Okay - quite a few motions filed for Elwyn:
62 Certificate of Service certificate of service and index of motions #1-40 03/01/2021 Bell, Jerilyn 4
63 Motion motion # 2 notice of non waiver of rights 03/01/2021 Bell, Jerilyn 3
64 Motion motion # 3 notice of elwyn crocker revocation of any prior waivers and affirmative assertion of fourth fifth and sixth amendment rights 03/01/2021 Bell, Jerilyn 3
65 Motion exhibit a to def.'s motion #4 supplemental guidelines for the mitigation function of defense teams in death penalty cases 03/01/2021 Bell, Jerilyn 16
66 Motion motion # 5 motion to delcare unconstitutional a mandate requiring a defendant to waive his fifth amendment right to silence 03/01/2021 Bell, Jerilyn 4
67 Motion exhibit b to motion # 4 guidelines for the appointment and performance of defense counsel in death penalty cases, revised edition february 2003 03/01/2021 Bell, Jerilyn 51
68 Motion motion #4 notice of intent to abide by the american bar association guidelines for the appointment and performance of defense counsel in death penalty cases 03/01/2021 Bell, Jerilyn 6
69 Motion motion #6 motion to require investigative agencies to preserve notes on all interviews and investigative actions 03/01/2021 Bell, Jerilyn 4
70 Motion motion # 7 motion for an order to preserve all evidence and to preclude any additional state testing or examination of evidence that would alter reduce or destroy evidence without notice to the defense and prior to court arrival 03/01/2021 Bell, Jerilyn 13
71 Motion motion # 8 motion for the court reporters tapes and notes to be made a part of the record of these proceedings 03/01/2021 Bell, Jerilyn 8
72 Motion mmotion # 9 motion for an order requiring the distric attorney to respond in writing to each motion which is contested by the state 03/01/2021 Bell, Jerilyn 10
73 Motion motion #10 motion to prevent ex parte communication between the state and the court 03/01/2021 Bell, Jerilyn 5
74 Motion motion # 11 motion to adopt and conform applicable motions of other defendants 03/01/2021 Bell, Jerilyn 4
75 Motion motion # 12 motion for disclosure of any possible basis for recusal of judge 03/01/2021 Bell, Jerilyn 6
76 Motion moition # 13 motion for disclosure of any improper bias or prejudice grounds for any legal clain or possible basis for disqualification of district attorney court personnell or other state actors involvedin any way in this case 03/01/2021 Bell, Jerilyn 15
77 Motion moition #14 motion to follow supreme court jurisprudence for heightened reliability once the state seeks the death penalty 03/01/2021 Bell, Jerilyn 4
78 Motion moition # 15 motion to strike as unconstitutional the georgia statutes providing for the imposition of the death penalty and their application to this case 03/01/2021 Bell, Jerilyn 5
79 Motion motion # 16 motion to bar the death penaly for failure to state and offense punishable by death 03/01/2021 Bell, Jerilyn 15
80 Motion moition # 17 notice of defendants election to proceed under ocga 17-16-1 et seq 03/01/2021 Bell, Jerilyn 3
81 Motion moition # 18 motion for disclosure of favorable information 03/01/2021 Bell, Jerilyn 14
82 Motion moition #19 motion for dsiclousre of crimes wrongs or acts general bad character or prior conviction evidence and for a pretrial hearing to determine its admissibility 03/01/2021 Bell, Jerilyn 3
83 Motion moition #20 motion to bar introduction of any evidence relating to prior convictions or bad acts 03/01/2021 Bell, Jerilyn 8
84 Motion motion #21 motion for an order permitting discovery of transcript exhibits other memorialization of the grand jury proceedings 03/01/2021 Bell, Jerilyn 5
85 Motion motion #22 motion to require the state to provide al information regarding procedures used to identify defendant as one of the alleged perpetrators in this case 03/01/2021 Bell, Jerilyn 8
86 Motion motion # 23 motion for disclosure of psychiatric history of states witnesses 03/01/2021 Bell, Jerilyn 5
87 Motion motion # 24 motion to inspect examine and test physical evidence 03/01/2021 Bell, Jerilyn 8
88 Motion motion #25 motion for disclosure of scientific and expert reports 03/01/2021 Bell, Jerilyn 24
89 Motion moition #26 motion for production of georgia bureau of investigation crime laboratory written and recorded materials regarding this case including autopsy reports autopsy photographs and all other official reports lab notes and otehr recorded information related to this case 03/01/2021 Bell, Jerilyn 10
90 Motion motion #27 motion for an order requiring the disclosure of all information regarind state experts testing and examinations 03/01/2021 Bell, Jerilyn 9
91 Motion motion #28 motion for phone records and for electronic data in raw native form 03/01/2021 Bell, Jerilyn 13
92 Motion motion #29 motion for the production of toxicology and other scientific and expert reports regarding the decedent 03/01/2021 Bell, Jerilyn 10
93 Motion motion #30 motion for disclosure of electronic surveillance 03/01/2021 Bell, Jerilyn 5
94 Motion motion #31 motion to compel disclosure of confidential informants 03/01/2021 Bell, Jerilyn 11
95 Motion motion # 32 motion for disclosure of deal with candice crocker roy prater and any other prosecution witnessess 03/01/2021 Bell, Jerilyn 8
96 Motion motion #33 motion to produce photographs videotapes and digitally enhanced pr processed images 03/01/2021 Bell, Jerilyn 8
97 Motion motion # 34 notice of defendants intent to challenge the grand and traverse jury array 03/01/2021 Bell, Jerilyn 16
98 Motion motion # 35 motion to produce the testimony before the superior court of effingham county relating and pertaining to the search warrants issued in this case 03/01/2021 Bell, Jerilyn 3
99 Motion motion # 37 general demurrer 03/01/2021 Bell, Jerilyn 4
100 Motion motion # 36 special demurrer and motion to dismiss the indictment 03/01/2021 Bell, Jerilyn 5
101 Motion motion # 38 motion for bill of particulars for each count of the indictment 03/01/2021 Bell, Jerilyn 4
102 Motion motion # 39 motion to require the state to disclose information that would br favorable to the defense at the penalty phase 03/01/2021 Bell, Jerilyn 20
103 Motion motion # 3 motion reserving the right to file additional motions 03/01/2021 Bell, Jerilyn 4
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