In the Municipal Court of Springfield Missouri
City of Springfield,
Ticket No.: 96-0682427-6560
Motion for Production of Evidence
COMES NOW, Defendant Marc Perkel, pursuant to Rule 25.03 to request the state produce the following information: Any reference to "the state" shall be construed to include the State of Missouri, Greene
County, City of Springfield, or
other governmental body. Note that the state is under a continuing duty to provide sought-after information if it is discovered after the receipt of the initial request. Note also that the state is required to use
diligence to cause these materials to be
made available to the Defendant.
- The names and last known addresses of persons whom the state intends
to call as witnesses at any hearing or at the trial, together with their
written or recorded statements, and existing memoranda, reporting or
summarizing part or all of their oral statements.
- Any written or recorded statement and the substance of any oral
statements made by the defendant, Marc Perkel, [list of people in police
report] and the "confidential informant" which was referenced in the
police report. Include names and dates with all statements and copies of
all audio tapes made of conversations referenced in the police
- The name and last known address of the "confidential informant" "
which was referenced in the police report.
- Any and all information or evidence as to any other complaints by
Shirley Anne Montgomery or Dee Montgomery relating to trespassing by
Marc Perkel or any other complaint made to the police about marc
- Copy of the audio recording of the incident and any transcripts of
audio recording of the incident as referenced in the police report by
the statement, "An audio recording of the incident exists and was ended
at 2246 Hours."
- Any and all records of any information relating to any investigation
in which Marc Perkel was a subject or discussed or referenced in any
- Any and all information obtained by surveillance, including
wiretapping, in the possession of the state that relates directly or
indirectly to Marc Perkel. Include dates, times, of said surveillences
and copies of any court orders or other authorizations to conduct
wiretap and surveillences. This is to include surveillences of Marc
Perkel or any other individual where evidence was obtained that
mentioned or related to Marc Perkel.
- Any and all written or recorded statement and the substance of any
oral statements, interviews, conversations, of any nature between
Officer Hollie or Officer Shipley and either Shirley Anne Montgomery or
Dee Montgomery that occurred in 1998 and involved the subject of Marc
Perkel or any other person named in the police report.
- Any and all police records relating to 911 or other police calls
involving Marc Perkel since the beginning of this year.
- The names of the jail staff who were present when Marc Perkel was
brought in and when Marc Perkel was released, or who were directly or
indirectly involved in booking, and any statements or recordings made by
them in reference to this incident.
- Any books, papers, documents, photographs, or objects, which the
state intends to introduce as evidence at the hearing or trial or which
were obtained from or belonging to the defendant or complainant.
- Any record of prior criminal convictions of, or pending charges
against, Shirley or Dee Montgomery or anyone else named in the police
report or anyone whom the state intends to call at trial.
- Any and all information relating to any deals, plea bargains, or
promises of immunity relating to any person named in the police
- Defendant requests 15 standard summons forms of the same type as
used in his arrest, marked VOID to prevent misuse, for the purpose of
scientific testing by the defendant.
- Any material or information, within the possession or control of the
state, which tends to negate the guilt of the defendant as to the
offense charged, mitigate the degree of the offense charged, or reduce
Marc Perkel * Plaintiff * 09-30-98