Rule 3.220(d)(1)(B)(ii) provides that if a defendant elects to participate in discovery, the defendant shall turn over to the prosecution "reports or statements of experts made in connection with the particular case, including results of physical or mental examinations and of scientific tests, experiments, or comparisons . . . ." In Kearse v. State, 770 So. 2d 1119, 1126-27 (Fla. 2000), the defendant argued during the penalty phase that rule 3.202 was unconstitutional because it imposed discovery obligations on the defense but no corresponding obligation on the State. Id. The Court rejected that argument and explained that "while rule 3.202 does not by its terms require reciprocal discovery by the State, rule 3.220 spells out very specific discovery obligations by both sides when the defendant elects to participate in discovery." Id. at 1127. Accordingly, rule 3.220 continues to apply during the penalty phase.