MCR 6.112(E) provides that “[t]he court, on motion, may order the prosecutor to provide the defendant a bill of particulars describing the essential facts of the alleged offense.” However, MCL 767.44 requires a bill of particulars “if seasonably requested by the respondent[.]” MCL 767.44 provides “statutory short forms” that may be used in the bill of particulars. People v Strutenski, 39 Mich App 72, 73 (1972). For example, the statutory short form for murder is “A.B. murdered C.D.”; the statutory short form for manslaughter is “A.B. killed C.D.” MCL 767.44.
Accordingly, “[w]hen a statutory short-form information is used, the defendant has a statutory right to a bill of particulars, while when the common law long-form of information is used, the trial court may in its discretion order a bill of particulars.” People v Johnson, 427 Mich 98, 109-110 (1986). “Once a bill of particulars is supplied, a defendant has a right ‘to have the trial confined to the particulars set up therein.’” Id. at 110, quoting People v Ept, 299 Mich 324, 326 (1941). Accordingly, “the procedural implementation of MCL 767.44 assures that the defendant will have notice in advance of trial of the factual basis underlying the alleged offense.” Johnson, 427 Mich at 110.