Carpenter v. Superior Court
In Carpenter v. Superior Court, 176 Ariz. 486, 862 P.2d 246 (App. 1993), the defendant had attempted to subpoena the police custodian of records without notifying the prosecutor's office. Id. at 488, 862 P.2d at 248.
The Court agreed with the trial court's ruling quashing the subpoena and its conclusion "that a criminal defendant cannot use the subpoena power of the court to circumvent the rules of criminal procedure and thereby obtain discovery without the knowledge of the state or consent of the trial court." Id. at 489, 862 P.2d at 249.