Disclosure Request Letter (Precedent)

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Application to Quash

DISCLOSURE LETTER
I have received and reviewed the initial disclosure package in the above-noted matter. I have reason to believe there exists materials of potential relevance that has not been disclosed and is required for full answer and defence. I wish to request as additional disclosure the following materials listed below. Should any of the requested records not be in the possession of the Crown but are reasonably believed to exist, a will-say to that effect would be requested. Should any materials be in the police or Crown counsel related to this prosecution that has not be disclosed after review for relevancy and privilege, I would kindly ask that the records be identified where not otherwise clearly outlined previously, along with an indication of the reasons for withholding the record. "Records", for the purpose of this request, include all typed or handwritten statements or notes, reports, letters, emails, memos, calendars, audio or video recordings. This would include any electronically stored records, including those that were previously deleted but are recoverable by forensic means. I would kindly ask for disclosure of the following material records: All records relating the statements (formal or informal, recorded, reduced to writing, or otherwise) given by the following relevant persons: [list people and identify the specific format of the statement if known] ... All records that are referenced by [witness] during their interview on [date]. If present in disclosure, I would kindly appreciate that you could identify where in disclosure this could be found. The records being requested consist of: [list the items that are mentioned in the particular statement] ... All relevant communications between XX and YY. A copy of the following Information(s) to Obtain: [list the type of warrant and the date of issuance] ... A copy of the following documents reviewed by the affiant to the judicial authoriations: [list documents referenced in the ITO as being relied up] A copy of investigative file # ________ [assuming there is a material connection to the case] Please confirm that the entire contents of XXX was provided in disclosure. If not complete, we would kindly ask for the entirety of the contents.