STATE OF NEW YORKCOUNTY COURTCOUNTY OF GENESEE-------------------------------------------------------------------XTHE PEOP...
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BILL OF PARTICULARS

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Transcript of "BILL OF PARTICULARS"

  1. 1. STATE OF NEW YORKCOUNTY COURTCOUNTY OF GENESEE-------------------------------------------------------------------XTHE PEOPLE OF THE STATE OF NEW YORK-against Indictment No. 5608CHRISTIAN J. NYKIANDefendant------------------------------------------------------------------XREQUEST FOR A BILL OF PARTICULARSI am the attorney of record for the accused CHRISTIAN J. NYKIAN. This request is made together with theaccompanying demand for discovery to help me prepare for trial. In order for CHRISTIAN J. NYKIAN todefend himself, it is necessary and essential to the defense that specific items of factual information, not recitedin the indictment. CHRISTIAN J. NYKIAN cannot adequately prepare or conduct his defense without theinformation requested. Pursuant to CPL §§ 100.45 and 200.95, I am requesting that you produce the followinginformation relating to the charges pending against CHRISTIAN J. NYKIAN.1. With respect to all charges, state:whether the prosecution intends to prove that CHRISTIAN J.NYKIAN.acted asa. principal, orb. accomplice, orc. both.2. State with sufficient specificity to understand the nature of the incident, and exactly where the incidentoccurred,Request is further made that any Bill of Particulars and/or any refusal to supply any of the requestedmaterial be made in writing setting forth the grounds for such refusal (CPL § 200.95(4)). A copy of suchwriting should be served upon the undersigned and filed with the Court within 15 days. Kindly serve theBill of Particulars requested and/or any refusals at my office.Dated: Buffalo, New York Respectfully Submitted,March 27th 2013J. John Sebastian, Attorney for DefendantTo: Genesee County District Atttorney by: ADA Melissa CianfriniClerk of Court

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