Filing # 95082634 E-Filed 09/01/2019 02:44:15 PM

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT

IN AND FOR ORANGE COUNTY, FLORIDA

CASE NUMBER: 2016 CF 15738 A

2017 CF 826

STATE OF FLORIDA,
Plaintiff,
vs.

MARKEITH LOYD,
Defendant.
_____________________/

NOTICE OF CONTINUED TESTING AND EVALUATION BY EXPERTS AND

REQUEST TO STAY DISCLOSURE OF RAW DATA AND OTHER TESTING
RESULTS UNTIL COMPETION OF TESTING

Defendant MARKEITH LOYD, by and through undersigned counsel, files this motion
and states:
1. This Court, over the Defendant’s objection, has set various deadlines for Discovery
involving compliance of both disclosure and otherwise. Several of the Defendant’s
experts have not completed their evaluation. This includes:
a. Christopher Robinson, Firearms Expert.
b. John Sawicki, Telephone Expert and Facebook Expert, which includes raw data and
reports and items in excess of 3200 pages.
c. Doug Carner, Video Expert, which includes approximately 3000 frames from the
Walmart video that were enhanced, clarified, highlighted or zoomed. Additionally,
included are multiple video fragments of the Walmart video footage provided by the
State.
d. Unknow Expert yet to be requested regarding 10,000+ images from police helicopter
video footage of Defendant’s arrest recently turned over to the Defense by Prosecutor
Stacey Salmons subsequent to August 1, 2019. (This material was also provided to
the Court by Ms. Salmons)

2. Other experts may be necessary based on the recent disclosure of material and witnesses
by the State.

1
 WHEREFORE, Defendant requests that this Court Stay Disclosure as outlined in this

motion.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing motion was served via
Efiling notification on the Office of the State Attorney on September 1, 2019.

Respectfully Submitted,

s/Terence M. Lenamon
Terence M. Lenamon, Esq.
Florida Bar No. 970476
245 S.E. 1st St.
Suite 404
Miami, FL 33131
p. 305-373-9911
f. 305-503-6973
terry@lenamonlaw.com