As I wait for the inevitable back-and-forth over my additional disclosure request, I've been thinking about what I may be able to do, particularly with respect to point 5 and any other cross-examination I may need.
Radar unit in good working order
"Officer, are you the only member of your police service who uses this particular radar unit?" Chances are the answer will be no. "When one of your colleagues uses it, how do you know it has been returned in good working condition?" He will probably say it passes the test. The test only shows that internal circuitry and all LED elements work, and that the radar corresponds to simulated speeds. He may say officers have to report damage. "How do you know there is no undisclosed damage that would still allow the device to pass the test, but could affect proper operation?" I'm guessing he'll go on about reporting damage, having damage fixed, some kind of damage log, etc. Perhaps he'll say "the maintenance person tells us the device has been repaired" or "the device would not be returned to the rack if it were damaged." I could challenge him on whether someone could make a mistake or whether someone who had damaged the device might not report the damage for fear of reprisal. Perhaps he would say so-and-so told him the unit has been fixed or hasn't been damaged. Any such statement is, of course, hearsay and would be inadmissible. If he says there's a repair log or some kind of book/log that shows devices are in good working order, I would go after the fact that said book or log has not been disclosed and any testimony based on it should be inadmissible.
"Officer, at what intervals must the device be maintained?" He may give a correct or incorrect answer (I assume the manual will tell me, so I can verify). If he's wrong, that would go to his training and certification (and, ultimately, credibility). If he gets that answer correct: "Officer, are you the person responsible for maintaining the device?" The answer will obviously be no. "Who does the maintenance?" I'm sure there's a maintenance person or team. "How do you know that required maintenance has been performed?" Again, there would probably be discussion about there being a maintenance log or report. If the maintenance person simply states that the device has been properly maintained, any such assertion by the officer is hearsay. If the officer says he checks the log, non-disclosure of the log works in my favour. I could, of course, also approach the idea that someone could have erred, could have inadvertently entered incorrect information, etc. Either way, getting him to talk could be helpful.
Same approach as with maintenance. How does the officer know the device has been properly calibrated? Where is the confirmation it left the factory properly calibrated? Where is the proof that calibration has been checked? Bring up my analogy of a sticker on the scale at the store or on the gas pump. Again, my thinking is unless the officer calibrates the device himself (and I HIGHLY doubt he does), any "proof" of calibration would be either hearsay or contained in some form of log that won't have been disclosed.
I know it's not quite as easy as I'm suggesting it is here, but unless I'm unaware of some case law or the officer has a zinger or two hiding up his sleeve, I should be able to raise doubt as to the reliability of the radar evidence.