Thank you for the good example. Below I have put down the things the defendant would want to know. There were more in the example. Do you think this is enough?
I wonder if the defendant should specifically request info about the specific toxicologist in question?
NOW COMES the Defendant, (Defendant's Name)., in the above-styled and numbered cause, and respectfully XXXXX XXXXX Court to order the State of Oklahoma to reveal and produce the following:
1.Any documents or records of any kind which, in any way, question or raise doubts about the accuracy or reliability of any scientific and/or expert testing.
2.Any evidence, documentary or otherwise, which might undermine or tend to undermine the credibility of any state witness.
3. All exculpatory evidence which the prosecuting attorneys and their agents may have in their files.
4.Any evidence of any kind which is in any way mitigating.
In the event that any of the above-requested evidence exists, the Defendant moves that the Court order the prosecuting attorney to produce the same for inspection by the defense at the earliest possible time the existence of such evidence becomes known to the State.
Defendant would show the Court that the failure to produce the above requested evidence would result in the suppression of evidence and a violation of the United States Constitution, Amendments V, VI and XIV. See Kyles v. Whitley, 514 U.S. 419,XXXXX 1555, 131 L. Ed. 2d 490 (1995); Brady v. Maryland, 373 U.S. 83,XXXXX ll94, l0 L.Ed.2d 2l5 (l963); Ashley v. Texas, 3l9 F.2d 80 (5th Cir. l963).
WHEREFORE, the Defendant respectfully XXXXX XXXXX the Court grant this Motion in all things.