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Monday, April 30, 2012

Sample Motion in Criminal Matters

Our Lawyers have been helping people in San Antonio and in Texas, when it comes with their criminal matters. Our Attorneys have defended innocent people in Texas in cases of, DWI, assault, battery, and other criminal matters. Bellow is a sample motion filed on behalf of our clients in District Criminal Courts.


Now comes PERSON, Defendant, and files this Motion for a List of Witnesses and seeks production of the items requested herein below relating to witnesses to be called by the State at any stage of the proceedings in this cause:

1. A list of the names and addresses of all witnesses the prosecution intends to call at any stage of the proceedings in this cause.

2. A list of the names, addresses and professions of all expert witnesses the prosecution intends to call at any stage of the proceedings in this cause, along with each expert's qualifications, the subject and a description of his or her contemplated testimony, and his or her report.

3. Any evidence in possession of the state that any of its witnesses is presently incompetent to testify, or that any of its witnesses has been found incompetent to testify, incompetent, or insane.

4. The criminal record of each witness for the state showing every conviction or probation for felony or misdemeanor involving moral turpitude which is admissible for impeachment under Rule 609 of the Texas Rules of Evidence.

5. The criminal record of each witness for the state showing every event which can be used to impeach the witness including any deferred adjudication probations, arrests, or juvenile adjudications pending against the witness between the time of the offense alleged against Defendant and Defendant's trial.

6. All inducements offered by the state which might tend to motivate its witnesses to testify against Defendant, including, but not limited to, plea bargain agreements, fee, expense, or reward arrangements, agreements to dismiss or reduce or not bring charges, or any other agreement of leniency.

7. All writings used to refresh the recollection of any witnesses, as provided in Rule 612 of the Texas Rules of Evidence.

8. Any supplementation hereof should be produced no later than 24-hours prior to the trial in this matter. See Hightower v. State, 629 S.W.2d 920 (Tex. Crim. App. 1981); Young v. State, 547 S.W.2d 23 (Tex. Crim. App. 1977).

9. In support of this motion, Defendant would show that (a) the items requested are in the exclusive possession, custody and control of the State of Texas or the United States Government by and through its agents, the police or the prosecuting attorney's office, and Defendant has no other means of ascertaining the disclosure requested; (b) the items requested are not privileged; (c) the items and information requested are material to this cause and the issues of guilt or innocence and punishment to be determined in this cause; (d) Defendant cannot safely go to trial without such information and inspection, nor can Defendant adequately prepare a defense herein; (e) Defendant's rights will be violated under Article 39.14 of the Texas Code of Criminal Procedure, Article I, Sections 3, 3a, 10, 13 and 19 of the Constitution of the State of Texas, and the Fifth, Sixth, Eighth and Fourteenth Amendments to the Constitution of the United States of America absent such discovery.

If you have been wrongfully accused in San Antonio, our law firm can help you with your legal defense. We handle all criminal matters for our clients in Texas, San Antonio, and in Bexar County. Give us a call (210) 979-9777 and you will know why our motto is:"we care about your legal needs!"


San Antonio Criminal Defense Attorney said...

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