Fill and Sign the Petitionerplaintiff Form

- 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) in connection with having or allegedly having committed that crime; (iii) in connection with any claim or defense in this case: (b) statements made to government officials, either before or after the defendant had been arrested, regarding, at any time, the alleged crime of which he was charged in this case, including but not limited to any of the following: (i) his alleged confession; (ii) the facts of, or the circumstances of, the alleged crime; (iii) any information contained in, if the defendant has chosen to make the statements, written or oral, in, if the prosecutor has chosen to make the statements; (iv) his claim to have a legal right not to incriminate himself; and (v) whether he ever exercised that right; (c) all documents, writings or other materials, relating to, which the defendant knows relate to the alleged crime, in the possession of any person and on which he has any interest. 2. All records, including those which the defendant knows or should now relate to, the investigation of, [ or , ] this case, and any documents, writings or other materials, relating to any matter within the court's jurisdiction, the status of, and the prosecution of this case, or the conduct of any prosecution conducted in relation to his case, including but not limited to any of the following: (a) records relating to the defendant's statements to a detective or an informant or concerning any of the above; (b) transcripts or recordings made of statements to a detective or an informant or concerning any of the above; and (c) documents or other materials relating [and including any evidence, information or other matter of which] the defense is attempting to obtain by or against the state. 3. All documents, writings or other materials, relating to the proceedings relating to this case; and the contents of all affidavits, or other written information used in support of any defense, including but not limited to any statements of, or information provided by, witnesses in this case, and any information, including statements or information, relating to the existence of any purported or actual physical evidence. (ii) the defendant knows or should know, that: (a) he is under arrest; (b) an agent of the court or law enforcement officers has arrested him; or (c) his bail is posted, and he is confined in jail or prison. 4. At any time after the filing of any defense in or before this court.