STATE OF NORTH CAROLINA

COUNTY OF STANLY

IN THE GENERAL COURT OF JUSTICE

SUPERIOR COURT DIVISION

FILE NO.:

 

 

                          

                                                      )

STATE OF NORTH CAROLINA              )

                                                      )        MOTION FOR FUNDS TO  

vs.                                                   )        FACILITATE DISCOVERY

                                                      )

Bobby Richard Taylor, III                      )

                                    Defendant     )

                                                      )

 

         NOW COMES THE STATE OF NORTH CAROLINA, by and through the undersigned Assistant District Attorney for the Twentieth Prosecutorial District of North Carolina, and Moves the Court for funds to expedite discovery in the above referenced matter.  In support of said Motion, the State shows the Court the following:

 

1.       William Henry “Billy” Huddleston, III was a 12 year old boy living in Stanly County at the time of his disappearance on Tuesday, 25 July 2000 from Oakboro, North Carolina; and,

 

2.       The search for Billy was conducted by, among others, the North Carolina State Bureau of Investigation, the Stanly County Sheriff’s Office and the Oakboro Police Department and continued until Friday, 28 July 2000; and,

 

3.       On Friday, 28 July 2000, Billy’s decomposed body was found in Union County; and,

 

4.       Billy’s body was autopsied at the Medical Examiner’s Office in Chapel Hill, North Carolina; and,

 

5.       The Union County Sheriff’s Office joined the investigation into Billy’s disappearance which continued as a murder investigation; and,

 

6.       At least four agencies participated in the investigation of Billy’s murder, they have followed numerous tips, conducted many interviews, examined two crime scenes, executed two search warrants and seized evidence, and are currently conducting laboratory tests on evidence seized during the investigation and the investigation is still continuing; and,

 

7.       Although the SBI report has not yet been dictated, the lead SBI investigator estimates the final report could be several thousand pages; and,

 

8.       The State has set a trial date for July 2001 and anticipates complying with discovery before January 2001; and,

 

9.       The material the State anticipates turning over to the Defendant during discovery is so voluminous that it would create an undue burden on the District Attorney’s office staff and equipment to photocopy so much material; and,

 

10.     Private photocopying businesses now exist in Stanly County which could photocopy such a large amount of material quickly, efficiently and at a reasonable cost; and,

 

11.     The State has previously used OfficeMax #911, 619 NC Hwy. 24/27 Bypass East, Albemarle, North Carolina 28001 for such voluminous photocopying in previous murder cases in Stanly County and has found their services to be exceptional.  

 

         WHEREFORE THE STATE PRAYS that the Court Order that: 

 

1.       When the State is ready to comply with discovery in the above case, that the State be allowed to employ OfficeMax #911, 619 NC Hwy. 24/27 Bypass East, Albemarle, North Carolina 28001 to photocopy the materials which are to be turned over to the defendant during discovery in the above captioned case; and,

 

2.       That OfficeMax shall be required to execute a confidentiality agreement and non-disclosure statement prior to beginning the photocopying of discoverable material; and,

 

3.       That the cost of such photocopying, not to exceed $1000.00, absent additional findings and orders of the Court, be paid by the Administrative Office of the Courts. 

 

 

         This the _____ day of ______________________, 20_____.

 

 

 

 

                                                      ____________________________________

                                                      Michael D. Parker

                                                      Chief Assistant District Attorney

                                                      20^th Prosecutorial District

                                                      Post Office Box 1065

                                                      Monroe, North Carolina 28111-1065

                                                      (704) 289-3340