Discovery Review Tracker

# Discovery Review Tracker

Builds a working tracker of criminal discovery for the defense: every item expected, what has arrived, what's still outstanding, and what to follow up on and when.

## What to ask for
- The prosecution's discovery cover letters, index or production log (with Bates ranges).
- The police report and supplements (they reference items that should exist).
- Prior discovery requests, informal letters, and any motions to compel or court orders on discovery.
- Charges, case number, court, next hearing date and trial date if set.
- Jurisdiction (state and county, or federal district).
- If something is missing, build the tracker anyway and mark each gap as [MISSING: ...]. Never mark an item received without a source.

## How to work
1. **Build the expected list.** Start from the standard categories, then add every item the reports reference (a second officer's bodycam, a photo lineup, a search warrant, a lab request, a recorded interview):
   - Police reports, supplements, arrest and booking records
   - Bodycam and dashcam for every officer present
   - 911 calls and CAD/dispatch logs, radio traffic
   - Search and arrest warrants with affidavits and returns
   - Photos, video (surveillance, cellphone), scene diagrams
   - Physical evidence and property logs, chain-of-custody records
   - Lab reports, bench notes, analyst credentials, instrument calibration and maintenance records (breath, blood, drugs, DNA)
   - The client's statements (written, recorded, oral as summarized)
   - Co-defendant and witness statements, interview recordings
   - Identification procedures and documentation
   - Criminal histories of prosecution witnesses
   - Brady and impeachment material: deals, benefits or payments to witnesses, informant files, officer discipline or credibility records, inconsistent statements, exculpatory lab results
   - Expert reports and CVs
   - Phone extractions, social media returns, subpoenaed records
2. **Match to production.** For each item: produced or not, Bates range, date received, and whether it's complete (e.g. bodycam that starts mid-encounter, redacted pages, missing audio).
3. **Flag outstanding.** Each missing item with the date first requested, how (letter, email, motion), and the next follow-up date. Prioritize what matters for motions and trial.
4. **Preservation.** Flag items at risk of being overwritten or purged (video retention windows, 911 recordings, jail calls) and whether a preservation letter was sent (To verify retention periods).
5. **Brady and impeachment.** List separately with the specific request made. Note that disclosure obligations are continuing.
6. **Deadlines.** Discovery and motion deadlines from the court or rules, each marked To verify.

## Output

**Discovery Tracker: [Client] / [Case no.]**  Updated: [date]  Next hearing: [date]

1. **Status summary** (3-4 lines: received count, outstanding count, top three priorities)
2. **Tracker** table: # | Category | Item | Source/reference | Date requested | Method | Date received | Bates range | Complete? | Follow-up date | Notes
3. **Outstanding, by priority** (numbered, with the reason it matters)
4. **Brady / impeachment requests** table: Item | Basis for request | Date requested | Response | Follow-up
5. **Preservation** table: Item | Retention risk | Preservation letter sent? | Date
6. **Draft follow-up request** (short letter or email to the prosecutor listing outstanding items, for the attorney to edit)
7. **Gaps** ([MISSING] items)
8. **To verify** (discovery rules and deadlines, reciprocal discovery obligations, retention periods for video and 911, motion-to-compel timing, protective order limits)

## Rules
- Draft for attorney review; not legal advice.
- Discovery deadlines, reciprocal obligations and retention periods vary by jurisdiction and change: list them under "To verify", never state them as final.
- Never invent items, dates or Bates numbers. Unknown = [MISSING].
- Never mark an item received or complete without the production that shows it.
- Note any protective order on discovery and keep restricted material out of anything sent to the client.