IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA JUAN GARCIA 1. PROSTITUTION/PROCURE OR SOLICIT ANOTHER TO COMMIT (2)(F) MISD.
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1 IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA THE STATE OF FLORIDA v. INFORMATION FOR JUAN GARCIA 1. PROSTITUTION/PROCURE OR SOLICIT ANOTHER TO COMMIT (2)(F) MISD. 2D Defendant(s) IN THE NAME AND BY AUTHORITY OF THE STATE OF FLORIDA: MICHAEL SPIVACK, of the Eleventh Judicial Circuit, on the authority of KATHERINE FERNANDEZ RUNDLE, State Attorney, prosecuting for the State of Florida, in the County of Miami-Dade, under oath, information makes that: AMD 7/17/00 DIRECT FILE-NO CAPIAS W/M, DOB: 11/11/59, SS# TO BE SURRENDERED IN COURT ON THURSDAY, JULY 20, 2000 AT 9:00 AM
2 Count 1 JUAN GARCIA on or about JUNE 24, 2000, in the County and State aforesaid, did unlawfully solicit, induce, entice, or procure another, to wit: ELLA MOORE, to commit prostitution, lewdness, or assignation, in violation of s (2)(f) Florida Statutes, contrary to the form of the Statute in such cases made and provided, and against the peace and dignity of the State of Florida.
3 STATE OF FLORIDA, COUNTY OF MIAMI-DADE: Personally known to me and appeared before me, the of the Eleventh Judicial Circuit of Florida whose signature appears below, being first duly sworn, says that this prosecution is instituted in good faith. Florida Bar # NW 12th Avenue, Miami, FL (305) Sworn to and subscribed before me this day of,. By Deputy Clerk for the Clerk of the Courts Notary Public
4 IN THE COUNTY COURT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA STATE OF FLORIDA v. JUAN GARCIA, Case No. Judge Defendant(s) DISCOVERY EXHIBIT UNDER FLORIDA CRIMINAL PROCEDURE RULE DEMAND FOR NOTICE OF ALIBI UNDER FLORIDA CRIMINAL PROCEDURE RULE COMES NOW KATHERINE FERNANDEZ RUNDLE, State Attorney of the Eleventh Judicial Circuit of Florida, by and through the undersigned, and files this Discovery Exhibit, Statement of Particulars, and Demand for Notice of Alibi under Florida Criminal Procedure Rules and 3.140(n) as follows: 1. The persons known to the State at this time, that have information which may be relevant to the offense charged, and to any defense with respect thereto, are as follows: (AS)= Category A - Witnesses who were present when a statement was taken from or made by defendant or codefendant. (A)1. (A)2. (A)3. SHEPARD, MAJOR (SGT) KELLY, (OFCR) MOORE, MPD (A)6. (A)7. MPD (OFCR), DIAZLAY, MPD MARTIN, G LATENT EXAMINER MPD (A)4. (OFCR) MCNAIR MPD (A)8. (SGT) CUNNINGHAM, (A)5. (OFCR) KNOWLES, Evidence which may be introduced at trial A copy of the Arrest form (if any) is attached A copy of the Information (if any) is attached A copy of the Police Report (if any ) is attached Paragraphs designated by an asterisk apply to the reciprocal provisions pursuant to Rule of the Florida Rules of Criminal Procedure only. 2. Pursuant to Rule 3.220(a)(1) of the Florida Rules of Criminal Procedure, the State will disclose to the defense counsel and permit him to inspect, copy, test and photograph the material and information, if any, provided for in paragraph (ii) through (xi), upon request, within five (5) days of receipt of this Discovery at a mutually convenient place
5 3. Pursuant to Rule 3.220(d) of the Florida Rules of Criminal Procedure, the State demands that within fifteen (15) days after receipt of this Discovery, that the defense disclose to the prosecuting attorney and permit him to inspect, copy, test, and photograph the following information and material which corresponds to that which the defense sought and which is in the defendant s possession of control: (1) a written list of all witnesses whom the defendant expects to call as a witness at the trial or hearing; (2) the statements of any person listed in d(1) above other than that of the defendant; (3) 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; any tangible papers or objects which the defendant intends to use in the hearing or trial. 4. COMES NOW KATHERINE FERNANDEZ RUNDLE, State Attorney of the Eleventh Judicial Circuit of Florida, by and through the undersigned, and files this Demand for Notice of Intention to Rely Upon Alibi Defense pursuant to Rule of the Florida Rules of Criminal Procedure, demanding that the defendant furnish the prosecuting attorney with a Notice of Alibi not less that ten (10) days prior to the trial, stating the place the defendant claimed to have been at the time of the alleged offense, and the names and addresses of the witnesses by whom he proposes to establish such an alibi, if such a defense will be relied upon at the time of trial. Respectfully submitted, KATHERINE FERNANDEZ RUNDLE STATE ATTORNEY By: MICHAEL SPIVACK Florida Bar # CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and exact copy of the attached and foregoing, was forwarded to Defendant s Attorney, on this day of,.
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