Opening paragraph of the in limine motion (sketch)
COMES NOW the State of Indiana, by Prosecutor Nicholas M. McLeland, for the 74th
Judicial Circuit, and respectfully requests that the Court enter an Order prohibiting the admission
or reference to composite sketches, prepared by any sketch artist for the investigation of the
murders of Abigail Williams and Liberty German, for the reason that a composite sketch is not
relevant, admission would result in undue prejudice, confuse or mislead the jury, or is
impermissible hearsay, and the witnesses who participated in the preparation of composite
sketch(s) will not be presented by the State for the purpose of in-court identification of the
defendant.
One of the 7 reasons the P gives:
5. It is the State’s belief that the defense intends to use composite sketches from the
investigation as demonstrative evidence and for impeachment purposes. That the
witnesses who participated in the preparation of composite sketches are not being
called to provide in-court identification of the accused; furthermore, no composite
sketch was instrumental in identifying Richard Allen as a suspect.
His request:
WHEREFORE, the State of Indiana, by Prosecuting Attorney, Nicholas C. McLeland,
respectfully requests this Court to grant the following relief:
A. Order the Defendant, his Counsel and witnesses to refrain from mentioning,
commenting, or making any reference whatsoever, either directly or indirectly, to
composite sketches without first obtaining permission of the Court outside the presence
and hearing of the jury;
B. To further order said persons to make no reference to the fact that this motion
has been filed and granted and all other relief just and proper in the premises.
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