The prosecution relies on information from the prior investigation in these proceedings, including the affidavit to justify searches in this case. That material also contains, or is likely to lead to, exculpatory evidence. (see Motion to Compel Discovery, pg2 || pg3 of the .pdf file) ------------------------------------------------------------------------ The affidavit that has been used in support of the dozens of searches in this case refers to information developed during the prior investigation. The affidavit quotes material used to search Mr. Jackson’s ranch in the prior investigation and summarizes the district attorney’s explanation about how that investigation became inactive without criminal charges. (see Motion to Compel Discovery, pg5 || pg6 of .pdf file) -------------------------------------------------------------------------- Materials from the investigation of 1993-94 are within the purview of discovery in this case. The prosecution has already utilized information developed during that investigation and innuendo from the settlement of civil proceedings initiated by the complaintant in that matter. The prosecution relies on so-called information from the prior investigation to justify the scope of the November 2003 search of Mr. Jackson’s ranch. (see Motion to Compel Discovery) -------------------------------------------------------------------------- Mr. Jackson’s right to receive exculpatory information from the prosecution also requires production of materials from the prior investigation. Law enforcement unquestionably developed information rebutting allegations of misconduct from the many people who testified before the grand juries or submitted to informal interview. (see Motion to Compel Discovery, pg6) ---------------------------------------------------------------------------- The 1993 case was also referenced and presented to the grand jury in this case at length. Request is hearby made that your office produce all documents relating to the 1993 case, including but not limited to, all documents and items of evidence contained in the reference five boxes, the entire grand jury transcripts, and any and all documents referencing, directly or indirectly [redacted information]. (see Motion to Compel, pg 12 of pdf file)