# Discovery Request — Draft Template

**Case:** State v. Matthew James McAchran, 26CR302000-330
**Filed under:** G.S. 15A-902 (Discovery in District Court)
**To:** District Attorney, Prosecutorial District 31, Forsyth County

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## Items Requested

| # | Item | Description | Basis |
|---|------|-------------|-------|
| 1 | **Bodycam footage (April 15, 2026)** | Full, unedited recordings from all officers present during the search of 417 Charles Conner Dr, including the consent conversation where a detective told Matthew "he was not being arrested" | Essential for Franks hearing and consent argument |
| 2 | **Bodycam footage (April 21, 2026)** | Full, unedited recordings from all officers present during the follow-up visit where Matthew was told he "was not in trouble" before an ultimatum was issued | Essential for April 21 statements argument |
| 3 | **Search warrant affidavit (full)** | Det. C.T. Inman's complete sworn affidavit, including all pages not captured in the warrant screenshots | Core Franks hearing evidence |
| 4 | **AOC-CR-206 (Inventory of Items Seized)** | Complete, legible copy of the official inventory form | Chain of custody, scope argument |
| 5 | **Det. C.T. Inman personnel file** | Limited to training records, prior complaints involving Fourth Amendment issues, and disciplinary history | Potential for Brady/Giglio impeachment |
| 6 | **KPD policies on search warrant execution** | Policies governing scope of search, plain view, and handling of locked containers | Scope argument, Monell claim |
| 7 | **KPD training records on cannabis/hemp laws** | Records of training provided to officers on distinguishing legal hemp from illegal marijuana | Failure to train (Monell) |
| 8 | **Audio recordings of 911 calls** | Any calls related to the April 14, 2026 incident | May contain exculpatory evidence |
| 9 | **Jamie Parson's medical records** | Records related to her treatment, intubation, and statements post-recovery | Victim exoneration evidence |
| 10 | **Photographs of the scene** | Any photos taken of 417 Charles Conner Dr during or after the search | Scope/nexus argument |

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## Legal Basis

### G.S. 15A-902 (Discovery in District Court)
The State must disclose all material and information within its possession or control that tends to negate the guilt of the defendant or reduce punishment.

### Brady v. Maryland, 373 U.S. 83 (1963)
The State must disclose evidence favorable to the defense, including impeachment evidence.

### G.S. 15A-903 (Discovery in Superior Court)
If the case is transferred to superior court, the State must make available all relevant oral statements, documents, and tangible objects.

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## Timing

| Deadline | Action |
|----------|--------|
| **Before May 29** | File discovery motion / serve written request on DA |
| **Within 5 business days** | State must respond or object |
| **Before suppression hearing** | Bodycam footage must be obtained for Franks hearing |

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## Notes
- If State objects, file motion to compel under G.S. 15A-904
- Request for personnel files may require in camera review per *State v. McGill*
- Bodycam footage is the single most critical item — without it, the consent argument relies solely on Matthew's testimony