Motion for Individual Voir Dire Examination of Veniremembers (Capital Case)

MOTION FOR INDIVIDUAL VOIR DIRE EXAMINATION OF VENIREMEMBERS (CAPITAL CASE)

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 allow the Defendant in the instant case to conduct individual voir dire of veniremembers; and in support thereof would show the Court as follows:

I.

That the Defendant in this case is on trial for the offense of capital murder. The State has elected to seek the death penalty in this case.

II.

Under Texas Code of Criminal Procedure art. 35.17(2) where the State of Texas seeks the death penalty, and upon the demand of the State or Defendant, the trial court shall allow the examination of each juror individually and apart...