DEFENDANT, by and through the undersigned attorney and pursuant to Rule 3.220(f), Florida Rules of Criminal Procedure, hereby moves this Honorable Court for an Order requiring the State of Florida to produce the following items in discovery. As grounds for this Motion, Defendant states as follows:

  1. The Jacksonville Sheriff’s Office has implemented the use of video/dvd/cd cameras in a significant percentage of its police patrol vehicles, including those used in the DUI Enforcement Division and other traffic enforcement divisions. The purpose of this evidence gathering technique is to record and to preserve traffic and roadside contact of police with the general public. The evidence typically gathered in such video footage includes the driving pattern of a defendant, statements made by defendants, gestures and demeanor of defendants, field sobriety exercises, and the conduct of arrests or citation issuance.
  2. With regard to criminal traffic violations or driving offenses, such as DUI, Racing on Highways, and Reckless Driving, this evidence is highly relevant and is discoverable material in accordance with Rule 3.220, Florida Rules of Criminal Procedure.
  3. On or about March 20, 2012, Defendant was subjected to a traffic stop by an Officer Ayers (Badge #1425) of the Jacksonville Sheriff’s Office, and cited for alleged Racing on Highways.
  4. Defendant has reason to believe that, on the date and time of this traffic stop, a video, DVD, or CD camera was in use in the patrol vehicle used by Officer Ayers.
  5. Defendant has reason to believe that, if such video exists, it would provide exculpatory evidence as to Defendant’s true driving pattern, or would otherwise call into question the veracity of the allegations made by Officer Ayers in the instant case.
  6. Accordingly, Defendant seeks an exact copy of the videotape, dvd, or cd produced in connection with the camera installed in Officer Ayers’ patrol vehicle.

WHEREFORE, Defendant respectfully requests that this Honorable Court enter an Order requiring the State of Florida to produce the aforesaid items for Defendant or for Defendant’s inspection.