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Electronically Filed
2/4/2015 8:20:15 AM
Lois Rogers, Smith County District Clerk
Reviewed By: Jennifer Black
NO.12—2355-D
IN THE INTEREST OF § IN THE DISTRICT COURT
§
TRISTAN VAUGHAN, TANNER § 321JUDICIAL DISTRICT
VAUGHAN, TARIN VAUGHAN AND §
TRINITY VAUGHAN §
§
CHILDREN § SMITH COUNTY, TEXAS
FIRST AMENDED MOTION IN LIMINE
This First amended Motion in Limiue is brought by LACY VAUGHAN, Respondent, who
requests the Court:
1. To instruct the attorneys not to mention, refer to, or bring before the jury, directly or
indirectly, on voir dire examination, reading of the pleadings, statement of the case, interrogation 0f the
witnesses, argument, objections before the jury, or in any other manner any of the matters enumerated
below, unless and until the matters have first been called to the Court's attention out of the presence and
hearing of the jury and a favorable ruling received on the admissibility and relevance 0f the matters.
2. To instruct the attorneys for DANIEL VAUGHAN, KAREN VAUGHAN,
MICHAEL BROYLES, and KRISTIN BROYLES to inform DANIEL VAUGHAN, KAREN
VAUGHAN, MICHAEL BROYLES, and KRISTIN BROYLES and all witnesses called by either 0f
said parties to refrain from mentioning or referring to, inany way, in the presence or hearing of the july,
any of the matters enumerated below, unless specifically permitted to do so by ruling 0f the Court.
3. To instmct the attorneys for DANIEL VAUGHAN, KAREN VAUGHAN,
MICHAEL BROYLES, and KRISTIN BROYLES that violation of any of these instructions may cause
harm t0 LACY VAUGHAN and deprive LACY VAUGHAN of a fairand impartial trial,and the failure
to abide by the instructions may constitute contempt 0f court.
Cause No. 12-23550; ITIO Vaughan Children
First Amended Motion in Lllninc
Pagel
The matters prohibited are:
1. The filing of this motion, or any ruling by the Court 0n this motion, suggesting
01'implying to the jury that LACY VAUGHAN has wrongfully and improperly moved t0 prohibit proof.
2. Any adultery, cruelty, 01‘ other acts 0f fault indisrupting the marital relationship
between LACY VAUGHAN and AARON VAUGHAN
3. Any reference t0 settlement negotiations.
4. Any evidence of the character, reputation, or quality 0f, or the fees for, legal
services rendered by any attorneys in this case, unless attorney's fees are a jury issue.
5 . Any references t0 the terms of any temporary orders.
6. Any reference t0 sexual activity 0n the party of LACY VAUGHAN not
conducted in the presence of a child the subject 0f this suit or in that child’s sphere of awareness.
7. Examining any witness concerning grounds for termination or conservatorship.
8. Making reference to any temporary or interlocutory order requiring a party to
pay interim attorney fees for any attorney or any attorney ad litem.
9. Any suggestion of drug use during pregnancy.
10. Any mention of any juvenile adjudication.
11. Any Violation of any temporary order.
12. Any mention of Violation of a court order in suit affecting parent-ohild
relationship for which any part has not been sued for enforcement and/or not been tried and convicted of
contempt 0f court.
PRAYER
LACY VAUGHAN prays that the Court grant this First amended Motion in Limine.
Respectfully Submitted,
LAW OFFICES OF SAMUEL M. GEORGE
400 Troup Highway
Tyler, Texas 75701
Tel: (903) 595—6000
Cause No. 12-2355-D; ITIO Vaughan Children
Amended Motion in Limine
First
Page 2
Fax: (903) 595-6066
ByW/l,
'
SAMUEL M. GEORGE? K
State Bar No. 07806700
nicnat@sudden1inkmai1.com
Attorney for LACY VAUGHAN
Certificate 0f Service
I certify that a true copy of the above was served on Alicia Barkley, Michael Hogan, Matthew
Thigpen and Ric Freeman, by efile, in accordance with the Texas Rules of Civil Procedure 0n February
SAMUEL
7W1“
M. GEORGE I
Attorney for LACY VAUGHAN
Cause N0. |2-2355-D; ITIO Vaughan Children
First Amended Motion in Limine
Page 3
Preview
Electronically Filed 2/4/2015 8:20:15 AM Lois Rogers, Smith County District Clerk Reviewed By: Jennifer Black NO.12—2355-D IN THE INTEREST OF § IN THE DISTRICT COURT § TRISTAN VAUGHAN, TANNER § 321JUDICIAL DISTRICT VAUGHAN, TARIN VAUGHAN AND § TRINITY VAUGHAN § § CHILDREN § SMITH COUNTY, TEXAS FIRST AMENDED MOTION IN LIMINE This First amended Motion in Limiue is brought by LACY VAUGHAN, Respondent, who requests the Court: 1. To instruct the attorneys not to mention, refer to, or bring before the jury, directly or indirectly, on voir dire examination, reading of the pleadings, statement of the case, interrogation 0f the witnesses, argument, objections before the jury, or in any other manner any of the matters enumerated below, unless and until the matters have first been called to the Court's attention out of the presence and hearing of the jury and a favorable ruling received on the admissibility and relevance 0f the matters. 2. To instruct the attorneys for DANIEL VAUGHAN, KAREN VAUGHAN, MICHAEL BROYLES, and KRISTIN BROYLES to inform DANIEL VAUGHAN, KAREN VAUGHAN, MICHAEL BROYLES, and KRISTIN BROYLES and all witnesses called by either 0f said parties to refrain from mentioning or referring to, inany way, in the presence or hearing of the july, any of the matters enumerated below, unless specifically permitted to do so by ruling 0f the Court. 3. To instmct the attorneys for DANIEL VAUGHAN, KAREN VAUGHAN, MICHAEL BROYLES, and KRISTIN BROYLES that violation of any of these instructions may cause harm t0 LACY VAUGHAN and deprive LACY VAUGHAN of a fairand impartial trial,and the failure to abide by the instructions may constitute contempt 0f court. Cause No. 12-23550; ITIO Vaughan Children First Amended Motion in Lllninc Pagel The matters prohibited are: 1. The filing of this motion, or any ruling by the Court 0n this motion, suggesting 01'implying to the jury that LACY VAUGHAN has wrongfully and improperly moved t0 prohibit proof. 2. Any adultery, cruelty, 01‘ other acts 0f fault indisrupting the marital relationship between LACY VAUGHAN and AARON VAUGHAN 3. Any reference t0 settlement negotiations. 4. Any evidence of the character, reputation, or quality 0f, or the fees for, legal services rendered by any attorneys in this case, unless attorney's fees are a jury issue. 5 . Any references t0 the terms of any temporary orders. 6. Any reference t0 sexual activity 0n the party of LACY VAUGHAN not conducted in the presence of a child the subject 0f this suit or in that child’s sphere of awareness. 7. Examining any witness concerning grounds for termination or conservatorship. 8. Making reference to any temporary or interlocutory order requiring a party to pay interim attorney fees for any attorney or any attorney ad litem. 9. Any suggestion of drug use during pregnancy. 10. Any mention of any juvenile adjudication. 11. Any Violation of any temporary order. 12. Any mention of Violation of a court order in suit affecting parent-ohild relationship for which any part has not been sued for enforcement and/or not been tried and convicted of contempt 0f court. PRAYER LACY VAUGHAN prays that the Court grant this First amended Motion in Limine. Respectfully Submitted, LAW OFFICES OF SAMUEL M. GEORGE 400 Troup Highway Tyler, Texas 75701 Tel: (903) 595—6000 Cause No. 12-2355-D; ITIO Vaughan Children Amended Motion in Limine First Page 2 Fax: (903) 595-6066 ByW/l, ' SAMUEL M. GEORGE? K State Bar No. 07806700 nicnat@sudden1inkmai1.com Attorney for LACY VAUGHAN Certificate 0f Service I certify that a true copy of the above was served on Alicia Barkley, Michael Hogan, Matthew Thigpen and Ric Freeman, by efile, in accordance with the Texas Rules of Civil Procedure 0n February SAMUEL 7W1“ M. GEORGE I Attorney for LACY VAUGHAN Cause N0. |2-2355-D; ITIO Vaughan Children First Amended Motion in Limine Page 3