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IN THE CIRCUIT COURT OF THE FIRST mDICIAL DISTRICTOF HINDS COUNTY, MISSISSIPPISTATE OF MISSISSIPPIVS.SHARROD MOOREPLAINTIFFNO. 08-31
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DEFENDANT
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STATE'S RESPONSE TO DEFENDANT'S MOTION TO COMPELThe State promptly provided discovery upon the Defendant's request. TheDefendant made a further request for additional discovery in the form of a letter itemizing31 pieces of evidence. The State promptly provided the itemized request to the Cold CaseUnit of the Jackson Police Department. The Cold Case unit is currently searching forthese items per the Defendant's request. Further, the State has newly discovered evidencethat has led to a subsequent investigation. Attached is a transcript of the newly discoveredevidence, an eyewitness to the crime. The defense will be furnished newly discoveredevidence as it is received from the various agencies involved in this investigation.While the Defendant is constantly requesting discovery from the State, theDefendant should be reminded that it has an obligation to provide reciprocal discoverypursuant to U.C.C.C. rule 9.04 of the Mississippi Rules of Discovery. The Defendant hasyet to furnish any discovery whatsoever to the State at this time.The Court does not need to enter an order compelling the State to provideevidence until the Defendant provides its reciprocal discovery, and until the JacksonPolice Department and other agencies complete its investigation on the newly discoveredevidence.
 
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Respectfully submitted, this the ~
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of April, 2008.
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ROBERT SHULER SMITHHINDS COUNTY DISTRICT ATTORNEY'S OFFICEP.O. BOX 22747HINDS COUNTY COURTHOUSEJACKSON, MS 39225-2747TEL. (601) 968-6568FAX. (601) 968-6655CERTIFICATE OF SERVICE
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Robert Shuler Smith, hereby certify that I have delivered via hand delivery, atrue and correct copy of the foregoing Motion to Compel to:Charles R. Mullins (MSB# 9821)Coxwell
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Associates, PLLC500 North State StreetPost Office Box 1337Jackson, MS 39215-1337Tel. (601) 948-1600Fax. (601) 948-7097This the
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day of April, 2008.
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ROBERT SHULER SMITH
 
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STATEMENT OF STEPHAN HICKMANHINDS COUNTY COURTHOUSE MARCH 27, 2008
APPEARANCES:
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HONORABLE ROBERT SMITHHONORABLE WINSTON THOMPSONOffice of the District AttorneyDETECTIVE FELIX HODGEDETECTIVE KENNETH WESTJackson Police Department1112131415161718192021222324
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25Reported by:Connie Chastain
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RMR
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CSROfficial Court ReporterPost Office Box 327Jackson
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Mississippi 39205CSR NO. 1025
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