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Motion to Produce Records of Prior Jury Service and in the Alternative to Allow Inquiry into Prior Jury Service
MOTION TO PRODUCE RECORDS OF PRIOR JURY SERVICE AND IN THE ALTERNATIVE TO ALLOW INQUIRY INTO PRIOR JURY SERVICE
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 order the State to produce records of prior jury service or in the alternative to allow the Defendant to inquire into prior service of the veniremen, and in support thereof would show the Court as follows:
I.
The Defendant would show that the (name of county) District Attorney's Office has a database program or records or access to the same, in which it stores detailed information about jurors who have served in prior criminal cases. This information summarizes the type of case in which the jurors served, the verdict rendered, the sentence imposed, whether the jury was able to reach a verdict, the position of the individual juror if a verdict was not reached, and other information unknown to Defendant or his attorney. Such information will likely be used in this case to assist the prosecutors in examining prospective jurors and in exercising their peremptory challenges as to jurors who are on the venire panel in this case who have prior criminal jury service in this county.
II.
There are or will be jurors on the venire panel in this case who have had prior criminal jury service in this county.
III.
Neither the Defendant nor his attorney has access to this valuable information, nor do they have any means of obtaining this information other than by Court Order. To allow the State to have and use this information and to deny same to the Defendant creates such an imbalance of power and advantage in favor of the State as to be fundamentally unfair to the Defendant, to deny him equal opportunity to obtain a fair and impartial jury, to deny him due process and to deny him equal protection of the laws.
IV.
This information is not privileged in favor of the State nor is it the work product of the District Attorney's Office in this case. It is not written notes, reports, memoranda, statements of witnesses, nor written communication covering any factual or legal aspect of this case. In fact, such information was and has been kept and stored...
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Request your trial- Appendices
- Jury Selection and Voir Dire
- Motion to Shuffle Jury
- Motion for Attachment of Absent Veniremen
- (Defendant’s or State’s) Motion to Exclude Alternate Juror From Deliberations
- Motion to Submit Jury Questionnaire
- Motion to Excuse Disabled Juror
- Motion to Disqualify Veniremen
- Defendant’s Brief in Support of Motion to Submit Jury Questionnaire
- Order to Attach Venireman
- Juror Questionnaire; Non-Capital Cases
- Challenge to the Array
- Jury Questionnaire; Capital Cases
- Peremptory Challenge Submission
- Motion for Additional Time to Conduct Voir Dire
- Motion for Individual Voir Dire Examination of Veniremembers (Capital Case)
- Motion for Additional Peremptory Challenges
- Motion for Individual Voir Dire Examination of Veniremembers (Non-Capital Case)
- Motion to Produce Criminal History Records of Veniremen and in the Alternative to Allow Inquiry into Criminal History
- Sample Peremptory Challenge Tally Form for Capital Cases
- Defendant’s Brief in Support of Motion for Additional Time to Conduct Voir Dire
- Motion to Produce Records of Prior Jury Service and in the Alternative to Allow Inquiry into Prior Jury Service
- Motion to Require State to Exercise Challenges Pursuant to Art. 35.13
- Jury Instruction on Note-Taking (Upon Impaneling)
- Defendant’s Motion for the Court to Decide Jurors’ Exemptions, Excuses and Disqualifications Pursuant to Art. 35.03
- Jury Instruction on Note-Taking (For Jury Charges)
- Sample Writ to Summon Special Venire
- Defendant’s Motion for Special Venire
- Sample Writ to Serve Defendant Jury List
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