Cause No. __________

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

MOTION IN LIMINE NO. ___
(PRIOR CRIMINAL RECORD)

TO THE HONORABLE JUDGE OF SAID COURT:

	COMES NOW ***, 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 of counsel, the direct and cross-examination of any witnesses, jury arguments, or during any part of the punishment hearing, if same becomes necessary, that the 
Defendant may have been previously convicted of any criminal law offense or may have been charged or arrested for any criminal offense or may have any criminal case presently pending against him/her, in the presence of the jury until a hearing has been held outside the presence of the jury to determine the admissibility of 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.  In an effort to avoid prejudice by the jury and abuse of discretion by the court, Defendant urges this motion in limine.

(Insert argument based on the facts of your case to negate admissibility of the prior arrests, charges, or convictions including Tex. R. Evid. 403.)
	WHEREFORE, PREMISES CONSIDERED, the Defendant respectfully prays that this 
honorable Court will grant this his 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. ___ (Prior Criminal Record) 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. ___ and the same is hereby GRANTED and the prosecution is ordered to advise the Court prior to eliciting any testimony concerning any prior record of arrest or conviction of the Defendant, in the presence of the jury, until a hearing has been held outside the presence of the jury to determine the admissibility of such testimony.

SIGNED this _____ day of _____________________, 200___.

____________________________________
JUDGE PRESIDING