Status report Re: Discovery Excerpt: ___________________________________________________________ The prosecution replied that: [b](1) all of the handwritten notes of officers and investigators were destroyed;[/b] (2) the prosecution’s work product will not be produced (the defense does not seek district attorneys’ work product); and (3) under the law, the defense is not entitled to reports generated by “social” agencies, such as the Department of Child and Family Services (“DCFS”) in Los Angeles and the Child Protective Services (“CPS”) in Santa Barbara, that it did not have an obligation to seek and obtain such documents from these agencies, and that thereby the prosecution will not produce them. The defense pointed out that chronologies prepared by those other than the district attorneys were important because the dates regarding the alleged molestation in the original complaint were different from those in the Indictment. The dates are different because the Doe family apparently provided different dates in their interviews before the criminal complaint was filed and then changed the dates for the grand jury proceedings. The chronologies are crucial to the defense because they will reveal not only the inconsistent dates of the alleged molestation, but also of the inconsistent facts and dates regarding other alleged acts in the Indictment. The defense requests that the prosecution produce all such chronologies (handwritten and typed). pg 3 Download here: :nav Status Report Re: Discovery

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