California, United States of America
The following excerpt is from People v. Briggs, 19 Cal.Rptr. 772 (Cal. App. 1962):
On appeal it is not asserted that there was any bad faith or deliberate misconduct on the part of the prosecution. It is appellant's contention that he should have been provided with the typewritten statement or some memorandum of it well in advance of cross-examination so that he could have examined it with a view to impeachment of its author. There is no rule pursuant to discovery proceedings that requires the prosecution voluntarily to produce all documents for the defense. They can, of course, be obtained upon demand for their production, and a violation of the right to discovery may be ground for reversal on appeal from a judgment of conviction (People v. Estrada, 54 Cal.2d 713, 716, 7 Cal.Rptr. 897, 355 P.2d 641; People v. Cartier, 51 Cal.2d 590, 594, 335 P.2d 114). But no case had been cited to us, and we are aware of none, which holds that the prosecution must produce all documents which it obtains subsequent to a demand on the theory of a 'continuing demand'. There was no violation of appellant's right of discovery.
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