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11/04/19 DEMAND FOR DISCOVERY AND BILL OF PARTICULARS (Michael Miller-EL Matter)

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17 USC § 107 Limitations on Exclusive Rights – FAIR USE

UPDATE On Michael Miller-EL
https://www.slideshare.net/VogelDenise/110219-reminder-of-110419-pretrial-hearing-reminder-michael-miller-el

$100,000.00 CASH/SURETY/PROP. Bond was REDUCED To
$2,500.00 PERSONAL Bond

A GOVERNMENT SETUP:
COURT-Appointed Attorney (Jonathan McDonald) who WORKS for the Government and IS PAID by the Government to represent Michael Miller-EL files a “DEMAND FOR DISCOVERY AND BILL OF PARTICULARS”

Pursuant to the Ohio Rules of Criminal Procedures (Rule 12) [and other applicable Statutes/Laws governing such matters] rather than file this FRIVOLOUS Motion to FRAME Michael Miller-EL, the JURISDICTIONAL Defense was to be made instead of this FRIVOLOUS Motion by McDonald to SETUP Miller-EL to have him ENSLAVED as a “BLACK” Man… - i.e. when he is NOT Black – and in keeping with the USA’s BLACK Codes “SLAVERY Agendas!”

United States of America’s 21st Century EFFORTS TO COVERUP WAR CRIMES - - - TRICK OF WORDS/WORD GAMES: “Slaves” Has Been REPLACED With “BLACK” - - - Black Codes were part of a larger pattern of whites trying to maintain political dominance and suppress the freedmen, newly emancipated African-American slaves. Black codes were essentially replacements for slave codes in those states. Before the war, Northern states that had prohibited slavery also enacted Black Codes: Connecticut, OHIO, Illinois, Indiana, Michigan, and New York enacted laws to DISCOURAGE free blacks from residing in those states.

https://en.wikipedia.org/wiki/Black_Codes_(United_States)


The Government will NOW attempt to assert that Miller-EL is represented by Counsel and BOUND by McDonald’s Criminal Acts. However, that is NOT the case and not only can the “DIRTY-HAND Policy” be applied here, the OBJECT of the Conspiracies leveled against Michael Miller-EL to COVER UP the United States of America’s Racketeering Enslavement Empire’s WAR Crimes…ENFORCERS roles can be PROVEN through EVIDENCE!

DISMISS the FRIVOLOUS Criminal Charges against the STRAWMAN – i.e. alleged to be Michael Miller-EL!


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11/04/19 DEMAND FOR DISCOVERY AND BILL OF PARTICULARS (Michael Miller-EL Matter)

  1. 1. DEMAND FOR DISCOVERY AND BILL OF PARTICULARS CUYAHOGA COUNTY COURT OF COMMON PLEAS Case No. CR 19-641058-A A GOVERNMENT SETUP EXPOSING UNITED STATES OF AMERICA’S FRAUDULENT JUDICIAL RACKETEERING ENSLAVEMENT EMPIRE QUESTION: WHY WAS THIS COURT DOCUMENT FILED BY A “COURT-APPOINTED ATTORNEY…” WHEN RECORD EVIDENCE SUPPORTS COURT LACKS JURISDICTION? DISMISSAL OF CRIMINAL CHARGES SHOULD HAVE BEEN SOUGHT and GRANTED and CRIMINAL ACTS OF JUDICIAL OFFICIALS/COURT OFFICIALS/COUNTY OFFICIALS… REPORTED 17 USC § 107 Limitations on Exclusive Rights – FAIR USE
  2. 2. Motion No. 4823329 THE STATE OF OHIO vs. MICHAEL MILLER-EL NAILAH K. BYRD CUYAHOGA COUNTY CLERK OF COURTS 1200 Ontario Street Cleveland, Ohio 44113 Court of Common Pleas MOTION FOR DISCOVERY November 4,2019 15:17 By: JONATHAN M. MCDONALD 0090425 Confirmation Nbr. 1860184 CR 19 641058-A Judge: REEVE KELSEY Pages Filed: 5 Electronically Filed 11/04/2019 15:17 / MOTION / CR 19 641058-A/Confirmation Nbr. 1860184 / CLSXD
  3. 3. IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO CRIMINAL DIVISION MICHAEL MILLER-EL STATE OF OHIO, - vs - Defendant. Plaintiff, ) ) ) ) ) ) ) ) ) JUDGE REEVE KELSEY CASE NO. CR 19-641058-A DEMAND FOR DISCOVERY AND BILL OF PARTICULARS NOW COMES Defendant Michael Miller-El (hereafter “Mr. Miller-El”) by and through the attorneys at McDonald Humphrey, LLC and the undersigned counsel and respectfully makes demands pursuant to Rule 16 ofthe Ohio Rules ofCriminal Procedure, Rule 23.1 ofthe Cuyahoga County Common Pleas Local Court Rules of Court, and the Sixth and Fourteenth Amendments to the United States Constitution, all those matters discoverable including but not limited to, the following information, and this demand shall be deemed continuing in nature: 1. Statement of defendant or codefendant [Crim. R. 16(B)(1) & Local Rule 23.1(B)(2)]; a. Any written or recorded statement by Mr. Miller-El or a co-Defendant, including police summaries ofsuch statements, and including grandjury testimony by either Mr. Miller-El or co-Defendant. 2. Prior criminal record(s) of defendant, codefendant, and witnesses [Crim. R 16(B)(2) & Local Rule 23.1(B)(5)]; a. Complete criminal record ofMr. Miller-El, co-defendants, and the criminal record of any witness associates with the instant matter pursuant to Local Rule 23.1(B)(5). Witness includes any person who has or claims to have knowledge or is believed to have knowledge concerning a fact or facts about the issues involved in this criminal action or proceeding or about the credibility of another witness, irrespective of whether the State intends to call such person as a witness at trial. See generally 4 O.J.I. §521.04. Concerning the criminal record of a “witness”, the instant request includes information pertaining to prior felony convictions Electronically Filed 11/04/2019 15:17 / MOTION / CR 19 641058-A / Confirmation Nbr. 1860184 / CLSXD
  4. 4. under Crim. R. 16(B)(2) as well as any other criminal record pursuant to Local Rule 23.1(B)(5). 3. Documents and tangible objects [Crim. R. 16(B)(3)]; a. All laboratory or hospital reports, books, papers, documents, photographs, tangible objects, buildings, places, and any and all video/audio recordings (including, but not limited to, wearable camera system footage and dash camera footage) which are related to the indictment, information or complaint in the above captioned matter, or its investigation. This includes copies of all recordings of radio transmissions between all police vehicles and dispatch, radio transmissions between police vehicles, emergency response calls, 911 correspondences, other telephone communications, all wearable body camera video, all dashboard camera video, all audio or video recordings of Mr. Miller-El, co-Defendant and/or witnesses during police encounters with them including, but not limited to, during questioning, transporting, booking, interrogating, and jail processing. 4. Reports of examination and/or tests [Crim. R. 16(B)(4) & Local Rule 23.1(B)(4)]; a. Any reports or results of physical or mental examination, and of scientific experiments and/or tests, made in connection with the above captioned case or copies thereof, available to, or within the possession, custody or control of the State or reasonable available to the State, the existence of which is known or by the existence of due diligence may become known to the prosecuting attorney. Mr. Miller-El further requests that any and all laboratory and hospital reports, or copies thereof, associated with the above captioned matter be remitted forthwith pursuant to Local Rule 23.1(B)(4). 5. Evidence favorable to Defendant [Crim. R. 16(B)(5) & U.S. Const. Amends. VI and XIV]; a. Any evidence or information known or which may become known to the prosecuting attorney which may be favorable to Mr. Miller-El or which could be used to obtain evidence favorable to Mr. Miller-E, including information or evidence which could be used to obtain evidence that would diminish the credibility of any State’s witness, as well as material relevant to either guilt or punishment. This includes without limitation, any written or oral statements of police officers or other persons having knowledge of the facts and circumstances of either the offense, the state’s witnesses, or events leading up to the events involved in this offense or statements, either oral or written, that may impeach the testimony of a witness such as conflicting statements made by a witness or statements that conflict with statements made by witnesses, recantations of any statement made by a witness, plea bargains, pardons, grants of clemency, grants of immunity, informal of formal promises to speak on behalf of another in a legal proceeding, whether such accommodations have been extended on behalf of the witness or on behalf of a family member, friend or associate ofthe witness. 6. Peace officer, OS1IP, and federal law reports [Crim. R. 16(B)(6) & Local Rule 23.1(B)(1)] Electronically Filed 11/04/2019 15:17 / MOTION / CR 19 641058-A / Confirmation Nbr. 1860184 / CLSXD MM CR19641058-A 2
  5. 5. a. All police reports from peace officers, the Ohio State Highway Patrol, and/or federal law enforcement agents, both original and supplemental, the existence of which may be known or may become known to the prosecuting attorney and that are associated with the above captioned matter, including, but not limited to, any and all police reports, and/or Federal Bureau of Investigation (FBI) reports (including any and all FBI Form 302s). 7. Witness names and addresses [Crim. R. 16(1) and Local Rule 23.1(B)(3)]; a. A written list ofthe names and addresses of all witnesses that the State intends to call at trial either in its case-in-chief, or that it reasonably anticipates calling as a rebuttal or surrebuttal witness. 8. Witness statements [Crim. R. 16(B)(7) & Local Rule 23.1(B)(2)]; a. Any written or recorded statements, or copies thereof, and any written summaries of any oral statements or copies thereof, made by a witness to a prosecuting attorney or to any law enforcement officer. For purposes of this request, a “witness” shall include any person who has or claims to have knowledge or is believed to have knowledge concerning a fact or facts about the issue(s) involved in this criminal action or proceeding or about the credibility of another witness, irrespective of whether the State intends to call such person as a witness at trial. See generally 4 O.J.I. §521.04. 9. Expert Witness; Reports [Crim. R. 16(K)]; a. All written reports summarizing an expert witness’s testimony, findings, analysis, conclusion, or opinion, including a summary of the expert’s qualifications, and including any communications between government counsel and the expert witness that: (a) relate to the compensation for the expert’s study or testimony; (b) identify facts or data that the government’s attorney provided and that the expert considered in forming the opinions to be expressed; and (c) identify assumptions that the government’s attorney provided and that the expert relied on in forming the opinions to be expressed. Additionally, Mr. Miller-El hereby demands, pursuant to Crim. R. 16(A) that the prosecuting attorney exercise reasonable diligence to investigate and obtain the items requested herein which are available to, within the possession, custody, or control of the State, or any of its agents or officers, or known to or by exercise of due diligence may become known to the prosecuting attorney. Mr. Miller-El specifically requests, pursuant to Crim. R. 12(E), that the items requested herein be preserved by the State for use by Mr. Miller-El in preparing the defense. Mr. Miller-El hereby puts the State on notice that the specifically requested items are exculpatory Electronically Filed 11/04/2019 15:17 / MOTION / CR 19 641058-A / Confirmation Nbr. 1860184 / CLSXD MM CR19641058-A 3
  6. 6. or will provide evidence essential to Mr. Miller-El in preparing the defense or would reasonably lead to evidence favorable to Mr. Miller-El and relevant to guilty or punishment. Mr. Miller-El understands and agrees that reciprocal discovery shall be made pursuant to Criminal Rule 16. In an effort to save unnecessary cost of service and expedite the exchange of discovery, I agree to waive the procedure for service of discovery requests and responses upon the parties in this matter set forth under Ohio Rules of Procedure and the local rules of Cuyahoga County Court of Common Pleas. Respectfully submitted, MCDONALD HUMPHREY LAW, LLC JONATHAN M. MCDONALD (#0090425) 1220 W. 6th Street, Suite 203 Cleveland, Ohio 44113 Phone: (216) 298.9111 | Fax: (216) 320.8107 Email: jonathan@mcdonaldhumphrey.com Attorneyfor Mr. Miller-El Electronically Filed 11/04/2019 15:17 / MOTION I CR 19 641058-A / Confirmation Nbr. 1860184 I CLSXD MM CR19641058-A 4
  7. 7. CERTIFICATE OF SERVICE I certify that a true and accurate copy of the above motion has been sent to the Cuyahoga County Prosecutor’s Office this 4th day ofNovember 2019 by the Court’s electronic filing system. Respectfully submitted, MCDONALD HUMPHREY LAW, LLC JONATHAN M. MCDONALD (#0090425) 1220 W. 6th Street, Suite 203 Cleveland, Ohio 44113 Phone: (216) 298.9111 | Fax: (216) 320.8107 Email: jonathan@mcdonaldhumphrey.com Attorneyfor Mr. Miller-El Electronically Filed 11/04/2019 15:17 / MOTION I CR 19 641058-A / Confirmation Nbr. 1860184 I CLSXD MM CR19641058-A 5

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