East Aurora, New York Criminal Lawyers

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Michael Charles Cimasi
Michael Charles Cimasi
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New York Criminal Law Attorney

My practice pattern at the Cimasi Law Office is focused on DWI, criminal defense, and traffic matters (e.g. speeding, mechanical violations, unlicensed operation, etc.) in courts across Western New York. I... Read More »
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Michael Meredith Mohun
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Cowlesville, NY Criminal Law Lawyer with 37 years experience
(585) 937-8987 344 Kern Road
 Cowlesville, NY 14037
Criminal and DWI
State University of New York - Buffalo
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My practice is limited to the defense of those charged with crimes. I practice in State Courts,throughout Western New York
Michael A. Klima
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Orchard Park, NY Criminal Law Lawyer with 4 years experience
4063 North Buffalo Road
 Orchard Park, NY 14127
Criminal, DWI, Probate and Traffic Tickets
SUNY Buffalo Law School
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Michael Charles Cimasi
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Amherst, NY Criminal Law Attorney with 4 years experience
(716) 560-1171 66 Park Circle
 Amherst, NY 14226
Free ConsultationCriminal, DWI, Landlord Tenant and Traffic Tickets
State University of New York - Buffalo
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My practice pattern at the Cimasi Law Office is focused on DWI, criminal defense, and traffic matters (e.g. speeding, mechanical violations, unlicensed operation, etc.) in courts across Western New York. I also represent clients on parole violations and landlord-tenant matters. I am a highly meticulous and diligent practitioner who seeks to provide dedicated service to each client, regardless how big or small the matter. I am always available by phone, and there is no fee for initial consultations.

I also teach courses in sociology and legal studies to undergraduates at the University at Buffalo ("UB") and Buffalo State College....
Matthew Borowski Esq
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Buffalo, NY Criminal Law Attorney with 4 years experience
(716) 330-1503 295 Main St,
Suite 1060
 Buffalo, NY 14203
Criminal, Appeals and Immigration
Drexel University
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The first-generation son of immigrants, Matthew Borowski is a knowledgeable and compassionate lawyer. He has been featured on news media outlets including CNN, NBC, ABC, and The Buffalo News for his asylum and refugee work. Matthew is licensed in both the U.S. and Canada. He is well-versed in immigration matters including deportation defense, family and business immigration including NAFTA/TN visas and rehabilitation/waivers, federal criminal defense, and post-conviction relief. He appears before Immigration Courts, the Board of Immigration Appeals, USCIS, New York state courts and the U.S. Court of Appeals for the Second Circuit. Borowski Law is located in downtown Buffalo,...
Carl Scott Spector
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Buffalo, NY Criminal Law Attorney with 31 years experience
(716) 631-9999 70 Niagara Street
 Buffalo, NY 14202
Free ConsultationCriminal and DWI
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I'm Carl Spector and I have been providing my client's with effective defense in criminal law cases since 1986. I worked as an Assistant District Attorney for six years in Bronx County, New York. While working there I learned all about how the prosecutors office and the police work within the criminal justice system. I attended State University of New York at Buffalo where I received my B.A. degree. I then went to Nova Southeastern University in Florida where I received my law degree (J.D.). I am currently admitted to practice law in New York and New Jersey and am...
(800) 879-6410 30 Wall Street
8th Floor
 New York, NY 10005
Dennis Charles Gaughan
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Hamburg, NY Criminal Law Attorney with 33 years experience
(716) 648-8000 6161 South Park Ave
 Hamburg, NY 14075
Free ConsultationCriminal, Appeals, Bankruptcy and DWI
New York Law School
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We chose to remain a small law office to provide personal, dedicated and aggressive service to our clients. My office costs a few dollars more but excellent service takes time and strategy. Offsetting our higher fees we have payment plans. We have seven lawyers working together to get the best solutions. As a small firm we call upon all areas of the law to form a comprehensive strategy and plan. As in a game making the right move determines the outcome of the case. A divorce case is often helped by a bankruptcy or our tax law knowledge. We create...
Steven Michael Cohen
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Amherst, NY Criminal Law Attorney with 29 years experience
(716) 636-7600 2410 N Forest Rd
Ste 301
 Amherst, NY 14068
Criminal
State University of New York at Buffalo School of Law
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From New York City originally and now residing and practicing law in Buffalo, New York, Mr. Cohen has been successfully trying civil and criminal cases, including numerous civil rights and constitutional law cases, for over 25 years. In addition to corporate clients and individual litigation clients, he regularly represents local, state and federal law enforcement officers from numerous agencies, defending them in civil, criminal and administrative proceedings. Admitted to practice in the States of New York and Pennsylvania, he has been admitted pro hac vice to conduct trials in many other states. Mr. Cohen is frequently brought in as...
Harry N Konst
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Lancaster, NY Criminal Law Lawyer with 17 years experience
(716) 601-1000 5511 Broadway Street
Lancaster, New York USA
 Lancaster, NY 14086
Free ConsultationCriminal, Business, Divorce and Immigration
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Founded in Upstate New York, Konst Law serves clients in from Manhattan to Los Angeles, California, as well as international clients seeking to invest in businesses in the United States. The firm provides corporate, real estate, and business legal services, as well as investment immigration assistance. The experienced lawyers at Konst Law have successfully counseled a wide variety of clients in matters ranging from starting a company to attaining immigration goals.
Michael Timothy Dwan
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Depew, NY Criminal Law Attorney with 13 years experience
(716) 870-4030 5136 Transit Road
Suite 100
 Depew, NY 14043
Criminal, DWI, Real Estate and Traffic Tickets
State University of New York - Buffalo
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Michael T. Dwan is the senior partner at the Law Offices of Dwan & Counter. Mr. Dwan oversees Real Estate, Estate Planning and Criminal Defense departments at Dwan & Counter. Mr. Dwan is one of the top trial lawyers in Erie County.

Mr. Dwan is the son of longtime Judge and trial attorney Timothy J. Dwan.

Mr. Dwan received his undergraduate degree from Niagara University, and received his J.D. from the University of Buffalo Law School. He has also served as an adjunct criminal justice professor at Erie Community College and is frequently asked to be a guest lecturer at...
(716) 870-4030 115 Elmwood Avenue
 Buffalo, NY 14201
David Centeno
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Buffalo, NY Criminal Law Lawyer with 12 years experience
(866) 830-2064 300 International Drive, Suite 100
 Buffalo, NY 14221
Free ConsultationCriminal and Divorce
Benjamin N. Cardozo School of Law
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My name is David Centeno and I was born and raised in New York City. Today, I'm proud to serve as a divorce and family lawyer throughout New York State for people like you. I use my experience to help you get through your NY uncontested divorce, which can be a very stressful time. I'm not just a NY divorce lawyer, I'm a NY family man. As a husband and father, I know and appreciate the value of family. I understand what you have at stake and will work hard to protect you and your family through...
(866) 830-2064 22 Cortlandt St., 16th Fl.
 New York, NY 10007
140 Broadway
46th Fl.
 New York, NY 10005
Emily Trott
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Buffalo, NY Criminal Law Lawyer with 21 years experience
(716) 362-1148 The Plaza Suites
70 Niagara Street, Suite 210
 Buffalo, NY 14202
Criminal, Domestic Violence, Juvenile and White Collar Crime
Franklin Pierce Law Center
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John I LaMancuso
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Buffalo, NY Criminal Law Attorney with 5 years experience
(716) 708-4409 37 Franklin St #800
 Buffalo, NY 14202
Free ConsultationCriminal, DWI, Personal Injury and Workers' Comp
SUNY Buffalo Law School
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Mr. LaMancuso was born and raised in Western New York and practices in Lewis & Lewis' Jamestown, Olean, and Buffalo offices. He is committed to living and working in Western New York, and his aim is to ensure that the people of our community have a tenacious and effective advocate they can turn to when faced with a difficult legal issue.

Mr. LaMancuso focuses his practice on personal injury litigation, Workers' Compensation, and criminal defense.

Practice Areas:

Personal Injury - Car Accidents, Slip and Fall Accidents, Catastrophic Injuries, Ladder Accidents, Scaffold Accidents, Construction Site Injuries, Motorcycle Accidents, Trucking Accidents, Boating Accidents, Defective Products,...
(716) 708-4409 208 Pine St.
 Jamestown, NY 14701
(716) 708-4409 174 N Union St
 Olean, NY 14760
(716) 708-4409 2065 River Rd
 Niagara Falls, NY 14304
Michael Anthony Rossi
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Buffalo, NY Criminal Law Attorney with 37 years experience
(716) 854-5555 68 Niagara Street
 Buffalo, NY 14202
Criminal, DWI, Divorce and Personal Injury
State University of New York - Buffalo
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A tough, aggressive trial lawyer, Michael Anthony Rossi began practicing in New York in 1981 and went on to form The Rossi Law Firm. The Rossi Law firm is a “results oriented” criminal and civil litigation firm with offices in Downtown Buffalo, representing clients throughout NY State.

In his 37 years of practice, Michael has focused his expertise in the areas of serious personal injury claims, complex divorce and custody matters, and criminal and DWI defense. As senior trial counsel of the firm, Michael is a fierce advocate for his clients because he knows how important results are. He has demonstrated...
Barry Nelson Covert
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Buffalo, NY Criminal Law Lawyer with 28 years experience
(716) 849-1333 42 Delaware Avenue
 Buffalo, NY 14202
Criminal, Appeals, DWI and White Collar Crime
State University of New York - Buffalo
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Barry Covert focuses his practice New York State and federal criminal trials and appeals; constitutional law, including First Amendment, Second Amendment, and civil rights actions; Qui Tam Act, also known as the False Claims Act; defending against allegations of scientific misconduct, scientific fraud, research misconduct, research fraud, plagiarism, and fabrication of evidence; defense of professional licensing, including for attorneys, doctors, and nurses. Mr. Covert has represented numerous professional clients relating to licensing issues and defended a prominent research scientist against allegations of scientific fraud and misconduct involving several federally funded research projects involving the Office of Research Integrity (ORI)....
Robert Friedman
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Buffalo, NY Criminal Law Attorney with 39 years experience
(800) 729-4571 70 Niagara Street
 Buffalo, NY 14202
Free ConsultationCriminal, DWI, Divorce and Personal Injury
Hamline University
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My Law Firm Partner and I have been working with Buffalo and WNY residents for almost four decades. So we're not surprised when clients tell us that we've helped a member of their family or neighbor in the past. We have offices in: Buffalo NY Rochester NY Akron NY Williamsville NY Batavia NY West Seneca NY Niagara Falls NY And our expertise is wide - just take a look at our practice areas and how we can help you. BUFFALO AREA PERSONAL INJURY & ACCIDENTS * Highway Accident: * Industrial Accident: * Jet Ski Accident:...
(800) 729-4571 70 Linden Oaks
3rd Floor
 Rochester, NY 14625
(800) 729-4571 7510 Porter Road
 Niagara Falls, NY 14303
(800) 729-4571 8207 Main Street
Suite 13
 Williamsville, NY 14221
(800) 729-4571 3686 Seneca Street
 West Seneca, NY 14224
(800) 729-4571 113 Main Street
Suite 3
 Batavia, NY 14020
(716) 542-5444 74 Main Street
 Akron, NY 14001
Mr. Frank M Bogulski Esq.
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Hamburg, NY Criminal Law Lawyer with 16 years experience
(716) 649-0090 265 Union St
Ste 203
 Hamburg, NY 14075
Criminal, Business, DWI and White Collar Crime
SUNY Buffalo Law School
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Frank M Bogulski was born and raised in Hamburg, NY along the lakeshore where he enjoyed water sports and played ice hockey. He graduated from Frontier High School and received a United States Army ROTC scholarship to attend Cornell University. While at Cornell, Frank studied economics and business and received a Bachelor of Science degree in Industrial and Labor Relations. He was active in the Army ROTC program and completed the United States Army Advance Camp at Fort Brag, NC. Following his educational career at Cornell, he was commissioned as a United States Army officer and served in the military...
(716) 649-0090 286 Delaware Ave
Ste 203
 Buffalo, NY 14202
Frank Stephen Ieraci
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Buffalo, NY Criminal Law Attorney with 31 years experience
(716) 832-7777 2140 Eggert Rd
 Buffalo, NY 14226
Free ConsultationCriminal, Bankruptcy, Divorce and Family
State University of New York - Buffalo
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A graduate of Cornell University and the University of Buffalo Law School, Mr. Ieraci has been a practicing attorney in the Buffalo/Niagara region since 1988. A lifelong resident of western New York, he has dedicated his practice to the representation of individuals with common legal issues.
Dominic Saraceno
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Buffalo, NY Criminal Law Attorney with 17 years experience
(716) 626-7007 534 Delaware Ave
 Buffalo, NY 14202
Criminal, DWI and Immigration
Georgia State University College of Law
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Dominic Saraceno holds both a law degree from Georgia State University Of Law and a Masters in Business Administration from the University of Buffalo. He has been practicing criminal defense law in New York State since 2001. Mr. Saraceno has often appeared on local television, the Buffalo News, and the Niagara Gazette defending his clients in high profile criminal defense cases. Mr. Saraceno’s aggressive defense of his clients has helped many of his clients minimize their sentences or have charges dismissed outright. Dominic Saraceno has been a member of the Erie County Bar Association and the New York State Defender’s Association...
James David Hartt
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Williamsville, NY Criminal Law Lawyer with 16 years experience
(716) 400-3260 1967 Wehrle Drive
Suite 1
 Williamsville, NY 14221
Free ConsultationCriminal, Civil Rights, Education and Employment
Chicago-Kent College of Law, Illinois Institute of Technology
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Attorney James D. Hartt represents victims of employment discrimination statewide. He has significant experience representing clients in the NYS Division of Human Rights, EEOC and in State and Federal Courts. Call Attorney James D. Hartt today to set up your free initial telephone consultation.
With Offices in Rochester, Buffalo, Syracuse and a Satellite Office in Manhattan, Attorney James D. Hartt is proud to offer his legal expertise to New Yorkers statewide.

James practices in several other areas of law, including but not limited to: criminal defense, professional licensure defense, civil litigation, education law, and others!
(585) 490-7100 290 Elwood Davis Road
Suite 290
 Liverpool, NY 13088
(585) 490-7100 70 Linden Oaks
Third Floor
 Rochester, NY 14625
David Richard Addelman
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Buffalo, NY Criminal Law Attorney with 34 years experience
(716) 856-4118 69 Delaware Ave. Suite 602
 Buffalo, NY 14202
Free ConsultationCriminal, Divorce, Family and Immigration
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Since 1984, David R. Addelman, Esq. has represented both individual and corporate clients in various areas of law which include criminal and civil litigation (personal injury, accident cases), divorce, real estate, immigration, estates and bankruptcy. Applying energy, experience, and resourcefulness to every project we accept, we are dedicated to your success. Mr. Addelman is experienced in handling Immigration court cases (removal and/or deportation proceedings) as well as criminal defense representation (in State and Federal courts).
Paul Cambria Jr
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Buffalo, NY Criminal Law Attorney with 45 years experience
(716) 849-1333 42 Delaware Avenue
 Buffalo, NY 14202
Criminal, Appeals, DWI and White Collar Crime
The University of Toledo College of Law
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Paul J. Cambria, Jr. is recognized as one of the nation's preeminent attorneys. He focuses his practice in the areas of criminal trials, criminal appeals, constitutional law, First Amendment law, zoning and land use, antitrust, and professional licensing defense. Mr. Cambria has built a strong reputation for successfully representing individuals and businesses in complex, high-profile cases at all levels of the courts, including state, federal, and the United States Supreme Court. Mr. Cambria's practice is nationwide, and he divides his time between the firm's offices in Buffalo and Los Angeles. He has represented many prominent individuals, including the...
John Mark Dudziak
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Depew, NY Criminal Law Attorney with 21 years experience
(716) 795-8600 4640 Broadway
 Depew, NY 14043
Criminal and DWI
Thomas M. Cooley Law School
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Annick T Koloko Esq
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Buffalo, NY Criminal Law Attorney with 11 years experience
(716) 200-1720 69 Delaware Avenue
608
 Buffalo, NY 14202
Criminal, Business and Immigration
Franklin Pierce Law Center
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Kyle Calabrese
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Hamburg, NY Criminal Law Attorney with 23 years experience
(716) 649-3311 265 Union St
 Hamburg, NY 14075
Criminal, DWI, Family and Traffic Tickets
Western Michigan University Cooley Law School
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Andrew S. Tabashneck
Claimed Lawyer ProfileQ&ASocial Media
Buffalo, NY Criminal Law Lawyer
(716) 526-7405 348 Sanders Road
 Buffalo, NY 14216
Free ConsultationCriminal, Divorce and Family
SUNY Buffalo Law School
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Free Consultations 24/7. Affordable Payment Plans. Divorce and Criminal Lawyer in Buffalo NY. Call Andrew Tabashneck direct at (716) 526-7405.
(585) 484-0140 46 Delancey Drive
 Geneva, NY 14456
Robert Ross Fogg Esq.
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Buffalo, NY Criminal Law Lawyer with 16 years experience
(716) 853-3644 69 Delaware Avenue
Suite 600
 Buffalo, NY 14202-3812
Criminal, DWI, Immigration and Personal Injury
SUNY Buffalo Law School and SUNY Buffalo Law School
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Robert Ross Fogg is a criminal defense attorney in Buffalo, NY who personally handles each of his clients’ cases from start to finish. He has used his knowledge, dedication, and tenacity to get his clients the best possible outcome since 2002.
Michael Ranzenhofer
Claimed Lawyer ProfileBlawgsearch
Buffalo, NY Criminal Law Lawyer with 38 years experience
(716) 631-9999 70 Niagara Street
 Buffalo, NY 14202
Free ConsultationCriminal, DWI, Divorce and Family
State University of New York - Buffalo
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My name is Mike Ranzenhofer. I assist residents of the Buffalo and WNY area with their legal needs in three specific practice areas. They are: * Injury Law * Divorce and Family Law * DWI and other Crimes I am one of the managing partners of Friedman & Ranzenhofer. Our firm has been helping Buffalo and WNY area folks since the late 1950's so it's likely we've helped a family member or friend in the past. In fact, we're told numerous times weekly just that. Area residents come to us for help for...
(716) 332-7106 534 Delaware Ave
 Buffalo, NY 14202
(716) 542-5444 2768 Niagara Falls Blvd
 Niagara Falls, NY 14221
(585) 377-5504 70 Linden Oaks
3rd Floor
 Rochester, NY 14625
(585) 343-0746 113 Main Street
 Batavia, NY 14021
Kevin Scott Mahoney
Claimed Lawyer ProfileSocial Media
Amherst, NY Criminal Law Lawyer with 21 years experience
(716) 636-7600 2410 N Forest Rd
Ste 301
 Amherst, NY 14068
Criminal, DWI, Divorce and Traffic Tickets
State University of New York at Buffalo School of Law
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Mr. Michael W. Cole
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Alden, NY Criminal Law Attorney with 17 years experience
(716) 937-9150 13349 Broadway Street
 Alden, NY 14004
Criminal, Bankruptcy, DWI and Estate Planning
SUNY Buffalo Law School
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J. John Sebastian
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Buffalo, NY Criminal Law Lawyer with 27 years experience
(716) 209-3141 70 Niagara Street
 Buffalo, NY 14202
Criminal, DWI, Traffic Tickets and White Collar Crime
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Sebastian Law Firm is a full service criminal and traffic ticket defense law firm committed to aggressively advocating for the rights and interests of our clients. Based in Buffalo, the office is proud to serve the Greater Buffalo Area and all of the surrounding Western NY counties. Mr. Sebastian is a native of New York State . He was born and raised in the NYC metro area. After graduating from law school and passing the NY Bar Exam, Sebastian gained valuable New York State Criminal and Traffic Law experience by serving as...
Mr. Alejandro Gutierrez Esq.
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Buffalo, NY Criminal Law Lawyer with 16 years experience
(716) 877-4276 745 Englewood Avenue
 Buffalo, NY 14223
Criminal and Immigration
SUNY Buffalo Law School
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The goal of Alejandro Gutierrez, Esq., is to make permanent residents of United States. He limits his practice to United States Immigration Law including the related criminal matters. He practices before the Citizenship and Immigration Services and the U.S. Immigration Courts throughout the United States, including appeals before the Department of Homeland Security, the Board of Immigration Appeals, U.S. District Courts, and U.S. Courts of Appeals. He is admitted to practice in the courts of the State of New York, U.S. District Court for the Western District of New York, and the U.S. Court of Appeals for the...
(716) 877-4276 110 Wall Street, 11th Floor
 New York, NY 10005-3817
Gary M. Phillips
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Buffalo, NY Criminal Law Lawyer with 8 years experience
(716) 849-5915 112 Franklin Street
 Buffalo, NY 14202
Free ConsultationCriminal, Business and Family
State University of New York - Buffalo
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David Pajak
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Alden, NY Criminal Law Attorney with 35 years experience
(716) 630-0400 13179 Broadway
Suite 2
 Alden, NY 14004
Free ConsultationCriminal, Appeals, Personal Injury and Products Liability
SUNY Buffalo Law School
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Harvey Frederick Siegel
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Buffalo, NY Criminal Law Attorney with 21 years experience
(716) 883-4800 88 West Utica Street
 Buffalo, NY 14209
Criminal, DWI, Family and Personal Injury
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Tara S. Evans Esq.
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(716) 400-2638 266 Elmwood Avenue #738
 Buffalo, NY 14222
Criminal, Business, DWI and Family
State University of New York - Buffalo
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Let the inside knowledge that I gained while working for years as a probation officer in Erie County work to your benefit. I can charge more reasonable fees than many attorneys as I am a solo practitioner with little overhead expenses. I am experienced in many areas of the law but my focus is on criminal law, family law and civil law. Hire me and get the caring and dedicated representation that you deserve.
Stephen Keith Underwood
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West Seneca, NY Criminal Law Lawyer with 19 years experience
(716) 656-7676 1395 Union Road
 West Seneca, NY 14224
Criminal, Bankruptcy, DWI and Traffic Tickets
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Stephen K. Underwood is a Buffalo New York lawyer that practices in the New York State and Federal Court systems. Mr. Underwood is a graduate of the Binghamton University School of Management with a concentration in Finance (B.S. 1992) and obtained his Juris Doctorate from OCU School of Law in 1997. Mr. Underwood was duly licensed and admitted to practice law in the State of New York in 1998.
John Vaughan Millane
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Buffalo, NY Criminal Law Attorney with 30 years experience
(716) 689-4449 300 International Drive
Suite 100
 Buffalo, NY 14221
Criminal, Divorce, Domestic Violence and Traffic Tickets
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John Patrick Pieri
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Buffalo, NY Criminal Law Lawyer with 44 years experience
(716) 854-3207 484 Delaware Ave
CORNELL Mansion
 Buffalo, NY 14202
Criminal, DWI, Divorce and Real Estate
University of Kentucky College of Law
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More than 40 years of litigation experience with an emphasis on high asset divorce,criminal trials and appeals,dwi/dui and estates.Member National Association of Criminal Defense Lawyers,American Academy Matrimonial Lawyers.Rated AV Martindale Hubbell for ethics and ability.
(716) 854-3207 NY
Stephen Michael Hughes
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Buffalo, NY Criminal Law Attorney with 38 years experience
295 Main Street
Suite 1076
 Buffalo, NY 14203
Criminal, DWI, Insurance Claims and Traffic Tickets
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Richard Leff
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Buffalo, NY Criminal Law Lawyer with 44 years experience
(716) 854-3321 Buffalo, NY 14203
Criminal, Bankruptcy, Business and DWI
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Criminal Lawyers in Nearby Cities

Criminal Lawyers in Nearby Counties

FAQ Lawyers Get Listed

East Aurora Criminal Legal Aid & Pro Bono Services

Erie County Bar Association Volunteer Lawyers Project
(716) 852-8687
Buffalo, NY

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Related Practice Areas

DWI
Traffic Tickets
White Collar Crime

Arrested or facing criminal charges?

Criminal law addresses the government's prosecution of individuals who have been accused of committing a crime. Such laws may be federal, state, or local. The prosecution represents the people of a particular jurisdiction, and acts on behalf of the government by bringing a case against an accused. Under the U.S. Constitution, a person accused of a crime may have the right to a criminal defense attorney during interrogations and certain other times before and during a trial.

Whether you are under police investigation, have been arrested, or are facing charges, having an advocate familiar with the criminal justice system.

Most jurisdictions classify crimes as felonies or misdemeanors, with felonies being the more serious offenses with the possibility of more severe sentences. Some criminal lawyers focus on a specific area of criminal defense law, such as white-collar crime, drug offenses, theft crimes, or violent crimes. You should consult with a criminal defense lawyer early on in the process to preserve options, such as diversion programs or plea bargains.

When hiring a criminal defense attorney, you should evaluate the experience and fee structure of the attorney. Some offer a free consultation to discuss your case.

Accomplice liability: If a person aids, assists, or encourages another in the commission of a crime, they are criminally liable as an accomplice to the crime.

Self-defense: The claim that an act otherwise criminal was legally justifiable because it was necessary to protect a person or property from the threat or action of another.

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