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