4 motions to suppress evidence seized from places.  “It is generally better to not allege specific grounds to avoid warning the prosecution which grounds will be pursued at the hearing. The above-listed grounds can serve as a guide for questioning of prosecution witnesses at the suppression hearing or for tailoring a specific motion if the facts require specificity.”  Text §§2:01-21, Forms 2-2 to 2-5

2 motions to reveal identity of informer.  “Even if the state is not ultimately required to reveal identity, the hearing on the motion can be an excellent discovery device and can coerce the state into dismissal or a favorable plea.” Text §§2:40-45, Forms 2-6 and 2-7 

10 motions to suppress evidence seized from persons.  “Another benefit to requiring the trial court to hear testimony on a motion to suppress evidence is to discover what the testimony of the involved law enforcement agents will be at trial. At the hearing counsel can lock in their testimony on crucial points.”  Text §§3:01-31, Forms 3-2 to 3-5 and 3-7 to 3-12 

7 Sixth Amendment motions.  “Although the accused has had counsel appointed for a particular offense his right to counsel often has not been properly invoked as to other offenses.  In this situation it is important to make sure that there is also a Fifth Amendment invocation by the defendant.”  Text §§4:01-43, Forms 4-1 to 4-2 and 4-13 to 4-17 

15 Fifth Amendment motions.  “If counsel seeks to suppress a defendant’s statement it is enough to show a violation of Miranda or Tex. Code Crim. Proc. art. 38.22. However, if counsel is seeking also to suppress evidence obtained through the taking of the defendant’s statement, actual coercion by government agents must be shown.”  Text §§5:01-103, Forms 5-4 to 5-6 and 5-10 to 5-21 

7 applications for writ of habeas corpus.  “Because collateral estoppel claims are not cognizable on a pre-trial writ of habeas corpus absent an accompanying constitutional double jeopardy claim, counsel should always couple the collateral estoppel claim with a constitutional double jeopardy claim.”  Text §§8:01-33, Forms 8-1 to 8-4 and 8-10 to 8-12 

11 bond motions and writs.  “Since bonds can be forfeited or declared insufficient so readily, it is often necessary for the counsel for the defendant be prepared on short notice to show the trial court good cause for the bond to be reinstated or to that the defendant was arrested in error.”  Text §§9:01-52, Forms 9-1 to 9-4, 9-6 to 9-10, and 9-12 and 13 

32 pretrial motions.  “Before pursuing the motion to testify free of impeachment by prior convictions, counsel should deliver a request to the state that they give notice under Rule 609 of any prior conviction they intend to use to impeach the defendant at trial.”  Text §§12:01-191, Forms 12-1 to 12-32 

25 discovery motions and requests.  “Because Rule 902(10)a states that proper notice is required before business records can be admitted at trial without a sponsoring witness, counsel may wish to delete this part of the request for notice in anticipation that the other party will fail to give the required notice, thus failing the predicate.”  Text §§13:01-222, Forms 13-1 to 13-7, 13-13 to 13-31 

18 jury forms.  “In order to preserve error in a trial court’s erroneous denial of a defense challenge for cause, the defendant must follow a rigorous predicate including….”  Text §§14:01-91, Forms 14-1 to 14-18 

16 limiting instructions.  “Requesting a limiting instruction gives opposing counsel another forum in which to explain to the trial court the reason to sustain the original objection to the proposed evidence; and gives an opportunity to make further objections to the evidence.”  Text §§15:140-59, Forms 15-24 to 15-32 and 15-35 to 15-41 

30 trial motions.  “There is a three-step procedure for preserving error when a subpoenaed witness does not appear. First….”  Text §§15:1-312, Forms 15-3 to15- 22 and 15-42 to 15-63 

16 punishment motions.  “As a general proposition, a defendant must object to terms and conditions of community supervision at the time they are imposed in order to challenge the same on appeal. However, the defendant can challenge the terms and conditions by way of a habeas corpus petition. This is true even for defendants on deferred adjudication community supervision.  [Citations omitted.]”  Text §§20:1-151, Forms 20-1 to 20-10 and 20-25 to 20-33 

15 for DWI.  Chapter 10

15 for child abuse.  Chapter 17

18 for sex offender registration.  Chapter 18