Discovery Request from Stefan Rose, M.D.
DUI EXPERT Discovery Request for Criminal and Civil Cases, that involved driving under the influence, impairment, blood drug tesitng, blood ethanol testing, any kind of urine testing, hospital blood tests, and impairment.
INTELLECTUAL PROPERTY OF:
Stefan Rose, M.D.
6526 South Kanner Highway
Suite 347
Stuart, Florida 34997
Phone: (561)-795-4452
Find EVERYTHING you need to know about FORENSICS, TOXICOLOGY, PHARMACOLOGY & MEDICINE ON HIS SITE AT www.UMFC.com
Laboratory Litigation Package Template
1. A clean copy of the laboratory quality manual or equivalent document
2. a copy of all of the chain of custody documents including intra-laboratory documents for the sample(s) in question
3. a copy of the analytical method used to perform all analytical tests on any specimen including the written method, the method software used and the method software settings and any method validation studies performed for the test results in question
4. a copy of all maintenance records of the instrument used in the analysis for previous 12 months including any software and/or hardware updates, patches, repairs, replacements
5. a copy of any repair records of the instrument used in the analysis for the previous 12 months
6. a copy of the qualifications, certifications, licenses, and permits of any individual performing analysis of the specimen in question
7. a copy of the instrumental raw data of all quality control and calibrator tests performed during the analysis of the defendant samples in question (on CD or flash drive)
8. a copy of the instrumental raw data of the analytical tests performed on all the defendant samples themselves (on CD or flash drive)
9. a copy of the instrumental raw data of the analytical tests performed on all proficiency samples analyzed for the twelve month period prior to the defendant sample (on CD or flash drive)
10. a clear high resolution copy of all chromatograms and calibration tables of all calibrators, controls and all samples in the batch of samples in question
11. a clear high resolution copy of all chromatograms and calibration tables of any reference standards used in the method validation or sample analysis
12. quality control data (e.g. Levi-Jennings charts) for the previous six months
13. a copy of any proficiency tests performed for a given analysis (blood ethanol, blood drug, urine drug) during the most recent six month period
14. calibration data for any weight and measuring device used in the analysis (i.e., pipettors and scales)
15. sample worklist and chromatograms and results for all samples analyzed with the subject (defendant) samples
16. a description of the samples analyzed including high resolution digital color photographs of the evidence, specimen type, amount, collection (storage) container, current availability and temperature history of the defendant samples from the time of initial collection to current date
17. A copy of all correspondence (including emails and hand written notes), regarding the testing of any and all samples in this case
18. A description and documentation of laboratory compliance with ASTM / ISO 17025 or ASTM / ISO 15189 standards if such compliance was in effect when the subject sample(s) were tested including any statement of uncertainty regarding the quantitative results and all data and calculations used in the determination of any statement of uncertainty
19. If no ASTM / ISO standard was in effect, then a description and documentation of the good laboratory standard that was in effect when the subject sample(s) were tested including any statement of uncertainty regarding the quantitative results and all data and calculations used in the determination of any statement of uncertainty
20. The current good laboratory standard in effect if different than included in 17), 18) above including any statement of uncertainty regarding the quantitative results and all data and calculations used in the determination of any statement of uncertainty
21. A copy of all documents transmitted in any fashion to and from the laboratory and any accreditation entity during the accreditation period in effect at the time of the subject sample test results
22. If any items have been destroyed please indicate each item, method of destruction, and date of destruction and reason for destruction.
23. Please provide any and all personnel files regarding any disciplinary actions of any kind.
24. If any items are not provided or are incomplete please provide a detailed explanation for each item.
25. Please provide the documents and files as an electronic PDF file in the numerical order of this document and with a table of contents and appropriate pagination
