IV. MOTION IN LIMINE TO PROHIBIT USE OF THE DEFENDANT’S PRIOR
CRIMINAL RECORD
14. Defendant incorporates by reference the allegations contained in Paragraphs 1-13, inclusive of this Motion as if same were fully set forth herein at length.
15. Cuadra believes and therefore avers that the Commonwealth will seek to introduce evidence of Cuadra’s alleged prior convictions, if any.
16. The. probative value of said evidence is far outweighed by its prejudicial effect.
17. Any alleged prior offenses of Cuadra are not relevant; nor bear any similarity to the present offenses against the Defendant.
18. Any alleged prior offenses of Cuadra are not crimen falsi offenses.
19. Presentation of said evidence is otherwise not permissible under Pennsylvania’s Rules of Evidence and violates Cuadra’s rights under the Pennsylvania and United States Constitutions.
WHEREFORE, the Defendant, Harlow Cuadra, respectfully requests this Honorable Court to enter an Order prohibiting the Commonwealth from introducing Cuadra’s prior criminal record.
CRIMINAL RECORD
14. Defendant incorporates by reference the allegations contained in Paragraphs 1-13, inclusive of this Motion as if same were fully set forth herein at length.
15. Cuadra believes and therefore avers that the Commonwealth will seek to introduce evidence of Cuadra’s alleged prior convictions, if any.
16. The. probative value of said evidence is far outweighed by its prejudicial effect.
17. Any alleged prior offenses of Cuadra are not relevant; nor bear any similarity to the present offenses against the Defendant.
18. Any alleged prior offenses of Cuadra are not crimen falsi offenses.
19. Presentation of said evidence is otherwise not permissible under Pennsylvania’s Rules of Evidence and violates Cuadra’s rights under the Pennsylvania and United States Constitutions.
WHEREFORE, the Defendant, Harlow Cuadra, respectfully requests this Honorable Court to enter an Order prohibiting the Commonwealth from introducing Cuadra’s prior criminal record.
