This is a document filed in a mock court in the State of Ridgeway on Roblox.com, and does not constitute
real-life legal advice in any way, shape, or form.
SUPERIOR COURT OF THE STATE OF RIDGEWAY
THE STATE OF RIDGEWAY,
v.
VEXNORAH,
Defendant.
No. RSC-CM-2649
DEFENSE’S MOTION FOR DISCOVERY
The Defense, by and through undersigned counsel, hereby, pursuant to Ridgeway Rule of
Criminal Procedure 14, moves for discovery of the following–
GENERAL DISCOVERY
1. Defendant(s)’ Statements | Criminal Rule 14(a)(1)(a). The Defense is entitled to
disclosure of any and all copies of any statement(s) 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 warnings under Miranda v. Arizona, 384 U.S. 436 (1966) 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
to disclose any statement of a Defendant in the possession, custody, or control of any agency or
department).
2. Video Evidence. Any and all video evidence (including long videos, clips, and other
videos) that the Government may have to support the charges, and in the case of a long video, the
timestamps of which are alleged by the Government to show that the Defendant(s) have
committed the alleged offenses as contained in the Information/Indictment. This request includes
any videos of an arrest or search warrant being executed, with timestamps of which alleged facts
the Government will rely upon.
3. Documents and Objects. Any and all copies of, or an opportunity to inspect and copy or
photograph, any and all books, papers, documents, depictions, photographs, tangible objects,
buildings, automobiles, or places that are material to the preparation of the Defense, or are
intended for use by the government in its case-in-chief or were obtained from or belong to the
Defendant(s). This request includes search warrant receipts.
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This is a document filed in a mock court in the State of Ridgeway on Roblox.com, and does not constitute
real-life legal advice in any way, shape, or form.
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. You are not required to produce any criminal investigation reports, but if produced, the
Defense would be grateful and will not introduce it into evidence for any purpose.
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 | United States v. Henthorn, 931 F.2d 29
(9th Cir. 1991). If the Government intends to call an officer of the Government to testify,
the Defense requests their personnel files, e.g., employment contracts (including any
non-disclosure agreement signed), any oath of office taken, recorded warnings, etc. The
Defense requests that the Government examine those 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 dishonesty or any other exculpatory material.
b. Evidence of Criminal Investigation of Any Government Witness | United States v.
Chitty, 760 F.2d 425 (2nd Cir. 1985). The Defense requests any evidence that any
prospective witness is under investigation by the Government for any criminal conduct.
c. Promises Made in Exchange for Testimony | 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 exchange for
their testimony in this case and all other information that could arguably be used for the
impeachment of any government witnesses.
d. 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.
e. Information Regarding Complainants, Informants, and/or Cooperating Witnesses |
Roviaro v. United States, 353 U.S. 53 (1957). The Defense requests that the Government
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This is a document filed in a mock court in the State of Ridgeway on Roblox.com, and does not constitute
real-life legal advice in any way, shape, or form.
provide all relevant information concerning any complainant(s), informant(s), and/or
cooperating witness(es). The Government is obligated to disclose the identification and
location of any complainant(s), informant(s), and/or cooperating witness(es), as well as
the identity and contact information of any other eyewitness or expert witness.
f. Expert Witnesses. A written summary of testimony the government intends to use
under Evidence Rule(s) 43, 44, and 46, describing the witnesses’ qualifications, opinions,
the bases and reasons for those opinions, and the contact information of those witnesses.
g. 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 audiotapes, dispatch/radio broadcasts, surveillance 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 video, audio, or tape-recorded.
EXCULPATORY EVIDENCE
6. General Exculpatory Evidence | Brady v. Maryland, 373 U.S. 83 (1963). The Defense
requests any and all information of whatever source, form, or nature, including 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 and exculpatory evidence fall 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). “[T]he government has an obligation to turn over evidence in its possession that is
both favorable to the accused and material to guilt or punishment … evidence is material only if
there is a reasonable probability that had the evidence been disclosed to the defense, the result of
the proceeding would have been different. A reasonable probability is a probability sufficient to
undermine confidence in the outcome.” Ritchie, 480 U.S., at 57 (cleaned up). The evidence
disclosed under Brady requires that information be produced in such a way that it will be of
value to the Defense. See United States v. Hsia, 24 F. Supp. 2d 14, 29 (D.D.C. 1998) (“The
Government can’t meet its Brady obligations by providing [the Defense] with access to 600,000
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This is a document filed in a mock court in the State of Ridgeway on Roblox.com, and does not constitute
real-life legal advice in any way, shape, or form.
documents and then claiming that [they] should have been able to find the exculpatory
information in the haystack.”)
7. 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 whom the Government does not intend to call at trial or who made an
arguably favorable statement concerning the Defendant(s).
8. 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
9. Bad Acts. 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.
10. Sentencing Disclosures. The Defense requests that the Government provide all relevant
information concerning sentencing (i.e. maximum sentence for each charge).
11. Plea Offers. Any and all plea offers that the Government wishes to make, i.e. disclosure
of any offer to agree to recommend a sentence for each offense lesser than the maximum
sentence of any charge in exchange for a plea of guilty, a plea under North Carolina v. Alford,
400 U.S. 25 (1970), or nolo contendere (no contest).
12. Grand Jury | Criminal Rule 14(a)(1)(a)(ii). If this proceeding was commenced by a Grand
Jury by an Indictment and not an Information, all grand jury minutes and the written or recorded
statements of any person who has testified before the grand jury.
* * * * * *
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 dispute or
will engage in motion practice. If the Government has produced all the material and other
information, the Government should certify as much.
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This is a document filed in a mock court in the State of Ridgeway on Roblox.com, and does not constitute
real-life legal advice in any way, shape, or form.
Dated: ______________________, 2024
Palmer, Ridgeway
/s/ DorkJacob
—————————————————————————————————————————————
DorkJacob
Ridgeway Bar No. 17135
Chief Public Defender
Counsel of Record
Public Defense Office
State Government Annex
1100 Lakeside Drive
Palmer, Ridgeway
Attorney(s) for Defendant(s)
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