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These motions are provide to assist legal professionals in the defense of their clients and for the informational purposes of the public. Nothing in these motions is intended to be legal advice.


Criminal Motions Brief Bank

Motion for Bond Reduction on Felony Charge.
Felony Bond Reduction Motion

Response to State's Motion for Increase in Felony Bond
Defense Response to State's Request to Increase Defendant's Felony Bond
Discovery Request for Preiminary Hearing Discovery.
Prelim Discovery Request

Demurrer to Information for failure to plead essential elements.
Demurrer to Information

Motion challenging the state’s use of the multi-county grand jury to investigate crime that occurred in single county. Motion to Supress Grand Jury Evidence; Defense Reply to State's Response to Motion to Supress Grand Jury Evidence . Defense Reply to States Response

Motion to Stop Illegal State Grand Jury investigation, because the state of Oklahoma is using Multi-county grand jury to investigate alleged crime that occurd in single county . Motion to stop Illegal Grand Jury Investigation
Application to Determine Defendant's Competency.
Application to Determine Defendant's Competency
Motion for Transcripts at State Expense for an Indigent Defendant.
Motion for Transcripts
Motion in Limine to Exclude Evidence of Prior Bad Acts.
Motion in Limine--Bad Acts
Motion for Evidentary Hearing to Determine Expert Witness Testimony Admissibility.
Motion for Daubert Hearing
Motion to Quash bind over order in accordance with Title 22 O.S. section 504.1.
Quash Motion

Motion to Preclude the state from conducting unduley suggestive physical line-up.Motion to Prohibit Unduley Suggestive Line-up

Motion to Pay Attorney's Fees in Accordance with State v. Lynch.
Attorney's Fees Motion

Notice of Intent to Introduce Alibi
Alibi Evidence Motion
Petition for Writ of Habeas Corpus to have an incustody witness to testify. Petition for Writ of Habeas. Writ of Habeas Corpus to have an incustody witness to testify. Writ of Habeas.
Motion to Exclude Testimony of Jailhouse Informants for failure to make proper disclosures. Motion to Exclude

Subpoena for 911 Tapes from Tulsa Police Department
TPD 911 Subpoena

Motion to Supress Evidence Derived from the Illegal Siezure of Attorney-Client Communications. Motion to Supress
Motion for production of DHS Records. Motion for DHS Records.
Order for production of DHS records. DHS production Order.

Motion to Exclude Out of Court Statements of Co-Defendant or in the alternative Motion for Severance. Motion to Exclude Co-Defendant Statements/Motion for Severance
Motion to Supress based upon United States v. Kastigar . This is a motion to supress adressing a very unique issue. In this case my client Gordon Todd Skinner had been previously granted immunity by the Department of Justice and provided information to the government pursuant to the immunity agreement. The government then turned around and used that information against him. Kastigar Motion I have also included my Supplemental Kastigar Motion filed after the Court granted an evidentary hearing on the issue.
Waiver of Speedy Trial under the Interstate Detainers Act. Speedy Trial Waiver
To appeal a conviction at a jury trial or a bench trial a Notice of Intent to Appeal must be filed within 10 days of the sentencing date. Included is an example of a Notice of Intent to Appeal. The blank form can also be located on the Oklahoma Court of Criminal Appeals website by clicking here.
When an appeal is filed, if the trial attorney is not handling the appeal, he is required to file an Advisory Proposition of Errors for the Appellate attorney. Included is an example of an Advisory Proposition of Errors that I filed in a case.
When an appeal is filed along with the Notice of Intent to Appeal is filed the trial attorney is also required to file a Designation of Record. Listed below is an example of a Designation of Record I filed in a case.
Motion to Expunge Criminal Record. Petition for Expungment. Order Expunging Record.
Motion to Dismiss/Demurrer filed in a case in which a client was charged with violating Title 21 O.S. 1171. With this motion Kevin Adams was able to convince a Tulsa County Judge that it did not violate Oklahoma law to secretly video tape "up the skirt" of a woman while she was located in a local store. (Motion to Dismiss/Demurrer in Microsft Word)
"How to Writ the Trial Court" CLE materials written by John Echols. Petition for Writ of Prohibition (PDF) dealing with the issue of punishment range for simple possession of marijuana.
Motion to Clarify the appropriate sentencing range for simple possession of marijuana.

Motion for New Trial in accordance with Title 22 O.S. § 952 based upon the Tulsa County District Attorney's office use of its  peremptory challenges in a racially discriminatory manner, the trial court's improper denial of the defendant's demurer and the defendant being denied a fair trial because she is entitled to a fair and impartial trial judge.

10th Circuit Appeal Brief in United States of America v. Melvin Bailey, Jr. The appeal challenges the denial of the motion to suppress at the trial level, improper admission of the testimony of officer Jeff Henderson and prosecutorial misconduct for threatening to prosecute a defense witness.

10th Circuit Appeal Brief in the United States of America v. DeMarco Williams arguing that the trial court denied Williams the ability to make a meaningful challenge to the search warrant and his ability to effectively cross-examine Tulsa Police Officer Jeff Henderson by denying him access to and the ability to introduce impeachment material to which he was Constitutionally entitled. The appeal was denied but it is a good brief.

A winning Motion to Supress the fruits of a search warrant based upon Franks v. Delaware. You can also read the Order. This motion District of Oklahoma.
A winning Motion to Suppress Defendant's Statements obtained without advising the Defendant of her Miranda Rights. This motion was filed in Federal Court for the Northern District of Oklahoma.

Oklahoma Criminal Law and Civil Rights Blog

 

Copyright ©2009 Kevin D. Adams

Disclaimer: Kevin D. Adams only provides legal advice after having entered into an attorney client relationship, which this website specifically does not create. Only after having entered into a representation agreement with Kevin D. Adams will an attorney-client relationship have been created. It is imperative that any action taken by you should be done on advice of legal counsel.* Because every case is different, the descriptions of outcomes and cases previously handled are not meant to be a guarantee of success.

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Tulsa Criminal Defense Lawyer: Kevin D. Adams

 

 
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