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

MOTION FOR INDIVIDUAL VOIR DIRE EXAMINATION OF

VENIREMEMBERS (NON-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 (felony or misdemeanor) offense of (offense for which Defendant is being tried).

II.

That (list the reason the Defendant requires individual voir dire: i.e. the circumstances surrounding the Defendant’s arrest; the sensitive and private topics that will be discussed in this case; the massive local, state and national media attention given to crimes of this nature; etc.) will require an extensive voir dire of the veniremembers so as to ensure that the Defendant is given the benefit of a fair trial as guaranteed by the United States Constitution and Texas Constitution.

III.

That the Defendant is entitled to question prospective jurors in order to intelligently exercise challenges for cause under Texas Code of Criminal Procedure art. 35.16 and to intelligently exercise his peremptory challenges under art. 35.14.

IV.

That if the Defendant is...