Cause No. __________

STATE OF TEXAS				§		IN THE _______________ COURT
						§
V.						§		COURT DESIGNATION
						§
***						§		_______________ COUNTY, TEXAS

DEFENDANT'S MOTION IN LIMINE NO.___
(NAME CALLING BY PROSECUTION)

	NOW COMES ***, the Defendant in the above entitled and numbered cause, by and 
through Counsel, and moves the Court as follows:
The Defendant requests the Court to instruct the Prosecuting Attorney and his assistants not to engage in any name-calling of the Defendant, but rather refer to him/her only by his/her Christian and surname, the "Defendant" or the “Accused".

	Movant would show that the use of any other name could only be for the purpose of attaching derogatory and satirically unflattering labels to the Defendant and same would be prejudicial and likely to create bias against the Defendant before the jury which would prevent him/her from obtaining a fair trial in violation of the Fifth and Fourteenth Amendments to the United States Constitution, Article I, Sections 10 and 19 of the Texas Constitution, and Articles  1.04 and 1.05 of the Texas Code of Criminal Procedure.

	WHEREFORE, PREMISES CONSIDERED, the Defendant respectfully prays this 
Honorable Court grant this motion.

Respectfully Submitted,

____________________________________
Attorney Name
State Bar Number
Address
City, State, Zip
Phone 
Fax

Attorney for Defendant
***

CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of the foregoing Defendant’s Request for Notice of Extraneous Offenses was served upon the attorney for the State on ________________________, 200___.

____________________________________
Attorney for Defendant

						

Cause No. __________

STATE OF TEXAS				§		IN THE _______________ COURT
						§
V.						§		COURT DESIGNATION
						§
***						§		_______________ COUNTY, TEXAS

ORDER
	
Came on to be considered the Defendant’s Motion in Limine No. _____ (Name Calling by Prosecution).  Upon consideration of the motion and argument of counsel, the motion is GRANTED.  During the trial of this case, the attorneys for the State are ordered not to call or refer to the Defendant by any name other than his/her Christian and surname, the “Defendant” or the “Accused”.
SIGNED on the _____ day of ___________, 200___.

____________________________________
JUDGE PRESIDING