IN THE UNITED STATES DISTRICT COURT
UNITED STATES OF AMERICA )
:
)
v. : CASE NO ________
)
:
_________________ )
Comes the defendant __________________ by and through counsel, pursuant to Brady v. Maryland and its progeny and hereby request that the government provide the following exculpatory information:
(1) Whether the following individuals have been given polygraph examinations: _____________________________________________________.
(2) The names of all other individuals who have been given polygraph examination in relationship to the investigation of the fact which underlie the prosecution of the present case.
(3) Whether or not ___________________________ has received and failed a polygraph examination.
(4) Whether ___________________________has been administered and has failed a polygraph examination.
(5) Please provide copies of all polygraph interviews and test results for any and all such individuals previously enumerated in requests Nos. 1-4.
(6) Any and all information or evidence in the possession of the government which tends to shows that ______________________ knew nothing about the _______________________________alleged in Count ______ of the present indictment until _____________________________________________.
(7) Any and all evidence in the possession of the government that _____________________ traveled from ______________ to ______________, at the instigation of someone other than ___________________.
(8) Any evidence in the possession of the government which would tend to show that the conspiracies alleged in Counts __,____ and _____ of the present indictment were related to the conspiracy charged in superseding indictment ________in the ______________ District of ____________.
(9) Any evidence in the possession of the government that would tend to show that ______________________________________________________________
were participants in any of the conspiracies charged in the present indictment.
(10) Any evidence of any kind in the possession of the government anywhere in the United States that information derived from __________________ prior to ______________________________ has been communicated in any fashion to any individual who has been concerned with or engaged in the return of the indictment in the present case or with the subsequent prosecution of the present case.
(11) Any information of any kind in the possession of the government anywhere in the United States that the U.S. Attorney's office for the ____________ District of __________ was engaged in or consulted during the prosecution of __________________ in either state or federal proceedings against ________________ in the State of _____________.
Respectfully submitted,
______________________________
ATTORNEY FOR DEFENDANT.
CERTIFICATE OF SERVICE
UNITED STATES OF AMERICA )
:
)
v. : CASE NO. ________
)
:
_________________ )
Comes the defendant, ________________, by and through counsel, pursuant to Brady v. Maryland, and its progeny and request the government to provide the following exculpatory information:
Whether the sole eye-witness in the present case, Lindsey Ward ever stated that he could not see his assailant's face or ever stated that he could not identify his assailant. Lindsey v. King, 769 F.2d 1034 (5th Cir. 1985).
Respectfully submitted,
______________________________
ATTORNEY FOR DEFENDANT
CERTIFICATE OF SERVICE
UNITED STATES OF AMERICA )
:
)
v. : CASE NO _________
)
:
_______________ )
Comes the defendant, ________________, by and through counsel request the government to provide the following exculpatory information:
Any and all information or reports which reflect that the weapon allegedly used by the defendant in the present case was inoperable. U.S. v. Ex Rel Smith v. Fairman, 769 F.2d 386 (___ Cir. 1985).
Respectfully submitted,
______________________________
ATTORNEY FOR DEFENDANT
CERTIFICATE OF SERVICE