North Carolina Office of Indigent Defense Services

You are here: Home / Archives for Motions and Briefs

Motions and Briefs

Motion to Exclude Firearm Identification Testimony of Agents Tanner and Ware

//  by 

Trial court denied the motion, but initially prohibited the State from offering testimony “that the bullets in question were fired from the same weapon” because of potential for misleading the jury. However, the testimony was allowed after the trial court found the defense opened the door to the testimony during opening statements.

Motion to Exclude Firearm Identification Testimony of Agents Tanner and WareRead More

Motion to Exclude Firearm Identification Testimony, Memorandum of Law, State’s Brief in Response to Defendant’s Motion, and Order

//  by 

2011 motion in limine by Richard Ramsey. Example of how to use the National Academy of Sciences report and other professional standards in a motion to exclude or suppress forensic evidence. Transcript of motion’s hearing available upon request.

Motion to Exclude Firearm Identification Testimony, Memorandum of Law, State’s Brief in Response to Defendant’s Motion, and OrderRead More

Motion to Suppress DNA Evidence

//  by 

Motion to exclude the SBI’s analysis of DNA evidence where analysis entirely consumed the sample and was performed in violation of a court order. Drafted by Lisa Dubs and Mark Rabil. Orders – Orders from the case above, including Order to Preserve Evidence and Notes, order to not test evidence without written consent of the state …

Motion to Suppress DNA EvidenceRead More