Home » Uncategorized » Discuss Possible Motions in Limine for the Defense

Discuss Possible Motions in Limine for the Defense

Justice for

What are your thoughts? What motions in limine would you recommend to the Defense to file?
[Posted May 20, 2013 at 2:15 pm]


95 thoughts on “Discuss Possible Motions in Limine for the Defense

  1. Love your Blog Annette!.. I have had a WordPress acct. for awhile and have never commented before.. Hope I’m doing it correctly! See ya around on the threads,Annette… JUSTICE FOR GEORGE ZIMMERMAN!

  2. All events which occured prior to the actual physical confrontation should be excluded, as they do not have bearing on the elements of 2nd degree murder or self defense.

      • I think that would require a “deal” between the State and the defense. I also think that either side could argue it and win but not in front of Nelson. She might approve a deal but she is not likely to do anything that helps George. Who benefits the most by excluding it?

        • True, but the prosecution is claiming that it is all one continuous act. So they would oppose the motion, strenuously. Without it there is no W8, no chase, no to establish a reason for TM to assault GZ.

  3. This one is for you Art Tart LOL Speaking of not using TM pictures under a certain age, the judge in the Casey Anthony case, Perry, told the defense they had to remove a picture of Casey in her younger days on a poster they were going to use in their closing arguments. He told them they had to replace it with a more recent picture.

    • minpin, LOL, about KC, but too, there were no 16 X 20’s in the Court room of the murdered & dumped victim, Caylee. The defense had relatives claim what a great mother KC was, Ashton bitch slapped that concept, Ashton pointed out how KC was a terrible mother, it was endless.

      Hopefully, BDLR will open the same door during trial for MOM/West to drive a MAC truck through, the real TM BDLR is trying to hide from the jury.

      • Do you recall how angry BDLR got when Mr. O’Mara put into evidence in the 2nd bond hearing on June 29th the picture of Trayvon in the 7-Eleven? The prosecutor doesn’t want the jury or the public to know about the youth GZ came upon that night.

        The jury however must be introduced to who he was and what he looked like that night.

        • That suggests another possibility: No mention of ‘blogs’ that comment on the case or supposed ‘doxing’ or any theoretical relationship between such blogs and the defense, GZ and/or his family,

          • Good point. At what part of the justice system does the Prosecutor have to be able to prove his comments? I’ve been very surprised at the amount of misinformation, that BDLR has been allowed to talk about in open court. Not even Mr. O’Mara stops him. I’m assuming at some point, those comments that have no proof get weeded out?

          • I would think BLOGS fall under “freedom of speech.” The most VILE/hate filled comments are made at the OS BLOG by TM supporters, they are NEVER deleted, that is the ONLY reason I can think f that the OS allows it.

              • Why don’t you listen for yourself and determine why BDLR thinks that photo is extremely unfair to be put in as an exhibit. At the time I laughed. BDLR was profiling Mr. Martin in his argument. You decide for yourself.

                At 36:42 Mr. O’Mara puts the photo in as an Exhibit and at 44:39 Mr. de la Rionda tells the Judge why he thinks that photo is unfair.

                At 49:10 Mr. O’Mara explains why the picture was put in as an exhibit.

                It’s clear the State thinks showing the public and jury how Trayvon looked that night is unfair to their “Victim”. I 1000% disagree.

              • Captain- no doubt there is hate filled rants by TM supporters anywhere they can post, I don’t go to Huff Po, I already have HIGH Blood Pressure & it makes me just furious, I follow some of the comments @ Click Orlando but I don’t post there, MUNG does a good job of slapping the haters with the facts there..

        • I remember that. BDLR was FURIOUS! Then he laughably tried to spin it into something positive for the prosecution saying since the clerk allegedy did not find TM suspicious it somehow shows a flaw in Georg’s judgement.

    • Related: No reference to the jail calls or any suggestion that the ‘code’ was used with the intent to hide money from the court. That motivation hasn’t been proven. Also no suggesting that GZ was trying to hide a passport from the court b/c that hasn’t been proven either. I also think those would be things relevant to the bond but irrelevant to the M2 charge.

  4. How about: Using proper terminology in court. No calling GZ a murderer since that hasn’t been proven. No calling TM a child as that is prejudicial to the defense. He’s a young man or a teenager. No reference to TM’s supposed ambition to be an aeronautics engineer, astronaut, or whatever the hell ppl thought he wanted to be. It’s irrelevant.

    Just tossing things out off the top of my head. I have no idea if any of them are doable in a ‘motion in limine’.

  5. No mention of GZ’s prior encounters with LE since none of them resulted in a conviction. If BDLR wants to stop MOM from saying GZ was never convicted he shouldn’t be able to bring up past incidents.

  6. #1 – MOTION IN LIMINE TO PROHIBIT PREJUDICIAL TERMINOLOGY – Seeks to prevent the state from using the term “profiled” since it has the capability to prejudice the jury without providing any evidence that it is illegal. In other words, even if Zimmerman did “profile” Trayvon, he didn’t commit a crime in doing so, and so it would be unfairly prejudicial to him for the state to use that term which carries an implication that the “profiler” is doing something wrong or illegal.

    #2 – MOTION IN LIMINE TO PREVENT PREJUDICIAL MISCHARACTERIZATION OF DISPATCHER COMMENT – prevents the state or any witness from saying that George Zimmerman was told or commanded not to follow Trayvon Martin or that he was told to get back in his truck, etc. – not only because it was not a “command” from the dispatcher, but also because following Trayvon Martin was not a crime. George was simply following the dispatcher’s earlier instruction (which actually was a command) to “just let me know if this guy does anything else.”

    #3 – MOTION IN LIMINE TO PROHIBIT WITNESS SPECULATION AS TO MOTIVATION – to keep any witness and the state from offering any speculation that George Zimmerman was suspicious of Trayvon Martin because of his skin color or because of the hoodie that he was wearing. There is no evidence that suggests either of those is true, and it would be severely prejudicial to George for anyone to speculate in front of the jury that George was motivated by those factors.

    #4 – MOTION IN LIMINE TO LIMIT MISCHARACTERIZATIONS OF DEFENDANT’S ACTIONS – seeks to prohibit the state or any witness from using the terms “murdered,” “in cold blood,” “like a dog,” “hunted,” and other terms that do not reflect the facts of the case but are severely prejudicial against defendant.

  7. #5 – MOTION IN LIMINE TO PROHIBIT DISCUSSION OF PENDING LEGAL ACTIONS AGAINST THIRD PARTY – Seeks to prevent the state from discussing alleged crimes committed by third parties, since no such alleged crime could possibly have any bearing on the events that transpired inside the Retreat at Twin Lakes on February 26, 2012.

  8. No mention of GZ’s prescription drugs or theoretical side effects of those drugs. Especially if state is allowed to block comments about TM’s ILLEGAL drug use.

  9. #6 – MOTION IN LIMINE TO REQUIRE USE OF EQUIVALENT TERMINOLOGY – would require that the prosecution and witnesses refer to the defendant as “Mr. Zimmerman” and to the deceased as “Mr. Martin” (or, alternatively, as “George” and “Trayvon”) in order not to limit the prejudicial effect that would occur if the deceased were continually referred to by his first name while the defendant is referred to by his last name.

    #7 – MOTION IN LIMINE TO PROHIBIT PREJUDICIAL IMAGERY – would prohibit the state from displaying photographs of the deceased or the defendant taken prior to February 26, 2012, UNLESS THOSE IMAGES CAN BE SHOWN TO HAVE SOME PROBATIVE VALUE AS TO THE POSSIBLE STATE OF MIND ON 2/26/12 OF EITHER THE DEFENDANT OR THE DECEASED.

  10. The parents…pseudo parents…step parents…whatever other type parents CANNOT testify as to what temperament TM was since NONE of them had him for any length of time that they could testify to and that they should only be able to testify on what behavior he was exhibiting the day of 2/26/12 IF they saw him that day.

    • That would leave only Chad…and he would present a real mix of contradictions if he was called to the stand…

    • I dont think they wiuld have anyone testify about his temperment because then the defense could rebut that with testimony that refers to bad parts of his temperment. That could bring in the fighting and maybe school problems.

      • Sorry to be so late here…All these motions from the prosecution, are they asking to exclude behavior noted by the parents or just school and social network?….If they are not excluding it…the parents can testify how well behave he was at home and the defense cannot ask anything other than, “are you sure?”…Just saying they need to limit that to 2/26/12.

  11. #8 – MOTION IN LIMINE TO REQUIRE CLEAR COMMUNICATIONS – Requires the state to ask clear and concise questions that can be answered with simple responses. Limits the compound questions that the state has shown a propensity to ask during cross-examination of defense counsel.

    #9 – MOTION IN LIMINE TO LIMIT EXTRANEOUS COURTROOM MOVEMENTS – Requires the state to utilize normal hand movements and gestures, because the state’s arm flapping gestures unfairly prejudice the jury, since they are a constant reminder that the defendant is a caged bird.

    • 9 is the best. How about adding a requirement that BLDR wear weighted shoes in case he loses his cool. This is a safety precaution to prevent him from becoming airborne and flying away.

      • When I did mock trial I intentionally walked around the “courtroom” when I made my arguments because it forced the jury to pay attention more. It’s easier to tune out someone who is just standing there than someone who is moving around.

            • He asks ridiculously loaded questions and then turns his back on West showing his disdain and total lack of respect, as if he just asked the question of the century that cannot be answered. He looked lke he was waiting for applause. West sunned him more than once.

              If I had been West, I would not have answered until he turned around and faced me. West could have responded with: “Hey Bernie… what are you looking at? Can can duck because you are blocking my view of the busty blonde chick in the back. Or.. Are you interested in my answers or not? And which of your nine questions should I answer first?”

              West handled him well. His honest jeering bewilderment at some of the questions was priceless.

              What a moron.

  12. #10 – MOTION IN LIMINE TO LIMIT DISTRACTING GLARE – Requires the state to take measures to limit the glare generated by counsel’s forehead as it will serve to distract the jury, potentially limiting defendant’s right to a fair trial. Possible methods include makeup, a toupee, or intervention by Hair Club for Men.

    • Captain- Anyone who runs a blog site is in complete control of what is said or not said. Free speech ends at the door of a blog site owner, just as Nettles can delete anything she chooses to. Jerylyn has had a tight ship at TalkLeft, the CTH controls what agenda they have chosen to promote. I understand your frustration, believe me I understand your frustration. Any blog owner can do whatever they will with their site, anything. I left the CTH because of the demand for political correctness, and questioning that position, and later saw Sharon post a comment something about blacks destroying any country they have ever ruled. As Howie likes to say, go figger.

      • Right. It’s his blog and he maintains it to talk about things of interest to him. I think he more objects to blatantly off topic posts (out of the blue) rather than digression as a result of an evolving conversation. There is more I’d say but in the interest of diplomacy I’ll refrain. 🙂

    • Diwataman has made it known LOTS of times, he wants the commentators to keep to the “topic” of the blog post.

      I took one of his posts off topic and AGAIN he asked all of us to stay on topic. To address my very bad habit of taking a thread off-topic he created the Nettles Breaking News pages. I think he has a Comments section now where off topic stuff can be posted.

      It is annoying for a person who looks to read about the continuance and you go through lots of posts about other topics.

      My daily thread is an open thread and any topic can be posted here. I would ask you Captain to think long and hard before posting Trent Sawyer’s stuff here. He has been absolutely vile with me and I’ve taken steps to block him. He keeps trying to insert his message into my tweeter feed and I’d appreciate any help that blocks that.

      Thanks again for all the pictures you’ve supplied me to use in the posts. ♥

    • It is his blogs so maybe we should respect his guidelines. Jeralyn at talkleft also controls the conversation and the CTH, even more so. It is their football and their back yard so I think we have to play by their rules. 😀

      Nettles is much more relaxed here.

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