Request for Discovery

KING COUNTY DISTRICT COURT
NORTHEAST DIVISION

TO: CITY OF REDMOND, Plaintiff; and
TO: Larry Mitchell, Redmond City Attorney, its Attorney

COMES NOW the defendant, Gregory R. Reddick, by and through his attorneys of record, McDonald & Quackenbush and G. William Shaw, and submits the following request for discovery pursuant to CrRLJ 4.7, CrRLJ 6.13, CrRL 4.7, IRLJ 3.1(b), IRLJ 3.3, IRLJ 6.6(b) and RCW 46.63 and request the following:

1. The names and address of all witnesses plaintiff intends to call at the hearing and a summary of the facts as to which each such witnesses are testifying (IRLJ 3.1(b). ) This includes, but is not limited to, the citing police officer.
2. Any memoranda, reports and/or notes made by the citing or arresting officer or other witnesses, including, but not limited to, a copy of the front and back of the ticket or infraction, and a copy of the citing officer's notebook or logbook (i.e., the notebook that the officer carries with him/her indicating the time of the stop, etc., for twenty-four hours prior to and after this incident).
3. Please identify each person whom you intend to call as an expert at the time of the contested hearing. As to each expert, please state:
   1. The expert's name, job title, address and telephone number;
   2. The name, address and telephone number of the expert's employer, if any;
   3. Whether any written reports have been furnished by the expert to plaintiff and, if so, the date thereof;
   4. The subject matter on which the expert is expected to testify;
   5. The substance of the facts and opinions to which the expert is expected to testify;
   6. A summary of the grounds for each opinion to which the expert is expected to testify; and
   7. A statement of the expert's qualifications to testify in this action, including, but not limited to, a resume or curriculum vitae for each such expert.
   8. Please produce copies of all reports and documents identified in this request.
4. Copies of the reports or certifications concerning the result of any scientific tests, experiments or comparisons or certificates that are intended to be submitted pursuant to CrRLJ 6.13 and/or IRLJ 6.6(b), including but not limited to, certificates for electronic speed measuring devices, speedometers, laser units, road markings and stop watch certificates;
5. Maintenance records for the radar unit, laser unit, stopwatch and/or speedometer or other type of speed measuring device used in this case;
6. Identity of the tuning forks used for calibration of the radar unit, laser unit, speedometer and or any electronic or other type of speed measuring device used in this case, including stopwatches;
7. Maintenance records for the tuning forks and/or stop watches used for calibration;
8. All certificates of calibration for the tuning forks used for the calibration used in this case;
9. All information related to or concerning the citing officer's training in estimating speed and operating speed measuring devices if plaintiff intends to call the officer as a witness;
10. All information regarding the signage of the area in which the infraction was alleged to have occurred showing that it was properly signed pursuant to RCW 46.61, et seq.
11. Certification that the SMD was included in the IACP Consumer Product List and that the SMD met or exceed the NHTSA and NIST model specification on the date of the alleged incident.
12. Any and all documents which are in any way pertinent and/or relevant to this matter.

PLEASE NOTE THAT FAILURE TO PROVIDE THE INFORMATION REQUESTED HEREIN WILL RESULT IN A MOTION FOR SANCTIONS, INCLUDING EXCLUSION OF THE PROFFERED EVIDENCE OR WITNESS OR DISMISSAL.

DATED THIS 25 day of January, 1998.

McDONALD & QUACKENBUSH

By G. William Shaw, WSBA #8573
Attorneys for Defendant Gregory R. Reddick