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Filing # 67840688 E-Filed 02/12/2018 03:07:33 PM
IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT, IN AND FOR BREVARD COUNTY, FLORIDA
STATE OF FLORIDA, CASE NO. 05-2018-CF-10519-A
Plaintiff, DIVISION E vs.
OMAR QAZI,
Defendant.
NOTICE OF DISCOVERY
NOTICE IS GIVEN that the Defendant, Omar Qazi, by and through the undersigned attorney, pursuant to Florida Rule of Criminal Procedure 3.220(a), requests the disclosure of, and permission to inspect, copy, test, and photograph, the following information and material within the State’s possession or control:
1. A list of the names and addresses of all persons known to the prosecutor to have information that may be relevant to any offense charged or any defense thereto, or to any similar fact evidence to be presented at trial under section 90.404(2), Florida Statutes. The listed persons should be designated as either Category A, B, or C witnesses in accordance with Florida Rule of Criminal Procedure 3.220(1)(A)(@)-@ii);
2. The statement of any person whose name is furnished in
compliance with the preceding paragraph;
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3. Any written or recorded statements and the substance of any oral statements made by Mr. Qazi, 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;
4. Any written or recorded statements and the substance of any oral statements made by a codefendant if the trial is to be a joint one;
5. The term “statement” as used in the preceding paragraphs includes a written statement made by the person and signed or otherwise adopted or approved by the person and also includes any statement of any kind or manner made by the person and written or recorded or summarized in any writing or recording. The term “statement” is also specifically intended to include all police and investigative reports of any kind prepared for or in connection with the case;
6. Those portions of recorded grand jury minutes that contain testimony of Mr. Qazi;
7, Any tangible papers or objects that were obtained from or belonged to Mr. Qazi;
8. Whether the state has any material or information that has been
provided by a confidential informant;
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9, Whether there has been any electronic surveillance, including wiretapping, of the premises of Mr. Qazi or of conversations to which Mr. Qazi was a party and any related documents;
10. Whether there has been any search or seizure and any related documents;
11. Reports or statements of experts made in connection with this particular case, including results of physical or mental examinations and of scientific tests, experiments, or comparisons;
12. Any tangible papers or objects that the prosecuting attorney intends to use in any hearing or trial that were not obtained from, or did not belong to, Mr. Qazi;
13. Any tangible paper, objects, or substances in the possession of law enforcement that could be tested for DNA; and
14. Any material or information that has been provided by an informant witness, including:
14.1 The substance of any statement allegedly made by Mr. Qazi about which the informant witness may testify; 14.2. A summary of the criminal history record of the informant witness; 14.3 The time and place under which the alleged statement of Mr. Qazi was made;
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14.4 Whether the informant witness has received, or expects to receive, anything in exchange for his or her testimony; 14.5 The informant witness’ prior history of cooperation, in
return for any benefit, as known to the prosecutor.
WHEREFORE, Mr. Qazi respectfully requests that the State provide the requested information in a manner mutually agreeable or provide timely notice that a court order needs to be obtained in accordance with Florida Rule
of Criminal Procedure 3.220(n).
CERTIFICATE OF SERVICE
I CERTIFY that the foregoing document has been furnished to the Office of the State Attorney, 2725 Judge Fran Jamieson Way, Building D, Viera, FL 32940-6605 by electronic mail on February 12, 2018.
/s/ Richard E. Hornsby
Richard E. Hornsby, Esquire Florida Bar Number 474134 RICHARD E. HORNSBY, P.A.
1217 E. Robinson Street
Orlando, Florida 32801-2115 407-540-1551 | Fax: 407-540-1553 richard@richardhornsby.com
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Filing 67840688 STATE VS QAZI OMAR 05-201 8-CF-010519-AXXX-XX
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