Complete chronological record from incident through conviction, appeal build, and critical deadline.
May 10, 2026 — Florida Rules of Appellate Procedure — all grounds must be filed
Altercation occurs inside active Uber vehicle near 1370 E Altamonte Dr, Altamonte Springs, FL 32701. Uber trip is commercially active at time of incident, establishing Uber's duty of care. Traffic cameras at location confirmed operational. Camera footage not preserved or disclosed to defense.
Brady Material — Camera FootageAltamonte Springs PD and Seminole County Sheriff's Office respond. SCSO Report #202300001348 filed. Witness statements taken at scene. Body cameras confirmed active on responding officers — footage must be requested via FL Ch. 119 records request.
Body Cam Records RequiredArrest warrant #23912CFA executed. Marquis Delcampo booked — Booking #202300004473, Seminole County. Charged with Aggravated Battery under F.S. 784.045(1)(a), Second Degree Felony. Defense alleges: rights advisement compliance at arrest must be reviewed in full booking record.
Warrant Adequacy Review RequiredPhoto lineup administered to primary identification witness. Critical procedural defect: lineup conducted in Spanish. Witness does not speak Spanish as primary language. Identification procedure is fundamentally tainted under Manson v. Brathwaite standards. Trial counsel failed to challenge this identification.
Tainted ID — Brady + IAC GroundDefendant arraigned in 18th Judicial Circuit, Seminole County, Florida. Case #202300001348. Plea entered. Bail hearing conducted. Defense counsel assigned/retained.
State produced discovery materials. Traffic camera footage at 1370 E Altamonte Dr — confirmed operational on date of incident — was NOT disclosed to defense. This constitutes a Brady violation under Brady v. Maryland (373 U.S. 83, 1963). State had constructive duty to disclose all potentially exculpatory material evidence.
Brady Violation — Camera Footage SuppressedTrial defense counsel filed motions. CRITICAL FAILURES: No motion to suppress tainted photo lineup identification. No Brady motion for camera footage. No motion exploring Uber corporate liability as alternative causation. These failures form the core of the Strickland IAC challenge.
IAC — Critical Motion FailuresTrial conducted in 18th Judicial Circuit. Prosecution presented tainted lineup identification. Witness inconsistencies between original police statements and trial testimony were not adequately impeached on cross-examination. Uber liability theory was never introduced as alternative causation. Trial counsel failed on all four critical defense vectors.
IAC — Inadequate Cross-ExaminationJury returns guilty verdict on charge of Aggravated Battery, Second Degree Felony. Defense failed to secure acquittal despite multiple viable challenge grounds that went unexplored. Verdict sets stage for illegal sentencing.
Court imposes 20-year sentence in Florida Department of Corrections. THIS SENTENCE IS ILLEGAL. F.S. 784.045(1)(a) is a Second Degree Felony. F.S. 775.082(3)(d) sets maximum at 15 years. The court exceeded the statutory maximum by 5 years. Sentence must be corrected — this is the single most powerful appellate ground.
ILLEGAL SENTENCE — 5 Years Over Statutory MaxFull case review initiated. 12 analytical reports authored. 15 subject dossiers compiled. 57 evidence PDFs cataloged and hash-verified. Brady violation identified, sentencing illegality confirmed, IAC grounds documented. Records request strategy built.
Intelligence Build CompleteFL Chapter 119 public records campaigns targeting: body camera footage (ASPD + SCSO), traffic camera footage, photo lineup records, dispatch logs, and State Attorney discovery production log. Subpoena template prepared for Uber Technologies Inc.
Records Campaign — ActivePriority ground framework complete: (1) Illegal Sentence — Motion to Correct, (2) Brady Violation, (3) Tainted Identification, (4) Witness Inconsistencies / IAC, (5) Uber Liability / IAC. Florida Rules of Appellate Procedure compliance framework in place. All grounds to be filed simultaneously.
Brief Framework ReadyAbsolute deadline for all appellate filings under Florida Rules of Appellate Procedure. Motion to Correct Illegal Sentence, full appellate brief, Brady motion, IAC challenge — ALL must be filed on or before this date. Missing this deadline forfeits all grounds permanently.
HARD DEADLINE — NO EXTENSIONS