Commonwealth v. Santos

OPINION BY

DUBOW, J.:

The Commonwealth appeals from the December 15, 2014 Order entered by the Philadelphia County Court of Common Pleas prohibiting the Commonwealth from calling a police officer at trial to remedy the Commonwealth’s purported discovery violation. After careful review, we reverse.

Between June 17, 2013, and July 2, 2013, Philadelphia narcotics police officers conducted surveillance at 3205 and 3207 Rorer Street. On June 17, 2013, Philadelphia Police Officer Stephen Dmytryk observed Appellee enter and exit 3205 and 3207 Rorer Street, 1 and sell 43 packets of crack cocaine to a…