DISTRICT COURT, ADAMS COUNTY, STATE OF COLORADO
1100 Judicial Center Drive
Brighton, CO 80601
Phone Number: (303) 659-1161
Plaintiff:
The People of the State of Colorado
? COURT USE ONLY ?
Defendant:
RICK STANLEY
Case Number: 03CR2971
THE REISCH LAW FIRM, LLC 03CR2956
R. Scott Reisch, #26892
Stacey L. Ross, #20823
370 Seventeenth Street, Suite 4970 Div.: Ctrm.:
Denver, CO 80202
Telephone: (303) 291-0555
FAX Number: (720) 904-5797
E-mail: rscottreisch@worldnet.att.net
BULL & DAVIES, P.C.
Brett Davies, #34175
812 Santa Fe Drive
Denver, CO 80204
Telephone: (303) 996-9815
MOTION FOR SPECIFIC DISCOVERY
COMES NOW the defendant, Rick Stanley, by and through his attorneys, and hereby moves the Court for an
Order, pursuant to Crim. P 16; Brady v. Maryland, 373 U.S. 83 (1963), and the Forth and Fourteenth
Amendments to the United States Constitution, requiring the district attorney to produce the following:
1. The e-mails and other postings from defendant's web site referred to in the "Affidavit and
Application for Arrest Warrant" in each of the above captioned cases which have not been provided
in discovery.
2. Copies of Court Orders, and corresponding applications for orders, authorizing the interception
of defendant's e-mail communications.
3. Roster lists of the Mutual Defense Pact Militia, and any surveillance notes,
records or recordings of the activities of the Mutual Defense Pact Militia made by any law enforcement
officer or agency.
4. Investigation file of Adams County Sheriff's Officer James McKenzie, including any
information that Officer McKenzie received from other law enforcement agencies regarding defendant.
According to the discovery, Officer McKenzie contacted Judges Marshall and Rose after defendant
filed the "Notice and Order." One of the central issues in the case is whether Judges Marshall and
Rose reasonably perceived the Notice and Order to be a true threat. Defendant believes that the
reaction of Judges Marshall and Rose was, to some degree influenced by information conveyed to them
by Officer McKenzie. Defendant believes that the investigation file contains potentially exculpatory
or impeaching information that is material and discoverable under Rule 16 and Brady.
5. Notes taken by James McKenzie of interviews of Judges Marshall and Rose.
6. All information relied upon by law enforcement agents when informing Judges Rose and Marshall of
Rick Stanley and the Mutual Defense Pact Militia, including but not limited to any "spy file" maintained
by the Denver Police Department Intelligence Bureau and any documents maintained by the Homeland Security
Task Force.
7. Notes and investigation file of Dan Estep, Jefferson County Sheriff's Office regarding investigation
of Defendant and/or the Mutual Defense Pact Militia.
WHEREFORE, defendant requests that this motion be granted.
Respectfully submitted this ______ day of March, 2004.
__________________________________
R. Scott Reisch
Stacey L. Ross
Brett Davies
CERTIFICATE OF SERVICE
I do hereby certify that on the ____ day of March, 2004, I ? deposited in the U.S. Mail, or ? sent via
facsimile to the following number: ___________ or ? hand delivered the foregoing Motion for Specific
Discovery to the following:
Mark Warner
Deputy District Attorney
District Attorney's Office
450 S. 4th Ave.
Brighton, CO 80601
