IN THE CRIMINAL COURT OF HAMILTON COUNTY, TENNESSEE STATE OF TENNESSEE No. 295881 BENJAMIN BREWER, Defendant, 1} Divisionsitt MOTION FOR SPECIFIC DISCOVERY \ Wal gy gas aut yoy: 20 aonih goisap wi 0314 3 o> Comes now the defendant, through counsel, and respectfully requests that the District Attomey General for the State of Tennessee provide certain information w contends is material to the preparation of his defense. For the purposes of this request, the defendant defines the Le the defendant tate of Tennessee” to include the District Atiorney General. the ‘municipal police department, the county sheriff, the Tennessee Highway Patrol, the Tennessee Bureau of Investigation, any agents or empl officer, and any other person acting in conjunction fees of those offices, construc iny other law enforcement th, or in behalf of, any law enforcement agency. The defendant defines the requests to include items currently within the actual or ive possession, custody, control or knowledge of the State of Tennessee, and items which may become known, identified or available through the exercise of due diligence by the State of Tennessee. The defendant hereby requests: 1) The follow Jocuments and things conceming the testing of the blood sample of Benjamin Brewer. TBI Lab Case No. 151012003: A) sample and test. Copies ofall correspondence and communications, in whatever form, between the TBI and the Hamilton County District Atorney’s Office concerning this particular blood B) Emails, letters, phone call logs, or any other document or thing concerning TBI notifying the Hamilton County District Attorney's Office of the contamination in this particular case. ©) cent or employee of the TBI, or the Hamilton County District Attomey’s Office, concerning what should be done about the contamination in this particular case. Emails, letters. phone call logs, memoranda, or any other document or thing concerning any discussion by any D) All. chromatograms from the batch run All documents concerning contaminated ammonium hydroxide for the years 2015-2016. This request includes, without limitation: SA) Internal emails, memoranda, or any other communications concerning when the contamination was discovered: B) ° E) Fy) 9 Internal emails, memoranda. or any other communications concerning the discussion of effects ofthis contamination on the efficacy of the testing process: Internal emails, memoranda, or any other communications conceming what remedial measures were considered or put into place: Emails, leters, phone call logs. or any other document or this or attempting (o notify any state prosecutors. any federal ages Attorney's Conference of the contamination: ‘oncerning TBI notifying cor the State District Listings of other samples that were contaminated. All invoices, bills of lading, etc of the purchase of ammonium hydroxide for the years 2015-2016. ‘TBI crime lab budget for years 2015 and 2016, and specifically for the ammonium hydroxide or solvents A copy of the TBI quality assurance protocol Respectfully submitted, Jay Underwood Assistant Public Defender 720 Cherry Sireet Chatianooga, TN 37402 Phone: (423) 209-6771 Fax: (423) 209-6722CERTIFICATE OF SERVICE 1 cenify that a true copy of the foregoing was served on the District Attomey’s Office via hand delivery on this the 6th day of September, 2018. lay Underwood