CAUSE NO. __________

STATE OF TEXAS				§		IN THE _______________COURT
					§
V.						§		_____________ COUNTY, TEXAS
					§
[DEFENDANT]				§		_______ TH JUDICIAL DISTRICT

MOTION TO ALLOW ADDITIONAL MOTIONS AND
FOR A SECOND PRE-TRIAL HEARING

TO THE HONORABLE JUDGE OF SAID COURT:

	COMES NOW, ________________, Defendant in the above styled and numbered cause, by and through his undersigned attorney and files this MOTION TO ALLOW ADDITIONAL MOTIONS AND FOR A SECOND PRE-TRIAL HEARING, and for same would show unto the Court the following:
I.
	The Defendant would show that the State has provided very limited voluntary discovery.   Therefore, Defendant has filed numerous motions for discovery and inspection and other motions in connection with the purported facts underlying the indictment herein.  It was necessary to request an investigator and several experts based on the information received to date.
II.
	Because the information the Court will order the State to produce will be produced after the deadline set by the Court for filing of motions, it may become necessary that additional motions be filed based upon such information and documents so produced, and on information received as a result of the work of the new investigator and experts.  The purpose of this motion is to put the State on notice that there may be a necessity for second pre-trial hearing and for filing additional motions based upon the information and documents produced under the Court's order as a result of the motions filed and to request permission at a future specified date set by the Court to file additional motions, if necessary.

III.
	The Defendant would show that motions may be filed at any time, for good cause shown.

	WHEREFORE, PREMISES CONSIDERED, Defendant respectfully prays that the Court allow the filing of additional motions and set a second Pre-trial hearing. 

							_______________________________
							Attorney Name
							State Bar Number
							Address
							City, State, Zip
							Phone 
							Fax

							ATTORNEY FOR DEFENDANT

CERTIFICATE OF SERVICE

	This is to certify that a true and correct copy of the foregoing Motion to File Additional 
Motions was served upon the attorney for the State on ________________________, 200___.

							___________________________________
							Attorney for Defendant

CAUSE NO. __________

STATE OF TEXAS				§		IN THE _______________COURT
					§
V.						§		_____________ COUNTY, TEXAS
					§
[DEFENDANT]				§		_______ TH JUDICIAL DISTRICT

ORDER ON DEFENDANT’S MOTION TO ALLOW ADDITIONAL MOTIONS AND
FOR A SECOND PRE-TRIAL HEARING

	On this day, came to be heard Defendant’s Motion To Allow Additional Motions and For a Second Pre-Trial Hearing, and the said Motion is hereby in all things:

				_____________DENIED AND IT IS SO ORDERED.

				_____________GRANTED, and leave is granted to file additional motions by order of this Court.
	A second pre-trial hearing it hereby set for the _____ day of _________, 20__, and the Defendant is hereby ordered to appear. 

			SIGNED and ENTERED on this the ____ day of ______________, 20__.

		_______________________
		JUDGE PRESIDING