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- 1 - IN THE ______________ COURT OF ______________ COUNTY STATE OF ________________ )) ) Petitioner/Plaintiff, ))) NO. Vs. )) ) Respondent/Defendant ) ) MOTION FOR DISCOVERY OF INFORMATION NECESSARY TO RECEIVE A FAIR TRIAL COMES NOW ___________ by counsel, and respectfully moves this Court pursuant to the Sixth, Eighth and Fourteenth Amendments to the United States Constitution, to require the prosecution to disclose to counsel, and permit them to inspect, copy, test and photograph the following: 1. All statements, written or oral, made by this defendant to any person, at anytime, before or after his arrest in this case, including the name and address of the person[s] to whom the statements[s] was [were] made, including but not limited to those relevant to: (a) the crime; (b) the investigation of that crime; and (c) any condition of ___________, including but not limited to his mental or physical state: (i) at the time of the alleged crime;
(ii) at the time of any statement, written or oral, made by the defendant to any person; (iii) as to what occurred at the time or times before or after the alleged crime or statements; (iv) as to the defendant's mental or physical state; (v) as to physical or mental injuries that occurred at the time of the alleged crime or statements; (vi) as to the conditions or circumstances of the commission of the alleged crime; and (vii) any other statement, written or oral, made or recorded by the defendant to any person before or after his arrest. 2. Any and all writings, written records, video or other recordings and other documents produced, created, kept or retained by the defendant that contain any evidence, information, opinion, conclusion or determination made by the defendant before or after his arrest: [in] (a) with respect to the crime of ; (i) with respect to the investigation of that crime; (ii) with respect to any condition of probation that may accompany the grant of the probation, pardon or executive clemency; [i] (iii) with respect to any conditions of probation or parole that may accompany the grant of the probation, pardon and executive clemency; and (iv) with respect to any condition of probation that is applicable to the defendant; and (b) that the prosecutor knows would not be material to any potential sentence, probation, parole or other condition of probation, parole or other disposition made by the court. 3. Any and all documents, notes, telephone, telegraph, television or cellular telephones records, photographs, video, sounds, sounds and images from, or concerning, any court, courtroom or courthouse, any state agency, and any agency of the United States, or any other person in possession of such records, notes, telephone, telegraph, televisions, photographs, video, sounds, sounds and images, whether maintained by the defendant, pertaining or relating to the trial. 4. Any other documents, information, opinions, conclusions or determinations made by the defendant and in his possession prior to his arrest. 5. Any documents, information, opinions or determinations made by the prosecutor before, during or immediately following the commencement of the trial, and relating to the guilt or innocence of the defendant or any other person who is charged, or who was charged, by the defendant, to commit or aid or abet the commission of a crime or.