Commonwealth v. Bing Sial Liang

In this case we consider whether a judge may order the Commonwealth to disclose to a defendant the notes of a *132victim-witness advocate (advocate) based on the advocate’s conversations with a victim or witness concerning the investigation or prosecution at issue.1 We conclude that the notes of advocates are subject to the same discovery rules as the notes of prosecutors. To the extent that the notes contain material, exculpatory information, Mass. R. Crim. P. 14 (a) (1) (C), 378 Mass. 874 (1979), or relevant “statements” of a victim or witness, as defined in Mass. R. Crim. P. 14 (d), 378 Mass.…