamps Successive Brief (4th Cir. 2013) |
| More 2255 Petitions... |
| Appeals |
Petition for Writ of Certiorari Booker (2012) |
| Petition for Writ of Certiorari Retroactive Guideline Amendments (2012) |
| More Appeals... |
| Bill of Particulars |
Bill of Particulars Firearm Possession Motion (D. Idaho 2004) |
| Competency |
Release Defendant from 18 USC § 4243 Care Order (D. Kansas 2009) |
| Competency Hearing Transcript BOP Psychologist Christina Pietz (D. Mont. 2009) |
| More Competency... |
| Conflicts and Withdraw |
Withdraw Conflict Ex Parte Affidavit (D. Idaho 2004) (redacted) |
| Withdraw Conflict Motion (D. Idaho 2004) (redacted) |
| Continuance |
Speedy Trial Objection Motion & Memo (D. Idaho 2000) |
| Extend Time to File Sentencing Brief Motion & Memo to (N.D. Ill.) |
| Continue & Declare Complex Drug Conspiracy Motion (W.D. Wash. 2012) |
| Discovery, Disclosures, Evidence |
Require Subpoena Compliance Phone Records Affidavit and Proposed Order (D. Idaho 2004) |
| Require Subpoena Compliance Phone Records Ex Parte Motion (D. Idaho 2004) |
| More Discovery, Disclosures, Evidence... |
| Dismissal |
Restraining Order Due Process Violation Memo 18 USC 922(g)(8) (D. Idaho 2006) |
| Deportation Due Process Violation Group Hearing Memo 8 USC 1326 (E.D. Wash. 2010) |
| More Dismissal... |
| Evidence and Motions in Limine |
Daubert DNA Expert Motion (D. Idaho 2001) |
| Exclude Post-Offense Conduct 404(b) Deprivation of Rights Response (D. Idaho 2001) |
| More Evidence and Motions in Limine... |
| Experts and CJA Funds |
Expert Fees Forensic Accountant Ex Parte Application, Motion, Affidavit, and Proposed Order (D. Idaho) |
| Expert Services and Costs Ex Parte Motion (D. Idaho) |
| More Experts and CJA Funds... |
| Jury Instructions |
Entrapment Drug Conspiracy Defense Proposed Jury Instruction (D. Idaho 2002) |
| Possession of Unregistered Machine Gun Defense Proposed Jury Instructions (D. Idaho 2005) |
| More Jury Instructions... |
| Jury Trials |
Request for Jury Trial for Petty Offense Memo (D. Idaho 2004) |
| Acquittal or New Trial Possession of Unregistered Machine Gun Memo (D. Idaho 2006) |
| More Jury Trials... |
| Pretrial Motions |
Refuse DNA Sample and Foreign Order Defense Brief Addendum (D. Idaho 2006) (redacted) |
| Pretrial Substance Abuse Treatment Motion (D. Idaho 2005) (redacted) |
| More Pretrial Motions... |
| Restitution and Forfeiture |
Waive Restitution Interest Motion (D. Idaho 2008) |
| Forfeiture of IRA Avoiding Penalty IRS Private Letter Ruling (IRS 2004) |
| Sentencing |
Reasonable Doubt for Supervised Release Revocation (D. Idaho 2005) |
| Standard of Proof Sentencing Enhancements and Apprendi PSR Objections (D. Idaho 2000) |
| More Sentencing... |
| Severance |
Sever Charges for Prejudice, Felon in Possession, Alien in Possession, Illegal Reentry, Memo (D. Idaho 2005) (redacted) |
| Sever Charges Felon in Possession and Offer to Stipulate to Prior Conviction Memo (D. Idaho 2007) |
| More Severance... |
| Spanish |
2255 Form English-Spanish |
| 2255 IFP application |
| More Spanish... |
| Subpoenas |
Subpoena Federal Law Enforcement Agent 28 CFR 16.23(c) Notice (D. Idaho 2004) |
| Subpoena Federal Law Enforcement Agent 28 CFR 16.23(c) Affidavit (D. Idaho 2004) |
| More Subpoenas... |
| Supervised Release and Probation |
Early Termination of Probation Memo (D. Idaho 2005) |
| Early Termination of Supervised Release Wrongful Denial of RDAP Early Release Memo (D. Idaho 2003) |
| More Supervised Release and Probation... |
| Suppression |
Inventory Search 4th Amendment Memo (D. Idaho 2000) |
| Dog Alert Automobile Search 4th Amendment Memo (D. Idaho 2007) (redacted) |
| More Suppression... |
| Voir Dire |
Proposed Voir Dire Race and National Origin, Drugs, Eyewitness Identification (E.D. Wash.) |
