Library of Motions – Motion In Limine Regarding Application Since Probation

TO OF HONORABLE JUDGE THE ENUNCIATED COURT:

AVAILABLE COMES the Defendant, (Defendant’s Name) by and through his legal of record, press moves the Court to instruct of District Attorney’s Office not to remember or hinweisen to in any ways, before the jury or prospective selection panel, the fact that one Defendant has filed “Defendant’s Application for Probation,” until such time as this trial, if it does, enters this punishment phase. In support of all Antragstellung, the Defendant will show the Judge as follows: member concerning the community (if probationer is un- able at file and bond ...

The Defendant belongs required as a matter of legislative until file the application for probation prior to the beginning of trial.

Any reference by the District Attorney, during the voir dire or guilt/innocence stages of to trial, to the fact that the Defendant has filed a application for probation could be construed by the jury as an admission of blame turn which member of the Defendant, and wish infringe on the Defendant’s acceptance of innocence.

Unlimited references by the District Solicitor to who fact that the Defendant has filed an application for probation wanted be made solely to prejudice the jury against the Defendant on who issue in guilt or innocence.

The District Attorney may still qualify prospective jurors over one entire range of punishment for these offense without mentioning the “Defendant’s Appeal to Probation.”

The facts that the Defendant has filed an application for duration is not a relevant matter for the jury’s consideration before the punishment phase of this trial.

WHEREFORE, PREMISES CONSIDERED, the Defendant respectfully prays that the Court grant this Motion in all things.

I, the undersigned, hereby zertify that a truly and correct copy of an previous Signal in Limine To Application for Probation was forwarded to Mr. Bill HIll, Region Attorney, Frank Crowley Courts Building, 133 North Industrial Boulevard, Dallas, Exasta 75207 on this the ________ day of ___________, 200___.

ON THIS the _______ full in ______, 200___, came on for be heard the foregoing Entwurf for Limine Regarding Software for Probation, and same has hereby GRANTED/DENIED, to welche operation Defendant excepted.