now comes the defendant joseph bebo in the above numbered cause and does move

this court in limine for rulings as to the admissibility of the following evidentiary items
prior to opening statements of counsel. In support hereof the defendant says that the
proposed evidence set forth below is inadmissible and highly prejudicial to the defense;

1.) defendant moves that this court exclude 911 phone calls to the brockton police
station. These contain inadmissible hearsay and violate the defendants constitutional
rights of confrontation and are irrelevant and immaterial to the case at trial.

2.) defendant moves that the proposed witness Joshua Mcdonough not be referred to
by his purported nickname “murder” as he was referenced in the grand jury. It is
expected that the defense will call Mcdonough as a witness and this is clearly
unnecessary and prejudicial to the defendant.

3.) defendant moves that the list of books or magazines alleged to have been seized
from the trunk of his car involving such topics as how to beat the polygraph and how to
save your assets and dissapear be excluded as prejudicial and immaterial. These items
were seized from the trunk of the defendant’s automobile pursuant to a search with a
warrant that has already been litigated as to the constitutionality of the search.

4.) defendant moves that all alleged conversation involving Raymond Muse and other
individuals present at the fight including Sean Curran and Joshua Pezzanetti that the
government may try to elicit including conversation after the stabbing where it is alleged
that Raymond Muse told people that “bebo wasnt there” or any conversation regarding
Muse or Tia Staroben or Sarah Raymond either telling witnesses that they were “wrong”
in their statements or accusing them of being “snitches” and threatening them not to say
anything be excluded. Further it is alleged that Joshua Pezzanetti contacted Raymond
Muse and Joshua Curran asking for the name of the unknown male (alleged to be Bebo
and his being told by Curran that he “couldnt drop names”. There is no evidence that
this was pursuant to any conspiracy or coverup that the defendant was involved in or
even aware of. At best it is a product of Raymond Muse’s self serving explanation as to
why he lied about his involvement in an effort to protect bebo. This evidence is hearsay
and inadmissible and clearly prejudicial to the defendant.

by his atty etc.

also laura...can you email me who has been served and who hasnt
also could you fx this motion to tom
also add the following to the final witness list:

Jordan Gonsalves
36 Reservoir Drive
Brockton, Ma.

Danielle walsh
36 union st.
stoughton, ma.

amanda eckman
(call tom and get address)

nicole tiso
120 Ingall St.
Taunton, Ma.

nicholas bebo
78 peters drive
stoughton, ma.

lisa mcdonough
(same address as josh a/k/a mookie