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Category: Prosecuting Attorney’s Office, Snohomish County, WA
Legal Document Repository

State of Washington v. Terrence Miller – Case Documents

These case documents pertain to the 1972 Washington murder-sexual offense case, State of Washington v. Terrence Miller, and collectively outline the evidentiary disputes central to the case, the parties’ competing positions on the admissibility and reliability of historical forensic evidence, and the investigative basis for the long-delayed charges. The materials include: (1) the prosecution’s response to multiple evidentiary issues raised by the defense; (2) the defense’s trial brief and motions in limine; (3) the defense’s motion to exclude evidence; and (4) the prosecution’s charging affidavit.
October 2020
Legal Document Repository

State of Washington v. William Talbott – Case Documents

The case documents pertain to the 1987 Washington double homicide case, State of Washington v. William Talbott, and collectively outline the parties’ positions on evidentiary and constitutional issues, the use and admissibility of Forensic Genetic Genealogy (FGG)derived investigative leads, and the forensic and procedural basis for charging decisions in this decades old double homicide case. The materials include: (1) the defense’s motion for a new trial; (2) the defense’s supplemental motions in limine; (3) the defense’s trial brief; (4) the defense’s motion to sever offenses; (5) The prosecution’s trial memorandum; and (6) the prosecution’s charging affidavit.
July 2019
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.
June 2019
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.
May 2019
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.
May 2019