Docket Exhibits - Mass. Injustice.Org

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WORCESTER, SS. COMMONWEALTH OF MASSACHUSETTS VS. MICHAEL G. ELBERY, Defendant COMMONWEALTH OF MASSACHUSETTS SUPERIOR COURT DEPARTMENT CRIMINAL ACTION NO: WOCR93-00135 MOTION TO SEQUESTER WITNESSES ! I i i The defendant, Mlchael G. Elbery, hereby moves this Honorable Court that all witnesses in the above entitled case be sequestered, includlng but not llmited to that portion of the trial related to opening statements. MICHAEL G. ELBERY BY HIS ATTORNEY / ; -':-;'"" "- Lo i.$, P. SHUMWAY, GIGUERE, BYRNE, FOX & ALOISE, P.C. 19 Cedar Street worcester, MA 01609 / (508) 756-2323 B.B.O. No.: 016040 Dated: June 21, 1993.
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-------- , , [ ", I , , , I Accordi
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worcester,ss. COMMONWEALTH OF MASSA
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94-P-740 Appeals Court COMMONWEALTH
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The statute, G. L. c. 265, § 15, c
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COMMONWEALTH OF MASSACHUSETTS Worce
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Supreme Judicial Court of Massachus
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1. This defendant/petitioner, Micha
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Certificate of Service I the defend
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Exhibit H-The Bolton Report, Report
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Toomey declines to enforce Massachu
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Toomey allowed his biased clerk- Jo
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how else would Toomey and Aloise kn
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Certificate of Service I the movean
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"< J /) (...,
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STATEMENT OF JURISDICTION This is a
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SUNIMARY OF ARGUMENT ARGUMENT The o
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There is no discretion for Judge Da
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Commonwealth Worcester s.s. Crimina
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judge a total of 20 months (assignm
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mjuries he allegedly sustained by T
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.l1ultiple punches at him and then,
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ju.stice. See id. at 173-174. The j
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ineffective assistance of counsel,
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defendant to shoyv: (1) witness was
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his OViD opinion and misstating fac
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"am 1right" especially with leading
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to one year for being a disorderly
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Jttl Commonwealth of Massachusetts
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v. Lucey, 469 U.S. 387, 105 S. Ct.
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In his motion, Elberry also claimed
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various trial witnesses, see the re
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ecord deciphered - those records ar
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(76) as her authority. First, Agurs
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If the jury was told the truth, tha
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happen in an American Court room. G
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Certificate of Service I the defend
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Docket Exhibits - Mass. Injustice.Org

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