Motion for Additional Time to Conduct Voir Dire

MOTION FOR ADDITIONAL TIME TO CONDUCT VOIR DIRE

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 pursuant to the Sixth and Fourteenth Amendments to the United States Constitution and Art. I, Sec. 9 of the Texas Constitution and files this Motion for Additional Time to Conduct Voir Dire; and in support will show the following:

I.

That the Defendant is on trial for the (felony or misdemeanor) offense of (offense for which Defendant is on trial).

II.

That in order to render reasonably effective assistance of counsel and assure the Defendant that he receives a fair and impartial jury trial, it is necessary for undersigned counsel to extensively voir dire the venire on certain principles of law, burden of proof, defenses, and to attempt to uncover any bias or prejudice which a potential juror may harbor. Adequate time to voir dire the venire is essential to counsel’s intelligent exercise of the Defendant’s peremptory challenges.

III.

That undersigned counsel is prepared to proffer to the Court a list of questions intended to be presented to the venire, thereby demonstrating that said questions are not irrelevant, immaterial or repetitious.

IV.

That undersigned counsel specifically requests no more than (time period requested) to conduct voir dire.

V.

That to unreasonably limit the time for voir dire will deny the Defendant a fair trial and effective assistance of...