Filing # 95083048 E-Filed 09/01/2019 06:29:03 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 A

STATE OF FLORIDA,
Plaintiff,
vs.

MARKEITH LOYD,
Defendant.
_____________________/

MOTION TO COMPEL

Defendant MARKEITH LOYD, by and through undersigned counsel, files this motion

and states:

1. Defense counsel was provided subsequent to August 1, 2019 from Assistant State

Attorney Stacey Salmons a hard drive with 179GB of material from the investigation conducted

by the Florida Department of Law Enforcement and herself involving the arrest and injuries

suffered by the Defendant Markeith Loyd.

2. On the drive are seventeen (17) videos, ten of which are encoded and cannot be

opened. Also there are 229 interviews and only 126 transcripts. Also included is 5,564 pages of

emails from various parties including the attorneys involved in the case.

3. Defendant requests for this Court to order the State to 1) provide Defendant with

non-encoded videos that can be opened, and 2) all interview transcripts.

4. Of course, encoded videos that Defendant cannot open are of no use. The State

must be required to provide this discovery in a readily-usable format.

5. Defendant is also entitled to receive copies of all interviews which were

transcribed.

1
WHEREFORE, Defendant requests that the Court enter an order requiring the State to provide

the videos described herein in a usable format and provide copies of all transcribed interviews.

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