Thankx. Also, both Federal and State Constitutions are mentioned and followed in Motions.
DEFENDANTS MOTION FOR DISCLOSURE OF THE
JUVENILE RECORDS OF PLAINTIFFS WITNESSES
Failure to provide this information to Defendant will deprive him of his rights under the State and Federal
U.S. Constitution Amendments. V, VI, VIII, and XIV;
Ohio Constitution Article I; 1, 2, 5, 10, and 16.
Some interesting things in the
"Civilian Clothes" Motion:
DEFENDANTS MOTION TO PERMIT ACCUSED TO APPEAR
IN CIVILIAN CLOTHING AND WITHOUT RESTRAINTS
AT ALL PROCEEDINGS
LOOKS DANGEROUS
This Court must
guard against heightened security precautions that make the accused look like a dangerous individual. If Defendant is convicted, then during the mitigation phase excessive security and/or restraints create the risk that jurors will consider future dangerousness when adjudicating the sentence.
Moreover, the prospective jurors will likely infer that
Defendant is heavily guarded because he is dangerous.
STUN BELT ARGUMENT
Defendant specifically asserts that there is no justification for restraining him by use of a stun belt, the prospective jurors will likely infer that Defendant is restrained because he is dangerous.
The Ohio Supreme Court has reversed cases where a stun belt has not been amply justified on the record.
Like chains and shackles, a stun belt remains visible to the public and to jurors,
and it restrains the defendant in part with psychological fear and anxiety that manifests itself in a defendant's demeanor in ways against the constitutional rights at issue (in the case of Deck.)
OTHER REASONS AGAINST RESTRAINTS
....Indeed, they can interfere with a defendant's ability to communicate with his lawyer
and participate in his own defense, say by freely choosing whether to take the witness stand on his own behalf.
Finally, compelling the accused to stand trial in prison garb operates usually against those who cannot post bail before trial.
Ironic much? 
