People v. Ravenell, 2024 NY Slip Op 51091(U)

Defendants were originally charged by felony complaint on October 28, 2023, with Assault in the Second Degree.
On January 8, 2024, a superseding misdemeanor information (SMI) was filed, charging lesser offenses including Assault in the Third Degree, Criminal Possession of a Weapon in the Fourth Degree, Petit Larceny, and Harassment in the Second Degree.
The prosecution filed Certificates of Compliance (COC) and Supplemental COCs (SCOC), declaring readiness for trial;
Defendants challenged the sufficiency of the People’s discovery (particularly regarding RAP sheets for the complaining witness), leading to prior invalidation of the prosecution's readiness.
The prosecution responded with further discovery and a second SCOC on April 26, 2024.
Defendants moved to dismiss under CPL §§ 170.30, 30.30, and 245.50, arguing noncompliance with discovery and violation of their speedy trial rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the People's discovery was complete	Discovery obligations satisfied; RAP sheet provided	RAP sheet incomplete; arrests and sealed matters not produced	People's discovery found sufficient
Whether the People’s COC/SCOC were valid	Filed proper certificates and declared readiness	COC/SCOC invalid due to incomplete discovery	Second SCOC deemed valid
If the People exceeded speedy trial limits	Did not exceed; only 52 chargeable days	Exceeded 90 days; should dismiss case	Only 52 days chargeable; motion denied
Entitlement to additional discovery	Only required to turn over convictions, not arrests	Entitled to arrests and other records	Only required to disclose convictions

People v. Bay, 41 NY3d 200 (NY 2023) (addressing scope of prosecution’s discovery obligations and readiness under CPL 245.20 and 30.30)
People v. Sinistaj, 67 NY2d 236 (NY 1986) (explaining CPL 30.30’s purpose regarding timely prosecutorial readiness)
People v. Luperon, 85 NY2d 71 (NY 1995) (discussing burdens and exclusions under CPL 30.30)