Memos and Pleadings

Attorneys are encouraged to share memos, training materials, and sample pleadings.   If you would like to add to these resources or have suggestions for these resources , contact Jason Nicholas.

The following documents were provided to MAJDC by the Kanawha PD for use by juvenile practitioners in WVA. Defenders are encouraged to use these documents as a starting point for their own research and pleadings:


1. Juvenile Discovery Practice

a. WV Rules of Juvenile Procedure

b. WV Rule 21

c. Addendum to Juvenile Discovery Practice (Police reports as public records; preservation of evidence and instruction on its destruction; expert witnesses)

d. WV Sample Motion for Discovery

e. WV Sample Response to Discovery Request

f. WV Sample Brady Motion for Exculpatory Evidence


2. Sample Orders

a. WV Agreed Order to Dismiss Based on the Child Receiving a High School Equivalency Diploma

b. WV Agreed Order to Take High School Equivalency Test (GED/TASC)

c. WV Agreed Order to Suspend Probation Provision (to allow youth to possess a gun for the purposes of hunting)


3. Role of Counsel

a. WV Interacting with Judges, Prosecutors, Probation Officers, Etc.

b. WV Law on Role of Juvenile Counsel


4. Detention

a. WV Tips for Juvenile Detention Hearings


5. Sentencing Reform Bill

a. WV Juvenile Sentencing Reform Bill


6. Sample Jury Instructions

a. WV Juvenile Jury instructions Template