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MyraB
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Category: Criminal Law
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Experience:  I have over 20 years experience in criminal law and civil litigation from pre-trial practice to appeal.
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For Myra B: What do you think of the following response to

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For Myra B: What do you think of the following response to State's response to APCR?

Comes Now the Petitioner, name, and respectfully XXXXX XXXXX court overrule the State’s response to Petitioner’s application for post conviction relief filed in this case on or about July 23, 2013. The State’s response has given no lawful reason why the Petitioner should not be found not guilty or in the alternative given a new trial with marijuana evidence excluded. In support thereof, the Petitioner will show the trial court the following:

The Petitioner will respond to each of the State’s points numbered 1 through 6.
Points 1 and 2 only explain the date of the charge, trial and conviction and sentencing. And the fact that the case was appealed and judgment and sentence was affirmed and after that the Petitioner filed a motion for suspended sentence which was denied. The Petitioner agrees those facts are correct.

(3.) The State says: “ on or about June 26, 2013, Petitioner filed the present application for post-conviction relief. He presents one proposition of error under the claim of ineffective assistance of counsel. The grounds center on the hiring of a toxicology expert...” This part the Petitioner agrees with. The State further claims: ”.. It appears from the face of the application that all of the issues raised are barred by waiver and res judicata and no plain or fundamental error is shown by Petitioner...” The Petitioner responds with the following information to refute this last statement:
Oklahoma Statute Section 1080 of Title 22 - Post-Conviction Procedure Act - Right to Challenge Conviction or Sentence states the following:
Any person who has been convicted of, or sentenced for, a crime and who claims:
(a) that the conviction or the sentence was in violation of the Constitution of the United States or the Constitution or laws of this state;
(b) that the court was without jurisdiction to impose sentence;
(c) that the sentence exceeds the maximum authorized by law;
(d) that there exists evidence of material facts, not previously presented and heard, that requires vacation of the conviction or sentence in the interest of justice;
(e) that his sentence has expired, his suspended sentence, probation, parole, or conditional release unlawfully revoked, or he is otherwise unlawfully held in custody or other restraint; or
(f) that the conviction or sentence is otherwise subject to collateral attack upon any ground of alleged error heretofore available under any common law, statutory or other writ, motion, petition, proceeding or remedy;
may institute a proceeding under this act in the court in which the judgment and sentence on conviction was imposed to secure the appropriate relief. Excluding a timely appeal, this act encompasses and replaces all common law and statutory methods of challenging a conviction or sentence.
The Petitioner’s Application for Post Conviction Relief explained that the Petitioner qualifies for such relief under both (a) and (d) above. It is stated in the Application under part B.” THE PETITIONER’S 6TH AND 14TH AMENDMENT CONSTITUTIONAL RIGHTS HAVE BEEN VIOLATED DUE TO INEFFECTIVE COUNSEL. THIS PROPOSITION ALSO INTRODUCES NEW EVIDENCE RELATED TO INEFFECTIVE COUNSEL THAT INDICATES A MISCARRIAGE OF JUSTICE.”
Ineffective counsel is the one proposition of relief given but the Petitioner gives two reasons for claiming that defense counsel was ineffective and they are 1. Failure to procure or even attempt to procure an expert toxicology witness and 2. Failure to find and use scientific studies and other literatures on driving under the influence of cannabis to counteract the State’s expert toxicologist’s expected testimony. In part of point 3 the State claims “.Petitioner provides no material facts that were not known or available at the time of sentencing...” It appears that the State must not have read the entire petition since pages 7-10 of the petition discusses new evidence in great detail. This new evidence is part of the claim of ineffective counsel as it should have been found by defense counsel.
To further illustrate that ineffective counsel is a valid reason to apply for post conviction relief, the following is Post Conviction Relief case that went to the Oklahoma Court of Criminal Appeals and relief was awarded to the Petitioner. The case is David XXXXX XXXXX v. State of Oklahoma, case number XXXXX A copy of the opinion is attached. (Opinion can also be viewed at the following link:http://www.state.ok.us/~oids/coca/BrownDJ.pdf ) The title of the case is ORDER GRANTING POST-CONVICTION RELIEF AND REMANDING MATTER TO DISTRICT COURT FOR FURTHER PROCEEDINGS. This is a post conviction relief case where the Petitioner argued that he was denied effective trial and appeal counsel and relief was granted.
This petition also claims trial and appeal counsels were ineffective. Therefore all the arguments that this petition has no merit are proven not to be valid by this one case example. Sometimes a single example is worth a thousand words.
As in the above case the proposition of relief has not been reviewed by Oklahoma Court of Criminal Appeals. Ineffective trial counsel could have been brought up by appeal counsel but the Petitioner contends that the defense appeal counsel was also ineffective for not bringing the problem to the attention of the Court even after being brought to the attention of appeal counsel by the Petitioner (see pg 12 of this petition). Therefore the complaints of res judicata and waiver and no new material evidence are not valid in this case. This is the same type of situation as the above case, David XXXXX XXXXX v. State of Oklahoma, case number XXXXX where relief was granted on appeal.


(4.) In point 4 the State says: “In addition to waiver and res judicata grounds, the court should deny relief for lack of merit...” The following is the required merit taken directly from pages 10 -11 of petition:
In reference to an indigent defendant being entitled to an expert witness at the State’s expense Fitzgerald v. State, 1998 OK CR 68, 972 P.2d 1157 states the following:
“...Ake [ v. Oklahoma, 470 U.S. 68, 105 S.Ct. 1087] held that when an indigent defendant makes a preliminary showing that his sanity at the time of the offense is likely to be a significant factor at trial, he is entitled to experts, at the State's expense, who will assist in evaluation, preparation and presentation of the defense. This Court has extended the principles of Ake to any expert necessary for an adequate defense. In doing so, we have emphasized necessity of providing each defendant with the “basic tools” for his defense. This comports with the Legislature's intent that indigent defendants be provided experts, and non-expert assistance, at State expense. In creating the Indigent Defense System, the Legislature has consistently provided that the Executive Director of that System shall approve expert witnesses, and non-expert assistance, when those services are necessary in a particular case...”

In reference to the requirements for the determination if counsel is ineffective, Strickland v.Washington, 466 U.S. 668,XXXXX 2052, 80 L. Ed. 2d 674 (1984) states the following:
“...A convicted defendant's claim that counsel's assistance was so defective as to require reversal of a conviction or setting aside of a death sentence requires that the defendant show, first, that counsel's performance was deficient and, second, that the deficient performance prejudiced the defense so as to deprive the defendant of a fair trial. Pp. 466 U. S. 687-696..”
There is no record to show that Mr filed a motion to continue for time to attain an expert toxicologist or motion for funds for an expert toxicologist although he knew almost from the time he was appointed counsel that an expert toxicologist would be critical for the defense of the Petitioner as demonstrated by his statements in the pretrial meetings. Nor did Mr.file a motion for a Daubert hearing to challenge the scientific basis and methodology of how the prosecution expert arrived at his conclusions nor did he introduce research studies on THC and driving. He even failed to bring the drug court person to counter the expected testimony from the prosecution expert as he said he would do in the pre-trial, pre-hearing meetings with the Petitioner.
The Petitioner contends he has proven, based on the above, the petitioner was deprived of the effective assistance of counsel at pre-trial hearings and trial. Defense counsel's performance was deficient and, that deficient performance prejudiced the defense so as to deprive the defendant of a fair trial. In addition, Petitioner has set forth evidence that disproves the testimony of the prosecution’s expert toxicology witness, sufficient to establish a miscarriage of justice in this case. As such, the Petitioner respectfully request the Trial Court to dismiss this case or in the alternative give him a new trial with the marijuana evidence excluded.


(5.) The State says in point 5: “It is clear from the above language of the United States Supreme Court that Petitioner has the burden of proof on all test and standards when raising an ineffective assistance of counsel claim..”

The Petitioner has proven all test and standards throughout the petition and in this response. The following are a few more quotes from the trial court and State’s counsel at trial, that shows they understood clearly just how prejudicial allowing this marijuana information into trial was to the benefit of the State and to the detriment of the Petitioner.
In discussing whether to allow the marijuana evidence into trial there is some discussion on page 24 of the Motion in Limine hearing Nov 8 2011. The trial court said “ --You know if I say you can’t do it then you—..”
Ms responded with: “ I can tell you my trial strategy is centered around this and it’s going to cause a huge prejudice to me if you make that ruling. So I do kind of need to know.”
On page 25 of the same hearing Ms says in response to Mr requesting to hear proffered testimony from States expert before trial. “Well, I also want to say how this is very prejudicial to the State because we’ve had this trial scheduled for months and months and we’ve been doing a lot of preparing and talking to witness and getting our opening and closing statements done, and Mr. just brings this up the day before the trial. That’s a little bit trial by ambush..”
On page 26 of the same hearing the discussion continues. The Trial Court said: “Like I say, my overall feeling , from previous arguments of counsel, and from looking at the file, is that the court is concerned about going over a line and messing up a pretty solid prosecution by letting something in that may be overkill. You know, I mean that is –you know, I think you can understand why the defendant would want to keep this out. I mean, once the jury in County hears that he had taken –he is a marijuana user, you know.” (11/08/11 Hrg Tr.26)
Ms responded with ”But again, one of the reasons we did file this as reckless, one of the elements, not devoting full time and attention is because that substance in his blood, which caused some impairment, caused him not to devote the full time and attention. So that was a lot of our reasoning behind this.”(11/08/11 Hrg Tr. 26)

In the Motion in Limine Hearing on Nov 9, 2011 just prior to trial, trial court made this statement: “..If it’s simply that, oh, by the way, he had his , you know, illegal drug in his system in traces, and nobody can testify that, in their opinion, there was enough to affect his driving, I would think the prejudicial value would outweigh the probative value.(11/09/11 Hrg Tr7-8)
The above are some of the statements by trial court and States trial counsel that show clearly that they knew allowing the marijuana evidence into trial was extremely negatively prejudicial to the Petitioner and extremely beneficial to the State.


(6.) The State says in point 6: “A great part of the Petitioner’s application centers upon the drug test results concerning marijuana in his blood at the time of the accident, the motion in limine attempting to exclude that evidence, and the hiring of a toxicology expert. It is clear this was no sleeper issue. Petitioner admits substantial discussion of these issues with counsel prior to trial. The issue of admissibility was clearly presented to the court in a proper manner and the court made a proper decision which was confirmed on appeal...” “Petitioner relies on speculation that contrary expert testimony would have changed the outcome..”

In response, the entire point of the Application for Post Conviction Relief was to show that due to ineffective defense counsel the court did not get a true picture of the effects of 1.1 ng/ml of THC that was allegedly found in his blood. The Petitioner has presented new studies and expert willing to testify that the testimony given by State’s expert toxicologist is not based on current scientific data related to driving under the influence of cannabis. The most comprehensive current study that the Petitioner is aware of (attached as addendum A of the Application) and the expert willing to testify on behalf of the defendant say that 1.1 ng/ml of thc in a person’s blood does not cause impairment, that it is the same as not having any intoxicant in the blood.
The trial court made it’s decision based on information presented at the motion in limine hearings. If the defense counsel would have presented the information to the trial court that the Petitioner presented in his petition it is not likely the marijuana evidence would have been allowed into trial. If defense counsel would have had a toxicology expert testify that 1.1 ng/ml of thc had no effect on driving and the Petitioner was not impaired at the time of the accident that would have been in agreement with the officer on the scene just minutes after the accident who said the defendant was apparently normal and the Petitioner was not charged with DUI or DWI. With an expert toxicologist and the officer on the scene minutes after the accident both saying the Petitioner was not impaired, what would be the chances the marijuana evidence would have been allowed into court? And here is the trial court’s statement again from the motion in limine hearing the morning of the trial: “..If it’s simply that, oh, by the way, he had his , you know, illegal drug in his system in traces, and nobody can testify that, in their opinion, there was enough to affect his driving, I would think the prejudicial value would outweigh the probative value..”(11/09/11 Hrg Tr7-8)

In point 6 the State also says: “..Petitioner claims his attorney made no effort to hire a toxicology expert. This appears not to be true from the record. The court record reflects that on or about October 31, 2011, counsel moved for a continuance to obtain an expert and motion was denied by the court..”
In response, the minute from October 31, 2011 says the following: “ Judge bench docket: State/; Deft/; Deft request continuance. Deft want to try to get OIDS to fund hiring of medical expert. Deft’s motion for continuance denied.”

So the defense counsel requested continuance for a medical expert not a toxicology expert. And although there is no transcript of what was said, it is very clear it was a medical expert he was trying to get funds for because the next day, Nov 1, 2011, State counsel, Ms. , filed a motion in limine to block the defense counsel from making any comments in any part of the trial about the possibility of the victim’s death being caused by medical negligence or malpractice.
Therefore the Petitioner’s statement that defense counsel made no attempt to procure a toxicology expert is accurate.

In point 6 the State finally says: “..Petitioner relies on speculation that contrary expert testimony would have changed the outcome. However the jury could have found that allowing yourself to go to sleep while driving a truck is reckless, without regard to drugs in your blood.. Petitioner has failed to show that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different...”
In response the Petitioner will quote again the words of trial court and State’s trial counsel relative to the prejudice caused by allowing the marijuana evidence into trial:

In discussing whether to allow the marijuana evidence into trial there is some discussion on page 24 of the Motion in Limine hearing Nov 8 2011. The trial court said “ --You know if I say you can’t do it then you—..”
Ms responded with: “ I can tell you my trial strategy is centered around this and it’s going to cause a huge prejudice to me if you make that ruling. So I do kind of need to know.”
On page 26 of the same hearing the discussion continues. The Trial Court said: “Like I say, my overall feeling , from previous arguments of counsel, and from looking at the file, is that the court is concerned about going over a line and messing up a pretty solid prosecution by letting something in that may be overkill. You know, I mean that is –you know, I think you can understand why the defendant would want to keep this out. I mean, once the jury in County hears that he had taken –he is a marijuana user, you know.” (11/08/11 Hrg Tr.26)
Ms responded with ”But again, one of the reasons we did file this as reckless, one of the elements, not devoting full time and attention is because that substance in his blood, which caused some impairment, caused him not to devote the full time and attention. So that was a lot of our reasoning behind this.”(11/08/11 Hrg Tr. 26)

In the Motion in Limine Hearing on Nov 9, 2011 just prior to trial, trial court made this statement: “..If it’s simply that, oh, by the way, he had his , you know, illegal drug in his system in traces, and nobody can testify that, in their opinion, there was enough to affect his driving, I would think the prejudicial value would outweigh the probative value.(11/09/11 Hrg Tr7-8)


Conclusion
So looking at all these statement together I think it is difficult for anyone to say that the outcome would have been the same without the marijuana evidence in trial. The State certainly did not think so. Ms went so far as to say her trial strategy was centered around using marijuana evidence in trial and in fact she did use it throughout the trial and sentencing. Ms said a number of times in motion in limine hearing that the thc evidence was needed to prove element three of the charge which is recklessness. The trial court said the evidence would be more prejudicial than probative if in fact amount of thc in the Petitioner’s blood was not enough to cause impairment.
Since the State did not object in it’s response to the Petitioner’s arguments in the application that1.1 ng/ml is not being high enough to cause impairment, the Petitioner respectfully XXXXX XXXXX trial court to not allow any objections on this matter in any future responses or hearings on this application as it would be very prejudicial to the Petitioner at this point in the proceedings.
From some of Ms statements in the Motion in limine hearings it appears unlikely the Petitioner would have even been charged with negligent homicide if the level of thc in Petitioner’s blood had not been high enough to cause impairment. Now that the Petitioner has proven, with no objection from the State, that the level of THC in the Petitioner’s blood was not high enough to cause impairment the Petitioner should be found not guilty or in the alternative be given a new trial with marijuana evidence excluded. (The response to State’s point 4 above gives the complete conclusion from the Application for Post Conviction Relief and gives the opinions referenced to reach that conclusion)

WHEREFORE, the Petitioner respectfully XXXXX XXXXX State’s Response to Petitioner’s Application For Post-Conviction Relief filed in this case on or about July 23, 2013, be denied and dismissed and the Petitioner be found not guilty or in the alternative be given a new trial with marijuana evidence excluded.
Submitted: 1 year ago.
Category: Criminal Law
Expert:  MyraB replied 1 year ago.
Hello again and thank you for your question.

Just wanted to let you know that I received the question. I will take a look at this and get back to you later today.

.
Customer: replied 1 year ago.


Ok. Thanks. I will greatly appreciate it.

Expert:  MyraB replied 1 year ago.

Overall this reply seems well organized and focuses on the points and errors made in the State’s response.

There are a few suggestions. I’ll put the suggestions for specific changes in quotes and write out the suggestions for other changes or additions.

The court can’t overrule or dismiss the response. It could, on a motion to strike, strike the response, but this is for when the state would include something that was not brought up at trial, would stray from the arguments or issues raised, and would not be applicable here. What you have here is a fairly straightforward response from the state.

So, you may want to change the introduction to “Now comes . . . and submits the following reply to the State’s response to the Petitioner’s . . . . . This reply is limited to addressing the arguments raised in the State’s response.” This is so the judge will know you are specifically addressing only the arguments made by the State in its response.

Then, “In support thereof the Petitioner states:

Points 1 and 2 accurately set forth the procedural history of the case. The Petitioner responds to Points 3 to 6 as follows:”

(3) You many not want to agree that the only ground centers on hiring the toxicology expert. There is the related argument, as you do mention later, that is equally strong that defense counsel should have challenged the prosecution’s expert by requesting a Daubert hearing and/or with scientific literature.

Also, you don’t need to set forth the entire section 1080. Quote the sections that apply and then make your argument. You may want to add that ineffective assistance of counsel has not previously been raised so no res judicata and that the issue has not been waived. You do point out, with the Brown case, that the issue is a valid grounds for post-conviction relief.

I would suggest avoiding remarks such as “state must not have read the entire petition.” Rather, just point out that the new evidence presented in the Petition. Such as, “However, the Petition describes and discusses new evidence in great detail at pages 7-10.”

In place of “as it should have been found by defense counsel” I would suggest something along the lines of “The defendant’s argument on the existence of new evidence is intertwined with the issue of the ineffective assistance of counsel. The defendant contends that defense counsel should have discovered and been aware of the new evidence and that his failure to do so constituted ineffective assistance of counsel.”

(4) Include the page cite to cases. The form of citations should be Fitzgerald v. State, 972 P.2d. 1157, [page] (1998).

Same with Strickland – include page cite where quote appears.


This is a nice summary of the ineffective assistance of counsel claims. The defendant may want to put it on an index card or something for reference at the hearing and use it like a hammer.

“There is no record to show that Mr filed a motion to continue for time to attain an expert toxicologist or motion for funds for an expert toxicologist although he knew almost from the time he was appointed counsel that an expert toxicologist would be critical for the defense of the Petitioner as demonstrated by his statements in the pretrial meetings. Nor did Mr.file a motion for a Daubert hearing to challenge the scientific basis and methodology of how the prosecution expert arrived at his conclusions nor did he introduce research studies on THC and driving. He even failed to bring the drug court person to counter the expected testimony from the prosecution expert as he said he would do in the pre-trial, pre-hearing meetings with the Petitioner.”

Juxtaposed against the prosecutor’s comments on how important the expert’s testimony was to the state’s case and on the issue of recklessness.

If the defendant could only say two things at the hearing, those might be the two things he wants to say.

(5) You may want to change the references to the trial court, to “the trial court judge” where it is the judge who is stating and not an order of the court.

at the end you may want to add “. . . that show clearly that they knew allowing the marijuana evidence into trial was extremely negatively prejudicial to the Petitioner and extremely beneficial to the State, and that it ultimately made a difference in the jury’s verdict.”

(6) “due to ineffective defense counsel the court did not get a true picture of the effects of 1.1 ng/ml of THC that was allegedly found in his blood.” You may want to change “the court” in this sentence to “the jury.”

“what would be the chances the marijuana evidence would have been allowed into court?” Avoid questions, unless you answer them. Or state the conclusion affirmatively – After DWI “Under those circumstances, it is likely the state’s expert’s testimony would not have been admitted. And even if it was admitted, the defendant would have had scientific evidence and its own expert to challenge and counter the state’s expert’s clearly erroneous opinion. In contrast, as a result of defense counsel’s failures, the defendant had nothing and was deprived of a viable and meritorious defense on this essential issue.

“..Petitioner claims his attorney made no effort to hire a toxicology expert. This appears not to be true from the record. The court record reflects that on or about October 31, 2011, counsel moved for a continuance to obtain an expert and motion was denied by the court..”

You may want to make it clearer from the outset that the state’s argument here is misleading. I would suggest reordering the response to read:

“..Petitioner claims his attorney made no effort to hire a toxicology expert. This appears not to be true from the record. The court record reflects that on or about October 31, 2011, counsel moved for a continuance to obtain an expert and motion was denied by the court..” The state here is mistaken. In fact, defense counsel requested a continuance for a medical expert on the issue of cause of death, and not for a toxicology expert. Defense counsel never sought to obtain nor sought a continuance to obtain a toxicology expert.

The docket reflects that on October 31, 2011 “Judge bench docket: State/; Deft/; Deft request continuance. Deft want to try to get OIDS to fund hiring of medical expert. Deft’s motion for continuance denied.”

Although there is no transcript of what was said, it is very clear it was a medical expert that defense counsel was trying to get funds for because the next day, Nov 1, 2011, State counsel, Ms. , filed a motion in limine to block the defense counsel from making any comments in any part of the trial about the possibility of the victim’s death being caused by medical negligence or malpractice.

Therefore the Petitioner’s statement that defense counsel made no attempt to procure a toxicology expert is accurate.”


Re: the falling asleep = recklessness argument. Did the prosecutor even argue this in the closing. The closing argument will reflect what it was that the prosecutor thought important. The closing is the prosecutor’s opportunity to frame the case for the jury. I’m pretty sure she said something like and you’ve heard from Mr. …. an expert who gave his opinion that the defendant was impaired. I don’t think she argued he shouldn’t have fallen asleep, although she may have. Anyway take a look at the closing and maybe incorporate it into your argument on what the prosecution thought was important if it supports your argument.

I would not include the parenthetical phrase in the Conclusion. If you want to state in Point 4 that something is more fully set forth in the Petition, then state it there and not at the end. You want to end strong and not with a phrase in parenthesis.

WHEREFORE, . . . Again requesting denial and dismissal is not quite right.

You may want something along the lines of: “For the foregoing reasons and those set forth in the Petition for Post Conviction Relief the court should reverse the conviction and enter a finding of not guilty or in the alternative grant a new trial with the marijuana evidence excluded."

MyraB, Lawyer
Category: Criminal Law
Satisfied Customers: 371
Experience: I have over 20 years experience in criminal law and civil litigation from pre-trial practice to appeal.
MyraB and 6 other Criminal Law Specialists are ready to help you
Customer: replied 1 year ago.

Thank you for your help. The response is in the mail to the defendant. I have to mail it to him but I can pick it up. So it should be filed Wednesday.


The question is what now? The prosecution would like to see the defendant stay in jail as long as possible whether they win this battle or not. We want to move things along once the defendant gets his response filed.


 


Somewhat confused on the best way to get things moving. He still has not filed a motion for expert although it was requested in the APCR. Defendant could request a hearing or motion in limine to block the state from raising the issue of the state raising the issue of thc causing impairment since they did not object to defendant's arguments countering their expert. What would you suggest at this time? Would not be such a big deal if my son was not sitting in small jail cell 20 plus hours a day.


 


Another point is I asked court reporter why the 17 page excerpt of transcript for the States toxicology expert testimony was filed. She told me that the person who ordered it only wanted that testimony so when it was ordered she filed it. She did not say who ordered it. I did not ask who ordered thinking she did not have to tell me. I did get a copy of the transcript. All 17 pages was the expert testimony. He has over 20 years with OSBI toxicology department, 15 years as supervisor of the department with all kinds of specialized training. He absolutely should have known what he was saying was false. He went so far as to say 1-1.5 ng/ml was enough to cause a person not to be able to pass a sobriety test. What he gave was testimony for a person who has 10 to 15 ng not 1 to 1.5 in their blood. Since someone ordered just that testimony I think it was ASCLD or OSBI.

Expert:  MyraB replied 1 year ago.
Now that the filings are complete, the next step is to get the hearing. You may want to contact the court and ask when the hearing is scheduled. If there is no hearing scheduled, the defendant may want to file a written motion. Basically, this would be a one page request for a hearing on the Application stating that a hearing would be in interest of justice and would facilitate the court in its decision. It is up to the judge, as under the rule he has the option of making a decision on the written submissions.

The defendant could file the motion for expert fees at the same time as the motion for hearing. Then file the motion in limine to limit the issues if and when the hearing is set. This would be the first order of business at the hearing.

It does seem that someone is looking into the expert's testimony. Because it is recorded, the expert should be able to be held accountable for his testimony. It seems to be a hopeful sign.
MyraB, Lawyer
Category: Criminal Law
Satisfied Customers: 371
Experience: I have over 20 years experience in criminal law and civil litigation from pre-trial practice to appeal.
MyraB and 6 other Criminal Law Specialists are ready to help you

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