Form 22: Notice of Pretrial Motions

• Library: Criminal Law Forms (ABA) (2013 Ed.)

Form 22: Notice of Pretrial Motions

KENNETH VERCAMMEN
& ASSOCIATES, PC
2053 Wood bridge Ave.
Edison, NJ 08817
(Phone) 732-572-0500
Attorney for d1

THE STATE OF NEW JERSEY

vs

d1 Defendant

MUNICIPAL COURT OF ___ COUNTY OF MIDDLESEX

SUMMONS NO.
NOTICE OF Pretrial Motions CDS

PLEASE TAKE NOTICE that on __________ or as soon thereafter as counsel may be heard, the undersigned, counsel for the defendant d1, will move before the above court, for an order on the attached Motions.

BY: KENNETH A. VERCAMMEN, ESQ.

TABLE OF CONTENTS

Appearance and Arraignment Waiver General Provisions Pretrial Motions

1) Suppress Evidence
2) Miranda/Privilege
3) Exclude Lab Tests
4) Discovery
5) Reciprocal Discovery
6) Speedy Trial
7) Notice of Objection to Lab Reports
8) Jury Trial
9) Punishment
10) Vagueness

APPEARANCE AND ARRAIGNMENT WAIVED

PRETRIAL MOTIONS

At a time to be set by the Court, Defendant will move for Orders pursuant to R. 3:105, 3:131, and 7:7-7, as follows and requests oral argument pursuant to R. 1:62(d) to preserve all of defendant's rights and defenses:

1) Suppress Evidence. Defendant will move to suppress, evidence obtained by the State during its investigation of case, pursuant to R. 3:57 and 7:5-2, because evidenceie defendant's person, breath, blood, and/or other thingswas seized unlawfully, without a warrant and contrary to U.S. Const. Amends. IV and XIV and N.J. Const. Art.1, para.7. Defendant believes the State will use this evidence in proceedings before this Court on the above captioned charges.

2) Miranda/Privilege. Defendant will move to exclude statements by, and evidence obtained from, Defendant during the...