Forrest v. State

We find no error in the failure of the trial court to hold a hearing pursuant to Richardson v. State, 246 So.2d 771 (Fla. 1971), because the record demonstrates that the state furnished the ballistics reports at issue to the defense prior to trial, so there was no discovery violation.

We also reject appellant’s argument that reversal is required due to the trial court’s denial of an ore tenus motion for disqualification.1 The law is well-set-*630tied that a motion for disqualification must be made in writing, and a request that is only made orally is legally insufficient. See Fla. R. Jud. Admin.…