Search Terms

Pleadings cannot be filed without first being edited.  Some pleadings need only be edited to include the attorney’s name and contact information along with the case name and number, but more complex pleadings must be heavily edited to include case-specific facts prior to filing.  Each Word file is a separate criminal defense motion in limine motion.  Motion categories correspond to chapters in California Criminal Defense Motions in Limine, and motion names correspond to names in the book.  Many motions have additional x, xx, or xxx at the end of the file name.  A single x indicates that some editing of facts may be needed.  XX indicates that some editing of facts in required.  XXX indicates that the motion must be heavily edited to include facts, arguments, and/or citations to the record.   If you are a pro per defendant, we strongly advise you to seek advice of counsel prior to filing anything.  If you are an attorney, we suggest that you hire us to create a full set of all pleadings from all of our books with your name, bar number, and contact information already in the pleadings.

Pleadings in the motions in limine pleading packages use search-and-replace terms as follows:

Search Term Example
FirstLine John Doe, Esq. SB#123456
SecondLine Law Office of John Doe
AddressLine 1234 L Street
CityCity Bakersfield
StateState CA
ZipZip 93301
PhoneNumber Tel: (661)633-1234
FaxNumber Fax: (661)863-6741
E-MailAddress E-Mail:
CountyCounty Kern
SignSign John Doe
ClientName Dave Defendant
CaseCase BF123456A
xxx Denotes places requiring case-specific text.


Notice Requirements

“Notice” simply means providing a copy of a motion to other interested parties.  In most cases, this means giving a copy of your motion to the district attorney and counsel for any codefendants.

Generally, motions in limine can be served in court on the first day of trial; however, many courts require motions in limine to be served at the readiness conference, at trial call, or at some other designated time.  Check local rules.

These general instructions should be used with caution because rules constantly change, and courts often have local rules that require different formatting, the addition of more information in the pleadings, or other variances from these instructions.