On May 11, 216 a
Party Notice
was filed
involving a dispute between
and
Otero-Rivera, Christopher J,
for FELONY
in the District Court of Osceola County.
Preview
Filing # 123386144 E-Filed 03/19/2021 09:13:07 AM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
OF THE STATE OF FLORIDA, IN AND FOR OSCEOLA COUNTY
STATE OF FLORIDA,
Plaintiff, CASENO, — 49-2019-CF-003738-O
49-2019-CF-004126-O
v.
CHRISTOPHER OTERO-RIVERA, and
ANGEL RIVERA,
Defendants.
/
STATE’S NOTICE OF INTENT TO RELY UPON SUMMARY PURSUANT TO § 90.956
COMES NOW the State of Florida, by and through the undersigned Designated Assistant
State Attorney, pursuant to Florida Statute section 90.956 (2020), providing notice to the co-
defendants and Court in this cause of its intent to rely upon a summary of data or information,
stating as follows:
1. The Co-Defendants have each been charged with Second Degree Murder, Abuse
of a Human Body, and Tampering with Physical Evidence. This Court set the trial in this cause
to begin with jury selection on Monday, April 5, 2021.
2. The State intends to admit testimony from multiple witnesses who were
incarcerated with Christopher Otero-Rivera in the Osceola County Jail and to whom Otero-
Rivera make incriminating statements.
3. State witness Brett Burger, a sergeant at the Osceola County Jail, will testify to
the housing of these inmates within the Osceola County Jail. Specifically, that housing records
of the Osceola County Jail corroborate these incarcerated witnesses in that they were in fact
housed with Christopher Otero-Rivera during the relevant time frame.
4, Sgt. Burger reviewed extensive and voluminous housing records from the
database kept by the Osceola County Jail in order to prepare for his testimony. Rather than
providing these voluminous records, Sgt. Burger prepared a summary of Christopher Otero-
Rivera’s cellmate assignments and housing. The State provided this summary at pages 4224
through 4226 in discovery in this case.5. The State will make the individual housing records upon which the summary is
based available to defense counsel or the Court upon request.
WHEREFORE, the State provides this Notice in hopes the Court will permit it to rely
upon the summary of information described above as evidence in this cause.
WILLIAM GLADSON
STATE ATTORNEY
FIFTH JUDICIAL CIRCUIT
/s/ Matthew Ryan Williams
Matthew Ryan Williams
Designated Assistant State Attorney
Fifth Judicial Circuit
Florida Bar No. 028645
425 N. Orange Ave.
Box 63
Orlando, FL 32801
twilliams@sao5.org
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the above has been furnished to Migdalia Perez and
Frank Bankowitz, Counsel for the Co-Defendants, by electronic service this 19th day of March,
2021.
/s/ Matthew Ryan Williams
Matthew Ryan Williams
Designated Assistant State Attorney
Document Filed Date
March 19, 2021
Case Filing Date
May 11, 216
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Filing # 123386144 E-Filed 03/19/2021 09:13:07 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, OF THE STATE OF FLORIDA, IN AND FOR OSCEOLA COUNTY STATE OF FLORIDA, Plaintiff, CASENO, — 49-2019-CF-003738-O 49-2019-CF-004126-O v. CHRISTOPHER OTERO-RIVERA, and ANGEL RIVERA, Defendants. / STATE’S NOTICE OF INTENT TO RELY UPON SUMMARY PURSUANT TO § 90.956 COMES NOW the State of Florida, by and through the undersigned Designated Assistant State Attorney, pursuant to Florida Statute section 90.956 (2020), providing notice to the co- defendants and Court in this cause of its intent to rely upon a summary of data or information, stating as follows: 1. The Co-Defendants have each been charged with Second Degree Murder, Abuse of a Human Body, and Tampering with Physical Evidence. This Court set the trial in this cause to begin with jury selection on Monday, April 5, 2021. 2. The State intends to admit testimony from multiple witnesses who were incarcerated with Christopher Otero-Rivera in the Osceola County Jail and to whom Otero- Rivera make incriminating statements. 3. State witness Brett Burger, a sergeant at the Osceola County Jail, will testify to the housing of these inmates within the Osceola County Jail. Specifically, that housing records of the Osceola County Jail corroborate these incarcerated witnesses in that they were in fact housed with Christopher Otero-Rivera during the relevant time frame. 4, Sgt. Burger reviewed extensive and voluminous housing records from the database kept by the Osceola County Jail in order to prepare for his testimony. Rather than providing these voluminous records, Sgt. Burger prepared a summary of Christopher Otero- Rivera’s cellmate assignments and housing. The State provided this summary at pages 4224 through 4226 in discovery in this case.5. The State will make the individual housing records upon which the summary is based available to defense counsel or the Court upon request. WHEREFORE, the State provides this Notice in hopes the Court will permit it to rely upon the summary of information described above as evidence in this cause. WILLIAM GLADSON STATE ATTORNEY FIFTH JUDICIAL CIRCUIT /s/ Matthew Ryan Williams Matthew Ryan Williams Designated Assistant State Attorney Fifth Judicial Circuit Florida Bar No. 028645 425 N. Orange Ave. Box 63 Orlando, FL 32801 twilliams@sao5.org CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the above has been furnished to Migdalia Perez and Frank Bankowitz, Counsel for the Co-Defendants, by electronic service this 19th day of March, 2021. /s/ Matthew Ryan Williams Matthew Ryan Williams Designated Assistant State Attorney