Defendant’s Motion for Special Venire

DEFENDANT’S MOTION FOR SPECIAL VENIRE

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW the Defendant in the above entitled and numbered cause, by and through his attorney of record, (name of the Defendant’s attorney of record), and respectfully moves this Honorable Court to summon a special venire for the trial of the Defendant’s case; and would show this Honorable Court as follows:

I.

The Defendant is charged with the offense of capital murder. The State of Texas has given notice that it will seek the death penalty in this case.

II.

Under Tex. Code Crim. Pro. Art. 34.01, the Defendant is entitled to have the District Court issue a writ commanding the sheriff of the county to summon such veniremen as will be necessary for the trial of the case from the citizens of the county.

III.

The Defendant further prays that this Honorable Court order that the...