§1:04 Sample Discovery Request: Blood/Urine Case (Relevant Paragraphs)
For a blood or urine case, replace paragraphs 17 through 37 in form §1:03 with the
following:
17. The specific name of the State's expert who will testify as a technical
supervisor and will interpret the blood/urine test results.
18. A copy of the blood/urine test record of the Defendant.
19. Copies of all training and operation manuals or other pertinent training
information given to the blood/urine analyst and technical supervisor for
their certification and for meeting proficiency requirements to perform
blood/urine analysis
20. The basic practical and educational requirements for the blood/urine staff
responsible for the maintenance and the calibration of the blood/urine
alcohol test devices. Included in this request is the identification of any
and all basic training requirements and all annual or periodic refreshertraining requirements for the people responsible for the maintenance and
calibration of the evidential blood/urine testing equipment.
21. An outline of the course work and the results of any proficiency testing
performed by the people responsible for the maintenance and the
calibration of the blood/urine alcohol device.
22. Computer-generated copies of all reports, testing logs, records, computer
data, or other memoranda of testing performed through use of the testing
equipment used to test Defendant herein beginning 30 days before date the
Defendant was arrested and 14 days after said date.
23. A copy of all tests, testing protocols and lab data collected by or on the
behalf of the chemical test section subsequent to the
approval/selection/purchase of the blood/urine testing device. This
request includes, but is not limited to: (a) any and all testing of the
accuracy, precision, and safeguards; (b) all and all pre-installation
certifications; (c) any and all in-house and/or independent lab testing; (d) a
copy of the owner's and /or user's manual for the data
acquisition/management program.
24. A listing of all databases collected from the blood/urine alcohol device
and identification of data fields for each of the databases.
25. A listing of all codes, shorthand, messages, and/or acronyms used in the
alcohol device's computer data files.
26. Copies of the quality assurance plan, warranties, cautions, constraints and
FCC notices that are provided by the manufacturer of the alcohol device.
27. A copy of the maintenance, calibration and operators’ manuals for the
alcohol device and any other materials utilized in the training the
Chemical Test Division Staff on the basic calibration.
28. Copies of any and all correspondence, memos, letters, e-mails, notes etc.,
either to or from any of the Chemical Test Division Staff, addressing the
operation and/or performance of the chemical alcohol device.
29. The written automobile inventory procedures of the law enforcement
agency that impounded and inventoried the Defendant's vehicle and the
written inventory of the vehicle.
30. Copies of all California State Department of Health and of the arresting
agency's internal memoranda, advisories or notices, or those sent from the
manufacturers of the chemical alcohol device of the type that was used to
test the Defendant for intoxication that generally provide information that
the device possibly suffers from a design defect or that it may be subjected
to false readings or errors due to outside interference.
31. Production of a comprehensive summary (history) of all invalid tests or
errors of the specific device that was used to test the Defendant.
32. An opportunity for defense experts to view, photographically record, and
test the testing device and simulator machine that were used the day the
Defendant was arrested to test the Defendant for intoxication.
33. All training manuals used by and in possession of the arresting officer in
this case for which he received his certification to perform standardized
field sobriety testing. This request for production is for the specific
manual or replacement manual, which was personally issued to the officer.
This request includes any and all handouts, documents or other training
materials and notes received by the officer or taken by the officer during
the field sobriety test certification process. In the event the officer should
not have this manual and materials, this production is to include a written
explanation as to their whereabouts.
34. Any and all studies, reports, articles, books or any other source used by
any expert witness to create, inform or otherwise influence any opinion
they may render on absorption, elimination or processing of alcohol;
divided attention tasks, or field sobriety tests.