Form 13: Request for Driving while Suspended Discovery

• Library: Criminal Law Forms (ABA) (2013 Ed.)

Form 13: Request for Driving While Suspended Discovery

KENNETH VERCAMMEN & ASSOCIATES, PC ATTORNEY AT LAW 2053 Woodbridge Ave. Edison, NJ 08817 (Phone) 732-572-0500 (Fax) 732-572-0030

website: www.njlaws.com

D

PROSECUTOR
c/o MUNICIPAL COURT

Court Administrator
MUNICIPAL COURT

RE: State v
D/O
Summons:
Offense: Driving While Suspended
Request for Complete Discovery
& Letter of Representation to Court

Dear Prosecutor and Court Administrator:

Kindly enter my appearance for said defendant and a plea of "NOT GUILTY". Under Rule 7:6-1b my client waives arraignment and certifies we have received a copy of the complaint, have read it and understand the substance of the charge.

Demand is made that the Prosecutor and the complainant provide us with discovery pursuant to Rule 3:13-3, Rule 7:7-7(b), the Open Public Records Act (OPRA), the Right to Know Law NJSA 47:1A-1 et seq. and the common law right to know under Shuttleworth v. City of Camden, 258 N.J. Super. 573 (App. Div. 1992). Since there is a DWS moving violation, you must provide us with a driver's license abstract. The Court Rules require the Prosecutor and Court to review the abstract.

Please forward to me all documents which you have in your possession or which are in the possession of any law enforcement agency or the complainant involved in this case.

In addition, each request is specifically sought under the rule of Brady v Maryland, 373 U.S. 83 (1963) and its...