NO. (Cause No.)
|THE STATE OF TEXAS|
|IN THE COUNTY CRIMINAL|
COURT NO. _____ OF
DALLAS COUNTY, TEXAS
MOTION FOR DISCOVERY AND INSPECTION OF EVIDENCE
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW the Defendant, (Defendant's Name), in the above styled and numbered cause and moves the Court, under the authority of Art. 39.14, Tex. Code Crim. Proc. Ann., for discovery and inspection of the following items:
The Defendant moves the Court to order the District Attorney to produce and permit by the Defendant or Defendant's counsel the inspection of and the copying and/or photographing of the following:
1. Any documents, papers, books, accounts, letters, photographs, objects or tangible things not privileged, which constitute or contain evidence material to any matter involved in the action and which are in the possession, custody or control of the State or any of its agencies;
2. Any written statements of the Defendant;
3. Any oral statements of the Defendant;
4. The prior criminal record of the Defendant;
5. The criminal records of the State's witnesses;
6. Any evidence which in any way is exculpatory to the Defendant.
7. Any tape recordings of the interviews with the Defendant by any law enforcement agent.
In support of this Motion the Defendant would show that the items and information requested are within the exclusive control and custody of the State, the items are not privileged, and that, absent such discovery, the Defendant's rights under Art. 39.14, Tex. Code Crim. Proc. Ann.; Art. 1, Sec. 10, of the Texas Constitution; and the Fourth, Fifth and Sixth Amendments of the United States Constitution will be violated.
WHEREFORE, PREMISES CONSIDERED, the Defendant respectfully prays that this Honorable Court grant this the Defendant's Motion for Discovery and Inspection.
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