Motion to Instruct Jury On Defendant’s Burden of Proof On Mitigating Circumstances
Motion for Peremptory Instructions on Mitigating Circumstances
Motion for Jury Instruction under Enmund v. Florida and Tison v. Arizona
Motion for Court to Give Understandable Jury Instructions
Jury Instructions. Penalty Phase Revised 3-2000 Version
Discretion in Capital Sentencing Instructions
Motion to Limit Victim-Impact Evidence
Motion to Allow Defendant to Address the Jury
Request for Special Instruction on the Highest Aim of Every Criminal Trial
Motion to Require Sequestration of State’s Witnesses
Motion to Prohibit Prosecutor from Telling the Jury that Mitigating Factors are Things that Reduce the Severity of the Crime
Motion to Prohibit District Attorney from Peremptorily Challenging Prospective Black Jurors
Motion to Preclude Leading Questions and Conclusory Statement on Voir Dire of Prospective Jurors
Motion to Preclude Death Penalty
Motion to Exclude Still Photographers, TV Cameras and Microphones from the Courtroom
Motion to Exclude Photographs
Motion to Bar the State from Presenting Inconsistent Theories of Prosecution
Motion to Allow Defense Counsel to Question any Potential Jurors Challenged for Cause by the Prosecutor Based on Opposition to the Death Penalty
Motion to Allow Defense Counsel to Distribute a questionnaire to Potential Jurors
Motion in Limine to Prohibit Reference to Defendant’s Silence
Motion In Limine to Limit Testimony of Statements of Defendant
Motion for Pre-Selection Instructions to Potential Jurors
Motion for Individual Voir Dire on Sensitive Subjects