In order to obtain records under Rule 3.852(h)3),
a defendant must show that he has previously requested records
from the same agency, the records sought were not previously the
subject of an objection, and the records sought were not
received or produced since the previous request.
Florida Supreme Court has explained that “a public records request
under [Rule 3.852(h)(3)] is intended as an update of information
previously received or requested.” Sims v. State, 753 So. 2d 66,
70 (Fla. 2000).