On December 21, 2020 a
Party Notice
was filed
involving a dispute between
and
in the District Court of Gadsden County.
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Filing # 118785754 E-Filed 12/28/2020 04:30:01 PM
IN THE COUNTY COURT OF THE
SECOND JUDICIAL CIRCUIT, IN
AND FOR GADSDEN COUNTY,
FLORIDA
STATE OF FLORIDA CASE NO. 20-00480MMA
SPN
vs
ANSWER TO DEMAND FOR DISCOVERY
AND
DEMAND FOR NOTICE OF ALIBI
Keith Lee Marshall,
Defendant(s).
/
Comes now the State of Florida, by and through the undersigned Assistant State Attorney,
pursuant to defendant's DEMAND FOR DISCOVERY and Florida Rule of Criminal Procedure 3.220,
and furnishes the following:
1. The names and addresses of all persons known to the prosecutor at the present time to have information
which may be relevant to the offense charged and to any defense with respect thereto or to any similar
fact evidence to be presented at trial under Section 90.404(2), Florida Statutes are listed below. All
names listed below are Category A witnesses unless specifically designated otherwise.
Cat. A
E. Smith ##1693, Quincy Police Department, 121 E. Jefferson Street, Quincy, FL 32351
Nakia Baldwin, 64 N. Cleveland St. Quincy, FL 32351, (850) 443-6633
Zola Akins, 119 Grace Cunningham Rd. Quincy, FL 32351, (850)591-9766
Cat. B
Cat. C
2. Listed below are the statements of witnesses whose names were furnished in #1 above and copies of
said statements or reports are Attached to defense counsel's copy of this Answer.
3. There are not written or recorded statements (unless listed below) of the defendant and copies are
attached to defense counsel's copy of this Answer. The defendant did not make oral statements to the
following persons (unless listed below), and the substance of those statements is listed below
STATEMENTS MADE TO: SUBSTANCE OF STATEMENT:
SEE REPORTS
4. There are not written or recorded statements of codefendants (unless listed below) and copies are
attached to defense counsel's copy of this Answer. The co-defendant(s) did not make oral statements to
the following persons (unless listed below), and the substance is listed below.
STATEMENTS MADE TO: SUBSTANCE OF STATEMENTS.
SEE REPORTS
5. There is not recorded Grand Jury testimony of the defendant (unless listed below).
6. There are tangible items which were obtained from or belong to the defendant and are described
belowPhotograph, fingerprints,
7. Information relative to the offense was not provided by a confidential informant.
8. There was not electronic surveillance of the premises of the defendant or of conversation to which
the defendant was a party (unless listed below).
9. There was not a search and seizure (unless listed below) and documents related to any search and
seizures are attached.
10. There are not reports or statements of experts (unless listed below), and copies of said reports or
statements are attached to defense counsel's copy and listed below
11. The tangible evidence known to the prosecutor in addition to items mentioned in #6 preceding is
listed below.
Arrest/NTA, Booking information sheet, FA Sheet, NTA, Offense-Incident report, Arrest/NTA,
Perjury Warning Notice, Witness statement form, recorded statement, Property receipt, Body cam
available upon request.
Defense counsel is hereby permitted, at a time and place mutually agreed upon by counsel for
the State and for the defense, or as otherwise ordered by the Court, to inspect, copy, test and/or
photograph the foregoing statements, documents, test results, and/or tangible items of evidence
12. The State has herein submitted its complete ANSWER TO DEMAND FOR DISCOVERY pursuant
to F.R.Cr.P. 3.220, and respectfully demands the defense to submit its corresponding witness list within
seven days and disclose to the State and permit them to inspect, copy, test and/or photograph the
information and material in the defendant's possession or control as listed in F.R.Cr.P. 3.220 within
fifteen days after receipt of this ANSWER TO DEMAND FOR DISCOVERY.
13. The State hereby makes DEMAND FOR NOTICE OF ALIBI in the event such defense is to be used
at the trial of this defendant.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to
Jared Woliver, on December 28, 2020 by e-service to service.gadsden@flpd2.com
JACK CAMPBELL
STATE ATTORNEY
SECOND JUDICIAL CIRCUIT
/s/Amanda Schneider
Assistant State Attorney
Document Filed Date
December 28, 2020
Case Filing Date
December 21, 2020
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Filing # 118785754 E-Filed 12/28/2020 04:30:01 PM IN THE COUNTY COURT OF THE SECOND JUDICIAL CIRCUIT, IN AND FOR GADSDEN COUNTY, FLORIDA STATE OF FLORIDA CASE NO. 20-00480MMA SPN vs ANSWER TO DEMAND FOR DISCOVERY AND DEMAND FOR NOTICE OF ALIBI Keith Lee Marshall, Defendant(s). / Comes now the State of Florida, by and through the undersigned Assistant State Attorney, pursuant to defendant's DEMAND FOR DISCOVERY and Florida Rule of Criminal Procedure 3.220, and furnishes the following: 1. The names and addresses of all persons known to the prosecutor at the present time to have information which may be relevant to the offense charged and to any defense with respect thereto or to any similar fact evidence to be presented at trial under Section 90.404(2), Florida Statutes are listed below. All names listed below are Category A witnesses unless specifically designated otherwise. Cat. A E. Smith ##1693, Quincy Police Department, 121 E. Jefferson Street, Quincy, FL 32351 Nakia Baldwin, 64 N. Cleveland St. Quincy, FL 32351, (850) 443-6633 Zola Akins, 119 Grace Cunningham Rd. Quincy, FL 32351, (850)591-9766 Cat. B Cat. C 2. Listed below are the statements of witnesses whose names were furnished in #1 above and copies of said statements or reports are Attached to defense counsel's copy of this Answer. 3. There are not written or recorded statements (unless listed below) of the defendant and copies are attached to defense counsel's copy of this Answer. The defendant did not make oral statements to the following persons (unless listed below), and the substance of those statements is listed below STATEMENTS MADE TO: SUBSTANCE OF STATEMENT: SEE REPORTS 4. There are not written or recorded statements of codefendants (unless listed below) and copies are attached to defense counsel's copy of this Answer. The co-defendant(s) did not make oral statements to the following persons (unless listed below), and the substance is listed below. STATEMENTS MADE TO: SUBSTANCE OF STATEMENTS. SEE REPORTS 5. There is not recorded Grand Jury testimony of the defendant (unless listed below). 6. There are tangible items which were obtained from or belong to the defendant and are described belowPhotograph, fingerprints, 7. Information relative to the offense was not provided by a confidential informant. 8. There was not electronic surveillance of the premises of the defendant or of conversation to which the defendant was a party (unless listed below). 9. There was not a search and seizure (unless listed below) and documents related to any search and seizures are attached. 10. There are not reports or statements of experts (unless listed below), and copies of said reports or statements are attached to defense counsel's copy and listed below 11. The tangible evidence known to the prosecutor in addition to items mentioned in #6 preceding is listed below. Arrest/NTA, Booking information sheet, FA Sheet, NTA, Offense-Incident report, Arrest/NTA, Perjury Warning Notice, Witness statement form, recorded statement, Property receipt, Body cam available upon request. Defense counsel is hereby permitted, at a time and place mutually agreed upon by counsel for the State and for the defense, or as otherwise ordered by the Court, to inspect, copy, test and/or photograph the foregoing statements, documents, test results, and/or tangible items of evidence 12. The State has herein submitted its complete ANSWER TO DEMAND FOR DISCOVERY pursuant to F.R.Cr.P. 3.220, and respectfully demands the defense to submit its corresponding witness list within seven days and disclose to the State and permit them to inspect, copy, test and/or photograph the information and material in the defendant's possession or control as listed in F.R.Cr.P. 3.220 within fifteen days after receipt of this ANSWER TO DEMAND FOR DISCOVERY. 13. The State hereby makes DEMAND FOR NOTICE OF ALIBI in the event such defense is to be used at the trial of this defendant. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to Jared Woliver, on December 28, 2020 by e-service to service.gadsden@flpd2.com JACK CAMPBELL STATE ATTORNEY SECOND JUDICIAL CIRCUIT /s/Amanda Schneider Assistant State Attorney