In supplying pretrial discovery in State v Ramirez, __NJ__ (Nov. 21, 2022), involving a sexual assault occurring in a cemetery into which the victim was "dragged" on her way home from work, the prosecutor redacted the victim's address and moved for a protective order. The prosecutor certified that the victim did not want her address to be provided as she was in fear of being located, and that she did not want to speak to the defense in advance of trial. The defendant argued that Rule 3:13–3(b) required production of that information and that the background information was necessary to prepare his defense. The motion judge ordered the address to be disclosed to counsel but not to the defendant himself.

The Appellate Division granted leave to appeal and reversed the order, thereby precluding discovery of the victim's address. After granting further interlocutory review, the Supreme Court, in an opinion by Appellate Division Presiding Judge Jack Sabatino, temporarily assigned, held that in addition to consideration of the defendant's rights to effective assistance of counsel, confrontation and preparation of an adequate defense, the Victim's Rights Amendment to the New Jersey Constitution, the Crime Victim's Bill of Rights and the Sexual Assault Victim's Bill of Rights had to be considered as part of the necessary balancing of interests relating to discovery of a sexual assault victim's address.