NOW COMES the defendant, by pro se, and pursuant to Illinois Supreme Court Rule 412, to order the city of Chicago Police Department to preserve and produce handwritten notes of police personnel for the following reasons:

1. That the defendant presently is charged with the offense of harassment by telephone, 720 ILCS 135/1-1.
2. That at various times in September of 1999, the first time being September 21, 1999, the defendant was notified of charges by Police Detective McCurrio of the 11th District and that he made himself known to defendant as the Investigator of complainant's charges.
3. That the State has not yet provided to defendant any police reports but that the defendant realizes formal reports in this instance exist by law, procedure and admission of the police detective to defendant.
4. That defendant believes any police reports to be based upon handwritten notes of Detective McCurrio and possibly other policemen.
5. Handwritten notes may contain evidence favorable to the Defendant, may be used for impeachment, and are necessary to the preparation of the defendant's defense.

WHEREFORE, the defendant moves this court to grant the motion for the Chicago Police to preserve and produce any and all handwritten notes of police personnel made in connection with the instant case.