Motion for Additional Peremptory Challenges

REQUEST FOR ADDITIONAL PEREMPTORY CHALLENGES

TO THE HONORABLE JUDGE OF SAID COURT:

NOW COMES 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 grant him additional peremptory challenges during jury selection; and for cause would show the following:

I.

The jury has not yet been impaneled after voir dire in this cause. The Defendant has exhausted the peremptory challenges permitted by statute for this type of case.

II.

Following the voir dire by the parties, the Defendant unsuccessfully challenged certain veniremen for cause. Due to the trial court’s erroneous rulings on these challenges for cause, the Defendant was forced to exercise peremptory challenges on those veniremen to prevent their serving on the jury in this case.

III.

Due to the fact that the Defendant had to use peremptory challenges on those veniremen unsuccessfully challenged for cause, the Defendant has insufficient peremptory challenges remaining to...