20 Pearl Street, St Augustine,
Hon. Judge Dennis Craig
Volusia County Courthouse Annex
125 E. Orange Ave., Suite 307
Daytona Beach, FL 32114
RE: CASE NO. 2015301300 CFDB
Your honor, I am the Defendant in the above captioned case. This letter serves as a humble
request that you rule on the Motion to vacate, which Motion I filed on July 21, 2021. Almost
ten months have passed since I filed the said Motion, but I am yet to get any response from
the State. Besides, your honor, there has been no communication from you regarding the
In the said Motion, I have alleged prosecutorial misconduct in that the State omitted and/or
deleted pertinent evidence on how they obtained the cell phone data that was used against me.
The evidence would be central to a determination of my innocence had the State presented it
The Motion also contains my need for legal representation. Your honor, the case is complex
since it involves a violation of my constitutional rights. I have little and/or no knowledge in
the law, and therefore cannot represent myself in this case. Besides, I cannot afford an
attorney. I have therefore requested for a Court-appointed attorney to help me in this case.
Your honor, I would be subjected to more detriment if a consideration of the Motion is
delayed any further. It would therefore be in the interest of justice for you to consider this
humble request for you to expedite the hearing and consideration of the Motion.
Thank you for your attention,
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