DEFENDANT, by and through the undersigned attorney and pursuant to Rule 3.220,
Florida Rules of Criminal Procedure, hereby demands that the State Attorney of this Judicial Circuit furnish and disclose to the undersigned within fifteen (15) days after service of this Notice the following information and material:
- Pursuant to Rule 3.220(b)(1)(A), the names and addresses of all persons known to the prosecutor to have information which may be relevant to the offense charged, and to any defense with respect thereto.
- Pursuant to Rule 3.220(b)(1)(B), the statement of any person whose name is furnished in compliance with the request of Paragraph 1, above. The term “statement,” as used herein, includes, but is not limited to, a written statement made by said person and signed or otherwise adopted or approved by him/her, and any statement of any kind made by such person and written or recorded or summarized in any writing or recording. This definition specifically includes all police and investigative reports of any kind prepared for or in connection with the above-captioned case.
- Pursuant to Rule 3.220(b)(1)(C), any written or recorded statements and the substance of any oral statements made by the accused, including a copy of any statements contained in police reports or report summaries, together with the name and address of each witness to the statements.
- Pursuant to Rule 3.220(b)(1)(D), any written or recorded statements and substance of any oral statements made by a co-defendant, if the trial is to be a joint one.
- Pursuant to Rule 3.220(b)(1)(E), those portions of recorded grand jury minutes that contain testimony of the accused.
- Pursuant to Rule 3.220(b)(1)(F), any tangible papers or objects that were obtained from or belonged to the accused. Please indicate the individual location of each and every such item so as to permit inspection.
- Pursuant to Rule 3.220(b)(1)(G), whether the state has any materials or information which has been provided by a confidential informant.
- Pursuant to Rule 3.220(b)(1)(H), whether there has been any electronic surveillance, including wiretapping, of the premises of the accused, or of conversations to which the accused was a party, and any documents relating thereto.
- Pursuant to Rule 3.220(b)(1)(I), whether there has been any search or seizure and any documents relating thereto.
- Pursuant to Rule 3.220(b)(1)(J), reports or statements of experts made in connection with the particular case, including results of physical or mental examinations and of scientific tests, experiments, or comparisons.
- Pursuant to Rule 3.220(b)(1)(K), any tangible papers or objects that the prosecuting attorney intends to use in the hearing or trial and that were not obtained from or that did not belong to the accused.
- Pursuant to Rule 3.220(b)(4), any material or information within the State’s possession or control that tends to negate the guilt of the accused.
- Any and all criminal arrest records, rap sheets, or judgments of guilty of any witness disclosed by the State as a potential witness in the above-captioned case.
- The criminal record, if any, of the accused.