Ridgeway Unified Courts

JUDICIAL COUNCIL OF RIDGEWAY

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This document is a document filed in a mock court in the State of Ridgeway on Roblox.com. I am a notary public of the State of Texas in real life. A notary public cannot give legal advice or accept fees for legal advice. See Tex. Gov't Code § 406.017. This document does not constitute legal advice in any way, shape, or form. SUPERIOR COURT OF THE STATE OF RIDGEWAY THE STATE OF RIDGEWAY, v. THEOMNIDESTROYER, Defendant. No. RSC-CM-323 MOTION FOR DISCOVERY Defendant TheOmniDestroyer, by and through undersigned counsel, hereby, pursuant to Ridgeway Rule of Criminal Procedure 14, moves for discovery of the following material– GENERAL DISCOVERY 1. Defendant(s)’ Statements | Rule 14(a)(1)(a)(i). The Defense is entitled to disclosure of all copies of any written or recorded statements made by the Defendant(s), the substance of any statements made by the Defendant(s) which the Government intends to offer in evidence at trial, any response by the Defendant(s) to interrogation, the substance of any oral statements which the Government intends to introduce at trial, and any written summaries of the Defendant(s)’ oral statements contained in the handwritten notes of any government agent; any response to any Miranda warnings which may have been given to the Defendant(s); and all other of the Defendant(s)’ statements that are discoverable. See United States v. Safavian, 233 F.R.D. 12 (D.D.C. 2005) (holding that the Government is required disclose any statement of a Defendant in the possession, custody or control of any executive branch agency or department, regardless of whether the statement originated from a local law enforcement agency, a non-law enforcement agency of the government, or a coordinate branch of the government). 2. Video Evidence. Any video evidence that the Government may have to support the charges, and the timestamps of which are alleged to show that the Defendant(s) have committed the alleged offenses. MOTION FOR DISCOVERY - 1 - DorkJacob Law 5 Cyrus Acres Milton, Ridgeway This document is a document filed in a mock court in the State of Ridgeway on Roblox.com. I am a notary public of the State of Texas in real life. A notary public cannot give legal advice or accept fees for legal advice. See Tex. Gov't Code § 406.017. This document does not constitute legal advice in any way, shape, or form. 3. Documents & Objects. Copies of, or an opportunity to inspect and copy or photograph, any books, papers, documents, depictions, photographs, tangible objects, buildings, automobiles, or places which are material to the preparation of the Defense, are intended for use by the government in its case-in-chief or were obtained from or belong to the Defendant(s). 4. Reports of Tests or Examinations. The Defense requests the reports of all tests and examinations conducted upon the evidence in this case that is within the possession, custody, or control of the Government, the existence of which is known, or by the exercise of due diligence may become known, to the attorney for the government, and which are material to the preparation of the defense or which are intended for use by the Government as evidence-in-chief at trial. This does not include investigation reports. 5. Witnesses. The Defense requests the names, contact information and written testimony of any witness the Government intends to present at trial or will present if the need arises, and any exhibits the Government plans to use to summarize or enforce the testimony. a. Officers of the Government Testifying. If the Government intends to call an officer of the Government to testify, the Defense requests their personnel files, e.g. employment contracts. b. Evidence of Criminal Investigation of Any Government Witness | United States v. Chitty, 760 F.2d 425 (2nd Cir. 1985), cert. denied, 474 U.S. 945 (1985). The Defense requests any evidence that any prospective witness is under investigation by authorities for any criminal conduct. c. Giglio Information | Giglio v. United States, 405 U.S. 150 (1972). The Defense requests all statements and/or promises, expressed or implied, made to any government witnesses, agencies, entities, or other governments in MOTION FOR DISCOVERY - 2 - DorkJacob Law 5 Cyrus Acres Milton, Ridgeway This document is a document filed in a mock court in the State of Ridgeway on Roblox.com. I am a notary public of the State of Texas in real life. A notary public cannot give legal advice or accept fees for legal advice. See Tex. Gov't Code § 406.017. This document does not constitute legal advice in any way, shape, or form. exchange for their testimony in this case, and all other information which could arguably be used for the impeachment of any government witnesses. d. Government Examination of Law Enforcement Personnel Files United States v. Henthorn, 931 F.2d 29 (9th Cir. 1991). The Defense requests that the Government examine the personnel files and any other files within its custody, care, or control, or which could be obtained by the Government, for all witnesses. The Defense requests that these files be reviewed by the Government for evidence of perjurious conduct or other like dishonesty, or any other exculpatory material. e. Evidence of Bias or Motive to Lie | Pennsylvania v. Ritchie, 480 U.S. 39 (1987). The Defense requests any evidence that any prospective government witness is biased or prejudiced against the Defendant(s), or has a motive to falsify or distort their testimony. f. Information Regarding Informants and Cooperating Witnesses Roviaro v. United States, 353 U.S. 53 (1957). The Defense requests that the Government provide all relevant information concerning any informants or cooperating witnesses involved in this case. The Government is obligated to disclose the identification and location of any informants or cooperating witnesses, as well as the identity and contact information of any other witnesses. g. Expert Witnesses. A written summary of testimony the government intends to use under Ridgeway Rules of Evidence 43, 44, and 46, describing the witnesses’ qualifications, opinions, and the bases and reasons for those opinions, as well as, the contact information of those witnesses. 6. Request for Preservation of Evidence. The Defense specifically requests that all evidence in whatever form, including but not limited to all notes, reports, memoranda, logs, video and audio tapes, dispatch/radio broadcasts, surveillance MOTION FOR DISCOVERY - 3 - DorkJacob Law 5 Cyrus Acres Milton, Ridgeway This document is a document filed in a mock court in the State of Ridgeway on Roblox.com. I am a notary public of the State of Texas in real life. A notary public cannot give legal advice or accept fees for legal advice. See Tex. Gov't Code § 406.017. This document does not constitute legal advice in any way, shape, or form. records, telephone conversations, photographs, and any and all physical evidence that may be destroyed, lost, or otherwise put out of the possession, custody, or care of the government and which relate to the Information or the events leading to the Information being filed be preserved. The Defense requests that all information and statements taken in whatever form including but not limited to meetings, conferences, conversations, debriefings, and proffers be audio or tape-recorded. Tape recording those proceedings will ensure an accurate record of what statements are actually made by any potential witness. EXCULPATORY DISCOVERY 7. Exculpatory Evidence | Brady v. Maryland, 373 U.S. 83 (1963). The Defense requests all information of whatever source, form, or nature, to include but not limited to documents, statements, intelligence, reports and any and all tangible evidence favorable to the Defense on the issue of guilt and/or which affects the credibility of the Government’s case. Impeachment as well as exculpatory evidence falls within Brady’s definition of evidence favorable to the accused. See United States v. Bagley, 473 U.S. 667 (1985); United States v. Agurs, 427 U.S. 97 (1976). Evidence disclosed under Brady requires that information be produced in such a way that it will be of value to the Defendant(s). See United States v. Hsia, 24 F. Supp. 2d 14, 29 (D.D.C. 1998) (“The Government cannot meet its Brady obligations by providing [the Defense] with access to 600,000 documents and then claiming that she should have been able to find the exculpatory information in the haystack.”), rev’d on other grounds, 176 F.3d 517 (D.C. Cir. 1999). 8. Favorable Witnesses | Jackson v. Wainwright, 390 F.2d 288 (5th Cir. 1968). The Defense requests any witness statements that may be favorable to the Defendant(s),and the contact information of any witness who the Government does not intend to call at trial, or who made an arguably favorable statement concerning the Defendant(s). MOTION FOR DISCOVERY - 4 - DorkJacob Law 5 Cyrus Acres Milton, Ridgeway This document is a document filed in a mock court in the State of Ridgeway on Roblox.com. I am a notary public of the State of Texas in real life. A notary public cannot give legal advice or accept fees for legal advice. See Tex. Gov't Code § 406.017. This document does not constitute legal advice in any way, shape, or form. 9. Witness Statements. The Defense requests any written statements made by the witness that are signed or otherwise adopted and approved by the witness, a substantially verbatim recital of an oral statement recorded contemporaneously, or a statement made to a grand jury, as well as, any other related material. MISCELLANEOUS DISCOVERY 10. Bad Acts | Ridgeway Rule of Evidence 13. Notice of evidence of any other crimes, wrongs, or acts which the Government intends to introduce at trial. This includes a request for all supporting records, reports, notes, and memoranda providing the details of any such evidence. 11. Sentencing Disclosures | United States v. Rosa, 891 F.2d 1074 (3rd Cir. 1989). The Defense requests that the Government provide all relevant information concerning sentencing if not already provided. If the Government does not produce any of the requested material, the Defense requests that the Government state, in writing, the reasons why the Government refuses to produce such material. In response, the Defense will request a pretrial conference to resolve such a dispute. Respectfully submitted. Dated: May 9th, 2022 Milton, Ridgeway /s/ DorkJacob ——————————————————————————— DORKJACOB Ridgeway Bar No. 17135 Counsel of Record DorkJacob Law 5 Cyrus Acres Milton, Ridgeway JacobInAustin#0001 [email protected] Attorney for Defendant MOTION FOR DISCOVERY - 5 - DorkJacob Law 5 Cyrus Acres Milton, Ridgeway

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