REQUEST FOR DISCLOSURE AND DISCOVERY

COMES NOW the Defendant herein, pursuant to Supreme Court Rule 25.03 and 25.04, and requests that the State disclose to him the following:

1. The names of persons whom the State intends to call as witnesses at any hearing or at the trial, together with their written or recorded statements, and existing memoranda reporting or summarizing part or all of their oral statements.

2. The last known address of persons whom the State intends to call as witnesses at any hearing or at trial, including change of address information submitted to the postal service, as that information is accessible only to representatives of the government and law enforcement agencies.

3. Any written or recorded statements and the substance of any oral statements made by the Defendant or by a co-defendant, a list of all witnesses to the making, and a list of all witnesses to the acknowledgment of such statements, and the last known addresses of such witnesses.

4. Any reports, statements, or laboratory notes of experts, made in connection with the particular case, including results of physical or mental examinations and of scientific tests, experiments, or comparisons.

5. Any books, papers, documents, photographs, (including access to all the negatives) or objects, which the State intends to introduce into evidence at the hearing or trial, which were taken during the investigation or were obtained from or belong to the Defendant.

6. Any record of prior criminal convictions of persons the State intends to call as witness at a hearing or the trial. This request is to include interrogation of the Highway Patrol Computer, the National Crime Information Center, and the FBI Computer.

7. If there has been any photographic or electronic surveillance (including wiretapping), relating to the offense with which the Defendant is charged, of the Defendant or of conversations to which the Defendant was a party or of his premises, a summary and the identity of those making same.

8. Any material or information, within the possession or control of the State, which tends to negate the guilt of the Defendant as to the offense charged, mitigate the degree of the offense charged, or reduce the punishment.

9. All items set out in the foregoing paragraphs which are known to the State to be in the possession or control of other governmental personnel.

10. All items or information which could reasonably be expected to weaken or affect any evidence or testimony to be used against Defendant.

11. All items or information which in any manner could be expected to aid Defendant in ascertaining the truth as to any matter affecting this cause.

12. The statements of all persons who have been interviewed by an agent of the State in connection with the subject matter of this case and whom the State does not presently intend to call at trial.

13. The memoranda or summaries of any oral statement made to an agent of the State by any person in connection with the subject matter of this case whether or not:

a. The statement, if in writing, has been signed, or approved by the witness, and

b. The statement relates to the proposed subject matter of the direct testimony of the witness at trial.

14. The stenographic recording or transcription of any oral statement made by any person to an agent of the State in connection with the subject matter of the case, whether or not:

a. The stenographic recording or transcription is a substantially verbatim recital of the statement, and

b. The statement was recorded contemporaneously with its making, and

c. The statement relates to the proposed subject matter of the direct testimony of the witness at trial.

15. The statements of persons or memoranda or recordings of any oral statement pertinent to the subject matter of this case whether or not made to an agent of the State, including change of address information submitted to the postal service as requested in Paragraph 2.

16. Any memoranda, documents or statements used by the State during the investigation of this case.

17. The names and addresses of all persons who may have some knowledge of the facts of the present case.

18. A summary reflecting the criminal records of all persons the State intends to call at trial.

19. A summary reflecting the criminal records of the Defendant.

20. All reports and memoranda prepared on behalf of the State or otherwise used in connection with the investigation of this case.

21. All reports, memoranda and any other data in the hands of the State and its agents in regard to Defendant.

22. Whether any witness to any event alleged in the indictment, or surrounding the incidents as alleged in the indictment, made a statement which was not written or recorded and, if so, the substance of any such statement.

23. Notes, memorandum, written or recorded statements reporting or summarizing ex parte statements obtained from impeachment witnesses or defense alibi witnesses. State v. Culkin, 791 S.W.2d 803 (Mo.App.1990); Foote v. Hart, 728 S.W.2d 295 (Mo.App.1987).

24. Any and all factual details known to the State, as well as other details it will seek to introduce as to any “other crime” or act of misconduct allegedly committed by Defendant. If the evidence will be introduced by means of a documentary exhibit, identify each exhibit and provide a copy.

25. The name of any witness who will give testimony about any “other crime” or act of misconduct allegedly committed by Defendant and/or lay the foundation for the entry of any exhibit.

26. Disclose whether any such “other crime”, evidence or allegations of acts of misconduct is presently the subject of a pending charge or ongoing criminal investigation.

27. Identify the element of the crime for which each “other crime” is offered as proof, e.g., motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.

28. Any notification request forms or other documents that contain statements from the alleged victims concerning any aspect of the crime, including any claims of financial, emotional or physical impact caused by or attributable to the event.

29. Whether or not any books, papers, records or other materials of any evidentiary nature, including oral examination of witnesses, were secured by a subpoena pursuant to 56.085, and if so, a copy of all pleadings, requests or other documents filed with the Circuit Court requesting issuance of such subpoena.

30. A copy of any victim impact statement or statement made by alleged victim(s) to the prosecuting attorney or any other victim related agencies.

31. Any statements, notes, memoranda, summaries, internal memos, or other procedures relating to any interviews of alleged victims by the Victims Service Council.