TO:     District Attorney for Eau Claire County
                721 Oxford Avenue
                Eau Claire, WI 54703

The defendant, appearing specially by her attorney and reserving her right to challenge the court's jurisdiction, pursuant to secs. 971.23 Stats.; the 5th, 6th, and 14th Amendments to the United States Constitution, and article I. sections 1, 7, and 8 of the Wisconsin Constitution, demands that the district attorney provide disclosure, discovery and inspection of the items listed below, and permit her attorney to inspect and copy or photograph all of the following materials and information, if it is within the possession, custody or control of the state:

1.    Any written or recorded statement concerning the alleged crime made by the defendant, including the testimony of the defendant in a secret proceeding under sec. 968.26 or before a grand jury, and the names of witnesses to the defendant's written statements, pursuant to sec. 971.23(1) (a), Stats.

2.    A written summary of all oral statements of the defendant which the district attorney plans to use in the course of the trial and the names of witnesses to the defendant's oral statements, pursuant to sec. 971.23(1) (b), Stats.

3.    Evidence obtained in the manner described under sec. 968.31(2) (b), if the district attorney intends to use the evidence at trial, pursuant to sec. 971.23(1) (bm), Stats.

4.    A copy of the defendant's criminal record, pursuant to sec. 971.23(1) (c), Stats.

5.    A list of all witnesses and their addresses whom the district attorney intends to call at trial, pursuant to sec. 971.23(1) (d), Stats.

6.    Any relevant written or recorded statements of a witness named on a list under paragraph 5., including any audiovisual recording of an oral statement of a child under sec. 908.08, any reports or statements of experts made in connection with the case or, if an expert does not prepare a report or statement, a written summary of the expert's findings or the subject matter of his or her testimony, and scientific test, experiment or comparison that the district attorney intends to offer in evidence at trial, pursuant to sec. 971.23(1) (e), Stats.

7.    The criminal record of a prosecution witness which is known to the district attorney, pursuant to sec. 971.23(1) (f), Stats.

8.    Any physical evidence that the district attorney intends to offer in evidence at trial, pursuant to sec. 971.23(1) (g), Stats.

9.    Any exculpatory evidence, pursuant to sec. 971.23(1) (h), Stats.

10.  Notice of any conduct of the defendant the state intends to introduce as an implied admission or as proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident pursuant to sec. 904.04, 908.03, or 908.045. Stats., pursuant to Whitty v. State, 34 Wis. 2d 278, 149 N.W. 2nd 557 (1967), cert. denied; 390 U.S. 959 (1968).

11.    The names and addresses of all persons known to the state to have witnessed any matter related to this case, whether or not the state intends to call them as witnesses at any hearing or trial in this case, pursuant to Brady v. Maryland, 373 U.S. 83 (1963); State v. Simmons, 57 Wis. 2d 285, 203 N.W.2d 887 (1973); Nelson v. State, 59 Wis. 2d 474, 208 N.W.2d 410 (1973).

12.    Copies of all written, recorded, or videotaped statements and a summary of any oral statements made by witnesses, including but not limited to copies of all police reports, showups, notebooks, memo books, and all other documents prepared by the witnesses, whether or not the state intends to call them to testify at any hearing or trial in this case, pursuant to State v. Groh, 69 Wis. 2d 481, 230 N.W.2d 735, cert. denied, 423 U.S. 986 (1975); State v. Van Ark, 62 Wis. 2d 155, 215 N.W.2d 41 (1974); Simos v. State, 53 Wis. 2d 493, 192 N.W.2d 877 (1972).

13.    Copies of any written or recorded statements and a summary of any oral statements made by any accomplice, coconspirator, or codefendant in connection with this case, sec 971.24(1), Stats., pursuant to Bruton v. United States, 391 U.S. 123 (1968); Brady v. Maryland, 373 U.S. 83 (1963); State v. Groh, 69 Wis. 2d 481, 230 N.W.2d 745, cert, denied, 423 U.S. 986 (1975); State v. van Ark, 62 Wis. 2d 155, 215 N.W.2d 41 (1974); Nelson v. State, 59 Wis. 2d 474, 208 N.W.2nd 410 (1973); Simos v. State, 53 Wis. 2d 493, 192 N.W.2d 877 (1972).

14.    Disclosure of any promises, rewards, or inducements made in connection with this case either explicitly or implicitly, directly or indirectly, to any person or persons by the state or its agents or by any other person or group, including but not limited to hot lines, crime lines, and tip lines, pursuant to Gigliio v. United States, 405 U.S. 150 (1972); Ruiz v. State, 75 Wis. 2d 230, 249 N.W.2d 277 (1977).

15.    copies of all reports or statements of experts made in connection with this case, including but not limited to the results of any physical, medical, or mental examinations and of scientific tests, experiments, or comparisons, pursuant to Brady v. Maryland, 373 U.S. 83 (1963); State v. Simmons, 57 Wis. 2d 285, 203 N.W.2d 887 (1973); Nelson v. State, 59 Wis. 2d 474, 208 N.W.2d 410 (1973).

16.    Copies of all photographs of the defendant and any other persons used in any identification or attempted identification procedure in this case, including photographs of all persons picked out by witnesses in this case, whether or not the defendant took part; the names and addresses of any witnesses to any lineup or showup; and the name and address of any person identified in those identification procedures pursuant to Simmons v. United States, 390 U.S. 377 (1968).

17.    An inventory and copies of all books, papers, documents, photographs, and tangible objects related to this case that the state has within its possession, knowledge, or control or that were obtained from or belong to the defendant, together with the date, time, place, and manner in which these items were obtained under sec. 968.17, Stats.

18.    Any relevant material or information that has been provided by any informant, including the informant's identify, pursuant to McCray v. Illinois, 386 U.S. 300 (1967); Roviaro v. United States, 353 U.S. 53 (1957).

19.    All information concerning any electronic surveillance of the defendant's person or premises, under secs. 968.27-.37.

20.    All exculpatory evidence, including laboratory reports, hospital records or reports, police reports, or any other information within the state's possession, knowledge, or control, that would tend to negate the defendant's guilt, pursuant to Brady v. Maryland, 373 U.S. 83 (1963); State v. Stanislawski, 62 Wis. 2d 730, 216 N.W.2d 8 (1963); Nelson v. State, 58 Wis. 2d 474, 208 N.W.2d 410 (1973).

21.    All exculpatory evidence, including laboratory reports, hospital records or reports, police reports, or any other information within the state's possession, knowledge, or control, that would tend to affect the weight and credibility of evidence used against the defendant, pursuant to Giglio v. United States, 405 U.S. 150 (1972); Ruiz v. State, 75 Wis. 2d 230, 249 N.W.2d 277 (1977); State v. Stanislawski, 62 Wis. 2d 730, 216 N.W.2d 8 (1974).

22.    All exculpatory evidence, including laboratory reports, hospital records or reports, police reports, or any other information within the state's possession, knowledge, or control, that would extenuate, mitigate, or reduce the degree of the offense charged or the defendant's punishment for the offense, pursuant to Ruiz v. State, 75 Wis. 2d 230, 249 N.W.2d 277 (1977); State v. Stanislawski, 62 Wis. 2d 730, 216 N.W.2d 8 (1974).

23.    All exculpatory evidence, including laboratory reports, hospital records or reports, police reports, or any other information within the state's possession, knowledge, or control, that could form the basis for further investigation by the defense, pursuant to Brady v. Maryland, 373 U.S. 83 (1963); Ruiz v. State, 75 Wis. 2d 230, 216 N.W.2d 277 (1977); State v. Stanislawski, 62 Wis. 2d 730, 216 N.W.2d 8 (1974).

Dated January 19, 2007
/s/
Bryon J. Walker
Attorney at Law
State Bar # 01001112
101 North State Street, Suite 3
PO Box 10
La Farge, Wisconsin 54639
(608)  625-4321

KAY LEE'S CASE NUMBER 07 CM 69

EMAIL  Kay Lee