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McCraney Rena Crumb Motion

The defense filed a Motion for Specific Production requesting the prosecution provide any documents relating to interviews of former reserve police officer Rena Crumb regarding the victims in this case. The motion states Crumb was interviewed several times by law enforcement, including the Ozark Police Department, and any statements or evidence from these interviews would be material to preparing the defense and could be exculpatory. The defense argues this information should be produced under Rule 16 of the Alabama Rules of Criminal Procedure and Brady v. Maryland.

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782 views2 pages

McCraney Rena Crumb Motion

The defense filed a Motion for Specific Production requesting the prosecution provide any documents relating to interviews of former reserve police officer Rena Crumb regarding the victims in this case. The motion states Crumb was interviewed several times by law enforcement, including the Ozark Police Department, and any statements or evidence from these interviews would be material to preparing the defense and could be exculpatory. The defense argues this information should be produced under Rule 16 of the Alabama Rules of Criminal Procedure and Brady v. Maryland.

Uploaded by

Ethan Brown
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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DOCUMENT 68

ELECTRONICALLY FILED
8/21/2019 11:43 AM
26-CC-2019-000187.00
26-CC-2019-000191.00
CIRCUIT COURT OF
DALE COUNTY, ALABAMA
DELORES WOODHAM, CLERK
IN THE CIRCUIT COURT OF DALE COUNTY, ALABAMA

STATE OF ALABAMA )
)
VS. ) CASE NO.: CC-2019-187,188,189,
) 190,191
)
COLEY LEWIS MCCRANEY, )
Defendant. )

MOTION FOR SPECIFIC PRODUCTION

COMES NOW, the Defendant, COLEY LEWIS MCCRANEY, by and through his undersigned

counsel, pursuant to Rule 16.1 of the Alabama Rules of Criminal Procedure, respectfully requesting

this Honorable Court order the prosecution to produce and permit defense counsel to analyze, inspect,

and copy or photograph, any and all documents, to include recordings, relating to any interviews of

former reserve Ozark Police Officer Rena Crumb regarding the victims in this case, conducted by any

law enforcement agency. And as for grounds thereof, Counsel states the following:

1. Rule 16 of the Alabama Rules of Criminal Procedure, requires the production, to a

defendant, of documents and tangible objects which are material to the preparation of the defendant’s

defense.

2. Furthermore, the United States Supreme Court has held that due process requires, in

a criminal prosecution, the state to disclose any information it has which is favorable to the defendant.

Brady v. Maryland, 373 U.S. 83 (1963).

3. Thus, in a criminal prosecution, evidence which is material to a defendant’s defense

and evidence which is exculpatory in nature must be turned over to the defendant.

4. In the present case, public statements by former Ozark reserve police officer Rena

Crumb, as well as several federal and state litigations, have indicated that members of law

enforcement interviewed Ms. Crumb several times regarding the murders of JB Beasley and Tracie

Hawlett, including at least once by members of the Ozark Police Department, in particular Chief

Marlos Walker.
5. Counsel believes statements made during these interviews, as well as any evidence
DOCUMENT 68

obtained as a result of these interviews, to be material in the preparation of this Defendant’s defense

and that some of this evidence is in fact exculpatory.

WHEREFORE, the Defendant requests this Honorable Court to issue an Order requiring the

prosecution to produce to the Defendant any and all documentation, to include statements and

recordings, relating to any interviews of Rena Crumb regarding the victims in this case, conducted by

any law enforcement agency.

RESPECTFULLY SUBMITTED this the 21st day of August, 2019.

/s/ Andrew J. Scarborough


ANDREW J. SCARBOROUGH (SCA018)
Attorney for Defendant
210 West Troy Street
P.O. Box 2101
Dothan, Alabama 36302
(334) 678-8200

/s/ David J. Harrison


DAVID J. HARRISON (HAR149)
Attorney for Defendant
P.O. Box 994
Geneva, Alabama 36340
(334) 684-8129

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing has been sent via AlaFile
delivered to:

Honorable Kirke Adams


District Attorney
P.O. Box 1688
Ozark, Alabama 36361

DATED this the 21st day of August, 2019.

/s/ Andrew J. Scarborough


OF COUNSEL

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