Motions to File As Soon As Client is Charged
Racial Justice Act
- BatsonJustification May 2021
- TopGunBlckOut May 2021
Other Pre-Trial Motions
- GlossipMaterials May 2021
- Motion for Bill of Particulars May 2021
- Motion for Continuance May 2021
- Motion for Disclosure of Aggravating Circumstances May 2021
- Motion for Disclosure of Identification Procedures May 2021
- Motion for Disclosure of State’s Theory of Acting-in-Concert May 2021
- Motion for Discovery Pusuant to N.C. Gen. Stat. 15A-903 May 2021
- Motion for Pre-Trial Hearing to Determine that Defendant is Mentally Retarded May 2021
- Motion for Production of Exculpatory Information May 2021
- Motion for Separate Juries May 2021
- Motion for Separate Trial May 2021
- Motion in Limine Unrecorded Statements of Defendant May 2021
- Motion to Compel Investigating Officers to Turn Over All Information Related to the Investigation of this Case to Prosecutors May 2021
- Motion to Compel State to Disclose Felonies It Intends to Use to Support Felony-Murder Theory May 2021
- Motion to Compel State to Disclose Theory Upon Which It Seeks a Conviction of First Degree Murder May 2021
- Motion to Disclose Penalty Phase Information May 2021
- Motion to Memorialize Discovery Provided by the Prosecutor Pursuant to an Open File Policy May 2021
- Motion to Obtain Mental Health Records May 2021
- Motion to Prevent the State from Seeking the Death Penalty and Objections to this Court Declaring this Case Capital May 2021
- Motion to Prohibit a Death Sentence Based on the International Covenant on Civil and Political Rights and Customary International Law May 2021
- Motion to Reveal Deals or Concessions May 2021
- MotionDetermineIntellDisability May 2021
- MotionToDeclareDPUnconst May 2021
- Request for Discovery May 2021
- Strike DP SMI Sample May 2021
Guilt Phase
- Motion for Complete Recordation of All Proceedings May 2021
- Motion for Court to Note the Race of Every Potential Juror Examined in This Case May 2021
- Motion for Individual Voir Dire on Sensitive Subjects May 2021
- Motion for Pre-Selection Instructions to Potential Jurors May 2021
- Motion In Limine to Limit Testimony of Statements of Defendant May 2021
- Motion in Limine to Prohibit Reference to Defendant’s Silence May 2021
- Motion to Allow Defense Counsel to Distribute a questionnaire to Potential Jurors May 2021
- Motion to Allow Defense Counsel to Question any Potential Jurors Challenged for Cause by the Prosecutor Based on Opposition to the Death Penalty May 2021
- Motion to Bar the State from Presenting Inconsistent Theories of Prosecution May 2021
- Motion to Exclude Photographs May 2021
- Motion to Exclude Still Photographers, TV Cameras and Microphones from the Courtroom May 2021
- Motion to Preclude Death Penalty May 2021
- Motion to Preclude Leading Questions and Conclusory Statement on Voir Dire of Prospective Jurors May 2021
- Motion to Prohibit District Attorney from Peremptorily Challenging Prospective Black Jurors May 2021
- Motion to Prohibit Prosecutor from Telling the Jury that Mitigating Factors are Things that Reduce the Severity of the Crime May 2021
- Motion to Require Sequestration of State’s Witnesses May 2021
- Request for Special Instruction on the Highest Aim of Every Criminal Trial May 2021
Additional Guilt Phase Materials
- JURY SELECTION QUESTIONS May 2021
- MEMORANDUM RE JURY VOIR DIRE May 2021
Beginning of Sentencing Phase
Penalty Phase Instructions Requests
- Discretion in Capital Sentencing Instructions May 2021
- Jury Instructions. Penalty Phase Revised 3-2000 Version May 2021
- Motion for Court to Give Understandable Jury Instructions May 2021
- Motion for Jury Instruction under Enmund v. Florida and Tison v. Arizona May 2021
- Motion for Peremptory Instructions on Mitigating Circumstances May 2021
- Motion to Instruct Jury On Defendant’s Burden of Proof On Mitigating Circumstances May 2021
- Motion to Instruct Jury on Emotionally Troubled Youth as a Mitigating Circumstance May 2021
- Motion to Instruct Jury on Evidence of Low I.Q. May 2021
- Motion to Instruct Jury on Satisfactory Prison Adjustment May 2021
- Motion to Instruct the Jury on Age as a Statutory Mitigating Factor May 2021
- Motion to Preclude State from Using any Juvenile Conviction as an Aggravating Factor May 2021
- Motion to Restrict Prosecutor’s Argument May 2021
- Objection to Use of NCGS 15A-2000e5 (fairness, double jeopardy, cruel & unusal) May 2021
- Objection to Use of NCGS 15A-2000e9 (vague & broad) May 2021
- Request for Jury Instruction Definition of Mitigating Circumstance May 2021
- Request for Jury Instruction on Personal Viewpoints May 2021
- Request for Jury Instruction Re Sympathy and Mercy May 2021
- Request for Jury Instruction–Life Without Parole (I) May 2021
- Request for Jury Instruction–Life Without Parole (II) May 2021
- Request for Jury Instruction–Residual Doubt May 2021
- Request for Jury Instruction–Residual Mitigating Circumstances May 2021
- Request for Jury Instruction–Vicarious Liability with Regard to N.C. Gen. Stat. 15A-2000(e)(9) May 2021
- Understandable Jury Instructions May 2021