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Filing # 83014229 E-Filed 01/08/2019 01:44:26 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA CRIMINAL ACTION
STATE OF FLORIDA CASE NO: — 18-001881CF - (DHM)
(GNS)
vs.
EDGAR JUNIOR KELLER, JR.
ANSWER TO DEMAND FOR DISCOVERY
Coes Now the STATE OF FLORIDA, by and through the undersigned Assistant State
Attorney, pursuant to Defendant's Notice of Discovery, and pursuant to Fla. R. Crim. P. 3.220,
and submits the following information.
1. The names and addresses of all persons known to the prosecutor to have information which
may be relevant to the offenses charged, and to any defense with respect thereto, are as follows:
+— indicates victim
* — indicates witness is under the age of 18
David A. Brooks, Charlotte County Sheriff's Office, Punta Gorda, FL 33982 Category C
Fernando Burga, Punta Gorda Police Department, 1410 Tamiami Trail, Punta Gorda, FL 33950
Category A
Shane Chodakowsky, Punta Gorda Police Department, 1410 S Tamiami Trail, Punta Gorda, FL
33950 Category A
Patrolman Justin DaVoult, Punta Gorda Police Department, 1410 S. Tamiami Trail, Punta
Gorda, FL 33950 Category A
Matthew Douglas Eliassen, 4315 Homewood Street, Punta Gorda, FL 33980 Category A
Abby M Gowin, c/o Bayfront Punta Gorda, 809 E. Marion Avenue, Punta Gorda, FL 33950
Category A
Officer Dean R. Irving, Punta Gorda Police Department, 1410 S. Tamiami Trail, Punta Gorda,
FL 33950 Category A
Linet Kamandulis FT, Florida Department of Law Enforcement, 500 W Robinson Street,
Orlando, FL 32801 Category A7 (Expert)
Francesca M. Swartz DR, C/O Orthopedic Associates of Southwest Florida, PA, 13691 Metro
Parkway S # 400, Fort Myers, FL 33912 Category A7 (Expert)
Joseph Trufan, Punta Gorda Police Department, 1410 Tamiami Trail, Punta Gorda, FL 33950
Category A
+ Diana Wenz, 1098 Strasburg Drive, Port Charlotte, FL 33952 Category A
Together with any other persons named in any investigative or laboratory reports or other
documents furnished in compliance with Discovery Rules.
Discovery 001-042
Page 1 of 4RE: Edgar Junior Keller, Jr., 18-001881CF
2. An affirmative response will appear below for each subparagraph listing items in the State’s
possession or control.
a. [J Material or information provided by confidential informant, the
name(s) of confidential informant(s) will NOT be supplied unless the state
intends to use same as witness(es) at the trial or unless required by court
order after notice and hearing.
b. [] Electronic surveillance of premises of accused or of conversations to
which accused was a party. (Documents relating thereto.)
c. [XJ Search and seizure. (Documents relating thereto.)
3. All tangible papers, objects and statements provided under Fla.R.Crim.P.3.220(b) may be
inspected, photographed or tested, upon signed receipt for same during the regular and
ordinary business hours at
a. State Attorney’s Office, Punta Gorda.
And/or
b. Punta Gorda Police Department
Certificates of Assurance for the applicable Alcohol Reference Solution and all
relevant intoxilyzer documentation may be inspected, copied, tested, or photographed at
the office of the State Attorney, 20th Judicial Circuit. Please provide the undersigned 48
hours (excluding weekends and holidays) written notice of the time you will appear for
inspection of the documents.
Certificates of Assurances for the applicable Alcohol Reference Solutions are
maintained by the Florida Department of Law Enforcement in Tallahassee but are
available online at https://www.fdle.state.fl.us/Alcohol-Testing-Program/Intoxilyzer-8000-
Records Intoxilyzer records, including inspection data, are available in the public records
section in the Alcohol Testing Program portion of the FDLE website available online at
the above listed web address.
Please give the undersigned 48 hours (excluding weekends and holidays) written
notice of the time you will appear for inspection of the disclosures herein.
This document serves as authorization for the attorney for the defendant or his
designated representative, to conduct the said discovery of tangible papers, objects and
statements in the above-styled cause, with reference to:
Agency Number: 18-00403 Punta Gorda Police Department
GNS:hkm
Page 2 of 4RE: Edgar Junior Keller, Jr., 18-001881CF
Employee files including internal investigative reports are maintained by the current or
former employing law enforcement agencies.
4. The State has herein submitted its witness list and expects the defense to submit its witness
list, with names and addresses, within fifteen (15) days as provided in R.Cr.P.3.220(d)(1),
or promptly upon receipt of such information. Please notify the undersigned Assistant State
Attorney within fifteen (15) days, or promptly upon receipt of such information, whether
you have in your possession or control any of the following:
a. The Statement of any person whom the Defendant expects to call as a
witness at a trial or hearing.
b. Reports or statements of experts made in connection with the
particular case, including results of physical or mental examinations
and of scientific tests, experiments or comparisons.
c. Any tangible papers or objects, which the Defendant intends to use in
a hearing or trial.
CERTIFICATE OF SERVICE
THEREBY CERTIFY that a true and correct copy of the foregoing Discovery Disclosure has
been furnished to Brian Concilio, Assistant Public Defender, 350 E. Marion Avenue, Suite A-
1099, Post Office Box 510304, Punta Gorda, FL 33951-0304, by United States Mail/Hand
Delivery/Electronic Transmission this January 7, 2019.
Amira D, Fox
ACTING STATE ATTORNEY
BY: /s/ Garrick N. Soja
Garrick N. Soja
Assistant State Attorney
Florida Bar Number 0093306
350 E. Marion Avenue
Punta Gorda, Florida 33950
(941) 637-2104
eService: ServiceSAO-CH@sao.cjis20.org
GNS:hkm.
GNS:hkm
Page 3 of 4Page 4 of 4
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Filing # 83014229 E-Filed 01/08/2019 01:44:26 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CRIMINAL ACTION STATE OF FLORIDA CASE NO: — 18-001881CF - (DHM) (GNS) vs. EDGAR JUNIOR KELLER, JR. ANSWER TO DEMAND FOR DISCOVERY Coes Now the STATE OF FLORIDA, by and through the undersigned Assistant State Attorney, pursuant to Defendant's Notice of Discovery, and pursuant to Fla. R. Crim. P. 3.220, and submits the following information. 1. The names and addresses of all persons known to the prosecutor to have information which may be relevant to the offenses charged, and to any defense with respect thereto, are as follows: +— indicates victim * — indicates witness is under the age of 18 David A. Brooks, Charlotte County Sheriff's Office, Punta Gorda, FL 33982 Category C Fernando Burga, Punta Gorda Police Department, 1410 Tamiami Trail, Punta Gorda, FL 33950 Category A Shane Chodakowsky, Punta Gorda Police Department, 1410 S Tamiami Trail, Punta Gorda, FL 33950 Category A Patrolman Justin DaVoult, Punta Gorda Police Department, 1410 S. Tamiami Trail, Punta Gorda, FL 33950 Category A Matthew Douglas Eliassen, 4315 Homewood Street, Punta Gorda, FL 33980 Category A Abby M Gowin, c/o Bayfront Punta Gorda, 809 E. Marion Avenue, Punta Gorda, FL 33950 Category A Officer Dean R. Irving, Punta Gorda Police Department, 1410 S. Tamiami Trail, Punta Gorda, FL 33950 Category A Linet Kamandulis FT, Florida Department of Law Enforcement, 500 W Robinson Street, Orlando, FL 32801 Category A7 (Expert) Francesca M. Swartz DR, C/O Orthopedic Associates of Southwest Florida, PA, 13691 Metro Parkway S # 400, Fort Myers, FL 33912 Category A7 (Expert) Joseph Trufan, Punta Gorda Police Department, 1410 Tamiami Trail, Punta Gorda, FL 33950 Category A + Diana Wenz, 1098 Strasburg Drive, Port Charlotte, FL 33952 Category A Together with any other persons named in any investigative or laboratory reports or other documents furnished in compliance with Discovery Rules. Discovery 001-042 Page 1 of 4RE: Edgar Junior Keller, Jr., 18-001881CF 2. An affirmative response will appear below for each subparagraph listing items in the State’s possession or control. a. [J Material or information provided by confidential informant, the name(s) of confidential informant(s) will NOT be supplied unless the state intends to use same as witness(es) at the trial or unless required by court order after notice and hearing. b. [] Electronic surveillance of premises of accused or of conversations to which accused was a party. (Documents relating thereto.) c. [XJ Search and seizure. (Documents relating thereto.) 3. All tangible papers, objects and statements provided under Fla.R.Crim.P.3.220(b) may be inspected, photographed or tested, upon signed receipt for same during the regular and ordinary business hours at a. State Attorney’s Office, Punta Gorda. And/or b. Punta Gorda Police Department Certificates of Assurance for the applicable Alcohol Reference Solution and all relevant intoxilyzer documentation may be inspected, copied, tested, or photographed at the office of the State Attorney, 20th Judicial Circuit. Please provide the undersigned 48 hours (excluding weekends and holidays) written notice of the time you will appear for inspection of the documents. Certificates of Assurances for the applicable Alcohol Reference Solutions are maintained by the Florida Department of Law Enforcement in Tallahassee but are available online at https://www.fdle.state.fl.us/Alcohol-Testing-Program/Intoxilyzer-8000- Records Intoxilyzer records, including inspection data, are available in the public records section in the Alcohol Testing Program portion of the FDLE website available online at the above listed web address. Please give the undersigned 48 hours (excluding weekends and holidays) written notice of the time you will appear for inspection of the disclosures herein. This document serves as authorization for the attorney for the defendant or his designated representative, to conduct the said discovery of tangible papers, objects and statements in the above-styled cause, with reference to: Agency Number: 18-00403 Punta Gorda Police Department GNS:hkm Page 2 of 4RE: Edgar Junior Keller, Jr., 18-001881CF Employee files including internal investigative reports are maintained by the current or former employing law enforcement agencies. 4. The State has herein submitted its witness list and expects the defense to submit its witness list, with names and addresses, within fifteen (15) days as provided in R.Cr.P.3.220(d)(1), or promptly upon receipt of such information. Please notify the undersigned Assistant State Attorney within fifteen (15) days, or promptly upon receipt of such information, whether you have in your possession or control any of the following: a. The Statement of any person whom the Defendant expects to call as a witness at a trial or hearing. b. Reports or statements of experts made in connection with the particular case, including results of physical or mental examinations and of scientific tests, experiments or comparisons. c. Any tangible papers or objects, which the Defendant intends to use in a hearing or trial. CERTIFICATE OF SERVICE THEREBY CERTIFY that a true and correct copy of the foregoing Discovery Disclosure has been furnished to Brian Concilio, Assistant Public Defender, 350 E. Marion Avenue, Suite A- 1099, Post Office Box 510304, Punta Gorda, FL 33951-0304, by United States Mail/Hand Delivery/Electronic Transmission this January 7, 2019. Amira D, Fox ACTING STATE ATTORNEY BY: /s/ Garrick N. Soja Garrick N. Soja Assistant State Attorney Florida Bar Number 0093306 350 E. Marion Avenue Punta Gorda, Florida 33950 (941) 637-2104 eService: ServiceSAO-CH@sao.cjis20.org GNS:hkm. GNS:hkm Page 3 of 4Page 4 of 4