IN THE CIRCUIT COURT OF
STATE OF MISSOURI )
vs. ) CASE NO.
MOTION FOR DISCLOSURE TO DEFENDANT
COMES NOW defendant, _______________ Pro Se, pursuant to V.A.M.R.
Criminal Rule 25.03 hereby requests the following information from the
1. The names and last known address of person whom the state intends to call as witnesses at any hearing or at trial, together with
their written or recorded statements, and existing memoranda reporting
or Summarizing part or all of their oral Statements.
2. Any written or recorded statements and the substance of any
oral statements made by the defendant, a list of all witnesses to the
making, and a list of all witnesses to the acknowledgement of such statements, and the last known addresses of such witnesses.
3. Those portions of existing transcripts of (preliminary hearing) which relate to the offence with which the defendant is charged, containing testimony of the defendant and testimony of persons whom the state intends to call as witnesses at a hearing or trial.
4. Any reports or statements of experts, made in connection
with this case, including results of physical or mental examinations and
of scientific tests, experiments or comparisons. This to include maintenance schedules for all equipment used and the tolerances, margin of error and training needed to operate said equipment.
5. Any books, papers, documents, photographs, or objects which
the state intends to introduce into evidence at the hearing or trial or which were obtained from the defendant.
6. Any record of prior criminal convictions of persons whom the state intends to call as witnesses at a hearing trial. Defendant requests that this information be obtained by the state through record
checks of the F.B.I., National Crime Information Center, and Missouri State Highway Patrol computers. Please include all traffic tickets.
7. Any material or information, within the possession or control of the state, which tends to negate the guilt of the defendant as to the offense charged, mitigate the degree of the offence charged, or reduce the punishment .
8. If there have been any photographs or electronic surveillance, relating to the offense with which the defendant is charged, of the defendant or of conversation to which the defendant was a party or of his promises, this disclosure shall be in the form of written statement by conceal for the state briefly setting forth the facts pertaining to the time, place, and persons making the same.
9. The defendant requests that the prosecuting attorneys use
diligence and make a good faith effort to obtain any of the above items
or information which may be in the possession or control of any other government personnel, under the authority of rule 25.03 (c).
10. The defendant requests that the duty to disclose be made a continuing duty and that the prosecution furnish to the defendant such additional information as may come to its attention or within its possession or control here after including during trial under V.A.M.R.
Criminal Rule 25.08.
, Pro Se
Springfield, Mo. 65806
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