People v. Holtzman

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NATURE OF THE CASE

Recently, the Michigan Supreme Court promulgated Michigan’s reciprocal criminal discovery rule, MCR 6.201, which mandates, among other things, that a party provide the opposing party with “any written or recorded statement by a lay witness whom the party intends to call at trial” upon request by the opposing party. MCR 6.201(A)(2).

This prosecutor’s appeal raises an issue of first impression under MCR 6.201(A)(2): does the term statement as used in this subrule include the attorneys’ notes of interviews with witnesses whom the attorney intends to call at trial? Or, does the…