Appendices
Early Steps in the Case
- General Release
- Memorandum in Support of Defendant's Motion to Compel Production of Grand Jury Transcript
- Motion for in camera Inspection and Disclosure of Identity of Confidential Informants
- Memorandum of Law in Support of Motion for in camera Inspection and Disclosure of Identity of Confidential Informants
- Motion for in camera Inspection of Police Investigation and Personnel Records
- Brief in Support of Motion for in camera Inspection of Police Investigation and Personnel Records
- Discovery Demand [State Court]
- Discovery Demand [Federal Court]
- Motion to Compel Discovery - Items Not Provided by Prosecutor [Federal Court]
- Subpoena duces tecum - Police Policies and Practices
- Motion to Release Records from Juvenile File (Bellows)
- Motion for in camera Review of Confidential Records (Psych. Treatment)
Motion Practice
Home Searches
- Motion to Suppress Seized Evidence - Unlawful Entry onto Protected Curtilage
- Motion to Suppress Evidence - Affidavit in Support of Search Warrant Lacks Probable Cause
- Memorandum of Law in Support of Motion to Suppress Evidence - Affidavit in Support of Warrant Lacks Probable Cause
- Motion to Suppress: No Consent
- Motion to Suppress: No Consent; Coercion
- Motion to Suppress: No Consent; Apparent Authority
- Brief in Support of Motion to Suppress: No Consent; Apparent Authority
- Motion to Suppress: Warrantless Search; Georgia v. Randolph
- Motion to Suppress: Search Incident to Arrest; Protective Sweep
- Motion to Suppress: Search of Hotel Room; No Exigent Circumstances
Arrests, Stops and Seizures
- Motion to Suppress - No Probable Cause to Arrest
- Motion to Suppress - Unlawful Pat Down
- Motion to Suppress - No Reasonable Suspicion for Stop or Pat Down
- ACLU (New Jersey) Amicus Brief re: Reasonable Suspicion, Race, Implicit Bias
- ACLU (New Jersey) Amicus Brief re: Reasonable Suspicion, "High Crime" Area, "Reasonable Person" Standard
Motor Vehicle Searches
- Motion To Suppress Evidence Seized Following Stop for Minor Non-Moving Violation and Prolonged Detention
- Motion To Suppress: No Reasonable Suspicion for Search of Person or Vehicle (Terry Search)
- Motion To Suppress: Unlawful Search of Car Incident to Arrest (Gant)
- Motion To Suppress: Prolonged Detention, Unlawful Seizure and Search of Car - Dog Sniff
- Motion To Suppress: Unlawful Roadblock
- Motion To Suppress: Unlawful Inventory Search of Car
- Motion to Suppress - Raw Marijuana, Dog Sniff, Extended Detention
- Motion to Suppress - Raw Marijuana, Dog Sniff, Extended Detention
"Special Needs" Searches and Other Searches
Searches of Electronic Devices
- Motion to Suppress - Staleness, Particularity; Franks Motion
- Motion to Suppress Evidence From Facebook
- Motion to Compel Discovery of Use of Cell Phone Tracking Device (Stingray)
- Motion to Exclude Cell Phone Evidence (Warrantless Search - Riley)
- Motion to Suppress - Evidence Obtained Pursuant to "Geofence" General Warrant
- Motion to Compel Discovery of Computer Programming Code (NIT case)
Suppressing Involuntary Confessions
Search and seizure of electronic devices