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! There are also actual motions for California available and they can be accessed at: http://www.californiamotions.com. Since the “Points and Authorities” change over time, when using this California motion section, be aware that research may have to be done to insure that the “Point and Authorities” for this motion are up to date. 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