12 analytical reports • 15 subject dossiers • 57 evidence PDFs • 7 records request templates
F.S. 784.045(1)(a) classification vs. F.S. 775.082(3)(d) maximum — 20yr exceeds 15yr cap by 5 years. Primary appeal ground.
Spanish-language lineup administered to English-primary witness. Manson v. Brathwaite admissibility challenge framework.
Traffic cameras operational at 1370 E Altamonte Dr. Footagenot disclosed to defense. Brady v. Maryland (1963) analysis.
Medical evidence review. Challenges prosecution's classification of injury severity to support aggravated battery charge.
7 documented contradictions between police statements and trial testimony. Impeachment framework for appeal.
Active ride = Uber duty of care. Florida $1M commercial liability. Third-party alternative causation theory.
Strickland v. Washington analysis. Trial counsel failures: lineup challenge, Brady motion, Uber theory, inconsistency cross.
State disclosure compliance, discovery production timeline, and potential bad faith suppression analysis.
Scoresheet analysis, prior record, enhancement factors. Challenges basis for any enhancements above statutory max.
Priority ordering of all grounds. Consolidated appellate brief framework. Parallel motion to correct illegal sentence.
FL Chapter 119 framework. Priority targets: body cam, traffic cam, lineup records, dispatch logs, prosecutor file.
Strategic use of public advocacy to support legal campaign. Platform coordination, narrative framing, timing.
Full background, prior record assessment, character evidence, community ties, and mitigating factors for sentencing.
Statement history, background, credibility assessment, prior interactions with law enforcement.
Driver profile, background, employment with Uber, any prior incidents. Key commercial ride liability witness.
Officer background, complaint history, lineup administration procedure review, report accuracy analysis.
Officer responsible for Spanish-language lineup. Procedure review, training records, and prior lineup challenges.
Trial attorney profile, case strategy review, motions filed, cross-examination records. IAC analysis foundation.
Complete statement history: 911, first responder, detective interview, deposition, trial. Inconsistency grid.
Complete statement history and cross-reference matrix. Background and credibility assessment.
State attorney profile, prior Brady violation history, appellate record, prosecutorial conduct review.
Judicial history, reversal rate, prior sentencing challenges, and rulings on motions to correct illegal sentences.
Secondary witnesses, first responders, SCSO responding unit, medical personnel, and Uber corporate representative.
FL Ch. 119 public records request for all traffic camera footage at/near 1370 E Altamonte Dr on February 22, 2023. Preservation demand and legally required response deadline assertion.
All body-worn camera footage from every officer responding to incident #202300001348 on February 22, 2023. Includes officer interaction footage from arrival through transport.
Complete incident report, dispatch logs, CAD records, and all interdepartmental communications related to Booking #202300004473.
All records related to photo lineup procedure — administration notes, officer instructions given to witness, witness statements before and after, recorded identification, and procedural compliance documentation.
Complete case file: all filings, motions, orders, transcripts (arraignment, hearings, trial, sentencing), and correspondence. Case #202300001348 / Warrant #23912CFA.
All materials disclosed to defense during discovery plus internal production log. Required to identify Brady material omissions through disclosure gap analysis.
Subpoena template for Uber Technologies Inc. — full trip record for ride active on Feb 22, 2023 originating near 1370 E Altamonte Dr: GPS data, timestamps, driver info, fare, safety events, communications.