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
Motion for Court to Note the Race of Every Potential Juror Examined in This Case
Motion for Complete Recordation of All Proceedings
MEMORANDUM RE JURY VOIR DIRE
JURY SELECTION QUESTIONS
Strike DP SMI Sample
Request for Discovery
MotionToDeclareDPUnconst
MotionDetermineIntellDisability
Motion to Reveal Deals or Concessions
Motion to Prohibit a Death Sentence Based on the International Covenant on Civil and Political Rights and Customary International Law
Motion to Prevent the State from Seeking the Death Penalty and Objections to this Court Declaring this Case Capital
Motion to Obtain Mental Health Records
Motion to Memorialize Discovery Provided by the Prosecutor Pursuant to an Open File Policy