Joseph Daryl Mathis v. State

. OATEgJlzAp&blS INMATE REQUEST FORM AD S YOUR REQUEST TO THE PROPER OFFICE BY CHECKING ONE • 1. CHAPLAIN -Religious Requests • 2. CLASSIFICATION -Job Requests/Housing Problems • 3. COMMISSARY -Questions regarding Voids, Shorts, Etc. • 4. EDUCATION -Class Information/Applications Q 5. FCC DEPUTY -Court Information/Court Dates/Bond Information -I 6. GRIEVANCE BOARD -See Inmate Handbook for proper procedures Q 7. INMATE BANK -Deposits/Balance/Valuable Property Information a 8. LAW LIBRARY -Requests for Law Library Information/Notary • 9. MEDICAL -Requests to the Medical Section -I /10. SHIFT SUPERVISOR -Emergency Telephone Calls or Cellbloc U 11. OTHER -(explain below) l)k^nci_CDudi^r'Appeals $CD_& ¥ROM:JlX(pk j\. Al/i-rUlt -Tf LOCATION<*120 701 711 1307 (circle one) Cellblock<^ " / DC-162-(05/03) 14 THE STATE OF TEXAS § IN THE jP^ JUDICIAL vs- § DISTRICT COURT OF /fp/Q&llS iW^/ /WM/r^.VTr § HARRIS COUNTY, TEXAS MOTION FOR DISCOVERY AND INSPECTION OF EVIDENCE TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW the Defendant, To«y>l>Q./folH„<>Jr). in the above-styled and numbered cause and moves the Court, under the authority of Art. 39.14, Tex. Code Crim. Proc. Ann., for discovery and inspection of the following items: I. The Defendant moves the Court to order the District Attorney to produce and permit by the Defendant or Defendant's counsel the inspection ofand the copying and/or photographing of the following: I. Any documents, papers, books, accounts, letters, photographs, objects or tangible things not privileged, which constitute or contain evidence material to any matter involved in the action and which are in the possession, custody or control of the State or any of its agencies; Any written statements of the Defendant; Any oral statements of the Defendant; The prior criminal record of the Defendant; The criminal records of the State's witnesses; Any evidence which in any way is exculpatory to the Defendant. Any tape recordings of the interviews with the Defendant by any law enforcement agent, II. In support ofthis Motion the Defendant would show that the items and information requested are within the exclusive control and custody of the State, the items are not privileged, and that, absent such discovery, the Defendant's rights under Art. 39.14. Tex. Code Crim. Proc. Aim.: Art 1, Sec. 10. of the Texas Constitution; and the Fourth, Fifth and Sixth Amendments of the United States Constitution will be violated. WHEREFORE. PREMISES CONSIDERED, the Defendant respectfully prays that this Honorable Court grants this the Defendant's Motion for Discovery and Inspection. 14 Respectfully submitted, Ik OosqpI tWMa-AkTn ^mv^DEFE^IDANT ftb&dGli79.6/ "I (INSERT NAME AND INMATE IDENTIFYING NUMBER FROM TEXAS DEPARTMENT OF CORRECTIONS OR COUNTY JAIL), being presently incarcerated in (INSERT TEXAS DEPARTMENT OF CORRECTIONS UNIT NAME OR COUNTY JAIL NAME) in /-/nrriS (m.inHS County, Texas, declare under penalty ofperjury that the foregoing is true and correct. ._. , Executed o^/^pr;?, A; fT /CJ *222Gbx^k>l <£L <4^ (DATE) J ^ (SIGNATURE) ORDER ON THIS the clay of. . 20 . came on to be heard the foregoing Motion for Discovery and Inspection of Evidence, and same is hereby GRANTED, with respect to paragraphs numbered . and DENIED, with respect to paragraphs numbered . to which action Defendant excepted. JUDGE