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IN THE CIRCUIT COURT OF RANKIN COUNTY, MISSISSIPPI STATE OF MISSISSIPPIVS. CAUSE NUMBER _________**DEFENDANT MOTION TO PRODUCE NEGATIVES COMES NOW, ____________, by counsel, and moves this Court pursuant to the Fourth, Fifth, Sixth, Eighth and Fourteenth Amendments to the United States Constitution, and Article 3, §§ 5, 12, 13, 14, 15, 16, 18, 21, 22, 23, 24, 25, 26, 27, 28, 29, 31 & 32 of the Mississippi Constitution to order production of the negatives of every picture taken during the investigation of this case, including but not limited to every picture taken at the crime scene and the autopsy. In support of his motion, ______ states as follows:___________ has an absolute, constitutional right to access to physical evidence for independent testing. See , Jackson v. State, 243 So.2d 396, 398 (Miss. 1970); Love v. State , 441 So.2d 1353, 1355 (Miss. 1983); Harris v. State, 446 So.2d 585, 588 (Miss. 1984). _____________ wishes to reproduce copies of the photographs in this case in a manner which will render them less prejudicial to his substantial rights. This can only meaningfully be done from the negatives. ___________ will not be able to prepare for trial unless this motion is granted immediately. WHEREFORE, _____________ moves that his motion be granted, and the negatives be produced. Respectfully submitted,**By:_________________________ ** CERTIFICATE OF SERVICE I, __________________, attorney for ____________, do hereby certify that I have on this day mailed, postage prepaid, a true and correct copy of the foregoing Motion to This the ____ day of __________, 19___. _____________________________ **