EFTA00179492¶
Filing¶
E-Filed 05/11/2016 02:33:12 PM¶
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT OF STATE OF FLORIDA IN AND FOR HILLSBOROUGH COUNTY CIRCUIT CRIMINAL DIVISION¶
STATE OF FLORIDA¶
CASE No.:¶
VS¶
DIVISION: B¶
NOTICE OF DISCOVERY¶
THE STATE OF FLORIDA, in response to defense counsel’s written Request for Discovery, pursuant to Rule 3.220 Florida Rules of Criminal Procedure, furnishes the following information:¶
- Pursuant to Rule 3.220(b)(1)(i), Florida Rules of Criminal Procedure, the names and addresses of all persons known to the State of Florida to have information which may be relevant to the offense charged or any defenses thereto or to any similar fact evidence to be presented at trial under F.S. 90.404 (2) are as follows:
All other Category A Witnesses pursuant to Rule 3.220 (b)(1)(A)(i), F.R.CR.P.:¶
STEPHEN HANILY,¶
QUALIFIED AS EXPERT CHEMIST¶
QUALIFIED AS FIELD NARCOTICS INVESTIGATION EXPERT¶
- Below is a list of the information and material within the State’s
possession or control which will be produced for defense counsel to inspect,¶
copy, test and photograph:¶
A) Pursuant to Rule 3.220(b)(1)(B), Florida Rules of Criminal Procedure, Statements by persons whose names are furnished in compliance with Rule 3.220(b)(1)(i), Florida Rules of Criminal Procedure.¶
NONE.¶
B) Pursuant to Rule 3.220(b)(1)(C), Florida Rules of Criminal Procedure, written, recorded and/or oral statements of the accused.¶
NONE.¶
Page 1 of 4¶
Notice of Discovery¶
EFTA00179493¶
C) Pursuant to Rule 3.220(b)(1)(D), Florida Rules of Criminal Procedure, written recorded and/or oral statements of the co-defendants.¶
NONE.¶
D) Pursuant to Rule 3.220(b)(1)(E), Florida Rules of Criminal Procedure, recorded Grand Jury minutes containing testimony of the accused.¶
NONE.¶
E) Pursuant to Rule 3.220(b)(1)(F), Florida Rules of Criminal Procedure, tangible papers or objects obtained from or belonging to the accused.¶
YES. Methamphetamine.¶
F) Pursuant to Rule 3.220(b)(1)(G), Florida Rules of Criminal Procedure, material or information provided by a confidential informant.¶
NONE.¶
G) Pursuant to Rule 3.220(b)(1)(H), Florida Rules of Criminal Procedure, electronic surveillance, pursuant to Chapter 934, Florida Statutes, of the premises of which the accused was a party, and documents relating thereto.¶
NONE.¶
H) Pursuant to Rule 3.220(b)(1)(I), Florida Rules of Criminal Procedure, whether there has been any search or seizure and any documents relating thereto.¶
NONE.¶
I) Pursuant to Rule 3.220(b)(1)(J), Florida Rules of Criminal Procedure, reports or statements by experts, including results of physical or mental examinations and of scientific tests, experiments or comparisons.¶
YES. FDLE results & reports are being furnished via email. Field Reagent Test. Stephen Hanily is qualified as Expert Chemist. Sigure R. O’Neal is qualified as Field Narcotics Investigation Expert.¶
J) Pursuant to Rule 3.220(b)(1)(K), Florida Rules of Criminal Procedure, tangible papers or objects intended for use at hearing or trial which were not obtained from or belonged to the accused.¶
NONE.¶
K) Pursuant to Rule 3.220(b)(1)(L), Florida Rules of Criminal Procedure, any tangible paper, objects or substances in the possession of law enforcement that could be tested for DNA.¶
NONE.¶
L) Pursuant to Rule 3.220(1)(b)(M), Florida Rules of Criminal Procedure, whether the state has any material or information that has been provided by an informant witness.¶
NONE.¶
Page 2 of 4¶
Notice of Discovery¶
EFTA00179494¶
-
Pursuant to Rule 3.220(b)(2), Florida Rules of Criminal Procedure, the following material information is within the State’s possession or control which tends to negate the guilt of the accused as to the offense charged: NONE.
-
In addition, please be advised that any information contained in reports or other materials provided to you pursuant to your request for discovery is deemed to be included in this response even if not specifically noted above.
-
At a time mutually convenient to the State of Florida and defense counsel, the State will disclose to defense counsel and permit him to inspect, copy, test and photograph all information and material within the State’s possession and control pursuant to Florida Rules of Criminal Procedure 3.220(b)(iii) through (xi).
-
Pursuant to Rule 3.220(d)(1), Florida Rules of Criminal Procedure, the State of Florida expects a written list of the names and addresses of all witnesses whom defense counsel expects to call as witnesses at the trial or hearing of this case within seven days after receipt of the witness list furnished by the State of Florida.
-
Pursuant to Rule 3.220(d)(2), Florida Rules of Criminal Procedure, the State of Florida expects a disclosure of the items set forth in subsections (i)-(iii) of Rule 3.220(d) within fifteen days after the corresponding disclosure by the State of Florida.
-
In addition to the above, be advised of the following: A copy of TPD agency report number 2016-00190882 is being furnished via email. Scoresheet previously provided. Regarding statements of the accused see law enforcement reports and interview witnesses listed. All witnesses listed in police report and additional witnesses may be called to testify.
Page 3 of 4¶
Notice of Discovery¶
EFTA00179495¶
I HEREBY CERTIFY that a copy of the foregoing Notice of Discovery has been furnished by email to JULIAN A HAYES, JHAYES@HAYESATTORNEY.COM, P O BOX 271682, TAMPA, FL 33688, attorney for defendant, COURTNEY ELIZABETH MOODY, this 10th day of May, 2016.¶
Respectfully submitted,¶
MARK A. OBER¶
STATE ATTORNEY¶
/S/CAMARIA Z, PETTIS-MACKLE¶
CZPM/mjb¶
CAMARIA Z. PETTIS-MACKLE¶
ASSISTANT STATE ATTORNEY¶
FLORIDA BAR# 66243¶
STATE ATTORNEY’S OFFICE¶
TAMPA, FL 33602-4022¶
Page 4 of 4¶
Notice of Discovery¶