Law Offices of Scott Zonder

1 SUITE 200, TRANSAMERICA BUILDING

177 NORTH CHURCH AVENUE
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TUCSON, ARIZONA 85701
3 TEL.(520) 302-0416

4 State Bar No. 032609

Pima County Bar No. 66863
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Attorney for Defendant
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IN THE CONSOLIDATED JUSTICE COURTS,
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COUNTY OF PIMA, STATE OF ARIZONA
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9 STATE OF ARIZONA,
Case No: CR 16-612627-MI
10 Plaintiff,

11 vs. DEFENDANT’S REQUEST FOR

DISCLOSURE
12 ROY WARDEN,

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Defendants.
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Defendant, pursuant to Ariz.R.Crim.P., Rules 1.1,15.1, 15.4, 15.6(a) and 15.7, Brady v.
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Maryland, 373 U.S. 83 (1963) and its progeny, hereby requests that the Court order the State
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to furnish defendant with the following information:
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1. All documents that support the State’s claim that Defendant violated A.R.S. section
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13-2810.
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2. All documents that support the State’s claim that Defendant violated A.R.S. section
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13-2921.
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3. The names, addresses and telephone numbers of all witnesses the State intends to
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call as witnesses at trial in this case.
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4. The names, payroll numbers, agencies and agency addresses of all police
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officers/law enforcement officers or civilian police department employees or other
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law enforcement employees who investigated this case.
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 1 5. The names, addresses and telephone numbers of all civilian witnesses in this case
2 known to the State or who may become known, in as much as this request does not
3 violate the Victim’s Rights Laws.
4 6. The name, address, CV or resume and phone number of any expert witness the State
5 may call at trial.
6 7. All police or law enforcement reports prepared in connection with this case.
7 8. All books, papers, documents, photographs, sound or video recordings, tangible
8 objects, electronic files, and surveillance reports related to the arrest of defendant.
9 9. All photographs, diagrams, videos and audio tapes created with respect to this case.
10 10. All reports or records of any prior convictions of Defendant.
11 11. All reports or records of any prior convictions of persons whom the State intends to
12 call as witnesses.
13 12. All reports or records of convictions for any witness Defendant intends to call as a
14 witness at trial.
15 13. All material known to the State or which may become known, through due diligence,
16 to the State, which is exculpatory in nature or favorable to Defendant or which may
17 lead to exculpatory material.
18 14. Any other evidence obtained by observation of police witnesses intended to be used
19 against Defendant at trial that is not part of the police reports furnished to defense
20 counsel.
21 15. A list of any felony convictions of the Defendant that the State plans to introduce
22 at trial.
23 16. A copy of any search warrant, return of warrant and statement of probable cause for
24 any warrant.
25 17. The Defendant timely requests the preservation of the following items which may
26 have been created as part of, or as a result of the police investigation in this case:
27 911 calls, audio and video recordings, warrant colloquy and all radio transmissions
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 1 18. A copy of all recorded and taped statements of Mr. Whitaker.
2 19. A copy of all recorded or taped statements of Defendant.
3 20. A copy of all images from the photographic memory film cards from Mr. Whitaker’s
4 computer, as referenced by Dep. Bowe in his 4/11/16 report.
5 21. . A copy of all photographs taken by Dep. Bowe, as referenced in his 4/11/16 report.
6 22. A copy of the documents referenced in the 8/10/16 report by Det. Petersen as a
7 “packet” of documents.
8 23. A copy of all recorded and taped statements of any individual aside from Mr.
9 Whitaker and Defendant.
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13 Dated this ____ day of January, 2018.
14 Scott Zonder
Attorney for Defendant
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Copy of the foregoing mailed/delivered
17 this ____ day of January, 2018 to:
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Pima County Attorney’s Office
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