EXHIBIT

 
 
 
 

i

   

STATE OF MARYLAND IN TIIE
V. CIRCUIT COURT
KERRON ANDREWS FOR
CASE NOS.: 114149007-9 BALTIMORE CITY
9: v: 9: 9: a: i:

RESPONSE TO MOTION FOR DISCOVERY
Now comes the State of Maryland, by Marilyn Mosby, State?s Attorney for Baltimore
City and Katie M. O?Hara, ID 623250, Assistant State?s Attorney, and pursuant to Rule 4-263 of
the Magland Rules of Procedure, responds to the Defendant?s request for discovery, disclosure,
and procedural motions as follows:

1. The State does not possess any documents or notes related to Su3pect Det.
Converse will testify that the witnesses told Det. Converse that this second person merely
stood by and didn?t participate in the crime. Additionally, he would testify that the
Defendant gave a physical description of this person only, that that description mirrored
the Defendant?s own physical description, and did not provide detectives with any other
information about this person that would allow the detectives to identify him.

2. The State does not at this time possess any documents related to neighborhood
canvasses. Det. Converse will check with his colleagues to determine if there is anything
outstanding in this regard and if so, will produce it to the State to be produced to the
Defense.

3. Det. Converse will forward all information related to any identi?cation and/or tracking
of phone number 443?208-2776. When it is received the State will disclose same.

4. The State previously disclosed phone records related to 410-830-0312. Anything
further related to that or anything related to 443-415-8960 will be disclosed upon receipt
from Det. Converse.

5. The State does not at this time possess information related to the method used to
locate the Defendant at 5302 Clifton Ave. The State will forward that information upon
receipt.

6. The subject vehicle belongs to the Victim?s mother. Disclosure of the requested
information would lead to the disclosure of shielded information. The State will not

disclose shielded information including contact information of the victim and witnesses
in this case without a Court order to that effect.

7. There does not exist a document indicating the order of entry of of?cers into 5302
Clifton Ave.

3. The State will furnish criminal history of the requested individuals as soon as it is
available.

9. The victims and witnesses in this matter have requested that their contact information

remain shielded. The State will not disclose that shielded information without a Court
order to that effect.

submitted,

Marilyn Mesby
State?s Attorney for Baltimore City

 

Katie M. O?Hara (#623250)

Assistant State?s Attorney

Of?ce of the State?s Attorney for Baltimore City
120 E. Baltimore Street, 9lh Floor

Baltimore, Maryland 21202

(443) 984-6199 (telephone)
kohara@5tattorney.0rg

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 7th day of JAN, 2015, a c0py this ReSponse was
mailed via interol'fice mailing:

Deborah K. Levi
Of?ce of the Public Defender

Marilyn Mosby
State?s Attorney for Baltimore City

Katie M. O?Hara (#623250)

Assistant State?s Attorney

Of?ce of the State?s Attorney for Baltimore City
120 E. Baltimore Street, 9th Floor

Baltimore, Maryland 21202

(443) 984-6199 (telephone)

kohara@startomey. org