Appendix E -2 Defendant's Motion Concerning Furnishing Information About Dna Evidence

• Library: How to Try a Murder Case: Pretrial and Trial Guidelines for Prosecution and Defense (ABA) (2011 Ed.)

APPENDIX E-2 Defendant's Motion Concerning Furnishing Information About DNA Evidence

Now comes [Defendant], by and through undersigned counsel, pursuant to Courts and Judicial Proceedings Section 10-915, Maryland Rule 4-263, and Brady v. Maryland, 919 U.S. 83 (1963), and request that the State of Maryland provide the following information relating to the DNA test results the State is seeking to admit in this case.

1. Case File: Please preserve and provide a legible copy of the complete case file including all records of DNA testing, serology, and CODIS or other DNA database runs in the instant case. For materials that are represented in any format other than black and white paper copies please provide copies that are equivalent in content and quality (that is, X-ray film copies of X-ray files, photographic quality copies of photographs and Polaroids, CD-ROMs or ZIP disc copies of computerized data, and copies of GeneScan printouts, including tabular data and copies of Genotyper printouts.)
2. Documents Relied upon in Performing Testing: Please preserve and provide legible copies of all documents that were, or are claimed to have been, followed or relied upon in executing, interpreting, and/or reporting the DNA tests performed in the instant case, including:

(a) Standard operating protocols (SOPS) of the DNA testing laboratory
(b) Quality assurance/quality control manuals

(c) Instructions provided by manufacturers of commercial test kits ("package inserts" and "user guides")
(d) Protocols and manuals relating to instruments (including user's manual and machine run specifications) and/ or software

3. STR Database: Please preserve and

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