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opie bles UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE UNITED STATES OF AMERICA MOTION FOR DISCOVERY v. 1:07-cr-189-GZS DANIEL RILEY, Et al, COMES NOW, making a special appearance, Daniel Riley, acting in a sovereign capacity, Sui Juris, not Pro Se repeat not Pro Se representing the fiction DANIEL RILEY, and files this notice of appeal. In no way can this notice be construed to grant jurisdiction over the defendant, because the defendant's counsel still contends no jurisdiction exist. In no way should this notice be construed to be considered a.contract, aand all rights are reserved at the common law UCC 1-308 and 1-103.6 without prejudice. 1. The defendant makes this motion in accordance to F.R.Cr.P. rule 16. 2. The defendant request the following discovery in accordance with precedence set by the following cases; Giglio v United States (2006)164 LED2D 102, U.S. v, Rosario (1939)84 LED 507, 308 US 606, Brady v Maryland (1963) 10 LED2D 215, 373 US 83, Kyles v. Whitley, 115 S.Ct. 1555 (1955), Rovario v. U.S., 353 U.S. 53 (1957) and the Jenks Act. 3. The defendant requests again all hand written ruff notes by all government agents at mectings with the defendant held on 9/19/07, 9/20/07 and 9/24/07 and any recordings be it audio or video of any of those meetings. 4. The defendant requests again all hand written ruff notes taken by any government agent in any meetings with the other three defendants in this case and any recordings be it audio or video of any of those meetings. Requests any statements made by un-indicted co-conspirators and any ruff written notes by government agents concerning interviews with a any un-indicted co-conspirators. 5. The defendant requests the picture mentioned by the government in the original indictment on page 7, 10{(p) in the manner “RILEY and co-conspirator A possess rifles.” This picture is needed to be inspected or photo copied. This picture is necessary in preparing a defense and could of possible belonged to the defendant. This picture is also exculpatory in nature and is required to be turned over by the precedents mentioned above. If the government does not have or assent to this discovery then please notify the defendant in a reasonable timely manner. 6. Ifthe picture in question does not exist please state this for the record. If ‘the picture is not tuned over the defendant reserves the right to declare it does not exist. 7. ‘The defendant has a right to see all evidence produced in a case whether or not it is going to be used at trial as tong as itis relevant(see rule 16(e)). This picture has become very relevant if not produced because it affirms the defendants allegations that the prosecution is vindictive and lied to the grand jury, thus the non-existence of this picture has become exculpatory in nature. The defendant has a right to examine relevant evidence and the prosecution has a duty to produce evidence. “Constitutional dimensions of accused's rights to production of all evidence at criminal trial are expressed in Sixth Amendment explicitly conferring upon every defendant right to be confronted with witnesses against him and to have compulsory process for obtaining witnesses in his favor; its manifest duty of courts to vindicate those guarantees and to accomplish essential requirement that all relevant and admissible evidence be produced.” See United States v Nixon, (1974) 418 US 683, 41 L Ed 2d 1039, The defendant has a right to cross exam the evidence presented against him. The picture that the defendant contends does not exist, caused prejudice in the grand jury and if is proven to be non- existent is exculpatory in nature to prove a continuing pattern of prosecutorial misconduct. The defendant intends to use the prosecutions vindictive nature towards him as part of his defense. 8. __ If the defendant is deprived the facts concerning this picture he is being denied his right to prepare a proper defense. Part of that defense is that he is being prosecuted by an unlawful, reckless, ruthless, wanton, lying, cheating, conspiratorial, vindictive, lawless, coercive, overbearing, government who will do anything, inchuding illegal acts to convict this patriot. 9. The defendant requests; any ruff hand written notes, training records, disciplinary records, interviews with neighbors on Center of Town Rd., reports required to be made in the course of duty from any of the government agents in and around the Browns property on especially on June, 6 & 7, 2007. These include but not limited to U.S. Marshals Ed Recor, David Dallaire, Joe Buchanan, Michael Allen, Jeff Mertes, Jamie Barry, Stephan Monier and all other government agents. Requests any spent shell casings from any rounds that were discharged that day for expert analysis, including the (2) .223 cal. shell casings that were shot from an M-4 rifle. Requests the weapons assignment reports i.e, that designate each type of weapon w/serial no. assigned to each (SOG) sniper, the amount and type of each round given out, the amount of rounds turned back in after operations were complete, etc.. of those that were stationed in and around the Browns on June 6 & 7, 2007. 10. The defendant requests any ruff hand written notes, training records, disciplinary records, reports required to be made in the course of duty from any of the government agents in and around the Browns property on July 28 & 29, 2007. These include but not limited to U.S. Marshals Ed Recot, David Dallaire, Joe Buchanan, Michael Allen, Jeff Mertes, Jamie Barry, Stephan Monier and all other government agents involved in any manner to the operations carried out on those two days. u ‘The defendant requests the names of all persons in the Department of Homeland Security helicopter that flew above the Browns property in Plainfield, New Hampshire for nine hours on July 14, 2007 from approximately 12:30 p.m. until 9:30 pam, 12, The defendant request the flight log, any ruff hand written notes by any government agent concerning this helicopter, any radio traffic that was recorded, any reports made in the normal course of business concerning this helicopter flight on July 14, 2007. 13, The defendant requests the year, make, model, any modifications, ‘weapons on board (physically attached to helicopter or on a persons inside the helicopter), name and type of any recording devices attached to the helicopter with their specifications, maintenance records, a designation list of the helicopter’s required use and any other relevant information concerning this helicopter. 14, The pilot’s name of the helicopter flown on July 14, 2007 over the Browns property, his training and experience background if any, any written statements made by the pilot or any reports made by the pilot concerning his flight on July 14, 2007. Details. of any weapons the pilot might have been carrying and the training for such weapon(s). Any and all video, pictures, audio (inside and out) that the helicopter might of produced ‘that day. 15. The defendant requests discovery of all police reports made in the normal course of business including that of any law enforcement agencies that worked in collusion with the federal government to apprehend the Browns and any ruff hand written notes made by any of these agencies or their employees or officers. The defendant request documentation of any agreements between the federal government and any local or state police to apprehend the browns. 16. The defendant requests documentation of any payments made by the federal government to any local or state agencies in the normal course of business to help apprehend the Browns. 17, This motion is considered to be in full force and effect in an ongoing nature to compel discovery of those items listed as well as previously submitted motions for discovery. The defendant reminds the government it has an obligation to tum over any exculpatory or impeaching evidence to the defendant. 18, The defendant requests discovery of the video taken by the camera mounted at the intersection of the Brown’s driveway and Center of town Road sometime between early May 2007 until late June 2007. The defendant has received a copy of the logbook, in which notes were taken by various Marshals as they reviewed what the

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