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IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
COMMONWEALTH OF PENSYLVANIA
vs.
CRIMINAL DIVISION
CC
JOHN DOE,
Defendant
MOTION FOR ADDITIONAL
DISCOVERY(DNA)
Filed on behalf of:
JOHN DOE,
Defendant
Attorney of Record:
Michael J. Machen, Esquire
PA I.D. 40551
310 Grant Street
Suite 823
Pittsburgh, PA 15219
(412) 973-8008
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
COMMONWEALTH OF PENSYLVANIA
vs.
CRIMINAL DIVISION
CC
JOHN DOE,
Defendant
MOTION FOR ADDITIONAL DISCOVERY (DNA)
AND NOW COMES, the Defendant, John Doe, by and through his counsel, files
the within Motion for Additional Discovery (DNA), whereof the following is a statement:
1.
That the Commonwealth of Pennsylvania provide all records in connection
with the above-captioned matter.
This would include all sample files, project files,
injection lists, sample sheets and injection logs.
2.
That the Commonwealth of Pennsylvania provide all laboratory guidelines,
protocols and procedures used in generating DNA data.
3.
That the Commonwealth of Pennsylvania provide the chain of custody for
the DNA as tested by the Allegheny County Crime Lab. This would be specific to
evidence collection, serological analysis, and DNA analysis.
4.
That the Commonwealth of Pennsylvania provide all data necessary to:
a.
b.
re-analyze the raw data; and
reconstruct the analysis performed.
5.
That the Commonwealth of Pennsylvania provide the allele frequency
6.
That the Commonwealth of Pennsylvania provide all guidelines, protocols
tables.
and procedures related to interpreting DNA data.
7.
That the Commonwealth of Pennsylvania provide all laboratory reports
related to DNA evidence such as, but not limited to: DNA typing results and allele
tables.
8.
That the Commonwealth of Pennsylvania provide all quality assurance
reports and audits for the past five (5) years.
9.
That the Commonwealth of Pennsylvania provide all curriculum vitae for
all personnel who were involved in conducting or reviewing the DNA in the abovecaptioned matter.
10.
That the Commonwealth of Pennsylvania provide any corrective actions
that the Allegheny County Crime Lab has instituted pursuant to the DNA Advisory Board
Quality Assurance Standards for Forensic DNA testing.
WHEREFORE, Defense Counsel respectfully requests that this Honorable Court
consider the within Motion for Additional Discovery (DNA).
Respectfully submitted,
_____________________________
MICHAEL J. MACHEN, ESQ.
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
COMMONWEALTH OF PENSYLVANIA
vs.
CRIMINAL DIVISION
CC
JOHN DOE,
Defendant
PRELIMINARY ORDER OF COURT
AND NOW, to-wit, the _______ day of ____________________, 2016, upon
consideration of the within Motion for Additional Discovery (DNA), a hearing shall be
heard on the _____ day of ____________________, 2016 at 9:00 a.m..
BY THE COURT:
________________________________J.
IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
COMMONWEALTH OF PENSYLVANIA
CRIMINAL DIVISION
vs.
CC
JOHN DOE,
Defendant
ORDER OF COURT
AND NOW, to-wit, the _______ day of ____________________, 2016, upon
consideration of the within Motion for Additional Discovery (DNA), it is hereby
ORDERED,
ADJUDGED
and
DECREED
that
the
within
Motion
is
hereby
GRANTED/DENIED.
BY THE COURT:
________________________________J.