Successful Motions Practice

[...]be consistent throughout your motion. [...]trial counsel routinely request the court to order the criminal investigation command (CID) to turn over documents to the defense counsel, but the judge generally does not have the authority to order a third party to do anything-the judge will instead order the trial counsel to make CID turn over the documents. [...]it will provide you (and the judge) structure for the rest of your motion (and the judge's ruling). [...]consider a motion to suppress an accused's statement to civilian law enforcement that involves issues of voluntariness: whether civilian law enforcement should have informed the suspect of the rights in Article 31(b), Uniform Code of Military Justice9 (nexus between civilian and military law enforcement investigations?) and Miranda rights (custodial interrogation?); whether later searches or statements were fruit of the poisonous tree; and whether suppression is an appropriate remedy.