Filing # E-Filed 12/20/2023 01:55:44 PM

IN THE CIRCUIT COURT,

SEVENTH JUDICIAL CIRCUIT, IN AND FOR
VOLUSIA COUNTY, FLORIDA

CASE NO: 2023 305335 CFDB

STATE OF FLORIDA

VS.

CHARLES LEON IVY

NOTICE OF INTENT TO SEEK THE DEATH PENALTY AND LIST OF

AGGRAVATING FACTORS

COMES NOW, R.J. LARIZZA, State Attorney for the Seventh Judicial Circuit,
by and through the undersigned Assistant State Attorney, and hereby gives notice of the
State's intent to seek the Death Penalty against the Defendant. The State intends to prove
and has reason to believe it can prove beyond a reasonable doubt the following
aggravating factors:
1. The Defendant was previously convicted of another capital felony or of a
felony involving the use or threat of violence to the person.
2. The capital felonies were committed for the purpose of avoiding or preventing
a lawful arrest or effecting an escape from custody.
3. The capital felonies were committed while the Defendant was engaged in the
commission of, or an attempt to commit, Arson and/or Burglary.
4. The capital felonies were especially heinous, atrocious, or cruel.
5. The capital felonies were committed in a cold, calculated, and premeditated
manner without any pretense of moral or legal justification.
6. The victim of one of the capital felonies was a person less than 12 yeas of age.
7. The Defendant knowingly created a great risk of death to many persons.

I HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished by delivery to Assistant Public Defender Lawrence Avallone, on December 20,
2023.
Respectfully submitted:

- z--- -
ANDREW J URBANAK
ASSISTANT STATE ATTORNEY
FLORIDA BAR NO. 76713
ESERVICEVOLUSIA@SAO7.ORG