Library of Motions – Motion In Limine – Extraneous Matters

MOTION IN LIMINE – EXTRANEOUS MATTERS
NO. (Cause No.)
THE STATE OF TEXAS
VS.
(Defendant’s Name)
§§

§

IN THE COUNTY CRIMINAL
COURT NO. _____ OF
DALLAS COUNTY, TEXAS
MOTION IN LIMINE – EXTRANEOUS MATTERS

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)

CERTIFICATE OF SERVICE

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
ORDER

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
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