Motions for use in criminal trials, also known as motions in limine.

Criminal defense attorneys and paralegals need a collection of motions in limine to help control the trial process by excluding bad evidence, introducing good evidence, and ensure a fair trial for the defendant.  Criminal defendants who review in limine motions may better understand the criminal justice court system and may better help assist in their own defense.

The in limine motions in the packages on this page are from the book California Criminal Defense Motions in Limine along with several other motions that were created after publication.  These motions were prepared and used by some of the best criminal defense attorneys.  California Criminal Defense Motions in Limine and other books we have helped write can be found in bookstores or by clicking here.  These in limine motions are sold to the public, but they are primarily designed for attorneys and paralegals.  If you are a criminal defendant, you should seek the advice of an attorney before using any of these pleadings.

These pleadings are for use during trial.  If you are looking for motions for use prior to trial or for sentencing (Trial Motions), click here.  The motions have received acclaim and endorsements, which you can find here.

General instructions for motions in limine packages can be found by clicking here.  Keep scrolling or jump to a specific in limine package by clicking one of the jump links:

We sell individual Criminal Defense Motions in Limine Packages for $10 each.  Instant access is given to individual packages, but they are not custom formatted, so you’ll have to insert your own name, address, and phone number. If you purchase the entire set of all pleadings for $100, we custom format them for you, but this may take up to five business days.  Order the full set on our books page.


A. Late Pretrial Motions

This package includes the following motions in limine in Word format:

  1. Transcript of Prior Proceedings
  2. Set Aside Information (Penal Code §995)
  3. Strike Improperly Alleged Overt Acts
  4. Suppress Evidence – No Warrant
  5. Disclose Prosecution Agreements
  6. Suggestion to Dismiss – Unfair Discrepancy
  7. Suggestion to Dismiss – Family

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


B. Defendant’s Prior Conduct

This package includes the following motions in limine in Word format:

  1. Prohibit Use of Prior Felony Convictions
  2. Prohibit Use of Prior Misdemeanor Conduct and Convictions – No Moral Turpitude
  3. Prohibit Use of Prior Misdemeanor Conduct and Convictions – With Moral Turpitude
  4. Prohibit Use of Prior Juvenile Matter
  5. Prohibit Reference to Probation or Parole Status
  6. Prohibit Use of Prior Bad Acts
  7. Prohibit Impeachment of Defendant’s Character Evidence
  8. Prohibit Reference to Prior Police Contact
  9. Prohibit Use of Gun Propensity Evidence

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


C. Defendant’s Image

This package includes the following motions in limine in Word format:

  1. Prohibit Reference to Lack of Remorse
  2. Prohibit Use of Restraints in the Courtroom
  3. Prohibit Bailiff from Standing Behind Defendant During Testimony
  4. Prohibit Use of Stun Belt
  5. Prohibit Jail Clothes During Trial
  6. Prohibit Use of Aliases
  7. Allow Defendant to Wear Customary Cosmetics
  8. Allow Defendant to Conceal Tattoos

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


D. Defendant’s Statements

This package includes the following motions in limine in Word format:

  1. Prohibit Reference to Ambiguous Confession
  2. Defendant Statements (Intoxicated or Disabled Defendant)
  3. Prohibit use of Defendant Statements (Impeachment)
  4. Prohibit Use of Defendant Statements (Prejudicial)
  5. Defendant Statements (Corpus Delicti Rule)
  6. Prohibit Reference to Withdrawn Plea
  7. Limit Cross Examination

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


E. Defendant’s Right to Counsel

This package includes the following motions in limine in Word format:

  1. Provide Private Meeting Room for Defense
  2. Facilitate Defendant’s Communication with Counsel
  3. House Defendant Locally
  4. Prohibit Comments on Right to Counsel
  5. Prohibit Criticism of the Defense Team
  6. Prohibit Access to Defense Interview Notes

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


F. Defendant – Other Issues

This package includes the following motions in limine in Word format:

  1. Prohibit Comments on Defendant’s Demeanor
  2. Prohibit Reference to Defendant’s Failure to Disclose Alibi
  3. Allow Display of Physical Characteristics
  4. Admit Polygraph Evidence
  5. Admit Evidence of Consciousness of Innocence
  6. Allow Defendant to Give Narrative Testimony
  7. Prohibit References to Defendant’s Immigration Status
  8. Prohibit Reference to Self-Improvement Efforts
  9. Prohibit Reference to Lack of Love
  10. Prohibit Improper Character Rebuttal

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


G. Prosecution’s Conduct

This package includes the following motions in limine in Word format:

  1. Require Equal Access to Witnesses
  2. Estop Prosecution Theories and Evidence
  3. Prohibit Witness Intimidation
  4. Prohibit Expression of Personal Belief
  5. Prohibit Vouching
  6. Prohibit Reference to Facts Not in Evidence
  7. Prohibit Use of Prejudicial Titles
  8. Prohibit Testimonial Statements by Counsel
  9. Prohibit Sandbagging in Closing Argument
  10. Prohibit Premature Rebuttal
  11. Prohibit Invitations to Stipulate
  12. Prohibit Use of Prosecution’s Demonstrative Evidence
  13. Prohibit Implied Representation of Jury
  14. Require Prosecution to Disclose Theory of Guilt
  15. Prohibit Inconsistent Theories (Theory of Guilt)
  16. Prohibit Inconsistent Theory of Guilt (Culpable Defendant)

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


H. Prosecution’s Argument

This package includes the following motions in limine in Word format:

  1. Prohibit Prosecution Integrity Argument
  2. Prohibit Improper Explanation of Reasonable Doubt
  3. Prohibit Religious Arguments
  4. Prohibit the Prosecution from Misstating the Law
  5. Prohibit “Standing in the Victim’s Shoes” Argument
  6. Prohibit Misstating the Role of the Jury
  7. Prohibit Allegations of Lying
  8. Prohibit Comments on Custodial Status
  9. Prohibit “Waste of Time” Argument
  10. Prohibit Comments on Failure to Call Witnesses

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


I. Bifurcations

This package includes the following motions in limine in Word format:

  1. Separate Trial – Conflicting Defenses
  2. Separate Trial – Allow Codefendant Testimony
  3. Separate Trial – Codefendant Statements
  4. Separate Trial – Notorious Codefendant
  5. Bifurcate Prior Convictions
  6. Sever Counts
  7. Free Codefendant to Give Truthful Testimony

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


J. Procedural Matters

This package includes the following motions in limine in Word format:

  1. Prohibit Reduction in the Gravity of the Proceedings
  2. Equal Treatment of Counsel and Witnesses
  3. Prohibit “Door Holding”
  4. Make Use of Personal Recording Device
  5. Daily Transcripts
  6. Federalize Objections
  7. Pretestimonial Hearing
  8. Adopt Codefendant Motions
  9. Prohibit Video Testimony
  10. Limit Impeachment of Witness
  11. Limit Prosecution Witness Conferences
  12. Take Judicial Notice
  13. Recess at Close of Prosecution’s Case-in-Chief
  14. Appoint Interpreter for Defendant’s Exclusive Use
  15. Disclose Witness Schedule
  16. Examine Exhibits Outside the Presence of the Jury
  17. Make Motions in Limine Binding
  18. Delay Release of In Limine Proceedings
  19. Request for Gag Order
  20. Prohibit Comments on Motions in Limine

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


K. Courtroom Environment

This package includes the following motions in limine in Word format:

  1. Limit Courtroom Security
  2. Exclude Witnesses
  3. Prohibit Media Coverage
  4. Allow Expert Witnesses to Remain in the Courtroom
  5. Require the Investigating Officer to Testify First
  6. Allow Favorable Defense Evidence in Opening Statement
  7. Limit Display of Exhibits
  8. Prohibit Spectators from Influencing Trial
  9. Exclude Alleged Victim
  10. Exclude Alleged Child Victim
  11. Exclude the Public
  12. Jury View
  13. Prohibit Cameras in the Courtroom

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


L. Drugs and Alcohol

This package includes the following motions in limine in Word format:

  1. Prohibit Use of Upper Range of Margin of Error
  2. Prohibit Unqualified “Breath Test” Expert from Testifying
  3. Prohibit Impeachment by Alcohol Use
  4. Drug Use as Financial Motive
  5. Exclude Trombetta Advisement
  6. Prohibit Use of PAS Evidence (Trombetta)
  7. Prohibit Use of PAS Evidence (Foundation)
  8. Prohibit Use of PAS Evidence (Secondary Evidence)
  9. Prohibit Use of PAS Evidence (Wrongful Purpose)
  10. Prohibit Use of PAS Evidence (Due Process)
  11. Prohibit Reference of PAS Refusal
  12. Prohibit Use of Blood Test (Denial of Choice)
  13. Prohibit use of Alcotest Evidence
  14. Exclude Blood Test (Hearsay)
  15. Prohibit Use of Evidence of Tolerance
  16. Prohibit Use of Alcohol Admonition Evidence
  17. Prohibit Stimulant Evidence
  18. Prohibit Depressant Evidence
  19. Prohibit Drug/Alcohol Recognition Expert
  20. Prohibit Field Sobriety Exercise Evidence
  21. Prohibit Improper Use of Horizontal Gaze Nystagmus
  22. Admit Partition Ratio Evidence
  23. Prohibit Opinion of Alcohol Impairment
  24. Prohibit Extrapolation Evidence
  25. Prohibit Evidence of Withdrawal

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


M. Hearsay

This package includes the following motions in limine in Word format:

  1. Prohibit Hearsay (Crawford)
  2. Prohibit Description of Video Recording
  3. Prohibit Use of Incomplete of Video Recording
  4. Prohibit Use of Codefendant Statements
  5. Prohibit Use of Redacted Codefendant Statements
  6. Prohibit Use of Codefendant Statements (Conspirator)
  7. Prohibit Use of Calls to
  8. Prohibit Use of Codefendant Jail Calls
  9. Prohibit Use of Booking Records
  10. Prohibit Use of Compelled Statements
  11. Prohibit Use of Third-Party Coerced Statements
  12. Prohibit Use of Statements Coerced by Plea Agreement
  13. Prohibit References to Informant
  14. Prohibit Use of Police Statements to Defendant
  15. Prohibit Use of Preliminary Hearing Testimony
  16. Prohibit Use of Victim Writings
  17. Prohibit Use of Dying Declaration
  18. Prohibit Use of Medical Records (Past Recollection Recorded)
  19. Prohibit Testimony as to Contents of Medical Records
  20. Prohibit Use of Social Media Evidence
  21. Prohibit Display of Labels
  22. Prohibit Extraneous Documentation in the Courtroom
  23. Prohibit Hearsay Under Guise of Explaining Future Conduct

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


N. Interference with Evidence

This package includes the following motions in limine in Word format:

  1. Grant of Immunity for Defense Witness
  2. Prohibit Use of Altered Evidence
  3. Prohibit Use of Altered Evidence (Alternate Form)
  4. Prohibit Use of Evidence Not Timely Disclosed
  5. Dismiss for Failure to Timely Disclose Evidence
  6. Dismiss for Lost Evidence (Trombetta)
  7. Prohibit Impeachment of Prosecution Investigation
  8. Prohibit Reference to Accidentally Destroyed Evidence
  9. Prohibit Use of Text Message Screen Shots

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


O. Privileges and Rights

This package includes the following motions in limine in Word format:

  1. Prohibit Comments on Post Arrest Silence
  2. Prohibit Comments on Defendant’s Failure to Testify
  3. Prohibit Comments on Exercise of Fourth Amendment Rights
  4. Prohibit Use of Defendant Statements (Miranda)
  5. Prohibit Use of Jailhouse Informant (Miranda)
  6. Invocation of Marital and Spousal Privilege
  7. Invocation of Clergy Penitent Privilege
  8. Prohibit References to Religion
  9. Prohibit References to Sexual Orientation

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


P. Gangs and Other Conspiracies

This package includes the following motions in limine in Word format:

  1. Prohibit Opinions as to Defendant’s Gang Intent
  2. Prohibit Use of Gang Profile Evidence
  3. Limit Gang Evidence
  4. Limit Gang Evidence (Alternate)
  5. Prohibit Gang Expert Hearsay
  6. Prohibit Gang PowerPoint

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


Q. Experts

This package includes the following motions in limine in Word format:

  1. Prohibit Expert Opinions of Credibility
  2. Prohibit Comments on the Law
  3. Prohibit Improper Hypothetical Questions
  4. Prohibit Use of Fingerprint Evidence
  5. Prohibit Use of DNA Evidence (Random Methods)
  6. Prohibit Use of Profile Evidence
  7. Prohibit Use of Improper Opinions
  8. Prohibit Accident Reconstruction Testimony (Automobile)
  9. Prohibit Reconstruction Experiments
  10. Prohibit Speculative Expert Testimony (Sargon Test)
    • Bite Marks
    • Child Sexual Abuse Accommodation Syndrome
    • Gunshot Residue
    • Informant
    • Makeup Sex
    • Mental Health Opinions
    • Meaning of Conversation
    • Rape Trauma Syndrome
    • Shaken Baby Syndrome
    • Thought Process
    • Weapon Possession Intent
    • Tool Marks

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


R. Admit Favorable Evidence

This package includes the following motions in limine in Word format:

  1. Admit Evidence of Victim Drug Use
  2. Allow Impeachment of Prosecution Witnesses
  3. Admit Evidence of Third-Party Culpability
  4. Allow Evidence of Prior Sexual Conduct to Prove Knowledge of Acts
  5. Admit Evidence of Lack of Deviance
  6. Admit Evidence of Intimate Partner Battering
  7. Admit Evidence of Effect of Homelessness

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


S. Inflammatory Evidence

This package includes the following motions in limine in Word format:

  1. Prohibit Use of Photographs of Living Victim
  2. Prohibit Use of Gruesome or Prejudicial Photographs
  3. Prohibit References to Decision to Terminate Life Support
  4. Prohibit Appeals to Passion
  5. Prohibit Appeals to Emotion
  6. Prohibit Music During Presentations
  7. Prohibit Use of the Term “Victim”
  8. Prohibit References to Fear by Victim
  9. Stipulate to Prejudicial Facts
  10. Prohibit Improper Opening Statement
  11. Prohibit Improper Cross
  12. Prohibit Use of Implied Answers
  13. Prohibit Cumulative Inflammatory Evidence

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


T. Jury Issues

This package includes the following motions in limine in Word format:

  1. Limit Conversations Near Jurors
  2. Allow Objections to Peremptory Juror Challenges
  3. Motion for Jury Questionnaire
    • Sample Jury Questionnaire (Sex Crime)
    • Sample Jury Questionnaire (Murder)
  4. Restrict Use of Computers for Juror Selection
  5. Request to Poll the Jury Count by Count
  6. Require that Potential Jurors Represent a Cross-Section of the Community
  7. Remove Prosecution Team Members from the Jury
  8. Strike the Jury Panel (Opinion Formed)
  9. Strike the Jury Panel (Vicinage)
  10. Strike the Jury Panel (Demographic)
  11. Additional Jury Challenges
  12. Determine Special Jury Instructions
  13. Define Abiding Conviction
  14. Sequestered Voir Dire
  15. Prohibit Press Coverage of Voir Dire
  16. Prohibit Juror Questions
  17. Extend the Scope of Readback
  18. Request to Argue Supplemental Instructions
  19. Require Prosecutor to Disclose Prosecution Juror Information
  20. Bailiff Hold Cellular Telephones During Deliberations
  21. Further Voir Dire Regarding Death Penalty Qualification

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


U. Other Issues

This package includes the following motions in limine in Word format:

  1. Prohibit Use of Prejudicial Evidence
  2. Prohibit Officer Bolstering
  3. Prohibit Testimony from Non-Team Members
  4. Prohibit In-Court Identification
  5. Exclude Prejudicial References (Ammunition)
  6. Prohibit Prejudicial References (BB Gun)
  7. Prohibit Use of Web Printouts
  8. Request for Judicial Disclosure

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


V. Omnibus Pleadings

This package includes the following motions in limine in Word format:

  1. Stipulated Motions in Limine
  2. Omnibus Motion in Limine
  3. Trial Brief

Buy now for only $10 including tax and you will receive instant access to the web page where you can download all of the pleadings in the package.


Endorsements

Most of the pleadings in these packages come from books we have helped with, so we are sharing some of the praise and endorsements we have received for those books and the pleadings in them.

“Actually, this is as good as I’ve seen it regarding federalizing objections… you put a lot of effort into this… and you are trying to be specific, so I think that’s good.”  Judicial comments at trial of People v. Xavier Harris, BF155952A.

“The pleadings in this book are good to use as examples to help you understand the system…” Attorney J. Anthony Bryan

“Great motions in limine, such as those you’ll find in this book, can help level the playing field and get your client a fair trial.”  Attorney George A. Boyle

“I’ve spent decades defending the accused.  During that time I have poured countless hours into developing the most effective motions.  I hope you can benefit from my efforts.”  Trial Attorney Roger Lampkin (661)633-1234

“All of my clients should have a copy of this book.  It has a great overview of the criminal process with examples from some of the best attorneys.” Bob Melendez, Gotta Go Bail Bonds (661)633-2245

“As a seasoned, no nonsense criminal defense trial lawyer with more than twenty years experience in the courtroom, I know good motions when I see them, and this book is filled with great motions.” Attorney Joe Whittington (661)322-5822

“I see contributions in this book from some of the top criminal defense attorneys and I am honored to have my motions featured here.”  Attorney Bill Slocumb (661)324-1400

“If you are accused, you need this book.” Champaign Butler, Buzzy’s Bail Bonds (661)324-8119

 

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