Form 15: Request for Discovery to Dmv/mvc

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

Form 15: Request for Discovery to DMV/MVC

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

Motor Vehicle Commission
Hearing Unit
PO Box 166
Trenton, NJ 08666-0166

RE: MVC v
DL
Opposition to Suspension AND REQUEST FOR ALJ
HEARING
Dear Division of Motor Vehicles:

Please be advised that I represent the defendant/driver in the above-entitled matter. Kindly enter my appearance for said defendant and formal objection to DL Suspension. We request a hearing on any proposed suspension or other action. PLEASE SCHEDULE THE HEARING FOR EATONTOWN/FREEHOLD AREA .

Demand is made that the Motor Vehicle Commission provide us with discovery pursuant to the New Jersey Administrative Code, NJAC 1:1-1 et seq. and NJAC 1:13-10 and the Open Public Records Act/ Right to Know Law NJSA 47: 1A-1 et seq. Please forward to me all documents which you have in your possession or which are in the possession of any law enforcement agency involved in this case. We demand copies of every letter and notices send to my client.

In addition, each request is specifically sought under NJAC 1:13-10, the Open Public Records Act (OPRA), Brady v Maryland, 373 U.S. 83 (1963) and its progeny, and State v Polasky 216 N.J. Super. 549 (Law Div. 1986). Unless all requested discovery is received, the defense will make a motion to dismiss all charges and will object...