NO. (Cause No.)
|THE STATE OF TEXAS|
|IN THE COUNTY CRIMINAL|
COURT NO. _____ OF
DALLAS COUNTY, TEXAS
MOTION FOR DISCOVERY
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES the Defendant, (Defendant's Name), and moves the Court, under the authority of Art. 39.14, Tex. Code Crim. Proc. Ann., for discovery and inspection of the following items:
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. Photographs of the injured party.
2. Names and addresses of the eyewitnesses to the incident.
3. Medical records evidencing the claimed injury to the child.
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, Defendant prays that the Court grant this Motion for discovery and inspection.
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that a true and correct copy of the foregoing Motion for Discovery was forwarded to Mr. Bill Hill, Dallas County District Attorney. on this the ________ day of ___________ , 200___.
ON THIS the _______ day of ______, 200___, came on to be heard the foregoing Motion for Discovery, and same is hereby GRANTED/DENIED, to which action Defendant excepted.
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