information that the state has and will use against the defendant is not simply a matter of common sense, .. . it is the duty of the lawyer .. . ." Rotnpillal. Beard, 545 U.S. 374, 386 (2005), citing 1 ABA Standards for Criminal Justice 4-4.1 (2d ed. 1982 Supp).2 The constitution also requires that crimina