Category: Post-Charge and Trial Issues

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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
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.
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.
Legal Document Repository

Defense’s Motion to Sever Offenses (State of Washington v. William Talbott)

Defense’s motion to sever offenses in a Washington double homicide case that occurred in 1987. The defense argues that the two homicides in question should be charged separately based upon differences in proof for each murder including the date, time, and location of each incident.
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Affidavit of Probable Cause (State of Washington v. Terrence Miller)

Prosecution’s charging affidavit detailing a Washington murder-sexual offense case that occurred in 1972. This affidavit includes details of the investigation such as the Forensic Genetic Genealogy process used in this case, the suspect’s criminal history, and charges brought against the suspect 47-years after the incident occurred.
Legal Document Repository

Affidavit of Probable Cause (State of Washington v. William Talbott)

Prosecution’s charging affidavit detailing the case against the defendant in a Washington double homicide case that occurred in 1987.   Included in the affidavit was a description of the surreptitious collection of the defendant’s DNA once he was identified as a likely suspect from the results of the family tree build-out and the ensuing match and confirmation to the DNA recovered from the female victim decades earlier.
District Attorney’s Office, Denver, CO

People’s Response to Defense Motion to Dismiss (State of Colorado v. Hector Bencomo-Hinojos)

Prosecution’s response to the defense’s motion to dismiss a Colorado sexual homicide that occurred in 1981. The prosecution’s response addresses the defense’s due process arguments of a preindictment delay of 30 years and advances in forensic techniques that occurred since the date of the incident which enabled investigators to leverage forensic DNA analysis and the Combined DNA Index System (CODIS).