“If I had eight hours to chop down a tree, I’d spend six hours sharpening my ax.” A. Lincoln
At the start of a trial, the judge and attorneys may need to address a number of “housekeeping” tasks, as well as to resolve issues relating to motions made previously.
Attorneys often make motions in limine, which will need the judge’s attention near the beginning of trial.
The following is a list of issues that frequently arise:
• Sandoval – Pretrial motion issues not yet ruled on
• Molineux – Presence of all jurors after recesses
• Brady – Numbering of indictment counts
• Discovery – Sequestration of witnesses
• Redaction – Preliminary jury instructions
• Preclusion – Renewal or reargument of previous motions
• Witness Lists – Proposed stipulations
• Audibility – Scheduling
• Protective order – Calling witnesses out of order; Use of charts or computers.
Gary Muldoon is a lawyer and author of “Handling a Criminal Case in New York.” His email address is firstname.lastname@example.org.