Doc. No. CBE-OI092016-IDRJanuary 9, 2016

Informal Discovery RequestCover Letter MEMO

Corey Eibc/o 16209 Victory Blvd #215Van Nuys, CaliforniaNon-Domestic

The Hon. Jackie Lacey, District AttorneyLos Angeles County6230 Sylmar Ave #201Van Nuys, CA 91401

re: citation number CJ 56370

Dear District Attorney Lacey,

Enclosed please find three copies of a my Informal Discovery Request (ea 3 pages)pursuant to Penal Code and Government Code.

One copy is for your office, please date stamp and return the remaining two copies in thepre-addressed and postage paid envelope.

Thank you."

, :t".'

CoreyEibc/o 16209 Victory Blvd #215Van Nuys, CaliforniaNon-Domestic

Pro Per

SUPERIOR COURT OF THE STATE OF CALIFORNIACOUNTY OF LOS ANGELES, VAN NUYS COURTHOUSE

vs.Case No. CJ 56370

PEOPLE OF THE STATE OF CALIFORNIA,

Eib, Corey BrandonINFORMAL

DISCOVERY REQUEST

Pursuant to California Penal Code sections 1054 and 1054.1, and California Government

,Code section 26500, the defendant in the above entitled matter does hereby request under

discovery the following:

• Names and addresses of all witnesses for the prosecution.

• Statements of all witnesses.

• A copy of all of Officer BEMILLER's notes including copies of the front and back of

the officer's copy ofthe NOTICE TO APPEAR form.

• Copy of the DMV Application for Registration In the name EIB, COREY

BRANDON for PT Cruiser Vin #3C8FY78G45T541364

• Copy of audio recorded by officer BEMILLER and any other officer present when

citation #CJ 56370 was issued.

• Copy of dash cam or any other video from BEMILLER'S CHP cruiser or body cam

and any other video recorded during the stop by any officer at the scene.

• C~py of CHP policy HPM 81.2 Chapter 1 CHP 180, Vehicle Report pages 1-1

through 1-27.

• Copy ofCHP Notice of Stored Vehicle Completed by Officer BEMILLER CHP180.

• Copy of Officer Bemiller's subscribed Oath of Office.

• Copy of CHP Supervisor A. Smith's subscribed Oath of Office.

• Copy of any notes or other recording medium of officer A SMITH, SUPERVISOR.

Page 1 of3

• Copy ofCornmunications Network Message attached to CHP180.

Copy of the CHP inventory report for PT Cruiser Vin # 3C8FY78G45T541364.

Copy of CHP Policy governing the completion of a CA Judicial Council Approved

NOTICE TO APPEAR form.

Copy of CA Judicial Council TR-INST, NOTICE TO APPEAR AND RELATED

FORMS.

Copy of all evidence the State intends to use as evidence of defendant's residency in

this State.

Copy of all, applications, authorities, notes recorded in any type of medium which the

State intends to use as evidence that specifies defendant's name to be in the specific

name sequence of FIRST / MIDDLE / LAST or any variation thereof.

Copy of all records of CHP informal tow hearing RE PT Cruiser Vin #

3C8FY78G45T541364.

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• Copy of hand written notes taken by the hearing officer conducting CHP informal

tow hearing RE PT Cruiser Vin # 3C8FY78G45T541364.

Copy of CHP policy governing the destruction of hand written notes taken by a CHP

hearing officer during an Informal Tow Hearing.

Copy of Manufacturer's Certificate of Origin for PT Cruiser Vin #

3C8FY78G45T541364.

Copy of Citizen's Complaint Information received by Capt. 1.1. Starling referenced in

letter dated Dec. 2, 2016 signed by Starling.

Copy of DMV policy governing the processing of submitted DMV Reg 5050 Exempt

License Plate Request form.

Copy of DMV policy governing the requirement to maintain registration application

records.

Copy of CA Vehicle Code applicable to DMV requirement to maintain registration

application records.

Copy of DMV policy governing the requirement to maintain accurate computer

records.

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• Copy of all evidence Defendant's presence in the United States is authorized under

Federal Law

Page 2 of3

• Copy of CA DMV FORM DL44

Please note: PC 1054.1 uses the imperative, "shall disclose." The only place in the law

where we find any choice in this matter is in Government Code 26500, which states in

part:

The public prosecutor shall attend the courts, and within his or her discretionshall initiate and conduct on behalf of the people all prosecutions for publicoffenses. (emphasis added)

Obviously the public prosecutor would not violate the law, therefore I will have to

interpret a failure to provide the documents requested under discovery as an exercise of

the discretion provided for in GC 26500 and a decision not to prosecute this case.

This request is made on this the 8th day of January 2016.

Page 3 of3

Please File Stamp and

Return The Two (2) attached Copies

The Hon. Jackie Lacey, District AttorneyLos Angeles County6230 Sylmar Ave #201Van Nuys, CA 91401

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Corey Eibc/o 16209 Victory Blvd #215Van Nuys, California: Non-Domestic

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