Basic Motion for Discovery-2.doc - NO 000000 THE STATE OF...

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NO. 000000 THE STATE OF TEXAS § IN THE DISTRICT COURT OF § vs. § HARRIS COUNTY, TEXAS § JEAN VALJEAN § 999TH JUDICIAL DISTRICT DEFENDANT'S MOTION FOR DISCOVERY AND INSPECTION OF EVIDENCE TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES JEAN VALJEAN, the Defendant in the above cause, under the authority of U.S. Const. Amend. XIV, Tex. Const. Art. I, Sec. 19, and Tex. Code Crim. Pro. Ann. Art. 39.14, and makes his Motion for Discovery and Inspection of Evidence, and in support thereof would show the Court as follows: I. The Defendant moves the Court to order the District Attorney to produce and permit the inspection of and the copying and/or photographing of, by or on behalf of the Defendant, the following designated items: STATEMENTS BY DEFENDANT 1. All confessions, admissions and statements, in writing, signed by the Defendant, in connection with the offense with which the Defendant is herein indicted. GRANTED : DENIED: ______ 2. All confessions, admissions and statements, oral in nature and set down and preserved under Article 38.22 of the Texas Code of Criminal Procedure, made by the Defendant in connection with the offense with which the Defendant is herein indicted. GRANTED : DENIED:______
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3. All oral, written and recorded statements or memoranda of same made by the Defendant to any investigating officer or to any member of any law enforcement agency or to any third party and in the possession of or within the knowledge of the District Attorney's Office or any agent thereof, including any law enforcement agency, including those portions of any reports (including police offense reports) memoranda, notes, other writings, or records, which contain either a verbatim account or a summary of the substance of said statements. GRANTED : DENIED:______ 4. The written waiver alleged by the State to have been signed by the Defendant concerning the Defendant's right to counsel prior to the making of any written and/or oral statement while the Defendant was under arrest. GRANTED : DENIED:______ SCIENTIFIC EVIDENCE 5. All fingerprints, palm prints, and foot prints and reports of same, alleged by the State to have been made by the Defendant, his co-defendants and co-conspirators in the commission of the offense with which Defendant is herein indicted. GRANTED : DENIED:______ 6. Name, address and telephone number of all expert witnesses the state intends to call as witnesses. GRANTED : DENIED:______ 7. Name, address and telephone number of all expert witnesses who consulted with experts the state intends to call as witnesses. GRANTED : DENIED:______ 8. All reports of scientific tests, experiments and comparisons, and all other reports of experts and the name and address of each such person who made such report or performed such test, experiment or comparison, including but not limited to reports pertaining to any kind of weapons, controlled substances, and the like.
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