Innovative DUI Trial Tools
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Table of Contents
CHAPTER ONE: PRE-TRIAL DISCOVERY AND MOTION PRACTICE
I. Introduction
II. Pre-Trial Discovery Requests
§1:01 Legal Principles
§1:02 Use of Discovery Request
§1:03 Sample Discovery Request: Breath Case
§1:04 Sample Discovery Request: Blood/Urine Case
(Relevant Paragraphs)
§1:05 Independent Analysis of Blood Samples
§1:06 Letter to Crime Lab Requesting Forwarding of
Blood Sample to Private Lab
§1:07 Letter to Private Lab re Blood Re-Testing
III. Motions Based on Defendant’s Right to Compulsory
Process
§1:20 Legal Principles
§1:21 Inspection of Breath Machine
§1:22 Motion for Subpoena Duces Tecum for Breath
Machine
§1:23 Memorandum in Support of Motion for Subpoena
Duces Tecum for Breath Machine
§1:24 Statement of Facts in Support of Motion for
Subpoena Duces Tecum for Breath Machine
IV. Due Process and Motions in Limine
A. General Points
§1:30 Legal Principles
§1:31 Defendant’s Motion in Limine
B. Partition Ratios
§1:40 Admissibility of Testimony Regarding
Blood/Breath Partition Ratios
§1:41 Memorandum in Support of Defendant’s Motion in
Limine to Introduce Partition Ratio Evidence
C. Tolerance
§1:50 Precluding Evidence of Tolerance
§1:51 Memorandum in Support of Defendant’s Motion in
Limine to Exclude Evidence of Tolerance
D. Retrograde Extrapolation
§1:60 Precluding Evidence of Retrograde Extrapolation
§1:61 Memorandum in Support of Defendant’s Motion in
Limine to Preclude Evidence of Retrograde Extrapolation
E. Prosecutorial Misconduct
§1:70 Precluding Prosecutorial Misconduct
§1:71 Memorandum in Support of Defendant’s Motion in
Limine to Preclude Prosecutorial Misconduct
F. Field Sobriety Tests
§1:80 Precluding Field Sobriety Test Evidence
§1:81 Memorandum in Support of Defendant’s Motion in
Limine to Preclude Field Sobriety Test Evidence
V. Creating Your Own Database
§1:90 How to Create
§1:91 Using Your Information
CHAPTER TWO: JURY SELECTION
I. Purpose of Voir Dire
§2:01 Exposing Juror Bias
§2:01.1 Eliciting the Key Words
§2:02 Limits on Time and Scope
§2:02.1 Whose 20 Minutes Is It?
§2:03 Uncovering Juror Personality Types and
Finding Leaders
II. What Kind of Juror Do You Want?
A. Ideal Juror Depends on Theory of Case
§2:10 Importance of Theory of Case
§2:11 Improperly Conducted Breath Test
§2:12 Disconnect Cases
§2:13 Bad SFST Performance
§2:14 Rising Alcohol Cases
§2:15 Refusal Cases
§2:16 Drug Cases
B. Jurors Usually Best to Avoid
§2:30 Prospective Jurors With Strong Anti-Alcohol
Positions
§2:31 Prospective Jurors With Prior DUI Charges
§2:32 Truckers and Other High Mileage Drivers
III. Sample Voir Dire Questions
§2:40 How to Use These Questions
§2:41 Questions Regarding Relationship to Defendant,
Witnesses, Law Enforcement
§2:42 Questions Related to Police Officers
§2:43 Questions Related to Punishment
§2:44 Questions Related to Scientific Evidence
§2:45 Questions Related to Expert Opinion
§2:46 Questions Related to Blood Analysis
§2:47 Questions Regarding Constitutional Issues
§2:48 Questions Related to Motor Skills
§2:49 Questions Related to Physical Characteristics of
Intoxicated Persons
§2:50 Questions Regarding Memory
§2:51 Questions Regarding Odor of Alcohol
§2:52 Questions Regarding Nervousness
§2:53 Questions Regarding Intoxication
§2:54 Questions Related to Bodily Functions
§2:55 Questions Related to Offense of DUI
§2:56 Questions Related to Alcohol
§2:57 Staircase Metaphor
IV. Jury Questionnaires
§2:70 How to Use
§2:71 Sample Jury Questionnaire
V. Slides and Scorecard to Use When Voir
Dire Is Limited
§2:80 How to Use
§2:81 Sample Slides
§2:82 More Sample Slides
CHAPTER THREE: OPENING STATEMENTS
I. Strategies and Tactics
§3:01 To Open or Not to Open; That Is Not a Question.
§3:02 When to Reserve Opening Until After
Prosecution’s Case
§3:03 Set the Tone
§3:04 A Strong Positive Argument, Not a Trial Road Map
§3:05 Grab Jurors’ Attention
§3:06 Establish Rapport and Humanize Your Client
§3:07 Fill in the Blanks With Positive Information
§3:08 Point Out Problems With the Prosecution’s Case
§3:09 Tell Jurors About Your Defense
§3:10 Boost the Officer and Prosecution Expert so You
Can Knock Them Down on Cross-Examination
§3:11 Use Element of Surprise to Your Advantage
§3:12 Go Out of Order
§3:13 Wake Up the Jurors
II. Sample Openings
§3:20 Who Was Driving
§3:21 Refusals
§3:22 FSTs
§3:23 Rising Blood Alcohol
§3:24 Keeping an Open Mind
§3:25 It Wasn’t My Client
§3:26 The Missing Element
§3:27 You Cannot Believe the Officer
§3:28 Quick Ideas for Basic Issues
CHAPTER 4: CROSS-EXAMINATION
I. Introduction
§4:01 Cross-Examination Is Your Testimony
§4:02 A Kinder, Gentler Approach to the Officer
§4:03 A Radical Approach to SFSTs
II. The Police Report
§4:10 Lock the Officer In
§4:11 Establish Bias
III. The Initial Contacting Officer
§4:20 Goals
§4:21 Technical Stop (for Burned Out Lights, Expired
Registration etc.)
§4:22 Driving Violation: Speeding
§4:23 Driving Violation: Illegal Turn
§4:24 Accident
§4:25 NHTSA Criteria
§4:26 The Stop
§4:27 Stop Set-Up
§4:28 Approach
§4:29 Pre-Exit Interview
IV. The Arresting Officer
§4:40 Goals
§4:41 General Questioning
§4:42 Admission of Drinking
§4:43 The Exit
§4:44 SFSTs
§4:45 Preliminary Breath Tests
§4:46 The Arrest
§4:47 Drinking Pattern
§4:48 Transportation and Observation
V. The Breath Test Operator
§4:60 Goals
§4:61 Observation
§4:62 Accuracy
§4:63 Maintenance
VI. The State’s Expert
§4:70 Goals
§4:71 Voir Dire
§4:72 Articles
§4:73 Science
§4:74 Henry’s Law
VII. Blood Cases
A. Background Information on Blood Testing
§4:80 In General
§4:81 Taking a Blood Sample
§4:82 Transporting and Storing a Blood Sample
§4:83 Testing of the Blood Sample
§4:84 Plasma vs. Whole Blood
B. Cross-Examination of Specific Witnesses
§4:90 The Witnesses
§4:91 The Phlebotomist
§4:92 The Officer With Custody of the Blood Before
Pick-Up and Delivery
§4:93 The Pick-Up and Delivery Person
§4:94 Login at the Lab
§4:95 The Analyst
VIII. Doctors
§4:100 Reluctance to Disagree With Other Doctors and
Peer-Reviewed Articles
§4:101 Some Words About the AMA
§4:102 Sample Cross-Examination
IX. Lay Witnesses
§4:110 Goals
§4:111 Sample Cross-Examination
X. Cross-Examination Ethics
§4:120 Ethical Limitations of Cross-Examination
§4:121 The American Bar Association Model Rules of
Professional Conduct
§4:122 Traditional Supreme Court Cases on
Cross-Examination
XI. Cross-Examination, Hearsay, and the
Confrontation Clause
§4:130 Crawford and the Right to Confront
§4:131 What Is Testimonial
§4:132 Application to DUI Cases
CHAPTER FIVE: PREPARATION OF DEFENSE WITNESSES AND DIRECT EXAMINATION
I. Introduction
§5:01 Types of Witnesses
§5:02 Direct Examination of Experts: The Correct
Approach
II. Percipient Witnesses
§5:10 Preparation
§5:11 Purpose and Goals
§5:12 Establish Witness’ Lack of Personal Interest and
Attempts to Talk to Prosecution
§5:13 Sample Direct Examination of “Drinking Buddy”
§5:14 Introduction of Receipts Through Percipient
Witness
§5:15 Sample Direct Examination of Bartender
III. Field Test Experts
§5:20 Selection and Preparation
§5:21 Purpose and Goals
§5:22 Administration of SFSTs
§5:23 Interpretation of SFSTs
§5:24 Reliability and Meaning of SFSTs
§5:25 Direct Examination of SFST Expert: Version 1
§5:26 Direct Examination of SFST Expert: Version 2
IV. Breath Experts
§5:40 Selection and Preparation
§5:41 Purpose and Goals
§5:42 Basic Operation of the IR Machine
§5:43 Blood/Breath (Partition) Ratio
§5:44 Absorption Phase Testing
§5:45 Temperature Issues
§5:46 Two Samples
§5:47 Steepling Example
§5:48 Two Breath Samples With .02 Agreement
§5:49 Example of .02 Agreement
§5:50 Machine Specificity and Interferents
§5:51 Acetaldehyde
§5:52 Airblank Fallacy
§5:53 Slope Detector/Mouth Alcohol
§5:54 Diabetes, Hypoglycemia, Dieting
§5:55 GERD Cases
V. Alcohol Expert and Rising Alcohol
§5:60 Selection and Preparation
§5:61 Purpose and Goals
§5:62 Physiology of Alcohol
§5:63 Destruction of Presumptions
§5:64 Creating Doubt
§5:65 Disconnect Theory
§5:66 Tolerance
§5:67 Consistency Theory
§5:68 Blood Tests
§5:69 Henry’s Law
VI. Medical Experts
§5:80 Treating Physician
§5:81 Validity of Test
§5:82 Cross-Examination
CHAPTER SIX: THE CLIENT’S TESTIMONY
I. How to Evaluate Whether the Client
Should Testify
A. In General
§6:01 To Testify or Not to Testify, That Is the
Question
§6:02 Jurors Expect Innocent Clients to Testify
§6:03 Memorandum in Support of Defendant’s Motion in
Limine to Limit the Scope of Defendant’s Cross-Examination
B. Cases That May Call for Client’s Testimony
§6:10 Client’s Testimony Is Only Source of Evidence
§6:11 Client Has Physical Problem That Interfered With
SFSTs
§6:12 Client’s Testimony Will Evoke Sympathy
§6:13 Client Has Sufficient Physical Evidence to Make
Up for Slips
§6:14 Client Has Medical Condition That Interfered
With Breath or Blood Tests
§6:15 Client Has Necessity Defense
§6:16 Client Has SODDI a Defense
II. Sample Trial Examination Questions for
Client
A. Preliminary Questions
§6:30 Introduction and Setting Client at Ease
§6:31 Why Client Has Decided to Testify
§6:32 Stress on Client on Day of Incident
B. FSTs
§6:40 Direct Examination
§6:41 Cross-Examination
C. Physical Limitations
§6:50 Direct Examination
§6:51 Cross-Examination
D. Refusal
§6:60 Due to Confusion
§6:61 Due to Belief in Right to an Attorney
§6:62 Due to Belief Officer Had No Right to Demand
Compliance
E. Rising Alcohol Defense
§6:70 Direct Examination
§6:71 Cross-Examination
F. Medical Condition
§6:80 Direct Examination
G. Environmental Exposure
§6:90 Direct Examination
§6:91 Cross-Examination
§6:92 Alcohol to Feel Better
III. Client Handout
§6:100 Ten Rules Every DUI Defense Witness Should Know
Before Testifying at Trial: The Nickel and Dime Mnemonic
CHAPTER SEVEN: CLOSING ARGUMENTS
I. Introduction
§7:01 Goals
§7:02 Neutralizing Prosecutor’s Closing: Solutions to
Not Having the Last Word
§7:03 Capturing the Jurors' Hearts and Mind
§7:04 Developing Your Own Voice
§7:05 Handling the Defense Stigma
II. Types of Closing Arguments
§7:10 Basic Categories of Closings
A. The Story Closing
§7:20 Effective Storytelling
§7:21 Example: Bloodshot Eyes
§7:22 Chronological Order Is Best
§7:23 Tell Story in “Here and Now”
§7:24 Emphasize Theme
§7:25 The Moral
B. The Rules Closing
§7:30 What Is a "Rules" Closing?
§7:31 Rules Closing Must Be Accurate
§7:32 Use Outline, Rather Than Chronological
Organization
§7:33 Repeat "Reasonable Doubt"
§7:34 Tailor Trial Examination to Closing
§7:35 Use Charts
§7:36 Use Demonstrations
§7:37 Combine With Story Close
C. The "I Cannot Believe This Piece of Junk Made
It This Far" Closing
§7:50 When to Use
§7:51 How It Works
§7:52 Two Cautions
§7:53 Sample Closing Argument
III. Analogies, Anecdotes, and Stories
§7:60 Introduction
§7:61 Witness Testimony
§7:62 Minor Problems
§7:63 Acceptable Machine Errors
§7:64 Machine versus People
§7:65 Rising Alcohol
§7:66 Circumstantial Evidence
§7:67 The Note Pad
§7:68 The Tripod
§7:69 The Reveal: No Observed Driving Case
§7:70 Three Verdicts: The Hung Jury
§7:71 Lack of Rebuttal
§7:72 Urine Test: Hawaiian Punch Demonstration
IV. Burdens of Proof
A. The Staircase
§7:80 Introduction
§7:81 Reasonable Suspicion
§7:82 Probable Cause
§7:83 Preponderance
§7:84 Clear and Convincing
§7:85 Beyond a Reasonable Doubt
§7:86 Prosecution’s Rebuttal
B. Closing Argument Aids
§7:90 Burden of Proof Building Blocks
§7:91 Degrees of Guilt
V. Complete Closings
§7:100 The Interrogator (Refusal Cases)
§7:101 The Inspector (Breath Test Cases)
§7:102 Disconnect Cases (High BAC)
§7:103 Circumstantial Evidence Case (No Test or Other
Guy Drove)
VI. Constructing a Power Point Closing Argument
§7:110 Introduction
§7:111 The Evidence
§7:112 Essential Points to Be Made on
Cross-Examination
§7:113 The Presentation
CHAPTER EIGHT: DEMONSTRATIVE EVIDENCE
I. Introduction
II. Rising Alcohol Defense
§8:01 Blood Alcohol Curve
§8:02 Use at Trial
III. Meaning of “Average,” “Normal,” and “Most People”
§8:10 Standard Deviation
§8:11 Calculation Example
§8:12 Use at Trial
IV. Standardized Field Sobriety Tests
§8:20 Walk-and-Turn Demonstration
§8:21 Horizontal Gaze Nystagmus Demonstration
§8:22 NHTSA SFST Slides
§8:23 National College for DUI Defense Demonstration
Boards
§8:24 Scoring SFSTs
§8:25 Huser’s Totality Charts
V. Slides for Common Issues and Concepts
§8:30 Introduction
§8:31 Witness Who Tells Only Bad Facts
§8:32 Objective Symptoms
§8:33 Field Sobriety “Tests”
§8:34 Precision and Accuracy
VI. Low Budget Ideas
§8:40 Demonstrating Witness Unresponsiveness
§8:41 What’s in a Beer
VII. Miscellaneous
Diagrams and Photos
§8:50 Fuel Cell Diagrams
§8:51 Infrared Spectroscopy Diagrams
§8:52 Intoxilyzer 5000 Photos
§8:53 Filter Wheel Diagrams
§8:54 Sample Chamber Diagrams
§8:55 Breath Machine Diagrams
§8:56 Wavelength and Interference Diagrams
§8:57 Gas Chromatograph Photos
VIII. Perspective: Things May
Not Be What They Seem
§8:70 Horse/Frog Sketch
§8:71 Dihydrogen Monoxide Power Point Presentation
§8:72 The Beautiful House Power Point Presentation
APPENDIX A: The District Attorney’s Manual
I. Preparing for Trial
A. Reviewing the Police Reports
1. In General
§A:01 Driving Pattern
§A:02 Age
§A:03 Gender
§A:04 Race
§A:05 National Origin
§A:06 Height and Weight
§A:07 Medical Condition and/or Treatment
§A:08 Physical Oddities/Special Medical Problems
§A:09 AKAs (Aliases)
§A:10 DMV Printouts
§A:11 Time Booked
§A:12 Destination and Origination
§A:13 Clothing Worn
§A:14 Vehicle Driven
2. Statements Made by the Defendant
§A:20 Alcohol Consumption
§A:21 Obscenities
§A:22 Fatigue
§A:23 Rising Blood Alcohol/Absorption
§A:24 Investigatory Questions/Miranda
3. Field Sobriety Tests
§A:30 Officer’s Documentation
§A:31 Horizontal Gaze Nystagmus
§A:32 DUI Drugs
§A:33 Refusals
§A:34 DMV Administrative Hearings
§A:35 Scene Visits/Photos
B. Interviewing Witnesses
§A:40 Police Officers
§A:41 Non-Police Witnesses
C. Preparing for the Introduction of the Blood
Alcohol Results
§A:50 The Breath Test
§A:51 The Blood Test
§A:52 The Urine Test
§A:53 The Blood Alcohol Expert
D. Response to Discovery Motions
§A:60 Typical Defense Requests and Motions
§A:61 Maintenance History
§A:62 Instructional Manuals
§A:63 Witness Rap Sheets
II. Jury Voir Dire and Proposed Sample
Questions
§A:70 Imposition of Judicial Voir Dire
§A:71 Scope of Voir Dire
§A:72 Bias
§A:73 Voir Dire Questions
III. Opening Statement
A. The Prosecution’s Position
§A:80 Strategy Checklist
§A:81 A and B Count
B. Preempting the Defense Arguments
§A:90 The A Count
§A:91 The B Count
§A:92 Additional Points for Blood or Urine
§A:93 Refusal
IV. Direct Examination of Arresting Officer and
Other Prosecution Witnesses
A. Preparation for Examination of Arresting
Officer
§A:100 Preparation Before Trial
§A:101 Checklist for Preparing Officer to Testify
§A:102 Checklist for Questioning Officer at Trial
B. Sample Direct Examination Questions for
Arresting Officer
§A:110 General Background
§A:111 The Stop
§A:112 First Contact With Defendant
§A:113 FSTs
§A:114 Modified Position of Attention Test
§A:115 Post-FST Questions
§A:116 Chemical Test Admonition
§A:117 Refusal Admonition
§A:118 Breath Test
§A:119 Blood Tests
§A:120 Urine Test
C. Cross-Examination and Redirect Examination of
Officer
§A:130 Cross-Examination of the Officer
§A:131 Demonstration of FSTs by Officer
§A:132 Was the Defendant 647(f) (Drunk in Public) or
Other Arrestable Offense?
§A:133 Redirect Examination
D. Questions for Other Prosecution Witnesses
§A:140 Breath Machine Operator Questions
§A:141 Blood Technician/Nurse Questions
V. Examination of the Prosecution’s Alcohol
Expert
A. Introduction
§A:150 Goals for Direct Examination of Criminalist
§A:151 Blood Alcohol Not Exclusive Measurement of
Impairment
§A:152 Testing Methods
B. Breath Test Short Form Direct Examination
Questions
§A:160 Intoxilyzer 5000
§A:161 Tips on Redirect
§A:162 Notes on Delayed Absorption
C. Blood Draw Direct Examination
§A:170 Blood Alcohol Results
§A:171 Redirect Examination
D. Urine Testing
§A:180 In General
§A:181 Points of Attack
E. General Questions and Blood Alcohol
Calculation Questions
§A:190 Opinion Testimony by Experts.
§A:191 General Interpretation Questions
§A:192 Blood Alcohol (BA) Calculation Questions
VI. Common Defenses for Chemical Tests
A. General
§A:200 Main Defense Approaches
§A:201 Qualification of Criminalist
B. Breath Analysis Defense Issues
§A:210 Overview
§A:211 Partition Ratio Generally
§A:212 Defendant’s Individual Partition Ratio
§A:213 Mouth Alcohol
§A:214 Maintenance of Instrument
§A:215 Radio Frequency Interference
§A:216 Acetone and Solvent Interferences
§A:217 Arterial vs. Venous Blood
§A:218 Temperature
§A:219 Hematocrit
§A:220 Mother Solution for Calibration Checks
§A:221 Low Calibration Checks Readings
§A:222 Simulator Solution Temperature
C. Blood Analysis Defense Issues
§A:230 Lack of Preservative/Anticoagulant
§A:231 Micro Clots
§A:232 Bacterial Growth
§A:233 Contamination of Sample From Arm Swab
§A:234 Switched Samples
§A:235 Instrument Calibration
§A:236 Hematocrit (Blood Cell Count)
§A:237 Drug/Alcohol Interactions
§A:238 Aspirin/Tagamet
§A:239 Venous vs. Arterial Blood
D. Urine Analysis Defense Issues
§A:250 1.3:1 Ratio (Blood to Urine)
§A:251 Void Studies
§A:252 Residual Urine
§A:253 Special Note
E. Widmark Calculations Defense Issues
§A:260 Time to Peak Alcohol Level
§A:261 Burn-Off Rate
§A:262 Widmark’s Factor
VII. Cross-Examination of
Defense Witnesses
A. Cross-Examination of Defense Expert
§A:270 Breath Questions
§A:271 Questions if Defense Says FSTs Are Not Valid
§A:272 Questions Defense Expert Says It Takes Two
Hours for Absorption
§A:273 Questions to Show Bias of Defense Expert
B. Cross-Examination of Defendant/Defense
Witnesses
§A:280 Strategy
§A:281 Driving Patterns
§A:282 Activities Prior to Arrest
§A:283 Symptoms That Alcohol and Over Consumption
Usually Produce in Defendant
§A:284 The Obvious
§A:285 New Drinking Pattern
§A:286 Drinking Companion Questions
§A:287 Questions for Bartender
VIII. Closing Argument
A. Introduction
§A:300 Preparation
§A:301 Moral Behavior and Physical Appearance
B. First Argument
§A:310 Outline
§A:311 Explain the Charges
§A:312 Discuss the Facts
§A:313 Ask Jury to Convict
C. Defense Argument and Rebuttal
§A:320 Defense Argument
§A:321 Rebuttal Argument
D. Checklists for
Closing Argument
§A:330 What to Do
§A:331 What to Avoid
E. Common Defenses/Responses
§A:340 “My Client Only Made a Few Mistakes on the
Field Sobriety Tests.”
§A:341 “There Was No Accident.”
§A:342 “My Client Wasn’t Driving.”
§A:343 “The Officer Made a Mistake in the
Investigation.”
§A:344 “The Officer Is Biased and Just Wants to Win
This Case.”
§A:345 “The Chemical Test Results Are Incorrect.”
§A:346 “My Client Had a Rising Blood Alcohol.”
§A:347 “The People Did Not Call a Certain Witness, So
You Don’t Have All of the Evidence.”
§A:348 “The Evidence Leaves a Reasonable Doubt.”
§A:349 “There Really Was No Bad Driving in This Case.”
§A:350 “The Officer Is Mistaken, or Has Lied.”
§A:351 Arguments Based on Sympathy, Including Those
With Racial Overtones
§A:352 “A Critical Fact Is Missing From the Arrest
Report and the Officer Is Now Embellishing on the Report to Make the Case
Seem Stronger.”
§A:353 “My Client Was Honest With You. He Didn’t Come
in Here and Tell You That He Hadn’t Had Anything to Drink. He Had Two Beers,
and That Was All.” (The “Two Beers” Defense.)
§A:354 “My Client Explained to You Why He Refused to
Take the Chemical Test.”
§A:355 “Only a Minute Sample of Breath Was Actually
Analyzed. You Can’t Even See The Alcohol in Such a Small Amount. Can You
Convict a Person of a Crime Based Upon Such a Tiny Amount of Alcohol?”
§A:356 “Because My Client Performed Well on the Field
Sobriety Tests, He Should Be Acquitted Because That Performance Raised a
Reasonable Doubt.”
§A:357 “The People Get ‘Two Bites at The Apple.’ They
Get to Argue to You Twice, But I Only Get One Chance.”
§A:358 “The DA Didn’t Disprove Our Case” or “Show My
Client Was Lying; Therefore His Drinking Pattern Is to Be Believed, and
Based Upon That Pattern, He Was Less Than .08 at the Time Of Driving.”
§A:359 “And, Finally, Ladies and Gentleman, I Ask You
to Remember That I Cannot Speak to You Again. Please Listen to the
Prosecutor’s Argument as I Will, Thinking of the Arguments That My Client
and I Cannot Make.”
APPENDIX B: Deposition of Marcelline Burns
APPENDIX C: Arrest Video Analysis Form
TABLE OF CASES
INDEX
Updated 04/06/12
