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Original motion filed on May 22nd. Read:::

NORTH CAROLINA
DURHAM COUNTY
FILED
IN THE GENERAL COURT OF JUSTICE
06 1;AY 22 An 9: 35 SUPERIOR COURT DIVISION
FILE NOS. 06 CRS 4334-356
DUFIHAZ COUNTY. C.S.C.
BY
STATE OF NORTH CAROLINA )
VS. )
1
READE WILLIAM SELIGMANN,
Defendant. )
MOTION FOR PRODUCTION OF TOXICOLOGY REPORTS
NOW COMES READE WILLIAM SELIGMANN, the Defendant, through his
undersigned counsel, pursuant to the Fifth, Sixth and Fourteenth Amendments to the United
States Constitution, Article I, $8 19, 23, 24, 26, 27, and 36 of the North Carolina Constitution,
and N.C. Gen. Stat. $ 15A-901, et seq., and hereby moves this Honorable Court for an Order
directing the State to make available to the defense any and all toxicology reports generated from
blood, urine or other biological samples collected from the complaining witness, Crystal Gail
Mangum, on March 14, 2006 at Duke University Hospital. In support of this Motion, the
Defendant shows the Court the following:

1. In an interview with Newsweek reporters, District Attorney Mike Nifong, while
running for election "hinted to NEWSWEEK that blood and urine tests of [the accuser] would
reveal the presence of a date-rape drug." Newsweek; May 1,2006 p.42.

2. No such toxicology report, if it exists, was provided to the defense in the 1278
pages of discovery (Discovery) the District Attorney turned over to counsel for the Defendant on
May 18, 2006. The District Attorney represented to the Court that the Discovery he provided to
the Defendant was everything he had in his files.

3. The discovery provided does show that a known blood sample, and known cheek
scrapping were obtained from the accuser on March 14, 2006. See Discovery, pp. 218 & 543.

The S.A.N.E nurse specifically checked a box on the Sexual Assault Exam Report indicating that
toxicology samples were not collected. See Discovery, p. 543.

4. Discovery Records provided to the defense indicate that a pregnancy test was
performed. See Discovery, p.527. However no toxicology reports (if they exist) were provided.

5. The Defendant makes this Motion without prejudice to his rights to come back at
some later day and move for the production of other documents not provided in discovery but
allegedly generated by during the investigation of this matter.

WHEREFORE, the Defendant prays the Court to enter an Order directing the State to
make available to defense any and all toxicology reports generated from blood, urine or other
biological samples collected from the complaining witness, Crystal Gail Mangum, on March 14,
2006, at Duke University Hospital.

RESPECTFULLY SUBMITTED this the 22nd day of May, 2006.
ERNEST L. CONNER, JR.
ATTORNEY FOR THE DEFENDANT
1829 East Franklin Street
600 Franklin Square
Chapel Hill, NC 275 14
Tele: (91 9) 929-0987
Fax: (919) 929-2740
AlTORNEY FOR THE DEFENDANT
DIXON, DOUB, CONNER & FOSTER
Post Office Drawer 8668
Greenville, NC 27835-8668
Tele: (252) 355-8 100
Fax: (252) 355-0271
CERTIFICATE OF SERVICE
THIS IS TO CERTIFY that the undersigned attorney this day served a copy of the
foregoing Motion for Production of Toxicology Reports by hand delivery upon following person
or to someone duly authorized to accept service for that person at the following address:
Michael B. Nifong, Esq.
District Attorney
Durham County Courthouse
Durham, NC 27701
This the 22nd day of May, 2006.
J. KIRK OSBORN
ATTORNEY FOR THE DEFENDANT
1829 East Franklin Street
600 Franklin Square
Chapel Hill, NC 275 14
Tele: (9 19) 929-0987
Fax: (9 19) 929-2740