Model Appellate Motions
Docketing and Late Docketing
- Docketing and Late Docketing Tips
- Intern Memo on Late Docketing
- Motion to Dismiss for Failure to Docket
- Motion to Enlarge Time for Docketing
- Motion to Waive Docketing Fee Appellant-Children
- Motion to Waive Docketing Fee Appellant-Mother
Late Notice of Appeal
- Trial Court Motion to File Late Notice of Appeal
- Appeals Court Petition to File Late Notice of Appeal
- Late Notice of Appeal, Affidavit of Child’s Counsel
- Late Notice of Appeal, Motion to Waive Docketing Fee
- Intern Memo on Late Notice of Appeal
Motions for New Trial/Ineffective Assistance of Counsel (see our due process issue bank here for more information on Ineffective Assistance of Counsel)
- Intern Memo on IAC 2008
- Intern Memo on IAC in Other Jurisdictions
- Memo re Trial Atty Roles Duties when IAC Raised
- Motion for Leave from Appeals Court to File New Trial Motion
- Motion for New Trial (Mother) 60(b)(6)
- Motion for New Trial (Mother) 60(b)(6)
- Motion for New Trial (Mother) 60(b)(6)
- Motion to Vacate and New Trial (Father) 60(b)(4)
- Motion to Re-Open Evidence (Father) 60(b)(5)
- Motion to Re-Open Evidence (Mother) 60(b)(6)
- Motion for New Trial – Aff of Trial Counsel
- Motion for New Trial – Aff of Mother
- Motion for New Trial – Aff of (Uncalled) Witness
Other Motions
- Children’s Motion to Join Father’s Brief and Argue
- Motion to Approve Briefing Schedule
- Motion to Consolidate Appeals
- Motion for Continuance of Oral Argument
- Motion to Enlarge Briefing Deadline
- Motion to Exceed 50 Pages
- Motion to File and Serve Fewer Copies of RA and Trans Volumes
- Motion to Stay Briefing for Settlement (and Aff of Counsel)
- Motion for Stay Pending Appeal (in App Court)
- Motion to Strike Brief (and Memo in Support)
- Motion to Supplement Record Appendix
- Motion to Vacate Assembly
- Motion to Waive All Copying Fees
- Motion to Withdraw Appeal (and Aff of Client)
- Opposition to Motion to Stay Appeal
- Status Report and Motion for Briefing Schedule
- Status Report to Single Justice