NO. (Cause No.)

MOTION FOR PRODUCTION OF WITNESS STATEMENTS

TO THE HONORABLE JUDGE OF SAID COURT:

   NOW COMES the Defendant, (Defendant's Name), in the above?styled and numbered cause, by and through his attorney of record, and pursuant to the United States Constitution, Amendments V, VI and XIV, and the Texas Constitution, Art. l, Sec. l0, and pursuant to Gaskin v. State, 353 S.W.2d 467 (Tex. Crim. App. l96l), respectfully moves this Court to order the prosecuting attorneys to produce, after a witness has testified on direct examination, the following items:

1. Any statement, whether in writing or however recorded, whether signed or unsigned, of said witness;

2. Any police report, where such report 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, so long as the witness has adopted the same as correct.

   WHEREFORE, PREMISES CONSIDERED, the Defendant respectfully prays that the Court grant this Motion in all things.

CERTIFICATE OF SERVICE

   I, the undersigned, hereby certify that a true and correct copy of the foregoing Motion for Production of Witness Statements was mailed to Mr. Bill Hill, Dallas County District Attorney, on this the ________ day of ___________, 200___.

ORDER

   ON THIS the ______ day of______________, 200__, came on to be heard the foregoing Motion for Production of Witness Statements, and same is hereby GRANTED/DENIED, to which action Defendant excepted.

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