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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EX PARTE MOTION FOR OUT-OF-STATE WITNESS

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, Article 1, Sections 2, 3, 5, 13, 14, 16 & 17 of the Louisiana Constitution, and other law set out below, to order funds and an out-of-state witness subpoena for the attendance of I. SEENIT, 4738 Witness Boulevard, Ft. Lauderdale, Florida to attend his trial.
In support of his motion, Mr. CLIENT states as follows:

1. Since this is to be a capital prosecution, exacting standards must be met to assure that it is fair. As the Louisiana Supreme Court has held, "[d]eath, in its finality, differs more from life imprisonment than a 100-year prison term differs from one of only a year or two. Because of that qualitative difference, there is a corresponding difference in the need for reliability in the jury's determination that death is the appropriate punishment in a specific case." State v. Myles, 389 So. 2d 12, 30 (La. 1980) (citing cases).
2. Mr. SEENIT will provide critical evidence concerning Mr. CLIENT's alibi for the time of the crime. Further evidence concerning his testimony will be provided to the Court at an ex parte hearing on this matter.
Statement regarding Service
Because this is an ex parte pleading, I hereby certify that I have NOT served a copy of the foregoing document upon the District Attorney this ___ day of October, 1992
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