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of Terms
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Descriptions
Sample Briefs, Writs
and Motions
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Sample
Briefs, Writs and Motions
For most attorneys, The Court of Appeal is a foreign experience,
with very different rules, demands and expectations when
filing any motion or brief compared to the trial court. The
years David has invested in his appellate law practice has
resulted in a wealth of knowledge and insight into how the
court works, and an attention to detail that can prevent
potential errors.
The following is a representative sample of David's Appellate
Briefs, Writs and Motions. Please note that while these samples
were actually used in the course of previous proceedings, they
are offered as a resource to attorneys who are considering an
appellate action-- and all names of parties and attorneys have
been deleted or redacted.
Sample Briefs
• Appellant’s
Opening Brief (112K .doc)
• Appellant’s
Opening Brief (72K .wpd)
• Appellant's Opening
Brief (124K PDF)
• Appellant’s
Reply Brief (120K .doc)
• Appellant's
Reply Brief (52K .wpd)
• Appellant's Reply
Brief (76K PDF)
• Respondent’s
Brief (1.7 MB PDF)
• Appellant’s
Petition for Rehearing (104K .doc)
• Appellant's
Petition for Rehearing (32K .wpd)
• Appellant's
Petition for Rehearing (88K PDF)
Sample Writs
• Denial
to Return to Petition for Writ of Habeas Corpus (2.3
MB PDF)
• Petition for Writ
of Habeas Corpus (228K .doc)
• Petition for Writ
of Habeas Corpus (292K .wpd)
• Petition for Writ
of Habeas Corpus (472K .PDF)
• Petition
for Writ of Certiorari (1.6 MB PDF)
Sample Notices & Motions
• Application
for Order Permitting Preparation of a Settled Statement (132K
PDF)
• Application
for Transmittal of Exhibit (176K PDF)
• Application
for Extension of Time to File Opening Brief (36K
.doc)
• Application
for Extension of Time to File Opening Brief (8K
.wpd)
• Applicarion
for Extension of Time to File Opening Brief (32K PDF)
• Application
to Augment the Record (80K .doc)
• Application
to Augment the Record (16K .wpd)
• Motion
for the Production of Additional Evidence (536K
PDF)
• Motion
for Release on Bail During Pending Appeal (164K
.doc)
• Motion
for Release on Bail During Pending Appeal (32K .wpd)
• Motion
for Release on Bail During Pending Appeal (60K PDF)
• Notice
of Appeal (56K .doc)
• Notice
of Appeal (16K .wpd)
• Notice of Appeal (32K
PDF)
• Petition
for Declaration of Factual Innocence (68K .doc)
• Petition
for Declaration of Factual Innocence (60K .wpd)
• Petition
for Declaration of Factual Innocence (84K PDF)
• Proposed
Statement on Appeal (52K .doc)
• Proposed
Statement on Appeal (12K .wpd)
• Proposed
Statement on Appeal (40K PDF)
• Stipulated
Final Statement (44K .doc)
• Stipulated
Final Statement (24K .wpd)
• Stipulated
Final Statement (40K PDF)
For additional motions, or for consultation
on a specific appellate issue you may be considering, please
call David Carico at (415) 931-1140.
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