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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PRELIMINARY
MOTION TO QUASH THE INDICTMENT AND CHALLENGE
TO THE COMPOSITION OF THE GRAND AND PETIT JURIES

The defendant, by counsel, moves this Court pursuant to the Sixth, Eighth and Fourteenth Amendments to the United States Constitution, Article I, Section 16 of the Louisiana Constitution of 1974 and La. Code Crim. Proc. arts. 408, 409, and 419, to quash the indictment against him and challenges the composition of the grand and petit jury venire because of the systematic underrepresentation of [whatever group: blacks, women, young adults (age 18-30) or other cognizable group] in the selection of grand and traverse juries in this county.
IN SUPPORT THEREOF, defendant states as follows:
1. There was an intentional, discriminatory and systematic exclusion of [black persons, women, young adults and other cognizable groups] from the jury rolls from which the grand jury which indicted the defendant was selected and from which the traverse jury which will try this case will be selected.
2. This county has a history and pattern of intentional, discriminatory and systematic exclusion of [black persons, women or young adults] from the grand and petit jury pools.
3. [Black persons, women, young adults or other group] constitute a cognizable, distinctive class of persons in this community.
4. Exclusion of [whatever group] from the [grand or petit] jury pool violates the defendant's right to a [grand or petit] jury composed of a fair cross-section of the community, Duren v. Missouri, 439 U.S. 357, 99 S. Ct. 664, 58 L. Ed. 2d 579 (1979), and denies him equal protection of the law, Castaneda v. Partida, 430 U.S. 482, 97 S. Ct. 1272, 51 L. Ed. 2d 498 (1977), and violates the Constitution and laws of Louisiana. See also, La. Code Crim. Proc. art. 419; La. Sup. Ct. R. XXV; Vasquez v. Hillery, 474 U.S. 254, 106 S. Ct. 617, 88 L. Ed. 2d 598 (1986); State v. Procell, 332 So. 2d 814, 816 (La. 1976).
WHEREFORE, the defendant prays:
(a) That the court provide access to funds for the expert assistance needed to develop demographic and statistical facts;
(b) That the court set down this motion for an evidentiary hearing;
(c) That the indictment returned against him be quashed because of the unconstitutional composition of the pool from which the venire was drawn;
(d) That the traverse jury panel not be put upon him because of the unconstitutional composition of the pool from which the venire was drawn;
(e) That the Court order the compilation of a new jury pool that is a fair cross-section of the community; and
(f) Such other relief as may be appropriate in light of the constitutional violations shown at the hearing on this motion.
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