Gibbs v. Commonwealth

Opinion

BARROW, J.

In this appeal from a criminal conviction, we hold that a subpoena duces tecum applied for under the provisions of Rule 3 A: 12(b) is not limited to materials that are admissible in evidence but may be issued for any writings or objects that are “material to the proceedings.”

Before trial, the defendant, who was charged with crimes arising out of a bank robbery, requested a subpoena duces tecum to be directed to an individual who was employed by and represented the bank that had been robbed. The defendant requested “all documents, records, reports, statements, letters,…