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AUN
28763552
IN THE DISTRICT COURT OF TULSA COUNTY
STATE OF OKLAHOMA’
STATE OF OKLAHOMA, )
Plaintiff, )
Vv. Case No. CM-2022-0124
MICHARE DawD RANDOLPH, } BSpuige guy
JUL 19 2022
STATE’S MOTION TO COMPEL DISCOVERY
SRB ci
COMES NOW, the State of Oklahoma, by and through its duly elected and acting District
Attomey for Tulsa County, Steve Kunzweiler, through Assistant District Attorney J jacob King, and
respectfully requests that Defendant disclose discovery, in accordance with 22 O.8. § 2002(B)(1)
and 22 O.S. § 2002(B)(3), and provide the State with the following:
1, The full names, current addresses, social security numbers, and dates of birth of any
witness Defendant will call, other than himself, for testimony relating to mental defect,
or other condition bearing upon his mental state at the time that the alleged offense was
committed, together with the witness’ statement, if the statement is redacted by the
court to preclude disclosure of private information.. 22 0.5. § 2002(B)(1X¢).
2. The full names, current addresses, telephone numbers, social security numbers, and
date of births of all alibi witnesses to include the date, time, and place of the alleged
alibi, together with the witness statement or summaries of those facts. 22 0.8. §
2002(B)(1){b).
3. The full names, current addresses, telephone numbers, social security numbers, and
birth dates of all witnesses the defense will call at trial, together with their written
record, recorded statements, or significant summaries. 22 O.S. § 2002(B)(1){a).
4. In reasonable time, the opportunity to inspect, photograph, copy, or have reasonable
tests made upon any book, paper, document, photograph, or tangible object, which is
within the defense’s possession or control and which the defendant intends to offer in
evidence, except to the extent it contains any privileged communication of the
defendant, or is a report or statement as to physical or mental examinations, scientific
tests, or experiments made in connection with the particular case, prepared by and
relating to the anticipated testimony of the person whom the defendant intends to callas a witness, provided that the report or statement is redacted by the court to preclude
disclosure of privileged communications. 22 0.8. § 2002(B)(3).
5. Accordingly, the above mentioned items should be completed at least ten (10) days
prior to trial. 22 O.S. § 2002(D).
In support of the State’s request, the State cites Allen v. District Court of Washington County, 803
P.2d 1164 (Okla. Cr, 1990).
Respectfully submitted,
1b King, OBA #34699
Assistant District Attorney
500 S. Denver Ave., Ste. 900
Tulsa, OK 74103
(918) 596-4862CERTIFICATE OF DELIVERY
1, Jacob King, do certify that a true and correct copy of the foregoing was delivered to Tulsa County
Public Defender’s Office, Attomey of Record for Defendant.
Jacob King
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AUN 28763552 IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA’ STATE OF OKLAHOMA, ) Plaintiff, ) Vv. Case No. CM-2022-0124 MICHARE DawD RANDOLPH, } BSpuige guy JUL 19 2022 STATE’S MOTION TO COMPEL DISCOVERY SRB ci COMES NOW, the State of Oklahoma, by and through its duly elected and acting District Attomey for Tulsa County, Steve Kunzweiler, through Assistant District Attorney J jacob King, and respectfully requests that Defendant disclose discovery, in accordance with 22 O.8. § 2002(B)(1) and 22 O.S. § 2002(B)(3), and provide the State with the following: 1, The full names, current addresses, social security numbers, and dates of birth of any witness Defendant will call, other than himself, for testimony relating to mental defect, or other condition bearing upon his mental state at the time that the alleged offense was committed, together with the witness’ statement, if the statement is redacted by the court to preclude disclosure of private information.. 22 0.5. § 2002(B)(1X¢). 2. The full names, current addresses, telephone numbers, social security numbers, and date of births of all alibi witnesses to include the date, time, and place of the alleged alibi, together with the witness statement or summaries of those facts. 22 0.8. § 2002(B)(1){b). 3. The full names, current addresses, telephone numbers, social security numbers, and birth dates of all witnesses the defense will call at trial, together with their written record, recorded statements, or significant summaries. 22 O.S. § 2002(B)(1){a). 4. In reasonable time, the opportunity to inspect, photograph, copy, or have reasonable tests made upon any book, paper, document, photograph, or tangible object, which is within the defense’s possession or control and which the defendant intends to offer in evidence, except to the extent it contains any privileged communication of the defendant, or is a report or statement as to physical or mental examinations, scientific tests, or experiments made in connection with the particular case, prepared by and relating to the anticipated testimony of the person whom the defendant intends to callas a witness, provided that the report or statement is redacted by the court to preclude disclosure of privileged communications. 22 0.8. § 2002(B)(3). 5. Accordingly, the above mentioned items should be completed at least ten (10) days prior to trial. 22 O.S. § 2002(D). In support of the State’s request, the State cites Allen v. District Court of Washington County, 803 P.2d 1164 (Okla. Cr, 1990). Respectfully submitted, 1b King, OBA #34699 Assistant District Attorney 500 S. Denver Ave., Ste. 900 Tulsa, OK 74103 (918) 596-4862CERTIFICATE OF DELIVERY 1, Jacob King, do certify that a true and correct copy of the foregoing was delivered to Tulsa County Public Defender’s Office, Attomey of Record for Defendant. Jacob King