CAUSE NO. 

THE STATE OF TEXAS

V.

JOHN DOE

§	IN THE ____________COURT
§
§	OF
§
§	_______________ COUNTY, TEXAS

MOTION FOR A HEARING ON THE ADMISSIBILITY OF 
ENHANCEMENT PORTION OF INDICTMENT PRIOR TO THE 
VOIR DIRE OF THE JURY PANEL

TO THE HONORABLE JUDGE OF SAID COURT:
	COMES NOW, JOHN DOE, Defendant in the above-styled and -numbered cause, acting by and through his attorney of record, and hereby moves that the Court conduct a hearing prior to the voir dire examination for the purposes of the enhancement portion of Defendant's indictment, and would show the following:
I
	In order to conduct a proper voir dire of the prospective jury panel, Defendant must know the correct range of punishment which Defendant faces.  If Defendant does not know whether the enhancement count of the indictment is admissible, Defendant will not know which range of punishment is applicable to this case during jury selection and will therefore not be able to properly qualify said panel.
	WHEREFORE, PREMISES CONSIDERED, JOHN DOE, Defendant, prays that the Court conduct a hearing prior to voir dire examination for the purposes of determining the admissibility of the enhancement of Defendant's indictment.

Respectfully submitted,

By:                                                     

CERTIFICATE  OF  SERVICE

	This is to certify that a true and correct copy of the above and foregoing Motion for a Hearing on the Admissibility of Enhancement Portion of Indictment Prior to the Voir Dire of the Jury Panel was hand-delivered or mailed, postage prepaid, to the __________Attorney of____________ County, Texas, on the _____ day of ______, 200__.

CAUSE NO. 

THE STATE OF TEXAS

V.

JOHN DOE

§	IN THE ____________COURT
§
§	OF
§
§	_______________ COUNTY, TEXAS

	O R D E R

	On this day, came on to be heard the Motion for a Hearing on the Admissibility of Enhancement Portion of Indictment Prior to the Voir Dire of the Jury Panel and it is in all things (GRANTED) (DENIED, to which action of the Court Defendant duly excepts).

	SIGNED                                                              , 200__.

							JUDGE PRESIDING