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 (831) 646-0372.