Motions, Etc


Motions are documents that request the judge to take some type of action. They are powerful tools which effective lawyers use to obtain essential discovery, suppress inadmissible evidence, and, sometimes, to have the case dismissed. I file motions in almost every case I handle. This section of the website contains many of the different motions I have filed over the years, organized by categories. Lawyers are welcome to download any motions they find useful. It goes without saying, of course, that every criminal case is different, and that any motion you file in your case must be modified to fit your particular facts. Feel free to call me if you have any questions or comments on these motions.

Jury Charges

At the end of the trial the judge instructs the jury on the law that applies to the case. Cases can be won or lost depending on what instructions are given, and how the instructions given are worded. Effective criminal lawyers pay attention to this part of the trial, and carefully draft and propose instructions they believe will help their clients to win. We are fortunate to have two good resources to look to when crafting our proposed instructions:   Texas Criminal Jury Charges, by Judge Elizabeth Berry, Judge George Gallagher, and Paul McClung (James Publishing Incorporated), and Texas Practice, Volumes 7, 7A and, 8 by Judge Tom Blackwell, Judge Michael McCormick, and Betty Blackwell (West Publishing Company). I rely on these two resources extensively, but from time to time I have had to modify the forms, or even to draft applicable instructions from scratch. I have included some of those instructions in this portion of the website, and make them available to any lawyer who finds them useful, with the same caveat in the previous section: Use these charges only as a place to begin, then modify them to fit the particular facts in your case.


I have cross-examined witnesses and made arguments in many different kinds of cases over the years. Some of these have been transcribed and are included in this section of the website.

Recent PowerPoint Presentations

I accompany most of my CLE presentations with Power Point slides.  Some of my recent Power Point presentations are included here.

Recent Decisions From The Texas Court of Criminal Appeals