Small Claims County Court District Court
Probate Court Juvenile Court Water Court
Jefferson County, State of Colorado
100 Jefferson County Pkwy.
Golden, CO 80401
(303) 271-6215
PEOPLE OF THE STATE OF COLORADO,
Plaintiff, v.
XXXXXX,
Defendant.
Attorney for Defendant:
Daniel N. Recht, #11569
Recht & Kornfeld, P.C.
1600 Stout Street, Suite 1000
Denver, CO 80202
(303) 573-1900
Fax: (303) 446-9400 admin@rechtkornfeld.com
COURT USE ONLY
Case Number: 06 CR
Div.: 3 Ctrm:
MOTION FOR IN-PERSON TESTIMONY OF LABORATORY TECHNICIAN(S)
COMES NOW, XXXXX, by and through his counsel of record Daniel N.
Recht of Recht and Kornfeld, P.C., and hereby respectfully requests this
Honorable Court Order the prosecution to produce for in-person testimony, pursuant to C.R.S. § 16-3-309(5) (2001), the employee or technician who accomplished any test result, analysis, comparison, identification or other criminalistics laboratory result which the prosecution seeks to introduce at any hearing or trial.
Respectfully submitted,
_______________________________
DANIEL N. RECHT #11569
Attorney for Defendant

CERTIFICATE OF SERVICE
I hereby certify that on this _____ day of January 2007, a true and correct copy of the foregoing MOTION FOR IN-PERSON TESTIMONY OF
LABORATORY TECHNICIAN(S) was placed in the United States Mail, correct postage prepaid, and addressed to the following:
Office of the District Attorney
Jefferson County Office
500 Jefferson County Pkwy.
Golden, CO 80401
_______________________________
PRACTICE NOTE:
THIS MOTION MUST BE ACCOMPANIED BY A LETTER TO THE
WITNESS – SEE, People v. Hinojas-Mendoza 03CA0645 (7/28/2003)
Sample Letter below:

December , 2006
Tony Steele
Phlebotomist
And
CDPHE – LS personnel who performed testing
Re: People v.
06CR
Dear ,
The defendant is charged in Douglas County with Sexual Assault and other charges. The discovery provided by the District Attorney indicates that you may be a witness in this matter. Pursuant to C.R.S. § 16-3-
309(5), the defendant hereby requests that you testify in person at the criminal trial on behalf of the state.
This case is currently set for trial in the district court, Div. of
Douglas County, Colorado on , 2006 at 8:30 a.m. Please be advised that criminal trials are often continued to a date subsequent to the currently scheduled trial date. You may want to contact the Deputy
District Attorney handling this case on a regular basis to confirm your appearance date and time.
This is a continuing request and will remain in effect until the conclusion of this case. This will be the only notice you receive.
Respectfully,
Daniel N. Recht
Defense Counsel