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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.
For example, a party can make a motion to ask to allow him or her not to give the other side the discovery that was asked for. If a party thinks that a subpoena asks for documents that have nothing to do with the case, or asks for too much information, the party can make a motion to quash the subpoena.
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.
Be as persuasive as possible as you write your motion in a sequential, logical format. Express your ideas clearly, and make sure you outline what steps are necessary and how they will help your case. Use facts of the case whenever you can to avoid baseless emotional appeals.
General format - each motion generally consists of a case caption, a title that briefly identifies the relief sought, a series of numbered paragraphs that explains -- in a logical way -- why you are entitled to that relief, a prayer for relief, a signature block, a certification that a copy of the motion was sent to ...