1. All defense evidence is prejudicial to the state, that is the point of a defense.
2. They conflate "harmful to the prosecution" with "unfairly prejudicial," and mis-cite Evidence Rule 403, which is based on FRE 403 and is not exotic or hard to understand.
3. The Delphi/Allen material is not merely collateral; Todd Click was charged because of his role as a witness in the Allen proceedings. Click's attorneys have the right to develop any "theory of case" that they wish, and this is their theory of case.
4. "Not mention, allude, or in any way refer to..." is overbroad and is in effect a dragnet, and unconstitutional.
5. A motion in limine is not a vehicle to control admissibility, because admissibility depends on foundation and context. This should be reserved for a offer-of-proof, outside the jury's presence.
6. The movant, in this case the state, has the burden in a motion in limine to explain the issue, and they've provided no analysis as to why the things they claim are prejudicial are prejudicial (not that it matters, because see (1-5 above)).
7. Potentially most importantly: if this motion were granted, the defense couldn't cross-examine the state's witnesses (ISP) on anything to do with the Delphi/Odinism drama that brought Click into this situation.