Cause No. __________

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

MOTION IN LIMINE NO. ___
(STATEMENTS MADE WHILE UNDER ARREST)

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 may have made a statement immediately after he/she was detained and/or arrested in this cause, to any law enforcement official or agent thereof, 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.

(Insert case law and evidence to negate the admissibility of the testimony based on the facts of your case.)

	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. ___ (Statements Made While under Arrest) 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 statements allegedly made by the Defendant immediately after he/she was detained and/or arrested by law enforcement officials or their agents, and order that a hearing be conducted outside the presence of the jury to determine the admissibility of said testimony.
SIGNED this _____ day of ________________________, 200___.

____________________________________
JUDGE PRESIDING