Arraignment Order And Standard Discovery Requests (Page 4 of 6) in pdf

__________D. Furnish the defendant with a copy of the defendant’s prior criminal record that is

within the government’s possession, custody, or control if the attorney for the government knows--or

through due diligence could know--that the record exists. [F.R.Crim.P. 16(a)(1)(D)].

__________E. Permit the defendant to inspect and to copy or photograph books, papers, documents,

data, photographs, tangible objects, buildings or places, or copies or portions of any of these items,

if the item is within the government’s possession, custody, or control, and (i) the item is material to

preparing the defense; (ii) the government intends to use the item in its case in chief at trial; or (iii)

the item was obtained from or belongs to the defendant. [F.R.Crim.P. 16(a)(1)(E)].

__________F. Permit the defendant to inspect and to copy or photograph the results or reports of

any physical or mental examination and of any scientific test or experiment if (i) the item is within

the government’s possession, custody or control; (ii) the attorney for the government knows--or

through due diligence could know--that the item exists; and (iii) the item is material to preparing the

defense or the government intends to use the item in its case-in-chief at trial. [F.R.Crim.P.

16(a)(1)(F)].

__________G. Give to the defendant a written summary of any testimony that the government

intends to use under Rules 702, 703, or 705 of the Federal Rules of Evidence during its case-in-chief

at trial. If the government requests discovery under Federal Rules of Criminal Procedure

16(b)(1)(C)(ii) and the defendant complies, the government must, at the defendant’s request, give

to the defendant a written summary of testimony that the government intends to use under Rules 702,

703, or 705 of the Federal Rules of Evidence as evidence at trial on the issue of the defendant’s

mental condition. The summary provided must describe the witness’s opinions, the bases and

reasons for those opinions, and the witness’s qualifications. [F.R.Crim.P. 16(a)(1)(G)].

__________H. Disclose to defendant all evidence favorable to defendant, including impeachment

evidence, and allow defendant to inspect, copy or photograph such evidence.

__________I. Notify defendant of all evidence the government intends to introduce pursuant to Rule

404(b) of the Federal Rules of Evidence.

__________J. Disclose to defendant all reports of government “mail cover”, insofar as the same

affects the government’s case against the defendant or any alleged aiders and abettors or co-

conspirators.

__________K. Disclose to defendant any matter as to which the government will seek judicial

notice.

__________L. Disclose to defendant and make available for inspection, copying or photographing,

the results of any interception of a wire, oral or electronic communication in the possession, custody

or control of the government, the existence of which is known, or by the exercise of due diligence

could become known, to the attorney for the government, which contains any relevant statement

made by the defendant or which is material to the preparation of the defendant’s defense or which

is intended for use by the government as evidence in its case-in-chief at the trial. For each such

interception, disclose (a) any application for an order authorizing the interception of a wire or oral

Arraignment Order And Standard Discovery Requests Page 4