NOTE: You must insert your own caption here before submitting this form to the court.
MOTION TO COMPEL DISCOVERY Joseph R Doe, by his attorney Jake L Attorneymannie, moves to compel the production of the below-requested discovery materials and represents: 1) Petitioner, the defendant in the above-captioned case, was arrested on January 12, 2008 and charged with {insert charges against petitioner here} arising from an incident alleged to have occurred on January 4, 2008. 2) This Motion is filed pursuant to {State rule in support of motion here}, and the Due Process Clauses of the United States and Ohio Constitutions. 3) The District Attorney's Office has provided limited discovery to date, to wit, ___________________________. 4) Undersigned counsel has submitted two (02) informal discovery requests to the State (see attached letters). To date, no reply has been received to any of these requests. 5) The information requested in these two (02) letters is critical to the presentation of petitioner's defense. It should be disclosed in the interests of justice and may be favorable and/or exculpatory in nature. 6) In addition to those documents and materials requested in the two (02) appended letters, petitioner specifically requests this Court to compel disclosure of the following items: a) {insert the names of the identifying documents you are requesting the court to compel disclosure of here}; 7) The requested information is critical for the following reasons: a) { insert reasons here }; WHEREFORE, for the reasons contained herein, petitioner, by his counsel, respectfully requests this Court to grant the instant Motion and compel disclosure of the requested discovery.
Respectfully submitted,
Jake L Attorneymannie
Attorney #88777445 DEWEY CHEATEM AND HOWE 7788 Bar Avenue Anycity, Ohio 44777 Counsel for Defendant