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 REQUIRE THE STATE TO FURNISH PROPOSED
JURY INSTRUCTIONS TWENTY-FOUR HOURS PRIOR TO TRIAL

COMES NOW, JOHN CLIENT, through the undersigned attorney, and hereby respectfully moves this Court, pursuant to the Sixth, Eighth and Fourteenth Amendments to the United States Constitution and Article 1 of the Louisiana Constitution to require the State to furnish the Defendant with copies of the State's proposed jury instructions at least twenty-four hours prior to trial. In support of this Motion, defendant states the following:
1. Customarily, some district attorneys furnish defense counsel copies of the State's proposed jury instructions just prior to submitting them to the Court, thereby leaving counsel little time to properly research objections to the proposed instructions.
2. Because the courts may require specific objections to the instructions at trial, and because this is a capital case necessitating more than the usual number of instructions, counsel will need at least twenty-four hours in which to prepare his objections. If the District Attorney is permitted to withhold his instructions until the case is about to be submitted to the jury, the Defendant will be denied his right to a fair trial.
WHEREFORE, premises considered, the Defendant respectfully requests this Court to require the District Attorney to furnish the State's proposed jury instructions to defense counsel no later than twenty-four hours prior to trial.
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