12 Documents To Request When Preparing A Defense (Refusal)


1. All statements or utterances by our client, however recorded or preserved, whether or not signed by our client.

2.The names, addresses and phone numbers of all witnesses to be called to testify against our client at trial.

3.All statements or utterances of those testifying witnesses relating to the case, however recorded or preserved, whether or not signed or acknowledged by them.

4. The names, addresses and phone numbers of all persons who were percipient witnesses to the offense, including those who my have personal knowledge of any facts relevant to the case, whether or not they are to be called to testify against our client at trial.

5. All preserved statements of persons identified in item 4 above, who cannot fully recall the details of those statements.

6. All physical evidence obtained in the investigation of the case of the case against our client.

7. All notes or reports of investigation of the case made by police or other investigators, however recorded or preserved, whether oral or written, and whether or not signed or acknowledged by them.

8. All photographs or drawings shown or to be shown to witnesses or prospective witnesses in this case, if any, for the purpose of establishing any element of the corpus of this case.

9. All records of any felony convictions of any witness to be called to testify against our client, and of our client as well.

10. Anything that may have a tendency to exculpate our client, impeach any witness, or lessen punishment in the event of a conviction.

11. The names, addresses and phone numbers of all witnesses to be called to testify against the defendant at trial or preliminary hearing.

12. All existing notes, memoranda, and reports containing information relevant to the investigation of this case, whether handwritten or typed, including but not limited to:

a. Arrest, crime and accident reports, including accident reconstruction reports;

b. Medical and laboratory reports;

c. "Rough" notes made by any officers during the investigation of this case, sometimes referred to as "field notes," and if these notes have been destroyed, information concerning the time, place and manner of destruction and by whom destroyed;

d. Records of daily activity of officers at the station where the arresting officer herein was assigned at the time of arrest (sometimes referred to as "daily logs"), for a period of 7 of that officer's working days before and after the arrest and including the day of arrest, i.e., for a period of 15 of the officer's working days;

e. All sworn statements by officer involving violation of Vehicle Code Section 23152 or 23153 executed by investigation at the scene of arrest of Defendant, for a period of 7 of that officer's working days before and after the arrest and including the day of arrest, i.e., for a period of 15 of the officer's working days; it is agreed that the names and addresses of the arrestees may be deleted from the reports.