V. MOTION IN LIMINE TO PROHIBIT USE OF THE DEFENDANT’S ALLEGED PRIOR BAD ACTS
20. Defendant incorporates by reference the allegations contained in Paragraphs 1-19, inclusive of this Motion as if same were fully set forth herein at length.
21. The Defendant believes and therefore avers that the Commonwealth will seek to introduce evidence of alleged prior uncharged bad acts of Cuadra.
22. The probative value of said evidence is far outweighed by its prejudicial effect.
23. Any alleged prior uncharged bad acts offenses of Cuadra are not relevant nor bear any similarity to the present offenses against Cuadra.
24. Any alleged prior uncharged bad acts of Cuadra are not prior convictions for crimen falsi offenses.
25. Said evidence is otherwise not permissible under Pennsylvania’s Rules of Evidence and violates Cuadra’s rights under the Pennsylvania and United States Constitutions.
26. Cuadra has neither been charged; nor been convicted of any such acts.
WHEREFORE, the Defendant, Harlow Cuadra, respectfully requests this Honorable Court to enter an Order prohibiting the Commonwealth from introducing any alleged prior bad acts of Cuadra.
20. Defendant incorporates by reference the allegations contained in Paragraphs 1-19, inclusive of this Motion as if same were fully set forth herein at length.
21. The Defendant believes and therefore avers that the Commonwealth will seek to introduce evidence of alleged prior uncharged bad acts of Cuadra.
22. The probative value of said evidence is far outweighed by its prejudicial effect.
23. Any alleged prior uncharged bad acts offenses of Cuadra are not relevant nor bear any similarity to the present offenses against Cuadra.
24. Any alleged prior uncharged bad acts of Cuadra are not prior convictions for crimen falsi offenses.
25. Said evidence is otherwise not permissible under Pennsylvania’s Rules of Evidence and violates Cuadra’s rights under the Pennsylvania and United States Constitutions.
26. Cuadra has neither been charged; nor been convicted of any such acts.
WHEREFORE, the Defendant, Harlow Cuadra, respectfully requests this Honorable Court to enter an Order prohibiting the Commonwealth from introducing any alleged prior bad acts of Cuadra.
