RIDGEWAY SUPERIOR COURT
STATE OF RIDGEWAY,
Plaintiff,
v.
XJVMMA,
Defendant.
Case No. RSC-CM-821
MOTION FOR DISCOVERY
MOTION FOR DISCOVERY
In accordance with Rid. R. Crim. P. 14(a)(2), the Defendant in the above entitled matter
hereby moves to discover the following items in addition to the automatic discovery obligated by
Rid. R. Crim. P. 13(a)(1):
1. Any and all evidence that the State has knowledge of materially relating to this case but is
not obligated to turn over under the rules that may take the form of testimony, tangible
exhibits, photographs, videos, etc.
2. Any discussions with witnesses where the topic of discussion is materially related to the
facts of the case including direct messages. This extends to all witnesses who the State
intends to call at trial, doesn’t intend to call at trial, intended to call at grand jury, and did
call at grand jury, and otherwise.
3. The names and contact information of all witnesses that the State has knowledge of
regardless of their intent to call them.
4. Any records of internal affairs investigations including the internal affairs tip, evidence
collected, names and contact information of witnesses spoken to, testimony of the
witnesses, internal deliberations about the facts of the case, and internal affairs
investigations report.
5. Any discussions/collaboration between investigators across multiple agencies including
but not limited to discussions between the criminal investigative agency and the internal
investigative agency.
6. Any discussions, directives, orders, or otherwise from any individual within or outside the
Palmer Police Department relating to the disciplinary action of the named Defendant.
7. The original tip was filed to the Department of Justice and all associated evidence.
8. The Defendant’s full employment record with the Palmer Police Department including all
past disciplinary actions, all past promotions, commendations, and otherwise.
9. The names of all investigators within the State Bureau of Investigation (SBI) or otherwise
applicable investigative agency who contributed to this case.
10. Any criminal investigative report produced by SBI or other investigative agency related to
this case.
11. Any expert opinion that was sought even if the State does not intend to call that expert at
trial.
12. The complete criminal record of the complainant inclduing any records related to lying,
stealing, cheating, forgery, fraud, pergury, and otherwise.
13. The complete criminal record of any witness including records related to lying, stealing,
cheating, forgery, fraud, pergury, and otherwise.
14. The percentage of grand jurors who are law enforcement officers or work for a law
enforcement agency.
15. The percentage of grand jurors who are members of the State Bar.
16. Any other evidence or testimony not included in this motion but related to the allegations
of this case.
Respectfully Submitted.
CLIFFORD2
Counsel
10 000
TURTABLE5000
Counsel
10 000
Dated: 12/23/2022
