CJA Briefbank


About the Briefbank

Below are links to sample motions filed by AFPDs in the Northern District of California, as well as some contributions by CJA counsel and other defense counsel. To incorporate these motions into your brief, right click and download the document. Please take care to update the research in these motions and tailor them to the unique facts of your case. There is nothing less persuasive than an obvious boilerplate motion with outdated law, that does not reflect the unique case before the Court. Using these motions as boilerplate, without updated research and modification, is a disservice to the client and a misuse of this briefbank resource.

This briefbank is a work in progress, and we will be adding motions to it periodically. When you revisit the site, make sure to hit "refresh" on your browser to pick up new additions.

If there are any motions that contain outdated summaries of the law, or that rely on authority that has been overruled, please contact our office with corrections.


Bifurcation and Severance:

Competency & Sell:
Comptency Motion word

Defense Experts:

Discovery and Confidential Informant Disclosure:

Government Experts:

Illegal Reentry Challenges:

Indictments - Surplusage, Multiplicity, Duplicity, & Bill of Particulars:
Bill of Particulars word

Judgment of Acquittal and for New Trial:


Miscellaneous Motions (Return of Property, Etc.):

Search/4th Amendment Challenges:

Sentencing Memoranda:

Speedy Trial:

Suppress Statements & Miranda Issues:

Suppress Eyewitness ID:

Trial and In Limine:

Wiretaps (Title III Electronic Interceptions):