Ridgeway Unified Courts

JUDICIAL COUNCIL OF RIDGEWAY

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SUPERIOR COURT OF THE STATE OF RIDGEWAY FOR THE DISTRICT OF RIDGEWAY RIDGEWAY NATIONAL RIFLE ASSOCIATION, INC., a Ridgeway licensed corporation; SAGE03X, an individual and resident of Ridgeway County; ANTHONYPANCI, an individual and resident of Ridgeway County, and; TOMDONOVANSMITH, an individual and resident of Ridgeway County; Plaintiffs, v. LARGETITANIC2, in his official capacity as Governor of the State of Ridgeway; TECHIEY, in his official capacity as the Attorney General of the State of Ridgeway; AERIUM, in his official capacity as the Colonel of the Ridgeway State Police; Defendants. Case No. RSC-CV-881 MOTION FOR DISCOVERY MOTION FOR DISCOVERY Plaintiffs, Ridgeway National Rifle Association, Sage03x, AnthonyPanci, and TomDonovanSmith (collectively “Plaintiffs,”), through their undersigned counsel of record, moves to discover the items listed below pursuant to Rid. R. Civ. P. 19. None of the items requested are privileged, and are relevant to this court’s disposition of the claims before it. 1. Any instructions, policies, procedures, directives, or orders, whether written, verbal, or otherwise, instructing staff of any capacity about how to administer and enforce the State Firearms Act. 2. Any instructions, policies, procedures, directives, or orders, whether written, verbal, or otherwise, instructing staff of any capacity of the amended provisions of the State Firearms Act. 3. Any and all records upon a repository, archive, or directory containing the information of all individuals who turned over their firearms in the forty-eight-hour amnesty prescribed in the State Firearms Act. 4. Any and all records upon a repository, archive, or directory containing the information and models of all firearms and magazines turned over to the Ridgeway State Police or any other law enforcement entity in the forty-eight-hour amnesty prescribed in the State Firearms Act. 5. Any and all firearms and magazines issued by developer oversight that has not yet been released for sale to the public containing more than fifteen rounds. 6. Any studies, reports, or expert opinions that were considered by the state legislature in the process of drafting and passing the State Firearms Act. 7. Any data or statistics related to the impact of similar regulations in other jurisdictions, including but not limited to crime rates, public safety, and Second Amendment rights. 8. Any internal or external communications or correspondence related to the enforcement of the State Firearms Act, including but not limited to training materials, instructions, and guidance provided to law enforcement officers. 9. Any data or statistics related to the number of individuals who have been charged or convicted under the State Firearms Act, as well as the disposition of those cases. 10. Any data or statistics related to the number of firearms, magazines, and ammunition that have been seized or confiscated by law enforcement as a result of the State Firearms Act. 11. Any documents or communications related to the legal defense of the State Firearms Act, including but not limited to any briefs, memorandums, or opinions prepared by the attorney general or other legal counsel for the State. Dated: February 8, 2023 Respectfully submitted. STICKZA Managing Partner COHN, CICERO, & GOODRICH, LLC Suite 3B, Palmer Apartments Palmer, RW 33328 D: stick#0677 E: [email protected] ELLOM8HOWAREYOU Partner COHN, CICERO, & GOODRICH, LLC Suite 3B, Palmer Apartments Palmer, RW 33328 D: ello ! #2023 E: [email protected] BOBFOGARTY Senior Associate COHN, CICERO, & GOODRICH, LLC Suite 3B, Palmer Apartments Palmer, RW 33328 D: bob.#4225 E: [email protected] Counsel of Record

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