MEMORANDUM

TO: Defense Attorneys, 24th Judicial Circuit

FROM: Grant R. Doty, Assistant Public Defender

DATE: May 12, 2026

Other posts regarding Rule 57.03(b)(4) depo info:

• Ste. Genevieve County Sheriff’s Department (SGCSD) [pending]
• Farmington Police Department (FPD)
• Bismarck Police Department (BPD) [this post]
• St. Francois County Sheriff’s Department (SFCSD)

I. The Power of Rule 57.03(b)(4)

I’ve posted about Rule 57.03(b)(4) Depos (applicable in criminal cases via Rule 25.12). I think it is a potent but underutilized tool – in large part because paying criminal defendants are unlikely to want to pay for such depos which are by nature “general” depos on topics like policies and procedures, etc., and not on client specific facts.*

*Rule 57.03(b)(4) organizational depos require the organization to designate a representative to testify on its behalf regarding specific and relevant (relevant to the client)  “topics”. The testimony is binding upon the organization, effectively locking the department into a specific version of its policies, hardware capabilities, and retention practices.

II. Deposition Topics:

In a recent deposition involving the St. Francois County Sheriff’s Department (SFCSD), I had three “General Topics” that were relevant to my client: 

• Topic A: Body Cameras: Hardware, deployment, triggers, training, retention.
• Topic B: Dash Cameras: Hardware, deployment, triggers, training, retention.
• Topic C: Booking Area and Recording: Hardware, audio/visual capabilities, and data retention within the detention center.

III. Key Findings

A. Body Cameras: Pending Deployment in March 2026

Pending Deployment: As of March 24, 2026, the SFCSD body camera program is not yet deployed.

Cameras: The department took receipt of 40 Motorola V700 units approximately two weeks prior to the deposition.

Manual Triggers: The cameras will be manually operated via a power button. They will not automatically trigger based on vehicle speed or weapon withdrawal because the department’s current holsters are not compatible with the necessary Bluetooth technology.

TBD: Because the program was under development, I did not inquire about cloud storage, training, video retention, because it was not relevant to my case (i.e., no body cameras were use when my client was arrested. For cases occurring before April/May 2026, it is confirmed that no SFCSD body cam footage exists.

B. Dash Cameras: None

None/Zero Inventory: The SFCSO currently has no dash cameras in any of its vehicles.

C. Booking Area Video Evidence

Coverage of Booking Area: There are 12 Samsung (Model QNV-6082R) cameras in the booking and holding areas. These are fixed cameras that cover the booking counter and inside cells.

No Audio: Crucially, these cameras are strictly video only; there is no audio recording capability in the booking area.

Limited Manipulation: While the cameras have digital pan-tilt-zoom (PTZ) features, these can only be utilized at the time of recording from the central control area. PTZ cannot be performed on recorded footage during later review.

Standard Retention: Booking footage is generally retained for 30 days before being automatically overwritten.

Evidence “Burning”: If a crime occurs (e.g., assault or contraband), supervisors “burn” the footage to a separate file to be held until court proceedings are concluded.

Custodian of Records: While Rhonda Grosberg is the official Custodian of Records for Sunshine Law/report requests, the IT Department maintains direct contact with the servers.