Author: Yujiemi Chisholm

Legal Document Repository

State of Washington v. William Talbott – Case Documents

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
National Institute of Justice

National Best Practices for Implementing and Sustaining a Cold Case Investigation Unit

The U.S. Justice Department’s National Institute of Justice (NIJ) assembled and collaborated with the Cold Case Investigation Working Group (CCIWG) in developing this guide to assist law enforcement agencies in creating a mechanism for addressing the cold cases in their jurisdictions [Description provided by the NIJ website].
Legal Document Repository

Defendant’s Trial Brief (State of Washington v. William Talbott)

Defense’s trial brief in a Washington double homicide case that occurred in 1987. The defense raises confrontation clause issues regarding testimonial evidence from absent witnesses (including individuals involved in the forensic testing of evidentiary items in the case) and chain of custody and admissibility issues regarding evidence collected during the autopsy of one of the victims.
Office of Justice Programs

Investigating Violent Crime: The Prosecutor’s Role – Lessons Learned From the Field

Based on the discussions of seasoned prosecutors of violent crime who met in 2017 to examine how to improve the investigation of violent crimes, this paper reviews the various phases of an investigation and provides an overview of issues discussed, along with representative descriptions of the approaches used and challenges faced by the jurisdictions represented [Description provided by the OJP website].
Legal Document Repository

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

Prosecution’s trial memorandum detailing the anticipated evidence and course of the investigation in a Washington double homicide case that occurred in 1987. This included the steps taken during the Forensic Genetic Genealogy investigation leading to the defendant. The motion in limine focused on the admissibility of the defense’s efforts to introduce “other suspect” evidence.