CAUSE NO. __________

STATE OF TEXAS				§		IN THE _______________ COURT
						§
V.						§		______________COUNTY, TEXAS
						§
[DEFENDANT]				§		_______TH JUDICIAL DISTRICT

MOTION FOR PRODUCTION OF WITNESS STATEMENTS

TO THE HONORABLE JUDGE OF SAID COURT:

	NOW COMES______________, the Defendant in the above styled and numbered cause, by and through his undersigned attorney, and based upon the Fifth, Sixth and Fourteenth Amendments of the Constitution of the United States of America, Article 1, Sections 10 and 19 of the Constitution of the State of Texas, Rules 612 and 615, Texas Rules of Evidence, and Tex. Code Crim. Proc. art. 39.14, and respectfully moves this Honorable Court to order the District Attorney or his Assistant to produce, after a witness called by the State has testified on direct examination, the following requested items, to-wit:

1.	All of the statements, whether in writing or however recorded and whether signed or 
unsigned, of any witness called to testify by the State, after his direct examination.  Texas Rules of Evidence Rule 615(a).
	__________GRANTED
	__________DENIED

2.	All documents used by the witness to refresh his memory concerning the facts in this cause, either prior to his testimony in this case or as he was giving direct testimony in this cause before the trier of fact.  Texas Rules of Evidence Rule 612.
__________GRANTED
	__________DENIED

3.	A transcript of the Grand Jury testimony of any witness called by the State to testify after the witness has completed his direct examination.  Texas Rules of Evidence, Rule 615(a).
	__________GRANTED
	__________DENIED

4.	Any police report where same is shown to purport to be what the witness observed or did at the time in question and which concerns facts testified to by the witness on direct examination whether made by the witness or not as long as the witness has adopted same as correct.  Texas Rules of Evidence, Rules 615(a) and (f).
	__________GRANTED
	__________DENIED

5.	Any document, object, photo or chart, the contents of which may in any way be placed before the jury before or during direct examination of the witness.
__________GRANTED
__________DENIED

6.	The Defendant further requests the Court to order the District Attorney or his Assistant to not, in the presence of the jury, offer any of the foregoing statements, documents, charts, photographs or other requested objects in evidence until their admissibility has been established outside the presence of the jury.
__________GRANTED
__________DENIED

7.	The Defendant further requests the Court to recess the trial upon production of the above requested statements for the purpose of allowing the Defense to examine the statement prior to cross examining the witness.  Texas Rules of Evidence, Rule 615(d).
__________GRANTED
__________DENIED
	
	As a basis for this motion, Defendant would show the Honorable Court that he cannot under the Sixth and Fourteenth Amendments of the Constitution of the United States and Article 1, Sections 10 and 19 of the Texas Constitution, properly cross examine the witnesses without the production of the material requested.

	WHEREFORE, PREMISES CONSIDERED, Defendant respectfully prays this Motion be in all things granted.
							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 for Production of 
Witness’ Statements 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 DEFENDANTS MOTION FOR PRODUCTION OF WITNESS STATEMENTS

	On this_____day of___________, 200__, the Defendant's Motion For Production of Witness 
Statements was presented to the Court.  Upon consideration, the motion is hereby:
						
__________GRANTED as above indicated

__________DENIED as above indicated, to which action of the Court the Defendant duly excepts.

	The prosecution is further ordered to have available in Court, after the witness testifies, all 
of the documents ordered produced herein.

			SIGNED AND ENTERED this _____ day of ____________________, 200___.

						____________________________________
						JUDGE PRESIDING