Cause No. ___________ THE STATE OF ______ VS.

____ (DEFENDANT) IN CRIMINAL DISTRICT COURT NUMBER ____ (COUNTY), (STATE)

MOTION TO SUPPRESS ORAL & WRITTEN STATEMENTS OF DEFENDANT TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, _________________, (court-appointed) attorney of record for Defendant, _____________, and respectfully moves the court to suppress any and all oral or written statements of Defendant in this cause made to agents of the State. In support of said motion Defendant would show the court as follows: 1. That the Defendant was arrested, detained, and interrogated by law enforcement officers on _______________; 2. That during said interrogation, the Defendant clearly and unambiguously invoked his right to counsel ; 3. That law enforcement officers continued to question Defendant and obtain written and oral statements from him; 4. That the aforesaid written and oral statements were not voluntarily given, but rather were obtained in violation of Defendants rights under the Fourth, Fifth, Sixth, and Fourteenth Amendments to the United States Constitution; Article 1, Sections 9 and 10 of the Texas Constitution; and Articles 1.06, 38.22, and 38.23 of the Texas Code of Criminal Procedure, among others.

WHEREFORE, PREMISES CONSIDERED, Defendant prays that the court set this motion for hearing prior to trial, and upon hearing thereof, that the court enter an order suppressing any and all written or oral statements made by Defendant to agents of this or any other state or law enforcement agency. Respectfully submitted, LAW OFFICES OF _____________________ Address Line #1 Address Line #2 Telephone E-mail _______________________________________ Printed Name State Bar No. XXXXXXXXX