FILED

08-20-2018
CIRCUIT COURT
DANE COUNTY, WI
STATE OF WISCONSIN CIRCUIT COURT DANE COUNTY
2018CM000962
BRANCH 7

STATE OF WISCONSIN Court Case No.: 2018CM000962

Plaintiff,

vs.

John A Owen III

Defendant,
For Official Use

THE STATE OF WISCONSIN’S MOTION AND DEMAND FOR DISCOVERY

AND NOTICE OF DNA AND WITNESS LIST

Plaintiff, State of Wisconsin, by Dallas B. Montano Assistant District Attorney demands and
moves as follows:

1. Pursuant to Wis. Stat. 971.23(2m), Plaintiff demands that the defendant or defense counsel
produce for inspection and copying within a reasonable period of time before trial:

a.) A list of witnesses, other than the defendant, whom the defendant intends to call at trial,
together with their addresses;

b.) Any relevant written or recorded statements of a witness named on the list demanded above,
including any reports or statements of experts made in connection with the case or, if an expert
does not prepare a report or statement, a written summary of the expert’s findings on the
subject matter of his or her testimony, including the results of any physical or mental
examination, scientific test, experiment or comparison that the defendant intends to offer in
evidence at trial;

c.) The criminal record of a defense witness, other than the defendant, which is known to the
defense;

d.) Any physical evidence which the defense intends to offer in evidence at the trial.

2. Pursuant to Wis. Stat. 971.23(5), Plaintiff moves the Court to order the defense to produce
any item of physical evidence which is intended to be introduced at trial for scientific analysis under
such terms as the Court prescribes. This Motion is based upon the Plaintiff’s need to prepare for trial in
a timely fashion.

3. Pursuant to Wis. Stat. 971.23(1)(d), Plaintiff puts defendant or defense counsel on notice that
all witnesses listed in the police reports are potential witnesses that Plaintiff may call at trial. Plaintiff
herein reserves the right to supplement this list with additional witnesses and addresses, or to inform
defendant or defense counsel of new addresses for previously named witnesses based upon new
information and within a reasonable amount of time.

4. Pursuant to Wis. Stats. 971.23(9), Plaintiff intends to introduce deoxyribonucleic acid profile
evidence at trial, when applicable.
 AUTHORIZATION TO OBTAIN COPY OF EVIDENCE IN A CRIMINAL CASE

TO: Attorney Andrea N. Winder

RE: State of WI vs. John A Owen III

Dane County Court Case # 2018CM000962
Referral Agency: Madison (City) Police Department
Agency Case #: 2018-00202899

DATE: August 20, 2018

Any photographic or electronically recorded evidence in this case is maintained by the Madison (City)
Police Department or other investigating agency identified in reports provided. With the exception of
City of Madison Police Department, law enforcement agencies may provide you with photographic or
electronic evidence directly. For those agencies, you are hereby authorized to obtain reproductions of
this evidence. Agencies charge a fee for reproduction of this evidence, and will require that you submit
this document and payment in advance. A RECORDED STATEMENT OF A CHILD OR CHILD
PORNOGRAPHY IS EXCLUDED FROM THIS AUTHORIZATION. To obtain a copy of or view any of
the excepted materials or City of Madison Police Department cases, contact me directly.

YOU WILL INCUR A COST FROM THE LAW ENFORCEMENT AGENCY OR THIS OFFICE FOR
COPIES OF ANY DISCS, AUDIO CASSETTES OR PHOTOGRAPHS.

If you instead wish to inspect any photographic, electronically recorded, or physical evidence in this
case, please promptly contact me directly.

Date Signed: 08/20/18

Electronically Signed For:
Dallas B. Montano by NMR
Assistant District Attorney
State Bar #: 1112901

LAW ENFORCEMENT AGENCY: Please forward to the DA’s Office a copy of any photographic or
electronically recorded evidence given to the defendant or defense attorney pursuant to this
authorization.