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 ENJOIN THE PROSECUTION FROM
INFORMING WITNESSES AS TO WHAT OTHER WITNESSES MAY
HAVE SAID OR FROM PREPPING ITS WITNESSES TOGETHER

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 prohibit the prosecution from telling witnesses what other witnesses may have said in statements or from prepping witnesses together. In support of his motion, Mr. CLIENT states as follows:
1. This is a capital case. Defendant faces the death penalty.
2. Defendant has filed a motion regarding the rule of sequestration of witnesses. See also State v. Narcisse, 426 So. 2d 118, 132 (La. 1983) ("'upon request of the state or the defendant the court shall order that the witnesses . . . refrain from discussing the facts of the case or the testimony of any witness'").
3. The rule contemplates that witnesses should testify to what they know. This means that they should not be told what other witnesses know. It also means that they should not be prepped as to the "correct" answers to questions that may be forthcoming with respect to prior inconsistent statements.
WHEREFORE, Mr. CLIENT moves for an order assuring that the witnesses not be advised of the testimony or statements of other witnesses, and that they not be "prepped" as to the right answers for their testimony.
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