Cause No. __________

STATE OF TEXAS				§		IN THE _______________ COURT
						§
V.						§		COURT DESIGNATION
						§
***						§		_______________ COUNTY, TEXAS

MOTION TO FILE ADDITIONAL MOTIONS

TO THE HONORABLE JUDGE OF SAID COURT:

	NOW COMES ***, the Defendant in the above entitled and numbered cause, and requests leave to file additional motions at a later time and for cause would show the Court as follows:

	Defendant is required, by [local rules] [Court Order] and Article 28.01, Section 2 of the Texas Code of Criminal Procedure, to file all pre-trial motions not less than seven (7) days before any hearing upon such motions. Defendant has in good faith attempted to file such pre-trial motions as appear to be at this time necessary and relevant to the trial of Defendant.  In the event that additional matters become known to the defense, after the exercise of due diligence, the Defendant requests leave of Court to file additional motions at a later date.  

	This motion is not made for purposes of delay, but so that justice might be done.  Failure to grant this motion would violate rights guaranteed to the Defendant by the Fourth, Fifth, Sixth and Fourteenth Amendments to the Constitution of the United States, Article I, Sections 9, 10, 13 and 19 of the Constitution of the State of Texas, and Articles 1.04, 1.05, 1.051(a) and 106 of the Texas Code of Criminal Procedure.

	WHEREFORE, PREMISES CONSIDERED, Defendant prays that the Court, upon good 
cause shown, grant to Defendant the opportunity to file additional motions herein.

Respectfully Submitted,

____________________________________
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.						§		COURT DESIGNATION
						§
***						§		_______________ COUNTY, TEXAS

					ORDER

BE IT REMEMBERED, that on the ______ day of _______________, 200___, came on to 

be considered the above and foregoing Motion for  Leave to File Additional Motions by Defendant.  

After consideration of the motion, it is hereby:

__________	GRANTED.

__________	DENIED, to which ruling the Defendant excepts.

SIGNED on the _____ day of ___________________, 200___.

____________________________________
JUDGE PRESIDING