MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT’S MOTIONS IN LIMINE

DEFENDANT’S MOTION TO PRECLUDE PROSECUTORS FROM MAKING
POST-VERDICT STATEMENTS CONCERNING ANY ARREST AND/OR
CRIMINAL CONVICTION RECORD OF THE DEFENDANT TO MEMBERS
OF THE JURY AFTER VERDICT IS RENDERED OR A MISTRIAL GRANTED
TO PREVENT HARASSMENT AND TAINTING THE JURY BY NEGATIVE INFLUENCING FUTURE JURY SERVICE