SR ‘Sum CAUSE NO. F08-33908-Y ‘THE STATE OF TEXAS § INTHE CRIMINAL § vs. § DISTRICT COURT #7 § YASER SAID § OF DALLAS COUNTY, T FILED 19/9/2020 10:30 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS jetra Rayson DEPUTY DEFENDANT'S MOTION FOR DISCOVERY, UNDER THE MICHAEL MORTON ACT. ‘TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW the defendant in the above styled and numbered cause, pursuant to Article 39.14, Code of Criminal Procedure (the Michael Morton Act) and would make the following requests of the prosecution: 1 ‘The defendant requests the production and the duplication (either in hard copy or electronically) of: (a) any offense report generated in connection to this case, (b) any documents or papers relevant to the case, specifically any laboratory testing results (forensics, ballistics, serology, DNA, trace evidence analysis, etc), and copies of surveillance video made at the crime scene. (0 any written or recorded statements of the defendant or a witness, including witness statements of law enforcement officers, and(d) any books, accounts, letters, photographs, objects or other tangible things not otherwise privileged that constitute or contain evidence material to any matter involved in the action. it The defendant requests disclosure of any exculpatory, impeachment, or mitigating document, item, information in the possession, custody, or control of the state that tends to negate the guilt of the defendant or would tend to reduce the punishment for the offense charged. Mm. ‘The defendant requests that all requested documents, statements, books, accounts, letters, photographs, or objects or other tangible things be submitted to the defendant's counsel without redaction of any sort, except as permitted by law. Mm. ‘The defendant requests the production by the state of the requested materials be completed as soon as is practicable. Respectfully submitted, B .nbte, K Cron } 7 Bradley K. Lollar Attorney for the Defendant State Bar No. 12508700 Assistant Public Defender 133 N. Riverfront Blvd., LB 2 Dallas, Texas 75207 Tel. (214) 653-3550 Fax (214) 65Cell (214) 384-8178 bklollar@sbeglobal.net Bradley. Lollar@dallascounty.org