Library of Motions

MOTION TO DISCOVER CRIMINAL RECORDS OF WITNESSES

NO. (Cause No.)

THE STATE OF TEXAS
VS.
(Defendant's Name)

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IN THE COUNTY CRIMINAL
COURT NO. _____ OF
DALLAS COUNTY, TEXAS

MOTION TO DISCOVER CRIMINAL RECORDS OF WITNESSES

TO THE HONORABLE JUDGE OF SAID COURT:

   NOW COMES (Attorney's Name) defendant herein, and moves the Court to require the District Attorney and his office to make available to the Defendant and the Defendant's attorney any and all criminal records which any of the State's witnesses or possible witnesses may have in this cause and, in support of such Motion, would show the Court as follows:

I.

   Defendant would show the Court that if there is information which the District Attorney's Office has reflecting that any witnesses they may call are guilty of criminal acts and/or acts of misconduct, this testimony could be used by the Defendant for impeachment purposes, or to show the interest and bias of the witness. Thus, if the State does not reveal this to the Defendant, the State will be secreting evidence which could alter the verdict in such cause.

   WHEREFORE, PREMISES CONSIDERED, the Defendant moves the Court to require the District Attorney's Office to reveal any criminal record or act of misconduct which any witness they will call or may call has in this case.

 

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 Discover Criminal Records of Witnesses was forwarded to Mr. Bill HIll, District Attorney, Frank Crowley Courts Building, 133 North Industrial Boulevard, Dallas, Texas 75207 on this the ________ day of , 2002.

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