Good grief, I can help you Mr. Baez, on my lunch break I can venture a guess.
OK then Jose..here you go...
We plan to use the fact that little baby Caylee was under twelve years of age. We plan to enter into evidence her birth certificate, a ten year calender, photos of her two birthday celebrations and sworn testimony that indeed she was two when your client killed her,allegedly.
We plan to prove that she was in the care of one of her parents. The defendant's own father has testified under oath to the grand jury that the last time anyone in your client's family saw baby Caylee was when pop saw the pair of them leaving the home on the 16th. We intend to call pop to the stand, we are fully prepared to impeach him should he somehow forget his testimony. We plan to submit for the jury's consideration, the very, very clear fact that the child was not with her when she and boyfriend Tony were wrapped together at Blockbuster. We certainly plan to prove that the baby was at some point in the trunk. The tow yard's security will testify that the car was not tampered with during the time it was in their care. The baby's body was decomposed in items that appear to a reasonable degree of certainty to have come from the Anthony family home, the blanket the hamper, the specialized kind of Henkel duct tape, the garbage bags. Sir even the child's pull ups match the pull ups found in the baby's things at the home and or car. She was alive in her mother's care, and then never seen or heard from again, despite your clients lie about Caylee phoning her . We will be introducing into evidence the phone records, which each and every incoming and outgoing call can be accounted for and none are of any would be lovely, young , straight haired, perfect teeth and perfect ten...Zanny. So yes, Mr. Baez..there are some clues for you. We will be calling pop, Tony, CSI and FBI experts, tow yard officials.
The state only needs one aggravating factor. Next question Mr. Baez.....
By the way sir where, pray tell, is your reciprocal discovery?
I think these highly experienced prosecutors have been asked for this many times over the years, and know full well what is and is not required of them. The proper time to ask for this was...let's see..immediately after the death penalty was added. When was that, not November 2009, when they did get around to asking for it, by any stretch of the imagination. Did they subsequently file another motion, or did they really wait for another half of a year to bring it up again? Six months!!! This reminds me of them making an appointment to view the TES records, canceled, never rescheduled for over eight months!!!
You just can't make this stuff up!!
Supreme Law Library : Court Cases : U.S.A. v. Vroman : courtpar
A Bill of Particulars, unlike most criminal discovery devices, directly implicates the Sixth Amendment's guarantee of the right to make a vigorous and prepared defense in a criminal case. See, United States v. Tanner, supra, 279 F.Supp.
www.supremelaw.org/cc/vroman/courtpar.htm
