Julia Keen
Solicitor

175 Liverpool Street,
Sydney
DX 9999 Sydney Downtown
Telephone 9267 1234
Fax 9267 1234

1 February 2002

The Director of Public Prosecutions,
DX 11525
Sydney Downtown

Dear Sir,

Re: Regina v Bloggs
District Court File No. 02/11/0391

I act for the accused in this matter.

I request that you provide me with the following documents and particulars:

1. Please provide me with a copy of the draft indictment.

2. Please provide me with a list of the witnesses whom the Crown intends to call, if possible in the order in which they will be called.

3. Please provide me with photocopies of any documents which the Crown proposes to tender, [and any documentary exhibits from the committal].

4. Please provide me with colour photocopies of any photographs which the Crown proposes to tender.

5. Please provide me with the following particulars [in relation to each count on the indictment]:

(in an indictment for sexual assault or indecent assault)

a. when is it alleged that the offence was committed
b. where is it alleged that the offence was committed
c. what act of the accused is it alleged constituted the sexual assault/indecent assault (please also refer to the relevant paragraph number of the complainant's statement).

(in an indictment for conspiracy)

a. what is it alleged was the precise scope of the conspiracy
b. what overt acts does the Crown rely upon

(in an indictment for manslaughter)

Please specify the basis upon which it is alleged that the accused is guilty of manslaughter.

If the Crown is relying on an alleged unlawful and dangerous act, what is the alleged unlawful and dangerous act?

If the Crown is relying on criminal negligence, what is the alleged act of criminal negligence?

(in an indictment for supply prohibited drug)

Please specify the basis upon which it is alleged that the accused is guilty of the offence of supply prohibited drug.

(in an indictment for manufacture prohibited drug)

a. Please specify what act or acts of the accused alleged to consitute the offence of manufacture prohibited drug

b. If it is alleged that the accused participated in a step in the manufacture of a prohibited drug, please specify what step in the manufacture of a prohibited drug is relied upon.

(in an indictment for dangerous driving occasioning death/grievous bodily harm)

a. Does the Crown allege that the accused was

i. driving in a manner dangerous to the public
ii. driving at a speed dangerous to the public
iii. driving under the influence of alcohol or drugs

b. If the Crown alleges that the accused was driving in a manner dangerous to the public, please specify what conduct of the accused is alleged to constitute the driving in a manner dangerous to the public.

(in an indictment for accessory after the fact)

Please specify the act or acts of the accused, alleged to constitute the offence of accessory after the fact.

I look forward to hearing from you soon.

Yours faithfully,

Julia Keen
Solicitor