Caruço Law
PLLC
Appeals
Admitted to practice before:
- All Florida state trial and appellate courts
- All federal District Courts in Florida
- U.S. Court of Appeals for the Eleventh Circuit
- U.S. Court of Appeals for the Armed Forces
- Supreme Court of the United States
1
- Review the entire record of trial
- Assess all preserved and potential unpreserved errors at trial
- Perform legal research in support, or defense, of alleged prejudicial errors committed at trial
- Draft a persuasive appellate brief addressing issues identified in the review of the record or in response to Appellant’s initial brief.
- Ask for oral argument and address the judiciary’s concerns regarding the identified issues
- Identify conflicts in decisions that require resolution by the relevant court of last resort
- Draft amicus briefs on behalf of client’s with a demonstrable interest in a pending appellate case to which it is not a direct party, but will be impacted by the court’s decision
2
- Pre-trial strategy sessions with trial counsel to discuss preserving the record for a potential appeal in tandem with laying the groundwork to defeat opposing party's likely claims on appeal
- Craft detailed motions to address procedural, evidentiary, statutory, constitutional, and other legal questions critical to preserving a client's rights on appeal.
- Sit at counsel table during trial to assist in preserving the record for attack or defense on a potential appeal
3
- Rule 3.850 Motions
- Trial court judgment entered (or sentence imposed) in violation of the Constitution, federal law, or Florida law
- Plea was involuntary
- Lack of jurisdiction by trial court to enter judgment or impose sentence
- Adjudged sentence exceeded the maximum authorized by law
- The judgment or sentence is otherwise subject to collateral attack
- Extraordinary Writs
- When justice requires an option not otherwise available
- Writ of Certiorari
- Writ of Habeas Corpus
- Writ of Mandamus
- Writ of Prohibition
- Writ of Quo Warranto
- All Writs Act