All these items have been requested and denied or evasive answers given by prosecution

Defense Request # 1: All information and documents concerning or comprising communications (including, without limitation, e-mail messages) between or among law enforcement personnel, prosecutors, and the Court concerning our client’s repeated requests for a lawyer during questioning at Beth Israel hospital following his arrest.

Defense Request # 2. The complete immigration “A-files” of certain individuals.

Defense Request # 3. FBI 302s, police reports, Grand Jury transcripts, and any other documents comprising or concerning interviews of or statements by certain named individuals.

Defense Request # 4. Transcripts of Grand Jury testimony by individuals as to whom FBI 302s and other reports already have been produced.

Defense Request#5. All documents and reports concerning surveillance of and/or interviews of Tsarnaev family members by law enforcement before April 15, 2013.

Defense Request#6. Audiorecordings of telephone calls fromF MCDevens and reports/transcripts concerning/comprising those calls if/as they are created.

Defense Request # 7. All documents and information concerning or comprising intercepted communications (e.g., U.S. mail, voice (telephone/skype/etc.) calls, text messages, e-mail messages, web search history/browser requests) of the defendant and his family members.

DefenseRequest#8. All documents concerning or comprising “tips,” warnings, or other information provided by Russian authorities concerning Tsarnaev family members.

Defense Request # 9. All documents concerning the investigation of the triple homicide that occurred in Waltham, MA on September 10-11, 2011, including without limitation documents concerning investigation of the alleged involvement of Tamerlan Tsarnaev, Ibragim Todashev, and/or our client in those murders.

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