What are the best arguments to support the objections


Problem: The defendant is charged with importation and possession of marijuana with intent to distribute. The defendant and her boyfriend had crossed from the U.S. into Mexico to do some shopping, and returned later in the day. At the border the defendant was driving the boyfriend's van. The van was searched, and border agents found 89 packages weighing a total of 151 pounds in a false compartment in the van's ceiling.

After she was arrested, the defendant took a polygraph exam. The exam showed that the defendant was not being deceptive when she denied knowing that there was marijuana in the van at the time she drove the van to the border. Before the trial starts the defense moves in limine to admit the results of the polygraph exam.

In addition, the defense also moves to bar the testimony of a U.S. Customs agent who is expected to testify in the prosecution's case that he has been a border agent for several years, that during those years "on a number of occasions I've talked to individuals in organizations that smuggle marijuana across the border, and they explain that nobody in their right mind would entrust that amount of marijuana to someone that doesn't know what they're doing."

The following then happens:

Judge: I have two defense motions, one to admit results of a polygraph examination, the other to preclude the anticipated testimony of a government witness. Counsel, why do I need to hear or rule on these motions at this time?

1. What objections and motions should be made?

2. What are the best arguments to support the objections?

3. What are the best arguments to oppose the objections?

4. What are the proper rulings?

5. How else could these issues have been?

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