Cause No. __________

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

MOTION IN LIMINE NO. ___
(OTHER PROCEEDINGS)

TO THE HONORABLE JUDGE OF SAID COURT:

	COMES NOW ***, the Defendant in the above styled and numbered cause and respectfully requests this honorable Court to instruct the prosecution not to mention, allude to, or refer to, directly or indirectly, during any stage of this trial, including but not limited to the voir dire examination, opening statements, and the direct and cross-examination of any witness, the fact that 
the Defendant herein is or may have been involved in another legal proceeding arising from the same facts of this case or the result, orders or judgment resulting from that case, until such time as a hearing has been conducted out of the hearing of the jury to determine the admissibility of any such testimony.

	The Defendant further requests that this Court instruct the prosecution to advise the Court prior to eliciting any such testimony in order for the Court to excuse the jury and conduct a hearing outside the presence of the jury, without the necessity of counsel for the Defendant having to object to said testimony and request that the hearing be held outside the presence of the jury.

(If needed insert facts relevant to your case and use rules of evidence such as 403 to bolster your motion.)

	WHEREFORE, PREMISES CONSIDERED, the Defendant respectfully prays that the 
honorable Court will grant this his/her Motion In Limine No. ___.

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 Motion in Limine No. ___ (Other Proceedings) 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

On this the _____ day of __________________, 200___, came on to be heard the Defendant's Motion In Limine No. ___ (Other Proceedings) and the same is hereby GRANTED.  The prosecution is ordered to advise the Court prior to eliciting any testimony that the Defendant herein is or may have been involved in another legal proceeding arising from the same facts as this case or the result, orders or judgment resulting from that case, until such time as a hearing is conducted outside the presence of the jury to determine the admissibility of such testimony.

SIGNED this _____ day of ________________________, 200___.

____________________________________
JUDGE PRESIDING