Motion to Submit Jury Questionnaire

MOTION TO SUBMIT JURY QUESTIONNAIRE

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 parties in the instant case to submit a jury questionnaire; 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 the circumstances surrounding the Defendant’s arrest, the sensitive and private topics that will be discussed in this case, as well as the massive local, state and national media attention given to crimes of this nature, will require an extensive voir dire of the jury panel so as to ensure the Defendant that he is given the benefit of a fair trial as guaranteed by the United States Constitution and Texas Constitution.

III.

That the jury selection process will be substantially expedited by the use of a jury questionnaire designed to elicit critical and sensitive background information as well as seek to identify those jurors who may be susceptible to challenge for cause.

IV.

That juror questionnaires have been previously used in this county as well as in numerous courtrooms all over the country. There is universal...