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Motion for Pre-Trial Hearing to Determine Reliability of Complaining Witness'
Testimony
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Motion to Determine Admissibility of Complainants Testimony
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Motion for Autopsy of Minor Child to Include Specific Procedures; Autopsy
to be Videotaped
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Defendant's Request for Notice of Evidence Intended for Use in Case in Chief
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Defendant's Proposed Jury Instruction Relating to Closed Circuit Testimony
of Child Witness
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Motion to Compel Co-Defendant Statements
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Motion to Determine Competency of Complaining Witness
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Motion to Suppress Confession
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Motion to Compel Disclosure of Evidence to States Attorney by State Agents
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Motion for Production of All Relevant Police Reports
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Request for Discovery With Memorandum
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Motion to Exclude Use of Anatomically Detailed Dolls
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Motion to take Deposition of Dr. _______, a Defense Witness
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Motion for Exparte Hearing and Determination for Court Approved Appropriations
for Fees and Expenses of Experts and Investigators
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Motion in Limine Limiting the Number of Photographs of the Victim to be Shown
to the Jury
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Motion in Limine to Exclude any Testimony of the Physician Other Than the
Specific Physical Findings
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Motion in Limine to Prohibit Any Display of Evidentiary Exhibits Until Proffered
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Motion to Prohibit the Filming, Photographing or Videotaping of Defendant
While He is in the Courtroom
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Motion to Disqualify Counsel and Appoint Special Prosecutor
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Motion Directing a Complete Copy of the State's File Be Turned Over to the
Court for Review and Sealed for Appellate Record
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Motion to Sever Counts
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Motion to Suppress Defendant's Statement
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Motion for Disclosure of Witness' Statements Prior to Trial
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Motion for Defense Expert to Interview Complaining Witness or, in the
Alternative, be Present in Court During the Complaining Witness' Testimony
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Motion in Limine for Admissibility of Defense Expert
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Motion for Release of Grand Jury Testimony
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Motion in Limine to Exclude Any Uncorroborated & Unrecorded Hearsay
Statements of the Complainant and/or any State Witness
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Motion in Limine Regarding Testimony Presented to the Jury
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Motion for Jury Questionnaire With Memorandum and Proposed Questionnaire
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Motion for Deposition of Complainant
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Motion to Exclude Testimony of Sexual Conduct
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Motion to Exclude Admissions of Masturbation and X-Rated Tapes
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Motion for Independent Medical Examination of the Complaining Witness
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Response in Opposition to Closed Circuit Television Testimony
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Motion to Require Prosecutor to Give Notice of Intent to Use "Bad Acts" Testimony
Pursuant to Evid. Rule 404(b) and Motion in Limine to Determine Admissibility
of Said Evidence
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Request for Pretrial Discovery
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Motion for Bill of Particulars
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Motion in Limine Regarding Shaken Baby Syndrome Testimony
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Motion to Preserve and Produce Rough Notes
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Motion to Produce Documents Used to Prepare Witness
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Motion to Compel Complainant to Submit to Mental Examination
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Motion for Independent Psychological Examination of Complaining Witness
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Motion in Limine for the Admissibility of Prior Findings and Allegations
of Sexual Abuse Defendant's Former Wife
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Motion to Suppress
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Motion to Compel Law Enforcement Officers to Turn Over and Advise the State
of all Information Acquired During the State's Investigation
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Motion to Compel State's Attorney to Investigate and Disclose
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Motion for Supplemental Discovery Request
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Motion to Suppress With Memorandum
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Motion to Dismiss for Selective Prosecution
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Motion Ordering Video Taping of all Complaining Witness' Interviews and
Statements
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Motion to Exclude Use of Prejudicial Terms
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Motion in Limine Excluding Any Hearsay Statements Made by Complainant as
She/He had a Motive to Fabricate or Lie with Supporting Memorandum
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Motion to Set Reasonable Bond
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Motion to Exclude Video Testimony and Affix Standards
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Motion for Admissibility of the Penile Plethysmograph
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Motion for Emergency Hearing Regarding Child Abuse By Foster Parents to
Complainant in the Present Matter
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Motion for Resume's for Each and Every Professional Who Interviewed or Questioned
Each Complainant/Child Witness and Protocols Relied Upon
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Motion for the Admissibility of Evid. Rule 404(b) Testimony of the Complainant
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Motion in Limine to Exclude Any Witness From Mentioning Any Indicators Allegedly
Observed and/or Described Concerning the Complainant in this Cause
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Motion in Limine to Exclude any Mention of Behavioral Changes or Indicators
of Complainant As Indicative of Sexual Abuse by MHP
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Motion to Elect (Multiple counts with similar import)
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Motion for Production of Exculpatory Evidence
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Motion in Limine to Exclude any Testimony From Suicide Hot-Line As Being
Indicative of Child Molestation
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Motion in Limine Excluding Any Mention by Complainant's Parents Regarding
Any Type of Behavioral Indicators and/or Changes as Relevant to Any Elements
of the Allegations
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Motion in Limine Excluding any Mention of Performances/Behaviors in School
by Complainant as Relevant to any Elements of the Charges Against Defendant
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Motion to Dismiss on Grounds of Prosecutorial Misconduct
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Motion in Limine to Exclude any Testimony of the Examining Physician
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Motion in Limine to Exclude any References to Polygraph Examinations
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Notice of Defendant's Intent to use Complainant's Prior Sexual Activity at
Trial
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Motion to Modify and Delete Registration Requirements From Sentence
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Demand for Discovery (Predator Hearing)
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Motion to Dismiss (Predator)
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Motion to Exclude (Predator)
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Brief to Dismiss and Brief for Pretrial Release
Remember, your life and future are in that attorney's hands. A mistake could
easily put you in prison for years.