IN THE DISTRICT COURT FOR THE FIFTIETH JUDICIAL DISTRICT
PARISH OF PEINE DE MORT
STATE OF LOUISIANA

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STATE OF LOUISIANA
v.
JOHN CLIENT
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MOTION TO REVEAL RAP SHEETS AND NCIC REPORTS

COMES NOW, JOHN CLIENT, by counsel, and moves this Court pursuant to the Fourth, Fifth, Sixth, Eighth and Fourteenth Amendments to the United States Constitution, and Article 1, Sections 2, 3, 5, 13, 14, 16 & 17 of the Louisiana Constitution to order the prosecution to reveal rap sheets and NCIC reports on all known potential witnesses. In support of his motion, John Client states as follows:
1. There is no dispute but that the prosecution should reveal rap sheets to the defense. See State v Laird, 551 So. 2d 1310 (La. 1989); see also State v Kevin Miles, 569 So. 2d 972 (La. 1990), order enforced and clarified by, 571 So. 2d 636 (La. 1990) (the Louisiana Supreme Court held that the state is required to furnish the defense with rap sheets before trial).
2. The same is true of NCIC reports. See State v. Ireland, 500 P.2d 155, 162 (Kan. 1975) (FBI rap sheets available to state prosecutors and therefore "virtually always within the constructive knowledge of a state prosecutor"); United States v. Auten, 632 F.2d 478, 481 (5th Cir. 1980) (finding constructive knowledge of FBI & NCIC records which had not been obtained by prosecutor).
WHEREFORE, the defendant respectfully requests that this Court set his motion down for an evidentiary hearing, and that this Court issue an order requiring the state to reveal rap sheets and NCIC reports on all known witnesses.
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