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

Prosecuting Attorney’s Office, Snohomish County, WA | Jun 5, 2019

Defense raises the following issues:

confrontation clause issues regarding testimonial evidence from absent witnesses and
chain of custody and admissibility issues regarding evidence collection during the victim’s autopsy.

Related Resource(s)

Washington v. Talbott II – Case Resources

July 2019 Investigative Resource Repository,Post-Charge - Case,Prosecuting Attorney’s Office, Snohomish County, WA Washington v. Talbott II

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...

Motion for New Trial (Washington v. Talbott II)

July 2019 Investigative Resource Repository,Post-Charge and Trial Issues,Prosecuting Attorney’s Office, Snohomish County, WA Washington v. Talbott II

Defense argues prosecutorial misconduct and evidentiary insufficiency...

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

June 2019 Investigative Resource Repository,Post-Charge and Trial Issues,Prosecuting Attorney’s Office, Snohomish County, WA Washington v. Talbott II

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

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

May 2019 Investigative Resource Repository,Post-Charge and Trial Issues,Prosecuting Attorney’s Office, Snohomish County, WA 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...

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

May 2019 Investigative Resource Repository,Post-Charge and Trial Issues,Prosecuting Attorney’s Office, Snohomish County, WA Washington v. Talbott II

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

Affidavit of Probable Cause (Washington v. Talbott II)

June 2018 Investigative Resource Repository,Post-Charge and Trial Issues,Prosecuting Attorney’s Office, Snohomish County, WA Washington v. Talbott II

Prosecuting attorney’s charging affidavit detailing the case against the defendant for the 1987 murders of Tanya VanCuylenberg and Jay Roland Cook...