Pretrial Motion – Motion for Discovery of Evidence of Extraneous Offenses
In November 2022, Adkins filed a request for timely notice of the state’s intention to use evidence of extraneous misconduct at trial.
Pretrial Motion No. 1 for Discovery – 911 and Radio
In November 2022, Powell made a motion for Discovery to review all 911 calls related to Adkins’ murder indictment and also a copy of the “Radio Call Master” or “Radio Call Log”
Pretrial Motion No. 2 for Discovery – Autopsy and Medical
In November 2022, Powell made a motion for Discovery to review all autopsy reports from the body of Hailey Dunn and all medical reports that showed the physical condition of Hailey or Adkins at the time of the alleged murder. He also asked to review the blood types of Hailey Dunn and Adkins.
Pretrial Motion No. 3 for Discovery – “Confession” Material
In November 2022, Powell made a motion for Discovery to review all confessions, admission, and statements in writing signed by Adkins in connection to the Hailey Dunn murder. He also requested any statements that were recorded by investigators and any statements made by Adkins before the Grand Jury.
Pretrial Motion No. 4 for Discovery – Other Suspects
In November 2022, Powell made a Motion for Discovery to review the name of all suspects who were interrogated and/or arrested in conjunction with the Hailey Dunn murder.
Pretrial Motion No. 5 for Discovery – Photographs
In November 2022, Powell made a Motion for Discovery to review all photographs, drawings, and charts made by prosecutors and/or investigators, all photographs of Hailey Dunn at the crime scene and during autopsy, all negative prints developed by prosecutors and/or investigators, all photographs of suspects that were shown to witnesses, and all photographs of Adkins used in connection to this investigation, including photographs that may have been shown to witnesses.
Pretrial Motion No. 6 for Discovery – Informants
In November 2022, Powell made a Motion for Discovery to review all information investigators received about the Hailey Dunn homicide through Crime Stoppers or similar programs.
Pretrial Motion No. 7 for Discovery – Law Enforcement Notes
In November 2022, Powell made a Motion for Discovery to review all handwritten and typed notes from investigators throughout the case.
Pretrial Motion No. 8 for Discovery – Prosecution Experts
In November 2022, Powell made a Motion for Discovery to review all names and addresses of each person the State plans to use for expert opinion during trial.
Pretrial Motion No. 9 for Discovery – Tangible Things
In November 2022, Powell made a Motion for Discovery to review all tangible property alleged by the State to have been taken or used by Adkins or any co-conspirator during the commission of the murder of Hailey Dunn, all weapons alleged by the State to have been used in the murder, all articles of clothing allegedly belonging to Adkins and Hailey Dunn, all contraband drugs, controlled substances, and paraphernalia seized during the case, all documents, papers, books, accounts, letters, objects, and tangible things that belong to Adkins and are currently in the possession of prosecutors and/or investigators.
Defendant’s Election for the Jury to Assess Punishment
In November 2022, Adkins officially elected to have a jury assess his punishment upon conviction.
Pretrial Motion for the Production of Grand Jury Transcripts Pursuant to Article 20.02(d) C.C.P.
In November 2022, Adkins moved obtain and review any transcripts, documents, power points, witness testimony, and exhibits presented to grand jurors that help lead to his indictment in this case.
Pretrial Matter Defendant’s Request for Discovery as Authorized by Article 39.14 of the Texas Code of Criminal Procedure
In November 2022, Adkins requested the State produce discovery of legally discoverable but previously undisclosed materials. This includes law enforcement records, records on consent to search, statements made by Adkins, witnesses, codefendants, video and audio recordings, electronic data, books, accounts, and letters, photographs and drawings, biological materisal, autopsy reports, list of witness, records of criminal conviction of Adkins and all other codefendants, accomplices, and witnesses, all records involving Adkins’ juvenile criminal history, all evidence related to extraneous misconduct of Adkins, and all tangible things involved in the case.
Pretrial Matter Request for Timely Notice of the State’s Intention to Use Evidence of Extraneous Misconduct at Trial
Pretrial Matter Defendant’s First Amended Request for Discovery as Authorized by Article 39.14 of the Texas Code of Criminal Procedure
In November 2022, Adkins requested the State produce discovery of legally discoverable but previously undisclosed materials. This includes law enforcement records, records on consent to search, statements made by Adkins, witnesses, codefendants, video and audio recordings, electronic data, books, accounts, and letters, photographs and drawings, biological materisal, autopsy reports, list of witness, records of criminal conviction of Adkins and all other codefendants, accomplices, and witnesses, all records involving Adkins’ juvenile criminal history, all evidence related to extraneous misconduct of Adkins, and all tangible things involved in the case.
Motion for Change of Venue
In November 2022, Adkins requested a Change of Venue from Nolan County, Texas because he believes “there exists knowledge and conclusion as to Adkins’ guilt or innocence and that these conclusions influence public opinion to the degree that Adkins cannot obtain a fair and impartial trial.” A witness, identified as a 36-year-old Nolan County resident, also provided a statement saying he believes that there is great prejudice in Nolan County and that Adkins cannot obtain a fair and impartial trial. He cites media coverage of this crime as a reason why.
Pretrial Matter First Amended Request for Timely Notice of the State’s Intention to Use Evidence of Extraneous Misconduct at Trial
Pretrial Matter Defendant’s Second Amended Request for Discovery as Authorized by Article 39.14 of the Texas Code of Criminal Procedure
In November 2022, Adkins requested the State produce discovery of legally discoverable but previously undisclosed materials. This includes law enforcement records, records on consent to search, statements made by Adkins, witnesses, codefendants, video and audio recordings, electronic data, books, accounts, and letters, photographs and drawings, biological materisal, autopsy reports, list of witness, records of criminal conviction of Adkins and all other codefendants, accomplices, and witnesses, all records involving Adkins’ juvenile criminal history, all evidence related to extraneous misconduct of Adkins, and all tangible things involved in the case.
ABILENE, Texas (KTAB/KRBC) – One hundred fifteen pages of pretrial paperwork has been filed in the murder of Colorado City teen Hailey Dunn as suspect Shawn Adkins is set to stand trial later…
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