CAUSE NO. 1587614

STATE OF TEXAS	§	IN THE JUDICIAL DISTRICT	
	§
V.	§	338TH DISTRICT COURT
	§
_______________________			§	HARRIS COUNTY, TEXAS

MOTION TO DISCLOSE EXPERTS

TO THE HONORABLE JUDGE OF SAID COURT:
	COMES NOW, _____________________, a party in the above captioned and numbered cause, by and through his attorney MARK THIESSEN pursuant to TEX.  CODE CRIM. PROC., art.3914 (b) [1999]. After notice to the Harris County District Attorney’s office, the attorney for the State herein, the Defendant request this Court enter an order directed to Harris County District Attorney’s, the attorney for the State, to disclose to the undersigned attorney Mark Thiessen all expert witnesses. Said disclosure shall be by a date which is at least twenty (20) days before the trial is scheduled to begin. The disclosure shall contain the names(s) and address(es) of each person who the State and the Attorney for the State may use to present evidence under Rules 702, 703, and 705, Texas Rules of Evidence at the trial in the above captioned and numbered cause. The attorney for defendant further request, as required by TEX. CODE CRIM. PROC., art. 39.14 (b) [1999], that said order specify a time, no later that the 20th day before the date the trial begins herein for the State and its attorney to make the disclosure to the Defendant, and further, that said order specify the manner in which the State and his attorney must make said disclosure to the Defendant.

Respectfully Submitted,
						THE THIESSEN LAW FIRM

												               						By:	_____________________________
	MARK THIESSEN 
SBN:  24042025
mark@thetexastrialattorney.com
TALY JACOBS
							SBN:  24074476
							taly@thetexastrialattorney.com
CHRIS DENUNA
							SBN: 24092338
							chris@thetexastrialattorney.com
733 E. 12 ½ Street
							Houston, Texas 77008
							PH: (713) 864-9000
							FX: (713) 864-9006

Attorney for Defendant
						________________________

CERTIFICATE OF SERVICE
		
	I hereby certify that a true and correct copy of the foregoing Motion have been submitted to the Assistant District Attorney assigned to this case, on this the _______ day of _____________, 20___.
							___________________________
							MARK THIESSEN

CAUSE NO. 1587614

STATE OF TEXAS	§	IN THE JUDICIAL DISTRICT	
	§
V.	§	338TH DISTRICT COURT
	§
_______________________			§	HARRIS COUNTY, TEXAS

ORDER ON MOTION TO DISCLOSE EXPERTS

	BE IT REMEMBERED that on this day, after proper and timely notice to the State, by and through its attorney of record, came on to be heard and considered the Defendant’s Motion To Disclose Experts, and in which the Defendant request that the State and its attorney disclose the name(s) and address(es) of each person who the State and the Attorney for the State may use to present evidence under Rules 702, 703, and 705, Texas Rules of Evidence at the trial in the above captioned and numbered cause.
The Court having considered said Motion, it is hereby:
	ORDERED that said Motion to Disclose is (GRANTED)   (DENIED)
	ORDERED that the State and its attorney are directed to disclose to the Defendant, by and through his Attorney, Mark Thiessen, the name(s) and address(es) of each person who the State and its attorney for the State may use to present evidence under Rules 702, 703, and 705, Texas Rules of Evidence at trial in the above captioned and numbered cause at least Twenty (20) days before trial is scheduled to begin, herein, and that the manner of making that disclosure is as follows: 
Written notice, faxed, mailed or personally served.
SIGNED AND ENTERED this _____ day of ____________________, 20___.
																				_________________________________
							JUDGE PRESIDING