Name of State
Plaintiff Plaintiff Attorney Defendant Defendant Attorney Case Number
Title of Motion
Put your Jurisdiction statement in here. Below is an example of what I have submitted as a jurisdiction statement. You should consult your statutes, and rules of court for your particular jurisdiction. WARNING Jurisdiction can be a problem if the courts do not want to grant it. This particular portion is important to getting your cause heard.
Comes now, Robin C. McDermott, defendant pursuant to Missouri Supreme Court Rule 24.05, prior to trial, and does request that the presumed testimony be suppressed of the State’s endorsed witnesses::
The following text boxes are all facts, Judges will on ly reconsider their order based on facts.
Thomas D. Royal-Springfield Police Department cpl. Phillips- Springfield Police Department</b></li> Darren Whisnant-Springfield Police Department</b></li> Tammy Laazier-Frazee- Springfield Police Department</b></li> Doug Wilson-Springfield Police Department</b></li>
Here is where you put your argument.
The testimony of said witnesses is not relevant to the crime charged, and testimony of these witnesses would only be hearsay and not admissible. The official arrest report of Officer Smith fails to note any witness to the alleged crime. Further the arrest and incident reports of any and all other officers listed on the endorsement do not mention that they were witnesses to the alleged crime. The defendant in her motion for discovery has requested "The name and last known address of persons whom the State intends to call as witnesses at any hearing or at trial, together with their written or recorded statements, and existing memoranda reporting or summarizing part or all of the their oral statements." None of the information provided to the defendant substantiates the materiality of the endorsed state’s witnesses, as none of these aforementioned state witnesses claim to have been present at the scene of the alleged crime nor to have witnessed the alleged crime or to have any knowledge at all of the alleged crime. Any such admission of their testimony would not be relevant and is hearsay as to the charge.
Here is the prayer for relief, tell the court what you want. You may not think it but the court did make compromises with me on this motion.
Wherefore, the defendant has presented to this Honorable Court her firm belief that said listed state witnesses are immaterial and therefore must request that these witnesses and their testimony be suppressed.
Respectfully Submitted,
I hereby certify this pleading was served upon all attorneys of record for each of the parties to this action and All parties not represented by counsel, in the following manner: ___ By delivering a copy to him/her; ___ By leaving a copy at his/her office with the clerk; ___ By leaving a copy at his/her office with an attorney associated with him/her; ___ By mailing a copy to him/her, as prescribed by law; ___ By faxing a copy to him/her.
The foregoing pleading will be called for hearing before the court on at 1 pm or as soon thereafter as petitioner may be heard.
So noticed: _______________________________
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