It is important to note that this “Table of Motions” section be used as a Guideline only when determining what motions may be needed in your case!    Do not try to do any of these motions without the help of an attorney!

 

 

“TABLE OF MOTIONS”

 

·        Motion for Pre-Trial Hearing to Determine Reliability of Complaining Witness Testimony

·        Motion to Determine Admissibility of Complainants Testimony

·        Motion for Autopsy of Minor Child to Include Specific Procedures; Autopsy to be Videotaped

·        Defendant’s Request for Notice of Evidence Intended for Use in Case in Chief

·        Defendant’s Proposed Jury Instruction Relating to Closed Circuit Testimony of Child Witness

·        Motion to Compel Co-Defendant Statements

·        Motion to Determine Competency of Complaining Witness

·        Motion to Suppress Confession

·        Motion to Compel Disclosure of Evidence to States Attorney by State Agents

·        Motion for Production of All Relevant Police Reports

·        Request for Discovery With Memorandum

·        Motion to Exclude Use of Anatomically Detailed Dolls

·        Motion to take Deposition of Dr.__________, A Defense Witness

·        Motion for Exparte Hearing and Determinations for Court Approved Appropriations for Fees and Expenses of Experts and Investigators

·        Motion in Limine Limiting the Number of Photographs of the Victim to Show to the Jury

·        Motion in Limine to Exclude any Testimony of the Physician Other than the Specific Physical Findings

·        Motion in Limine to Prohibit Any Display of Evidentiary Exhibits Until Proffered

·        Motion to Prohibit the Filming, Photographing or Videotaping of Defendant While He/She is in the Courtroom

·        Motion to Disqualify Counsel and Appoint Special Prosecutor

·        Motion Directing a Complete Copy of the State’s File be Turned Over to the Court for Review and Sealed for Appellate Record

·        Motion to Sever Counts

·        Motion to Suppress Defendant’s Statement

·        Motion for Disclosure of Witness Statements Prior to Trial

·        Motion for Defense Expert to Interview Complaining Witness or, in the Alternative, Be Present in Court During the Complaining Witness Testimony

·        Motion in Limine for Admissibility of Defense Expert

·        Motion of Release of Grand Jury Testimony

·        Motion in Limine to Exclude Any Uncorroborated and Unrecorded Hearsay Statements of the Complainant and/or any State Witness

·        Motion in Limine Regarding Testimony Presented to the Jury

·        Motion for Jury Questionnaire w/ Memorandum and Proposed Questionnaire

·        Motion for Deposition of Complainant

·        Motion to Exclude Testimony of Sexual Conduct

·        Motion to Exclude Admissions of Masturbation and X-Rated Tapes

·        Motion for Independent Medical Exam of the Complaining Witness

·        Response in Opposition to Closed Circuit Television Testimony

·        Motion to Require Prosecutor to Give Notice of Intent to Use “Bad Acts” Testimony Pursuant to and Motion in Limine to Determine admissibility of Said Evidence

·        Request for Pretrial Discovery

·        Motion for Bill of Particulars

·        Motion in Limine Regarding Shaken Baby Syndrome Testimony

·        Motion to Preserve and Produce Rough Notes

·        Motion to Produce Documents Used to Prepare Witness

·        Motion to Compel Complainant to Submit to Mental Examination

·        Motion for Independent Psychological Examination of Complaining Witness

·        Motion in Limine for the Admissibility of Prior Findings and Allegations of Sexual Abuse Defendant’s Former Wife

·        Motion to Suppress

·        Motion to Compel Law Enforcement Officers to Turn Over and Advise the State of all Information Acquired During the State’s Investigation

·        Motion to Compel State’s Attorney to Investigate and Disclose

·        Motion for Supplemental Discovery Request

·        Motion to Suppress With Memorandum

·        Motion to Dismiss for Selective Prosecution    

·        Motion Ordering Videotaping of all Complaining Witness Interviews and Statements

·        Motion to Dismiss for Selective Prosecution

·        Motion to Exclude Use of Prejudicial Terms

·        Motion in Limine Excluding Any Hearsay Statements Made by Complainant As She/He Had a Motive to Fabricate or Lie With Supporting Memorandum

·        Motion to Set Reasonable Bond

·        Motion to Exclude Video Testimony and Affix Standards

·        Motion for Admissibility of the Penile Plethysmograph

·        Motion for Emergency Hearing Regarding Child Abuse By Foster Parents to Complainant in the Present Matter

·        Motion for Resume’s for Each and Every Professional Who Interviewed or Questioned Each Complainant/Child Witness and Protocols Relied Upon

·        Motion for the Admissibility of Testimony of the Complainant

·        Motion in Limine to Exclude Any Witness From Mentioning Any Indicators Allegedly Observed and/or Described Concerning the Complainant in this Cause

·        Motion in Limine to Exclude and Mention of Behavioral Changes or Indicators of Complainant As Indicative of Sexual Abuse by MHP

·        Motion to Elect (Multiple Counts with Similar Import)

·        Motion For Production of Exculpatory Evidence

·        Motion in Limine to Exclude any Testimony from Suicide Hot-Line As Being Indicative of Child Molestation

·        Motion in Limine Excluding Any Mention of Complainant’s Parents Regarding Any Type of Behavioral Indicators and/or Changes As Relevant to Any Elements of the Allegations

·        Motion in Limine Excluding any Mention of Performances/Behaviors in School By Complainant As Relevant to Any Elements of the Charges Against Defendant

·        Motion to Dismiss on Grounds of Prosecutorial Misconduct

·        Motion in Limine to Exclude any Testimony of the Examining Physician

·        Motion in Limine to Exclude Any References to Polygraph Examinations

·        Notice of Defendant’s Intent to use Complainant’s Prior Sexual Activity At Trial

·        Motion to Modify and Delete Registration Requirement From Sentence

·        Demand for Discovery (Predator Hearing)

·        Motion to Dismiss (Predator)

·        Motion to Exclude (Predator)

·        Brief to Dismiss and Brief for Pretrial Release

·        Admissibility of Mother’s obsession with Molestation

·        Admissibility of Parental Alienation and Expert Testimony

·        Admissibility of Psychological Evaluation of Alleged Victim

·        Admissibility of Testimony of Mediator in Criminal Trial

·        Admit Family Court Evaluator Records and Testimony

·        Advise jury of Defendants Acquittal of Prior Sex Offense

·        Certification of Rehabilitation – Compel Evaluation, Victims Capacity to Consent to Sex

·        Complaining Witness’s Diary Copy motion Victims Sexual History

·        Copy of Admissibility of Mothers Obsession with Molestation

·        Copy of Admissibility of Parental Alienation and Expert Testimony

·        Copy of Admissibility of Psychological Evaluation of Alleged Victim

·        Copy of Admissibility of Testimony of Mediator in Criminal Trial

·        Copy of Admit Family Court Evaluator Records and Testimony

·        Copy of Exclude Sexual Paraphernalia

·        Exclude Argument of Counsel re Consequences of Verdict

·        Exclude Evidence of Other Sex Offenses

·        Exclude Evidence of Polygraph

·        Exclude of Prior Uncharged Sex Offenses

·        Exclude Evidence of Therapy of Alleged Victim

·        Exclude Expert Opinion that Child is Victim of Sexual Molest

·        Exclude Expert Testimony of V’s Capacity to Consent to Sex

·        Exclude Hearsay Statements of Alleged Victim as not being a Fresh Complaint

·        Exclude Munchausen by Proxy Syndrome or Factitious Disorder by Proxy

·        Exclude of Anatomical Dolls

·        Exclude Police-Counselor Opinion V is Truthful

·        Exclude Post Molest Symptoms

·        Exclude Subterfuge

·        Exclude Admit V’s Character Truth and Veracity

·        Exclude Defendants Adult Sexual Contact With Other Adults

·        Exclude Defendants Character (Alcoholism, Drugs)

·        Exclude Evidence of Defendants Character for Violence

·        Exclude Evidence of Prior Bad Acts

·        Exclude Evidence of Profiles of Child Molesters

·        Exclude Evidence of Sexual Paraphernalia

·        Exclude Hearsay Based on Incompetence

·        Exclude Hearsay Evidence Code Section

·        Exclude Homosexual References

·        Exclude Impeachment with Drug Diversion or Arrest

·        Exclude Prior Felony Conviction Involving Moral Turpitude created

·        Exclude Rebuttal Evidences for Traits of Def’s Character not Raised on Direct Exam on Habit or Custom

·        Exclude Rebuttal Evidence of Defendants Character Traits Other than Non-Deviant Sexual Behavior

·        Exclude Sexual Paraphanalia

·        Exclude Specific Acts of Lying

·        Hospital Records (Limited Admissibility)

·        Introduce Typed Transcript of Audiotape or Video Tape Interview

·        Motion to Exclude Bad Acts of Third Parties

·        Past Recollection Recorded

·        Petition Decl., P&A, Order for Relief

·        Police Report Where Author Unavailable & Prior Inconsistent Statements are ALLEGED

·        Suggestibility child witness