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J. Michael Price II
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Dallas criminal lawyer J. Michael Price II and his criminal defense support team have successfully defended a vast assortment of criminal matters, including drunk driving, possession of drugs and other controlled substances, narcotics sales, theft, white collar fraud, conspiracy, computer crimes and sex offenses. READ MORE
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MOTION TO REVEAL WITNESSES AND EXTRANEOUS OFFENSES

  1. (Cause No.)
THE STATE OF TEXAS

VS.

(Defendant’s Name)

§

§

§

IN THE COUNTY CRIMINAL

COURT NO. _____ OF

DALLAS COUNTY, TEXAS

MOTION TO REVEAL WITNESSES AND EXTRANEOUS OFFENSES

TO THE HONORABLE JUDGE OF SAID COURT:

NOW COMES the Defendant, (Defendant’s Name), and moves this Court to order the attorney for the State to reveal to the Defendant the following information:

I.

  1. The names, addresses, and telephone numbers of all witnesses who will be called or who may be called by the State in any phase of the trial to testify as to any extraneous offense allegedly committed by the Defendant.
  2. The details, including dates, names of witnesses, and all other pertinent information, concerning any extraneous offense which the State intends to offer at any phase of the trial.
  3. The extraneous offense or act which the Defendant will be accused of committing, the date of its commission, and the name of the victim of the act or offense.

The information requested is necessary for the Defendant to have a reasonable length of time before trial, in order that he may investigate the alleged extraneous offenses and prepare his defense to them.

This Motion is based on the Defendant’s due process rights under the Fifth and Fourteenth Amendments of the United States Constitution, and Art. 1, Sec. 19, of the Texas Constitution, and his right to effective assistance of counsel under the Sixth and Fourteenth Amendments of the United States Constitution, and Art. 1, Sec. 10, of the Texas Constitution and Rule 404, Texas Rules of Criminal Evidence.

WHEREFORE, PREMISES CONSIDERED, Defendant prays that this Motion be granted in all things.

Respectfully submitted,

____________________________________
(Attorney’s Name, Address, Bar Card No.)
ATTORNEY FOR DEFENDANT (Name)

CERTIFICATE OF SERVICE

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

____________________________________
(Attorney’s Name)

ORDER

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

____________________________________
JUDGE