We have a case going to trial next week with an indictment alleging a 2nd degree felony with 5 enhancement paragraphs. Enhancement paragraphs 1,2&3 are for convictions on 5/26/92. Enhancement paragraph 4 is for a 9/17/01 conviction. Enhancement paragraph 5 is for a 2/8/02 conviction. I'm looking for the most simple way (short of just abandoning what are probably surplus enhancements)to word the punishment charge enhancement provisions and verdict forms. I've got a pretty good charge on a case with 3 enhancements but none of these are for convictions on the same date.

If any of ya'll have a more simple example of a charge dealing with this or a similar scenario please fire me an email at bsmith@snydertex.com, or post your suggestions here.

Ben, My legal assistant has a charge that seems to simplyify the mulitple convictions in punishment charges.Call Patti at 361-358-1007