Professional Documents
Culture Documents
STATE OF KANSAS
SALINA KANSAS
)
)
STATE OF KANSAS )
Plaintiff, )
)
) NO. 2006 CR 1219
Vs. )
)
DANIEL JOSEPH JACKSON )
Defendant )
)
COMES NOW; the Defendant herein, Daniel Joseph Jackson and by counsel,
Andrew Hartnett; and respectfully moves this Court as pursuant to the Sixth, Eighth and Fourteenth
Amendments to the United States Constitution and the Kansas Constitution Bill of Rights. to
require the State of Kansas prosecutor to disclose to counsel, and permit them to inspect, copy, test and
(d) All statements, written or oral, made by this Defendant, Daniel Joseph Jackson to
any person, at anytime, before or after his arrest in this case, including the name and
address of the person[s] to whom the statements[s] was [were] made, including but
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(b) the investigation of that crime; and including but not limited to that of
cell phone, along with the lawful court orders authorizing said such
activities, and by whom these applications were made by, when made, and
(c) any condition of the accused, including but not limited to his mental or
physical state:
2. All statements, written or oral, made by any of the co-defendant Jennifer Sue
Scott; to any person, at the time of or subsequent to their arrests in this case, including the
name and address of the person[s] to whom the statement[s] was [were] made, including
(b) the investigation of that crime; and any statements made by the co-
well as that of the Saline County Jail, from on or about the 3rd of
November 2006 through but not limited to that of December 1st 2006.
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(c) any condition of the defendant including but not limited to his mental
or physical state at the time of the alleged crime, at the time of any of the
3. The names and addresses of all persons the prosecution proposes to offer as
witnesses at the trial or any hearing of this case, and any persons with knowledge of any
4. The names and addresses of all persons who have given recorded statements to the
5. The names and addresses of all persons who have given oral statements to the
6. Copies of all written and/or oral statements made by any of the persons referred to
as well as grand jury testimony. Furthermore, the State is requested to record the
substance of any oral statements made by any such persons for delivery to the defense, if
7. All memoranda, documents and reports to, from and between law enforcement
8. All memoranda, documents and reports to, from and between the investigative
staff of the prosecution, exclusion those portions if any, which contain the opinions,
9. The criminal records of any of the witnesses and any list or summary reflecting
criminal records of all persons whom the prosecution intends to call as a witness at trial.
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10. All evidence in the prosecutor's possession or available to the prosecution, which is
favorable to Defendant, Daniel Joseph Jackson on the issue of guilt, including but not
limited to:
(c) Any and all evidence, letters, memoranda or other material of any
Saline County against Daniel Joseph Jackson, and the identity of the
(d) Any and all other information respecting any prosecution witness
(e) Statements made by any persons which are exculpatory with respect to
witnesses.
11. All evidence in the prosecution's possession or available to the prosecution which
is favorable to accused Daniel Joseph Jackson on the issue of punishment, including but
(d) the offense was committed while the co-defendant; was under the
slight a way;
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(d) JAMES KOEHN was an accomplice and his participation was
(e) Jennifer Sue Scott acted under some kind of duress or under the
(g) any agent of the state, who abused this defendant, Daniel Joseph
Jackson his rights and or violated his constitutional rights when the
defendant Daniel Joseph Jackson was arrested; including but not limited
Joseph Jackson.
(k) that Jennifer Sue Scott and or Daniel Joseph Jackson has suffered
abuse at any time in his life, at the hands of family members or anyone else;
(m) in support of any other possible mitigating factor which the State
that:
(a) were obtained from or belong to the Defendant, Daniel Joseph Jackson ;
(b) the prosecution intends to offer at any trial or hearing of this case;
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(c) the prosecution is retaining for potential use in evidence at any trial or hearing
in this case;
(d) any law enforcement official is retaining for potential use in evidence at any
(e) the prosecution or any law enforcement official has submitted to any
13. All diagrams, sketches and photographs which have been made by or shown to any
witnesses or prospective witnesses in this case, as well as the identity of each witness to
whom this material was shown. Including but not limited to the statements and or
comments made by those witnesses after the showing of these items listed.
14. All records and reports of every kind reflecting the conduct or results of any
15. All records and reports relating to the co-defendant Jennifer Sue Scott; including:
(a) all juvenile detention, jail, prison, parole, probation and presentence
investigation records;
(b) all arrest, conviction, and adult and juvenile criminal offense records;
(e) any and all records of visitation while co-defendant; Jennifer Sue Scott; was
held in custody since here arrest on or about the 3rd day of November 2006.
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(f) the prosecution or any law enforcement official has submitted to any
(a) all juvenile detention, jail, prison, parole, probation and presentence
investigation records;
(b) all arrest, conviction, and adult and juvenile criminal offense records;
17. A statement as to whether the prosecution will rely on prior acts or convictions of
a similar nature for proof of knowledge or intent, including a description of each act or
18. A list of all expert witnesses the prosecution intends to call at trial, along with each
expert's qualifications, the subject and a description of his or her contemplated testimony,
19. Any statements as to whether the prosecution will use felony convictions for
impeachment of the accused this Defendant, Daniel J. Jackson if he testifies, along with
Respectfully submitted,
_____________________
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By: _________________________
_________________________
)
)
STATE OF KANSAS )
Petitioner/Plaintiff, )
)
) NO. 2006 CR 1219
Vs. )
)
DANIEL JOSEPH JACKSON )
Respondent/Defendant )
)
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CERTIFICATE OF SERVICE
I, ___________, attorney for _______________, do hereby certify that I have on this day
_____________________________
_____________________________
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