Dallas Criminal Lawyer

THE STATE OF TEXAS VS. (Defendant's Name)

§ § §

IN THE COUNTY CRIMINAL COURT NO. _____ OF DALLAS COUNTY, TEXAS

TO THE HONORABLE JUDGE OF SAID COURT:

   NOW COMES the Defendant, (Defendant's Name), in the above-styled and numbered cause, by and through his attorney of record, (Attorney's Name) and respectfully requests that the trial court instruct the prosecuting attorneys not to mention, allude, or refer in any manner to any prior conviction, alleged violation of the law, or extraneous act by this Defendant or any other witness, in the presence of the jury, until a hearing has been held outside the presence of the jury to determine the following:

1. Whether the conviction, alleged violation, or extraneous act involved either a felony or a misdemeanor involving moral turpitude;
2. Whether the conviction, alleged violation, or extraneous act occurred at a time sufficiently recent to have some bearing on the present credibility of the witness;
3. Whether the prejudicial effect of the conviction, alleged violation, or extraneous matter will outweigh the alleged probative relevance of said matter;
4. Whether the person is the same person previously convicted or alleged to have committed the violation or extraneous act.

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

Respectfully submitted, ____________________________________ (Attorney's Name, Address, Bar Card No.) ATTORNEY FOR DEFENDANT (Name)

   I, the undersigned, hereby certify that a true and correct copy of the foregoing Motion in Limine ? Extraneous Matters was forwarded to Mr. Bill Hill, District Attorney, Frank Crowley Courts Building, 133 North Industrial Boulevard, Dallas, Texas 75207 on this the ________ day of ___________, 200___.

____________________________________ Attorney's Name

   ON THIS the _______ day of ______, 200___, came on to be heard the foregoing Motion in Limine - Extraneous Matters, and same is hereby GRANTED/DENIED, to which action Defendant excepted.

____________________________________ JUDGE