The following excerpt is from People v. Tejeda, 2015 NY Slip Op 50836 (U) (N.Y. Crim. Ct. 2015):
Discovery in criminal cases in New York State is governed by statute. See People v. Colavito, 87 NY2d 423, 427 (1996) ("Items not enumerated in article 240 are not discoverable as a matter of right unless constitutionally or otherwise specially mandated"); see also Matter of Johnson v. Sackett, 109 AD3d 427, 429 (1st Dept 2013), lv denied 22 NY3d 857 (2013) (neither a defendant nor a court has the "authority to compel pretrial discovery in criminal cases that is unavailable pursuant to statute.").
New York does, however, have "a philosophy of broad pretrial disclosure." People v.
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