Category: Prosecuting Attorney’s Office, Snohomish County, WA

Investigative Resource Repository

Washington v. Miller – Case Resources

1) Affidavit of Probable Cause
2) Defendant’s Motion to Exclude Evidence
3) Defense Trial Brief and Motions in Limine
4) State’s Response to Defense Motions

October 2020

Investigative Resource Repository

State’s Response to Defense Motions (Washington v. Miller)

Prosecution addresses four evidentiary issues raised in the case including: 1) relevance of jail calls made by the defendant, 2) access to firearms, 3) newspaper articles, and 4) statistical probability not necessary pertaining a to female fraction in a differential extraction.

October 2020

Investigative Resource Repository

Defense Trial Brief and Motions in Limine (Washington v. Miller)

In advance of trial, the defense submits a host of evidentiary issues and advances objections to evidence anticipated for trial.

October 2020

Investigative Resource Repository

Defendant’s Motion to Exclude Evidence (Washington v. Miller)

Defendant’s motion to exclude evidence based on deficient chain of custody and testimonial foundation which included a lack of witnesses.

October 2020

Investigative Resource Repository

Washington v. Talbott II – Case Resources

1) Affidavit of Probable Cause
2) State’s Trial Memorandum and Motions in Limine
3) Defense’s Motion to Sever Offenses
4) Defendant’s Trial Brief
5) Defendant’s Supplement Motions in Limine
6) Motion for New Trial

July 2019

Investigative Resource Repository

Motion for New Trial (Washington v. Talbott II)

Defense argues prosecutorial misconduct and evidentiary insufficiency.

July 2019

Investigative Resource Repository

Defendant’s Supplement Motions in Limine (Washington v. Talbott II)

Defense requests evidentiary rulings on items of evidence including photographs, certain testimony, and exclusion of “genetic genealogy evidence.”

June 2019

Investigative Resource Repository

Defendant’s Trial Brief (Washington v. Talbott II)

Defense raises the following issues: 1) confrontation clause issues regarding testimonial evidence from absent witnesses and 2) chain of custody and admissibility issues regarding evidence collection during the victim’s autopsy.

June 2019

Investigative Resource Repository

State’s Trial Memorandum and Motions in Limine (Washington v. Talbott II)

Prosecution’s trial memorandum detailing the anticipated evidence and course of the investigation. Evidentiary issues also included in a motion in limine.

May 2019

Investigative Resource Repository

Defense’s Motion to Sever Offenses (Washington v. Talbott II)

Defense argues that the two homicides charged be severed based upon difference in proof for each murder.

May 2019