The following definitions are an integral part of these requests for documents and are applicable throughout this request.

"Document", either singular or plural, is defined as any and all originals, or if not available, true copies of all memorandum, reports, appraisals, evaluations, correspondence, receipts, payment vouchers, accounting records and books, communications, interoffice communications, intra-office memorandum, inter-agency communications, electronic recordings including computer generated and/or preserved recordings, video recordings, audio recordings, summaries of conversations, summaries of memorandum of meetings or conferences, list of persons attending meetings or conferences, diaries, records or summaries of interviews, investigation or reports, summaries of negotiations, agreements, contracts, agency rules, agency policies, office manuals, invoices, canceled checks, journals, ledgers, file cards, index cards, indices, deposit slips, data processing cards, computer or business machine printouts, electronic recordings, work papers, statements, financial statements whether audited or unaudited, leases, speeches, information provided to the media, press releases, advertisements, pamphlets, circulars, professional letters, annual and other reports, documents filed with government agencies, reports of experts and research personnel, draft and preliminary copies of any of the foregoing, marginal comments appearing in any document and all other writings and data compilations, including any written, printed, recorded or graphic matter, photographic matter or similar reproductions, however produced or reproduced or tangible things upon which words or phrases are affixed.

  The effective use of subpoenas in litigation is a little used skill. The requirement to bring documents aspect of the subpoena should be written much as the concentric statements concept in Action Motions 2K10.  
  In fact, the subpoena should be a modified motion. It should command the person being subpoenaed to bring numerous items with him/her to the Action Motions 2K10 hearing to be used as Energized Evidence.

  Action Motions 2K10 need evidence. This evidence is needed to ignite the presentation of the motion and to give the record teeth. Many lawyers “argue” motions. A motion that is merely argued is just another motion, it is not a Action Motion 2K10.
  To produce the Energized Evidence required to qualify a motion as an Action Motion 2K10 it is necessary to understand a  few other concepts.

	CHARISMA  (ke riz' ma)  the special quality that gives an individual influence, charm, or inspiration over large numbers of people.

	POWER  (pou' er)  the ability or capacity to act or perform effectively.

  Time is a critical element in the presentation of Action Motion 2K10. There are some limitations on when motions may be presented, but often you can control both the time of filing and the time of presentation.
  To present motions properly, evidence should be presented on all factual matters raised by the motion and any other necessary facts that affect the issues. It is not sufficient to simply "argue" motions.
 If funds are needed to obtain evidence and to present it properly, specific motions for funds, supported by evidence to show the need for funds, should be made. When possible, motions for funds should be frequently renewed with a specific showing of need. If the client is not completely indigent and can pay attorney's fees or other fees for defense services, this should not be assumed to preclude the need for funds from the State to adequately defend the charges.
 If the trial court refuses to hear evidence on behalf of any factual matters contained in the motions, or if a denial of funds makes it impossible to present all of the evidence needed, a specific offer of proof of what evidence could have been presented -- framed in a manner which is favorable to the accused -- should always be made to the trial court.
 There are certain kinds of motions that should be presented out of the hearing of the public. These motions can be presented in camera. The in camera presentation of a motion can be the subject of a motion itself. The restrictions on an in camera motion can include not only a hearing outside the presence of the public, but also, a sealed decision together with a concealment of both the motion, and the motion to have the motion heard in camera.
 Examples of this type of motion are motions in limine and motions for directed verdicts of acquittal. These in camera motions shield the client from the adverse effects of both a denial of the motion and the prejudicial evidence that may be presented during the motion hearing. The accused also has the right to an ex parte hearing on an application for funds.
 At any stage of the proceeding where the rights of the person accused are affected by the denial of a prior motion, you should renew the motion and supplement it with additional evidence, or, if prohibited from presenting evidence, make an offer of proof.
 The ways in which motions should be formulated to communicate information depend in great part upon an individual's communication skills and understanding of the many ways in which messages are sent and received.
 We may be familiar with the use of psychologists to help interpret body language of potential jurors. Body language is but one of the many "languages" we all speak, often unconsciously. Many other "languages" exist that can assist or affect communication by spoken word.
 There are things that allow us the security of communicating effectively.  One of these things that provides security is having a model of representation.  Another is having a strategy specialist to oversee the adherence to the goals of the model of representation.