Court Records


May 2, 1975

United States District Court
Eastern District of North Carolina

Amendment to Defendant's Motion for Discovery and Inspection of Documents

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NORTH CAROLINA
FAYETTEVILLE DIVISION
UNITED STATES OF AMERICA, plaintiff :
VS. : Criminal No. 75-26-CR-3
JEFFREY R. MACDONALD, defendant :
The defendant, JEFFREY R. MACDONALD, respectfully moves to Amend his heretofore filed Motion for Discovery Pursuant to Federal Federal Rule of Criminal Procedure 16, and by said Amendment adds the following demands for discovery to his aforesaid motion:

1. To Section IV, paragraph 19, on page 5 of the aforesaid Motion, the defendant adds the following demand for discovery:

Further, all experiments, tests, and reports of the clothing of Colette, Kristen and Kimberley [sic] MacDonald, including but not limited to tests of the clothing worn by the aforesaid persons on or about February 17, 1970, on or about the time of the deaths of the said persons, and tests of any other clothing of the said persons. Further, all experiments, tests and reports relating to bath mats, towels, bed linen, including but not limited to sheets and pillow cases, blankets, bedspreads, mattress protectors of all sorts, mattresses, pillows, and any other physical items which the Government believes or relies upon as having been used underneath or used to cover in any fashion the bodies of the above-named persons.

2. To Section VIII, paragraph 32, on page 13 of the said Motion, the defendant adds the following subparagraph to his demand for discovery:

f) The following tangible objects: those obtained from the scene of the crime, to wit, all matters referred to in paragraphs 7 through 26 of the Motion for Discovery, including the amendment to paragraph 19 which is set forth in this amendment.

Respectfully submitted,

/Bernard L. Segal/
Bernard L. Segal, Esq.
Suite 220
536 Mission Street
San Francisco, CA 94105

/Durant Williams Escott/
Durant Williams Escott, Esq.
412 Law Building
Charlotte, NC 28202
Attorneys for Defendant

DATED: May 2, 1975