Request for disclosure and to schedule a bail hearing [Patrick Fox; Chris Johnson (BCPS)]

Dear Mr. Johnson:

I have received the evidence I have been waiting for and am now ready to proceed with the bail hearing. Therefore, I respectfully request you schedule a bail hearing at the earliest opportunity.

Also, as you know, we're less than four weeks aware from the scheduled trial date and I've still not received your witness list or the disclosure. Obviously, I would like to investigate your witnesses before I cross-examine them, and I may need time to obtain evidence to rebut any evidence you intend to offer, so if it gets too close to trial before the disclosure is provided then I may need to request a continuance.

However, I believe your case is going to be based solely on my “admissions” and the testimony of one or two VPD officers – in which case, I'm ready to proceed with the trial right now.