Motion to Restrict Publicity
by Edwin J. Youngblood
CAUSE NO.

STATE OF TEXAS		IN THE 91ST DISTRICT COURT
	§
VS.	§	OF
	§
	§	EASTLAND COUNTY, TEXAS
 
MOTION TO RESTRICT PUBLICITY
TO THE HONORABLE JUDGE OF SAID COURT:
	Now comes ________________, the Defendant, by and through attorney of record, and requests the Court to restrict publicity in this case, and for good cause shows the following:
	1.	
This case has garnered extensive coverage in the media and on the internet.
	2.	
________________ intends to produce evidence during pretrial hearings which might impair the possibility of obtaining a fair and unprejudiced jury. Accordingly, ________________ respectfully moves this Court to hold all pretrial hearings in chambers, outside the presence and hearing of the public and the press.
	3.	
________________ respectfully moves this Court to restrict the news media as follows:
		A.	
From taking any photographs in the courthouse of the defendant or witnesses or any person or persons connected with these proceedings;
		B.	
From photographing, or televising, or broadcasting these proceedings in or from the Courtroom or in such proximity as to disturb the order and decorum of the trial;
		C.	
From photographing ________________ at any time during these proceedings or at any time while being transported to the Courtroom;
		D.	
From reporting in detail the evidence obtained by this Court during pretrial hearings other than reporting that certain persons testified at said hearings;
		E.	From photographing venirepersons and jurors in this case.
	4.	
________________ further requests that the Court order that no person, law enforcement personnel, witness, court participant, or counsel comment to the media on any matter concerning this case at any time during its pretrial or trial.
Respectfully submitted,

The Law Office Of Edwin J. Youngblood
1200 Summit Ave., Ste. 412
Fort Worth, Texas 76102
Tel: (817)338-4777
Fax: (817)335-8349

By: ________________________________
Edwin J. Youngblood
State Bar No. 22215900
Attorney for _______________________________

CERTIFICATE OF SERVICE
	This is to certify that on ________________, a true and correct copy of the above and foregoing document was served on the District Attorney’s Office by (hand delivery)(by mail.)

____________________________________
Edwin J. Youngblood
CAUSE NO. 

STATE OF TEXAS		IN THE 91ST DISTRICT COURT
	§
VS.	§	OF
	§
	§	EASTLAND COUNTY, TEXAS
 
ORDER
	On ___________________, 2009, came on to be considered _________________’s Motion to Restrict Publicity, and said motion is hereby
(Granted)  (Denied)

______________________________
JUDGE PRESIDING