Defense Motion for Order - Summary of case.  Commonwealth of MA vs Karen Read
Channel: Chasing.
Date: 25/10/2023

Now comes the defendant, Karen Read ("Ms. Read", or "the Defendant”), and 
respectfully moves this Court to (1) issue a summons pursuant to Mass. R. Crim. P. 17(a)(2) 
ordering key percipient witnesses Brian Albert, Nicole Albert, Matthew McCabe, Julie Albert, Brian Higgins, Colin Albert, and Julie Nagel to provide to the Clerk of the Court in advance of 
the trial any cell phones used by the respective parties on January 28, 2022, so that defense counsel may conduct a forensic examination of the parties' respective cell phone(s) to recover location data for a 7-day period spanning January 28, 2022, to February 4, 2022, and communications sent and/or received by the respective individuals between January 28, 2022, and February 28, 2022; and (2) issue an order that the Commonwealth produce a complete copy of the Cellebrite extraction obtained from Jennifer McCabe's phone to defense counsel for examination pursuant to Mass. R. Crim. P. 14, Mass. R. Crim P. 17, and the common law, subject to any protective orders deemed necessary by the Court.


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