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Filing # 122716512 E-Filed 03/08/2021 07:40:03 PM
IN THE COUNTY COURT OF THE
NINETEENTH JUDICIAL CIRCUIT
IN AND FOR SAINT LUCIE COUNTY, FLORIDA
STATE OF FLORIDA Case No. 56-2021-MM-000179-A
Demand For Notice of Alibi
-vs- Demand for Reciprocal Discovery
State’s Discovery Exhibit
Randal Lee Hiers
Defendant
COMES NOW the State of Florida, by and through its undersigned State Attorney and files this
Discovery Exhibit, Demand for Reciprocal Discovery and Demand for Notice of Alibi pursuant
to Fla. R. Crim. P. 3.220 and 3.200 as follows:
DEMAND FOR NOTICE OF ALIBI
(1) As particularly as is known to the undersigned State Attorney, the place, date, and time of
the commission of the crime charged is:
DATE (on or about) From: January 24, 2021
DATE (on or about) To:
TIME (at or about)/PLACE: 7802 S. US Hwy 1., Port St. Lucie, FL
(2) The state herewith files this Demand for Notice of Intention to Rely Upon Alibi Defense
pursuant to Fla. R. Crim. P. 3.200 demanding that the defendant furnish the prosecutor with a
Notice of Alibi not less than ten (10) days prior to trial, stating the place the defendant claims to
have been at the time of the offense and the names and addresses of witnesses he proposes to use
to establish that alibi, if such a defense will be relied upon at trial.
DEMAND FOR RECIPROCAL DISCOVERY.
The State has submitted its witness list and demands within fifteen (15) days a written list of
the names and addresses of all witnesses the defense expects to call at the trial or hearing. In
addition, the State demands a discovery exhibit which shall disclose to and permit the prosecutor
to inspect, copy, test and photograph the statements of any persons listed by the defendant,
reports or statements of experts made in connection with the particular case and any tangible
papers or objects that the defendant intends to use in the hearing or trial.
STATE'S DISCOVERY EXHIBIT
(1) Pursuant to Fla. R. Crim. P. 3.220(b)(1)(B) through (M), the State discloses to the defendant,
and will permit the defendant to inspect, copy, test, and photograph the information and material
within the State’s possession or control as specifically identified below.(A) Fla. R. Crim. P. 3.220 (b)(1)(A) The names and addresses of all persons known to the
prosecutor to have information which may be relevant to any offense charged, or to any defense
thereto, or to any similar fact evidence to be presented at trial under section 90.404(2), Florida
Statutes, are listed below.
(i) Category A Witnesses: Pursuant to Fla. R. Crim. P. 3.220
(b)(1)(A)G), the State identifies witnesses encompassed by this
section with an ‘A’ preceding their name. Separately identified
within this category are persons who were present when a recorded
or unrecorded statement was taken from or made by a defendant or
codefendant, and these witnesses names are preceded by an ‘S’.
(ii) Category B Witnesses: Pursuant to Fla. R. Crim. P. 3.220
(b)(1)(A)(ii), the State identifies witnesses encompassed by this
section with a ‘B’ preceding their name.
(iii) Category C Witnesses: Pursuant to Fla. R. Crim. P. 3.220
(b)(1)(A)(iii), the State identifies witnesses encompassed by this
section with a ‘C’ preceding their name.
C Megan Mangel, 4700 West Midway Rd., Ft. Pierce, FL 34981 St. Lucie County Sheriff's
Office
C Renee Pieniazek, 4700 West Midway Rd., Ft. Pierce, FL 34981 St. Lucie County Sheriff's
Office
C Dawn Radke, 4700 West Midway Rd., Ft. Pierce, FL 34981 St. Lucie County Sheriff's Office
S Venessa Michelle Veazie, 8042 Us Highway 441 Se, Okeechobee, FL 34974
S Jessica Mae Webster, 7505 Deland Ave, Fort Pierce, FL 34951
S Caitlin Sue-Ann Wolf, 4250 Hwy 441 Se, Lot C7, Okeechobee, FL 34974
S Ashlynn Wyatt, 4700 West Midway Rd., Ft. Pierce, FL 34981 St. Lucie County Sheriff's
Office
The following list of discovery is being provided:
(B) Fla. R. Crim. P. 3.220 (b)(1)(B) The statement of any person whose name is furnished
above.
(C) Fla. R. Crim. P. 3.220 (b)(1)(C) Written or recorded statements made by the defendant and
the substance of any oral statements made by the defendant. Including a copy of any statements
contained in police reports or report summaries together with the name and address of each
witness to the statements: Summary of statements at the end of this section.
(F) Fla. R. Crim. P. 3.220 (b)(1)(F) Tangible papers or objects that were obtained from or
belonged to the defendant:
(I) Fla. R. Crim. P. 3.220 (b)(1)(I) There has been any search and seizure, and there may be
documents relating thereto:
(K) Fla. R. Crim. P. 3.220 (b)(1)(K) Tangible papers or objects that the prosecuting attorney
intends to use in the hearing or trial and that were not obtained from or that did not belong to the
defendant:
(*) The State Attorney is in possession of reports of the Department of Children and FamilyServices that are confidential and privileged pursuant to Florida Statute 39.202; however, the
defense may apply to the court for disclosure of said documents.
"(C) and/or (D)" RESPONSE: Defendant stated to D/S Wyatt over the phone "are you kidding
me I'm not coming and speaking to you. What are you saying I did, why would I come up
there."
Any further statements contained in Discovery Exhibits.
ALL TANGIBLE OBJECTS as provided by Fla. R. Crim. P. 3.220 (b)(1)(F), (K) and (L) may be
inspected, copied, tested, and photographed at:
State Attorney’s Office
St. Lucie County Sheriff's Office
Law enforcement agencies maintain records and tangible items at its offices. You should not
assume that the State Attorney’s Office possesses copies of all of these items. This document will
serve as authorization for Adrienne Bucchi, attorney for the defendant, or the defendant's
designated representative to inspect, copy, test, and photograph information and material
specified in Rule 3.220(b)(1) at the agencies listed above.
Agency Number: 2021-00926
Lab Number:
CAD Number:
Digital Media available as indicated below (see Electronic Discovery receipt for details):
FWC Bodycam Link Expiration Date:
Evidence.com Link Expiration Date:
I HEREBY CERTIFY that a true copy of the foregoing has been furnished to Adrienne
Bucchi, by eservice/email at the designated email address of Amb@abucchiattorney.com on
March 8, 2021.
RESPECTFULLY SUBMITTED
THOMAS R. BAKKEDAHL
State Attorney
By: /s/ Paige Farach
Paige Farach
Assistant State Attorney
FL Bar#: 1018541
411S. 2nd Street
Fort Pierce FL 34950
(772) 465-3000Designated eService address:
SA19eService@sao19.org
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Filing # 122716512 E-Filed 03/08/2021 07:40:03 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR SAINT LUCIE COUNTY, FLORIDA STATE OF FLORIDA Case No. 56-2021-MM-000179-A Demand For Notice of Alibi -vs- Demand for Reciprocal Discovery State’s Discovery Exhibit Randal Lee Hiers Defendant COMES NOW the State of Florida, by and through its undersigned State Attorney and files this Discovery Exhibit, Demand for Reciprocal Discovery and Demand for Notice of Alibi pursuant to Fla. R. Crim. P. 3.220 and 3.200 as follows: DEMAND FOR NOTICE OF ALIBI (1) As particularly as is known to the undersigned State Attorney, the place, date, and time of the commission of the crime charged is: DATE (on or about) From: January 24, 2021 DATE (on or about) To: TIME (at or about)/PLACE: 7802 S. US Hwy 1., Port St. Lucie, FL (2) The state herewith files this Demand for Notice of Intention to Rely Upon Alibi Defense pursuant to Fla. R. Crim. P. 3.200 demanding that the defendant furnish the prosecutor with a Notice of Alibi not less than ten (10) days prior to trial, stating the place the defendant claims to have been at the time of the offense and the names and addresses of witnesses he proposes to use to establish that alibi, if such a defense will be relied upon at trial. DEMAND FOR RECIPROCAL DISCOVERY. The State has submitted its witness list and demands within fifteen (15) days a written list of the names and addresses of all witnesses the defense expects to call at the trial or hearing. In addition, the State demands a discovery exhibit which shall disclose to and permit the prosecutor to inspect, copy, test and photograph the statements of any persons listed by the defendant, reports or statements of experts made in connection with the particular case and any tangible papers or objects that the defendant intends to use in the hearing or trial. STATE'S DISCOVERY EXHIBIT (1) Pursuant to Fla. R. Crim. P. 3.220(b)(1)(B) through (M), the State discloses to the defendant, and will permit the defendant to inspect, copy, test, and photograph the information and material within the State’s possession or control as specifically identified below.(A) Fla. R. Crim. P. 3.220 (b)(1)(A) The names and addresses of all persons known to the prosecutor to have information which may be relevant to any offense charged, or to any defense thereto, or to any similar fact evidence to be presented at trial under section 90.404(2), Florida Statutes, are listed below. (i) Category A Witnesses: Pursuant to Fla. R. Crim. P. 3.220 (b)(1)(A)G), the State identifies witnesses encompassed by this section with an ‘A’ preceding their name. Separately identified within this category are persons who were present when a recorded or unrecorded statement was taken from or made by a defendant or codefendant, and these witnesses names are preceded by an ‘S’. (ii) Category B Witnesses: Pursuant to Fla. R. Crim. P. 3.220 (b)(1)(A)(ii), the State identifies witnesses encompassed by this section with a ‘B’ preceding their name. (iii) Category C Witnesses: Pursuant to Fla. R. Crim. P. 3.220 (b)(1)(A)(iii), the State identifies witnesses encompassed by this section with a ‘C’ preceding their name. C Megan Mangel, 4700 West Midway Rd., Ft. Pierce, FL 34981 St. Lucie County Sheriff's Office C Renee Pieniazek, 4700 West Midway Rd., Ft. Pierce, FL 34981 St. Lucie County Sheriff's Office C Dawn Radke, 4700 West Midway Rd., Ft. Pierce, FL 34981 St. Lucie County Sheriff's Office S Venessa Michelle Veazie, 8042 Us Highway 441 Se, Okeechobee, FL 34974 S Jessica Mae Webster, 7505 Deland Ave, Fort Pierce, FL 34951 S Caitlin Sue-Ann Wolf, 4250 Hwy 441 Se, Lot C7, Okeechobee, FL 34974 S Ashlynn Wyatt, 4700 West Midway Rd., Ft. Pierce, FL 34981 St. Lucie County Sheriff's Office The following list of discovery is being provided: (B) Fla. R. Crim. P. 3.220 (b)(1)(B) The statement of any person whose name is furnished above. (C) Fla. R. Crim. P. 3.220 (b)(1)(C) Written or recorded statements made by the defendant and the substance of any oral statements made by the defendant. Including a copy of any statements contained in police reports or report summaries together with the name and address of each witness to the statements: Summary of statements at the end of this section. (F) Fla. R. Crim. P. 3.220 (b)(1)(F) Tangible papers or objects that were obtained from or belonged to the defendant: (I) Fla. R. Crim. P. 3.220 (b)(1)(I) There has been any search and seizure, and there may be documents relating thereto: (K) Fla. R. Crim. P. 3.220 (b)(1)(K) Tangible papers or objects that the prosecuting attorney intends to use in the hearing or trial and that were not obtained from or that did not belong to the defendant: (*) The State Attorney is in possession of reports of the Department of Children and FamilyServices that are confidential and privileged pursuant to Florida Statute 39.202; however, the defense may apply to the court for disclosure of said documents. "(C) and/or (D)" RESPONSE: Defendant stated to D/S Wyatt over the phone "are you kidding me I'm not coming and speaking to you. What are you saying I did, why would I come up there." Any further statements contained in Discovery Exhibits. ALL TANGIBLE OBJECTS as provided by Fla. R. Crim. P. 3.220 (b)(1)(F), (K) and (L) may be inspected, copied, tested, and photographed at: State Attorney’s Office St. Lucie County Sheriff's Office Law enforcement agencies maintain records and tangible items at its offices. You should not assume that the State Attorney’s Office possesses copies of all of these items. This document will serve as authorization for Adrienne Bucchi, attorney for the defendant, or the defendant's designated representative to inspect, copy, test, and photograph information and material specified in Rule 3.220(b)(1) at the agencies listed above. Agency Number: 2021-00926 Lab Number: CAD Number: Digital Media available as indicated below (see Electronic Discovery receipt for details): FWC Bodycam Link Expiration Date: Evidence.com Link Expiration Date: I HEREBY CERTIFY that a true copy of the foregoing has been furnished to Adrienne Bucchi, by eservice/email at the designated email address of Amb@abucchiattorney.com on March 8, 2021. RESPECTFULLY SUBMITTED THOMAS R. BAKKEDAHL State Attorney By: /s/ Paige Farach Paige Farach Assistant State Attorney FL Bar#: 1018541 411S. 2nd Street Fort Pierce FL 34950 (772) 465-3000Designated eService address: SA19eService@sao19.org