MOTION TO LIST STATE’S WITNESSES

1. (Cause No.)

MOTION TO LIST STATE’S WITNESSES

TO THE HONORABLE JUDGE OF SAID COURT:

NOW COMES the Defendant, (Defendant’s Name), in the above-styled and numbered cause, and moves this Honorable Court to order the prosecuting attorney representing the State to make the following disclosure:

I.

The Defendant requests that the Court order the prosecuting attorney to list all of the State’s witnesses who it in good faith expects to use at the trial of this cause, both during the guilt or innocence stage and the punishment stage, for the reason that the Defendant has no way of knowing the existence of any relationships between such witnesses and the prospective jurors and the Defendant cannot make an intelligent use of his peremptory challenges without such knowledge.

WHEREFORE, PREMISES CONSIDERED, the Defendant moves this Court to grant this Motion in all things.

CERTIFICATE OF SERVICE

I, the undersigned, hereby certify that a true and correct copy of the foregoing Motion to List State’s Witnesses was forwarded to Mr. Bill Hill, District Attorney, Frank Crowley Court Building, 133 North Industrial Boulevard, Dallas, Texas 75207, on this the ________ day of ___________, 200___.

ORDER

ON THIS the ______ day of______________, 200__, came on to be heard the foregoing Motion to List State’s Witnesses, and same is hereby GRANTED/DENIED, to which action Defendant excepted.