Docstoc

tate ttorne

Document Sample
tate ttorne Powered By Docstoc
					                                                     ~tate ~ttorne!,
                                              SEVENTEENTH JUDICIAL CIRCUIT OF FLORIDA
                                              SUITE 665 BROWARD COUNTY COURTHOUSE
                                                  FORT LAUDERDALE, FLORIDA 33301
                                                        TELEPHONE (954) 831-5893


MICHAEL J. SATZ
 STATE ATTORNEY



 February 2, 2010


 Mr. Howard Finkelstein
 Public Defender
 Office of the Public Defender, 17th Judicial Circuit
 Suite 3872, Broward County Courthouse
 201 Southeast Sixth Street
 Fort Lauderdale, Florida 33301

 Dear Mr. Finkelstein:

 This letter is in further response to your letter of January 12, 2010. You mentioned in your letter
 the "Brady Disclosure" by Assistant State Attorney Sheila Alu, which you refer to as the "Alu
 Disclosure." You indicate that your chief assistants could find no Brady disclosures for these
 police officers prior to the September 6, 2009 "Alu Disclosure." I do not understand why you
 could not find prior disclosures, as we have found many Brady disclosures for the same officers
 that were sent to assistant public defenders in your office in individual cases. I have attached
 copies ofthese notices thafwerèsent to yòÍJr òffice before the so-called "Alu Disclosure" was
 made. '
 A computer program has been in existence in this office for many years in order to assist our
 ~ssistant state attorneys to comply with Brady responsibilities. In fact, the source of the "Alu
 Disclosure" was the computer program designed to aid assistant state attorneys in formulating
 possible Brady notices. The fact that a computer program was set up with regard to possible
 Brady information rebuts your mistaken conclusion regarding "systemic nondisclosure."

 It is true that we have streamlined and improved our delivery of possible Brady information.
 Initially, our procedure consisted of our Special Prosecutions Unit receiving information from all
 other units in our office that were investigating                  police offièers. The Special Prosecutions Unit
would then enter the police officer under investigation into our computer system. The computer
would then generate a notice to the individual assistant state attorney to determine if there was,
 in fact, Brady information. The intent of this system was to allow the individual assistant state
attorney to make a professional determination as to possible Brady information. The form of
Assistant State Attorney Alu's disclosure (an email with the names of officers without the
information of why it was possibly Brady information) was an indication to us that our system
needed improving. We therefore improved our system.

The new process no longer leaves it up to the individual assistant state attorney to determine if
the information is "material" and therefore Brady. See Floyd v. State, 18 SO.3d 432 (Fla. 2009);
and Riechmann v. State, 966 SO.2d 298 (Fla. 2007); Brady requires the State to disclose
material information within its possession or control that is favorable to the defense. The
Letter/Howard Finkelstein, Public Defender                                               Page -2-
February 2, 2010.

"onslaught," as you call it, is a result of this new supplemental discovery practice which far
exceeds our Brady obligations. While continuing our practice of disclosing material
information, I have made the decision to send out supplemental disclosures of the existence of
pending investigations (not accessible to the defense) on all police officers listed in our
discovery, even in nonmaterial cases, so long as no investigation is compromised. It is this
decision to provide you additional information - information beyond that required by Brady -
which generated the discovery notices you termed "troubling." Contrary to your suggestion, this
decision to provide more than the law requires does not imply           a systemic failure to comply with
the law in our past disclosures.

Your allegation "that there are two systems of justice at work in the State Attorney's Offce" is
both false and irresponsible. We file criminal charges in cases where there is a reasonable
likelihood of conviction and we will be able to carry our burden of proving charges beyond and
to the exclusion of every reasonable doubt. We apply this standard to every case we consider
with reference to .all persons, whether rich or poor, police officer or civilian. People may
disagree in individual cases, for none of these decisions are easily made. You are no doubt
aware of these difficulties as you have been involved in the criminal justice system for some
thirty years. I would not expect you, as the Public Defender, to agree on everyone of the
decisions we made in the 25,000 felony cases we                 reviewed in 2009, let alone the tens of
thousands of misdemeanor and juvenile cases that we also reviewed.

i will now address your accusation that we treat police officers differently when we consider
filing criminal charges against them. In your letter, you refer to six cases out of the numerous
close-out memos provided to your office. These cases were reviewed by four highly
experienced, dedicated assistant state attorneys: Catherine Maus, Michael Horowitz, David
Schulson and Timothy Donnelly. In each one of these six cases you state that criminal charges
shoùld have been filed against these police officers. In each one of these cases, there was no
likelihood of conviction and these cases could not have been proven beyond and to the
exclusion of every reasonable doubt. i have attached a close-out memorandum on each of
these cases.


Fort Lauderdale Police Officer Daniel Zavadil was not accused of falsifying a police report nor
did he make such an admission, as you claim in your letter. Officer Zavadil admitted to signing
the name of an individual on a Notice to Appear for Panhandling next to that person's inked
thumbprint. The charge of forgery requires a person to falsely alter or forge a public document
with the specific intent to injure or defraud an individuaL. In this case, there is insufficient
evidence that the officer had the intent to injure or defraud anyone at the time he signed the
Notice to Appear. This case was appropriately referred back to the Fort Lauderdale Police
Department to take whatever appropriate administrative action deemed necessary.

You state in your letter, "Hollywood Police Officer Matthew Goodnow was accused of
misappropriating funds obtained in undercover drug operations; again Special Prosecutions did
not prosecute, despite independent witnesses, and no Brady notices were filed." This is a false
statement in two respects. First, Officer Goodnow was not accused of misappropriating funds.
In 2005, Officer Goodnow accused a fellow officer, a lieutenant, of allegedly misappropriating
$100.00 recovered in an undercover drug operation. Furthermore, contrary to your allegation,
Brady notices regarding Officer Goodnow were sent to your office and i have enclosed several
examples.
Letter/Howard Finkelstein, Public Defender                                                 Page -3-
February 2, 2010.

Officer John Lafontant of the Lauderhill Police Department signed the name of an automobile
theft victim on an affidavit in order to enter the stolen vehicle information into the teletype
system. As in Fort Lauderdale Police Department Officer Daniel Zavadil's case, there was
insufficient evidence that the officer had the intent to injure or defraud anyone, and there was no
likelihood of conviction. A Brady notice was sent; see attached.

None of these six cases that you cite in your letter remotely supports your allegation that
Catherine Maus, Michael Horowitz, David Schulson and Timothy Donnelly used a "double
standard" in handling these cases. If these individuals were not law enforcement officers, the
results would have been the same. Again, i enclose all six close-out memorandums for you or
anyone else to review.

Lastly, your allegations of a systemic failure to disclose Brady information reflects a complete
misunderstanding of our office's efforts to exceed its basic requirements.

The Florida Supreme Court has expressly rejected your suggestion that Brady demands the
disclosure of any and all information the defense chooses to claim beneficiaL. To the contrary,
                                     "material" evidence favorable to the accused. See Davis v.
the law requires the disclosure of all

State, 34 Fla. L. Weekly S605 (Fla. November 5, 2009); Hurst v. State, 18 SO.3d 975, 988 (Fla.
2009); Floyd v. State, 18 SO.3d 432, 450 (Fla. 2009); Byrd v. State, 14 SO.3d 921, 925 (Fla.
2009). See also Strickler v. Greene, 527 U.S. 263, 119 S.Ct. 1936 (1999). There is no dispute
or confusion over the definition of "material"; evidence does not meet the Brady standard unless
it puts "the whole case in such a different light" as to undermine confidence in a verdict reached
without it. Davis, supra; Floyd, at 450 citing Strickler, at 290; Byrd, at 925.

Although our present disclosure standard is broader than this heightened test of "materiality,"
the State's pre-trial obligation is to provide favorable information when it is of such a nature that
there is a "reasonable probability" the outcome of the proceedings would be different but for its
omission. Young v. State, 739 SO.2d 553,558 (Fla. 1999) citing Kyles v. Whitley, 514 U.S. 419,
115 S.Ct. 1555 (1995) ("00'              the prosecution, which alone can know what is undisclosed, must be
assigned the consequent responsibilty to gauge the likely net effect of all such evidence and
make disclosure when the point of 'reasonable probability' is reached. 'J

Your letter makes no mention of this established legal standard. Moreover, your allegations
implicitly reject this well-settled law as they assume any form of information can constitute Brady
evidence without need for consideration of their context in each individual case in determining
materiality. The assertion you make in your letter that "The post conviction Brady standard is
not applicable in the pretrial Brady context" is a misstatement of the law. To support this
assertion in your letter, you quoted a paragraph from a seminal United States Supreme Court
opinion - United States v. Agurs, 427 U.S. 97, 108, 96 S.Ct. 2392, 49 L.Ed.2d 342 (1976). I
note that you excluded the last sentence of the paragraph that clearly contradicts your
assertion. That last sentence emphatically states: "But to reiterate a critical point, the
proseçutor wil not have violated his constitutional duty of disclosure unless his omission is of
sufficient significance to result in the denial of the defendant's right to a fair trial." In fact, in the
preceding paragraph the Court, in Agurs, took the position that the same standard of
"materialiy" must "logically" apply at both the pre-trial and post-conviction stages.

It appears your errant assumption is merely parroting the recent disclosures made by our office
which go beyond the law's basic requirements and provide additional information which might
assist the defense. Our decision to do more than Brady demands does not create new
Letter/Howard Finkelstein, Public Defender                                      Page -4-
February 2, 2010.

obligations. Nor does it relieve you of your responsibility to conduct reasonable investigation
into your own cases and obtain that information which is equally accessible to both parties. See
again Floyd, at 451 citing Provenzano v. State, 616 SO.2d 428, 430 (Fla. 1993); Riechmann v.
State, 966 SO.2d 298, 308 (Fla. 2007).

Nevertheless, as i previously stated in my letter of January 13, 2010, I welcome you to bring to
my attention any case in which a defendant was prejudiced by the failure to provide materially
favorable evidence in his or her case.




enclosures: as noted
  ~i~G~~r~~~~~i!;~1q!.~f~:~fJt;n~~1~~~~~K~gi~I~i~LKr~rl~~~~~i~;~:;r~~~g1~l~~~~1~~ff~~~~~:~J~J~~~i:~~1~:~~it;~~~l!~~i~~i~i~¡i~~~i~

   TO:                   SAO FILE

   FROM:                David Schulson

   SUBJ:                Offcer Joseph Devito/Margate Police OffcerISP07..4..39

   DATE:                April     17, 2007

  REASON FOR CLOSEOUT:

        On January 18, 2007, Sgt. Gary M. Paquin of the Jnternal Jnvestigations Unit of
  the Margate Police Department initiated an administrative investigation of Off. Joseph
  Devito. The investigation focused on the circumstances related to damage to marked
  pòlice unit 578 while in the possession of Off. Devito, on Dec. 28 & 29, 2006.

           On the morning of Dec. 29, 2006, Off. Devito contacted Sgt. Scott Vegotsky and
 initially informed him that unit 578 had incurred damage while parking overnight at Off.
 Devito's residence in N. Lauderdale. Sgt. Vegotsky then instructed Offcer Devito to
 report the incident to BSO's N. Lauderdale District.

          Off. Devito proceeded to speak with a SSC call taker and, in pertinent part,
 stated "I live in North Lauderdale and last night somebody hit my marked unit in the
 parking lot overnight. My sergeant told me to call you to have a deputy or CSA come
 by and take a report."

          Shortly after Off. Devito's call to 8S0, Dept. Rpn Carlson responded to the
                                                           unit 578. Based upon his
Devito residence to investigate Devito's report of damage to

examination of the damage to unit 578, Dept. Carlson had the following conversation
with Off. Devito as memorialized in his SSO Event Report:

         "I asked Offcer Devito if he was certain that the damage occurred at this
location, or if it could have occurred elsewhere. He said that he had been at a detail at
Lakewood Mall last night and had not looked at the passenger side prior to entering
his vehicle and driving home, and had discovered the damage just prior to callng in.
He said that it could have occurred there without his knowledge."

    As Dept. Carlson was conducting his investigation, Sgt. Kerin Stewart of the
Margate Police Dept. arrived at the Devito residence at
                                                        approximately 10:30 am to
complete a Florida Traffc Crash Report. As memorialized in the Florida Traffic Crash
Report, Sgt. Steward detailed her initial conversation with Off. Devito as follows:

        "Offcer Devito told me he came out of his apartment this morning to empty his
garbage and found damage to the passenger side of his assigned marked PD unit
#578. i told Ofcer Devito my first impression of the damage was that his car hit a
        .:



0)



         yeflow pole. Offcer Devito told me that he dId not hit a pole, and if he did, he would
         have heard the crash." .
            Aftercompletingher on scene investigation and learning from Dept. Carlson that,
        based upon the damage to. unit 578, he did not believe that the vehicle had been
        damaged in the parking Jot of the apartment complex; Sgt. Stewart returned to. the
        Margate Police Department and told Capt. Watson that she believed that unit 578 had
        hit a pole. Sgt. Stewart then left the station with Sgt. Palma, and they. went to the
        Lakewood Mall. As they drove around the Lakewood Mall, Sgts. Stewart and Palma
        found a yellow pole with evidence of damage and paint transfer consistent with
        damage observed on unit 578.

           As a result of locating the evidence on the yellow' pole at the Lakewood Mall,
      . Capt. Watson instructed Sgts. Stewart and Palma to reinteiview Off. Devito. The
       Florida Traffic Crash Report memorialized the Devito reintervÎew as follows:

                  Officer Devito "said that he had lied about" the Hit
                                                                         and Run occurring in North
       Lauderdale. Offcer Devito stated that on Thursday, December 28, ,at approximately
       8:00 PM, he was   patrollng the area of the Lakewood Mall. While he was driving
       around the rear of the building, he noticed a tractor-trailer backed up to the rear of
       one of the businesses. Offcer Devito said that he thought he would have enough
       room to drive by the truck. As Offcer Devito was passing to the right of the truck, he
       stated th.at he heard a' noise. He said that he thought he hit the curb so he stopped
      and checked both passenger side tires. Officer Devito said there was no noticeable
      damage to the tires so he returned patrollng the area. Ofcer Devito said that the
      incident was bothering him so he rechecked the passenger side of his vehicle again
      and saw the damage, Officer Devito said he was so upset about the crash that he felt
      sick, so he called Sergeant Palma to see if he could go home, which he did, at
      approximately 9:00 PM without reporting a crash."

                 As a result of the investigation conducted by SSO Dept. Ron Carlson, Sgts.
      Stewart and Palma, and lead investigator Sgt. Gary Paquin, Margate Chief of Police
      Jerr A. Blough, formally notified Off. Devito in a memorandum dated January 31,
      2007 that he was alleged to be in violation of numerous General Orders, several
     . Florida State Statutes. and a section of the FloridaAdministrative Code.

                In order to determine whether criminal charges should be fied against Of.
      Devito, I have thoroughly reviewed the following documents produced during the
      course of the Margate Police Department administrative investigation: .


      1. A 47 page Memorandum. of the administrative investigation prepared by Sgt.
             Paquin and dated February 26, 2007; .
     2. The Notification of Administrative Investigation from Chief Blough to Of. Devito
             dated January            31 , 2007;
     3. The BSO Event Report prepared by Dept. Ron Carlson;
     4. The Florida Traffc Crash Report prepared by Sgt. Stewart;
     I ;."


             I"

I~



       5. Transcript of Off. Devito's call to SSO Communications on December 29, 2006;
       6. Sworn statements of Dept. Ron Carlson, Sgt. Richard Anton, Adam Malec, Alan
          Duke, and Jason Cumbers;
       7. Photographs;
       8. SSO Crime Laboratory Analysis Report
       9. Memorandum prepared by Sgt. Kerin Stewart and dated December 30, 2006.

                  While , have determined that Offcer Devito's statements to Dept. Ron CarlSon
      and Sgt. Kerin Stewart on the morning of December 29th were materially false as to
      the circumstances resulting in the damage to unit 578, I have concluded that there is
      not a reasonable likelihood of convicting Offcer Dévito of the charges of
                                                                                       Offcial
      Misconduct and Falsifying Records.

          While a recantation defense to a perjury charge is not a defense to the charges
      of Offcial Misconduct and Falsifying Records, i have con~idered certain aspects of
     the recantation defense in analyzing the reasonable likelihood of conviction issue.
     When Off. Devito first meets with 8g1. Stewart on the morning of December 29th, he
     does falsely state to her that he only saw the damage to the vehicle when he came
     out to empty his garbage earlier that same mominw. Ho.wever, ~hen reinteNiew~ by
     8gts. Stewart and Palma at 8 pm on December 29t , Officer Devito truthfully descnbes
     the cause of the crash. 80th Devito's false and truthful statements are memorialized
     in the same Florida Traffc Crash Report.

           While Off. Devito's decision not to truthfully and immediately report the accident
     to a supervisor was improper, wrong, and clearly in Violation of the numerous General
     Orders cited in Chief Blough's Notification of Administrative Investigation, i have
     essentially concluded that a jury would view Devito's remorseful recantation on the
     night of December 29th as a legitimate reason not to convict Devito of criminal
     charges. Thus, this matter should be deferred for administrative handling by the
     Margate Police Department.




                               ¿
                              ./      i
     .t., ~..




""




                TO:         SAO FILE

                FROM:       Michael Horowitzl~
                            Assistant State Attorney

                SUBJ:       Debra Bridgeman
                            James Bridgeman
                            SP06-06-048

                DATE:       December 31, 2007
                            ." - -

                B. EA§.QllB CLOSEOUT:
                      This case was originally opened in June 2006 to assist the Broward County
                Sherìf's Office Internal Affairs Unit in its investigation into Deputies Debra Bridgeman
                and James Bridgeman involving allegations of Insurance Fraud regarding insurance
                claims they made after Hurricane Wilma and Offenses Against Computer Users
                aøainst Deputy Debra Sridgemanfor her excessive use of the teletype
                comrnunícations to run criminal background checks on individuals. In November of
                2007 Detective Mitch Gordon and Sergeant Mary Guess provided the State Attorney's
                Offic:~ with.nurnerous documents relating to this investigation. .

                     Debra Bridgeman and James Bridgeman. husband and wife, are both employed
                as deputies for the Broward County Sheriff's Office. In June of 2005 the Sridgemans
                bought a house in Southwest Ranches. At the time they became friendly with one of
                their neighbors Juan Echevarria, Over time thè relationship between the neighbors
                deteriorated to the point of each filing police repoiis against the other, each 'accusing
                the other of crimes, internal affairs complaints by Echevarria against the Bridgernans,
                and restraining orders.

                      One of Eclievarria's cornptaints against the Bridgemans included allegations of
                insurance fraud. After Hurricane Wilma a car owned by the Bridgemans had a back
                window damaged. Echevarria claims that Debra Bridgeman wanted the car to be
                totaled so he took his skid loader over to the Bridgeman's propert and used it to pick
                up a large branch and struck the c.ar with the branches to cause extensive damage to
                car. According to Echevarria, Mr. Bridgeman ran a hose inside the car to cause
                further damage to the car. According to Echevarria this was done so that the
                insurance company would consider the car damage a total lost. The incident was
                wìtnessed by Echevarri.a's daughter Cynthia Echevarria.

                     The Bridgemans provided sworn testimony, documents, and photographs to th'e
                ínsurance company's investigators regarding their claim. They stated that the damage
                to the Gar Vias caused by Hurricane Wilma and they called the insurance company to
-::




      report the damage to the car. They were told based on the damage              they described
      that the car would be totaled but it would be a while before an adjuster could come
      out. Some time after that Echevarria came over to the Bridgeman's house with a skid
      loader to remove large branches that had fallen during the hurricane.       According to the
      Bridgemans, as Echevarria was moving large branches he struck the car and caused
      additional damage to the car. The Sridgemans became upset with Echevarria, yelled
      at him to stop, and told him to leave.


              Also, Echevarria claims that .the Bridgemans fraudulently made an insurance
      claim for a fence that had been removed prior to Hurricane Wilma. Echevarria stated
      that after the Brídgernans bought the house they removed a wooden fence that
      surrounded the property and purchased a new fence to be installed. After the old
      fence was removed and before the new fence was installed Hurricane Wilma hit.
      Echevarria stated the Sridgemans collected insurance proceeds             for the loss of the
      fence when they had removed the fence prior to the hurricane.

              The Bridgemans provided the insurance company with receipts, invoices,
      checks, and photographs to document their claim for loss of the fence. The
      Bridgemans ordered a new PVC fence several days before Hurricane Katrina in
      r\ugust 2005. When Hurricane Katrina hit the Bridgemaiis had damage to their
      property including the old fence that surrounded their property. Although they did file a
      claim for damage to their property for damage caused by Hurricane Katrina, they did
      not report the damage to the fence because they did not believe the fence was
      covered by their insurance. After Hurricane Katrina, but before Hurricane Wilma, the
      new fence had been delivered. The Bridgemans had removed sections of the old
      fence that had been damaged by Katrina and had begun installing post for the new
      fence. Hurricane Wilma caused damage to the Bridgeman's property including their
      house, car, and portions of their old and new fence. When they spoke to the
      insurance adjuster, he told them that fence damage was covered by their insurance.
      The insurance company paid the Bridgeman's claim including the fence.

              The insurance company conducted an investigation into the possibility of
      insurance fraud. They reviewed the documentation provided by the Bridgemans to
      support their         insurance claims. As part of their investigation the insurance company
      took sworn statements from the Sridgemans and Echevarria. According to Sergeant
      Guess and Detective Gordon, the insurance company paid the claims for the fence
      and car and they are not pursuing any case for insurance fraud against the
      Brìdgemans for their insurance claims for loss caused by Hurricane Katrina or
      Hurricane Witma.

             As to the claim for insurance fraud there is insuffcient evidence to support the
      charge. The main witness Echevarria has questionable motives and credibility based
      on the antagonistic relationship that has developed between himself and the
      Bridgemans. Additionally, the insurance company after completing its investigation
      does not feel that there was sufficient evidence to pursue a case for insurance fraud.
      Therefore, it is recommended that no criminal charges be filed based on the
,.




     allegation of insurance fraud due to the lack of evidence and conflicts in the evidence
     to support such a charge.

          The other part of the investigation involved a possible charge of Offenses
     Against Computer Users for Debra Bridgeman based on her running multiple criminal
     history checks on her neighbors including Mr. Echevarria and his famíly, As a deputy
     sheriff she is authorized to contact communication to have an individual's criminal
     history checked. The fact that she may have abused her privilege or exceeded the
     authority given to her by the sheriffs office to run criminal history checks does not give
     rise to a criminal char~e for Offenses Against Computer Users. Rodriguez v. Sate,
     9r:i6 SO.2d 1226 (Fla. 4 ) DCA 2007).

          Therefore, it is recommended that based on the fact stated above that no
     criminal charges are filed and this case be closed.
~;~t:~~;f.~~~,r;~:;ft%~l~~~m;ftf~fn~;~:~:~r~~m;i~~f.~Jl:¡;¡f~~1~;~I;¡;:~Eli~ti~Jkk;¡:i:~¡l~r~\;:~.i'.~I~;'mft.J;~~l~~~~?~t*Er~:t;~~Sl(~;;.:'£~


 TO:                 SAO FILE

 FROM:               Michael Horowitz 1\ r L
                     Assistant State Att~~nii
 SUBJ:               John Lafontant
                     SP08~.094
 DATE:               November 14,2008

 REASON FOR CLOSEOUT:

         Lauderhill Police Department forwarded an allegation of forgery of an auto theft
 affdavit by Offcer John Lafontant. A teletype operator noticed that the victim's name
was misspelled on the affdavit and the signature did not match the victim's driver's
license signature. The victim was contacted and indicated that she did not sign the
form and did not authorize anyone to sign the form,

         The victim called Lauderhll Police Department to report that her car had been
stolen. Officer Lafontant responded to the call and met with the victim and completed
an incident report. Part of the paperwork he needed to complete in order to enter the
information into teletype is an affdavit from the victim that she did not trade her car for
drugs. Officer Lafontant provided a voluntary sworn statement that after he left the
scene he went to the station to enter the information into teletype and realized that he
forgot to have the victim sign the auto theft affidavit that he filled out while at the
scene with the victim. Due to him being backed up on ~aiis.to respond to and in order
to expedite the entry of the information into teletype he signed the victim's name
rather then return back to the scene to have her sign the form. There was no benefit
to the offcer and no harm to the victim. The victim's car was recovered and returned
to the victim. The victim stated that she did not want to see the offcer dìsciplined.

      . Based on the facts of this case no criminal charges wil be filed and it wil be sent
'back to the Lauderhil Po.lice Department to take whatever administrative action they
 deem necessary.
             1J
 ~ .::
'..;1: ;or
.. - ~...




             TO:            SAO FILE

             FROM:          Michael HorOWi~ \t
                            Assistant State Attor~ày

           SUBJ:            Daniel Zavadil
                            SP09~5-043
             DATE:          August 27, 2009                                         -

           REASON FOR CLOSEOUT: .
                    Offcer Zavadil submitted a police report and a notice to appear for panhandling
          issued to Daniel Roberts to his supervisor Sergeant Greenlaw for his approvaL.
          Sergeant Greenlaw saw' the notice to appear did have an inked thumb print of the
          defendant Daniel Roberts, but did not have his signature. Sergeant Greenlaw returned
          the report and notice to appear back to Zavadil with a note for Zavadil to see him and
         . questioning the lack of a signature. A few days later the report and notice to appear
         were returned to Sergeant Greenlaw with a signature. Sergeant Greenlaw contacted
         Zavadil to speak to him about the signature and the policy of not issuing a notice to
         appear for panhandling. When questioned about the signature Zavadil acimitted that he
         signed the notice to' appear. When Zavadil attempted to explain Sergeant Greenlaw
         stopped him and reported this to his chain of command. The notice to appear and the
         charges against Roberts were never processed and Roberts was never prosecuted for
         pan handling.


                   Daniel   Roberts gave a statement to Fort Lauderdale Internal Affairs that the
         signature on the notice to appear was not his and he produced his copy of the notice to
         appear which did not have a signature. Handwriting examination of the notice to appear
         indicates that the signature on the notice to appear was not Roberts' signature. The
         notice to appear had an ink thumbprint on it which matched Roberts, Fort Lauderdale
         Police Department foiwarded this investigation to the State Attorney's Offce to review
         for the .charge of forgery against Offcer ZavadiL.

                      of this investigation this ASA met with Sergeant Greenlaw and attempted
                  As part

         to meet with Roberts. This ASA spoke to Roberts on the telephone and he agreed to
         meet on July 31, 2009 but he failed to appear. Several telephone messages were left
         for Roberts with no return call. Sergeant McCarthy spoke to Roberts who stated he did
      not want any involvement with the case. Based on Roberts' failure to appear i had a
      State Attorney investigator personally serve Roberts with a mandatory subpoena for
      August 12, 2009. When State Attorney Investigator Walley mad.e contact with Roberts .
         by telephone, Roberts told Walley that he was not going to meet with him or appear
      because he did not want to testify against a policeman, that the policeman had a family
      and he did not want him to lose his job. Roberts stated that he would not testify at a
"'0.

t. ,.
                      "
           ..



         :. ;.-.'- ~~. -t : ~~:-;:.':~ :~~:.~~~~'.T':;- ~--::. .:?~~.::: -.; :::':.:~.~ :'~/i.~~~:~'~~:~~; :.:~~~;:~~~'~/;~'~~;~i;:~dJ;il¡~¡LTf::~;~:~~;;~W~::~~4:~;!7.:~~~~



          TO:                   SAO FILE

          FROM:                . David Schulson .

         susJ:                  SSO Deputy Roberto Aspuru
                                SPOB.08-084

         DATE:                  September 4, 2008

         REASON FOR CLOSEOU~

                  On August 13, 2008, Sergeant Joseph Muller of the SSG Divísíon of Intemal
        Affairs, requested a 8roward SAO review of
                                                      an allegation of theft as to 8S0 Deputy
         Roberto Aspuru.

        On April 9, 2008, Deputy Aspuru conducted a traffiç stop on a 1997 Toyota driven by
        a Ryan Gayle. In a search incident to
                                                                                           the arrest of Gayle for a misdemeanor
        Possession of Marijuana, Deputy Aspuru discovered 57 grams of MDMAJEcstasy pils
        and proceeded to additionally charge Gayle with Traffcking in Phenethylamines. For
        forfeiture purposes, Deputy Aspuru also seized the Toyota as well as $502.47 in
        Gayle's possession. The $502.47 was placed into evidence by Deputy Aspuru and
        included 2 $100 bills.

        After Gayle's arrest on April 9th, 'Gayle through his attorney, Paul Lazarus, fied a
        complaint against Deputy Aspuru essentially alleging
                                                                that Deputy Aspuru had not
        placed all of the money in Gßyle's possession into evidence. On April
                                                                                                                                             15, 2008, Gayle
       provided a sworn statement to Sergeant Muller. In the sworn statement, Gayle
       testified that on April 8, 2008 he had received $700 in cash (which included 3-4 $100
       bills) as a rent payment from Dionne's Hair Store. (On April 17, 2008, Paul Lazarus
       faxed a copy of a receipt reflecting the $700 rent payment to Sergeant Muller.) Gayle
       further testified that, as Deputy Aspuru was transporting him to jail, Deputy Aspuru
       stopped at a Shell gas station in Cooper City to check whether any of the money was
       counterfeit.

       On April 15, 2008, Sergeant Muller took a sworn statement from a Brandon Arnold, a
       clerk employed at the Shell gas station in Cooper Cit. Brandon Arnold 'confirmed that
       Deputy Aspuru had stopped at the Shell gas station on April 9th and asked Mr. Arnold
       to verify whether 3 $100 bils we~e counterfeit or not. Mr. Arnold also confirmed that
       Deput Aspuru left an inmate alone in his patrol van while meeting with him inside the
       store. Sergeant Muller also recovered a surveilance video from the Shell gas station'
       which confirmed Deputy Aspuru's visit to the station on April 9th.
.,.

~ '" /I
            .'


       At the request of Sergeant Muller, Sergeant Michael DeVita of the Division of Internal
       Affairs, administered a polygraph examination of Gayle on April 17, 2008. Sergeant
        DeVita concluded that Gayle "attempted deception" as to questions asking whether
      . Deputy Aspuru actually took some of his money. In his report, Sergeant DeVita
       specifically stated that Gayle "seemed genuinely confused and unsure of how much
       money he had at the time of his arrest. Gayle indicated that he made several stops
      between the time he left Gayle Plaza and when he was arrested. Gayle indicated that
      he could have let his friend "Dave" borrow some money that day. I advised Gayle that
      the deputy   submitted $502.47. Gayle said that he was not sure how much money he
      had, but felt it was more than the amount submitted for forfeiture. Gayle advised that
      his lack of confidence regarding the amount of money he possessed keeps him from
      insisting that the money was stolen." .
      While Brandon Arnold, the Shelf gas station clerk, clearly remembers examining 3
      $100 bills received from Deputy Aspuru and only 2 $100. bils were subsequently
      placed into evidence by Deputy Aspuru, the conflicting statements of Gayle to
      Sergeant Muller on April 16th and to Sergeant DeVita on April 1 yth create a significant
      proof problem as to whether Deputy Aspuru actually stole àt least 1 $100 bill from
      Gayle. Based upon my review of all sworn statements taken by Sergeant Muller and
      other evidence obtained by Sergeant Muller, there is no reasonable likelihood of
      convicting Deputy Aspuru of petit theft. However, B$O has an ongoing internal
                  of Deputy Aspuru as to such issues as leaving an inmate alone in a
      investigation

      patrol van and Ih7dling and processing of             the money seized from Gayle.


                               ~.
I




    ~¡~J!láll~rl~~i~~~~:;~~i:~4~l~~~£~~;i~~~~~~r~1g~~~~~~~JIK~~~~iï~~~!;tgfiJg~1~~~~~¡~~~~~1¡~:~~1.:;¡i¡~~~~



    TO:            SAO FILE

    FROM:          Catherine Maus

    SUBJ:          Matthew Goodnow
                   SP05-07 -079


    DATE:          february 23, 2006

    REASON FOR CLOSEOUT:

               The above referenced investigation was presented for review of
          possible perjury charges' against Matthew Goonow, an officer with'
          Hollyoo Police Department's Crime Suppression Team. On Januar 13,
          2005, Goodnow, Lieutenant Keith Haberland, and several other
          Hollywoo officers were involved in a controlled drug buy using $300
          from Hollywoo Police Departments r'HPD") investigative funds.
          Following completion of the buy during which the defendant received the
          $300, the defendant fled and was taken down by a K-9 unit after a
         chase. Only $200 of the $300 was recovered from the defendant.


                  An Internal Affairs investigation was opened following the drug
         buy because of allegations by Haberland's subordinates that Haberland
         took the unrecovered department money l and Goodnow provided a
         statement to IA on May i 1, 2005 (the "IA statement"). Lieutenant
         Richard Nardello. points specifically to three statements made by
         Goodnow to Internal Affairs that seemingly contradi(:t what Goodnow
         said in his police reports (that the defendant threw $200 into the
         road).

                  The three alleged. contradictory IA statements are:
                  1. Goodnow's statement that he was told by two other
                               officers that Haberland patted the Defendant down and
                               no money was located.
     ,,.
             ..
     '.: ~
.'




                           2. His statement that he did not Jose sight of. the
                                    defendant and he did not see the defendant throw
                                    anything down.
                           3. His statement that he was the first one to reach the
                                    defendant. Nardello alleges. this contradicts the
                                    statement of Steve Bolger l the K- 9 officer l who said
                                    that he thought the first officer to arrive at the
                                    defendant after the K-9 dog had engaged was Officer
                                    Catlett l and that there were no other detectives close
                                    in proximity who were ,in dangr of being bitten.


                           On October 7, 2005, Goonow provided a statement to me
                  pursuant to my invitation. He stated that he did not intentionally or
              knowingly provide false information to Internal Affairs; that he made a
              mistake, and any inconsistencies were the result of him being confused
              about which case was being discussed. He stated at the time he had a
              heavy case       load, . usually doing 2 controlled buys a day in a four day
              workweek. He stated that the defendant released $200 after being
              taken' down and he recovered it. He said that he had no knowledge of
              any improprieties committed by Haberland.

                   Because any inconsistent statements contained in Goodnow's IA
             statement were the result of a mistake it is clear they are not material.
             The State is unable to demonstr,ate that Goonow made the statements
             with criminal intent so, therefore, this investigation is closed.
         IN THE COUNTY/CIRCUIT COURT OF THE SEVENTEENTH JUICIAL CIRCUIT
                      IN AN FOR BROWARD COUNTY, FLORIDA

                                                                       CASE NO: 05-3325CFI0A

                                                                      mDGE: Tobin-Singer

  STATE OF FLORlDA
                                            Plaintiff,

 vs.
. Ortiz, Nelson
                                            Defendant.


                                            NOTICE PURSUANT TO RULE 3.220(b)(4)

              COMES NOW the State of Florida, by and through the undersigned Assistant State
 Attorney, pursuant to Rule 3.220(b)(4), Florida Rules of Criminal Procedure, submits the

 following information which is in the State's possession or control which may fall within the
purview of          Brady v. Maryland and/or Rule 3.220(b)(4):
             Witness, Courney, Jeffrey of                the Hollywood Police Departent has been arested in

      connection with an investigation                   by the Federal Bureau ofInvestigations and a criminal

      prosecution is pending.
             I HEREBY CERTIFY that a true copy hereof                      has been furnished by U.S. Mail! Hand!
Fax delivery this 3rd day of                 March, 2007, to: the Broward County Public Defenders Offce.


                                                                     MICHAL 1. SATZ



                                                                          ~~;
                                                                     State Attorney



                                                               By: Adam Baer
                                                                    Assistant State Attorney
                                                                    Florida Bar # 713511
                                                                    201. S.E. Sixth Street
                                                                    Fort Lauderdale, Florida 33301
                                                                    831-7731
                             ,t;

           IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                     IN AND FOR BROW ARD COUNTY, FLORIDA

                                               CASE   NO:        07-000073CF10A

                                              JUDGE:             GOLD

 STATE OF FLORIDA,

                        Plaintiff,

 vs.

JUAN MORENO,

                        Defendant.


                          NOTICE PURSUANT TO RULE 3.220(b)(2)

                COMES NOW the State of Florida~ by and through the undersigned Assistant

State Attorney, pursuant to Rule 3.220(b)(2), Florida Rules of Criminal Procedure and submits

the following information, which may fall within the purview of Brady v. Maryland: Detective

Simcox of the Hollywood Police Department has been arrested and charged with federal offenses

in the Southern District of Florida.

               I HEREBY CERTIFY that a true copy hereof has been furnished by U.S. Mail

delivery thisllo+tay of March, 2007, to:                 Esq., Office of the Public Defender.




                                       By:
                                             Anita G. White
                                             Assistant State Attorney
                                             Florida Bar #0537861
                                             201 S.E. Sixth Street, Suite 568
                                             Fort Lauderdale, Florida 33301
       IN THE COUNTY/CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                    IN AND FOR BROW ARD COUNTY, FLORIDA

                                                     CASE NO: 08-21861CF10A

                                                     JUDGE: MURPHY II

STATE OF FLORIDA
                             Plaintiff,

vs.
ANDRE SOLOMAN
                                                                                                 '\
                             Defendant.


                            NOTICE PURSUANT TO RULE 3.220(b)(4)

             COMES NOW the State of Florida, by. and through the undersigned Assistant State
Attorney, pursuant to Rule 3.220(b)(4), Florida Rules of Criminal Procedure, submits the

following information which is in thè State's possession or control which may fall within the
purview of      Brady v. Maryland and/or Rule 3.220(b)(4):
             Witnesses, MICHAEL TUCCIARONE and NICHOLAS NOVELLO of the BROW ARD
      SHERIFF'S OFFICE for allegations of Battery.
             I HEREBY CERTIFY that a true copy hereof has been furnished by HAND delivery
this 20th day of July, 2009, to: Benjamin Herbst, ESQ., Public Defender's Office, Attorney for
Defendant.




                                               By: lare
                                                    As' ant State Attorney
                                                      orida Bar # 28471
                                                    201. S.E. Sixth Street, Ste. 655
                                                    Fort Lauderdale, Florida 33301
                                                    954-831-7186
~.

             IN THE COUNTY/CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                          IN AND FOR BROWARD COUNTY, FLORIDA

                                                                          CASE NO: 08-6528CF10A

                                                                          JUDGE: MURPHY II

     STATE OF FLORIDA
                                              Plaintiff,

     ýS.
     JOSEPH LUCKNER
                                              Defendant.
     --
                                             NOTICE PURSUANT TO RULE 3.220(b)(4)

                  COMES NOW the State of Florida, by and through the undersigned Assistant State
     Attorney, pursuant to Rule 3.220(b)(4), Florida Rules of Criminal Procedure, submits the

     following information which is in the State's possession or control which may fall within the
     purview of Brady v. Marland and/or Rule 3.220(b)(4):
                  Witnesses, ROBERT SOKOL and NICHOLAS NOVELLO of                                the BROWARD
            SHERIFF'S OFFICE for allegations of                     Battery.
                  I HEREBY CERTIFY that a true copy hereof has been fuished by US MAIL delivery
     this 20th day of July, 2009, to: Mavel Ruiz, ESQ., Attorney for Defendant. 3399 NW 72nd Ave.,
     Ste. 224 Miami, FL 33122


                                                                          MICHAEL J. SATZ
                                                                          State Attorney/!
                                                                               / \'I '/
                                                                                 /"~-'~", /' I




                                                                    By: .Jréd"~
                                                                               ( II'l'/, i. //
                                                                               \ /../;
                                                                        !As~Jsr'~ . t State Attorney
                                                                        '-rida Bar # 28471
                                                                          201. S.E. Sixth Street, Ste. 655
                                                                          Fort Lauderdale, Florida 33301
                                                                          954-831-7186
                         IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                                    IN AND FOR BROWARD COUNTY, FLORIDA

                                                         CASE NO:          06-20315CF10A

                                                        JUDGE:             PAUL BACKMAN

  STATE OF FLORIDA,

                                 Plaintiff,

  VS.                                                                      NOTICE PURSUANT TO
                                                                             RULE 3.220(8)(2)

 ANDRE DELANCY, BERNARD FORBES
  & ELOYN INGRAHAM,

                                Defendants.




                          COMES NOW the State of Florida, by and through the undersigned counsel,
pursuant to Rule 3.220(b)(2), Florida Rules of Criminal Procedure, submits the following

information which is in the State's possession or control which may purview of Brady v Maryland,

and/or Rule 3.220(b)(2):

                                Deputy Bleiweiss of the Broward Sheriff's Office is currently under
investigation. He will        not be called as a witness for the State of Florida.

                               I HEREBY CERTIFY that a true copy hereof has been furnished by U.S.
Mail to H. Dohn Williams, Esq., Assistant Public Defender, 500 SE 6th St., Ft Lauderdale, FL,


                                                    i .
33301; Melodee A. Smith, Esq., 110 SE 3rd Ave., #1500, Ft Lauderdale, FL,33301; Daniel 'R.
Aaronson, Esq., Peter T. Patanzo, Esq., an~V9m Laswell, Esq., One Financial Plaza, Ste.
1615, Ft. Lauderdale, FL, 33394, on this /~ l1ay of July, 2009.
~-




              IN THE COUNTY/CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                           IN AND FOR BROWARD COUNTY, FLORIDA

                                                                    CASE NO: 08-6528CF10A

                                                                    JUDGE: MURPHY III

     STATE OF FLORlDA
                                              Plaintiff,

     vS.
     JOSEPH LUCKNER
                                              Defendant.
     --
                                              NOTICE PURSUANT TO RULE 3.220(b)(4)

                  COMES NOW the State of Florida, by and through the undersigned Assistant State
     Attorney, pursuant to Rule 3 .220(b)( 4), Florida Rules of Criminal Procedure, submits the
     following information which is in the State's possession or control which may fall within the
     purview of  Brady v. Marland and/or Rule 3.220(b)(4):
                  Witnesses, ROBERT SOKOL and NICHOLAS NOVELLO ofthe BROWARD
            SHERlFF'S OFFICE for allegations of              Battery.
                  I HEREBY CERTIFY that a true copy hereof                has been fuished by US MAIL delivery
     this 20th day of July, 2009, to: Mavel Ruiz, ESQ., Attorney for Defendant. 3399 NW nnd Ave.,
     Ste. 224 Miami, FL 33122


                                                                   MICHAEL J. SATZ
                                                                   State Attorney/!
                                                                    . /-~-'\ / i

                                                                              /J,./ ,.'
                                                                        (/ JIY' ii'..../
                                                                        \ // /., .
                                                                       .' .. ¡"/'
                                                             By: /~;~~~~ Attorney

                                                                 '-rida Bar # 28471
                                                                   201. S.E. Sixth Street, Ste. 655
                                                                   Fort Lauderdale, Florida 33301
                                                                   954-831-7186
             IN THE COUNTY COURT OF THE SEVENTEENTH JUICIA CIRCUIT
                       IN AN FOR BROW AR COUNTY, FLORIDA

                                                             CASE NO: 05-4162CFI0A

                                                             JUGE: ELIJAH WILLIAS
STATE OF FLORIDA,
                                          Plaintiff,

vs.

ASHLEY CURTISS,
                                         Defendant.



                                           NOTICE PURSUANT TO RULE 3.220(4)

             COMES NOW the State of Florida, by and through the undersigned Assistant State
Attorney, pursuant to Rule 3.220(b)(4), Florida Rules of Criminal Procedure, submits the

following information which is in the State's possession or control which may fall within the
purview of         Brady v. Marland and/or Rule 3.220(b)(4):
             Witness, CHRISTIAN ZAPATA, of the Broward County Sheriffs Office has received a
copy of       the attached letter.
             I HEREBY CERTIFY that a tre copy hereof
                                                                  has been furnshed by U.S. Mail / Hand /
Fax delivery this -. day of June, 2005, to: Russell Wiliams, Esq., 633 SE 3rd Ave #4F, Ft.

Lauderdale, FL 33301.


                                                             MICHAEL J. SATZ
                                                             State Attorney



                                                       By:   D~RIUS
                                                             Assistant State Attorney
                                                             Florida Bar # 0637890
                                                             20 i. S.E. Sixth Street
                                                             Fort Lauderdale, Florida 33301
                                                             (954) 831-2945
                 IN THE COUNY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                                        IN. AN FOR BROWAR COUNY, FLORIDA

                                                        CASE NO: 05-3775CF10A

                                                        JUGE: S. KAPLA
STATE OF FLORIDA,

                                      Plaintiff,
vs.
JOSE MONTES,

                                      Defendant.


                                         NOTICE PURSUANT TO RULE 3.220 (4)
                                                                         "\

                       COMES NOW the State of Florida, by and through the
undersigned Assistant State Attorney, pursuant to Rule 3.220 (b) (4) ,
Florida Rules of Criminal Procedure, submits the following information

which is in the State i s possession or control which may fall within

the purview of Brady v. Maryland and/or Rule 3.220 (b) (4) :
          Witness, Ofc. Matthew Goodnow, of the Hollywood Police Department
          has received the attached letter.
                      I HEREBY CERTIFY that a true copy hereof has been furnished
by U.S. Mail delivery this 23rd day of January, 2006, to:
Kayo Morgan- 432 NE 3rd Avenue Ft .                          Lauderdale, FL 33301

                                                       MICHAEL
                                                       State A


                                                   By: Kr'
                                                       Assistant tate Attorney
                                                       Florida Bar #668095
                                                       201 S.E. Sixth Street, Suite 730
                                                       Fort Lauderdale, Florida 33301
                                                       (954) 831- 7968




                                                         1
~'
                       IN THE CIRCUIT COURT OF THE SEVENTEENTH JUICIAL CIRCUIT
                                 IN AN FOR BROWARD COUNTY, FLORIDA

                                                                      CASE NO: 06-l5l4CFlOA

                                                                      JUGE: M. KALAN
      STATE OF FLORIDA
                                                  Plaintiff,

      vs.

      EDWAR STROMA
                                                 Defendant.


                                             .
                                                 NOTICE PURSUANT TO RULE3.220(b)(4)

                  CO:MS NOW the State of Florida, by and through the undersigned Assistat State
     Attorney, pursuant to Rule 3.220(b)(4), Florida Rules of Criminal Procedure, submits the
                 -
     following information which is in the State's possession or control which may fall within the
     puriew of          Brady v. Maryland and/or Rule 3.220(b)(4):


            Witness, Offcer Matthew Goodnow, of                the Hollywood Police Deparment has been sent   a
            letter by the Broward State Attorney's Office inviting the officer to appear and give a
            volunta sworn statement concernng an investigation of falsified police report.


     I ~REBY CERTIFY that a true copy hereof has been fushed by U.S. Mail delivery this
     -l day of
                               March, 2006, to: Diane Alvarez, Esq. Public Defender's Offce.
                                                                     MICHAEL.J; SATZ
                                                                     State A om y



                                                                     L' aHo man
                                                                       ssista State Attorney
                                                                    FloridaBar # 10427
                                                                    201. S.E. Sixth Street, Room 655
                                                                    Fort Lauderdale, Florida 33301
                                                                    954-831-7935
      IN THE COUNTY/CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                   IN AND FOR BROWARD COUNTY, FLORIDA

                                                                 CASE NO: 05-18675 CFIOA

                                                                 JUDGE: JOHN 1. MURPHY II

STATE OF FLORIDA
                                           Plaintiff,

vs.
DANIEL NICKSON
                                           Defendant.


                                           NOTICE PURSUANT      TO RULE 3.220(b)(4)

             COMES NOW the State of Florida, by and through the undersigned Assistant State
Attomey, pursuant to Rule 3.220(b)(4), Florida Rules of Criminal Procedure, submits the
following information which is in the State's possession or control which may fall within the
purview of         Brady v. Maryland and/or Rule 3.220(b)(4):
             Witness, MATTHEW GOODNOW of                      the Broward County Sheriffs Offce has been sent
      a letter by the Broward State Attomey's Office inviting the officer to appear and give a
      voluntary swom statement concerning an investigation of falsified police reports.
             I HEREBY CERTIFY that a true copy hereof has been fumished by U.S. Mail/Hand /
Fax delivery this 31ST day of MARCH, 2006, to: PUBLIC DEFENDER, COUNSEL FOR
DEFENDANT.


                                                                MICHAEL 1. SATZ
                                                                State Attorney



                                                             By: M. ANDE ON
                                                                  s istant State Attomey
                                                                Florida Bar # 0722138
                                                                201. S.E. Sixth Street
                                                                Fort Lauderdale, Flörida33301
                                                                954-831-7186
         IN THE COUNTY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                    IN AND FOR BROWARD COUNTY, FLORIDA

                                        CASE NO: 04-7316CF10A

                                        JUDGE: Holmes
STATE OF FLORIDA,

                 Plaintiff,
vs.
Jerome King,
                 Defendant.


                    NOTICE PURSUANT TO RULE 3.220 (4)

           COMES NOW the State of Florida,               by and through the
undersigned Assistant State Attorney, pursuant to Rule 3.220 (b) (4) ,
Flörida Rules of Criminal Procedure, submits the following information

which is in the State i s possession or control which may fall wi thin
                                    ,
the purview of Brady v. Maryland and/or Rule 3.220(b) (4):
      Witness, Christian Zapata, of the Broward County Sheriff's Office
      has been charged with fourteen counts of official misconduct.

           I HEREBY CERTIFY that a _true copy here0f has been furnished
by U.S. Mail/hand/Fax delivery this 1'8 day of March, 2005, to:
Gordon Weeks, Office of the Publ ic Defender.

                                        stat/~ey_
                                    MICHAEL J. SATZ



                              By:   ~toPher E. Palamara
                                    Assistant State Attorney
                                    Florida Bar #513921
                                    201 S.E. Sixth Street, Suite 655
                                    Fort Lauderdale, Florida 33301
                                    (954) 831-7969




                                         i
                 IN THE COUNTY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                           TN AND FOR BROWARD COUNTY, FLORIDA

                                                        CASE NO: 06-8876CFlOA

                                                        JUDGE: COHEN

 STATE OF FLORIDA
                                  Plaintiff,

 vs.

 JAMEKA MILLER                    Defendant.



                                   NOTICE PURSUANT TO RULE 3.220(4)

             COMES NOW the State of Florida, by and through the undersigned Assistant State
Attorney, pursuant to Rule 3.220(b)(4), Florida Rules of Criminal Procedure, submits the

following information which is in the State's possession or control which may fall within the
purview of Brady v. Maryland and/or Rule 3.220(b)(4):


STATE WITNESS, JORGE REYES, is CURRNTLY UNDER INVESTIGATION BY THE STATE
ATTORNEY'S OFFICE IN DADE COUNTY.


                        I HEREBY CERTIFY that a true copy hereof has been furnished by U.S. Mail /
Hand / Fax delivery this day of                December, 2008, to: Public Defender's Office


                                                        MICHAEL 1. SA TZ
                                                        State Attor . y



                                                  By:
                                                        Assistant State Attorney
                                                        Florida Bar # 29686
                                                        201. S.E. Sixth Street
                                                        Fort Lauderdale, Florida 33301
                                                        954-831-6598



                                                              (! (JltJ
                   IN THE CIRCUIT COURT OF THE SEVENTEENTH JUICIAL CIRCUIT
                              IN AN FOR BROWARD COUNTY, FLORIDA

                                                    CASE NO:     07 - 158 91CF10A

                                                    JUDGE:       LEVENSON

 STATE OF FLORIDA,

                              Plaintiff,
 vs.
 YOLANA JONES.,

                              Defendant.


                               NOTICE PURSUANT TO RULE 3.220 (b) (2)

                        COMES NOW the State of Florida,              by and through the
undersigned Assistant State                      Attorney, pursuant to Rule 3.220 (b) (2),
Florida Rules of Criminal Procedure, submits the following information

which is in the State r s possession or control which may fall wi thin

the purview of Brady v. Maryland and/or Rule 3.220(b)(2):

                        Former Officer Robert Merkel. has been charged with Official
                       Misconduct and Falsifying Public Records by the State
                       Attorney's Office

                       I HEREBY CERTIFY that a true copy hereof has been furnished

by € ~hand/Fax delivery                             this 3       day of June, 2008, to:
Brian Reidy, ESQ., office of the Public Defender.


                                                   MICHAEL J. SATZ
                                                   State Attorney



                                           By:     ~f= ~~
                                                   Stacie Wilensky
                                                   Assistant State Attorney
                                                   Florida Bar #17155
                                                   201 S.E. Sixth Street, Suite 655
                                                   Fort Lauderdale,' Florida 33301
                                                   (954) 831-7976
                                                                       .
                  .\.~'                           \.,,."



     IN THE COUNTY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
               IN AND FOR BROWARD COUNTY., FLORIDA




          COMES NOW thè State of Florida, by and through the
undersigned Assistant State Attorney, pursuant to Rule
3.220 (b) (2), Florida .RulèS of Criminal Procedure, submits. the
following information which is in the State i s possession or
control which ~ay fall within the purview of Brady v. Maryland
and/or Rulè 3.220 (b) (2): .
          Community Service Officer Karim Thomas of the Hollywood
Police Department is currently under investigation.

          I HEREBY CERTIFY that a. true copy               he.r.eof has been
furnished by U.S. Mail/hand/Fax delivery this                6TH   . day of
August, 2009, to: Public Defender.

                                MICHAEL J. SATZ
                                State Attorne~
                          By:
                                Richard A. Sherman, r.
                                Assistant State Attorney
                                Florida Bar # 0716431
                                201 S,E. Sixth Street, Suite 730
                                Fort Lauderdale, Florida 33301
                                (954) 831-8453 .
                                                                   .
                                 1
                       ..
                     -$4


         IN THE COUNTY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                    IN AND FOR BROWARD COUNTY, FLORI DA

                                     CASE NO: 04-10269CF10B
                                     JUDGE: ALEMÁN
STATE OF FLORIDA,

                  Plaintiff,
vs.
ANDY GARCONVIL,

                  Defendant.


                     NOTICE PURSUANT TO RULE 3.220 (4)

           COMES NOW the State of Florida,            by and through the
unders igned Assistant State Attorney, pursuant to Rule 3.220 (b) (4) ,
Florida Rules of Criminal Procedure, submits the following information

which is in the State i s possession or control which may fall wi thin

the purview of Brady v. Maryland and/or Rule 3.220 (b) (4) :
      Witness, Christian Zapata, of the Broward County Sheriff's Office
      has been arrested for fourteen counts of official misconduct.

           I HEREBY- CERTIFY that a true _F9PY hereof has been furnished
_':/ U. E. Mail/hand/Fax delivery this StX day of January, 2005, to:
Abe Bailey, Esq., 18350 NW 2nd Ave., Miami, FL 33169.




                               By:
                                     Lawrence Marí
                                     Assistant State Attorney
                                     Florida Bar # 638102
                                     201 S.E. Sixth Street, Suite 620
                                     Fort Lauderdale, Florida 33301
                                     (954) 831-8840




                                       1
        IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                   IN AND FOR BROWARD COUNTY, FLORIDA

                                          CASE NO:         08-10446 CF 10 A
                                          JUDGE:           GOLD

STATE OF FLORIDA,

                       Plaintiff,

vs.

JEFFERSON MONTENEGRO,

                       Defendant.


                        NOTICE PURSUANT TO RULE 3.220(b)(2)

              COMES NOW the State of Florida, by and through the undersigned
Assistant State Attorney, pursuant to Rule 3.220(b)(2), Florida Rules of Criminal
Procedure, submits the following information which is in the State's possession or
control which may fall within the purview of Brady v. Maryland and/or Rule 3.220(b)(2):

              Officer Andre Tomassi of the Hollywood Police Department is currently
under investigation.

            I HEREBY CERTIFY that a true copy hereof has been furnished by U.S.
Mail/hand/Fax delivery this 2 day of September, 2009, to: Jessica Mishali, Office of the
Broward County Public Defender.

                                          MICHAEL J. SATZ
                                          State Attorney



                                    By:
                                            fi'~
                                          Kerrie Taylor
                                          Assistant State Attorney
                                          Florida Bar # 45049
                                          201 S.E. Sixth Street, Suite 655
                                          Fort Lauderdale, Florida 33301
                                          (954) 831-7971



                                            i
                                            ,~ '"




                    IN THE COUNY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                              IN AND FOR BROWARD COUNTY, FLORIDA

                                                                      CASE NO: 04-18707CFIOA

                                                                      JUGE: ELIJAH WILLIAS
   STATE OF FLORIDA
                                            Plaintiff,

  vs.

  CLARA BARNIK
                                            Defendant.



                                            NOTICE PURSUANT TO RULE 3.220(4)

              COMES NOW the State of Florida, by and through the undersigned Assistant State
 Attorney, pursuant to Rule 3.220(b)(4), Florida Rules of Criinal Procedure, submits the
 following information which is in the State's possession or control which may fall withi the
purview of          Brady v. Maryland and/or Rule 3.220(b)(4):
             Witness, Chrstian Zapata, of                the Broward County Sheriffs Offce has received a copy of
the attached letter.
             I HEREBY CERTIFY that a tre copy hereof                      has been furnshed by U.S. Mail/Hand /
Fax delivery this                  020       day of April, 2005, to: John F. Phillips, Esq., 1401 S. Andrews Ave,
Ft. Lauderdale, FL 33316-1839.


                                                                    MICHAEL J. SATZ
                                                                                                 -¡
                                                                    State Attorney
                                                                                               /0;/2...
                                                              By:   MICHELLE ZEIGER              I 7
       ~~\) ~~                                                      Assistant State Attorney
                                                                    Florid¡i Bar # 662283
                                                                    201. S.E. Sixth Street
                                                                                                 G/////

              ~~
       ~ \...~.~
    ~,,~ '~
     . ",::.,
                                                                    Fort Lauderdale, Florida 3330 1

                                                                    (954) 831-7945


                . .. ....":'". ""
               .......'...... ""
                     .....~..':~
                IN THE CIRCUIT COURT OF THE SEVENTEENTH JUICIA CIRCUIT
                                     IN AND         FORBROWARD COUNTY, FLORIA

                                                                       CASE NO: 08-16456CFlOA

                                                                       JUDGE: BACKMN

STATE OF FLORIDA
                                        Plaintiff,

vs.
CHA VRON WARN
                                        Defendant


                                       NOTICE PURSUANT TO RULE 3.220(b)(4)

             COMES NOW the State .of Florida, by and through the undersigned Assistant State
Attorney, pursuant to Rule 3.220(b)(4), Florida: Rules of Criminal Procedure, submits the
following inormation which is in the State's possession or control which may fall within the
purview of         Brady v. Maryland and/or Rule 3.220(b)(4):
             Witness, Deputy Aandrea Tomassi of                     the Hollywood Police Department is curently
      under criminal investigation.
                        I HEREBY CERTIFY that a true copy hereof
                                                                                      has been furnished by U.S. Mail
delivery this \ ì day of August, 2009, to: Maury Halperin, 1326 SE 3 Ave., Fort
Lauderdale, FL 33316.

                                                                       MICHAELL ATZ
                                                                       State Attorn



                                                                   By: David Frankel
                                                                       Assistant State Attorney
                                                                       Florida Bar # 741779
                                                                       201. S.E. Sixth Street, Room 670
                                                                       Fort Lauderdale, Florida 33301
                                                                       954-831-7921
            IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                       IN AND FOR BROWARD COUNTY, FLORIDA

                                         CASE NO:        09 10064CF10A
                                        JUDGE:           LAZARUS
STATE OF FLORIDA,

                    Plaintiff,

vs.

FABIAN LEE,

                    Defendant.


                     NOTICE PURSUANT TO RULE 3.220(b)(2)

              COMES NOW the State of Florida, by and through the undersigned
Assistant State Attorney, pursuant to Rule 3.220(b)(2), Florida Rules of Criminal
Procedure, submits the following information which is in the State's possession or
control which may fall within the purview of Brady v. Maryland and/or Rule 3.220(b)(2):

              Offcer Andrea Tomassi of the Hollywood Police Department is currently
under investigation. Please direct any inquiries to Assistant State Attorney Timothy
Donnelly.

              I HEREBY CERTIFY that a true copy hereof has been furnished by u.s.
Mail/hand/Fax delivery this 21st day of August, 2009, to: Lawrence Wolk, Attorney for
the Defendant.
                                        MICHAEL J. SATZ
                                        State Attorney

                                                  ".
                                                 \'" '
                                                    '\


                                 By:
                                        PET SAPA
                                        Assist nt State Attorney
                                        201 S.E. Sixth Street, 'Suite 655
                                        Fort Lauderdale, Florida 33301
                                        (954) 831-7187


                                           1




                                                                                          ~tJf
',.




       IN THE CIRCUIT COURT OF THE SEVENTEENTH .n JDTCTAL CIRCUIT, IN AND
                                             FOR BROWARD COUNTY, FLORIDA


                                                        Case NO.:05 - 1472CFI0a

      STATE OF FLORIDA,                                 Judge:          MARCIA BEACH
                 Plaintiff,

      vs.                                               BRADY NOTICE

      FELICIA CI-IERRY,
                   Defendant.
                                                   /

                 COMES NOW the State of Florida, by and through the undersigned Assistant

      State Attorney, and lists the following evidence which falls within the purview of Brady

      v. Maryland and/or Florida Rule of               Criminal Procedure 3.220 (b) (4):

                 1. WITNESS, MATTHEW GOODNOW, of                        the Broward CountySherifts Office

      has been sent a letter by the State Attorney's Office inviting him to give a voluntary

      statement concerning an investigation into falsified police reports and/or crime statistics.

                I HEREB Y CERTIFY that a true copy hereof has been furnished by MAIL

      delivery this_27 _ day of _JANUARY _ 2006, to:                             .CHESTER McLEOD, ESQ.

      269 N. UNfVERSITY DRlVE, SUITE E, PEMBROKE PINES, FL 33024 ~
                                                                 MICHAEL 1. SATZ
                                                                 State Attorney


                                                          By:
                                                                 James M. De Hart
                                                                 Florida Bar #244775
                                                                 Assistant State Attorney
                                                                 Broward County Courthouse
                                                                 201 S.E. 6th Street, Suite 665
                                                                 Ft. Lauderdale, Florida 33301
                                                                 Telephone: (954) 831-7990
 JI08
                                                                                                                                                                PAGE 13
                                                                             - - - - - - - REMARK - - - - - - -
DEFT ~: 05001472CF10A DATE: 11/23/05
    REMARK: HEARING NOT HELD                                                                                                          CNTS:
      NOTE: I/CR ELEC/PTI DETERMINE/KEEP 1 - 3 - 6                                                                     DA TE ENTR: 11/23 /05
    USER: LEONA F RIEGEL-HART KEY: RE
DEFT #: 05001472CF10A DATE: 01/03/06
    REMARK: HEARING HELD / STATUS REPORT                                                                                       CNTS:
    NOTE: I / CR ELEC                                                                                                   DATE ENTR: 01/03/06
    USER: LEONA F RIEGEL-HART KEY: RE
DEFT #: 05001472CF10A DATE: 01/03/06
       REMARK: FILE,~lJ.Pl.,C.I.L_.~RETRIAL DEFER PROSECUTION AGREEMENT CNTS:
      NOTE : ::::~:~_____... DATE ENTR: 01/03/06
      USE,R; LEONA F RIEGEL-HAR.Y' KEY ;-RÈ~~.
DEFT W; 05001472CF10A DATE: 01/30/06
      REMARK: FILE STATE i S
      NÒXE: BRADY NOTICE
      USÈR: LEONA F RIEGEL-HART KEY: .._..RE. ..-.-"
DEFT # :.ÒS-0.o..i..4:l2C-P.:h.OA........ÐATE".:.....-cf21ò7"/0 6
                                                                                              )                                       CNTS:
                                                                                                                        DATE ENTR: 01/31/06

      REMARK: HEARING HELD / STATUS REPORT                                                                                     CNTS:
      NOTE: I / CR ELEC / ALLSTAR                                                                                       DATE ENTR: 02/07/06
      USER: LEONA F RIEGEL-HART KEY: RE
   * * PRESS ENTER FOR NEXT PAGE * *

                                                              ..,..,...,..
 JI08                              .-......
                                           ,.....-
                                                     .~....

                                                                                                                                                                L-, i\ '.~~ E;   .l.t.::


DEFT #:
                    / - -DEFENSE
                           ..//.

             05001~12CF10A SEQ: 02
                                                                                             ATTORNEY- -          \.                  -'-"-
                                                                                                                                              ..'.......


    DEF ATTY: (MCLEOD, CHESTER                                       "'\
    ATTY TYPl. SPECIAL PD BEGIN DATE: 06/23/05 END DATE: 01/23/07
    NOTE:                                               DATE ENTR: 0)/24/07
    USER: LEO ~ F RIEGEL-HART KEY: AT
                         '-~ ~--
                                                                  //'~"
                                                                                                                              .."""
                                                                                                                                              ,/
                                         __ - - - GENERAL CUSTODY - -
DEFT #: 05001472CF10A-"-ì3'CJOKINGDATE-.:...06/23/0S
      RELEASE REASON: COMMUNITY RELEASE RELEASE DATE:                                                                  06/24/05
      NOTE:                                                                                                            DATE ENTR:                          06/24/05
     USER: BOOKING INTERFACE                                                  KEY:     CU
   ** END OF INQUIRY **
.,




                    IN THE COUNTY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                              IN AND FOR BROWARD COUNTY, FLORI DA

                                                                  CASE NO:      07-000167CF10A
                                                                  JUDGE:        S. KAPLAN
       STATE OF FLORIDA,

                                           Plaintiff,
      vs.
      JENNIFER KOEFFLER,

                                          Defendant.


                                         NOTICE PURSUANT TO RULE 3.220 (b) (2)

                             COMES NOW the State of Florida, by and through the
     undersigned                      Assistant           State     Attorney,     pursuant     to    Rule
     3.220 (b) (2), Florida Rules of Criminal Procedure, submits the
     following information which is in the State i s possession or
     control which may fall within the purview of Brady
                                                                                             v . Maryland
     and/or Riile 3.220 (b) (2) :
     B. S. O. Officer Robert Delaney, CCN BS10928 was arrested on
     Tuesday March 27, 2007 and charged with Possession of Cocaine and
     Possession of Oxycodone-Percodan, Percocet

                            I HEREBY CERTIFY that a true copy hereof has been
     furnished by U. S. Mai~/Fax deli very this                                     L/fYay of April,
     2007, to: Melanie Golden, ESQ., Public Defender's Office


                                                             MICHAEL J. SATZ
                                                             Sta te At torney


                                                          By(L(~
,;)


      "

          Nicole A. Bloom
          Assistant State Attorney
          Florida Bar #21444
          201 S.E. Sixth Street,. Suite 730
          Fort Lauderdale, Florida 33301
          (954) 831-7183




          2
~-
           IN THE COUNTY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                      IN AND FOR BROWARD COUNTY, FLORIDA

                                     CASE NO:       07-1509CFIOA
                                     JUDGE:         M. KAPLAN

     STATE OF FLORIDA,

                     Plaintiff,
     vs.
     CLIFTON DYER,

                     Defendant.


                     NOTICE PURSUANT TO RULE 3. 220.(b) (2)

               COMES NOW the State of Florida, by and through the

     undersigned   Assistant State At torney, pursuant to Rule
     3.220 (b) (2), Florida Rules of Criminal Procedure, submits the
     following information which is in the State i s possession or
     control which may fall wi thin the purview of Brady v. Maryland

     and/or Rule 3.220 (b) (2):


               Officer Thomas      Simcox #1475 of Hollywood Police
               Department is being indicted federally. He has pled

               Guil ty and is awaiting sentencing.



               I HEREBY CERTIFY that a true copy hereof has been

     furnished by U. S. hand delivery this      4       day of June, 2007,

     to: Melissa Magenelli, ESQ., Office of The Public Defender
'.




           MICHAEL J. SATZ
           State Attorney



     By:   VD\tY
           Vanessa Casullo
           Assistant State Attorney
           Florida Bar #10924
           201 S.E. Sixth Street, Suite 730
           Fort Lauderdale, Florida 33301
           (954) 831-8448




                         '.




             2
      IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                 IN AND FOR BROWARD COUNTY, FLORIDA

                                   CASE NO:            07-4066CF10A
                                   JUDGE:              LEBOW

STATE OF FLORIDA,

                  Plaintiff,
vs.
ANDRES RAMIREZ,

                  Defendant.
                                   /
                  NOTICE PURSUANT TO RULE 3.220 (b) (4)

           COMES NOW the State of Florida, by and through the

undersigned    Assistant       State       Attorney,      pursuant    to    Rule
3.220 (b) (4), Florida Rules of Criminal Procedure, submits the
following information which is in the State's possession or
control which may fall wi thin the purview of Brady v. Maryland

and/or Rule 3.220 (b) (4) :
           Wi tness Detective Thomas Simcox of the Hollywood Police

Department pleaded guilty to the federal charge of Conspiracy to

Possess with Intent to Distribute Heroin on May 9, 2007.

           I HEREBY CERTIFY that a true copy hereof has been

furnished by US MAIL delivery this 21st day of May, 2007 to:

Scott Rubinchik, Esq., 1860 N Pine Island Rd Ste                           i18A,
Plantation, Florida 33322.




                                       1
'/
     ~




               MICHAEL J. SATZ
               State Attorney



         By:
               Michelle Zeiger, E/. ,_ .
               Assistant State Atorney
               Florida Bar #662283
               201 S.E. Sixth Street, Suite 568
               Fort Lauderdale, Florida 33301
               (954) 831-8526




                2
                                      .,,t
~..:.--.~
  ',1

                    IN THE COUNTY COURT OF THE SEVENTEENTH JUICIAL CIRCUIT
                              IN AND FOR BROW AR CÖUNTY, FLORIDA

                                                         CASE NO: 04012484CFIOA

                                                         JUDGE: KALAN,STANTON

      STATE OF FLORIA
                                  Plaintiff,

     vs.
     F ARIA,      RICHARD
                                  Defendant.



                                   NOTICE PURSUANT TO RULE 3.220(4)

                  COMES NOW the State of Florida, by and through the undersigned Assistant State
     Attorney, pursuant to Rule 3.220(b)(4), Florida Rules of Criminal Procedure, submits the

     following information which is in the State's possession or control which may fall withi the
     purview of      Brady v. Marland and/or Rule 3.220(b)(4):
                  Witness, LEE MARTIN of the Broward County Sheriffs Office has received a copy of
    the attached letter.
                  I HEREBY CERTIFY that a true copy hereof has been furnshed by ~ / Hand /

    Fax delivery this r:1 day of February, 2005, to: JOSEPH CARTER, ESQ. 1225 SE 2ND

    AVE. FT.LAUDERD, FL 33316


                                                        MICHAEL J. SATZ
                                                        State Attorney


                                                     -kAr~ u')'173rO
                                                   B~'t ~IP SEMENICK j.iQar
                                                   7b"' Assistant State Attorney
                                                        Florida Bar # 0598623
                                                        201. S.E. Sixth Street
                                                        Fort Lauderdale, Florida 33301
                                                        954-831-7925
         .I
       ,/
"


                                                                      MICHAELJ. SATZ
                                                                    . STATEATrORNEY
                                                              SE\gNT JÌJOICIAL ciRCUIT OF FLORIOA
                                                                    BROWARO COUNT COURTOUSE;
                                                                     201 S.E. SIXTH STREET
                                                        FORT LAUDERDALE, FLORIDA 33301-3360                     PHONE (954) 831-6955



      Plugut 13, 2004 ~~
      Det. Le Mar. ~ 1; .'
      Broward CountySherifis Offce
      2601 W. BrowardBlvd.
      Fort Lauderdale, Florida 33312


     RE: Crial Investigaton

     Dear Detective Mar:

                 Ou offce is conductig an investigation into allegations that. you may have falsified
    certai reports.


                By way 'of ths letter, I aIextendig an invitation to you to appear voluntaly at the


    would say
              . .
    Offce of the State Attorney

    allegations. Ths statement would be without the benefit of any imunty and anytg that you
                     in   the
                                                     and to provide a: sworn statement regardig your position as to these

                                  statement could be used against              you in a crial proceeding.

           I would appreciate a response from either you or your attorney, as to whether you would
    or would not like to provide a statelent, by Friday, Plugu 27, 2004, at 5 :00 PM.



                                                                         Sin



                                                                      ~anette M. Camacho
                                                                         Assistat State Plttorney

                                            .'
                                                                         Special Prosecutions and Public Corrption Unit
                                                                         Offce of the State Attorney
                                                                         201 SE 6th Street, Suite 620
                                                                        Fort Lauderdale, Florida 33301
                                                                        (954) 831-8029
      IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
           IN AND FOR BROWARD COUNTY, STATE OF FLORIDA


      STATE OF FLORIDA
                                                          Case: 08-23508CF1 OA
                     Plaintiff,
                                                          Judge: RODRIGUEZ-POWELL
  vs.

  DANIEL CORTES,
             Defendant!                          NOTICE PURSUANT TO RULE 3.220(4)



                       COMES NOW the State of      Florida, by and through the undersigned Assistant

 State Attorney, pursuant to Rule 3 .220(b)( 4), Florida Rules of Criminal Procedure, submits the

 following information which is in the State's possession or control which may fall within the

 purview of Brady v. Maryland and/or Rule 3.220(b)( 4):


          Deputy Michael Tucciarone, Deputy Robert Sokol, and Deputy Nicholas Novello
          are currently being investigated by the 17th Judicial Circuit State Attorney's

         Offce. See attached letters.



I HEREBY CERTIFY that a true copy hereofhas been furnshed by mail this _23_
day     of June, 2009, to: Brian Silber, Esq. 440 South Andrews Ave. Ft. Lauderdale, FL 33301.



                                                        MICHAEL J. SATZ
                                                        State Attorney,

                                                   ~ rfOIY tl
                                                ByArielle Demby ~ '-/-
                                                       Assistant State Attorney
                                                       Fl Bar NO.27675
                                                       201 SE 6Th St., Suite 655
                                                       Ft. Lauderdale,Florida 33301
                                                       Telephone: (954) 831-3568
                                                                            ..
                                                                            ~~.

                                        MICHAEL J. SATZ
                                        STATE ATTORNEY
                                  SEVENTEENTH JUDICIAL CIRCUIT OF FLORIDA

                                       BROWARD COUNTY COURTHOUSE

                                        201 S,L SIXTH STREET
                               FORT LAUDERDALE, FLORIDA 33301-3360                PHONE (954) 831-6955




 May 22, 2009

 Deputy Nicholas Novello
 Broward County Sheriffs Office
 2601 W. Broward Blvd.
 Fort Lauderdale, Florida 33312

Re: SP09-04-028

Dear Deputy Nicholas Novello:

        By way of introduction I am an Assistant State Attorney assigned to the Special
Prosecutions Unit at the State Attorney's Office in Fort Lauderdale, Florida. Cun-ently we are
conducting an investigation regarding allegations of Battery.

        Should you and/or your attorney feel that it would be in your best interest to come
forward to provide a voluntary statement regarding this matter, I would request that you and/or
your attorney contact this offce no later than the close of business, Friday June 5, 2009 and we
will make arrangements to take your voluntary statement at a time convenient for alL. Should 1
not hear from you and/or your attorney by that date we will presume that you are not coming
forward and thereafter I will take that action deemed most appropriate.

        Please do not hesitate to call should you or your attorney have any questions with respect
to the above.

                                                v

                                               Michae owff
                                                                . 'If       #
                                               Assistant State Attorney
                                               Special Prosecution Unit
                                               201 Southeast Sixth Street, Room 620
                                               Fort Lauderdale, Florida 33301
                                               Ph: (954) 831-8029 FAX: (954) 831-6290
                                       MICHAELJ. SATI
                                       STATE ATTORNEY
                                 SEVEHTEENTH JUDICIAL CIRCUIT Of fLORIDA

                                      8ROWARD COUNTY COURTHOUSE
                                       201 S.E. SIXTH STREET
                              FORT LAUDERDALE, FLORIDA 3)301-3360                  PHONE (954) 831-6955




May 22, 2009

Deputy Robert Sokol
Broward County Sheriffs Office
2601 W. Browar.d Blvd.
Fort Lauderdale, Florida 33312

Re: SP09-04-028

Dear Deputy Robert Sokol:

       By way of introduction I am an Assistant State Attorney assigned to the Special
Prosecutions Unit at the State Attorney's Office in Fort Lauderdale, Florida. Currently we are
conducting an investigation regarding allegations of Battery.

       Should you and/or your attorney feel that it would be in your best interest to come
forward to provide a voluntary statement regarding this matter, I would request that you and/or
your attorney contact this office no later than the close of business, Friday June 5, 2009 and we
will make arrangements to take your voluntary statement at a time convenient for alL. Should I
not hear from you and/or your attorney by that date we will presume that you are not coming
forward and thereafter I will take that action deemed most appropriate.


to the above. '
       Please do not hesitate to call should you or your attorney have any questions with respect




                                                Michael tz
                                                Assistant State Attorney
                                                Special Prosecution Unit
                                                201 Southeast Sixth Street, Room 620
                                                Fort Lauderdale, Florida 33301
                                                Ph: (954)831-8029 FAX:     (954)   831..6290
                                          c~,
                                                          MICHAEL J. SATZ
                                                          STATE ATTORNEY
                                                 SEVENTEENTH JUDICIAL CIRCUIT OF FLORIDA

                                                        BROWARD COUNTY COURTHOUSE

                                                          201 S.E. SIXTH STREET
                                             FORT LAUDERDALE, FLORIDA 33301-3360                  PHONE (954) 831-6955




 May   22, 2009

 Deputy Michael Tucciarone
 Broward County Sheriffs Office
 2601 W. Broward Blvd.
 Fort Lauderdale, Florida 33312

 Re: SP09-04-028

Dear Deputy Michael TucCiarone:




                  . ,
        By way of introduction I am an Assistant State Attorney assigned to the Special
Prosecutions Unit at the State Attorney's Gffice in Fort Lauderdale, Florida. Currently we are
conducting an investigation regarding allegations of Battery.

        Should you ":d/or your attorney feel that it would be in
                                                                       your best interest to come
forward to provide a voluntary statement regarding this matter, I would request that you and/or
your attorney contact this office no later than the close of business, Friday June 5, 2009 and we
will make arrangements to take your voluntary statement at a time convenient for alL. Should I
not hear from you and/or your attorney by that date we will presume that you are not coming
forward and thereafter I will take that action deemed most appropriate.

        Please do not hesitate to call should you or your attorney have any questions with respect
to the above.

                                                                   ve~ Sincer~


                                                                   MJh~Ji
                                                                   Assistant State Attorney
                                                                   Special Prosecution Unit
                                                                   201 Southeast Sixth Street, Room 620
                                                                   Fort Lauderdale, Florida 33301
                                                                   Ph: (954) 831-8029 FAX: (954) 831-6290
..

     ..

           IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                IN AND FOR BROWARD COUNTY, STATE OF FLORIDA


           STATE OF FLORIDA
                                                                       Case: 08-23508CFlOA
                                    Plaintiff,
                                                                       Judge: RODRIGUEZ-POWELL
           vs.

           DANIEL CORTES,
                      Defendant!                               NOTICE PURSUANT TO RULE 3.220(4)



                                       COMES NOW the State of Florida, by and through the undersigned Assistant

          State Attorney, pursuant to Rule 3.220(b)(4), Florida Rules of Criminal Procedure, submits the

          following information which is in the State's possession or control which may fall within the

          purview of Brady v. Maryland and/or Rule 3.220(b)(4):


                   Deputy Michael Tucciarone, Deputy Robert Sokol, and Deputy Nicholas Novello
                   are currently being investigated by the 17th Judicial.Circuit State Attorney's

                   Offce. See attached letters.



          I HEREBY CERTIFY that a true copy hereof              has been furnshed by mail this _23_
          day    of June, 2009, to: Brian Silber, Esq. 440 South Andrews Ave. Ft. Lauderdale, FL 33301.




                                                                      St~ rfO/Y (l. .
                                                                      MICHAEL 1. SATZ


                                                              By:
                                                                     Arielle Demby :. '- /-
                                                                     Assistant State Attorney
                                                                     FI Bar NO.27675
                                                                     201 SE 6Th St., Suite 655
                                                                     Ft. Lauderdale, Florida 3330 1
                                                                     Telephone: (954) 831-3568
                               c~,
                                           MICHAEL J. SATZ
                                           STATE ATTORNEY
                                     SEVENTEENTH JUDICIAL CIRCUIT OF FLORIDA

                                          BROWARD COUNTY COURTHOUSE

                                           201 S.E. SIXTH STREET
                                 FORT LAUDERDALE, FLORIDA 33301-3360                PHONE (954) 831-6955



                                                                      '\
  May 22,2009

 Deputy Michael Tucciarone
 Broward County Sheriffs Office
 2601 W. Broward Blvd.
 Fort Lauderdale, Florida 33312

 Re: SP09-04-028

 Dear Deputy Michael Tucciarone:

           By way of introduction I am an Assistant State Attorney assigned to the Special
 Prosecutions Unit at the State Attorney's Gffice in Fort Lauderdale, Florida. Currently we are
conducting an investigation regarding allegations of Battery.

        Should you and/or your      attorney feel that it would be in  your best interest to come
forward to provide a voluntary statement regarding this matter, I would request that you and/or
your attorney contact this offce no later than the close of business, Friday June 5, 2009 and we
will make arrangements to take your voluntary statement at a time convenient for alL. Should I
not hear from you and/or your attorney by that date we will presume that you are not coming
forward and thereafter I will take that action deemed most appropriate.

          Please do not hesitate to call should you or your attorney have any questions with respect
to the   above.

                                                   veG Sincer:1


                                                   MJhw04i
                                                   Assistant State Attorney
                                                   Special Prosecution Unit
                                                  201 Southeast Sixth Street, Room 620
                                                  Fort Lauderdale, Florida 33301
                                                  Ph: (954)831-8029 FAX:
                                                                              (954) 831-6290
                                                          MICHAEL J. SAri
                                                          STATE ATTORNEY
                                                 SEVENTEENTH JUDICIAL CIRCUIT OF FLORIDA

                                                        8ROWARD COUNTY COURTHOUSE
                                                          20 I S.E. SIXTH STREET
                                             FORT LAUDERDALE, FLORIDA 33301-3360                    PHON E (954) 831-6955




 May 22,2009

Deputy Robert Sokol
Broward County Sheriffs Office
2601 W. Broward Blvd.
Foii Lauderdale, Florida 33312

Re: SP09-04-028

Dear Deputy Robert Sokol:

        By way of introduction I am an Assistant State Attorney assigned to the
                                                                                                             Special
Prosecutions Unit at the State Attorney's Office in Fort Lauderdale, Florida. Currently we are
conducting an investigation regarding allegations of Battery.

        Should you and/or your attorney feel that it would be in your best interest to come
forward to provide a voluntary statement regarding this matter, I would request that you and/or
your attorney contact this office no later than the close of business, Friday June 5, 2009 and we
will make arrangements to take your voluntary statement at a time convenient for all. Should I
not hear from you and/or your attorney by that date we will presume that you are not coming
forward and thereafter I will take that action deemed most appropriate.

       Please do not hesitate to call should you or your attorney have any questions with respect
to the above.

                                                                    Very Sincerely,


                                                                    Michael tz
                                                                    Assistant State Attorney
                                                                    Special Prosecution Unit
                                                                   201 Southeast Sixth Street, Room 620
                                                                   Fort Lauderdale, Florida 33301
                                                                   Ph: (954)831-8029 FAX: (954) 831-6290
                                                                                                 ..
                                                                                                 (,
                                                             MICHAEL J. SATZ
                                                             STATE ATTORNEY
                                                       SEVENTEENTH JUDICIAL CIRCUIT OF FLORIDA

                                                            BROWARD COUNTY COURTHOUSE

                                                              201 S.E. SIXTH STREET
                                                FORT LAUDERDALE, FLORIDA 33301-3360                    PHON E (954) 831-6955




May 22,2009

Deputy Nicholas Novello
Broward County Sheriffs Office
2601 W. Broward Blvd.
Fort Lauderdale, Florida 33312

Re: SP09-04-028

Dear Deputy Nicholas Novello:

            By way of introduction I am an Assistant State Attorney assigned to the Special
Prosecutions Unit at the State Attorney's Office in Fort Lauderdale, Florida. Currently we are
conducting an investigation regarding allegations of                            Battery.

            Should you and/or your attorney feel that it would be in your best interest to come
forward to provide a voluntary statement regarding this matter, I would request that you and/or
your attorney coIitact this office no later than the close of business, Friday June 5, 2009 and we
will make arrangements to take your voluntary statement at a time convenient for alL. Should i
not hear from you and/or your attorney by that date we will presume that you are not coming
forward and thereafter I will take that action deemed most appropriate.

        Please do not hesitate to call should you or your attorney have any questions with respect
to the above.




                                                                      Michae          o~if
                                                                      Assistant State Attomey
                                                                      Special Prosecution Unit
                                                                      201 Southeast Sixth Street, Room 620
                                                                      Fort Lauderdale, Florida 33301
                                                                      Ph: (954)831-8029 FAX:(954)8Jl-b:2SìU
'.
                    IN THE COUNTY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                              IN AND FOR BROWARD COUNTY, FLORIDA

                                                                              CASE NO: 07-12543CF10A

                                                                              JUDGE: COHEN

     STATE OF FLORlDA
                                                Plaintiff,

     vs.

     COREY WHITEHAD Defendant.



                                                 NOTICE PURSUANT TO RULE 3.220(4)

                  COMES NOW the State of Florida, by and through the undersigned Assistant State
     Attorney, pursuant to Rule 3.220(b)(4), Florida Rules of Criminal Procedure, submits the

     following information which is in the State's possession or control which may fall within the
     purview of        Brady v. Maryland and/or Rule 3.220(b)(4):


     STATE WITNESS, ROBERT MoRRS, WAS INVOLVED IN A POLICE-INVOLVED SHOOTING THAT IS

     CURRNTLY BEING INVESTIGATED BY THE STATE                                  ATTORNEY'S OFFICE.



                             I HEREBY CERTIFY that a true copy hereof has been furnished by U.S. Mail/
     Hand / Fax delivery this                                day of   December, 2008, to: Public Defender's Office


                                                                              MICHAEL 1. SATZ
                                                                              State Attorney


                                                                                              5r¡~ GJtj
                                                                        By:
                                                                              Assistant State Attorney
                                                                              Florida Bar # 29686
                                                                              201. S.E. Sixth Street
                                                                              Fort Lauderdale, Florida 33301
                                                                              954-831-6598
     b018
                                                                                    PAGE 38
..
                               - - - - - - - REMARK - - - - - - -
DEFT #: 07012543CF10A DATE: 11/21/08
    ~EMARK: FILE STATES PRAECIPE                                           CNTS:
        NOTE: ( 2 ) ( 4 )                                           DATE ENTR: 11/25/Q8
        USER: SHOYAH GRAT KEY: RE
DEFT #: 07012543CF10A DATE: 12/16/08
    REMARK: FILE NOTICE                                                    CNTS:
    NOTE: PUSUANT TO RULE 3. 220 (4)                                DATE ENTR: 12/29/08
        USER: JULIE M JOHNHOPE KEY: RE.
DEFT #: 07012543CF10A DATE: 01/08/09
    REMARK: FILE DEFENSE MOTION FOR CONTINUANCE                CNTS:
    NOTE:                                               DATE ENTR: 01/14/09
    USER: JUNE JONES           KEY: RE
DEFT #: 07012543CF10A DATE: 01/08/09
    REMARK: FILE ORDER GRANTING DEF MOTION FOR CONTINUANCE     CNTS:
    NOTE: VERBAL                                        DATE ENTR: 01/14/09
        USER: JUNE JONES . KEY: RE
DEFT #: 07012543CF10A DATE: 01/08/09
     REMARK: HEARING HELD / STATUS CONFERENCE                              CNTS:
     NOTE: F/CT REPT J GARCIA                                       DATE ENTR: 01/16/09
     USER: VICTORIA P MOISE      KEY: RE
  * * PRESS ENTER FOR NEXT PAGE * *
                                                             "

"          IN THE COUNTY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                     IN AND FOR BROWARD COUNTY, FLORIDA

                                         CASE NO:        06-6728CFIOA
                                         JUDGE:          Aleman
    STATE OF FLORIDA,

                    Plaintiff,
    vs.
    Chelsea Daughtry,
                    Defendant.


                    NOTICE PURSUANT TO RULE 3.220 (b) (2)

               COMES NOW the State of Florida, by and through the

    undersigned    Assistant     State       Attorney,      pursuant    to   Rule
    3.220 (b) (2), Florida Rules of Criminal Procedure, submits the
    following information which is in the State's possession or
    control which may fall wi thin the purview of Brady v. Maryland

    and/or Rule 3.220(b) (2):
          On August 14, 2006, Officer Michael Dunsavage of the Coconut

    Creek Police Department was arrested by the Broward Sheriff's

    Office and charged with grand theft in Case No. 06013604CF10A.

    He plead guilty to the charges on August 24, 2006.

              I HEREBY CERTI FY that a true copy hereof has been




                                         1
"   furnished by   ~"~~/hand/Fax delivery this         Ji     day of
    November, 2006, to: Lawrence Schweiker, Esq., Public Defender.


                                  MICHAEL J. SATZ
                                  State Attorney



                            By:   ~f-'L~.
                                  Stacie K. Wilensk~t;
                                  Assistant State Attorney
                                  Florida Bar # 17155
                                  201 S.E. Sixth Street, Suite 655
                                  Fort Lauderdale, Florida 33301
                                  (954) 831-6002




                                   2
         IN THE COUNTY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                   IN AND FOR BROWARD COUNTY, FLORIDA

                                    CASE NO: 04-7316CF10A

                                     JUDGE: Holmes
STATE OF FLORI DA,

                 P lainti ff,

vs.
Jerome King,
                 Defendant.


                     NOTICE PURSUAN~ TO RULE 3.220 (4)

           COMES NOW the State of Florida,             by and through the
undersigned Assistant State Attorney, pursuant to Rule 3.220(b) (4),
Florida Rules of Criminal Procedure, submits the following information

which is in the State's possession or control which may fall within
the purview of Brady v. Maryland and/or Rule 3.220 (b) (4) :
      Wi tness, Lee Martin, of the Broward County Sheriff's Office has
      received the attached letter.

           I HEREBY CERTIFY that a true copy hereof has been furnished
by U.S. Mail/hand/Fax delivery this 71\ day of March, 2005, to:
Gordon Weeks, Office of the Public Defender.

                                    MICHAEL J. SATZ
                                    State .A~tor ey
                                       /'-('1,./, L-
                                      ./ /1/E. Palamara
                                By: ~;topher
                                    Assistant State   Attorney
                                    Florida Bar #513921
                                    201 S.E. Sixth Street, Suite 655
                                    Fort Lauderdale, Florida 33301
                                    (954) 831-7969




                                        i
                                                                      ...
                                                                      ~
                                         MICHAEL J. SATZ
                                       . STATEAlTORNEY
                                  SEVENTENT JUDICIAL CIRCUIT OF FLORIDA
                                      . BROWARD COUNT COURTHOUSE'

                                        201 S.E. SIXTH STREET
                               FORT LAUDERDALE, FLORIDA 33301-3360                   PHONE (954) 831-6955 .



i\ugust 13, 2004 ~~~

Det. Lee Marin ~
Broward County Sheriffs Offce
2601 W. BrowardBlvd. .
Fort Lauderdale, Florida 33312


RE: Criuùnal hivestigation

Dear Detective Mar:

        Our offce is conducting an investigation into allegations that you may have falsified
certain reports.


        By way     of this letter, I al extending an invitation to you to appear voluntaly at the
Offce of the State Attorney and to provide a: sworn statement regarding your position as to these
allegations. Ths statement would be without the benefit of any imuntyand anythig that you
would say in the statement could be used against you in a crimial proceeding.

        I would appreciate a response from either you or your attorney, as to whether you would
or would not like to provide a statement, by Friday, August 27, 2004, at 5 :00 PM.



                                               Sin



                                            ~al1netle M. Camacho
                                               i\ssistat State Attorney
                                               Special Prosecutions and Public Corrption Unit
                          .'
                                               Offce of the State Attorney
                                               201 SE 6th Street, Suite 620
                                               Fort Lauderdale, Florida 33301
                                               (954) 831-8029
'.                                        -:i



           IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                      IN AND FOR BROWAR COUNTY, . FLORIDA

                                                        CASE NO:      08017172cf10a
                                                        JUDGE:        GOLD

     STATE OF FLORIDA,

                              Plaintiff,
     vs.
     RADY JONES,
                             Defendant.


                            NOTICE PURSUANT TO RULE 3.220 (b) (2)

                COMES NOW the State of Florida, by and through the
     undersigned         Assistant              State     Attorney,     pursuant      to   Rule
     3.220 (b) (2), Florida Rules of Criminal Procedure, submits the
     following information which is in the State i s possession or
 control. which may fall wi thin the purview of Brady v. Maryland

 and/or Rule 3.220 (b) (2) ;


               Officer Robert Morris is
                                                             currently the subject of an
investigation surrounding an officer involved shooting.
!..

      '"




                     I HEREBY CERTIFY that a true copy hereof has been

           furnished by u.s. Mail/hand/Fax delivery this 28th day of July,
           ~ 009, to: Jonah Dickstein, ESQ., Office of Regional Conflict.


                                          MICHAEL J. SATZ
                                          State Attorney


                                    By:   L&
                                          HARIS KIRSCH
                                          Assistant State Attorney
                                          Florida Bar #30873
                                          201 S.E. Sixth Street, Suite 730
                                          Fort Lauderdale, Florida 33301
                                          (954) 831-7972




                                           2
,.


           IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                      IN AND FOR BROWARD COUNTY, FLORI DA

                                        CASE NO:            OS-2046SCFlOA

                                        JUDGE:              HOLMES

     STATE OF FLORIDA,

                       Plaintiff,
     vs.
     DONALD JOHNSON,

                       Defendant.



                       NOTICE PURSUANT TO RULE 3.220 (b) (2)


                COMES NOW the State of Florida, by and through the
 undersigned        Assistant       State       Attorney,      pursuant     to   Rule
     3.220 (b) (2), Florida Rules of Criminal Procedure, submits the
     following information which is in the State' s possession or
 control which may fall within the purview of Brady v. Maryland

 and/or Rule 3.220 (b) (2):


                Officer Matthew Goodnow of the Hollywood Police
 Department has an acti ve investigation pending against him by the

 Office of the State Attorney.




                                            1
"-




           I HEREBY CERTIFY that a true copy hereof has been

 furnished by hand delivery this 2nd day of February, 2006, to:

 Ian Boettcher, Esq., Office of the Public Defender.


                                MICHAEL J. SATZ
                                S ta te At torney


                          By:   ~
                                Vanessa Maiorana
                                Assistant State At torney
                                Florida Bar #10593
                                201 S.E. Sixth Street, Suite 655
                                Fort Lauderdale, Florida 13 ~ n i
                                (954) 831-8040




                                  2.
      IN THE COUNTY COURT OF THE SEVENTEENTH JUICIAL CIRCUIT
                IN AN FOR BROWAR COUNTY, FLORIDA

                                                   CASE NO:   06-1758CF10A
                                                   JUGE:      IMPERATO

STATE OF FLORIDA,

                Plaintiff,
vs.
RAYMOND MINICHER,

                Defendant.


                NOTICE PURSUANT TO RULE 3.220(b)                   (2)


COMES NOW the State of Florida i by and through the undersigned

Assistant State Attorney, pursuant to Rule 3.220 (b) (2), Florida
Rules of Criminal Procedure, submits the following information

which is in the State i s possession or control which may fall

wi thin the purview of Brady v. Maryland and/or Rule 3.220 (b) (2) :


OFFICER' MATTHEW GOODNOW was under investigation by the State

Attorney's Office.




                                                    1
                     .$,
                      .....
,,


               I HEREBY CERTIFY that a true copy hereof has been

     furnished by U. S. Mail/hand/Fax delivery this __ day of Marchi

     20061 to: The Public Defenderls Office.


                                    MICHAL J. SATZ
                                    State Attorney



                              By:              :d
                                    James Harris \
                                    Assistant stat~ Attorney
                                    Florida Bar #7t4054
                                    201 S.E. Sixth Streeti suite 655
                                    Fort Lauderdale i Florida 33301
                                     (954) 831-3558




                                      2
            IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                       IN AND FOR BROWARD COUNTY i FLORIDA

                                                              CASE NO:    0819595CFI0A
                                                              JUDGE:      DALE COHEN

 STATE OF FLORIDA1

                                     Plaintiff i
vs.
STEVEN PINDER1

                                     Defendant.

                                    NOTICE PURSUANT TO RULE 3.220 (b) (2)

                        COMES NOW the State of Floridai by and through the
undersigned Assistant State Attorney i pursuant to Rule
                                               i submits the
3.220 (b) (2) i Florida Rules of Criminal Procedure

following information which is in the State's possession or
control which may fall wi thin the purview of Brady v. Maryland
and/or Rule 3.220 (b) (2) :
          Sergeant Andrew Diaz of the Hollywood Police Department
is currently under investigation.

                       I HEREBY CERTIFY that a true copy hereof has been
furnished by U. S. Mail/hand/Fax deli very this day of July i
2009, to: Anthony Quackenbush, Esq. Public Defender.




                                                      By:
                                                            FLO NC
                                                            Ass'st
                                                            Flo id r # 027118
                                                             201 S.E. Sixth Street, Suite 655
                                                             Fort Lauderdale, Florida 33301
                                                            '(954) 831-6598




                                                              1
      IN THE CIRCUIT COURT OF THE ,sEVENTEENTH JUDICIAL CIRCUIT
                 IN AND FOR BROWARD COUNTY', ¡FLORIDA

                                     CASE NO:    09-12209CF10A
                                     JUDGE:      GILLESPIE

STATE OF FLORIDA,

                  Plaintiff,
vs.
NEFTALI RIVERA,

                  Defendant.

                  NOTICE PURSUANT TO RULE 3.220 (b) (2)

            COMES NOW the State of Florida, by and through the
undersigned Assistant State Attorney, pursuant to Rule
3.220 (b) (2), Florida Rules of Criminal Procedure, submits the
following information which. is in the State i s possession or
control which may 'fall wi thin the purview of Brady v. Maryland
and/or Rule 3. 220 (b) (2) :
           Officer Dewey Pressley of the               Hollywood   Police
Department is currently under investigation.

           I HEREBY CERTIFY that a true copy hereof has been
furnished by U.S. Mail delivery this 18 day of August, 2009, to:
 Jessica Medina, Esq. APD.

                                     MICHAEL J. SATZ
                                     State Attorney



                               By:         0~ Coy
                                     Arielle Demby
                                     Assistant State At torney
                                     Florida Bar # 27675
                                     201 S.E. Sixth Street, Suite 655
                                     Fort Lauderdale, Florida 33301
                                     (954) 831-7125




                                       1
      IN THE CIRCUIT COURT OF THE SEVENTEENTH JUICIAL CIRCUIT
                 IN AN FOR BROWAR COUNTY, FLORIDA

                                  CASE NO:     07 -'163 17CF10A
                                  JUDGE:       GOLD

STATE OF FLORIDA,

                  Plaintiff,
vs.
IRVIN, KENNETH,

                  Defendant.


                  NOTICE PURSUAN TO RULE 3.220 (b) (2)
           COMES NOW the State of Florida; by and through the
undersigned Assistant State Attorney, pursuant to Rule
3.220(b) (2), Florida Rules of Criminal Procedure, submits the
following information which is in the State i s possession or
control which may fall within the purview of Brady v. Maryland
and/or Rule 3.220 (b) (2) :
           Deputy Ulysses Rodriguez (BSO 13814) has been charged
in case 08 - 913CF10Ar and he is suspended without pay pending the
outcome of the case.

         I HEREBY CERTIFY that a true copy hereof has been
furnished by hand delivery this March 3, 2008, to Jacqueline
Moody, OFFICE OF THE PUBLIC DEFENDER.

                                 MICHAEL J. SATZ
                                 State Attorney


                              By: ~~L~
                                ~tlt Sherman
                                Assistant State Attorney
                                Florida Bar #165735
                               .201 S.E. Sixth Street, Suite 655
                                Fort Lauderdale, Florida 33301
                                (954) 831-7974
.,

     \

                               IN THE COUNTY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                                         IN AND FOR BROWARD COUNTY, FLORlDA

                                                                                          CASE NO: 06-203l5CF10ABC

                                                                                         JUDGE: PAUL BACKMAN

          STATE OF FLORIA,
                                                          Plaintiff,

          vs.

          ANDRE DELANCY,
          BERNARD A. FORBES and
          ELOYN DEVON INGRAHAM,
                                Defendants.


                                                      NOTICE PURSUANT TO RULE 3.220(4)

                      COMES NOW the State of Florida, by and through the undersigned Assistant                                 State Attorney,
         pursuant to Rule 3.220(b)(4), Florida Rules of Criminal Procedure, submits the following information

         which is in the State's possession or control which may fall within the purview of Brady v. Maryland
         and/or Rule 3.220(b)(4):


                     Witness, Ulysses Rodriguez, of the Broward County Sheriffs Offce is a defendant in Case No.
         08-913CFIOA; he will not be called as a witness in the above-referenced case by the State of                            Florida.


                     I HEREBY CERTIFY that a copy of the foregoing has been delivered via hand-deliveryfUS Mail
         to: H. Dohn Williams, Jr., Esq., Assistant Public Defender, 500 SE 6th Street, 2nd Floor, Fort Lauderdale,
         Florida, 33301; to Daniel R. Aaronson, Esq., Peter T. Patanzo, Esq., and William Laswell, Esq., One
         Financial Plaza, Suite 1615, Fort Lauderdale, Florida, 33394; and to Melodee A. Smith, Esquire, 101 N.E.
         3rd Avenue, Suite 1500, Foii Lauderdale, Florida, 33301, this day                                  of June,   2008.


                                                                                        MICHAEL J. SATZ
                                                                                                                          6/ ;:to/ö?
                                                                                        State Attorney
                                                                                                                               lõì~
                                                                               By: JEFF A MARCUS
                                                                                        Assistant State Attorney
                                                                                        Florida Bar # 328790
                                                                                        201. S.E. Sixth Street
                                                                                        Fort Lauderdale, Florida 33301
 J.::C,:8"
             '.                                                                          PAGE 59
                                  - - - - - - - REMARK - - - - - - -
DEFT #: 06020315CF10A DATE: 0 6 /2 3 / 0 8
    REMARK: FILE ORDER GRANTING DEF MOTION FOR CONTINUANCE     CNTS:
    NOTE: VERBAL                                        DATE ENTR: 06/23 /08
       USER: WENDY LABRANCHE KEY: RE
DEFT #: 06020315CF10A DATE: 06/23/08
    REMARK: RESET JURY TRIAL                                                   CNTS:
    NOTE: CT REPT-C. TRAT (I)                                          DA TE ENTR: 06/23 /08
       USER: WENDY LABRANCHE KEY: RE
DEFT #: 0602031SCF10A DATE: 06/24/08
    REMARK: FILE SENT                                                         CNTS:
    NOTE: TO FILE ROOM                                                 DATE ENTR: 06/24/08
       USER: WENDY LABRACHE KEY: RE
DEFT #: 060203lSCF10A DATE: 06/26/08
    REMARK: FILE NOTICE                                                        CNTS:
    NOTE: PURSUANT TO RULE 3. 220 (4)                                  DATE ENTR: 06/3 0 /08
       USER: WENDY LABRACHE KEY: RE
DE~T #: Ó~6~~31SCF10A DATE: 06/26/08
       REMARK: STATE i S DISCOVERY SUBMISSION                                 CNTS:
       NOTE:                                                           DATE ENTR: 06/30/08
       USER: WENDY LABRACHE        KEY: RE
  * * PRESS ENTER FOR NEXT PAGE * *




                                                              ,(\ ~rC1
                                                               \y)~
                   IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                              IN AND FOR BROWARD COUNTY, FLORIDA

                                               CASE NO:         07 12677CF10A
                                               JUDGE:           COHEN
 STATE OF FLORIDA,

                           Plaintiff,

 vs.

JAMES AUGUSTE,

                           Defendant.


                           NOTICE PURSUANT TO RULE 3.220(b)(2)

                     COMES NOW the State of Florida, by and through' the undersigned
Assistant State Attorney, pursuant to Rule 3.220(b)(2), Florida Rules of Criminal
Procedure,         submits the following information which is in the State's possession or
control which may fall within the purview of Brady v. MarYland and/or Rule 3.220(b)(2):
         "-~,..-

                    Offcer William Sainvil of BSO is currently under investigation. Please
direct any inquiries to Assistant State Attorney Sarahnell Murphy.

                    I HEREBY CERTIFY that a true copy hereof has been furnished by u.s.
Mail/hand/Fax delivery this 21st day of August, 2009, to: Daphne Ganthier, Regional
Conflict Counsel's Offce, Attorney for the Defendant.
                                              MICHAEL J. SATZ
                                              State AttoF '


                                        By:
                                              PET SAPAK
                                              Assistant State Attorney
                                              201 S.E. Sixth Street, Suite 655
                                              Fort Lauderdale, Florida - 33301
                                              (954) 831-7187




                                                1




                                                                                             ~tYrf
                                          rl


                      IN THE COUNTY COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                                IN AND FOR BROWARD COUNTY, FLORIA

                                                                CASE NO: 08-992CFI0A

                                                                JUDGE: O'CONNOR

 STATE OF FLORIA
                                      Plaintiff,

 vs.

 DA VID HEWLETT,
                                     Defendant.



                                         NOTICE PURSUANT TO RULE 3.220(4)

            COMES NOW the State of Florida, by and through the undèrsigned Assistant State Attorney,
pursuant to Rule 3.220(b)(4), Florida Rules of Criminal Procedure, submits the following information
which is in the State's possession or control which irÌay fall within the purview of Brady v. Maryland
and/or Rule 3 .220(b)( 4):

                  1. State's "A" Witness,BSO Deputy Kevin Frankel was arested by the Federal
                           Government. He currently has a pending federal case.
            I HEREBY CERTIFY that a true copy hereof has been furnished by U.S. Mail/Hand / Fax
delivery this iih day of          November, 2008, to: Bruce Prober, Esq., PD's Office.


                                                               MICHAEl, J. SA TZ
                                                               State Attorney

                                                                                                   ".._-_._--..
                                                         By: I rki Alvar
                                                               Assistant State Attorney
                                                               Florida Bar If 22481
                                                              20 l. S.E. Sixth Street, Suite 655
                                                              Fort Lauderdale, Florida 33301
                                                              954-831-7956
                  IN THE COUNY COURT OF THE SEVENTEENTH JUICIA CIRCUIT
                                        IN AND FOR BROW AR COUNTY, FLORIA

                                                              CASE NO: 0301.584CFlOA

                                                              JUGE: SPEISER,MA A.

  STATE OF FLORIDA
                                          Plaintiff,

 vs.
  SMITH,       DEVON
                                          Defendant.



                                           NOTICE PURSUANT TO RULE 3.220(4)

              COMES NOW the State of Florida, by               and through the undersigned Assistant State
 Attorney, pursuant to Rule 3.220(b)(4), Florida Rules of Çriminal Procedure, submits the

 following information which is in the State's possession or control which ~ay fall within the
 purview of         Brady v. Marland and/or Rule 3.220(b)(4):
              Witness, EDWI ARIAS otthe Broward County Sheriffs Offce has received a copy of
 the attached letter.

                                  . ,li) .
              I HEREBY CERTIFY that a tre copy hereof has been furnshed by u.S. Mail/Hand /
. Fax delivery this c73 day of February, 2005, to: PD'S DFFICE ,



                                                             MICHAEL J. SATZ
                                                             State Attorney



                                                       By:   CAROLR'                                     --
                                                             Assistant State Attorney
                                                             Florida Bar # 0242380
                                                             201. S.E. Sixth Street
                                                             Fort Lauderdale, Florida 33301
                                                             954-83 i -7731
~ ,
      "
                                                        .                                               e
                           IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                                     IN AND FOR BROWARD COUNTY, FLORlDA

            STATE OF FLORlDA,

                                                Plaintiff,                                     CASE NUMBER: 08-13550CFlOA

            vs.
                                                                                              JUDGE: TOWBIN-SINGER
           ROBERT CROPPER,

                                               Defendant.

           - -- - ------ - --- -- -- ----- ------- -------------- ------ )(

                                                        NOTICE PURSUANT TO RULE 3.220(4)

                       COMES NOW the State of Florida, by and through the undersigned Assistant State
                                                                                                   \
           Attorney, pursuant to Rule 3.220 (b)(4), Florida Rules of                       Criminal Procedure, submits the

          following information which is in the State's possession or control which may fall within the

          purview of Brady v. Maryland and/or Rule 3.220 (b)(4):

                                   Witness Daniel Zavadil was recently terminated by the Fort Lauderdale Police
                                   Department for forging a signature on a Notice to Appear.


                      i HEREBlL CERTIFY that a true copy hereof has been furnished by U.S. Mail/hand/fax

          delivery this t:day of                November, 2009 to: Ralph Behr, Esq., 888 SE 3rd Avenue, Suite 400,

          Fort Lauderdale, FL 33316, Attorney for Defendant.

                                                                              MICHAEL 1. SATZ



                                                                              By:
                                                                                              s sq.
                                                                                    an t í\ttorney
                                                                              FI i Bar No. 0010056
                                                                                  S.E. 6th Street, Suite 640
                                                                              Fort Lauderdale, Florida 33301
                                                                              (954) 831-7935
       "

                           TRANSMISSION VERIFICATION REPORT
                                                                e
                                                               TIME 11/17/2009 11: 21
                                                               NAME
                                                               FAX
                                                               TEL




           DATE, TIME                           11/17 11: 20
           FAX NO./NAME                         99547511524
           DURATION                             00: 00: 34
           PAGE   (5)                           02
           RESULT                               OK
           MODE                                 STANDARD
                                                ECM




                                                                                . ':~.¡



                                   .MICHLJ. SATZ
                                   STATEA1TORN . \
                          SEVEEN JUDlCIAL CIRCUIT OF FLORIDA'
                              BROWARO COUNTY-cOURTHOUSE
                                   201 S.E. SIXTH STREET
                              FORT LAUDERDALE, FL 33301-3360



     To;                                     From:
                                             Unit:
                                             Phone:
                                             Fax:
    . Phone:
      Fax:



       ~la~\


      ùtlirJ 1evJ) I AJ dlJ'(!Ar¡¿úJI'¿;

      Gi i'r kt tor vLrt d r/uA il(v
      '3JjvVOJ6Jf)-Or( thr(ùJ 0\1 I;Jo. I
I
'"


           IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                       IN AND FOR BROWARD COUNTY,. FLORI DA

                                           CASE NO:        05-006022CFlOA
                                           JUDGE:          M. KAPLAN

     STATE OF FLORIDA,

                      Plaintiff,
     vs.
     DANNY CHRISTO,

                      Defendant.


                      NOTICE PURSUANT TO RULE 3.220 (b) (2)

               COMES NOW the State of Florida, by and through the

 undersigned       Assistant       State       Attorney,     pursuant   to   Rule
 3.220(b) (2), Florida Rules of Criminal Procedure, submits the

following information which is in the State's possession or
control which may fall wi thin the purview of Brady v. Maryland

and/or Rule 3.220 (b) (2):
               On June 28, 2005, Deputy Edwin Arias of the Broward

Sheriff's Office was charged with five (5) counts of official

misconduct in Case No. 05-9822CFIOA.                   The case is currently
pending in front of Judge Gold.




                                           i
'I




              I HEREBY CERTIFY that a true copy hereof has been

     furnished by U. S. Mail/hand/Fax delivery this I ~ day of July,

     2005, to: Public Defender's Office.


                                   MICHAEL J. SATZ
                                   State Attorney



                             By:




                                   2
            IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                       IN AND FOR BROWARD COUNTY, FLORIDA

                                             CASE NO:        08 17463CF10A
                                            JUDGE:           LAZARUS
 STATE OF   FLORIDA,

                       Plaintiff,

 vs.

 BABETA GAINES,

                     Defendant.


                     NOTICE PURSUANT TO RULE 3.220(b)(2)

              COMES NOW the State of Florida, by and through the undersigned
Assistant State Attorney, pursuant to Rule 3.220(b)(2), Florida Rules of Criminal
Procedure, submits the following information which is in the State's possession or
control which may fall within the purview of Brady v. Maryland and/or Rule 3.220(b)(2):

             Offcer John LaFontant of the Lauderhill Police Department is currently
under investigation. Please direct any inquiries to Assistant State Attorney Michael
Horowitz.

             I HEREBY CERTIFY that a true copy hereof has been furnished by U.S.
Mail/hand/Fax delivery this 21st day of August, 2009, to: James Wells, Public
Deffenders Offce, Attorney for the Defendant.
                                          MICHAEL J. SATZ
                                          State ey


                                    By:
                                          PETE APAK.
                                          Assistant State Attorney
                                          201 S.E. Sixth Street, Suite 655
                                          Fort Lauderdale, Florida 33301
                                          (954) 83t-7187



                                            i


                                                                                          0JtJf

				
DOCUMENT INFO
Shared By:
Categories:
Tags:
Stats:
views:21
posted:7/21/2012
language:
pages:78