IN THE FIFTIETH JUDICIAL DISTRICT, PARISH OF PEINE DE MORT
STATE OF LOUISIANA
No. _____

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STATE OF LOUISIANA, Plaintiff
v.
JOHN CLIENT, Defendant

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MOTION TO SEQUESTER WITNESSES PRIOR TO
AND DURING THE TRIAL OF THIS CASE

COMES NOW, JOHN CLIENT, by counsel, and moves this Court pursuant to the Fourth, Fifth, Sixth, Eighth and Fourteenth Amendments to the United States Constitution, and Article 1, Sections 2, 3, 5, 13, 14, 16, 17, 19, 20, 22, and 24 of the Louisiana Constitution to sequester the witnesses prior to and during the trial of this case. In support of his motion, Mr. CLIENT states as follows:
1. This is a capital case. Mr. CLIENT faces the death penalty.
2. In State v. Narcisse, 426 So. 2d 118, 132 (La. 1983), the Court held that "[t]he sequestration rule is contained in La. Code Crim. Pro. art. 764: '. . . upon request of the state or the defendant the court shall order that the witnesses be excluded from the courtroom or from where they can see or hear the proceedings and refrain from discussing the facts of the case or the testimony of any witness with anyone other than the district attorney or defense counsel.'"
3. Mr. CLIENT does make this request.
4. Moreover, Mr. CLIENT requests that the sequestration start prior to voir dire. His reason is that very often a party reveals his theory of the case through voir dire questioning.
WHEREFORE, Mr. CLIENT moves that an order be entered assuring that the witnesses be sequestered throughout the course of the voir dire and trial proceedings.
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