Fill and Sign the Now Comes the Applicantdefendant by and through Counsel Form

MOTION IN LIMINE COMES NOW the defendant, by and through her undersigned counsel, and hereby moves this Honorable Court to suppress any and all references either directly or indirectly to the Defendant's lifestyle, sexual preference or family history. In support of this motion, the defendant shows the following: 1. Any reference to the above-stated is irrelevant with regard to the issues before the Court.2. References to the above-stated will serve only to alienate the Defendant from the jury and detract from and confuse the relevant issues before the Court. 3. The Defendant's personal life and family history were discovered through a psychiatric evaluation made in connection with the defense of the case by the Defendant's attorney and therefore is protected as work product. (_________________ Rules of Criminal Procedure Rule_________) 4. The evaluating psychiatrist was hired by the Defendant's attorney in connection with the defense of the case and therefore qualifies him as an agent of the attorney, thus rendering any references to the above-stated therein undiscoverable work product. (Id.) 5. To not grant this motion would unduly prejudice the defendant. 6. The interests of justice so require. For these reasons, this Honorable Court should GRANT this motion in limine. Done this the day of ___________________, _________. Respectfully Submitted, ____________________________