CAUSE NO. 

THE STATE OF TEXAS

V.

DEFENDANT

§	IN THE _______________COURT
§
§	OF
§
§	_____________COUNTY, TEXAS

MOTION FOR ADDITIONAL WRITTEN VOIR DIRE

TO THE HONORABLE JUDGE OF SAID COURT:

	COMES NOW, Defendant in the above styled and numbered cause, by and through his counsel of record,_____________, and moves this Court to submit the following additional written voir dire, attached hereto, together with the usual written voir dire information submitted to potential jurors prior to jury selection. Counsel asks for such additional written voir dire because of the inflammatory and embarrassing nature of the offense(s) charged: because of the need to prevent embarrassment of jurors at oral voir dire; because of the need to obtain truthful, confidential answers from potential jurors sensitive questions; because of the need to conserve the Court’s time during oral voir dire, and because of the need to select a fair and impartial jury in such a difficult case.

	WHEREFORE, PREMISES CONSIDERED, the Defendant respectfully prays that the Motion herein be granted.

Respectfully submitted,

CERTIFICATE OF SERVICE

	The undersigned attorney, does hereby certify, that a true and correct copy of the foregoing Motion was delivered to the CrimDA/CtyAtty of______________- County, Texas on the ______ day of _________, 200__.

                                                     

APPENDIX A

ADDITIONAL WRITTEN VOIR DIRE

LADIES AND GENTLEMEN:

	You are potential jurors for a case involving charges of , the Defendant's name in this case is .  The offense is alleged to have occurred on or about ________, in  County, Texas.  Because of the nature of the case, and because of out need to gain truthful answers to questions about sensitive subjects, this written voir dire is being given to you to be filled out and brought to Court by you for jury selection on ____________, at _______.m.  You are not required to sign or place your name on this document, but you are required to place your juror number on the first page.  These additional written voir dire sheets will be destroyed by the Court following the end of the jury selection except as to those jurors selected as the actual jurors in the case.  The sheets of those actually selected will be destroyed following the verdict in this case unless the State of the Defense request that they be preserved for legal reasons.  Please answer the following questions as truthfully and completely as you can, remember as you are answering these questions that the Defendant is presumed to be innocent.

	1.	Do you know any of the attorney involved in this case?

		a.	, Attorney for Defendant.	Yes ____ No ____
		b.	______________, Assistant District Attorney.	Yes ____ No ____

	2.	If your answer is yes, how do you know this individual, and how close is this relationship? _______________________________________________________ ______________________________________________________________________________________________________________________________________________________________________________________________________

	3.	The following is a list of persons with their occupation who may or may not be witnesses in the case or be mentioned in the case.  Do you know any of these people?

		a.	______________________, Occupation	Yes ____ No ____
		b.	______________________, Occupation	Yes ____ No ____
		c.	______________________, Occupation	Yes ____ No ____
		d.	______________________, Occupation	Yes ____ No ____
		e.	______________________, Occupation	Yes ____ No ____
		f.	______________________, Occupation	Yes ____ No ____

	4.	If your answer is yes, how do you know this individual, and how close is this relationship? _______________________________________________________ ______________________________________________________________________________________________________________________________________________________________________________________________________

	5.	If you answered yes to knowing any attorney or other person whose name is listed above, do you feel that knowing such person will affect you in being a juror in this case:	Yes ____ No ____

	6.	This case involves a factual setting whereby , the Defendant is charged by indictment with the offense of .  The Defendant is ________________________(Occupation).  Have you read any newspaper accounts or seen and/or heard any radio or television account of this case?	Yes ____ No ____

	7.	If your answer to the above question was yes, please describe what you read, what you heard, or what you saw?   ____________________________________ ______________________________________________________________________________________________________________________________________________________________________________________________________

	8.	If your answer to the above question is yes, do you believe what you read, saw, or heard regarding this case would affect your service?   ___________________ ______________________________________________________________________________________________________________________________________________________________________________________________________

	9.	Have you at this time formed a belief as to guilt or innocence of the accused?

		Yes ____
		No  ____

	10.	What is that belief? _________________________________________________ ______________________________________________________________________________________________________________________________________________________________________________________________________

	11.	This case involves allegations of child sexual abuse.  have you, your family, or close friends, had experiences involving child sexual abuse, or the prosecution of child sexual abuse?  	Yes ____ No ____

	12.	Please describe those experiences.  [Reminder: your responses to this questions will be kept confidential except as required by law]  ______________________ ______________________________________________________________________________________________________________________________________________________________________________________________________

	13.	If your answer to the above question was yes, would those experiences affect you if you were selected as a juror in this case?  	Yes ____ No ____

	14.	Do you feel that you would be fair and impartial juror for the Defendant as well as for the State?  	Yes ____ No ____

	15.	If your answer to the above question was no, please state the reason why you do not feel you could be fair and impartial.  ________________________________ ______________________________________________________________________________________________________________________________________________________________________________________________________

	16.	The punishment range for the offense of  is _____________________________.

If there was a verdict of guilty [remember that a Defendant is presumed innocent]; could you fairly consider the lower range of punishment?

		Yes ____
		No  ____

	17.	Could you fairly consider the higher range of punishment?	Yes ____ No ____

	18.	If the jury should impose a sentence of ten years or less, the jury can recommend to the Court that the sentence be probated and that the Defendant be place on community supervision.  Could you fairly consider such probation in a case where the offense charged is ?	Yes ____ No ____

	19.	This trial is expected to last ______ days from ___________ to _____________
Given this, is there any reason why you could not serve as a juror during this time period?	Yes ____ No ____

	20.	If your answer to the above question was yes, please describe your situation:
______________________________________________________________________________________________________________________________________________________________________________________________________

CAUSE NO.  

THE STATE OF TEXAS

V.

§	IN THE 
§
§	OF
§
§	 COUNTY, TEXAS

O R D E R

	On this day, came on to be heard the Motion for Additional Written Voir Dire and it is in all things (GRANTED) (DENIED, to which action of the Court Defendant duly excepts).

	SIGNED                                                              

							JUDGE PRESIDING