Criminal Discovery Checklist

SUPERIOR COURT OF THE STATE OF EXECUTION

COUNTY OF WAYNE

________________________________

) Case No.: 239,000

People, )

) DEFENDANT’S MOTION

) FOR PRETRIAL DISCOVERY

v. )

Willie Melson, )

Defendant. )

________________________________ )

Defendant, by and through his attorneys hereby moves, pursuant to the applicable Rules of Criminal Procedure, that this court issue its order directing the People to make available to defendant’s attorney for inspection, viewing, examination and copying, all of the items listed hereunder; the items shall include all of the listed materials presently in the possession or under the control of the People, in addition to items (described herein) that may at any time hereafter come into the People’s possession, between now and the final disposition of this case:

 1. The names and addresses of all persons that the prosecutor intends to call as witnesses at trial.

 2. All statements of the defendant herein, including but not limited to: statements made by the defendant regarding this case, whether oral, written, recorded, videotaped, or audiotaped, together with all transcriptions of such recorded statements.

 3. All statements made, shown, read, or played to the defendant during any conversation, regarding this case, in which the defendant participated or was present.

 4. All relevant real evidence seized or obtained as part of the investigation of the offense(s) charged; this includes all forms of electronic and digital evidence retrieved from any source, including but not limited to: computer hard drives, floppy drives, thumb drives, flash drives, cellular telephones, portable electronic devices, iPads, the Internet, Internet servers or storage entities, including social networking sites.

 5. The existence of every felony conviction of any material witness whose credibility is likely to be critical to the outcome of the trial.

 6. Any and all exculpatory evidence.

 7. Relevant written or recorded statements of witnesses and reports of witnesses whom the prosecutor intends to call, and any reports of the statements of experts made in this case, including the results of physical or mental experiments, or comparisons with the evidence at trial.

 8. Any photographs taken or sketches made of the defendant, and any portion of the defendant’s body, which were shown, or will be shown, to any potential witness in this case.

 9. All photographic “line-ups,” if any, shown to any person...