REQUEST FOR DISCOVERY AND INSPECTION

The Defendant, through the undersigned counsel and pursuant to Fed.R.Crim.P. 16, hereby requests the United States to permit counsel for defendant to inspect and copy or photograph the following items:

1. Pursuant to Fed.R.Crim.P. 16(a)(1)(A), any relevant written or recorded statements made by defendant or copies thereof, within the possession, custody or control of the government, the existence of which is known, or by the exercise of due diligence may become known, to the attorney for the government; the substance of any oral statement made by defendant which the government intends to offer in evidence at the trial, whether before or after arrest in response to interrogation by any person then known to the defendant to be a government agent; and recorded testimony of the defendant before a grand jury which relates to the offense charged.

2. Pursuant to Fed.R.Crim.P. 16(a)(1)(B), a copy of prior criminal record of the defendant, if any, as is within the possession, custody or control of the government, the existence of which is known, or by the exercise of due diligence may become known, to the attorney for the government.

3. Pursuant to Fed.R.Crim.P. 16(a)(1)(C), books, papers, documents, photographs, tangible objects, buildings or places, or copies or portions thereof, which are within the possession, custody, or control of the government, and which are material to the preparation of the defense, or are intended for use by the government as evidence in chief at the trial, or were obtained from or belong to the Defendant.

4. Pursuant to Fed.R.Crim.P. 16(a)(1)(D), the results or reports of physical or mental examinations, and of scientific tests or experiments, or copies thereof, which are within the possession, custody, or control of the government, the existence of which is known, or by the exercise of due diligence may become known, to the attorney for the government, and which are material to the preparation of the defense or are intended for use by the government as evidence in chief at the trial.

WHEREFORE the Defendant moves for an Order directing the Government to furnish the discovery and notices as above described.

DATED this day of October, 1995.

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