On January 05, 2024 a
Answer
was filed
involving a dispute between
and
Kyle M Dailey,
for MUNICIPAL ORDINANCE
in the District Court of Palm Beach County.
Preview
Filing # 20383198 Electronically Filed 11/10/2014 12:30:00 PM.
IN THE COUNTY COURT OF THE FIFTEENTH
TINTOTAT. CTRANTT CDTMTNAT. NTVTeTON
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO.2014C0001986ANB DIVISION "H"
STATE OF FLORIDA
ANSWER TO DEMAND FOR DISCOVERY;
DEMAND FOR RECIPROCAL DISCOVERY AND
DEMAND FOR NOTICE OF ALIBI
vs.
KYLE M DAILEY
The State of Florida, by and through the undersigned Assistant
State Attorney, hereby responds to the Demand for Discovery made on behalf of
the Defendant, pursuant to Rule 3.220(a)&(b), Florida Rules of Criminal
Procedure. The State hereby demands a Reciprocal Discovery Exhibit and all
disclosure required by the Defendant, pursuant to Rule 3.220(a) (c)&(d),
Florida Rules of Criminal Procedure. Further, the State hereby demands
Notice of Alibi pursuant to Rule 3.200, Florida Rules of Criminal Procedure.
NOTICE IS HEREBY GIVEN that all information and material as
defined by Rule 3.220(a), Florida Rules of Criminal Procedure, within the
State’s possession or control has been disclosed by providing copies of all
reports and statements in the State Attorney’s file to the Attorney for the
Defendant.
The Attorney for the Defendant, AARON M. COHEN, ESQ., is hereby
granted permission to inspect, copy, test, and photograph the information and
material described in supplied reports which are attached to this answer, if
prior notice has been given to the undersigned of any such inspection,
copying, testing, or photographing.
Respectfully submitted,
DAVID ARONBERG
STATE ATTORNEY
/s/
By: PAMELA A. FORD
Assistant State Attorney
Florida Bar No. 0896608
E-Service E-Mail: CCDIVNC@SA15.ORG
PALM BEACH COUNTY, FL SHARON R BOCK, CLERKKYLE M DAILEY
201400001 9862NB
RIVIERA BEACH POLICE DEPARTMENT
AGENCY CASE NO: 14-08211
LIST OF PERSONS KNOWN TO HAVE INFORMATION
ALL WITNESSES ARE CLASSIFIED AS CATEGORY A UNLESS OTHERWISE NOTED
WITNESS CATEGORY A
OFC. JOHN VANDERLAAN #5768
RIVIERA BEACH POLICE DEPARTMENT
600 WEST BLUE HERON BOULEVARD
RIVIERA BEACH, FL 33404
WITNESS CATEGORY B
WITNESS CATEGORY CDEFENDANT:
CASE NUMBER:
AGENCY:
AGENCY CASE NO:
onan @
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IED
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KYLE M DAILEY
2014C0001986ANB
RIVIERA BEACH POLICE DEPARTMENT
14-08211
COUNTY COURT DIVISION EVIDENCE CHECKLIST
STATEMENTS OF WITNESSES:
STATEMENT OF DEFENDANT:
STATEMENT OF CO-DEFENDANT (S) :
] (Taped)
CERTIFIED COPIES OF DEFENDANTS CONVICTIONS
DEFENDANT’S DRIVING RECORD
[ ] (Written)
SUPPL. /OFFENSE REPORTS BY: on
BY: on
BY: on
PROPERTY RECEIPT DATE:
DATE
ADDITIONAL EVIDENCE
11 arrest panort/Motica to Agnasr T1 Accident Banort [1 Bhotae
{] Arrest Report/Notice to Appear [] Accident Report [] Photos
[] Probable Cause Affidavit [] Citations Cece eee eee
[] Def£’s Booking Photo [] Photo Line-up [] Narcotics
[] 911 tape and CAD Report. [] Miranda card [] Victim Med. Records
Certified Copy of
[] Drug Paraphernalia Oe [] Injunction and Proof
of Service
[] EM?_Reports
(dates):
[] other:
DUI
] Video Tape and/or DVD 0) BREATH TESTING MATERIAL
] DUI Probable Cause Affidavit [] Breath Test Affidavits
] Roadside tasks [] Results cards
[] DUI Testing Facility Task [] Instrument Certifications
Report
[] DUI Testing Facility [] Operator’s Permits
a Information Sheet TT
Miranda Card 0] Maintenance Records/Logs
Implied Consent Card [] Operator’s Checklists
Booking Slip [] Chemical Test Records
Refusal Affidavit
]
]
]
] Fingerprints
]
] Question and Answer Form{] URINALYSIS MATERIALS
[] Toxicology Report
[] Expert C.v.:
Q
VIOLATION OF PROBATION
a
0
300 60
Pride Probation File
Notice to Report
Affidavit of Violation
Monthly Statement Reports
Court Order
Information Sheets
Other:
BLOOD MATERIAL
Hospital Records/Medicals
Med. Blood/Analysis/Results
Legal Blood/Analysis/Results
Blood Test Affidavit
Blood Test Results
Certificates of Blood
Drawer
Blood Kit/Blood Vials
Analysis Certification
Ambulance/Paramedic Keports
Toxicology Report
Expert C.V .:
All witnesses,
disclosed during depositions.
statements and evidence listed in police reports and
Copies of all recordings are to be obtained from the Police Department.
CERTIFICATE OF SERVICE
IT IS HEREBY CERTIFIED by the undersigned that a true and correct
copy of the foregoing Discovery Exhibit (Answer
Demand for Reciprocal Discovery Exhibit;
to Notice of Discovery);
and Demand for Notice of Alibi has
been furnished by E-SERVICE to the Attorney for the Defenaant.
NAME: AARON M. COHEN, ESQ. at
day of November, 2014.
/s/
By: PAMELA A. FORD
amc@aaronmcohenpa.com on
this, the
Assistant State Attorney
Florida Bar No.
0896608
Document Filed Date
December 15, 2023
Case Filing Date
January 05, 2024
Category
MUNICIPAL ORDINANCE
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