(1) Can a trial judge postpone a trial on its commencement date at the prosecutor's motion for additional discovery without establishing how the opposing party (defendant) failed to comply with any discovery rule pursuant to N.J.C.R. 3:13-3 (b) (f)?

(2) Can discovery which is available pre-indictment in the prosecutor's office be considered new discovery produced to the defendant on the commencement date of a trial?

(3) According to Carbis Sales, Inc. v. Eisenberg, 397 N.J. (2007) "A motion made at trial for discovery of a particular document of which the moving party long since had knowledge and is in any case unlikely which is discoverable evidence so far out of time as to require a denial." So how could this discovery motion be granted, when the motion was made at trial, and the Movant party (State / Prosecutor) long since had knowledge of this report?

(4) According to State v. Merlino, 153 N.J. Super. 12, 17 (App. Div. 1977), a reviewing court will not overturn a trial judge's ruling on whether a defendant was deprived of due process on speedy trial grounds unless the judge's decision was "clearly erroneous." Since there is no "clearly erroneous" standard set forth, the defendant would like his case to set that standard.

(5) Also the defendant would like this court to implement a specific guideline on how a trial judge can continue or prohibit discovery pursuant to N.J.C.R. 3:13-3 (b)(f) which governs the continuation of discovery in New Jersey.

(6) Does the trial judge have a duty to investigate into a juror's regret about his or her verdict prior to a defendant's sentencing hearing? This would be to determine if any jury misconduct occurred during jury deliberation if the juror never gave a reason for the regret pursuant to State v. Weiler, 211 N.J. Super. 602, 609-12, 512 A. 2d 531 (App. Div.), certif. denied, 107 N.J. 37, 526 A. 2d 130 (1980).

(7) If not, should the defendant just depend on sheer luck that the reason for the juror's regret might somehow come to light?

(8) Last but not least, the defendant would like this court to establish a timeframe for a motion to be made pursuant to N.J.C.R. 1:16-1.

Can a trial judge postpone a trial on its commencement date at the prosecutor's motion for additional discovery without establishing how the opposing party (defendant) failed to comply with any discovery rule pursuant to N.J.C.R. 3:13-3(b)(f)?