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Write out each fact you wish the other party to admit is true. When writing these facts, be as clear and concise as possible. Each request must be for a single fact; do not include multiple facts, compound questions, or subparts.
Provide a brief synopsis (two or three sentences) of the crux of the motion that you are bringing before the court. 2. Give a good explanation of the facts of the case. The relevant scope of your discovery depends on these facts.
For example, a party may file a motion asking the court to: Order another party or person to: ... Quash a subpoena that improperly seeks documents or testimony. Order the parties to maintain the confidentiality of commercially sensitive, trade secret, proprietary, or personal information.
Some examples that your lawyer may request as part of their motion for discovery are: Photos or videos of the crime scene. Witness statements. Police reports or notes.
Some times prosecutors withhold evidence because it is harmful to their case or they don't feel it is relevant. When the defendant or the defense attorney learns of the withheld evidence, the defense attorney can file a Motion to Compel Discovery listing items believed to be unlawfully withheld by the prosecutor.