Motions
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Capital Motions Section
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Preliminary Motions | Client Care | Ex Parte | Discovery | Grand Jury | Constitutionality | Suppression | Mental Retardation | Mental Health | Limine | Petit Jury | Jury Charge | Sentencing | Miscellaneous
1.2 Request That Defense Be Allowed To Occupy Counsel Table Nearest To The Jury Box
1.1 Notice Of Filing In Compliance With The American Bar Association’s Guidelines For The Appointment And Performance Of Defense Counsel In Death Penalty (2003)
1.3 Occupy Counsel Table Nearest To Jury 2021
1.4 Court To Direct The Court Reporter To Record Proceedings (Fact Specific) 2021
1.5 Defendant’s First Motion For Continuance 2021
1.6 Dismiss This Prosecution Or Preclude The Death Penalty Because, Due To Delay, Evidence Has Gone Missing, Important Witnesses Have Died, And 2021
1.7 Motion For Immunity For Potential Defense Witnesses 2021
1.8 Motion For Limited Daily Transcripts 2021
1.9 Motion To List Witnesses And Request For Criminal Histories (Fact Specific) 2021
1.10 Motion For Leave To File Additional Pre-Trial Motions (Fact Specific) 2021
1.11 Motion For Complete Recordation Of All Pre-Trial And Trial Proceedings 2021
1.12 Defendant’s Motion For A Restrictive Order Regulating News Accounts, Comments And Editorials Concerning Certain Circumstance Of The Case 2021
1.13 Motion To Adjourn At A Reasonable Time 2021
1.14 Motion To Preclude Uniformed Police Officers From Attending The Proceeding Against Mr. [Client] And Limit The Show Of Force In The Courtroom 2021
1.15 Motion To Preclude Mr. [Client] From Being Shackled In Public 2021
1.16 Motion To Require The Prosecution To Respond In Writing To Every Written Motion Filed By The Defense 2021
1.17 Defendant’s Motion To Require The State To Answer All Contested Pre-Trial Motions In Writing (Fact Specific) 2021
1.18 Objection To Court’s Proposed Schedule (Fact Specific) 2021
1.19 Motion To Preclude Uniformed Police Officers From Attending Proceedings 2021
1.20 Motion To Preserve Right To File Other Motions 2021
1.21 Request That Court Maintain Appropriate Decorum During Trial 2021
1.22 Motion To Require The State To Give Notice Of Any Intent To Seek The Death Penalty 2021
1.23 Defendant’s Assertion Of Rights 2021
Client Care
2.1 Motion To Allow Defendant To Appear At Pretrial Hearings And Trial In Civilian Clothes And Funds For Such Suitable Courtroom Attire 2021
Ex Parte Motions
3.1 Motion To Proceed Ex Parte 2021
3.A Counsel
3.A.1 Motion For Payment Of Adequate Compensation To Court-Appointed Counsel 2021
3.A.2 Motion For Appointment Of Additional Counsel 2021
3.A.3 Motion For Appointment Of Appellate Counsel 2021
3.B Investigator
3.C Mitigator
3.C.1 Ex Parte, Sealed Funding Motion For Mitigation Specialist 2021
3.D Victim Outreach
3.D.1 Verified, Ex Parte And Sealed Funding Motion For Defense-Based Victim Outreach Specialist 2021
3.E Experts
3.E.1 Ex Parte, Sealed Funding Motion For Mental Health Expert (Psychologist) 2021
3.E.2 Ex Parte, Sealed Funding Motion For Expert Assistance (Classification Expert) 2021
3.E.3 Ex Parte, Sealed Funding Motion For Expert Assistance (Expert On Involuntary Confessions) 2021
3.E.4 Ex Parte Motion For Funds With Which To Retain Necessary Expert Assistance (Fact Specific) 2021
3.E.5 Ex Parte Motion For Funds With Which To Retain Expert Assistance Of A Statistician (Fact Specific) 2021
3.E.6 Ex Parte Motion For Reconsideration Of Defendant’s Motion For Funds With Which To Retain Expert Assistance Of A Statistician And For An Ex Parte Hearing (Fact Specific) 2021
3.E.7 Motion To Set Parameters For The Evaluation Of The Defendant By Dr. Tynus Mcneel, An Expert Witness Retained By The State To Rebut Psychological Or Psychiatric Testimony If Actually Offered By The Defendant 2021
4.1 Defendant’s Motion For Disclosure – Brady Material (Plea Offer) 2021
4.1 Defendant’s Motion For Disclosure – Brady Material (Plea Offer) 2021
4.2 Defendant's Ex Parte Sealed Motion For An Order Compelling Production Of Cell Tower Records 2021
4.3 Motion For Discovery, Production, And Rule 702/705 Hearing 2021
4.4 Defendant’s Motion For Discovery And Inspection 2021
4.5 Motion For Discovery And Limiting Instructions To The Jury 2021
4.6 Defendant’s Motion For Discovery Of Experts 2021
4.7 Defendant’s Motion To Discovery State’s Extraneous And/Or Unadjudicated Acts Of Misconduct To Be Offered At Guilt Or Punishment 2021
4.8 Motion To Discover Prosecution’s Medical And Autopsy Reports (Fact Specific) 2021
4.9 Motion For The Production Of Witness Interview Notes 2021
4.10 Motion For Disclosure Of Any Possible Basis For Judicial Qualification Or Recusal 2021
4.11 Motion For Discovery, Production, And Inspection Of Evidence (Fact Specific) 2021
4.12 Motion For Equal Access To Background Information On Prospective Jurors (Fact Specific) 2021
4.13 Motion For In Camera Inspections (Fact Specific) 2021
4.14 Motion To Preserve Evidence 2021
4.15 Motion For Discovery And Inspection 2021
4.16 Motion For Preservation And Production Of Evidence (Fact Specific) 2021
4.17 Motion For Production Of Exculpatory, Impeachment And Mitigating Evidence (Fact Specific) 2021
4.18 Motion For Production Of Documents Relevant To Under-Representation Of Cognizable Groups In The Grand Jury In [County] County 2021
4.19 Motion For Production Of Documents Relevant To Under-Representation Of Cognizable Groups In The Grand Jury In Rusk County (Fact Specific) 2021
4.20 Motion To Discover The Portion Of The Defendant’s Statement Which The State Intends To Use At Time Of Trial 2021
4.21 Motion To List Exhibits To Be Offered In Both Phases Of Trial (Fact Specific) 2021
4.22 Defendant’s Notice Of Receipt Of Discovery 2021
4.23 Motion For Production Of Impeachment Evidence 2021
4.24 Sample Kyle’s Letter 2021
Grand Jury
5.1 Motion To Proceed Ex Parte 2021
5.2 Motion To Quash The Indictment Based On Discrimination In The Selection Of Grand Jurors And Grand Jury Forepersons (Fact Specific) 2021
5.3 Motion To Quash Indictment Based On Unconstitutional Statutory Provisions For The Selection Of Grand Juries 2021
5.4 Motion To Quash The Indictment And Challenge To The Composition Of Grand And Petit Juries 2021
5.5 Defendant’s Motion To Quash Indictment On Grounds That Sect. 19.03(A)(1) Tex. Penal Code Is Unconstitutional 2021
5.6 Preliminary Motion To Quash The Indictment On The Basis Of Discrimination And Systematic Exclusion In The Selection Of Grand Jurors For A Full Hearing On The Issue 2021
5.7 Defendant’s Motion To Quash Indictment On Grounds That Tex. Code Crim. Proc. Art. 37.071(2) Is Unconstitutional 2021
Constitutionality
6.1 Motion To Declare The “10-12” Rule Unconstitutional 2021
6.2 Motion Requesting The Court To Find Tex. Code Crim. Proc. Art 37.071 Sect. 2(F)(4) To Be Unconstitutional 2021
6.3 Memorandum In Support Of Motion To Preclude The Death Penalty As A Sentencing Option 2021
6.4 Motion To Declare Tex. Code Crim. Proc. Art. 37.071 Unconstitutional And For Other Relief 2021
6.5 Motion To Declare Texas Death Penalty Statute To Be Unconstitutional (Juror’s Inability To Predict Future Dangerousness) 2021
6.6 Motion To Declare The Capital Sentencing Statute Unconstitutional Because It Allows Juries To Decide Future Dangerousness Based Solely On The Factors Of The Case 2021
6.7 Motion To Hold That Tex. Code Crim. Proc. Art. 37.01 Is Unconstitutional 2021
6.8 Motion To Hold Unconstitutional Tex. Code Crim. Proc. Art. 37.071 Sect. 2(E) And (F) – Failure To Require Mitigation Be Considered 2021
6.9 Motion To Hold Statutory Definition Of Mitigating Evidence Unconstitutional As Applied To Impose A “Nexus” Limitation, And To Grant Defendant’s Requested Clarifying Voir Dire, Instruction, Argument, And Motion In Limine. Tennard V. Dretke 2021
6.10 Motion To Declare Section 19:02-19:03 Texas Penal Code Unconstitutional 2021
6.11 Motion To Find That Tex. Code Crim. Proc. Art. 37.071 Sect. 2 (2)(B)(1) Is Unconstitutional (“Future Danger” Issue) 2021
6.12 Motion To Declare Article 37.071 § 2(A) Of The Texas Code Of Criminal Procedure Unconstitutional On Its Face (Fact Specific) 2021
6.13 Motion To Declare Article 37.071 § 2(B)(1) Of The Texas Code Of Criminal Procedure Unconstitutional On Its Face (Fact Specific) 2021
6.14 Motion To Declare Article 37.071 § 2(E) And (F) Of The Texas Code Of Criminal Procedure Unconstitutional On Its Face (Fact Specific) 2021
6.15 Motion To Declare Article 37.071 Of The Texas Code Of Criminal Procedure Unconstitutional Due To Unreliability (Fact Specific) 2021
6.16 Motion For Court To Find Art. 37.071 Of The Texas Code Of Criminal Procedure Unconstitutional As Applied To This Defendant 2021
6.17 Motion To Hold Unconstitutional Tex. Code Crim. Proc. Art. 37.071 Sec. 2(E) And (F) – Burden Of Proof 2021
6.18 Motion To Hold That Tex. Code Crim. Proc. Art. 37.01 Is Unconstitutional 2021
6.19 Motion To Impanel A Jury To Determine Whether The Defendant Is Mentally Retarded 2021
6.20 Motion To Preclude Death As A Sentencing Option And To Impanel A Jury To Determine Whether Defendant Is A “Person With Mental Retardation 2021
6.21 Motion To Preclude The Death Penalty As A Sentencing Option 2021
6.22 Motion To Preclude The Death Penalty As A Sentencing Option (Selection Of Death Penalty Cases) 2021
6.23 Motion To Preclude Death Penalty As A Sentencing Option Due To Equal Protection Violations (Fact Specific) 2021
6.24 Motion To Preclude The Death Penalty Due To The Grand Jury’s Failure To Allege In The Indictment All Elements Necessary To Make The Defendant Death-Eligible (Fact Specific) 2021
6.25 Motion To Preclude The Death Penalty As A Sentencing Option And To Declare Tex. Code Crim. Proc. Art. 37.071 Unconstitutional (Ring V. Arizona) 2021
6.26 Motion To Preclude The Death Penalty As A Sentencing Option And Declare 37.071 Unconstitutional (Jones V. United States; Apprendi V. New Jersey; And Ring V. Arizona) 2021
6.27 Motion To Preclude The Death Penalty As A Sentencing Option (Unequal Funding)
Microsoft Word 2021
6.28 Motion To (1) Preclude The Death Penalty As A Sentencing Option; (2) To Preclude The Offer Of Certain Extraneous Offenses And (3) Evidence Of The Defendant’s Mental Illness To Justify A Sentence Of Death 2021
6.29 Motion To Preclude The Death Penalty As A Sentencing Option 2021
6.30 Motion To Preclude Death Penalty As A Sentencing Option, Or In The Alternative, To Quash The Indictment; Apprendi V. New Jersey / Ring V. Arizona / Blakely V. Washington / Bush V. Gore; Requests To Voir Dire / Requested Instructions / Motion In Limine, Related To Claims In This Motion 2021
6.31 Motion To Preclude The Death Penalty As Sentencing Option (Bush V. Gore) 2021
6.32 Motion To Preclude Prosecution From Seeking The Death Penalty 2021
6.33 Motion To Require Constitutional Incarceration 2021
Suppression
7.1 Motion To Suppress [Client Name]’S Records Illegally Obtained From Federally Assisted Substance Abuse Treatment Center 2021
7.2 Motion For Hearing On Admissibility Of Any Statement By Defendant Whether Written Or Oral Or Evidence Resulting From Same 2021
7.3 Motion To Suppress Due To The Violation Of The Health Insurance Portability And Accountability Act 2021
7.4 Motion For Identification Hearing Outside Presence Of Jury (Fact Specific) 2021
7.5 Motion To Prevent Improper Jury Argument By State 2021
7.6 Motion To Suppress Evidence And Statements (Fact Specific) 2021
7.7 Motion To Suppress Out-Of-Court And To Preclude In-Court Identifications 2021
7.8 Motion To Suppress Evidence Of The Identification Of The Defendant Made By The Eye Witness From A Line-Up Due To Suggestiveness Of The Identification Procedure And To Preclude In-Court Determination (Fact Specific) 2021
7.9 Motion To Preclude Admission Of Prejudicial Photographs 2021
7.10 Motion To Preclude The Offer Of Evidence Of Extraneous Offenses (Ring V. Arizona) 2021
7.11 Motion To Preclude Creation Of Snitch Testimony 2021
7.12 Motion To Prohibit Comment On The Weight To Be Given Or Credibility Of Testimony During Trial 2021
Mental Retardation
8.1 Defendant’s Motions And Additional Objections To Charge At Punishment Based Upon Atkins V. Virginia, 536 U.S. 304 (2002) 2021
8.2 Motion For Pre-Trial Determination Of Special Issue Of Mental Retardation 2021
8.3 Motion To Impanel A Jury To Determine Whether Defendant Is Mentally Retarded (Fact Specific) 2021
Mental Health
9.1 Motion For Order Clarifying The Meaning Of Competence To Stand Trial 2021
9.2 Motion To Require State To Identify Mental Health Expert And To Limit The Scope Of Examination And Other Relief 2021
Limine
10.1 Motion In Limine (Guarantee Of No Violence) 2021
10.2 Motion In Limine (Inconsistent Theories Of Prosecution) 2021
10.3 Motion In Limine (Victim Impact Type Evidence) 2021
10.4 Motion In Limine To Exclude Psychiatric Or Psychological Testimony Concerning Future Dangerousness 2021
10.5 Motion In Limine (Preclude Testimony About Violent Acts By Others) 2021
10.6 Motion For Order “In Limine” To Preserve The True And Correct Meaning Of “Probability” In The Future Dangerousness Instruction 2021
10.7 Motion In Limine No. One (Fact Specific) 2021
Petit Jury
11.1 Motion To Allow Defendant To Voir Dire On Parole Law – 40 Year Minimum 2021
11.2 Motion To Impanel Separate Juries For Guilt/Innocence And Penalty Phase Of Capital Trial 2021
11.3 Motion To Voir Dire The Panel Summoned As A Whole And Thereafter Interrogate The Members Of The Panel Individually 2021
11.4 Demand For Individual Voir Dire 2021
11.5 Jury Questionnaire 2021
11.6 Defendant’s Motion For A List Of Veniremen Summoned (Fact Specific) 2021
11.7 Motion For Special Venire (Fact Specific) 2021
11.8 Motion Seeking To Preclude Judicial Rehabilitation And Granting Improper Challenges For Cause 2021
11.9 Motion To Limit Jury Argument Of The State 2021
11.10 Motion To Restrict The Press From Filming The Jury (Fact Specific) 2021
11.11 Motion To Sequester The Jury 2021
11.12 Defendant’s Motion To Present Written Questions To The Venire 2021
11.13 Motion To Propound Specific Question To Venireman Regarding The Burden Of Proof On Special Issue – Mitigation 2021
11.14 Motion To Qualify The Panel Prior To Requiring The Defendant To Exercise His Peremptory Strikes (Fact Specific) 2021
11.15 Request For Jury List 2021
11.16 Motion To Propound Specific Questions To Veniremen Regarding The Burden Of Proof On Special Issue: Mitigation 2021
Jury Charge
12.1 Motion To Preclude The Submission Of A § 8.04(B) Instruction On Voluntary Intoxication During The Punishment Phase 2021
12.2 Motion For Jury Instruction (Failure Of Jurors To Agree On Answers To Instructions) 2021
12.3 Requested Instruction To The Jury Regarding Residual Doubt As Mitigation 2021
12.4 Defendant’s Requested Jury Instruction Concerning The Definition Of “Criminal Acts Of Violence” 2021
12.5 Request For Jury Instruction (Proof Beyond All Doubt) 2021
12.6 Requested Instruction To The Jury To Answer The Final Question Affirmatively 2021
12.7 Defendant’s Requested Jury Instructions Concerning The “Future Danger” Issue 2021
12.8 Defendant’s Requested Jury Instructions Concerning The Use Of Human Evidence 2021
12.9 Defendant’s Requested Jury Instructions Regarding Parole From A Capital Life Sentence 2021
12.10 Motion For Order Prohibiting Use Of “No Sympathy” Instruction 2021
12.11 Defendant’s Objections To The Charge At Punishment (Single Defendant, No Mr Issue, No A Re-Trial) 2021
12.12 Defendant’s Objections To The Charge At Punishment 2021
12.13 Defendant’s Objections To Penalty Phase Instructions To The Jury 2021
12.14 Request To Instruct The Jury Regarding Party Liability 2021
12.15 Defendant’s Requested Instructions To The Sentencing Jury 2021
Sentencing
13.1 Motion To Introduce The Defendant’s Statement Of Allocution, Free From Cross-Examination By The State, Reflecting His Remorse For The Offense 2021
13.2 Motion To Exclude Victim Impact/Character Evidence In Absence Of Specific Legislative Authority And To Exclude Such Evidence As Irrelevant To Texas Punishment Special Issues; Requests To Voir Dire/Requested Instructions/Motions In Limine, Related To Claims In This Motion 2021
13.3 Motion To Introduce The Testimony Of Defendant’s Family And Friends Regarding Their Feelings On The Prospect Of A Death Sentence And The Impact An Execution Would Have On Them 2021
13.4 Motion To Limit State’s Cross Examination Of Defendant To The Scope Of The Direct Examination By The Defense During Punishment Phase 2021
13.5 Defendant’s Amended Motion Regarding Victim Character/Impact Testimony After Mosley V. State 2021
13.6 Motion To Allow The Defense To Close Arguments On Mitigation 2021
13.7 Motion To Preclude The State From Offering Victim Impact Testimony 2021
13.8 Election Of Jury Punishment (Fact Specific) 2021
13.9 Defendant’s Motion For Life Without Parole As A Sentencing Option 2021
Miscellaneous
14.1 Input For Motion For New Trial, Punishment Issues Only 2021
14.2 Motion To Withdraw Pending Motions Filed By Previous Counsel For The Defendant 2021
14.3 Sealed Order (Authorizing Medical Expert Examiner’s Fee) (Fact Specific) 2021
14.4 Motion To Preserve Right To File Other Motions 2021
14.5 Motion To Preclude Prosecutorial Use Of Defendant’s Disability To Justify A Sentence Of Death Due To The Violation Of The American With Disabilities Act 2021
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Admissibility of Touch and Contact DNA Evidence
Admissibility of Neuropsych and Psychiatric Evidence
Admissibility of 911 Calls
Advance of Funds for Witness Expenses, Indigent Defendant
Affidavit - Witness About to Leave the Country
Affidavit for Custodian of Business Records
Affidavit of Witness for Expense Reimbursement
Appearance of Counsel
Appellant’s Motion to Dismiss Appeal
Application and Motion for a Material Out of State Witness
Application for Community Supervision
Application for Community Supervision from Jury Application to Issue Subpoenas
Application to Issue Subpoenas
Application to Reveal Personal Information About Jurors
Application for Community Supervision
Allow Defendant to View Scene of Crime with Attorney
Appear in Own Clothes and Without Restraints
Authorizing Funds for Investigator
Additional Peremptory Challenges
Advance Notice of Mental Examinations
Appointment of Expert Witness
Appointment of Interpreter
Appointment of Investigator
Arraignment Outside Presence of Jury
Business Records Filing
Bushy Eyebrow Testimony
Continuance (General Form)
Continuance (After Trial has Begun)
Continuance by Defendant (Absence of Witness)
Court Reporter to Make Full Record
Court Certification of Out of State Witness
Court Order on Hearing Out of State Witness
Change punishment Election
Compel Election Between Charging Paragraphs
Crusading Capital Defense
Determine Admissibility of Recorded Statement
Determine Admissibility of Statement
Defendant’s Election as to Punishment
Defendant’s Motion to Set Bond
Defendant’s Criminal History, Race and Ethnicity
Discovery (Long Form with specific requests)
Discovery Arrest and Conviction Records of State Witness
Discovery Short Form (General form be very careful with this one)
Discovery of Exculpatory Evidence (Specific information that you know of)
Discovery of Grand Jury Testimony
Discovery of Punishment Evidence
Disclose and Produce Informer
Discover Crime Stoppers Information
Discover Exculpatory Evidence
Discover Telephone and Radio Recordings
Exempt Witness from Rule
Extend Time Limitation to Voir Dire
Examination Regarding Insanity
Exclude Death Penalty Due to Autism
Forensic DNA Testing
Free Reporter’s Record on Appeal
File Additional Motions
Franks Hearing
Hearing Franks v. Delaware
Inspect, Examine Physical Evidence
Independent Examination DNA Evidence
Inspection of Premises
Instructed Verdict
Invoking the Rule
Improper Death Penalty Comments
Juror Questionaire
Jury Questionnaire
Jury Shuffle
New Trial and Motion in Arrest of Judgement
Notice of Appeal
Notice of Appearance and Request for Compliance
Notice of Appearance Misdemeanor and Request for Compliance
Notice of Filing Business Records
Notice of Intent to Raise Insanity Defense
Notice to Expert (Concerning Matters of Incompetency)
Notice to Expert (Concerning Insanity)
Objections to State's Motion to Amend the Indictment
Objections to State's Motion to Amend the Information
Preferential Setting
Proceed Ex-Parte for Appointment of Expert Assistance
Produce Writings Used to Refresh Memory
Prohibit State's Use of Written Statements
Prevent Reading of Enhancement Count Before Punishment
Production, Rule 612 and 615
Prior Convictions, Extraneous Offenses
Preclude Death Penalty Due to Discovery Violations
Quash, Exception to From of Indictment, Information
Quash, Exception to Substance of Indictment, Information
Question Venire Individually (Publicity)
Reopen Testimony
Require State to Reveal Agreement
Restrict Publicity
Reveal Evidence Favorable to the Accused
Recess at Close of State's Case
Recovery of Expert Witness Fees
Recovery of Investigative Expenses
Request for Findings of Facts an Conclusions of Law
Request for Hearing Outside Presence of Jury
Request for Notice of Extraneous Evidence (404(b))
Request Funds Out-of-State Witness
Request for Pre-Trial Hearing
Speedy Trial
Set Aside Indictment or Information Pursuant to Speedy Trial Act
Sever Defendants
Sever Offenses
Substitute Counsel (After Conviction)
Suppress In Court Identification
Suppress Photograph Information
Suppress Statements
Suppress the Warrants
Suppress Genetic Information
Suppress ATT, Google, USB, Apple, and Amazon Information
Speaking Objections, Sidebar
Suggesting Incompetency and Request for Examination
Transcribe Pre-Trial Proceedings
Transcribe Testimony From Prior Trial
Use of Term Murder
Voir Dire
Witness List
Withdraw (After Conviction)
DWI/Cannabis Motions Section
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Blood Discovery Motion 2022
Breath Test Discovery 2022
Compel Inspection of Blood Kit 2022
Compel DRE Discovery 2021
DRE Discovery Motion 2021
Discovery—Blood 2022
Disclose Experts 2022
Discovery—Drugs 2022
Defendant's Motion to Protect the Fairness of Future Juries 2022
Designation of Experts 2022
Discovery Motion—Breath Test 9000 2022
Discovery Request—39.14 2022
DRE Discovery Motion 2022
Extrapolation Limine 2025
Harris County Blood Discovery Order 2022
Hospital Blood Test Motion for Discovery 2022
HGN Limine Alcohol Level 2025
HGN Suppress 2025
Limine Non-Alcoholic Non-Expert Testimony 2025
Limine Brown's Opinion's 2025
Limine - Terminology 2025
New 404 Motion 2022
Quash the Indictment (Warren Wolf) 2022
Suppress—DWI (Blood) 2022
Suppress—DWI (Breath) 2022
Suppress—DWI Drug Evidence 2022
SOG Breath Test Discovery 2022
Theus Motion 2022
Federal Motions Section
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I. Competency/Insanity
Notice of Intent to Present Insanity Defense.rtf 2021
Psychiatric Exam.rtf 2021
Response to Govt’s Motion for Psych Exam.rtf 2021
II. Ex Parte Motions for Experts/Investigators
Application to File Motion Under Seal.rtf 2021
Application to Hire Investigator.rtf 2021
Consult Psychological Expert.rtf 2021
III. In Forma Pauperis Filings
Proceed In Forma Pauperis.rtf (1) 2021
Proceed in Forma Pauperis.rtf (2) 2021
IV. Motions for Continuance
Continuance and Brief.rtf 2021
Continuance of Sentencing.rtf 2021
Continuance and Brief - Detention Hearing.rtf 2021
Detention Hearing.rtf 2021
Det. Hearing/Arr.rtf 2021
Prelim. Exam.rtf 2021
Rearraignment.rtf 2021
V. Motions for Discovery/Brady
Discovery.rtf 2021
Discovery and Insp. Of Ev.rtf 2021
Ev. Favorable to Defendant.rtf 2021
File Subpoenas under Seal.rtf 2021
Inspect Grand Jury Records.rtf 2021
Notice of Intent to Use Ev.rtf 2021
Production of Witness Statements.rtf 2021
Produce Arrangements Made.rtf 2021
Specific Discovery.rtf 2021
Supplemental Discovery.rtf 2021
Subpoena in a Criminal Case.rtf 2021
VI. Motions in Limine
Extrinsic Offenses.rtf 2021
Limine.rtf 2021
Other Crimes Evidence.rtf 2021
Prior Convictions.rtf 2021
Resp.to Govt’s Notice and Mot. In Limine.rtf 2021
Supp. Memo in Support of Motion in Limine.rtf 2021
VII. Motions to Dismiss
Dismiss.rtf (1) 2021
Dismiss.rtf (2) 2021
Dismiss.rtf (3) 2021
Dismiss – Speedy Trial.rtf 2021
Dismiss Charges.rtf 2021
Dismiss Count one and Strike Language.rtf 2021
Dismiss Indictment.rtf 2021
VIII. Motions to Suppress
Brief in Support of Motion to Suppress.rtf (1) 2021
Brief in Support of Motion to Suppress.rtf (2) 2021
Suppress with Memo of Law.rtf (1) 2021
Suppress with Memo of Law.rtf (2) 2021
Suppress with Memo of Law.rtf (3) 2021
Suppress.rtf 2021
IX. Motions to Withdraw
Withdraw.rtf (1) 2021
Withdraw.rtf (2) 2021
Withdraw on Appeal.rtf 2021
X. Pleas and Associated Filings
Acknowledgement of Plea Bargain Offer.rtf 2021
Acknowledgement of Plea Bargain Offer - Mandatory Minimum.rtf 2021
Amend Conditions of Release.rtf 2021
Downward Departure.rtf 2021
Downward Departure.rtf 2021
Downward Dept. and Sealing Reqt.rtf 2021
Expedited Reconsideration of Sentence.rtf 2021
Enforce Plea Bargain.rtf 2021
Expedite Sentencing.rtf 2021
Notice of Intent to Plead Guilty.rtf 2021
Objections to Presentence Report.rtf 2021
Request for Extension of Reporting Date.rtf 2021
Sentencing Memorandum.rtf 2021
Unopposed Motion to Resentence.rtf 2021
XI. Post-Trial Motions
Appeal of Denial of Suppression Motion.rtf 2021
New Trial.rtf (1) 2021
New Trial.rtf (2) 2021
Notice of Appeal.rtf 2021
XII. Pre-Trial Motions
Attorney Conducted Voir Dire.rtf 2021
Conduct Voir Dire.rtf 2021
Determine Admissibility of Co-Conspirator’s Statement.rtf 2021
Entry of Appearance of Counsel.rtf 2021
Expedited Bond Hearing.rtf 2021
Juror Questionnaire.rtf 2021
Release on Cash Bond.rtf 2021
Request for Questions to Prospective Jurors.rtf 2021
Strike Misleading Surplusage.rtf 2021
Substitute Counsel.rtf 2021
Sever.rtf 2021
Severance of Defendants.rtf 2021
Severance of Defendants.rtf 2021
XIII. Miscellaneous Motions and Filings
Ake Motions 2021
Court Appointed Lawyers are Cop Out Lawyers 2021
Criminal Contract 2021
Certificate of Conference.rtf 2021
Constitutional Objections to Limited Cross Examination 2021
Discovery 2021
Discovery and Inspection Concerning Government Use of Informants, Operatives, and Government Informants, Etc. 2021
DNA Analysis 2022
DNA Expert 2022
Disclose Withheld Information 2021
Frank's Motion 2021
Defenseless Case 2021
Notice of Lawsuit.rtf 2021
Obtaining documents from financial institutions 2021
Protective Order Motions 2021
Produce CI 2021
Set Aside Indictment for Failure of Speedy Trial 2021
Suppress 2021
Subpoena Bank Records 2021
Second Amended 17 Year Old 2021
Sanctions and Brief.rtf 2021
Support of Suppression 2022
Suppress Custodial Statement 2022
Waiver of Rule 40.rtf 2021
Waiver of Rule 40 Hearing Form.rtf 2021
Waiver of Service of Summons.rtf 2021
Miscellaneous Motions Section
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Article on how to Comple with Senate Bills 2021
Battleplan Preparing for Trial 2021
Continuance of In-Person Jury Trial 2020
Innocent Appendix 2021
Innocent Until Proven Indigent 2021
Judge Order 2021
Needle in a Haystack 2021
Opinion 2021
Order Setting Hearing and on Giving Notice 2021
Transcribe Media 2020
State Motions Section
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I. Pretrial Motions | Pretrial Motions: Motions in Limine | Pretrial Motions: Pretrial Discovery | II. DWI Motions | III. Sexual Assault Motions | IV. Post-Trial Motions | Post-Trial Motions: Art. 64 DNA Testing | Post-Trial Motions: Writ-invalid use of prior DWI | Miscellaneous
I. Pretrial Motions
Affidavit for Non-Prosecution 2017
Adopt Pleadings 2017
Allow Additional Motions for Pre-trial Hearings 2017
Arraign Defendant Out of Presence of Jury 2017
Consider Unadjuducated Offenses 2017
Application for Bench Warrant 2017
Additional Time to Conduct Voir Dire 2017
Appointment of Expert 2017
Appointment of Interpreter 2017
Appointment of Mitigation Specialist (ex parte) 2017
Bond Reduction Checklist 2017
Business Records Affidavit Before 2017
Challenge to the Constitutionality of Juvenile Transfer Proceeding 2017
Constitution Cross-Reference 2017
Competency Exam 2017
Continuance 2017
Consolidate 2017
Defer Adjudication 2017
Discover Criminal Histories of Witnesses 2017
Dismiss Prosecution With Prejudice 2017
Disclosure of Expert Witnesses and Data Relied Upon 2017
Disclosure under Brady and Kyles 2017
Daubert Type Motion 2017
Defendant’s Acknowledgement of the Plea Bargain Offer 2017
Defendant’s Acknowledgment of Plea Bargain 2017
Defendant’s Application For Community Supervision 2017
Defendant’s Election as to Punishment 2017
Defendant’s Motion for Additional Funding (testing drugs) 2017
Defendant’s Motion for Approval of Expenditure for Independent Forensic Analysis (drugs) 2017
Defendant’s Motion for Approval of Expenditure for Independent Trace Residue Analysis 2017
Defendant’s Motion to Require Election by State 2017
Defendant’s Motion Requiring Notice of Prosecution’s Intent to Use Copies of Writing 2017
Defendant’s Request for Court Reporter 2017
Defendant’s Request for Notice of Extraneous Offenses 2017
Defendant’s Written Objections to Admission of Extraneous Offenses 2017
Ex Parte Motion for Appointment of Investigator 2017
Ex Parte Motion for Court Approval for Reimbursement of Defense Costs (ID expert) 2017
Ex Parte Motion for Experts 2017
Ex Parte Motion for Funds 2017
Examination and Re-Weighing of Physical Evidence 2017
Exclude Testimony of Gang Affilliation 2017
File Additional Motions 2017
Funding Motion for Mitigation Specialist (ex parte) 2017
Habeas Corpus for Bond Reduction 2017
Hearing on Admissibility of Enhancement 2017
Hearing on Voluntariness of Any Admission or Confession Whether Written or Oral 2014
Hearing Pursuant to Rule 705 2017
Hearing Regarding Out of State Witness 2017
Hearing to Determine Competency 2017
Hearing to Test Qualifications of Prosecution Witness 2017
HIPAA Order for Medical Records 2017
Individual Affidavit for Non-prosecution 2017
ID hearing 2017
In Camera Inspection for Brady Material 2017
Jury Questionnaire 2017
Keep Prosecutors from Talking to Jurors Post Verdict 2017
Pre-trial Hearing 2017
Preclude Use of Prejudicial Terms 2017
Petition for Writ of Habeas Corpus Ad Testificandum 2017
Plea Offer Letter to Client 2017
Pretrial Index 2017
Quash Indictment 2017
Quash for Vagueness 2017
Reduce State Jail Felony 2017
Release Because of Delay 2017
Reconsider Suppression Search Invalid Permission 2017
Requesting Court to Schedule Examining Trial 2017
Request Under Art. 37.07 §(3)(g) 2017
Suppress Evidence of the Arrest—Lack of Probable Cause 2017
Suppress Identification 2017
Suppress Illegally Seized Evidence 2017
Substitution of Counsel 2017
Suppression Bad Stop (2) 2017
Suppression Bad Stop (3) 2017
Suppression Bad Stop 2017
Suppression Illegal Detention and Search 2017
Suppression Illegal Entry(2) 2017
Suppression Illegal Entry 2017
Suppression Invalid Search Warrant 2017
Suppression of Search and Statement 2017
Suppression Search of Person 2017
Suppression Statement 2017
Stipulation of Evidence 2017
Subpoena for medical records 2017
Transcription of Examining Trial 2017
Test Qualifications of Prosecution Reputation Witness 2017
Withdraw (ethical considerations) 2017
Pretrial Motions: Motions in Limine
Defendant’s Motion in Limine (Name Calling by Prosecution) 2017
Extraneous offenses and bad acts 2017
Extraneous Offenses, Wrongs or Acts 2017
Limit Jury Argument of State 2017
Limit Jury Argument of State (2) 2017
Limit Jury Argument of State at the Punishment Stage 2017
Limit Jury Argument of State at the Punishment Stage (2) 2017
Other Proceedings 2017
Objections to Admission of Extraneous Offenses 2017
Prior Criminal Record 2017
Prior Trials 2017
Regarding Application for Community Supervision 2017
Regarding Matters Not Within Personal Knowledge of a Witness 2017
Statements Made While Under Arrest 2017
Suppress Improper Prosecutorial Conduct (is another witness lying) 2017
Trial Conduct 2017
Pretrial Motions: Pretrial Discovery
Authority For State’s Witness to Discuss Facts 2017
Corroborative Evidence 2017
Discovery and Inspection of Evidence 2017
Evidence Favorable to the Defendant 2017
Independent Examination of Evidence (DNA) 2017
Inspect Evidence 2017
Inspect, Examine and Independently Test Physical Evidence 2017
Inspect Scene 2017
List of State’s Witnessess 2017
Order for Release of Medical Records 2017
Preserve Evidence 2017
Pretrial Discovery Index 2017
Production of Evidence for Expert Evaluation 2017
Production of Tape Recorded Evidence 2017
Production of Witness Statements 2017
Require Disclosure of CI Identity 2017
Reveal the Deal 2017
Require Prosecution to Reveal any Agreement 2017
State for Notice of Extraneous Offenses 2017
II. DWI Motions
DWI Motion to Suppress 2017
Exclude Extrapolation 2017
Preclude Police Officer Testimony on Reliability 2017
Suppression—anonymous tip 2017
Suppression-blood test 2017
Suppression-breath test consent 2017
III. Sexual Assault Motions
Additional Voir Dire 2017
Affirmative Finding Pursuant to Art. 42.017 CCP 2017
Exemption from Sex Offender Registration 2017
Limine-Recovered Memories, Rule 404(b) 2017
Permit Inspection and Copying of Items Covered by 2017
Produce Exculpatory and Mitigating Evidence in Regard to Allegations against Defendant of Sexual Assault of a Child or Indecency with a Child 2017
Suppress Hearsay Statement of Child Witness 2017
Suppress Outcry Statement 2017
IV. Post-Trial Motions
Agreed Motion to Modify Probation 2017
Application for Sealing of Juvenile Records 2017
Application for Writ of Habeas Corpus 2017
Application for Writ of Habeas Corpus (conviction based upon void indictment) 2017
Defendant’s Motion for ________ County to Pay for Statement of Facts 2017
DNA Test of Sperm Evidence—Art. 64.01 2017
Discharge Community Supervision 2017
Expunction of Criminal Records 2017
Imposition of Sentence of Shock Probation 2017
Nondisclosure of Criminal History 2017
Nondisclosure of Criminal History (Misdemeanor) 2017
Prompt Revocation Hearing 2017
Petition for Expunction of Criminal Records 2017
Reasonable Bail Pending Appeal 2017
Set Aside Felony and Entry of Misdemeanor 2017
Post-Trial Motions: Art. 64 DNA Testing
DNA Testing Motion Appendix 2017
DNA Testing (Art. 64) 2017
DNA Testing (Art. 64) (2) 2017
Amended Motion for DNA Testing (Ch.64) (2) 2017
Post Conviction DNA Test—Art. 64.01 2017
Post-Trial Motions: Writ-invalid use of prior DWI
Application for Writ of Habeas corpus (invalid use of prior DWI conviction) 2017
Memorandum and Order (regarding invalid use of prior DWI convictions) 2017
Proposed Findings of Fact and Conclusions of Law (regarding invalid use of prior DWI conviction) 2017
Miscellaneous
Ake Motions 2021
Allow the Defendant to Transcribe the Oral Statement of the Complaining Witness 2021
Amended Costs 2022
Bench Warrants Application 2021
Back time 2020
Court to Hold Cellular Phones of Jurors During Deliberation 2017
Compel DRE Discovery 2021
Court Appointed Lawyers are Cop Out Lawyers 2021
Criminal Contract 2021
Clerk's Record Designation 2021
Crossing on Bias 2020
Constitutional Objections to Limited Cross Examination 2021
CPS Records 2021
Corrected Costs 2022
Contempt Writ for Attorney 2023
Competency Exam 2022
Defendant’s Motion for Directed Verdict of Acquittal 2017
Defenseless Case 2021
Defendant's Objection to Telephonic Hearing 2021
Designation of Matters to Be Included in the Clerk's Record on Appeal 2021
Designation of Record on Appeal 2021
DRE Discovery Motion 2021
Discovery 2021
Disclose Withheld Information 2021
Dismiss State's Appeal for Want of Jurisdiction 2021
Declare Tex. Code Crim. Proc. 2021
Defenseless Case 2021
DNA Analysis 2022
Dismissal Motion 2023
DNA Expert 2022
Educate Panel by Trial Court During Voir Dire 2021
Entrapment 2021
Extend Deadline for Motions 2021
Exclude Cumulative Evidence 2021
Exclude Testimony for Unqualified Experts 2023
Frank's Motion 2021
Free Transcript 2021
Free Record 2021
File Under Seals 2021
In Court Hourly Worksheet 2021
Investigator 2021
Jury Questionnaire 2023
Limine to Prohibit Prosecutor and/or Court from Advising Venire 2021
Limine: Presentations to the jury 2021
Limine 2021
Motion2021
Monitoring Home-Confinement
Mental Health Professional Motions 2021
Michael Morton Notices 2021
Master Expunction Petition 2021
MMA 2021
New Trial Cert. Presentment 2023
Obtaining documents from financial institutions 2021
Psych Exam in County Jail 2021
Produce Motorcycle for Trial 2021
Professional Conduct Disclosure 2021
Protective Order Motions 2021
Preserving Error for Appellate Review 2017
Pre-indictment 39.14 Writ (K. Hampton) 2023
Produce CI 2021
Quash Dismiss 2021
Release on Personal Recognizance (Attorney Contempt) 2017
Reporter's Record Designation 2021
Recusal of DA 2021
Return of Property 2023
Return of Property 2022
Return Gun 2022
Reveal all Subpoenas 2022
Set Aside Indictment for Failure of Speedy Trial 2021
Suppress 2021
Subpoena Bank Records 2021
Service Dog Motion
Second Amended 17 Year Old sti2021
Support of Suppression 2022
Stidman Motion for Mental Health 2022
Set Revocation Hearing 20 Days 2022
Suppress County 2022
Suppress Custodial Statement 2022
Spoliation of Evidence and Instruction 2022
Statutory Notice Request 2023
Service Dog 2023
Speedy Trial 2021
Shock Probation 2020
Transcribe Forensic Interview 2021
Tips for Appointments 2021
Transcribe Media 2020
Waive Court Costs 2021
Wardlow v. Texas Amicus Brief 2021
" 38.45(c) and 39.15 (a) (3) Unconstitutional 2021
Voice Motions Section
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Writ of Habeas Corpus 2017
Writ of Habeas Corpus (A different one) 2017
Neuropsych Exam on Defendant 2017
Blood Discovery Motion 2017
Compel Production of Video Evidence 2017
State's Witnesses' Personnel Files 2017
Mental Retardation Expert 2017
Bolstering Motion 2017
Medical Records Sealed Motion 2017
Challenging Jury Array and to Quash Jury Panel 2017
Nystagmus Causes Other 2017
Breath Test Documents 2017
Speedy Trial 2017
Plea in Bar 2017
Exclude Service Dog Accompanying the State’s Witness Before the Jury 2017
Instruct Venireman and Jurors to Not Discuss or Research Using the Internet or Electronic Jurors and Electronic Devices\2017
Ake 2017
Indigent Client Attorney Fees 2017
Preserve Evidence 2017
Quash 2017
Quash Indictment 2017
Quash Information for Failure to Allege a Culpable Mental State 2017
Recuse Trial Judge Due to (a) Bias, Pressure as an Elected Judge and/or (b) Lack of Training and Qualifications in Death Penalty Cases 2017
Competency Exam Tapping 2017
Capias Pro Fine Warrant Recall 2017
Restrict Publicity 2017
Return Property 2017
Seat Defendant Nearest to the Jury 2017
Set Aside an Information for an Unlawful Carry of a Weapon Charge 2025
Suppress 2017
Suppress (2) 2017
Transfer Bond to Indicted Cause 2017
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