Case Involving R.C. 2945.72(E)

In State v. Brown, 98 Ohio St.3d 121, 2002 Ohio 7040, 781 N.E.2d 159, syllabus, the Ohio Supreme Court held that a defendant's demand for discovery or a bill of particulars is a tolling event per R.C. 2945.72(E). The Ohio Supreme Court reasoned that "discovery requests by a defendant divert the attention of prosecutors from preparing their case for trial, thus necessitating delay." Id. at P23.