I am not a discovery guru, but it is my understanding that a response to a request for production has to be organized according to the specific requests. The CDs that I am receiving from the CPS redaction unit have one file with 1000s of pages of documents which are in no particular order, just like the documents I use to receive when they were sending paper copies.

My problem is how to comply with the rules of discovery without having to reprint and/or remanipulate the data I receive from CPS. If I am going to end up with paper copies anyway, I would rather they foot the paper bill.

What are other CPS prosecutors doing?

We have a Discovery Control Plan in every case. If requested, we just have to provide a complete copy of the case record, along with certain written disclosures. The new format from CPS can make trial prep a pain, but hasn't affected our discovery.

Our county also utilizes a discovery control plan which requires upon written request a copy of the de-identified case file. When we were doing discovery via a formal production request, I responded to each request but it is my understanding under the discovery rules that the documents need to be in the format in which they are kept ordinarily. So it may be a stretch, but if that is how the Department in your area keeps its file then you should be ok. Our county produces the file via CD and I have asked that it be scanned in the order that they normally keep it in the binders and it has not been a problem. Hope that helps. You might see if your court will entertain a discovery control plan. It makes discovery much easier.