`
`IN THE CIRCUIT COURT OF THE
`FOURTH JUDICIAL CIRCUIT,
`IN AND
`FOR DUVAL COUNTY, FLORIDA.
`
`CASE NO.: 2020-CF-6033
`
`DIVISION: TBA
`
`STATE OF FLORIDA,
`
`vs.
`
`MAURICE TOMMIE YOUNG
`DEFENDANT.
`
`/
`
`NOTICE OF APPEARANCE, REQUEST
`
`FOR COPY OF CHARGES, WRITTEN PLEA
`OF NOT GUILTY, WAIVER OF APPEARANCE >
`AND NOTICE OF DISCOVERY
`
`The undersigned hereby enters his appearance as attorney for the Defendant.
`
`The Clerk of this Court, pursuant to Florida Rule of Criminal Procedure 3.140 (m), is
`hereby requested to furnish a copy ofthe Indictmentor Information with endorsements thereon
`to the undersignedattorney.
`
`Pursuant to Florida Rule of Criminal Procedure 3.170(a) Defendant hereby enters a plea of
`
`NOT GUILTYto all charges and waives personal appearance before the Court for arraignment and
`
`subsequent proceedings subject to this Court authorizing defense counselto file timely motions,
`
`otherwise due at the time of arraignment, within a reasonable timeafter his receipt of a copy ofthe
`
`requested documents.
`
`The Defendant, pursuant to Rule 3.220(a) Florida Rules of Criminal Procedure, files this
`
`notice of intent to participate in discovery and demands that the prosecuting attorney, within
`
`fifteen days, disclose to defense counsel and permit him/her to inspect, copy, test, and photograph,
`the following information and material within the State's possession and control:
`
`1. The names and addresses of all persons knownto the prosecutor to have information
`
`which maybe relevant to the offense charged, and to any defense with respectthereto.
`
`2. The statement of any person whose nameis furnished in compliance with the preceding
`
`paragraph, whether such statement
`
`is written,
`
`recorded or transcribed, signed or unsigned
`
`including a verbatim recital of any oral statement madeto an officer or agentofthe State.
`
`ACCEPTED: DUVAL COUNTY, RONNIE FUSSELL, CLERK, 07/10/2020 08:22:16 AM
`
`
`
`3. Any written or recorded statement and the substance of any oral statements made bythe
`
`accused together with the name and address of each witness to the statement.
`
`4. The records of all prior arrests, convictions and dispositions of any and all charges
`against Accused andofall witnesseslisted by the State.
`
`5. Any written or recorded statements and the substance of any oral statements made by a
`
`co-accused.
`
`6. Those portions of recorded grand jury minutesthat contain testimony of the Accused.
`
`7. Samples of any scientific tests, experiments or comparisons in such quantities as to
`allow counter scientific tests, experiments or comparisons to be made by any expert witness
`retained by the defense.
`
`8. Any tangible papers or objects which were obtained from or belonged to the accused.
`
`9. Whether the state has any material or information which has been provided by a
`confidential informant.
`
`10. 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.
`
`11. Whether there has been any search or seizure and any documents relating thereto.
`
`12. Reports or statements of experts made in connection with the particular case, including
`results of physical or mental examinations andofscientific tests, experiments or comparisons.
`
`13. Any tangible papers or objects which the prosecuting attorney intends to use at a
`
`hearingortrial and which were not obtained from or belongedto the accused.
`
`14. Any material information within the state's possession or control which tends to negate
`the guilt of the accused asto the offense charged.
`
`I HEREBY CERTIFYthat a true and correct copy of the foregoing was furnished by E-file
`Delivery this 6th day of July 2020, to the State Attorney's Office.
`
`BOWERSLAW OFFICE,P.L.L.C.
`
`/s/ Robert C. Bowers
`Robert C. Bowers, Esq.
`Florida Bar No.: 076852
`1830 Atlantic Blvd
`Jacksonville, Florida 32207
`Phone (904) 303-0853
`rb@bowerslawflorida.com
`
`
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