Skinner et al v. New York Times Company

Filing 91

Skinner et al v. New York Times Company

Doc. 91

IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OH OHIO EASTERN DISTRICT UNITED STATES OF AMERICA, P l a i nt i f f , v. TIFFANY NICHOLAS, Defendant. : : : : : CR -2-04-152 JUDGE SARGUS

MOTION TO COMPEL DISCOVERY Now comes the Defendant, Tiffany Nicholas, by and through her undersigned counsel, and hereby respectfully requests pretrial discovery of the original crime scene fingerprint impression on the subject checks relating to Defendant. Defendant demands to know whether the image compared to the Defendant's ink print was the original impression found on the submitted checks. If not, Defendant demands to know how law enforcement generated the image that was compared to the ink compressions. If the image was created by computer, Defendant demands to know the software that was used to produce the image and what research has been done to validate the accuracy of that software. If the original impression is no longer available, Defendant demands to know what happened to the original impression and if it was destroyed, why and who destroyed it. Respectfully submitted,

S/Neil W. Rosenberg Neil W. Rosenberg (0005771) Trial Attorney for Defendant Nicholas 400 South Fifth Street, Suite 102 Columbus, Ohio 43215 [phone]

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Dockets.Justia.com

CERTIFICATE OF SERVICE The undersigned certifies that a true copy of the foregoing was electronically delivered to the Brenda Shoemaker, Assistant County Prosecutor, 303 Marconi Blvd, Suite 200, Columbus, Ohio 43215 this 22nd day of February, 2005.

S/Neil W. Rosenberg Neil W. Rosenberg (0005771) Trial Attorney for Defendant Nicholas

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