Free Motion for Discovery - District Court of Delaware - Delaware

Case 1:05-cr-00036-JJF

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Filed 05/19/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. ROBERT COOKE, Defendant. : : : Cr.A.No. 05-cr-0036 : : REQUEST FOR DISCOVERY NOW COMES the Defendant, Robert Cooke, by and through his attorney and pursuant to Criminal Rule 16 requests the

Prosecution to produce the following: 1. Any relevant written or recorded statements made by

the Defendant or a co-defendant, or copies thereof, within the possession, existence diligence Government; of may the custody which or is control known known, of or to any of by the the Government, exercise of for which the due the the

become

the oral

attorney statement

substance

Government intends to offer in evidence a the trial made by the Defendant whether before or after arrest in response to interrogation by any person then known to the Defendant or codefendant to be a Government agent; and recorded tesitmony of the Defendant before a Grand Jury which relates to the offense charged. 2. 3. Prior criminal record of the Defendant, if any. Photographs, books, papers, documents, tangible

objects, buildings or places, or copies or portions thereof,

Case 1:05-cr-00036-JJF

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which are within the possession, custody or control of the Government, and which are material to the preparation of the defense or intended for use by the Government as evidence in the trial, or were obtained from or belonged to the Defendant. 4. Any results or reports of physical or mental

examinations, and of scientific test or experiments, or copies thereof, which are within the possession, custody, or control of the Government, the existence of which is known, or by the exercise of due diligence may become known, to the attorney for the Government, and which are material to the preparation of the defense or are intended for use by the Government as evidence at trial. LAW OFFICE OF EDWARD C. GILL, P.A.

DATED: 5-19-05

_S/Edward C. Gill_____ Edward C. Gill, Esquire Attorney for Defendant Bar I.D. 2112 P.O. Box 824 Georgetown, DE 19947 (302) 854-5400 [email protected]

Case 1:05-cr-00036-JJF

Document 23-2

Filed 05/19/2005

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