When it's used
After the prosecution's initial Penal Code §1054 disclosure, before the defense strategy conference with the client.
Definition
A criminal discovery review memo is an internal document the paralegal prepares after receiving the prosecution’s mandatory disclosure package under California Penal Code §1054 et seq., which requires the prosecution to disclose the names of witnesses, statements, reports, and physical evidence it intends to use at trial. The memo summarizes each item of discovery received—police reports, body-cam footage, forensic reports, witness statements, and prior criminal history of prosecution witnesses—and flags defense-favorable material such as inconsistencies in witness accounts, missing documentation, or potential Brady/Giglio issues requiring follow-up. The paralegal creates a chronological narrative of events based solely on the prosecution’s materials, identifies gaps or items the defense should demand, and notes deadlines for any reciprocal defense disclosure. This memo becomes the attorney’s primary reference for the initial client strategy conference and shapes the defense investigation plan.