STATE OF GEORGIA

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                       * NO.:

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MOTION FOR ISSUANCE OF SUBPOENA TO OBTAIN RECORDS FROM DEPARTMENT OF FAMILY AND CHILDREN SERVICES FILES

COMES NOW the Defendant in the above styled case, by and through undersigned counsel, and, pursuant to O.C.G.A. 49-5-41(a)(2), and pursuant to Davidson v. State, 183 Ga. App. 557 (1987), and pursuant to his right of confrontation and due process, and his right to a fair trial, all guaranteed by the United States Constitution, requests that this Court issue subpoenas directed to the Department of Family and Children Services of Fulton County, Georgia, to produce their complete files on , black female, D.O.B., AND for this Court's production of same to Defendant.

In the alternative, the Defendant requests that the Court conduct an in camera inspection of the records prior to trial to determine whether the aforementioned records contain information which is exculpatory, or is essential for trial preparation, or is necessary for determination of an issue.

WHEREFORE, Defendant requests that the Court make available to him all files as described above in the possession of the Department of Family and Children Services.

Respectfully submitted,

_______________________

Attorney for Defendant