Lisa Stahl in 'Burke's Law: Who Killed the Centerfold?'
Lisa Stahl (1965 - )
a.k.a. Lisa Stahl-Sullivan, a.k.a. Carol Stahl-Sullivan
Invasion U.S.A. (1985) [Teen Girl on Beach]: Shot to death (off-screen) with a silenced pistol by one of the terrorists on the beach; the scene cuts away just as he fires. Her body is not shown afterwards. (Thanks to Rocky)

Shallow Grave (1987) [Sue Ellen]: Presumably killed (off-screen) by Tony March after he gets into the ambulance with her; the movie ends with the ambulance driving off, just as Tom Law realizes that Tony is indeed the killer.

Burke's Law: Who Killed the Centerfold? (1995) [character name unavailable]: Strangled (though I don't know by whom). (Thanks to Nick)
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