MOTION FOR PRE-TRIAL PRODUCTION OF JENCKS ACT MATERIAL

The Defendant, *, by and through the undersigned attorney, hereby moves this Honorable Court to order the government to produce for use by the defense all Jencks Act material before trial within a reasonable time to allow for fair investigation as well as cross examination and confrontation at trial. As grounds, the Defendant states:

1. That trial is now scheduled for December 1, 1995, and the defense has not yet received any Jencks material.

2. No question exists as to the right to such material at trial under 18 U.S.C. §3500. Pre-trial production is the common practice within this district and is exercised within the trial court's discretion when the prosecution refuses to provide early discovery.

WHEREFORE, the Defendant requests this Court order the government to provide all Jencks Act material to the defense at this time.

DATED this day of October, 1995.

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