Free Motion for Discovery - District Court of Delaware - Delaware

Case1:O4-mj-00100-MPT D0cument9 Filed O3/O1/2005 Page10f3
IN THE UNITED STATES DISTRICT COURT 4%@`/ `*”€H%
FOR THE DISTRICT OF DELAWARE €?J_%&
UNITED STATES OF AMERICA, :
Plaintiff, :
v. : Cr.A.No. O4—IOO—M
LARRY PACKARD, :
Defendant. :
REQUEST FOR DISCOVERY
NOW COMES the Defendant, Larry Packard, by and through
his attorney‘ and. pursuant to Criminal Rule I6 requests the
Prosecution to produce the following:
I. Any relevant written or recorded statements made by
the Defendant or a co—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 which the
Government intends to offer in evidence a the trial made by
the Defendant whether before or after arrest in response to
interrogation by any person then known to the Defendant or co-
defendant to be a Government agent; and recorded tesitmony of
the Defendant before a Grand Jury which relates to the offense
charged.
2. Prior criminal record of the Defendant, if any.
3. Photographs, books, papers, documents, tangible
objects, buildings or places, or copies or portions thereof,

_ Case 1:04-mj-00100-MPT D0cument9 Filed O3/O1/2005 Page20f3
which are within. the possession, custody or control of the
Government, and which are material to the preparation of the
defense or intended for use by the Government as evidence in
the trial, or were obtained from or belonged to the Defendant.
4. Any results or reports of physical or mental
examinations, and of scientific test 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 at trial.
LAW OFFICE OF
EDWARD C. GILL, P.A.
{H &HW»w#””"#

Attorney for Defendant
P.O. Box 824
bvgv g M y g\¥?»” Georgetown, DE 19947
DATED: (302) 854 5400
}) } } 3 ) ) ) )

_ Case 1:04-mj-00100-MPT Document 9 Filed 03/01/2005 Page 3 of 3
AFFIDAVIT OF MAILING
STATE OF DELAWARE :
COUNTY OF New Castle ;
EE TT REMEMBERED that on this 28th day of February,
2005, personally appeared before me, the Subscriber, a
Notary Public for the State and County aforesaid, Judy
Maddox, Secretary, and being duly sworn according to law
deposes and says that she forwarded Request for Discovery
To; Captain Rivera—Miranda
436 Aw/JA 200 Eagle Way
Dover Air Force Base
Dover, Delaware 19902
by United States Mail with postage prepaid.
’ y `
ig?
SWORN TO and SUESCRIBED before me the 28th day of
February, 2005.
,i’”`N$,ary ‘ublic
J Y Jennifer K. G. Don
No1aryPr¤1c
Stare of Delaware _
Commission Expires 12/ 1/06