MOTION FOR PRE-TRIAL HEARING

1. (Cause No.)

MOTION FOR PRE-TRIAL HEARING

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 under the provisions of the United States Constitution, Amendments IV, V, VI and XIV, the Texas Constitution, Article 1, Section 10, and the Texas Code of Criminal Procedure, Article 28.01 (1973), and requests this Honorable Court to set this case upon the docket of said Court for a pre-trial hearing, in advance of any trial upon the merits, to consider any of the following matters which may be raised in this cause, to wit:

1. Exceptions to the Indictment;
   2. Motion to Suppress Evidence;
   3. Motion for Discovery;
   4. Special Pleas by the Defendant;
   5. Motion for Continuance; and
   6. Motion for Change of Venue.

And the Defendant further requests that the setting of such pre-trial hearing be in advance of any trial on the merits of this cause, so as to enable the Defendant and his counsel to properly prepare his defense, and that such would best serve the administration and interests of justice in this cause.

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 Pre-Trial Hearing was forwarded to the District Attorney’s Office on this the ________ day of ___________, 200___.

ORDER

ON THIS the _______ day of ______, 200___, came on to be heard the foregoing Motion for Pre-Trial Hearing, and the same is hereby GRANTED/DENIED, to which action Defendant excepted.