CAUSE NO. 

THE STATE OF TEXAS

V.

DEFENDANT

§	IN THE ___________________COURT
§
§	OF
§
§	_____________COUNTY, TEXAS

NOTICE OF MOTION TO PERMIT THE INSPECTION AND COPYING  OF ITEMS COVERED BY TEXAS CODE OF CRIMINAL PROCEDURE ARTICLE 39.14

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 gives notice to the State of his Motion for the Inspection and Copying of Items Covered by Texas Code of Criminal Procedure, Article 39.14.
	Article 39.14, Texas Code Crim. Proc. provides the following:

	Discovery

Upon motion the Defendant showing good cause
therefore and upon notice to the other parties, the court
in which an action is pending may order the State before
or during  trial of a  criminal action  therein pending or
on trial  to produce  and permit  the inspection  and
copying or  photographing by or on  behalf of the
Defendant of any designated documents, papers, written
statement of the Defendant, (except written statements of
witnesses and except the work product of counsel in the
case and their investigators and their notes or report,)
books, accounts, letters, photographs, objects or tangible
things not  privileged, which constitute or contain
evidence material to any matter involved in the action
and which are in possession, custody or control of
the State or any of its agencies. The order shall specify
the time, place and manner of making the inspection and
taking the  copies and photographs  of any of the
aforementioned  documents or tangible evidence;
provided, however, that the rights herein granted shall
not extend to written communications between the State

or any of its agents or representatives or employees.
Code of Criminal Procedure, Art. 39.14.

II.
	The defense asserts that it wishes to inspect and to make copies of all the items specifically listed in the foregoing article along with the following documents and tangible items which are also covered by the following article:

1.		Any medical report, scientific report, coroner’s report,
		psychological report, psychiatric report, etc. dealing with the
		Defendant and/or any of his alleged victims;
2.		Any video tape or audio tape of the Defendant, and/or of any
		alleged victim of the Defendant.
3.		Any writings purported to be that of the Defendant or of his
		alleged victims.
	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__.

CAUSE NO. 

THE STATE OF TEXAS

V.

DEFENDANT

§	IN THE ______________COURT
§
§	OF
§
§	_______________COUNTY, TEXAS

O R D E R

	On this day, came on to be heard the Notice of Motion to Permit the Inspection and Copying  of Items Covered by Texas Code of Criminal Procedure Article 39.14 and it is in all things (GRANTED) (DENIED, to which action of the Court Defendant duly excepts).

	SIGNED                                                              200__.

							JUDGE PRESIDING