IN THE PERRYSBURG MUNICIPAL COURT WOOD COUNTY, OHIO

STATE OF OHIO Plaintiff v. * JUDGE: Hon. S. Dwight Osterud * * Case No. TRD 13012345 * MICHAEL SCOTT * Defendant * MOTION FOR DISCOVERY * * * Denny Crane, Esq. (0012345) * CRANE, POOLE, & SCHMIDT LAW GROUP * 123 Main Street, Suite 202 * Perrysburg, OH 43551 * (419) 874-8700 * *********************************************************************** * Defendant, by undersigned counsel, respectfully moves the Court, pursuant to Rule 16 of the Ohio Rules of Criminal Procedure, that the State be ordered to produce and permit the defendant to inspect and copy or photograph each of the following which are available to, or within the possession, custody or control of the State, the existence of which is known or by the exercise of due diligence may become known to the prosecuting attorney: (1) Relevant written or recorded statements made by the defendant or co-defendant, or copies thereof; (2) Written summaries of any oral statement, or copies thereof, made by the defendant or co-defendant to a prosecuting attorney or any law enforcement officer; (3) Recorded testimony of the defendant or co-defendant before a grand jury; (4) Defendants prior criminal record, if any;

(5) Books, papers, documents, photographs, tangible objects, buildings or places, intended for use by the prosecuting attorney as evidence at the trial, or obtained from or belonging to the defendant; (6) Any results or reports of physical or mental examinations, and of scientific tests or experiments, (including but not limited to handwriting analyses) made in connection with the particular case; (7) A written list of the names and addresses of all witnesses whom the prosecuting attorney intends to call at trial, together with any record of prior felony convictions of any such witness; (8) All evidence favorable to the defendant and material either to guilt or punishment. (9) A copy of any Bill of Particulars. Undersigned counsel hereby certifies that demand for discovery was made upon the State on the 21st day of February, 2013 and the discovery has not been provided. /S/ Denny Crane Denny Crane, Esq. (0012345)
CRANE, POOLE, & SCHMIDT LAW GROUP

123 Main Street, Suite 202 Perrysburg, OH 43551 (419) 874-8700

Counsels Certificate of Service

I certify that I served a copy of the attached Motion for Discovery via U.S. Mail upon the Perrysburg Municipal Court Prosecutors Office at Clerk of Courts, 300 E. Walnut Street, Perrysburg, Ohio 43551 on February 21, 2013.

/S/ Denny Crane Denny Crane, Esq. (0012345)

CRANE, POOLE, & SCHMIDT LAW GROUP

123 Main Street, Suite 202 Perrysburg, OH 43551 Ph: (419) 874-8700