Severance Motion

Posted by emily on August 30, 2011
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The State’s Response to Defendant’s Motion to Sever, attached below, concedes severance is necessary to give each defendant individualized consideration of mitigation at the penalty phase.

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Motion to Preclude Death Penalty

Posted by emily on July 03, 2009
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Defendant’s motion to preclude the death penalty on the basis of an improper relevancy determination for mitigating evidence. This motion specifically object’s to the continued practice of giving de minimis weight to mitigation when defendant is unable to demonstrate a causal nexus to the crime.

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