IN THE STATE COURT OF FULTON COUNTY STATE OF GEORGIA

STATE OF GEORGIA
) ) v. ) ) ) ) ) _____________________________________ ) Accusation No.: _____________________

DISCOVERY DEMAND
COMES NOW, Defendant in the above-styled action and files this Demand, showing as
follows: 1. Pursuant to O.C.G.A. 17-16-3 and 17-16-8, Defendant demands that the State furnish a copy of the indictment or accusation and an accurate witness list reflecting the names, residential addresses, current locations, dates of birth, social security numbers, and telephone numbers of all witnesses the State will call to testify at trial. 2. Pursuant to O.C.G.A. 17-6-4(a)(2), Defendant demands that the State disclose and make available for copying any and all statements made by the Defendant, and any statement made by any co-conspirator. 3. Pursuant to O.C.G.A. 17-16-4(a)(2), Defendant demands that the State furnish a copy of the Defendants criminal history. 4. Pursuant to O.C.G.A. 17-16-4(a)(3), Defendant demands that the State permit the Defendant to inspect and copy all books, papers, documents, photographs, tangible objects, audio and videotapes, films and recordings, and to inspect and photograph any buildings or places relevant to the prosecution.

5. Pursuant to O.C.G.A. 17-16-4(a)(4), Defendant demands that the State make available for inspection and copying any and all reports of physical or mental examinations and any and all scientific test results, including a summary of the basis for any expert opinion rendered in any such report. 6. Pursuant to O.C.G.A. 17-16-7, Defendant demands that the State furnish all statements of all witnesses and potential witnesses that are within the possession, custody or control of the State. 7. Pursuant to Brady v. Maryland, 373 U.S. 83 (1963), Hicks v. State, 250 Ga. 393 (1974) and the Uniform Superior Court Rules, Defendant demands that the State furnish any and all information which is arguably exculpatory; any information tending to discredit any States witness; a description of any consideration or promise of consideration given by the State to any witness, suspect, co defendant or informant; or any evidence which could reasonably lead to the discovery of any of the foregoing types of information.

WHEREFORE, Defendant prays that the Court order the State to comply with the
foregoing demands. This ______ day of ______________________________, 20______.

______________________________________ Attorney for Defendant State Bar No. _____________________

FULTON COUNTY CONFLICT DEFENDER

State Court Division 185 Central Avenue, SW Suite T-1607 Atlanta, GA 30303

CERTIFICATE OF SERVICE
I certify that I have this day served opposing counsel with a copy of the foregoing pleading, by United States Mail addressed as follows: Mr. Robert Dixon Assistant Solicitor General State Court of Fulton County Justice Center Tower, Suite J301 160 Pryor Street, SW Atlanta, GA 30303 Or, in the alternative, by hand delivery. This ______ day of ______________________________, 20______.

______________________________________ Attorney for Defendant State Bar No. _____________________

FULTON COUNTY CONFLICT DEFENDER

State Court Division 185 Central Avenue, SW Suite T-1607 Atlanta, GA 30303