STATE OF GEORGIA

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In the interest of:    | Case number 123456

                       | Judge_______________

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MOTION FOR DISCOVERY

The Child, insert name, by a through his authorized counsel, files this motion for Discovery as provided by O.C.G.A. §17-16-1 through 17-16-4 to wit:

1. a copy of any statement given by the Child while in police custody pursuant to O.C.G.A. § 17-16-4(a)(1) together with statements of co-conspirators that are attibutable to the Child and arguably admissible against the Child at trial
2. a complete copy of any written scientific reports in the possession of the prosecution which will be introduced in whole or in part by the prosecution in its case-in chief or in rebuttal pursuant to O.C.G.A. § 17-16-4(a), including a summary of the basis for the expert opinion rendered in the report.
3. a complete copy of any statement made by any witness plus a summary of the substance of any statement made by any witness contained in any memorandum, report, or other type of written document whether signed or otherwise adopted by the witness, pursuant to O.C.G.A. § 17-16-1(20(c).

WHEREFORE, the Child prays that a copy of any statement given by the Child while in police custody, a copy of any statement by any witness, and a complete copy of any written scientific reports in the possessionof the prosecution which will be introduces in whole or in part by the prosecution in its case-in-chief or in rebuttal be provided to his counsel.

Respectfully submitted,