Motion to Require the State to Prove Beyond a Reasonable Doubt that Defendant is Irreparably Corrupt, the “Worst Offender”, and That This is the “Worst Case”
Motion to Require the State to Prove Beyond a Reasonable Doubt that Defendant Committed the Homicide and Had the Intent to Kill
Motion to Exclude the Admissibility of Bad Acts / Aggravation (see discovery motion requesting notice)
Motion for Court to Hold that the State has Failed to Meet their Burden and Therefore the Defendant Must Receive Sentence of Life with Parole (to be filed after State has rested at Sentencing Hearing)