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Cr - Motion in Limine to Strike Alias or Prior Names

Cr - Motion in Limine to Strike Alias or Prior Names

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Published by GlenGraham

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Published by: GlenGraham on Sep 17, 2009
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09/16/2009

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IN THE DISTRICT COURT IN AND FOR TULSA COUNTYSTATE OF OKLAHOMASTATE OF OKLAHOMA,)Plaintiff,)vs.))Defendant.)Case No.DEFENDANT’S MOTION
 IN LIMINE 
TO STRIKE ALIASAND/OR PRIOR NAMES AND BRIEF THEREONCounsel for the above-named defendant moves this Court,
in limine
, for an order instructing the prosecutors, and any witnesses that are called to testify in the above-listedcase, to refrain from making statements, commenting, or otherwise suggesting during theState’s voir dire, opening statements, direct or cross examination, responses to direct or cross examination, statements, objections, or by other means or device that any of thefollowing facts may exist:1. That State of Oklahoma has listed alias names underneath the Defendant’sname on the Information. None of these alleged alias or prior names have any bearing onthe case at hand.2. The Defendant, to the best of counsel’s knowledge, did not use any alias nameat the time he was arrested, or at the time of the alleged crime, nor is counsel for theDefendant aware that he ever used any alias name during the whole time he was in thecustody of the police, or being booked into the Tulsa County Jail.3. To allow all of these alleged alias or prior names to be read to the jury is more prejudicial than probative, irrelevant, misleading and confusing to the issues in the case athand.

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