Perhaps I was late in coming with relevant facts, because I was not knowledgeable about which facts were relevant. I assure you I was not trying to mislead you, be underhanded, or waste your time. I apologize for creating that impression!
While I agree I was concerned about the lawn at the front of the high school, it is also true grounds the students use during the school day are in fact fenced in. If you expand these pictures, you will see the fences. There is also a gate to the driveway, although it is open. (I am uploading with the docs that had broken links, just FYI.)
https://www.dropbox.com/sh/ew837tvx7...7-?n=120692905
In any event, I had my court hearing today and for anyone wondering what happened, here it is:
When I got to the court I asked a bailiff if the radar book was the same thing as an Engineering and Traffic Survey and he said no. So I decided to argue my case just for the hell of it (I had spent too much time working on it to throw in the towel) and was prepared to present my shaky everything-but-the-kitchen-sink defense:
- Motion for dismissal based on unanswered discovery request.
- Motion for dismissal based on speed trap, hoping "it is not a school zone at that time" because of the "no children coming or going" and the perimeter fencing would hold up. If it did, I'd then hope the radar book was not a true ETS or maybe the citing officer did not have POST certification on his radar training. The radar study was seven years old in August, so I would assert it was not admissible.
- If that fell apart, I planned to use the nine months that had passed, the ~1000 citations the officer had issued in the meantime, the incorrect written notes and lots of questions to demonstrate that the officer could not possibly remember my citation and therefore was not a credible witness.
But (luckily for me) my case was never heard!
The citing officer requested dismissal, and my case was dismissed.
Why this happened, I can only guess:
I had made several discovery requests which went unheeded. Finally, on the third request, the arresting officer provided some of the information, but not all. I had asked for the speed at which he had cited each of the hundreds of speeding tickets he issued this year (suspecting a large percentage would be at 41, the cut-off for higher fines). I had asked for information on the calibration of the tuning forks, which apparently was not available. Finally, I asked for a copy of his written notes before he altered them.
From what I learned on this forum and from reading the traffic code and other sources, it seems none of these requests were even relevant.
So, it is a mystery.
Of course many other citing officers did not show up at all, and the many defendants' cases were dismissed. Only one other besides mine was dismissed based on the citing officer's request, and she also had made a discover request which went unanswered.
Thanks again for your help.