On September 14, 1982 the People sent a letter to defendant's counsel, Kenneth Doonan, Esq., making formal demand pursuant to CPL 240.30 (subd 1) for reports of documents, more particularly photographs and reports concerning the scene of the crime.
The defendant, having received this formal demand, failed to follow the provisions of CPL 240.35 and did not timely refuse the demand in writing, which writing should have set forth...
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