LOL...speed is of the essence.
In light of the fact that Mr. Mangiapane has not waived his speedy trial rights, Mr. Mangiapane requests that this Court not allow the prosecution to drag its heels relative to the provision of discovery.
In fact, dragging its heels appears to also be a "long standing policy" of the prosecution when it comes to providing discovery.
This, however, gives the defense less time to review, investigate, and prepare for trial while the prosecution has had the luxury of years.
This borders on an intentional disregard or conscious indifference to the defendant's procedural and constitutional rights to due process and for a fair trial protected by the Fifth Amendment.