CAUSE NO. 

THE STATE OF TEXAS

V.

JOHN DOE

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

	MOTION TO REQUIRE THE STATE TO REVEAL
ANY AGREEMENT ENTERED INTO BETWEEN THE
STATE AND ANY PROSECUTION WITNESS THAT COULD
CONCEIVABLY INFLUENCE THEIR TESTIMONY

TO THE HONORABLE JUDGE OF SAID COURT:
	COMES NOW, JOHN DOE, Defendant in the above styled and numbered cause, and moves the Court to issue an order requiring the State to reveal any agreement entered into between the District Attorney's Office or any other law enforcement agency and any other prosecution witness that could conceivably influence said witnesses' testimony on the following grounds:
-1-
	That the credibility of said witnesses will be an important issue in the principal cause and the evidence of any understanding or agreement as to future prosecution or benefit, either promised or contemplated to be promised, whether implied or express, would be relevant to the said witnesses' credibility and the trial jury is entitled to know of it.
-2-
	The Defendant would further move the Court to order the State, by and through its attorneys, to reveal any promises, whether implied or express, or any aid, assistance, reward, compensation, or benefit conferred or to be conferred upon any witness, which said witness or witnesses would or might receive if said witnesses testified on behalf of the State, or any implied or express promise of aid or assistance or of possible benefit made by the State, by or through any attorney or law enforcement agency, to any attorney or member of the family or to any other person with whom said witness may have been associated or through whom said witness may have learned of said promise.
-3-
	That in the event any such agreement has been entered into between the State and any prosecution witness, the Defendant hereby requests the name and address of each such witness, and the exact and complete nature of the agreement, including, aid, assistance, reward, compensation or benefit conferred or to be conferred upon said witness.
	WHEREFORE, PREMISES CONSIDERED, the Defendant respectfully prays that this Honorable Court will entertain this Motion prior to the commencement of the trial herein and hold a hearing in order to permit the Defendant to develop evidence herein in order to establish the existence of such an agreement entered into between the State and any prospective prosecution witness that could conceivably influence the testimony of such witness.

Respectfully submitted,

By:                                                                 

CERTIFICATE OF SERVICE
	I certify that on this day a copy of the above and foregoing Motion to Require the State to Reveal Any Agreement Entered Into Between the State and Any Prosecution Witness That Could Conceivably Influence Their Testimony 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 to Require the State to Reveal Any Agreement Entered into Between the State and Any Prosecution Witness That Could Conceivably Influence Their Testimony and it is in all things (GRANTED) (DENIED), to which action of the Court Defendant duly excepts).

	SIGNED                                                              , 200__.

							JUDGE PRESIDING