Below is an Informal Discovery Request template I've used in fighting traffic citations. To use it effectively, you need to insert your name, citation information, etc. and replace the Agency mailing addresses with the ones appropriate in your case. The mailing must give the prosecution at least 20 days to respond. Therefore, mail it at least 20 days before your trial date or deadline for submitting Trial By Declaration.

DATE: INSERT DATE HERE AND DA’S OFFICE WITH POLICE AGENCY BELOW

Ventura County District Attorney

800 S. Victoria Ave., Ventura, CA93009 805-654-2500

Ventura Police Department

4656 Valentine Rd., Ventura

Ventura, CA 93003

805-477-4174

INFORMAL DISCOVERY REQUEST Case # XXXXXXXXXXX Citation no. XXXXXXXX date: XXXXXXXXX, CVC XXXXXXXX

TO THE DISTRICT ATTORNEY FOR THE ABOVE-REFERENCED COUNTY, AND TO THE ABOVE-REFERENCED LAW ENFORCEMENT AGENCY:

I, XXXXXXXXXXXXXXXXXXX XXXXXXXXXXXXXX, represent myself in the above-referenced case. I hereby file this informal discovery request pursuant to Penal Code Sections 1054, 1054.5(b), and 19.7 and/or other applicable statutes. I am requesting disclosure and production of the following materials and information within fifteen (15) days of the date of service of this request. This request is for information and evidence that may be used in any trial (whether by declaration or in court) regarding the above referenced citation. All requests herein are made for information or evidence regardless of whether or not the prosecution intends to offer the particular information or evidence at trial. If there is to be any expense for the production of information or documents, please notify me at so that I may reimburse your office for such expense or so that I may make arrangements to inspect the documents and other evidence in the appropriate offices where they are located..

Information Requested

1. The names, job titles or job descriptions, and addresses of all persons who may offer statements, whether written or verbal, in any trial by declaration or court trial regarding the above alleged infraction.
2. Copies of the front and back sides of the officer’s citation copy and copies of any notes, recordings or other records made by the officer or by any person who may testify regarding the above alleged infraction.
3. Copies of the front and back side of any citation(s) written for the above alleged offense by the officer who issued the above referenced citation during the 30 day period immediately preceding the date of this alleged infraction (privacy information redacted).
4. A description or photograph of the vehicle driven by the officer at the time of the alleged infraction. A description should contain at a minimum, the color of the vehicle and the presence or absence of any markings indicating whether the vehicle is a law enforcement vehicle.
5. Any briefing sheets, memos, training material, or other information during the period for which records are available provided to Officers or Deputies of the above referenced Agency addressing policy regarding the number of citations to be issued by an officer or deputy within a specific time period as a measure of job performance. This would include any quote, suggested average, or any reference to the expected number of citations to be issued by Officers or Deputies.
6. Any such information relating to officer job performance evaluations conditional upon the number of citations issued by an individual officer.
7. Any job performance evaluation (privacy information redacted) issued within the past twelve (12) months by the above reference Agency to any officer or deputy when that evaluation was in whole or in part based on the number of citations issued by any such officer.
8. Any job performance evaluation issued to the officer or deputy involved in this case within the past twelve (12) months (privacy information redacted). 

The following is disclosed to you pursuant to Penal Code Sec. 1054.3:

A. Names and addresses of trial witnesses (other than defendant, who may or may not testify):

(x) None.

B. Relevant unprivileged written or recorded statements of witnesses or other evidence that may be presented by defendant:

(x) None.

Defendant asks that this request be treated as a continuing request through the completion of trial (whether by declaration or in court) and through the complete disposition of this case. Do not hesitate to contact me if I can be of assistance of any kind. Thank you for your attention in this matter.

Sincerely,                                                 Date:

_____________________          ____________

XXXXXXXXXXXXXXX XXXXXX

Defendant In Pro Per

ADDRESS

PHONE