The following motion is used to request inclusion of desired explanatory instructions and definitions in the admonitory instructions given the jury panel before voir dire. Tex. R. Civ. P. 226a, part I, provides that prescribed oral instructions, “with such modifications as the circumstances of the particular case may require,” are to be given before the voir dire examination.
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Include the following notice if a minor is named in the caption or if the motion contains other unredacted sensitive data. See § 6 of the Introduction in volume 1 of this manual concerning protection of sensitive data in filed documents. |
NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA
[Caption. See § 3 of the Introduction in volume 1 of this manual.]
Motion for Special Instructions to Jury Panel
This Motion for Special Instructions to Jury Panel is brought by [name of movant], [party designation].
1.The matter is brought before the voir dire examination of the jury panel.
2.The fact issues raised by the pleadings are: [specify issues, e.g., cruel treatment, managing conservatorship].
3.To enable the jury panel to properly understand voir dire examination on these issues, [name of movant] requests the following explanatory instructions and definitions of legal terms be given to the jury panel by the Court before voir dire examination: [specify explanatory instructions and definitions requested. For examples see explanatory instructions and definitions in Texas Pattern Jury Charges—Family & Probate.].
[Name of movant] prays that the Court grant this Motion for Special Instructions to Jury Panel.
[Name]
Attorney for [name of movant]
State Bar No.:
[E-mail address]
[Address]
[Telephone]
[Fax]
Notice of Hearing
The above motion is set for hearing on __________________ at ____________ __.m. in [designation and location of court].
SIGNED on ________________________________.
Judge or Clerk
Certificate of Service
I certify that a true copy of this [document/[title of document]] was served in accordance with rule 21a of the Texas Rules of Civil Procedure on the following on [date]:
[Name of attorney of record or party to be served] by [electronic filing manager/e-mail at [e-mail address]/fax at [fax number]/personal delivery at [address]/commercial delivery service at [address]/certified mail at [address]/first-class mail at [address]]. [Repeat for each attorney of record or party to be served.]
[Name]
Attorney for [name of movant]