Fill and Sign the Motion in Limine Form

IN THE CIRCUIT COURT OF_________ COUNTY, ____________ NAME OF PLAINTIFF )       ) ) V. ) NO. ) ) NAME OF DEFENDANT )       ) ) MOTION IN LIMINE Comes now _______________, by and through his attorney, and files this his Motion in Limine for an Order instruction the District Attorney to refrain absolutely from making any direct or indirect inference whatsoever in person, by counsel, or through a witness to the specified evidence or testimony specified below on the following grounds: 1. That said ___________________ was indicted by the Grand Jury of the __________ County Circuit Court on a charge of Voyeurism habitually. 2. The defendant believes and hence alleges that at his trial the State will attempt to introduce evidence, make reference to, or otherwise leave the jury with the impression that he has been involved as a perpetrator, defendant, and subsequently convicted in previous cases charging the defendant with the offense of Attempted Rape and Burglary in _________ ____ and Voyeurism in __________ ____, with said offenses completely unrelated to nor tending in any way to prove the offense at bar, other than to place the defendant's character in issue. 3. It is immaterial and unnecessary to the disposition of this case and contrary to the rules at evidence recognized by law in this state to permit such evidence or inference and would be highly prejudicial to the defendant in the minds of the jury in that the same would place defendant's character in issue and inform the jury of past crimes and offenses for which the defendant has been convicted. 4. An ordinary objection during the course of trial even if sustained with proper instructions to the jury will not remove the effect of such evidence from the minds of the jurors even though the defendant's character has not been placed in evidence and these past activities of the defendant are too unrelated and too removed in time to have any evidentiary value in the case at bar. WHEREFORE, premises considered, defendant requests that this Court will enter its Order absolutely prohibiting any direct or indirect inference whatsoever in person, by counsel, or though a witness of the prior convictions of the defendant. Respectfully Submitted, _________________________________ CERTIFICATE OF SERVICE I, ________________, do hereby certify that I have on this day delivered by hand, a true and correct copy of the foregoing Defendant's Motion in Limine to ______________________ This the _____ day of __________ __, ____. ______________________________ ______________