In a criminal case, Defendant A claimed that the prosecution failed to obtain and disclose a laboratory report before filing a certificate of compliance on October 5, 2022. The Suffolk County District Court agreed with the defendant, invalidated the certificate of compliance, and dismissed the charges based on a violation of the speedy trial rule.
However, upon appeal, the Appellate Term, Second Department, found that the District Court had erred. The appellate court held that the prosecution was not required to disclose the results of scientific tests until the tests were completed. Therefore, the prosecution did not need to delay their certificate of compliance until the laboratory report was available. Additionally, the appellate court noted that while the prosecution must turn over all relevant reports and documents, it is not obliged to generate new material that do not already exist.
The appellate court also disagreed with the contention that the prosecution was not genuinely prepared to go to trial at that time. It asserted that a statement of readiness is presumed valid unless the defendant can prove otherwise. In this case, the defendant did not provide sufficient evidence to demonstrate that the prosecution was not ready.
Ultimately, the District Court's decision was reversed, the charges were reinstated, and the case was remitted for further proceedings.
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DECISION