Petition for Writ of Certiorari — Percy Allen Stucks, Petitioner v. Florida
Supreme Court briefOct 8, 2020
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IN THE
SUPREME COURT OF THE UNITED STATES
PERCY ALLEN STUCKS - PRO SE PETITIONER
VS.
JENNIFER J. MOORE - RESPONDENT(S)
23
First District Court of Appeal
State of Florida
No. 1D20-752
Percy Allen Stucks
Petitioner,
v.
State of Florida,
Respondent.
Petition for Writ of Prohibition—Original Jurisdiction.
September 21, 2020
Per Curiam.
Percy Allen Stucks has filed a pro se petition for writ of
prohibition seeking review of the trial court’s “Order Denying
Defendant’s Motion to Dismiss Pursuant to Florida Statutes
776.032 Justifiable Use of Force ‘Stand Your Ground.’” In case
number 1D18-1460, this Court dismissed an identical petition as
unauthorized pursuant to Logan v. State, 846 So. 2d 472 (Fla.
2003) (holding that, generally, a criminal defendant has no right
to partially represent himself and, at the same time, be partially
represented by counsel). When Stucks filed an original petition for
writ of prohibition directly in the Florida Supreme Court, the
supreme court likewise dismissed his case based on Logan. Stucks
u. State, No. SC19-2067, 2020 WL 639398 (Fla. Feb. 11, 2020).
!
,*
Nothing in the current record has changed in regard to Stucks’
pro se petition. Stucks still retains counsel below to represent him
in his criminal case; nothing in his petition indicates he sought, or
would be seeking, to discharge counsel in that proceeding as
required by Logan. 846 So. 2d at 474. Therefore, in light of the
decisions from this Court and our supreme court, we dismiss the
petition with prejudice as being barred by the doctrine of res
judicata. See Fla. Dep’t of Transp. v. Juliano, 801 So. 2d 101 (Fla.
2001); Hyland v. Inch, 291 So. 3d 1024 (Fla. 1st DCA 2020).
Dismissed.
Ray, C.J., and BlLBREY and Jay, JJ., concur.
Not final until disposition of any timely and
authorized motion under Fla. R. App. P. 9.330 or
9.331.
Percy Allen Stucks, pro se, Petitioner.
Ashley Moody, Attorney General, and Daren L. Shippy, Assistant
Attorney General, Tallahassee, for Respondent.
2
DISTRICT COURT OF APPEAL, FIRST DISTRICT
2000 Drayton Drive
Tallahassee, Florida 32399-0950
Telephone No. (850)488-6151
July 23, 2020
CASE NO.: 1D20-0752
L T. No.: 162016CF0Q6391 AXXXXMA
Percy Allen Stucks
Appellant / Petitioner(s),
v.
State of Florida
Appellee / Respondent(s)
BY ORDER OF THE COURT:
Petitioner’s motion to accept the reply as timely filed, docketed June 25, 2020, is denied
as moot. The Court notes that Petitioner’s reply was timely filed on June 25,’ 2020 in
compliance with this Court’s order of May 22, 2020.
I HEREBY CERTIFY that the foregoing is (a true copy of) the original court order.
Served:
Hon. Ashley Moody, AG
Percy Allen Stucks
Daren L. Shippy, AAG
co
KRISTIN/, SAMUELS, CLERK
A*v!
Supreme Court of jfiontra
TUESDAY, APRIL 14, 2020
CASE NO.: SC20-306
mi o 1
Lower Tribunal No(s).:
1D18-1460; 162016CF006391AXXXMA
PERCY ALLEN STUCICS
vs.
STATE OF FLORIDA
Petitioner(s)
Respondent^)
Petitioner’s Motion for Rehearing is hereby denied.
A True Copy
Test:
(.vV l0Lj:o
V
John A. Tomasino
Clerk. Supreme Couit
?*$?**%•r'
i
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Of
dl
Served:
JENNIFER J. MOORE
PERCY ALLEN STUCKS
HON. KRISTINA SAMUELS CLERK
HON. RONNIE FUSSELL, ’
^
CLERK
At
. !
•?
jf.
.J
Supreme Court of Jflortba
Office of the Clerk
500 South Duval Street
Tallahassee, Florida 32399-1927
John A. Tomasino
PhoneNumber: (850)488-0125
Clerk
Mark Clayton
Chief Deputy Clerk
Julia Breeding
Staff Attorney
www.floridasupremecourt.org
ACKNOWLEDGMENT OF NEW CASH
s
March 3, 2020
RE: PERCY ALLEN STUCKS
vs.
STATE OF FLORIDA
CASE NUMBER: SC20-306
Lower Tribunal Case Number(s): ID 18-1460; 162016CF006391AXXXMA
The Florida Supreme Court has received the following documents reflecting a
filing date of 3/2/2020.
Petition for Writ of Prohibition
The Florida Supreme Court's case number must be utilized on all pleadings and
correspondence filed in this cause.
tr
cc:
JENNIFER J. MOORE
TRISHA MEGGS PATE
PERCY ALLEN STUCKS
HON. KRISTINA SAMUELS, CLERK
W* I
Supreme Court of jfloriba
THURSDAY, MARCH 5, 2020
CORRECTED ORDER1
CASE NO.: SC20-306
Lower Tribunal No(s).:
1D18-1460; 162016CF006391AXXXMA
PERCY ALLEN STUCKS
Petitioner(s)
vs.
STATE OF FLORIDA
Respondent(s)
z.
Tj16 Peetltl°n for writ of Prohibition is hereby transferred, pursuant to
T
S0' 2d 1020 (Fla' 19">’t0
^‘District Court of
ppeal. The transfer of this case should not be construed as an adjudication or
mment on the merits of the petition, nor as a determination that the transferee
X„aforUrwrfof0n °H-HV ‘heLetiti0n ^ b6en P« denouttaatld Jt 6
transfer If flTl P
T ^ transferee C0Urt should not interpret the
oeTtion S
f35 “ lndlcfon that k “™st should reach the merits of the
fi fedTere h fttanferee °0Urt $ha11 treat ^ petiti°n 35 if il had been originally
whethtTf?," r ^“nT fi‘ed ” ‘hiS C°Urt'
termination concerning
cot^f aIvlnd8ane H
apP.licabIe *°this case shall be made by the transferee
transferee court.3 ?
®
CaSe are hereb* defe-d to the
menti„AnJ
pleadin8s flled regarding this case should be ftled in the above
ne is net court at 2000 Drayton Drive, Tallahassee, Florida 32399-0950.
™DADETC*a EXPIRES TO FILE SHEARING MOTION AND,
A True Copy
Test:
1. Corrected to reflect order dated from March 4, 2020 to March 5, 2020
ft" ft
DISTRICT COURT OF APPEAL
FIRST DISTRICT
STATE OF FLORIDA
2000 DRAYTON DRIVE
TALLAHASSEE, FLORIDA 32399-0950
(850) 488-6151
WVWV.1DCA.ORG
KRISTINA SAMUELS
CLERK OF COURT
DANA SHARMAN
CHIEF DEPUTY CLERK
March 06, 2020
Acknowledgment of New Case
RE:
Percy Allen Stucks v.
State of Florida
CASE NUMBER: 1D20-0752
Lower Tribunal Case Number: 162016CF006391 AXXXXMA
ohe, .^Ir+St ^'strict Court of APPeal has received the Petition/Application for Writ of
Prohibition filed in tnis Court on March 5, 2020.
In the future, all documents filed in this case must contain this Court's case number.
Per Administrative c Orders
10-1 and
a
’ Petitioner must file a Docketinq
Statement/Notice of Appearance of Counsel (“Docketing Statement”) immediately
rVirk +eCei'El thlS a<*nowledgment notice. If pro se, Petitioner may file a papeir
CoSrfsE9ni meportt»Mfmal1 °r 3? *l“,ronic Docketln9 Statement via the Fbrida
c. rtS E'Fll!ng P°rtal- If represented, Petitioner’s attorney must file the Docketina
Statement via the Portal. A tillable form version of the Docketing Statement is
httnlv/ 6 Via1!,lmk on *he “Documents” tab of the Portal or on this Court’s website at
^^ketinQWStatempnt^nS?Ur7efh^’eneral^nf°rrnatifln' °pPosin9 Parties must file a
Docketing Statement only if they seek to make amendments corrections or
additions to Petitioner’s Docketing Statement.
corrections, or
cp
Served:
Hon. Ashley Moody, AG
Percy Allen Stucks
* » r
i *"///.
Supreme Court of jflortba
FRIDAY, MARCH 13, 2020
CASE NO.: SC20-306
Lower Tribunal No(s).:
ID 18-1460; 162016CF006391AXXXMA
PERCY ALLEN STUCKS
vs.
Petitioner(s)
STATE OF FLORIDA
Respondent(s)
the
the party that attorney represents.
“ X":
3 CertiflCate of iS-vice stating
A^P^O*
°f
"?-m -* sas.*!1-
The Capitol. Tallahassee. Florida 3239<M05o’ and
Att,uTu.y ~eneral’ PL'01’
Certificate of Service Failure ™ -a +u- !^End fi ed Wlt^ ^ls Court a proper
within 20 days from the date of thN^ 6 1S S°Ult W*th a Certificate of Service
reinstatement!1
3nd
°n0e‘hiS 0386 is dismissed’1it may not be subject to
A True Copy
Test:
^22
John A. Tomasino
Clerk. Supreme Court
m,-.
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MN
Mrso/
di
Served:
JENNIFER J. MOORE
PERCY ALLEN STUCKS
.? vr
•V
DISTRICT COURT OF APPEAL, FIRST DISTRICT
2000 Drayton Drive
Tallahassee, Florida 32399-0950
Telephone No. (850)488-6151
May 22, 2020
CASE NO.: 1D20-0752
L.T. No.: 162016CF006391 AXXXXMA
Percy Allen Stucks
Appellant / Petitioner(s),
v.
State of Florida
Appellee / Respondent(s)
BY ORDER OF THE COURT:
No later than June 22, 2020, Respondent shall show cause why the petition for writ of
prohibition should not be granted. Petitioner may file a reply within 15 days thereafter.
I HEREBY CERTIFY that the foregoing is (a true copy of) the original court order.
Served:
Hon. Ashley Moody, AG
co
Krishna samuels, clerk
Percy Allen Stucks
%
IN THE CIRCUIT COURT, FOURTH
JUDICIAL CIRCUIT, IN AND FOR
DUVAL COUNTY, FLORIDA
CASE NO.:
16-2016-CF-6391 -AXXX
DIVISION:
CR-B
STATE OF FLORIDA
v.
PERCY ALLEN STUCKS,
Defendant.
ORDEl
TES 778
("MotJIT TT Came bef0re *" C0Urt 0n the Defendan^ Motion to Dismiss
(Motion) filed on February 21,2018. The Florida Legislature enacted Stand Y
our
may argue as an affirmative
“Jlr?13 U8r,,0rc8 W“ ,e9a"ViUStifl6d’ «*» ™032 contemplates
sut ler, T
en”"emBnt to the s,atulmy immune will no. be
subjected to Inal. Omnia V. State, 51 So. 3d 456,462 (Fla. 2010).
In the instant case, Defendant. Percy Stucks, shot and killed his girifri
©nd/live-in
roommate, Dorelle D. Davis ("Davis") m their h
ome on July 8, 2016*. The Defendant
was charged by Information with one count of Se
cond Degree Murder and one count of
amendment creating
aw was June 9. 2017 That subsection provides:
Immunity from
burden of proof by dear and
Klijr"."11
“»
immunity from criminal prosecution provided in section [776^32(1®]‘ "9 ° °V0rCOme ,he
1
A'2-
Tampering with Evidence,
based on the Defendant
ln,8'an'M0#0n ««•«'» <*s">lss the murder charge,
® kl#ln9 of Davls was justified under Florida1
s “Stand
Section 776.032(1), Florida Slalules. provides In Levant pan:
Your Ground" laws.
9
us?ng?uchforra md“lm™re
ln.'F 776012... Is justified in
such force.... As used i„Tfc"?i .!:,imlnal P^ecutlon... for the use of
Sod™'1"9’dote1"1"9 -led
Section 776.012, Florida Statute
s. provides in relevant part:
necJe®8t>nab^ ‘*3w?8ith!lt tSj ohr?hareantenin° l*® <hadty force if he or
With this subsection does not have a du/v t«8°*dead,y force in accordance
S5"ssSzt
The Court held an evidentiary hearing on March 5“ )n.» ,„
the Defendant could show an entitlement u. i
'
18 *° consider whether
Ground" Motion the Defendant mu
mmunllY. To succeed on a ‘Stand Your
shooting of Davis was In respTeTo 7" ' PreP°nd®rano® * *>® «*•»-.ha, the
prevent finminen, ^77^17“ ^
>° * ®® •»
-0 So,d 766 ,F,a,015);
OCA 2013, (applying objective s.andardT^f^’ 1,1/ " ** ™ ^
s as they
same force as did the
defendant. MBfetey. 132 S„. 3a
,le4.a5 (emphas|8 a
2
A'2*
PS,
In reviewing a Stand Your Ground" Motion, even when there are no other witnesses to
the events besides the Defendant, the court is not required to accept the Defendant's
testimony in support of his Motion as true. See, Leasure v. State 105 So.3d 5, 14 (Fla.
2d DCA 2012). The court may “consider the probability or improbability of the
Defendant's credibility in light of the circumstances established by other evidence." See,
~rtY
State, 223 So. 3d 1023,1025-26 (Fla. 1st DCA 2017). In a motion to dismiss
for immunity under section 776.032. Florida Statutes, "(t]he trial court's factual findings
are entitled to deference and must be supported by competent substantial evidence."
Joseph vt State, 103 So.3d 227, 229 (Fla. 4th DCA 2012). "The trial court's legal
conclusions are reviewed de novo” Id. at 230. State v. Chavers 230 So. 3d 35, 37 (Fla.
4th DCA 2017) A denial of immunity does not preclude a claim of self-defense as an
affirmative defense at trial. State v. Chavers. 230 So. 3d 35, 39 (Fla. 4th DCA
2017)(citations omitted)
FINDINGS OF FACT:
During the evidentiary hearing, the Court heard the testimony of Percy Stucks.
Alphonso Walker, James Small, Detective E. Wells, Detective M. Chizik and the
Associate Medical Examiner. The Court observed the demeanor of the witnesses and
made judgments of credibility. The Court has carefully considered the Defendant's
motion, all the exhibits in evidence [Attached Ex. A], and arguments presented at the
hearing on March 5, 2018 and finds as follows:
The Defendant testified that he had a relationship with Davis that predated her
killing by over a year. He testified he would help her to move and that he would spend
nights with her at her request for her protection. The Defendant went into detail about
Davis’ history of drugs and mental illness and that she had in the past thrown household
items at him and he would leave. He specifically detailed an evening where Davis threw
a vase and vacuum at him and punched him in the mouth. She then pulled a knife and
chased him. He claimed he had heard the next day she was arrested for fighting with
her landlord. He testified Davis got a voluntary commitment to Wekiva Springs where
he visited her numerous times. Despite these incidents, each time he would continue
their relationship. He would continue to go and stay with Davis after class in the
evening.
4-Z
P.5
In late May or early June 2016, the Defendant moved Into a room In Eaverson
Street. Defendant testified Davis asked to move In with him and he refused. On the day
Of the killing, Friday. July 8. 2016, Davis happened to be staying with him. The
Defendant had worked until 4:30 p.m. and arrived home at approximately 5:30 p.m. at
tMifeh time he found Davis impaired. Davis was slurring her speech. He saw a crack
P pe, and a syringe and an argument ensued where Davis threw college text books at
him. hitting him in the
nose and causing it to bleed "hard". He claimed she was
unreasonable and he could not calm her down. She grabbed a regular kitchen knife and
swiped wildly and missed. When she took another swipe he realized she was not going
lo stop, he grabbed for his gun in his bag with both hands, racked the fireamt, and on
her third swipe he pushed her off with his left hand and the gun which was in his right
hand went off. Davis was hit and fell to the ground. The Defendant testified he
put all
t e drug paraphemaiia in a box and left It on the bed. He panicked and fled by driving to
Tallahassee, where he got a room and proceeded to drink
all night. The next day, at
11:00 a.m. he called the landlord, Reverend Walker, (Walker”) and asked'hlm to unlock
the room. From Tallahassee, the Defendant went lo Pensacola where he testified his
truck broke down. The following Monday he returned to Jacksonville, went to the room
and saw the body of Davis with blood everywhere.
During the day he had
meeting with Walker, where he was questioned about
why a woman was in his room and where she went. Later that night he returned to the
scene and proceeded to clean the crime scene and dispose of the body. The Defendant
then fled to Georgia to look for work.
The Defendant was confronted by police in Georgia and he gave an interview
where he was videotaped. During the hearing, the Defendant testified he was Impaired
by drugs and alcohol when he talked to the police on July 12, 2016. Therefore, he did
not remember much of what was said. He did admit on
cross examination that on July
11, 2016 at approximately 2:30 a.m., he went to Walgreens to purchase cleaning
supplies to clean the crime scene; that he used the comforter to
wrap Davis's body; that
he used the rag In the house to move Davis’s body; that he burled her and covered her
with the rug, with leaves and limbs. Defendant specifically denied that Davis
there or paid him rent.
ever lived
A'i
Rs,
The landlord. Reverend Alphonse Walker ("Walker"), testified that he rented the
room to the Defendant and to Davis. He confirmed that Davis lived with the Defendant
n the room at 1322 Eaverson Street. He testified that on July 9,2016 he received a text
from the Defendant "when get a chance can you unlock my room I lost my key". [State
Ex. 1yj Walker continued to detail the conversation back and forth via text where
Defendant alternates between claiming to be
Miami. Th© Defendant
at work, in the Southside area, then In
repeatedly denies knowing what is going on when questioned
why the woman in the room
4h ,.
...
W°nt an8Wer his knock- lstat® Ex. 1z-1dd] Walker testified
a he did not look in the room and never thought for a moment that the person
was
dead. On July 11.2016, Walker went to the mom and saw that the Defendant had
moved hrs clothes, and the woman was not present so he reached out to question the
astir f tWha'W88 ^ °" ^ De'endan'and Walk9r
'°
When
asked specifically what had happened. Defendant continued to deny knowledge of
anything. The next day. Walker wen, to the house, saw the carpet gone and the btood
ha,l on the porch, on the threshotd of die door, and bloody drag marks In the hallway
He called the police. Walker testified, at no lime in his contact with the Defendant from
July 9, 2016 through July 11, 2016,
did the Defendant appear impaired by alcohol or
drugs.
The Court heard the testimony of James Small who was also a tenant in the
home at Eaverson Street. He also confirmed that Davis lived in the room with the
Defendant He further testified thal die Defendant was very protective and possessive
about Davis and all the men knew not to talk to Davis. He testifi
ed about seeing the
Defendant with cleaning gloves, rags and bleach, cleaning blood. He confronted the
Defendant who told him he had argued with Davis because
she wanted to see other
people. The Defendant was trying to convince him to convince Walker not to call the
police and to let the Defendant take care of it. Small testified he did in fact notify the
landlord, who then called the police.
The Court further heard from crime scene technician, Detective Wells, regarding
the scene, the trail of blood, the bloody foot print, the diagram of the room where Davis
was killed, and all the crime scene photos. [State Ex. 1a-1bbb] Significantly, she
testified that there was no evidence of drugs, drug paraphernalia (despite finding the
5
A-2.
as totfie size and dim ^
&^
^
DelecHve Wel,s testified
-
—small confines of the room. Had
Davis swung around three times
as described by the Defendant, in the location
described by the Defendant,
and consistent with the blood location, she would have
knocked
eorgia, the Defendant's
loaded^jivi^ndagun cleaning k„ were recovered front the
hotel room In Goodie.
The Court heard from Detective CM* regarding video surveillance of the
Deaden, purchasing the deanlng supplies In Walgreens a, 2:30 a IsTIL 2,
Detective Chbik
•
“ *
thlrty m,nute conversation with the Defendant,
Detective Chlzik convinced him to come out of the hotel room Th« n r ^ *
videotaped interview which the Court viewed which was in,
^*
roduced in evidence. [State's
Eh. 3] The Defendant
was mirandized and asked regarding the events in question.
Detective Chizik testified the Defend
Furtho. ,k „
W3S n0t impaired and he dld not smell of
alcohol.
rther, the Court made observations of the Defendant's d
emeanor during the
interview and noted that the Defends
nt did not appear Impaired. Upon being questioned
the Defendant told detectives he had i
nnyming. He admitted in the
ZT "" n°'
rent. He stated they lived together and that at
with him and was paying him
one point he had been the one to move
out. The Defendant told the detectives Initially that
on that Friday, they had argued
because
, Davis
. had said she met someone else and ha could leave. The Defendant In
MVS f.rs. vers,on claimed he grabbed his stuff and left going to Pensacola. He claimed
80 hS
WS ,andl°rd'°Ch6Ck°n hiS room a"d h's landlord told him
him Wh8 h8 °n ,he 9r0U"d' Th8 De,endan' Sa'd he th°U9h' Da™ ««• s«i„ mad a.
him. When he came bach to the room on Sunday, he saw the blood, grabbed his I*
n left again. The Court notes that the Defendant did not talk about Davis being violent
or on drugs. It was actually the detective who first mentioned th
drugs. For most of the Interview, the Defendant denie
e victim's drinking and
s any knowledge of what
A
✓
e.s.
happened. He claimed he always had great respect for Davis and that she was the first
person to make him kiss. The Defendant then invokes his right to counsel but after
some time reinitiates contact with police and agrees to talk. Finally, the Defendant
states Davis was mad at him because he was always working and she wanted him to
spend more time with her; that she had other people who wanted to spend time with
her. He said she had a temper and had "spells". That she had been drinking and
grabbed a Kitchen Knife. He told detectives he told her he had a gun and to calm down.
Then he fired a shot to get her off. He admitted that Davis never tried to stab him; that
she was just holding up the knife. He stated that Davis never took him seriously and
never respect nothing I did". He stated it was around three minutes from the time she
grabbed the knife to when he shot her. After the shooting, he stated he panicked
, took
her clothes, the knife and left. Subsequently, he admitted cleaning the
room and
disposing of her body. The Court further observed photos of the Defendant taken by
detectives. There are no injuries to his hands, his arms or significantly to his face.
The Court observed the surveillance video of the Defendant in Walgreens on July
11, 2016 at 2:26 a.m. purchasing the cleaning items which he used to clean the crime
scene. The Court notes the entire transaction takes approximately three minutes.
The
Defendant brings items to the counter and, by all appearances, punches in his phone
number or rewards number then pays in cash. He goes back to buy garbage bags and
once again punches in his phone number or Walgreens card number and pays again in
cash. At no point in the video does the Defendant appear impaired, frightened, and
despondent or any of the other emotions to which he testified.
The associate medical examiner testified regarding the autopsy. Davis was killed
by a gunshot wound to the back of the head. The path of the bullet was back to front
and left to right and upwards. Due to the decomposition, he could not testify regarding
the distance from the shooter. Tissue samples were tested and the liver came back
positive for very low concentrations of alcohol and marijuana. Due to decomposition, the
results and the levels are not reliable. There was no cocaine in the body.
A'2-
\
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IN THE CIRCUIT/COUNTY COURT OF THE l“flU /’4'U
JUDICIAL CIRCUIT
IN AND FOR
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CLERK’S DETERMINATION
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Thla form
APPLICANTS FO
not Indigent.
was completed with the assistance of
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5.
EVIDENCE 11ST
STATE V, PERCY STUCifc
l82016CFfi391
ID
evidence
EVID#
photographs
A1
Photo of blue house on Eaverson St
A2
Still photo of Defendant
A3
1a
coming in door of Walgreens
1b
1c
A4
jMphoto, profile of Defendant In
A5
Photo of wooded area at night
1d
A6
3h°to of trash, carpet
1e
A7
Photo, close-up of trash,
1f
~
A8
carpet
Photo, close-up of trash andcarpet from
A9
photo of carpet being remove
1h
A10
Photo of foot, bedspread
11
A11
Photo of deceased victim
A12
Photo of Defendant, taken July 12-13
other angle
covering body
A13
Photo of Defendant’s right hand
A14
Photo of Defendant's left hand
A16
Photo of Defendant’s right arm
A16
3hoto of Defendant's left arm
A17
Photo of Defendant's chin
A18
Photo of Defendant’s right side of face
A19
Photo of Defendant's left side of face
A20
3hoto of front porch
A21 JPhoto of hallway of blue house
Ik
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f?r,
ID
EVIDENCE
EVID#
A22
Photo of bathroom
A23
Photo of hallway, blood spots marked
A24
Photo of hallway, evidence placards 1-7
A25A36
Photos of Cell phone with text messages
A36
Diagram of house and street
A37
I Diagram of house
A38
Photo of boot print, Ev. 5
A39
Photo of receipt on bathroom floor
A40
Photo of Receipt from Walgreens
A41
Photo, close-up of Walgreens receipt
A42
Photo of bedroom from door
A43
Photo of floor to entrance of bedroom
A44
Photo of bed
A45
Photo of dresser with bleach bottle
A46
Photo of chair with box of garbage bags
A47
I Photo of bucket with dirty Brillo pads
A48
Photo of floor, coagulated blood
A49
Photo of floor, coagulated blood (Duplicate/mistake)
A50
Photo of large knife under bed
A51
Photo from hotel, gun cleaning kit and laptop bag
A52
Photo, close-up of laptop bag contents
AS3
Photo of gun
A54
Photo of swab from gun
A55
ME Photo: gunshot wound to back of head
A56
| ME Photo: close-up of gunshot wound to back of head
1v
1w
1)C
•fly-ill
1Jl
1kk
111
1mm
1nn
1oo
1pp
1qq
1rr
1S8
~
lit
1uu
1vv
1ww
1xx
1yy
1zz
~
1aaa
Ibbb
1ccc
Iddd
A-2~
P.S,
ID
A57
_
EVIDENCE
-E_Photo: $calP amoved to show bullet In he
EVOD#
ad
H©©e
physical evidence
B
Video surveillance from Walgre
C
Defendant's interview DVD
D
ens
2
3
E
F
G
H
I
J
K
L
N
O
P
Q
R
S
j
A-2.
•• I
P.s.
CONCLUSIONS:
.
totality of the testimonial „„H „„
Jhe Court, the Court finds the DefendL ^
-.
L lysjcal evidence presented to
this burden. At best, the
aiwlA
. ,
--------------------_ s, however, that th e evidence is beyond clear
iSteigciggtoaupportlhochamao.^^
I'l'IULWWiUJWWJ*
- sr- The Defendant's
ey appear to
bodily harm.
explanation for this point of entry la lotallv i
or great
of the head and the Defendant's
that she was In th
e to raise
Accordingly, it is hereby ORDERED
and ADJUDGED that Defendant's Motion t»
.-BiiHli&s is DENIED1
DONS in Chambers at Jacksonville Duval C
j^^^Fjgnd^ this i5f/l of March.
2018.
Circuit Judge
Copies to:
Office of the State Attorney
Division CR-B
Nah-deh Simmons, Esquire
Attorney for Defendant
A-2,
exhibit **M
■J.
Q
^h
New Felc
ssssar*
°y'March l3’2008to Frid»y. March 14,2008
new felony d
EFENDER PROGRAM
A PRACTICAL GUIDE TO
RRADY MOTIONS:
Getting What You Want
Getting What You Need
Ira Mickenberg
6 Saratoga Circle
?sT«!°c8o SprinBs’ NY 12866
(518) 583-6730
FAX (518) 583-6731
iramickrMdnetattjjet
4 :?
fiz,
R
a
4
UBB£Baau2MSF
discovery
--------------- ZL.
------- tuia rtl jPrnnrr mii..........
3ESsWHBHS*“
rootionsand
In practice ^irtuvn
5g^^™l^^ggSi
Not onlv i
rejudicl
., jpducin
| a<>”» rise
-Open tile” rfl.7
gry.
The practi,
man laces tw u
■gone " Many j,X
Ji
g round.
of an
hgthatwm.tdj ieJi
featn
______ ete tvii
igceofcv.,1.---- n«»
[0
lit it) is
Ithe rosecutnr
gr inada
rf ;■
^gEsaJisldMco^K,
le
iSJtisgond
Stoma jvayofdn.-,
grevenu,,^
ecause
“
llnfy *i
en
S' it —
imetl
S alwa|/P Kgen
gust be *^rnpy rrn
UL^mgKier v. n!zi
iroi
U.S. a
™^gEgijJjedS
obi/
■^°n lo furn overIn
exci
Regardless of vyhnt »• *
lorts,
283
k
i
nv flui/>..^n 'substimtJ ^7
jurauant f» D-ld^
it
ttmLflg_fonpt ?T
"'nrf
tiin iiniii I,
SsSlsSSrasaasa---
1
II. THE DIFFERENCE BETWEEN DISCOVERY AND BRADY
It is important to distinguisnbetween ftltind of discovery we are entitled to u"^state
turn
and local statutes. ruleB and customs, and the
over to'tKedefense all exculpatory evldence(HradY material^
. i
;« '
Every state is free under the Cbhstitution to establish whatever discovery rules it wants.
..El?jSiv'Znv no discovery at all. For example, New Yorkdo.snotcventequ.re
the State to give defense counsel a witness list. This (toes not vtoWe the CwjhMr vO*»
statesrequirejQtaUdiacoveryyForexMpple.Ttor^a^yMfeejtofCT^eMi^ftbsotote^B^^^^
swom daposition of all prOsecution^vitn
V
gP^ ^
^ including North Carolina
state dealswith discovery.
.
U'j* ifi-
the
inor
♦hmUvnne asnectof discove
(f. K *<'
1—4 ifTHT ft
K
Bra<t«Y,;iMflP/
..
’Mar y-1'-'
Greene. SjlTUA2ft»9ML....
r
;
r.>vv >■'
evidence the State must turn oygrjs ‘Ififfid
The generic term applied to the excubatoi
material”, , . i,
■
<•.
■ {Cr- s;
■
'-
, J"
1-
f
m '.mATlsHpXnVMATERlAL?
■■i
‘ •-
f
; -
i
Brady says that the prosecution must disclose any informatiou or material that is:
t
♦
A. Material (and)
' ♦
B_ Relevant to guilt or punishment. (and)
♦ *
+
C Favorable to the accused, (and) ,■ •
V> • •
i- ‘
W*
D. Within the actual pr constructive knowledge or possession of anyone
acting on behalf of the State.
•.V' \.
r
V
'■
individually, to get adear idea of exactly
It is helpful to examine eaehof these foctors utd
what kind of material tltti S^ite is required to turn over.
t
2
i
05.
------ AT DO WR MFAN RV
■
I
—Materiality in |i,.
" ;
.
Manvcourfg
™vioU"
^&^BBSSSSEmmr“icttonreveirsf |
roceedi
irol
______jaa^wp^1
mMfc
MWhethi
Igre was a rqasnnwhiT
bggn turned Qv^
LO*
iHififlavo oeendifferent/fti !g exculpatory mn»«^n| i"'1.
^st
;
•V*rH,
. .
v 'C-.‘..:■■■ 'i.
jlis-.i-.i.r
.
t
thit tiiistii !*»‘J u':-:
: rt
• 'i
'ffinUfeaPPrODriate
guide for
adhered to the
ovar anything that ‘ia*^
defense V'T,
• .;
W'.
u^tSeagiMijiia
iTSSSato :Qr tavoimblfl tn tu. t, -r
-/
fepflheoyieatifTf
----------- to'taarn-
•;
r
”*•
^^-^.-wSgSSSS^*
£-J^s^AyoSABLETnT„D
*4
II
Hflcem o/tL
jhS,?crHMd” find:
tsiS
ofRnirft/
r
IS
[gcution hi
*.....::
^
iiaimjgsg' flnnll,1lBm«kUi^^
that
ngpentcftheclim jga.... or
*
— may mitigate sentence;:
.. m
Jft can he hi
jir'"
aaft&ai -:„■
pendant is
s..-,
w‘..- •.
>
Ittlggachastate'
evident m„„* «|gjymc
i!g-innocenr!w
Again, iit is u goadidea to look at e
^ngnsrr^;J^ figg*****cchof^^eriaSdlvId^^
»•.
iJoubt nn
las
I l<:
■
A'3
C-l. WHAT DO WE MEAN BY “ IS EXCULPATORY?"
The most important tiding to underetand about the term “is exculpatory,” is that it is not
limited to things that prove the defendant did not commit the crime. Rather, it includes any
information or material that njiight lead the jury to conclude that the defendant should be found
not guilty of any of the crimep charged, .
'
’'r
’
-i • ‘
One constructive ^ay] of analyzing whether; something “is exculpatory” is to look at the
different general categories (or genres) of defenses in criminal cases, and ask ourselves whether
the evidence we want to discover helps establish any of those categories. These genres (within
whichstalest all defenses fit) are as. fallows:
•
•
•' ‘
-
"
■ ■
' r
•
••
■
■
•
1-:-W
1.
4.
5.
The drimtpaiact dccurredjbut the defendant was hof the one who did it. (Alibi,
for.example) v,v;
■■ •
-v ' ■; ■ ■
..
The criminal act occurred. the defendaiit committed it but itWasn’t legally a
crime. (Self-defense, for example)
The criminal act occurred, the defendant committed it, but it wasn’t the crime
charged. (Le iser included,pffcnse, for.example). ,
The criminal lact occurred, the defendant committed it, but he was not legally
responsible. (Insanity, for example)
r
Any material that mi ght help to establish any of these categories is Brady material, and
must be disclosed. foidieovto,it doesn’t matier whether the defendant has committed to raising a
defense with that information. As long as the material would help to establish a defense, it must
be turned over, and it is for the defense lawyer to determine whether and how he or she wishes to
use it.
"....
1
;
......
Along the same linei, any material that is inconsistent with the prosecutor’s theory of the
is
Bradv
material, rega rdless of whether arid how defense counsel is going to use that
case
material.
Due process also requires disclosure of anv evidenciLlhaLPtoyidg8_gro^^
defense to jjttflckdhfi-tslififei lift.
410.
ie del
n.fOT45Kim
1- ? •*
To sum up:
Any ma^rjnl that helps the defense attackthe reliability, thoroughness, or Rood
Sdfl. nf [haUlico investigation is discoverable undor Bradv. This is a torrififidl
bw inconsistent bchavj ir statements
Fpol
for prvim
:i nation.
rotocol^fo
—and generalBatoppincss tn mvesugaun^
fTI' !M4. \ i * m»)»»...
J (T .ailing to follow IfifldH Iff
""mve8tlgate1anytoing,that wouldnUhelp.convict your client. It is also very usefiij
4
)
fi5,
given witacMraa’Svolo’l'io'in"™^*”'”'
“,hcr orim« that may have
your client.
10 to in
om-« Siven the police a motive to fame
Even if something v.«/»..ivi n.
PtBrad
’’ ••
__»
be given all favorabl e
way.
A
IMt bc disclnsfftt i ^
d>,finif'0
Braga
t
*•*
■Even if the iroaeoutor thinks thi
k -
I,.
• '-J'
.t.i
1 >
BlJidV tnatR^^i tn ?m)
ijeoralienii
f#
ifense com
whether the Btift - •»
t|
|e
enough
/
flat ie other
For fit ‘ tLL
WhbcbhfaBBaH ascii
■flndunbBliev«-n^^dn^ nof ttz ise
Jhe prosecutii n tmm?ha~ Ilia a^ooBw
-X>
and Ins comession."
•*»
i
* ■*. -
i’Is
5?
l.\*“
-'i'r 7;
iV.-
f
C-2.
i
iWi-' vs
I-*
■ ‘
- formation or material
*
*”
,
' '-MV :-V
: •
■ 'M ^S^lfl^ais^Porto aWv ermiihohi vmi Z2;
'•'T
••
i
— >7- :•, .
less-than.wnyim.,^ni^'(^~^B>BSMtgLiajnake at Ee»ter,™ t«»
■
sentencing.
■■ .
■
Htaiini.
■
.•??.
V tvt"
,M
Jt,. .
^Anything the coiirt«in
be amitiotuinc factorat
e;mlici
Ld that i ■j
.—«£UiliSi£va?liiP sentence
C-3.
!j,y.
'll*.- •
?• •'
STATR-n wrtUi.f
, <•
Anything that jf aagistentwrithth^,
{[(ggnjNofaStately^
_ include prior stat™
yurce that i.Tiicnn.SjlgSHWll!lci“ Wanv oilier inrJSg}} p. This rr^ipfrt
from any other
e witness *3~testim6nT
i i5
►
State’s witness.
T
— V—.. H..
3
/4-3
(- *
testified to. This covers the very common situation where a State’s witness at trial
“remembers" for the first timeJhatl imnfflnrrrmWrW.n/rs.n m.iir sa^he,
_
, witness has such a miraculous rbcmamtLmemigy, any prior statements the, ~~
witness made that did-not include the alleged confession become Brady material,
and must be turned over immediately.
-i
D. WHAT IS “WITHIN THE KNOWLEDGE OR POSSESSION OF ANYONE ACTING ON
BEHALF OF THE STATB7"
• * ■!
_ The important thing torecoenize about this-temiirementihr Rradv material is that it is not
limitetTto things that are within the actual knowledge or possession of the individual pmsecu^nr
Zon the case. Airo^the|ollowinig areii»eluded: '!’
o
Q
□
..... r's'mmm^- *■: .•'Xu, it*; Anything hnhiallVlfnnwn to nr in the nossessidh of anyone in the prosecutor’s
f
-office.
i
Anything actually known to or in the possession of the police, even if the
prosecutor doesirTIcn^^SSSiii^^
O!
Anything actually known to or in the po isaiondf ___
theState.evenifthe prosecutor doesnt lowabOflt it.
of
Thw pmBPifiiitftr jn thRrpifnre nrnhUij^fl f^-pniljid'nP behjiid foe akf.iiHR thnt *‘I didn’t know
ahnnt that » If the Material waBWithlhthbkhowlcdge or possession of atfynhe Working nn-hehalf
nf thenrosecution. the State is considered to have constructive Knowledge or possession of that
material, and must obtain and turn it over to the defense pursuant to,grady. I
at the
the U S. Sum
les v.W
Even better, i
ot^er‘peopfe1'amfa^incfcs^Uri^orfth^{^vernment^9 behalfon theca^includ i n& thepoUcj?.
i.
t
i
;•
t*
II: USING YOUNGBLOOD v. WEST VIRGINIA,
II.S.
. 126 S.Ct. 2188 (2006)
*•
A WHAT IS YOUNGBLOOD?
Youngblood is the latest pronouncement of the U.S. Supreme Court on Brady/Kyjeg
issues. In addition to reaffirming the rulings in Brady and Kytes. it explicitly orders the West
Virginia courts to stop avoiding some of the most important provisions of Brady and Kyles.
Thus it can be cited for the proposition that state couri efforts to dilute the due process
protections concerning disclosure of exculpatory evidence by casting them in terms of state
evidentiary law will not l»e tolerated.
2.
Vminablood involved a defendant accused of abducting three teenaged girls and sexually^
assaulting one of them. His defense was consent. After he was convicted and sentenced to 26-60
years in prison, a defense investigator discovered that the “victims" had written a letter bragging
i
6
‘
'.
‘
A police
th®P°rson who had
convicted. Consequeiit^ ^ho hir 86 ^ noyw told a^t tlwfletter
11,0
*ri«l oouit aJso'lSd Itanf ^*1 be”"'«l<1dai^ ,hc F®‘i,i011. holding
•--^ittsssas^Sgeasai
ourt of Appeals by a 3-2 y.M." ~fr. <k1h tl,:bC1** v.\!j npp^liiti tt, ,v...;. -;:: ■'. - .;■
dims, but merely beld that rt,^, ^™8'1-'The "'■‘jWtydid
Supreme.<? ST'.'
««d that there was . j^SSEJ*-*«Mabu&t, ^0^T*®'
iL THE Horn--------g^QMQBLOOn
K
\>
, /HieU.S. Supreme(2™,,*
^ 1 :y:;,
W«“i;L ..
,0,i0Wfte:;;.
;-s; ,-•., ^S^WWtfindmgs, R„d ordered the
/ • it*
Wmsm*
" tbV W?s1i/
•
m, ? '
> •.* V . t * *>'* v>i» v& ■*'. r ?*••
V. w .»•.
is com mli . I i ■ Cf0>M. ............... ......ul
‘ •
"2&*inf< •> ,'•?!: .it
e wi
Mniincludin
SS.
even, if» ie ifl&££ssessmnof
•;
jgfossdfoven irihM:^
• •.»
i
•
>«gfe
1
he. rosecutor has an
>.•«
material in th„ — apa8‘on °*flnyono elseB IS^edc out and ■;... .,.
-»ie Doling. **"
,;
-
*•
'
•
Of
..*
!■■ ,'•!
..vf I
•?..:V
' »•< •
•,■••■-.
.
t
' A
1IL. What must u/p pn
3MEIBRAH. frrT , rfTTU7
i :
■
"i'Kf.s,.
•
.
*-• <
tailoring our demand to the fachii|r0SeSUt,0n to wease* out of its oblhath h°™ore general our.
•"•“-■■•iSSSssssdSBW^
■^■iaaaraaagMjjgji
,
>
. v \J',r ’;.'-.'i-. ■',••;■'•
,
4 i.
7
4-3
about the individual case to make our demand specific. At the very least, this means that we
should include facts in our demand that refer to:
✓
TheprosecUtimnwitnesse^^vara^nfonnatioi^bout. Forexample^
/
“AnyandainnfomjgJionbearin^ondietnithfiilneBgjbad^haracte^tJ^ad
"M"nt^mwifState*swSta(MsTotoS5i|lEnn55slB&i2UlJM^ilPitefLte:
rei
f^mmSTeteju^nilojgcor^anycgiitgmB^
complete adult enmma
_
_
nst
fhe
yyitness;
aay past instanceajofdigl^gflgg^,
cifanonsissuoii
^JraudJ^ij^^iolenceot^diejjcut^f^MWitngg^liBtJfiJSIUUfiUiLlflLibL6
State or its agents; any iiistoryofrncntaljllness
The specific documents or at »™™t the kind of documental we want to get. Fo
^example;
!
/
- i
..............
.
::“t
V
:
neimej. addresl an^Mf^ ^
iy
»
^ >■'<thajrobbervj^i^nwa|thaga'Wi^Vk :
_______ wetnesswhoetan^dme
HSftt'afl tiie person who committed
jnrt ai^yffi^urts that mention in any
yiM•4denMW'flf'nmeone other.
I 1.-1
tjjttJ
.am tuple .SRtetHhftt fe.-aj
mhhprv ermroed In this case; any BlhUJl reports thatmention in any wa^
tr:> " Lhn J?1"Whether named or unnamed, stated;that tne oeienoanv wy
tL n"«nn whoCommitted the robbery charged in this case,"
/
The specific evidence we think may be out them that fits within Tirade ,for
'^gjuuaple: j
✓
I i
;s
[ft
■5
raw data >mnnj»hich those test results W£ff
""base^S* ^dicate that the defendant was not the
Wl» V9mnIU^i.ed
jMyft,H^gnpksSjbuUiotbe
crimes charge . This request is intend
rnnuiogftttSEF;inE. serology testma. tinpemrtnt
limited to ^11 bloc
testing- hair sample testing.
!
✓
;■
•
vnu "r" aBifiinig frin vour motiop use the phrase
e
tg:' hnt not limited to” »" a way of preventing the court or the proqgcutor
yolpinnecessanl^lmitedttie^ope ofyoigrejuegt.
fromclatming
;•
iecific demands for Bradv material, we have to do several things before
In order tomakel sp
writing the motion:
!
nos aihle to think of things that mav be_
✓
Knowymirthcao hlven't fimired out what
our defense is.
ts '5'
8
:*
i
a
I&
p.s
✓
V
I
;
Investigate, Q
iLwill be inipAuntUjp tn
motion pBnnrn arm fj||
filfiteat i investi paf ifln before
le
ow
,3Pai™S==5attiiSBroearnm■Ul4£gurcase.
-$B8£;.
r
ore about th»
—SPiigw up on what*
■■flflfljflen malceriAip.
i
;
:V
11 0
jgate it.
OUT follow-U
%■:
i > .
l.
.•••>.;
■
•i
B. ■\5aimXO,DEMANB BPADY MATPP,,,
•>
•. *•
■
?
l.** 1
A
I
.■ru-'W'V ■/,; i'
. r%>/
-Xhft Rr«H'
is not ii
IS]
!on has.pn nncA-. -nmi
fana)
av ti"d if
"S»XVV
ian,
*
,
^ion the pm
o
IS
e Author?,tv nf Btta?
_.-----
rid
*. %
tw
■
r-
*, •
(■
r
-•
•i
*.■
-loecase.
'•l V‘0* > o.-cvn .. V
':•» >. *• ; •::: yrr/ >--Tv * V^^ft^triai’inotinn.'* r
:!
';■>
Z » ?/‘l
>• •
doing Ihrouphn.,,
nr ■
.•tf
•t
♦
iUSLfetrialbegii
•*
i
IfflL&racfrujvriw *ui
1
V " that mav he in
t
■
j .j
-■ — •- lpPmsecutorhas njattiiythe^ur^
' v- -■
.*• ■
•-••
-—r*
•v.\
xaniination,,. „v.
I,
J.
g*
-mu^aye..
.... —■"
Sleoritradicfai ih«;i
■“■■
• • ?
♦
■**
SSUiEjerosecutor’a doping - for
?.' '
«,
ig„gureUie
ilfi2222ithewitness
for fe after his or her
}
♦
*%
r
.
•
;.
ik
! >.-i 'h\y
. /,
•
.;
Lsentennin "”***-■ *-Tpl.i.„c
Jlttoaau........
i
t
anything lh„, wn„M
• -U. t:
Jn your pre-trial mnti.,..» H„„
>... . .
writing and to pel tin ........ I , an nnnrro WntTnr'1f1j| il ill ini| ortant.td nm^ ihe motion in
QTfifah Jfi Writing.
.■r
;v •-;• ^ .( • * .*i -,.i *V t- .
When you make Brad
fappiicaiionsfiiirin» tnal. be mit^to mnlcp ^0^
on the record,
1 --'i.
9
**r‘
c..
fl'3
iTwe^ita^wearemedywhcnwediscover ri^bntihnater^^T|^_StateJiedjbout_goinething.
“
v - •/ I,
C. BRADY DURING POST-CONVICTION
When Bradv material turns up after a defendant has been convicted and sentenced, a state
post-conviction or habeas corpus petition is usually the appropriate way to raise the issue. This is
standard practice. But what can be done when the Brady material is discovered after the
defendant has not only been convicted, but lost his or her appeal, and lost a post-conviction case?
In 'such cases, rthere: are hSually-serious procedural problems with filing a second, or successor
habeas. ; In particular, the defendant must shoVrCaUsfe why he did hot raise the claim in his first
petitiori; and actual pfejiidice' from the Violatidnt^
in^Wvn^n7T1|i?fl noq^-lim 1Q4Q (1 QQQ'l the 1 J.S. Suhisms.
fendnnt fries a successor hab<™ "tutor Bradv. if he proves that the Slate
witMiwitiaviflence. that will constitute cause for not presenting the claim earlier^—
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................................................................................
It is essential that we take advantage of this law by:
s
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P amninihi vigilantitieconoealed Bradv material even after conviction.
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IV P^miTHSiaTHR PI tOSEGUTOU’S ARGUMENTS "•
1TSTNO KYLES v. WHf T.RV- S14 U S. 410-115 SCt 1555 09951
Tha most significant Bradv case of the nast 30 years has hren KvlfilLY. WhitiS^jl&gr
aiQ (1995), The importance of Kyles, lies in the fact
to avoid
feregSS y vi°ffij"^lt is therefore essential that we become famiharjvithj^les,
and use it at every oppoi
The following ii» tint efmany tulinae f—■ **-
- WM in ^nR COMB™
esulted in ai
Materiality. The State_/y[gue8jthatiithei Withheld Material
Acouii
I
rvj*n
iij net ufetl&ttii defendant would mote likely than not have received a
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lltBl on fl nrim;.n|
eneewas
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ulpato: evil
tilitv of
^hetouchst^”
Uijfficiencyofeyii
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ialitv: ThP nnT1
Bee Wasn’t tm- ortant"
ESI
£gl_of Post-P1gnviclinn ,■...
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........... -j ,
Kyles: Th* mo o
rnme Court /jubopats that
"fihilftgjjuniCTtat
meeounsrfi^, (r)M,r .(
Eg-ShowtBnl
SJSdSSSSJS'ggvei important.
the prosecuti Is
Kyles. fornyanTpUJH: iSJUmcct Latter rif
amibt on
prose
loility an ooservationa
ddence that, it
hasn’t mn»w|a| "i
underBra
ecause_______
i&^earguedthat
m
illiTiTi
withheli
antandhich
ibnaty was material
jefa-error review^
me
»lt
i HfHn’t Know
Ifing ciosinp
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si me witnasaoB vvere
JLgtiuim imjj<»ntjQn Lp.
™£' I*”*"'1'
•t
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Told Me
3M£rosecutorSa: s. “
Failed tn rn-..
i£ioge_Wouid Have Chan
li
!gd the Jury’s
A'b
j^X!£^^£3^|^gg^QUlSflUlIS^S^S£iS8J20flliSB&Dd&DyBB^Q&l[iydecisioiis**foreacl^|Q(luuduflL
.pisegjof infonriatififl>wilh^ig^^JRather^trenuires-“^cm^^^|y^g‘^fl^|j[fl^jjQ^j^^^^^^jp^
the level of Brady materiality.
Finally. Kyles determined that the following kind of information is all Bradv material that
mustbedisdggfitL—,
:
? -
✓
►
/"
►
Jnconsisj^^de^^tioQg^b^jfiejjgi^jjQggg^ofdi^crinyQal.
. Inconsistent descriptionsJiyili£EBi£iiLMdtnes&qajoXllie^crirne^.
The fact thfrt someJif the witness’s descriptions of the criminal matched the police
informant I
That there wgjgjgendinecharKesacaing^tjygylij^jnlbr^^
That there \Sv
ion
■v x'.*
✓
►
►
crimes.
-That the police informant made inconsistent statements to the police about the
►
v»
►
llth”rffn1iM ^vpi pn^|^ ^j» finppir ^ fjnrnpiflppi nthfir {frfin the
defendant. I '
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►
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►
►
!!
JQ)gyjg^^^cUGan^|Sjj^£yiidflllfcJ2Q^£jSi&witnesae^{gjyousl^Said^{udsl}g
-had not acti ally seen the C|ripe
ame SMS
rrcsnanr;
<^g^^22SiiS3EfiS5SML»S£iDifiJDi^BtihS^ffi2jii2L!2fifi
ors^
.jyj^jjyjewitoesstestifie^at^^^mBorhn^
,
ThaLajadtn^ss’s prIorstatementsomi^iRn|ngaS2SaUaJMlfacts thatthewitnggs
_remembered^jit triaL.
~
-That a witntjss’s trial testimony omittedsignificant details or facts that the witness
•jugfljjgnedjj ijrigr^tajgjflgjjts.
That a witne ssor informant made 8tatWTT0J ts that incriminated himself in the
jy^jj^cljargj^gainsnh^e|gjjj|giii.
Please read Kvles b< ifore making your next Bradv demand.
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P^rcy St^ksTsuTpect)6nt r6qUeSt f°rm t£> T-Mobile- requesting location and phone records for the cell phone of
above phone*tomy emaT* SP°Ke WUh Mega"' Who advised ‘hat she will send information in reference to the
stationary^"aH^re^cotti^h^nn^TsOB fhghway IT),™ T'M°bile>n Ric^onZZTeo?^
"" suspect's phone was
.. „ru.9s from a yellow house, which is next door to thie^fi8 Smoke • The witness stated that "Smoke" sells
,0
Pollcc, The WI,„MS stated ,hav
~ uc^
Analysis Unit). I requested*IhaHhe'abovl MormsdStbem81' r*Jelvod ,rom T-Moblle to c. Rivera (Crime
the suspect spoke with.
* ,nforma‘'°n be mapped and an attempt made to identic people that
1800: I received the above information and forwarded it to Det
ective Edwards for follow-up investigation.
Note:
SDeakSh H
ThG suspect
speak with us in reference to this incident.
*
S
tt
made contact w,‘h the suspect at the
d me to the Richmond Hills Police Station and
interviewed. When we returned the suspect asked me if 1 ‘r°cm and ‘hen back to the room where ho was
suspect that he requested to speak with an attornev and
d 8 }down and ‘a,k ‘o him. I explained to the
told me that he did not want to look rke a monslTr snd l’ i ‘! C?1''d„n.°'speak »"h h"" nnymore. The susneot
suspect again stated that he understood and sinned rhi>nSti!,t*Ut ?na R flhts bV a standard rights form The
continued the interview In referen^e to thfs incISent
r'9 * ^ atWhich time Dete^ Sco« and I
R^oX^
in this case. Rater to De.ee,iva Scotfs Supplement
CASE STATUS
Cleared by Arrest, over 18, by Detective.
Ch-unmiv Si,inn: CASE NOT CLEARFfl'
I ...r *,* tw
------ -------------------- —-----------
CASE NOT CLEARED (DETFCTmo
CRIME ANALYSIS
^'CABLE I>mr cnti’ »„v 1 Inn;;/
Xitmhrr „t ( Vnvv (inn;;/
--------------------- ----------- ---------- 1
•'I.IW/Y/IY/WAs<s,mlt/\lunlur. ARGUMENT
i'yi>roni\’„/,,m: HANDGUN (DISCHARGED!
/■<»■<r,l Entry NOT APPLICABLE
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Struriinv Ocai/wiur Code:
Vnmhir oj Premium EiiMvi!:
NOT APPLICABLE
imviimi t\/i,-. Residence-Home
Incident Occurred Inside this Location
In,idem U< mi red in ,!„■
.\uiHnor 0/ Arrested.
Xnmhr of l Wi/r/rv ttrnnvr..;/.
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MISCELLANEOUS:
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/},(/(■ Printed A' ,i .'Hit,
No
....... N°
// .V« tv 11 tinniestn- Re/,lied NO
■hr there othrr Perlhent Re/mns No
MIKE WILLIAMS, SHERIFF
2016 dy.iS 75
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From: Rivera, Coralys
Sent: Tuesday, July 12, 2016 5:25 PM
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Disposition:
Blanket Bond:
VOP/FTA ONLY
Oii)*imil SLitute Art;
l>rpree
I'('ft CotIf
Attempt (\ulr: Commit
Deu upturn
ADDITIONAL INFORMATION 1
*•/»««*
D.K.SCOTT 7714
On 07-12-16, the Jacksonville Sheriffs Office responded to suspicious circumstances at 1322 Eaverson street.
What appeared to be bloody footprints were located leaving the room that the defendant rents leading out the
front door. What appeared to be blood drops were located at the threshold of the front door, as well as on the
front porch and the steps leading up to the front porch.
A search warrant was obtained for the room that the defendant rents inside the residence. Blood was located
inside of the room the defendant rents.
On 07-12-16,1 made contact with the defendant at 3888 Hwy. 17 Richmond Hills, GA. (Scottish Inn). The
defendant agreed to be transported to the Richmond Hills Police Department to speak with me further.
Post Miranda, the defendant advised that on Friday, 07-08-16 the victim (Dorelle Davis) and he got Into an
argument while Inside the room he rents. He advised that he shot the victim In the head and then fled to
Pensacola, Florida. The defendant stated that he returned to the house on Sunday, 07-10-16, loaded the victim
into the back of his sport utility vehicle, and dumped her In a field near the Intersection of West 26th Street and
Spring Grove Avenue.
The area of West 26th Street and Spring Grove Avenue was searched, and the victim was recovered in a field in
the 3600 Block of Spring Grove Avenue.
On 07-13-16. the Medical Examiner's Office conducted the victim's autopsy. The manner of death was ruled a
homicide, and the cause of death was determined to be a gunshot wound'to the head.
On 07-19-16, the defendant was transported to Duval County, Florida and booked into the Pre-trial Detention
Facility.
TniiHi’niictl H\: D.K.SCOTT #7714
Anritinn O/lii frt\l til D.K.SCOTT #7714
Ai’i’i'iniiin Siti’m tun R.A.JOHN
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nt tuni i *
t ....c ti. in thfi. • •
l>m l\r,' NOT APPLICABLE
nniK tMumi. UNKNOWN (OR N/A)
Unit; Arinin NOT APPLICABLE
Mi nhiil Rel,il,;l: UNKNOWN (OR N/A)
VICTIM: #1 iMi.i„,inh„> 1,1 Sin,,,, '. BOY/ GIRL FRIEND (Not Domestic. Viol)
/<■„•, . WHITE Kill,,,, in. NOT OF HISPANIC ORIGIN
Vi'.v. Female
__
/«>« 7/30/1976
Af>e: 39
Niiim1' DAVIS DORELLE D
Suh St'ftnr D/13
Adtlreu: 1322 EAVERSON ST Aih/I.iii ti.
Cnv: JACKSONVILLE Sum- FLORIDA Xi,». 32209
In: 120 ('rnwUiTri.
limin' I'll,ini’ ti liny Plume ti I’llnut' I'.xt
('i'll I’ll nil,'ti
l.'i'll I’ll,,nr I’rtnitlir
l\;n,nl
ADLT
SU CKS 1‘1'MCr Al l liN IK
ARREST REPORT
i\2 -t I
Jnil # 2IIIMIH77*
ADLT
A' Q>
Route To:
k£0UCIi
Intelligence
455998
461563
Jacksonville Sheriff's Office
Evidence Report
Year: 2016 Incident No. 453875 Sup No. 2
Incident Information
Report Completed by. ET
Date/Time Assigned: 00:00
Date/Time Arrived: 00:00
Location ofIncident: 1322 EAVERSON ST
Date/Time Completed: 00:00
Apt./Lot #•
City JACKSONVILLE state: FLORIDA Zip 32209
Taz: 120 Crossstreet:
Sub-Sector: M3
Same As Victim?
Type ofincident: Death Investigation/Undetermined
Scene Information: #2
Date/Time Assigned: 7/15/2016 10:00 Date/Time Arrived: 7/15/2016 10:00 Date/Time Completed: 7/15/2016 13:30
Scene Location: 1089 HAINES ST Apt./Lot #■
City: JACKSONVILLE State: FLORIDA Zip: 32206
Sub-Sector: B3
Taz: 110 Crossstreet:
Lift Cards Submitted? NO Elimination Prints? NO Total # of Lift Cards:
Photos at Scene? YES # ofPhotos 151 Video? NO Diagram? NO
Lifts of Value?
Evidence? YES Evidence Delivered To: Property Room
ADDITIONAL INFORMATIONS
Reporting Officers: K.A.LONG
jq# #7239
This report is being generated to change the date to 07/15/16, not 07/14/16.
OrginalReporting Officer:
W.B.FLEEMAN
Detective
Evidence Report Completed by: K.A.LONG
Approving Supervisor:
ET
Page I of!
H.R.BROOKS
Date Printed: 8/3/2016
ID #60838
ID #
ID #7239
ID #
id #7536
7/15/2016 15:05
7/15/2016 15:06
MIKE WILLIAMS, SHERIFF
2016-453875-2
4-?
ET
(I'd
doors, hood, and back hatch
The left rear window was missing, but CSU D
wrap over the window.
etective Bruce had placed plastic
pand
i
I opened the rear hatch rf««r
„ u
onne live round and packaged the live round.
S&SS^SS-Sssssg
c.ltec,.d a „ib ,„m tha i-JS^asraass" •“*• ■^^assa:
SSsS35£
CSU offlce. SSSw“ Sdd£i“ tZ'TpSZSm
P'ac<ld l»>o a drying
cabinet at the
The following evidence was placed Into the prop
erty room:
ocket
swab from rightfrom arefof'drtveP^.oal.blood08"'"'' “°0d
ood
.osch DNA swab HPR..3Q0 a-TSttSfiSSSLv door
Page 3 of 4
Date Printed: 8/23/3016
MIKE WILLIAMS, SHERIFF
2016-433875-3
A-9
ET
fits
£%/% Department of
%&* Veterans Affairs
sss
December 14, 2017
PO BOX 1437
ST PETERSBURG FL 33731
!
Veteran’s Name:
Stucks, Percy, Allen
#
000029964
1=0000
!
..................................................... i'Mi"29064 1 AV 0.370
PERCY ALLEN STUCKS
1650W28THST
JACKSONVILLEFL 32209
r
i
This letter is a summary of benefits you currently receive from the Department of Veterans Affairs
(VA). We are providing this letter to disabled Veterans to use in applying for benefits such as housing
entitlements, free or reduced state park annual memberships, state or localj property or vehicle tax
relief,civil service preference, or any other program or entitlement in which verification of VA benefits
is required. Please safeguard this important document. This letter replaces V A Form 20-5455, and is
considered an official record of your VA entitlement.
—America is Grateful to You for Your Service—
Our records contain the following information:
Personal Claim Information:
Your VA claim number is: 593 92 5867
You are the Veteran
Military Information:
Your character(s) of discharge and service date(s) include:
Army, Honorable, 01-Jul-2004 - 29-Aug-2flOZ3
(You may have additional periods of service not listed above)
:
!
:
:
VA Benefits Information:
Service-connected disability: Yes
Your combined service-connected evaluation is: 40 PERCENT
The effective date of the last change to your current award was: 01 -DEC-2016
Your current monthly award amount is: $589.12
i
■
;
:
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i
i
j
You should contact your state or local office of Veterans’ affairs for informz tion on any tax, license,
or fee-related benefits for which you may be eligible. State offices of Veterans’ affairs are available
at http://www.va.gov/statedva.htm.
Need Additional Information or Verification?
If you have any questions about this letter or need additional verification of VA benefits, please call
us at 1-800-827-1000. If you use a Telecommunications Device for the Deaf (TDD), the federal relay
number is 711. Send electronic inquiries through the Internet at https://iris.va.gov.
Sincerely yours,
Regional Office Director
ssss
HEALTH RECORD ~f
CHRONOLOGICAL RECORD OF 4^
ICAL CARE
* •
,,
X
*
Patient. STUCKS, PERCY ALLEN
Treatment Facility: Evan9 ACH-Fort
Carson
Patient Status: Outpatient
!SS£li!S5r
Date: 09 Aug 20071300 MDT
Clinic: PSYCHOLOGY
•
Appt Type: EST$
Provider. PALIANI.MELISSA ANNE '
^T2/CPT ALLEN/338^9S5
CEC
S2ms Reffe3hed bV PA'IAN'' MELISSA
ug 20071341 mdt
Active Family History
• Diabetes mellitus (Mother)
•joint stiffness of the ankle
• ASSESSMENT OF PATIENT
CONDITION WORK STATUS
• Visit for: ears / hearing exam
• JOINT INSTABILITY HUME&US /
ELBOW
Allergies
• No Known Allergies
• ADJUSTMENT DISORDER WITH
conductNCE °FEW!OTIONS and
• insomnia
-CANNABIS DEPENDENCE
■ ASSESSMENT OF PATIENT
CONDITION WORK-RELATED'
• ADJUSTMENT DISORDER
• INSOMNIA RELATED TO AXIS. I/ll
MENTAL DISORDER
(NONORGANIC)
•joint pain, localized In the knee
• Fever
• visit for: military services^physical
separation .
• visit for: military services physical
• foot pain (softtlssue)
• upper back pain (between shoulder
blades)
Active Medications
Active Medications
TRAZODONE HCL, 50MG, TABLET, ORAL
Active
Slg
T1 TAB PO.BID,#60 RF3
Refills Left
3 of 3
Last Filled
20 Apr 2007
T1 TAB PO HS
3 of 3
20 Apr 2007
-Psychiatric Therapy Individual'Approximately 20-30 Minutes x 1
gSBBSffliM
HPT
care.
Mate Wflttep by PAIIANI. MELISSA A p.nn ^ug 20Q7 mi MnT
T- Trd dia8"0Sed
Dtohr.
However,
supported. Disposition through medical channels is not '^mmted/This^^dier alsoreports'tha^.
Name: STUCKS, PERCY ALLEN
FMP/SSN. 20/59392586.7
DOB:
14 Nov 1985
PCat.
Al'1.2 USA ACTIVE DUTY
ENLISTED
MC'Status
Insurance: No
Sex.
M
Tel HTelW.
719-761-7017
719-761-7017
es.
SWS-
Sponsor/SSN.
Rank:
STUCKS, PERCY ALLEN/593925867
SPECIALIST
Unit
WJAXF0FC
Outpt Rec Rm: TMC 9 RECORD ROOM
PCM:
Tel. PCM.
/
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Ail •vldence collected wee
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packaged and placed In the p
roperty Room,
scene at 2020.
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«> OrMnbriliopMl^'^^Welta
a separate report.
sssssssr-""™
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Swabs:
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room.
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under the mattress by Detective Chizik the
^a&inpcated whatSri^j2!!1? L?,ca^d in^Uhe Qun contained civ Mx/0 r,____
We-aihat fesTrfl hfr^nblQOd oHtBgtSywg, leceiver
Writer’s note: The handgun
was left in the secured hotel
at the scene.
'°"n^ -
room overnight, so it c
ould be processed by ET Wells
1230: Detective Silcox obtained the
was wearing the
been secured In DetectiveacS'sa"elI'icter°ocnkel'lmnrred 'r°m StUcks' pante Pocket the
prior evening had
Technician photoglyphs Pr°Cess,ng of the hotel room, refer to ET Wells supplement
report, and the Evidence
Stucls^ vehicle. h°'61 P‘"1t'n9 tot*» 'be Richmon‘5 Hm" SSturts^Chevrolet Trail
secure
Writer's note: ET Wells sealed
and photographed the vehicle
prior to it being removed from the h
1243: Detective Chizik and I departed th
otel parking lot.
e scene.
^SsltCrS^tac”"Jpal Ed™a'aa at 912-856-3633. I did not receive an
answer and left a voice mail
r
records revealed that he
Georgia on 07-12-16, at 11- 16 am^VheTJcord^urth0 thiS telePhone
responded at 3:10 Pm. Stucks then
responded again at 3:11
fUrther re vealed that 912^856-3633 H 'S
pm.
^ssss^'^'
con tacted NCIC and
1- He received a text message
neasdlha vrork."
Jus* "*'"9 <a make some money ,o genome'' D^you ^a^ P'e?aa "elpm.7m
y
S^UP Page!2 of 18
Date Printed: 10/17/2016
nave any opening sir. I really
MIKE WlUJAMsTsHERiFF
2016-453875
A-n-
sup]
touch DNA swab butter knife from rear cargo area
control swab......
"
.....-... ....
......* ...... "
tank top front passenger seat between door & seat
'
On 07/16/16,1 removed the trunk compartment lid and piece of driver's seat and placed them Into the property
room.
This concludes my involvement with this case.
Orginal Reporting Officer:
W.B.FLEEMAN
Detective
Evidence Report Completed by: K.A.LONG
Approving Supervisor:
ET
Page 4 of 4
Date Printed: R/3/2016
ID #60838
ID #
ID #7239
ID #
ID #
8/3/2016 14:25
00:00
MIKE WILLIAMS, SHERIFF
2016-453875-3
'/3
ET
'Mfl
m
Photo, at Scene? YES
« ofPhoto, 137
Evidence? YES Evidence O'UveredTo.. P^^^ N°
4? ft * /•>
Scene Information; #6
crossstreai:
Date/Ti
mo Completed; 7/14/2010 12:45
^ GEORGIA a^. 31324
W Card* Submitted? NO
Elimination Prints? NO
Photos at Scene? YES
HofPhotos 37
Evidence? YES
Evince Delivered To:
Sub-Sector: OJ
^ZZfnT
Wft of Value?
ER SUSPECT VEHICLE TO 10SS HAINES ST
Scene Information; #7
srjAciS^/^E^rr^--'' 7,,9«««
roe,67 crawX,rr„r,t: LLE ^ FLORIDA ^ 33202
Date/Tt
me Completed; 7/19/2016 13:3Q
W> Card, Submitted? NO
Elimination Prints? NO
Photo, at Scene? YES
Total it qf
Cards:
# ofPhoto, 18 Video? NO
Evidence? NO
Diagram?
NO
Evidence Delivered To:
Sub-Scctor: A3
Wit of Value?
Physical Evidence: #4
Quanlfy:
Location:
Weight:
Unit ofAteamre
S«e narrative
Description
--------- ---------- -----------------------------------
r-~—
Synopsis:
On 07-12-16,
I loofc a phona call Iron, officer
roon Street,
R
owing Information:
£S8»SS£8teBtee^
■^-^sssssaSS:
I advised Off!
car Fleeman homicide
Officials at scene:
ET
Page 2 of 7
DatePrinted: S/23/2016
should be notified and that I
would respond to
the scene.
^^^^SHERiFF
2016-453875-4
gf
Aw
/s'
^3S5BS8BaaasBaS^:=Z>
1210: Detective Edw
1220:
S^SSg53g3£§^paS£?£>
viewto
fits
responded To him®-8^"* ?tucka a text message
Mr. Walker said h. called St k
Mr. Walker exoialn«rf # ^ Stucks on Monday 07.11 19
aak,„fl „
,s ok ^
.
sSs^£5§SSS^^S^,aaSSsr,,
hla•*-*
8 90back*°h,a(s^-'>arstasajsa-aSSSS*-
SpKH^
PTOh. Mr. Walker adSsad tEeT° bs bl°°* °" hSS5h,“ “"ha front door Mr wtli, Mr' w»"««on to
sfii#iisiai»*ifii
as
t*®i®“Sss£^r
Writer’s note: Forfurth
or details of the phot
cas eaddendum.
°graphs shown to Mr. Walke
r. refer to Officer W.B.
»» ■ ntamstty) ai the'veterans AffalR*>(VA)W>ra S“,ol“ wort« »ut
said that Stucka had t
Mr.
Fleqman's major
old him that he
was doing
Mr.
SHJP Pue* 7 of ia
Ome Printed:jonjrto)6
^HM^raiRiFF
9h'
2016-453875
7f7r
sup]
IU
r«ponSe a, ,he door^ hTlefta bSnesfct^
Ross. There wee
no
e Odwards also left Ross a voicemail asking her to call
locatedauilfsHw^^Vadvl'^r"^"^'1""*0"*°'thhmonkiHl"’ Po,lc* D»oartm.nt. h.
^ePR,|SonSdrHi“pollce
In®'1ThRelrehw°nd ?"'• GA 31324 <Mo"V
*ss
•hatStecfs ren„tedk'her'“om underts
-fe?SS S?t£iSffl5Gsa,,i*
'S <*^nE£^e\^ *“»; a?d <™c^« Wh-S
Wo a parking spot near hls ^35X38?*
- •^•SS^SSS^^gt-
Writer's note: For furthe
r details, refer to the hotel
2048: Detective chlzik and i ai
r6fllStry which has been made a part of the case file
Wrrr ~ - —gun magazine was removed fromhlshnh,h°r..?l?8
Writer's note:
Chizlk's locke
'"cldent. .During a
with
ti
sgesslon of the
lunma^nefromsf^e.
vehicle trunE
gnts pocket and
secured it in Detective
..''',!**^e«wnaK)e>a?caii»
orted
^®SSSS^-
90
AfterStuck^sIgned^h^c'11 ^ S6arCh '°rnis 1133 been made a part of the case file,
ifflCB
tolls
Writer's note: f
hing was nr
HWa
rsonne
le fol
eS
jSsedorrei
j§-Wj
hlzil
cplsto
le
tod from Si
rr
Ichmoi
JP infuse
rocesse
irPoncFH lowli
grtment aareSi
a:
220 « Detective Chlalk and I arrived at th
nr
ric<
om a
^^eTMT^om
e Richmond Hill Ponce Department lo
Stucks was
escorted to an intervle
222 4): Detective Chizik
cated at 120 Richard Davis Drive.
w room where he waited to be inte
rviewed.
and I began our Interview
not ba|ng aud|oMdeo
recorded,
I re ad Stucks is Constitute
°nal Rights, via form,
which he acknowledged he
During the interview, Stocks
understood and signed.
requested a lawyer, and the Intervle
w was terminated.
WrBter-s note: Forfurth
er details of the Interview,
refer to the audlo/vldeo
recording which has been made
a part
Page 10 of 1R Qate pricedjq/] 7/20 J 6
|sSp
mike williams, sheriff
20 J 6-453875
SUP
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Notes:
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THE NATIONAL RIFLE
ASSOCIATION OF AMERICA
* /T i ‘ *•
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NRA
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Awards this certificate to
Percy Allen Stucks Jr.
»*;
*:
'V
for successful completion of the
i •
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:•
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FIRST STEPS
PISTOL ORIENTATION
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Jacksonville, Florida
IstfCedV
June 7, 2015
Date
Certified Instructor, Signature
Arnold Gustafson
NRA Certified Instructor, Printed Name
NRA ID if.
149542514
NRA Secretary
l
C&P Final Report
I
Page.- 5
E*araC'nU,nl’8r! 593925867
“F *r ® * •* ■ b ■ o n ■ g
■■BMiaBBBBBBBBMMBB
Exam Results Continued
Environment
[ ]Physical illness
[ I Financial
[ 1 Housing
t ]Primary Support
[X ]Occupational
[ )Relationship
( ]Legal
AXIS V: 65-70
/
12/17/2009
A/P
2005-6 AND^AR^I^^RoWNIHa^a™
2/ETOH ABUSEDROWNING MVA 2008
3/cafPeKS^ T “PORTED
DEPL0™B®T
■
4/PROZAC 20 HO QD WITH
OPTION TO TAKE 40 MO PRN SHORT-TERM
5/UP TRAZODONE 50 MO
> 75-100MG •
6/ENCOURAGED TO RESTART THERAPY AT
VET CENTER
7/RTC 3 MONTHS
/as/ EDWARD ANDREW SQBOLBWSKI
M.D.
3/17/2010
A/P
;2*“e
«• > h ™ o»
/^f°D0NE 7s MO TITRATED TO
™s.r"™ "Tu- "»-*»
MVA 2008
INSPOMNIA, FITFUL SLEEP, NIGHTMARES,
NIOHTSWEATS MAX 300MQ
6/DR. STAUBLE EVAL
FOR FOR. IRAQ PTSD GROUP
WITH RTC NEXT AVAILABLE WITH ME
• /as/ EDWARD ANDREW SOBOLEWSKI
M.D.
4/20/2010
AXIS I
AXIS II
AXIS in
AXIS TV
AXIS V
Anxiety Disorder, NOS
R/0 PTSD
Referred
flee Medical Record
Extranous ciroumstanaee
Current OAF " 60
/
Continued on next page
VA Form 2507
i
J
COPY MADE BY VARMC. ST. LOUIS FROM A RECORD IN VA'S
POSSISSION
SHANDS JACKSONVILLE
Health Information Management Department
655 West Eighth Street
Jacksonville FL 32209
IP Encounter Report
Stucks, Percy
MRN: 04900677, DOB: 11/14/1985, Sex: M
Adm: 5/26/2014, D/C: 5/26/2014
Alt Notes
ED Notes by Clifton, Wendy G, RIM at 05/26/141443
Author: Clifton, Wendy G, RN
Service: Emergency Medicine
Filed: 05/26/141446
Date of Service: 05/26/14 1443
Editor: Clifton, Wendy G, RN (Registered Nurse)
Author Type: Registered Nurse
Status: Signed
28 yo bm ambulates to air room accompanied by two JSO c co abrasions to left forearm, right forehead,
right cheek about 1 hour ago after falling. Denies sob. To ecc for vitals and evaluation.
Electronically Reviewed and Signed by Clifton, Wendy G, RN on 05/26/14 1446
ED Notes by Salerno, Nicole, RN at 05/26/14 1446
Author: Salerno, Nicole, RN
Service: Emergency Medicine
Filed: 05/26/14 1447
Date of Service: 05/26/14 1446
Editor: Salerno, Nicole, RN (Registered Nurse)
Author Type: Registered Nurse
Status: Signed
Pt with JSO, c/o lower back pain, says it is a reoccurring injury. Pt is calm an cooperative, made Heather
RN aware of police hold patient. Pt to wait for availability in flexcare
Electronically Reviewed and Signed by Salerno, Nicole, RN on 05/26/14 1447
ED Notes by Tafuri, Joel J., RN at 05/26/141550
Author: Tafuri, Joel J., RN
Service: Emergency Medicine
Filed: 05/26/14 1551
Date of Service: 05/26/14 1550
Editor: Tafuri, Joel J., RN (Registered Nurse)
Author Type: Registered Nurse
Status: Signed
Patient slammed on ground while being detained and arrested has abrasions on right check -left forearm
And left deltoid.
Electronically Reviewed and Signed by Tafuri, Joel J., RN on 05/26/14 1551
ED Provider Notes by Roycroft, Claire M, MD at 05/26/14 1659
3S9
Author: Roycroft, Claire M, MD
Service: Emergency Medicine
Filed: 05/26/14 2044
Date of Service: 05/26/14 1659
Editor: Roycroft, Claire M, MD (Resident)
Author Type: Resident
Status: Signed
Cosigner: Duran, Petra E, MD at
05/30/14 0007
Procedure Orders:
1. ED Performed Ultrasound [123865386] ordered by Roycroft, Claire M, MD at 05/26/14 1915
History
Chief Complaint
Patierit presents with
• Abrasion
HPI Comments: 28 y/o M pmh chronic back pain presents foLabrasions and low back pain, pt was arrested.
aod fell totheorounti he hit his right face and left.shoulder on the ground. While he was"on the ground
Generated on 12/26/18 6:33 AM
Page 3
MRNkS649eor0677, DOB: 11/14/1985, Sex: M
SHANDS JACKSONVILLE
Health Information Management Department
655 West Eighth Street
Jacksonville FL 32209
IP Encounter Report_____ ____________
Adm: 5/26/2014, D/C: 5/26/2014
AW Notes (continued)
ED Provider Notes by Roycroft, Claire M, MD at 05/26/141659 (continued,
„—.........••—
^-hS l£;er back. sSi mit llme he has had worsening of his low back pain, denies
weakness, numbness, tingling.
Patient is a 28 y.o. male presenting with Trauma. The history is provided by the patient. No language
interpreter was used.
Trauma
the left shoulder. There is an injury to
,eft
inhaled smoke. Pertinent negativesinclud®"
-n
m
p
numbness no visual disturbance, no abdominal
bladder incontinence no headaches, no hearing loss,
contacts.
No Known Allergies
Discharge Medication List as of 5/26/2014 7:24 PM
START taking these medications
cyclobenzaprine (FLEXERIL) 5 MG
tablet
ibuprofen (ADVIL.MOTRIN) 600 MG
tablet
Take 1 Tablet (5 mg) by mouth 3 times daily as needed for muscle
spasms.Disp-9 Tablet, R-0, Normal
Take 1 Tablet (600 mg) by mouth 3 times daily for 3 days.Disp-30 Tablet, R-0,
NormalTake scheduled for 3 days then as needed for pain_______
History reviewed. No pertinent past medical history.
History reviewed. No pertinent past surgical history.
History reviewed. No pertinent family history.
History
jSocial History
"
• Marital Status:
Spouse Name:
Number of Children:
• Years of Education:
frnc.ial HiStOIV Main:T0PlCS
• Smoking status:
-----_
Single
N/A
N/A
N/A
Never Smoker
i
Page 4/
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Correspondences Page 4
A-lt
e
Hart, Amanda VBASPT
From:
Hart, Amanda, VflASPT
Monday, May 09, 2016 4:34 PM
'Stocks, Percy A.'
RE: (EXTERNAL] Patiently waiting
Sent:
To:
Subject:
Hi Percy,
I care-and I'm Clad you shared, l look Ward to meeting you In the near future and
am already proud of you. Hope to
see you working around the office In the near future. ©
Sincerely,
Amaiuta (Bileu) Hart, Ml IS, CVRC (previously Zalcskic)
Vocational Rehabilitation Counselor
Promt stucks, Percy A. (mfliltojstuco^^tudehtc fcn
Sent: Monday, May 09, 2016 4:30 PM
Hm J
To: Hart, Amanda, VBASPT
Subject: Re: [EXTERNAL] Patiently waiting
=ss=ss^^5:
cares.
From: Hart, Amanda, VBASPT <Amanrla Har^^ua enus
Sent: Monday, May 9,2016 4:01:48 PM
To: Stucks, Percy A.
---------------- ’--------------------------- -
Subject: RE: [EXTERNAL] Patiently waiting
Hi Percy,
Thank you for taking the time to explain the circumstances that
can see you are dedicated to doing welt in .hemogram ‘
^
your work study application.
through yet - that way nothing will be standing in th
fact
that
you emailed me back so ouicklv with surt^i r„n,w/ , k t dv',f you Brc sheeted. For what Ifs
worth, the
‘
‘
‘
!nd -1 will out In a onort w««t u.m, JL
*3 consldera,« a"d grammatically correct email is noticed
on my end -1 will put In a good word with Daryl for you.
—:25bs£sS=r”=
Sincerely,
A i ntn itfa (Bile,t) Hart, MUS, CVRC (previous},, z„iM
Vocational Rehabilitation Counselor
l
Correspondences Page 3
A'^3
F
Hart, Amanda. VBASPT
From:
Hart, Amanda, VBASPT
Monday, June 20, 201612:27 PM
Sent:
To:
Subject:
'Stucks, Percy A,'
RE: [EXTERNAL) Thanks again
Sincerely,
From: Stucks, Percy A. [
Sent: Sunday, June 19, 2016 9:33 AM
Tor Hart, Amanda, VBASPT
Subject: [EXTERNAL] Thanks again
1
no
a tot of people who don't want to
eace. 1 just wanted to let you know I really
appreciated the opportunity to work with
every one up at Vocation Rehab. Mrs. Hart the staff is some of
the best people I have ever worked with
and it has been a true pleasure working with every one. Thanks for
your time Mrs. Hart I Have a good morning!
see me do good. So, 1 always prepare for war In times of p
1
I
Correspondences Page 5
~r
Hart, Amanda, VBASPT
From:
Sent:
To:
Subject:
Stucks, Percy A. <stucpa2@students,fecj.edu>
Tuesday, July 12.2016 10:S8 AM
Hart, Amanda, VBASPT
[EXTERNAL] Good Morning
Good morning Mrs. Hart, I remember In one of our earlier conversion talking about having to leave.
Well, I have a serious emergency that requires me to leave Immediately, It Is a life and death situation. I
would just like to say It has been an absolute pleasure working with your staff. They are some of the best
people I ever had the chance to work in my life. I have one last request before I leave, 1 need Mr. Neil to please
give me the last to 2hours I need and submit my time cord. I really need that boost with this new situation
developing. Always a pleasure Mrs: Hart. Please talk to Mr. Neil, I really need him to do that favor, i really
need that favor more than anything. I might not be alive soon. I can't really get into details. Thanks again Mrs.
Hart
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Pnwumnndnnnni.' Pnrrp h
Hart, Amanda, VBASPT
From:
Sent:
To:
Subject:
Hart, Amanda, VBASPT
Tuesday. July 12, 2016 3:53 PM
'Stocks, Percy A,'
RE: (EXTERNALS Re: please respond ASAP
Percy, I've told Neil to go ahead and dose out your work study contract and pay you out. He tells me that It usually
takes several days to get the funds. In the meantime I'm letting your school pay keep running and will worry about that
whenever they send an updated enrollment certification, I will grant mitigating circumstances and let you keep
whatever possible. I understand you don't feel comfortable giving me any more details, but please know that i am here
and Will help however! can. I am still very worried about you.
Sincerely,
Amaurta (Bcleu) Hurt, MHS, CVRC (previously Zaleskid
Vocational Rehabilitation Counselor
From; Stocks, Percy A. fmalfrorstucpagtBstudents ,fsci.edul
Sent; Tuesday, My 12, 2016 2;56 PM
To; Hart, Amanda, VBASPT
Subject; [EXTERNAL] Re: please respond ASAP
Good afternoon Mrs, Hart, 1 got a situation and debt is not my concern my life is, 1 had to leave the school or
die. I am just trying to leave, 1 am running low on funds. All I am request is what i asked early for you to tell
Mr. Neil. 1 would never walk away from school or work study unless it was serious. I am so depressed and
wo itied. I just need that last favor 1 asked early. This is about my life not debt. Some times people don't want to
see you do good and you die. 1 am just trying to leave so I left.
From: Hart, Amanda, VBASPT <Anianda.Hart2(H)va.eov>
Sent; Tuesday, July 12, 201612:01:41 PM
To: Stucks, Percy A.
Subject; please respond ASAP
Hi Percy,
I tried to call you but got your voicemail. 1 am very worried about you after reading your last email. I need to know that
you are okay. Are you leaving Jacksonville completely? Are you coming back? Are you dropping out of school? Are you
quitting work study? You have a running subsistence award for school and an open work study contracl, I want to make
sure you get paid for the work study part and that you don't and up in a debt with subsistence. I am very concerned
about you and want to help any way that I can, even if it's just making sure you won't end up In debt. Please tell me
anything you can so that I know how best to help you. Please contact me by email or phone asap.
Sincerely,
Anitindii (Bdleit) Hurt, MHS, CVRC (previously Znhskic)
Vocational Rehabilitation Counselor
r'r.eroi’nAnHpni’PC PtUTf* 7
Sheriff John H. Rutherford
Jacksonville Sheriffs Office
Incident (Offense)
2010-0497742
Route To
Groups:
People:
'ncident Information
ncident Location
Day/Date/Time Reported:
Saturday, 06/26/2010 17:36
653 MONUMENT RD, #1104
Day/Date/Time Incident From: Saturday, 06/26/2010 16:00 To: Saturday, 06/26/2010 17:25
JACKSONVILLE, FLORIDA 32225
Is this a Corrections Information Report?: NO
Sub-sector: D3 TAZ: 626
Location Type:« APARTMENT / CONDO
Primary Weapon Used: HANDGUN
School Name: f.
School Number:
Incident Occurred: Inside Location Incident Occurred In the Parking Lot at this Location?: NO
Miscellaneous
# of Offenses: 1
Dwg Activity:
NOT APPLICABLE
Drug Type:
NOT APPLICABLE
Alcohol Related: UNKNOWN (OR N/A)
# of Victims: 1
Drug Related: UNKNOWN (OR N/A)
MCI Case:
NO
# of Suspects: 1
Follow-up By:
Was Hate Crime Involved?: NO
Dating Violence Involved?:
Is Offense(s) Related to Domestic Violence?: YES
If not Domestic Violenbe, Is it Domestic Related?:
Any Children under 18 Involved as a Victim?: NO
Offense(s)
#1
Statute #: 784.045(1 )(A)(2)
Degree: F2
UCRCode: 130A Attempt Code: Committed
BATTERY / AGG / DOMESTIC / WITH A DEADLY WEAPON - NO PREVIOUS STALKING
Victim #1 - STUCKS, PERCY ALLEN JR
Did victim invoke right to prevent the disclosure of personal info (Marsy's Law)?:
Demographics
Race: BLACK
Sex; MALE
Date of Birth: 11/14/1985
Ethnicity: NOT OF HISPANIC ORIGIN Sub Ethnicity: NOT OF HISPANIC ORIGIN
Primary Language: Secondary Language:
Age: 24
Height (inches): 6'03”
Weight (lbs): 175
Hairstyle:
Hair Color: BLACK
Hair Length:
Build:
Eye Color. BROWN
Facial Hair:
Complexion: Voice:
Clothing/Description:
Disability, Mental, Physical and Medical Information
Physical Descriptor
Descriptor Detail
NOT APPLICABLE
NONE / (NOT APPLICABLE)
Contact Information
Bus. Phone #:
Home Phone #: (904)-444-8623
Cell Phone Provider. METRO
Cell Phone#:
(904)-444-8623
Email Address:
Primary Identification
Type of ID Given:
ID:
Addresses
Is Homeless: KlO
Home Address
Mailing Address
653 MONUMENT RD, #1104
JACKSONVILLE, FLORIDA 32225
Sub-sector: D3 TAZ: 626
Employment/School
Employer:
MAXWELL HOUSE
School Last Attended:
Alternate Contact Information
Home Phone #:
Cell Phone#:
Email Address:
Other Information
Residence Type: CITY
Page 1 of5
Description
Ext.:
Alt. Phone #:
Issuing State:
Alternate Address
\
Occupation:
Bus. Phone #:
Cell Phone Provider:
Ext.:
Residence Status: RESIDENT
Printed 05/07/2020 15:59 by J.L. BUTLER (#66197 )
hr 11
Sheriff John H. Rutherford
2010-0497742
Incident (Offense)
2010-0497742 (Continued)
Drugs involved?:
Alcohol Involved?:
Mode of Travel:
Victim Type: ADULT Injury Extent: MINOR
Injury Type: SEVERE LACERATION
Hospital Victim Taken To: NOT APPLICABLE Sexual Battery Type:
Assault Specific Information
Was victlm pregnant:
Was fetus lost:
Did suspect know victim was pregnant:
Was prior stalking involved?:
Was intent to cause serious injury:
Weapon(s) Involved
Weapon(s): HANDGUN
Victim Relationship to Offenders):
Relationship: BOY FRIEND/ GIRL FRIEND (DOMESTIC VIOL)
To: Suspect (01) - MUGNO, GISELLA L
Related Offenses
-----—1: 784 045(1)(A)(2) - BATTERY / AGG / DOMESTIC / WITH A DEADLY WEAPON
- NO PREVIOUS STALKING
Domestic Violence
f?.a CliminBl Investigation, was the Suspect Arrested?: YES
What Was the Nature of the Offense?: Felony
Victim has Injunction for Protection?: NO
Type Of Injunction?:
VictimAMtness gave Written Statement?: NO
Threat Assessment Made?: YES
Prior History Of DV?: YES
Is History Documented?: NO
Behavior or Condition of Victim at the Time of Incident?:
Crying
Behavior or Condition of Suspect at the Time of incident?: Irrational
Domestic Violence Threat Assessment
01. Has your partner ever been violent to you?:
NO
M
P!ySiCa‘, Vi°,anCe 90tt0n W°rSB (more severe> over the
year?:
N/A
03. Has the physical violence been happening more often in the last year?N/A
04. Have you recently separated from or talked about leaving your partner?:
YES
05. Has your partner ever throated or attempted suicide ?:
YES
06. Is there a Orearam in the house or accessible to your partner?YES
07. Do you believe your partner would intentiaiiy kill you?:
YES
08. Has your partner ever told you how they plan to kill you?YES
10. Has your partner ever strangled you until you passed out?NO
UNKNOWN
YES
/fyes to question 12, which type of weapon?:
Gun
13.
Has
your
partner
ever
used
„.
a weapon to harm you?:
YES
14. Was your partner been stalking, following, or watching you?-
NO
UNKNOWN
UNKNOWN
19.
Does your partner act out violently to others outside the family?-
P
mgulafbasis?-1^ US° drU9S (cocaine< crack, or other illegal street drugs) or get drunk or high on a
If
Victims Level of Education:
Victim's Annual Income:
UNKNOWN
NO
NO
NO
S2ZSES5S FACTORVWORKER
SOME HIGH SCHOOL
^
Less than $15,000
’
°NE
SuspecVs Level of Education: HIGH SCHOOL COMPLETED
Suspect's Annual Income:
$35,000 - $49,999
Victim Notification
Contact Information
Home Phone#: (904)-444-8623
Cell Phone #: (904)-444-8623
Email Address:
Addresses
Is Homeless: NO
tome Address
653 MONUMENT RD, #1104
JACKSONVILLE, FLORIDA 32225
Sub-sector D3 TAZ: 626
Contact Type: Victim
Bus. Phone#:
(904)-632-3400
Cell Phone Provider METRO
Ext-
Alt. Phone #:
Mailing Address
text of Kin Notification
Jext of Kin Name: EBEBERHART, PERCILLA
Next of Kin Type: Other
Page 2 of5
Knitted 05/0/72020 15:6a Dy J.L. BUlLER (#66197)
Sheriff John H. Rutherford
A-Zl
2010-0497742
Incident (Offense)
2010-0497742 (Continued)
1
Contact Information
Home Phone #: (904)-647-6113
Cell Phone#: ' (904J-613-5000
Email Address:
Home Address
2250 BARRY DR S
Bus. Phone #:
Cell Phone Provider
Ext:
Alt. Phone #:
Mailing Address
JACKSONVILLE, FLORIDA 32208
Sub-sector N2 TAZ: 186
Who Made the Notification: MJ MEISSNER
Method Used: IN PERSON
Date/Time:
Suspect #1 - MUGNO, GISELLA L
Demographics
<~**CUHLY««»VY
^|^S™AWBERRY
Complexion: FAIR / LIGHT Voice: NORMAL
«^-LOR|
Facial Hair. NONE
Clothing/Description: NIGHT DRESS
Place of Birth:
Nicknames:
Aliases:
Distinguishing Marks (Scars, Marks, and Tattoos)
Characteristic
TATTOO
Body Location
Contact Information
Home Phone#: (904)-380-1621
Cell Phone #: (904)-380-1621
Email Address:
Primary Identification
Type of ID Given:
Addresses •
Is Homeless: NO
Home Address
653 MONUMENT RD, #1104
JACKSONVILLE, FLORIDA 32225
Sub-sector D3 TAZ: 626
Employment/School
Employer
UNEMPLOYED
School Last Attended:
Description
: RIGHT ARM "JARED" LEFT ARM
"MARIAH”
Bus. Phone #:
Cell Phone Provider Metro PCS
ID:
Mailing Address
Ext:
Alt. Phone #:
Issuing State:
Alternate Address.
Occupation:
CEW (Conducted Electric Weapon)
ECO Usage: NOT APPLICABLE
RTR Written Related to This Incident?: NO
RTR Incident Year:
RTR Incident #:
3ther Information
SHO Status:
ID Section Confirmation, By ID #:
Drugs Involved?: Alcohol Involved?:
Mode of Travel:
Juvenile?: NO Confessed?:
Arrested?: Arrested Were Miranda Rights Given?: YES
Jail# Type: Booking# Jail Booking #: 2010021886
delated Offenses
#01: 784.045(1)(A)(2) - BATTERY / AGG / DOMESTIC / WITH A DEADLY WEAPON NO PREVIOUS STALKING
Additional Information
On 06-26-10 at 17361 was dispatched to 9501 Arlington Expwy (JSO Substation) in reference to a domestic dispute
Page 3 of5
Printed 05/07/202015:59 by J.L. BUTLER (#86197)
Sheriff John H. Rutherford
A-zi
2010-0497742
i
Incident (Offense)
2010-0497742 (Continued)
I:onsemTsTu[edTh7haIIJguRnefrCom fhe'JKfcar
SC°ne ^ tr0ated Mr> StUCkS f°r 8 ,aceration to his hand-With the victim‘s
I observed the laceration to the victim’s right hand. I also observed scratch marks on the victim's right arm and right upper chest.
suspect.
An ET was requested to the scene.
Sgt MB Miller #5393 responded to the scene.
responded to the scene and
Rescue 30 transported the suspect to Shands Hospital where she was
absentee booked.
Case cleared by arrest.
Misc Information
Clearance Status: CLEARED BY ARREST
Clearance Code: ADULT
Date Case Was Cleared:
Case Geared: CLEARED BY ARREST (PATROL)
Number of Cases Cleamd: 1
Is there additional information included on a continuation report?: YES
Am them other Pertinent Reports?: NO
Did this incident qualify as a "Cargo Theft"?:
In your opinion is there significant mason to believe that the crime
can be solved by a patrol follow-up investigation?: NO
Neighborhood Canvass Conducted?: YES
Case Card Information Left with: Person
Victim (01) - STUCKS, PERCY ALLEN JR
Handouts
#1: Case information Card
#2: Domestic Violence Pamphlet
#3: Vine Information
*4: Victim Services Card
#5: Advised of Shelter
#6: Advised of Victim Services
#7. Victim Notification Form
#8- Signature Form
Neighborhood Canvass #1
No one home?:
WIRTH, JOANNE
Demographics
Race: WHITE
Ethnicity: NOT OF HISPANIC ORIGIN Sub Ethnicity: NOT OF HISPANIC ORIGIN
AQQ! 34 tO 34
Clothing/Description:
Contact Information
Home Phone #: (904)-430-3502
Bus. Phone it:
Ext.:
Cell Phone #:
Cell Phone Provider:
Email Addmss:
Home Address
Mailing Address
653 MONUMENT RD BLDG11 , #1101
JACKSONVILLE, FLORIDA 32225
Sub-sector: D3 TAZ: 626
Alt. Phone #:
Alternate Address
Additional Information: DID NOT HEAR ANYTHING
Neighborhood Canvass #2
Page 4 of5
A-ll
Printed 05/07y2020 15:59 by J.L. BUtLfeR (#66197)
Sheriff John H. Rutherford
2010-0497742
Incident (Offense)
2010-0497742 (Continued)
No one home?: YES
Demographics
Race:
Ethnicity:
Age:
Clothing/Description:
Sex:
Date of Birth:
Contact Information
Home Phone #:
Bus. Phone #.Cell Phone #:
Cell Phone Provider:
Email Address:
Home Address
Mailing Address
653 MONUMENT RD, #1103
JACKSONVILLE, FLORIDA
Sub-sector D3 TAZ: 626
Additional Information: NO ONE WAS HOME.
Ext.:
Alt. Phone #:
Alternate Address
Neighborhood Canvass #3
No one home?:
PERRY, VONUSA
Demographics
Race: BLACK
Sey FPMAi c
Ethnicity: NOT OF HISPANIC ORIGIN FEMALE
Date of Birth:
Sub Ethnicity: NOT OF HISPANIC ORIGIN
4ge;48 to 48
Clothing/Description:
Contact Information
Home Phone #: (904)-887-4597
Bus. Phone #:
Cell Phone #:
Cell
Phone Provider:
Email Address:
Home Address
Mailing Address
653 MONUMENT RD BLDG11, #1102
JACKSONVILLE, FLORIDA
Sub-sector: D3 TAZ: 626
Additional Information:
Ext.:
Alt. Phone #:
Alternate Address
DID NOT HEAR OR SEE ANYTHING
Investigation Time #1
Hour(s): 03
Minute(s): 00
Cost Amount: $43.38
Signature
Detective Called To the Scene:
Division:
Evidence Technician Called to the Scene:
Signature(s)
Reporting Officer #1
Reporting Officer #2
Report submitted on
Report Reviewer. ■
Report approved on:
Page 5 of5
Unit:
At Scene: Not Applicable
D.M.GRAY (#5692)
M.J.MEISSNER (#7323)
L.A.LOPEZ( #67833)
06/26/2010 20:20
M.B.MILLER (#5393)
06/26/2010 20:22
At Scene:
Division: PATROL
Division:
Section/Unit: ZONE 2
Section/Unit:
Status: Approved
15:59 byJ.L. BUTLER (*661971
Sheriff John H. Rutherford
A'll
2010-049774?.
c
c
JACKSONVILLE, FLORIDA 32206
examination report
name OF DECEASEDM.E. NO.:
DATE OF DEATH:
DATE OF AUTOPSY:
TIME OF AUTOPSYCOUNTY OF DEATH:
DAVIS, Dorelle D.
16-1420
Found July 12,2016
July 13,2016
10:00 AM
Duval
external examination
h teS Tta body iTto'ai'Sy to mS8 ',2S P0U"dS (S7 ks>
ss; “zradu,t
">™“ring 62 inches 1157 cm)
^ n*
rapy. The clothing
EVIDENCE OF INJURY:
GUNSHOT WOUND OF THE HEAD:
inches below the top of the head^d^ hJches^o* the^Ieft
W°Und located 4 1/2
wound is a 3/4 inch x 1/2 inch defect l/16<h inch m»r -ft
Postenor midiine of the head. The
soot or gunpowder stippling deposition on the sum3ninoa!lraS,0^COuar- There is no evidence of
and subcutaneous tissue and entere the skull throueh a f/?kn',,Theib/!JI,et goes throu8h ‘he skin
bevel,„g ,„to toe left temporal occipital bone. ITtobote thin ,1^ m
J1Ch **“ witl> i"™d
the brain, basal ganglia, right temporal lobe of the brain rioh, ,* Um>u6h Il,e *eft temporal lobe of
tough a 1/2 inch x 1/2 inch defect whh ou^ teveltoi
"T'■i “»■ “»■
SSSSSSS'J'-rSyi?'>"' *
Direction of
wound path, there
A'U
c
2 MEDICAL EXAMINATION
ME#: 16-1420
c
DAVIS, Dorelle D.
INTERNAL EXAMINATION:
HEAD:
calvarium oflhe?MnrSv^Ce^i^,f’^" i!!!81” 842 granK- ^ KalP is reflected. He
sections through the brain stem and cerebellum are u^emaSe!* V deSCnbed mjunes- Tra"sverse
NECK:
reveals no abnomalities^Thy^
thyroid S,and and large vessels,
BODY CAVITIES:
adhesions or abnomiU^olIecdoM offldd^present 'nCiSi°n p"h **“ ChCSt p,atC *S removed< No
are present in the noimal anatomic posC^rS is™ intern ^y.“vities*,A1l body
penetrating injury to the thoraco-abdominal regjevidence of blunt force or
on.
CARDIOVASCULAR SYSTEM:
£
rxr sr,h-giistenins- -
follow the usual distribution and are widelv uatent w-,h°n!' ^ coronary a^enes arise normally,
or thrombosis. The chambers and valves exhihii th out ey,dfnce of significant atherosclerosis
unremarkable. The myocardium is red/hmum
j USLUd s,ze‘Poslti°n relationship and are
septa are intact. £e aor^
.and unre^ble. The atrial and ventricular
widely patent, free of significant atherosclerosis andTnih110^ ^ f?I,OW the UsuaJ course md “«
major tributaries return to the heart in the usual distribute! mtZTfe!^ofSTromH
“* **’
RESPIRATORY SYSTEM:
M£££25 m£££
307
^ -W-
tutenes are nonnally developed, patent and without thtombus or emtoilL
is Cent of
pulmonary
HEPATOBILIARY SYSTEM:
The liver weighs 1029 grams. The hepatic capsule is smooth, glistening and intact
covering
friable parenchyma with no focal lesions noted. The gallbladder is emotv The mimnc
■ yellow,
i
and unremarkable. He extmhepatic biliary nee is patent, without eviden^of^cT
*
c
c
MEDICAL EXAMINER REPORT
NAME OF DECEASED:
M.E. NO.:
DATE OF DEATH:
DATE OF AUTOPSY:
TIME OF AUTOPSY:
COUNTY OF DEATH:
DAVIS, Dorelle D.
16-1420
Found July 12, 2016
July 13,2016
10:00 AM
Duval
DIAGNOSIS
0)
(2)
(3)
Gunshot wound of the head with multiple skull fractures, subarachnoid hemorrhage,
cerebral lacerations, and recovery of a copper-jacketed bullet
Hepatic steatosis
Polycystic kidneys
CAUSE OF DEATH
Gunshot wound of the head.
MANNER OF DEATH
Homicide.
Aurelian Nicolaescu, M. D.
Associate Medical Examiner
Date: 8/8/2016
AN:bb
a
Accredited by the National Association ofMedical Examiners
c
J
3 MEDICAL EXAMINATION
c
ME#: 16-1420
DAVIS, Dorelle D,
GASTROINTESTINAL SYSTEM:
“ 'ined by gray/Whi,e’ smooth
and the lumen contains no gastric
^ * "°m’al phltta
contents. The small and large bowels
6
lobulated appearance and the ducts are clear/ITteappemfa is
GENITOURINARY SYSTEM:
^handto! sT^fpaSTid^^w-r
293 *““• Tt’'
capsules are
cortical surfaces. The polycystic cortices aiedelinenimf?*6
^ Underlyin8 P°*ycystic, brown
The calyces, pelves, L umlers aT™re^S^^'lJd“'la,T
««<* ■» Ian.
gray/lan and smooth. The uterus weighs "t^nmSabt^ " CraPly' ^
“
ovaries.
RETICULOENDOTHELIAL SYSTEM:
The spleen weighs 228 grams and has
a smooth, intact capsule covering dark brown mushy
parenchyma. The lymphoid follicles are unre
markable. The regional lymph nodes appear normal.
ENDOCRINE SYSTEM:
The pituitary, thyroid and adrenal glands are unremarkable.
MUSCULOSKELETAL SYSTEM:
Muscle development is normal. No bone or joint abnormalities are
noted.
HISTOPATHOLOGICAL EXAMINATION:
Gunshot entrance wound: disrupted tissue architecture, with thermal alterations and autolytic
TOXICOLOGICAL EXAMINATION:
Testing performed at NMS labs. See attached NMS Labs Toxicol
ogy Report.
NMS
LABS
c
C\
NMS Labs
Inlegrated Forensic Services
x. •
» ..
North Jeffaraon Slreel, Jacksonville, FL 32206
e-mBH: JAX@nmslabs.com Phone: (215) 657-4900 Fax: (215)657-2073
SM&atf"
Robert A. Middleberg, PhD, F-ABFT. DABCC-TC, Labo ratory Director
Toxicology Report
Report Issued
To:
Patient Name
Patient ID
Chain
07/27/2016 16:00
Age 39 Y
Gender
Workorder
10072
DAVIS. DORELLE
161420
16213241
DOB Not Given
Female
LbeiBEHl
Page 1 of 3
Jacksonville, FL 32206
Positive Findings:
Sflmppund
Ethanol
Delta-9 THC
Result
Units
Matrix Soiirr^
86
22
mg/100 g
ng/g
002 - Liver Tissue
002 • Liver Tissue
See Detailed Findings section for additional Information
Testing Requested:
Analysis Code
805rfi
Description
Postmortem, Basic, Tissue (Forensic)
Tests Not Performed:
sPeacrlionfar0dfeSlseqUeS,ed ,eS,'n9 W3S Unab'B'° be performed-
Refer to the Analysis Summary and Reporting Limits
Specimens Received:
ID
Tube/Container
001 White Plastic Container
002 Homogenate Container
003 White Plastic Container
004 White Plastic Container
Volume/
Collection
Mass
Date/Time
32.36 g
Not Given
63.57 g
07/13/2016 10:40
07/13/2016 10:40
07/13/2016 10:55
07/13/2016 10:45
39.18 g
Matrix Source
Miscellaneous
Information
Liver Tissue
Liver Tissue
Brain Tissue
Kidney Tissue
All sample volumes/weights are approximations.
Specimens received on 07/14/2016.
NMS v. 16.0
CONFIDENTIAL
Workorder
Chain
Patient ID
.
UBS
|
1621 |?-M.
1621
/
161420
Pago 2 of 3
Detailed Findings:
Rpt.
Analysis and Comments
Result
Ethanol
86
Delta-9 THC
Ethanol
22
mg/100 g
ng/g
Confirmed
mg/100 g
Units
Limit
Specimen Source
Analysis By
40
002 - Liver Tissue
Headspace GC
2.0
40
002 - Liver Tissue
002 - Liver Tissue
LC-MS/MS
Headspace GC
«
toKlcoIoglcaUIgn^flcance'by^roce'durQs Outlined
p““h"
Reference Comments:
1.
Delta-9 THC (Active Ingredient of Marijuana) - Liver Tissue:
££££££& Ko." <*»*“**• **“"«
2.
marijuana/hashish. DalB-^oxy-THO (THCC) Is lha
Ethanol (Ethyl Alcohol) - Liver Tissue:
Sample Comments:
001
Tissue specimen required homogenization: 16213241-001
002
NMS Labs generated homogenized Tissue sample: 16213241-002
002
Select testing may have been performed at: 3701 Welsh Road. PO Box 433A, Willow Grove, PA 19090-0437
Workorder 16213241 was electronically
signed on 07/27/2016 15:51 by:
Matthew M. McMullin, M.S., F-ABFT, TC (NRCC)
Forensic Toxicologist
Analysis Summary and Reporting Limits:
Findings section of the report for those compounds that were identified as being present"9 Lim'1’ P,ease refer lo ,he Posi,ive
Acode 50013TI - Cannablnolds Confirmation, Tissue (Forensic) - Liver Tissue
-Analysis by High Performance Liquid Chromatography/
TandemMass Spectrometry (LC-MS/MS) for:
Cnmpnqrcfl
Bol. Limit
N/A
N/A
Not Reported: DeteJStK'J’T™'
11-Hydroxy Delta-9 THC
Delta-9 Carboxy THC
Comnniinrl
Delta-9 THC
Bp.1. Limit
2.0 ng/g
Acode 52250TI - Alcohols and Acetone Confirmation, Tissue (Forensic) - Liver Tissue
NMS v.16.0
ANMS
CONFIDENTIAL
\
LABS
Workorder
Chain
Patient ID
W2W1
1621^ i
161420*
Pago 3 of 3
Analysis Summary and Reporting Limits:
-Analysis by Headspace Gas Chromatography (GC) for:
Comnnnnff
Acetone
Ethanol
Acode 8051TI - Postmortem,
Rot. Limit
Comnonnff
20 mg/100 g
Isopropanol
40 mg/100 g
Methanol
Basic. Tissue (Forensic) - Liver Tissue
-Analysis by Enzyme-Linked Immun
Compound
Amphetamines
Barbiturates
Benzodiazepines
Buprenorphlne / Metabolite
Cannabinolds
Cocaine / Metabolites
Comnnugd
20 mg/100 g
20 mg/100 g
osorbent Assay (ELISA) for:
Rot. I.imlf
BOng/g
0.16 mcg/g
400 ng/g
2.0 ng/g
40 ng/g
80 ng/g
Comnnunr|
Fentanyl / Metabolite
Methadone / Metabolite
Methamphetamlne / MDMA
Opiates
Oxycodone / Oxymorphone
Phencyclidine
Analysis by Headspace Gas Chromatography (GC) for:
Acetone
Ethanol
Rpt. Limit
Rpt. I lml[
Comnnimr|
20 mg/100 g
40 mg/100 g
Isopropanol
Methanol
Rpt. Llmll
1.0 ng/g
100 ng/g
80 ng/g
80 ng/g
40 ng/g
40 ng/g
Rpt. Limit
20 mg/100 g
20 mg/100 g
NMS v.16.0
G
ME#: 16-1420
Name: Davis, Dorelle D.
Age: 39 years
Height: 62 in.
157 cm.
c:
MEDICAL
EXAMINER’S
OFFICE
Race: W
Sex: F
Weight: 1261b.
57 kg.
Date: 07/13/2016
Time:(,<9: Q&
Doctor: Nicolaescu
Diagnosis:
Of——
Autopsy.'
Inspection:! ]
Manner:
16
•— D 0
er-\ /V
—1Q§)
\
' 6"SF \ ^ fifty
Brain:
Heart:
Lungs: R.
Fluid Pleural: R. *~*\ ~L.
fe>
!
Uterus:
Stomach:
Pericardium:
Fluid Peritoneum:
us
ME#: 16-1420
Name: Davis, Dorelle D.
MEDICAL
EXAMINER'S
OFFICE
Age: 39 years
L
Date: 07/13/2016
Doctor: NicoIqcscu
£eport of Investigationc
)
ME Number
ILaw EnforcemBnt NumbBr:
---------
| Reason for jurisdiction: Homicide
ME
Notified
Date
Time
4:30 AM
07/13/2010
00453875
I
Investigator: Kammer
j ME Oeslgnee:
(By whom: Name, Address or Title)
Agency:
Det. Scott
JSO/Scott
i
Decedent Information
Name: Davis, Dorelle Dawn
Age:
Address: 3050 Detroit Cir, Jacksonville, FL, 32254
39 years
Race:
Date of Birth: 07/30/1976
Height: 62 In.
On the Job? N
Occupation:
DATE
TIME
found
found
07/12/2016
9:10 PM
F
Weight: 1261b.
Industry:
by:
LAST SEEN
ALIVE
POLICE
07/13/2016
NOTIFIE_______
Found by: Palro,
Rescue at scene?
Name of Doctor
or Institution
LOCATION
3050 E Detroit Clr, Jacksonville, FL, 32254
2100 West 26th St, Jacksonville, FL, 32209
PRON DEAD
COUNTY
PREMISES
Duval
Residence-Home
Duval
Grounds-Woods
at:
by:
9:10 PM
^
by: Alfonzo Walker
Rescue or Engine #:
Type of hospital death: None
Medical Attention and Hospital or Institutional Car
e
N
Address
Diagnosis
Date:
Next of Kin and Identification
Name
Identified? Y
Address
by:
Address
Deidre Waters
ID Date: 07/13/2016
If
Child
Sex:
Occurrence Information
ITEM
INJURY OR
ONSET OF
ILLNESS
DEATH OR
FOUND
Notified?
W
Phone:
Bom premature?
501 E Bay Street, Jacksonville, FL
ID Time:
3:07 PM
Weapon Type 1: 380 auto
Weapon Type 2:
Relationship
Phone
Relationship
(904) 630-2212
None
ID Location: JSO-AFIS
Additional Information
Twin?
Hospital of Birth
Weeks gestation
Victim Type
none
Phone
Restraint type
City of Birth
Vehicle Type
l
?
Charges
(
G
Report of Investigation
/
Law Enforcement Number
ME Number
ME
Notified
00453875
Reason for jurisdiction: Homicide
Date
07/13/2016
Investigator Kammer
ME Designee:
Time
(By whom: Name, Address or Title)
4:30 AM
Agency:
Det. Scott
JSO/Scott
Decedent Information
Name: Davis, Dorelle D.
Age:
Address: 3050 Detroit Clr, Jacksonville. FL, 32254
39 years
Race:
Sex:
F
Phone:
Date of Birth: 07/30/1970
Height: 62 in.
On the job? N
w
Occupation:
Weight: 1261b,
Industry:
Occurrence Information
ITEM
INJURY OR
ONSET OF
ILLNESS
DEATH OR
FOUND
DATE
TIME
found
found
07/12/2010
9:10 PM
PRON DEAL
location
COUNTY
3050 E Detroit Clr, Jacksonville, FL, 32254
PREMISES
Duval
Residence-Homo
2100 West 261h St., Jacksonville, FL, 32209
Duval
Graunda-Woods
by:
LAST SEEN
ALIVE
at:
by:
POLICE
07/13/2016
NOTIFIE
Found by: Patro,
Rescue at scene?
9:10 PM
N
by: Alfonzo Walker
Rescue or Engine #:
Type of hospital death; None
Medical Attention and Hospital or Institutional Care
Name of Doctor
or Institution
Address
Diagnosis
Date:
Next of Kin and Identification
Notified?
N
Identified? N
Name
by:
ID Date:
ID Time:
Address
Phone
Relationship
Address
Phone
Relationship
ID Location:
Additional Information
If
Child
Bom premature?
Twin?
Hospital of Birth
Weeks gestation
Victim Type
none
Weapon Type 1: 380 auto
Weapon Type 2:
Restraint type
City of Birth
Vehicle Type
Charges
c
C
^^SSaap
Name:
ME Number:
_______
SCENE INVESTIGATION
DorelJe, Davis D.
16-1420
July 13,2016
Office reporting the'drath^lhij3K^^oldthL^'
honnerfe. I responded and arrived on L^e eU^ S.
W'lh thc Jadc“>"ville Sheriffs
Tto
*S beln* «ated as a
ST'^3^on w tede"dresides 31 3050 Detrait
^d^e^S, ““
S„
'unkncwn'howcvcTtfie
hfd to bcSv'" her‘ Subs^”"“y. the boyfiiend adS to jsoT1 ^ the boyfrie"d "hete
no. respond" * W00ded ""l0cate1' “ 2100 Wes, 26* S,..
“d
SH£'w=~
is—-
many rounds
was not yet analyzed upon my
WMiWmms
was
Whl,e Sh“'- ™s investigator
"* ^ W“ P'-edlnl^
Horida “
Robert M. Kammer
Forensic Investigator
M.
InvcMluti
!• 0. NiimliiT .SiijicrviMir
Jcfirtyj. liroiu^------------
Page 1
ilWlISlL’ IlIVLKtl,........... f
c
c
OFFICE
OF THE MEDICAT, ffYAMjiy^p
2100 Jefferson Street • Jacksonville. w. rnn«
1VLU^^K
* t90**) 255-4000 • fax (004) 630-0064
FOLLOW-UP INVESTIGATION
Name:
ME Number:
Davis, Dorelle D,
16-1420
August 3, 2016
4°818“5^^
-is decedent, Jamie Limandn (siste,
however there was no answer therefore a voieemnil'1 ^ proceedl"S with funeral arrangements,
the MEO. On this date at I 02 pm 1 left a cerS message
,eft requesting that she contact
contact the MEO.
P *
d message for the decedent’s sister, Jamie, to
,l": decedent will then
be
contact information*fonhedMedTnfsMiy0 ,nqU,rC “ t0 WhCther °r "0t he had ^ additional
Wendy Meacham, F-ABMDI
Forensic Investigator
,'M. ir>llUt:slljjiiUir
I. U. NiiiiiIilt
Knpcrvisiir
Page 2
irz*
JcITrcyJ, Urukuw
jlMiyinfe lilvalliiuiliiiis Manama
&W)\7 &$0)
0”,SMSc7I"»JSHER,r
_______ _
Duval C o u n t y
501 .East Bay Street •
Jacksonville, Florida 32202
-2975
Mike Williams
Sheriff
April 24, 2018
Percy Stucks
2016018775 500 East Adams St
Jacksonville FL 32202
RE: Public Records Request of April 20, 2018, Reference # P071070-042018
Dear Percy,
JacksonviUe Sheriffs Office received a nnhlio records re
^requested the following:
11 ■
■guest from you on April 20, 2018. You
casc
of OfficerM.P. Chizik #7471 &.<?.
Wells #61130
After a diligent search we have determined that the records
requested are exempt from disclosure
for the folioowing reasons:
J^L£E°£iy°u_have requested is exempt at this time
'ursuant to 'ending investigation.
-f-hank you for y°ur Patience in awaiting this information.
Sincerely,
74868TCD
PRC
Public Records
WWW.JAXSHERIFF.ORG
*
1
First Appearance;
Continued:
Continued:
Continued:
Continued:
Continued:
Continued:
Continued;
Continued:
Continued:
Arrest And Booking Report
Jacksonville Sheriffs Office
Jacksonville Florida
rr 2016 me #206667
Amend b
Prev Juv Jail it
Jail it
ADULT
2016008478
4/1/2016 01:23
jso id a
Court: County
SSN
Arresting Agency: Jacksonville Sheriffs Office
Day/Date/Time Arrested: Friday 4/1/2016 00:45
OBTSH
Route To:
\S
Name: DAVIS, DORELLE DAWN
Aliases:
Arrestee's Home Address: 888 FRANKLIN ST Apt./Lotb.314
City JACKSONVILLE state. FLORIDA Zip: 32206
Taz: 768 Crossstreel:
Age:
*** --
tc
fcfUSOF r-
Nickname(s):
DOB: 7/30/1976
File Direct: NO
O
^ O ?
2 5 2
Sub-Secto
OC deployed prior tok
39
5* 2"
Weight (lbs): 110
Race: WHITE Ethnicity: NOT OF HISPANIC ORIGIN Sex Female
Height:
w O i
7)
?b
m
o
r
r* w
m W
o 2
NJ
>
>
2m 2
§
z ><
b
o
Eye Color: BLUE Hair Color: BLONDE/STRAWBERRY Complexion: FAIR / LIGHT Build: Thin
ECD Usage: NOT APPLICABLE
RTR written related to this incident? NO RTR Incident Yr: RTR Incident b:
Is an Offense a hate crime? NO Is an Offense a dating violence crime? NO Required to register as a sex offender? NO
Suspect Invoke Miranda? NO Arrestee needs ADA Consideration? NO Arrestee Confessed? Miranda Rights Given? NO
Disability or Special Consideration:
2
>
00
Si
00
s-n
Accommodations Requested:
Driver's License it D120164767700 State: FLORIDA Subject's Resident Type: CITY
Hm Phone b Bus. Phone b Phone Ext.
Cell Phone it Cell Phone Provider E-mail
Is Vagrant? NO
Arrest Made On: CALL
Subject's Residence Status: RESIDENT Armed With: NOT APPLICABLE (NONE)
Distinguishing Marks:
Employer: NONE Place of Birth: JACKSONVILLE DUVAL FLORIDA UNITED STATES Country of Citizenship- UNITED STATES
School Last Attended: UK
;
US Citizen: YES
Children under 18 Present:
If No is it Domestic Related: NO |
Day/Date/Time ofIncident-Front: Friday 4/1/2016 00:17
Day/Date/Time ofIncident-To: Friday 4/1/2016 00:45
Incident Address: 888 FRANKLIN ST Apt/Lot bSub-Sector: B3
I Domestic Violence Involved: NO
Go-JACKSONVILLE state-FLORIDA Zip. 32206
Taz: 768 Crossstreet:
Offense Location Type: Apartment / Condo Interviewed by:
Where Arrested: 888 FRANKLIN ST AptJLol it:
City JACKSONVILLE State: FLORIDA Zip. 32206
Taz: 768 Crossstreet:
Involved in Traffic Accident: NO
Injuries from Accident:
l
Interviewer ID:
Sub-Sector: B3
Is Incident Gang Related: NO
Is Arrestee a Gang member? NO
Statute or Ordinance Number(s): #1
Statute No: 856.011 (2) Degree. M2 UCR Code: 900C Attempt Code: Commit
DISORDERLY INTOXICATION - PUBLIC DISTURBANCE
4/1/2016-01:19
Citation b
SAb
Warrant Type: Not Applicable
Jso Control b
Warrant/Case b
No. of Counts:
ADLT
DA VIS. DORELLE DA WN
ARREST REPORT
Pglaf4
Jail b 2016008478
3
E&
ArbO
ADLT|
X
Jurisdiction:
CT. Localion/Div.:
Purge/Bond Type: Bond
Bond Amount:
Date ofIssue:
Date ofReturn-
Judge:
Disposition:
Disposition Date:
Blanket Bond:
VOP/FTA ONLY
Original Statute No:
Degree:
UCR Code: Attempt Code: Commit
Description:
Statute or Ordinance Number(s): #2
Statute No: 843.02 Degree M1 UCR Code: 9000 Attempt Code: Commit
RESISTING OFFICER WITHOUT VIOLENCE TO HIS OR;HER PERSON
4/1/2016-01:19
Citation #
SA#
Warrant Type: Not Applicable
Jso Control t)
Warrant/Case ti
Jurisdiction:
Purge/Bond Type: Bond
2W
Bond Amount:
Disposition:
No. ofCounts:
CT. Location/Div.:
Date ofIssue:
Date of Return:
Judge:
Disposition Date:
Blanket Bond:
VOP/FTA ONLY
Original Statute No:
Degree:
UCR Code: Attempt Code: Commit
Description:
ADDITIONAL INFORMATION
1
Reporting Officer: D.L.HODGES 74025
On 4/1/2016, at 0017 hours, I was dispatched to 888 Franklin St in reference to a drunken dispute.
Upon my arrival, I observed Cassy Donacin (wit 1) the security guard at the apartment complex escorting the
suspect down the hallway. The suspect was extremely intoxicated and uncooperative. As Ofc Carmona 64386
made contact with the suspect she began yelling obscenities at him and refused to place her hands behind her
back by tensing her arms and pulling away. The suspect was forced into hand restraints and placed in the back
seat of Ofc Carmona's patrol vehicle.
Cassy advised that he was called to the disturbance by Sheila Doyle (wit 2). As he showed up he observed the
suspect yelling at Sheila and lunging at her in an attempt to fight her. Cassy grabbed the suspect and held her
while Sheila called the police.
Sheila advised that the suspect has been drinking all day and that she has been causing a disturbance by
banging on her walls and door. She said she opened her door to ask the suspect to be quiet when the suspect
became extremely aggressive. The suspect started screaming at Sheila and lunged at her, at which point the
security guard grabbed the suspect to prevent a physical confrontation.
While the suspect was in the back of the Ofc Carmona's patrol vehicle she continued to scream and began
kicking the door. The suspect was advised that if she continued to kick the door she would be placed in hobble
restraints. The suspect continued to kick the door. She was placed in hobble restraints and immediately
transported to the PTDF without further incident.
Sgt H. Baker IV 65049 was notifed,
ADLT DA VIS. DORELLE DA WN
ARREST REPORT
rn2 oj 4
Jail H 2016008478
ADLT
fransBondH By: D.L.HODGES #7402$^^
Approving Supervisor: H.BAKER #@^g^
Arresting Officerfs) HI: D.L.HODGES #74025
H2: A.CARMONA-FONSECA #64386
Div/Zotic or Unit: PATROL ZONE I
ti of Cases Cleared:
State ofFlorida, County ofDuval
Arresting I Transporting Officer's Signature:
Personally Known
—iHcnc,
j
$y>CSS, 20(f) . by
Sworn to (or affirmed) and subscribed before me this
c?f>,’roduced Identfication____ Type ofIdentification produced:
MJll\
Print, Type, or Stamp, Commissioned name of Notary Public
Signature e)'/Votary - State of Florida Certified Law Enforcement Officer or Corrections Officer:
Investigative Time:
#1 Hours: 1
Minutes: 0
Drug Activity: UNKNOWN
Alcohol Related: SUSPECT USING ALCOHOL
Cost Amount: $48.24
Drug Type: UNKNOWN
Drug Related: UNKNOWN (OR N/A)
COMPLAINANT #1
Race BLACKS/,nicity. NOT OF HISPANIC ORIGIN
Sex: Male
DOB: 4/7/1985
Age: 30
Name: DONACIN CASSY LOVE
Address: 4731 MONROE SMITH RD AptJLot ft:
City: JACKSONVILLE state. FLORIDA Zip: 32210
Taz: 540 Crossstreet:
Home Phone ft (904)-380*1074 Bus. Phone If Phone Ext.
Cell Phone # Cell Phone Provider E-mail
Is Vagrant? NO
Sub-Sector ofArrest Location: L2
WITNESS #2
Race: WHITE Ethnicity: NOT OF HISPANIC ORIGIN
Sex: Female
DOB. 10/14/1965 Age: 50
Name. DOYLE SHEILA MARIE
Address: 888 FRANKLIN ST Apt./Lotff: 324
City: JACKSONVILLE State: FLORIDA Zip: 32206
7VI2.-768 Crossstreet:
Home Phone if (904)-672-0430 Bus. Phone it Phone Ext.
Cell Phone ft Cell Phone Provider E-mail
Is Vagrant? NO
Jail Information (Back Door)
JaU tf 2016008478
Triage Questions:
Sub-Sector ofArrest Location:
Date and Time Admitted: 4/1/2016 01:23
Juvenile/Court Clerk U
Involved in Traffic Accident: NO
Injuries from Accident:
OC deployed prior to/during Arrest: NO Was a hobble restraint used on the arrestee? YES
Does the arrestee exhibit any signs ofsuicidal behavior or attempts? NO Does the arrested have any observable medical/mental health problems? NO
Has the arrestee shown any escape potential or violence propensity behaviors? NO
Is there any other information about the arrestee that jail personnel need to know? NO
Ifyes, what?
Part II ofArrest And Booking Report:
Arrestee Personal Information: How Long in Jax? ^
S3
fcDLT DA VIS. DORELLE DA WN
v
ARREST REPORT
Pg3 of 4
Jail ft 2016008478
ADLT
^gftion By:
4
1'
•
Chemical^ast Data
■
■*»
Specimen:
None
Breath
Urine
1st
g/HOI.
TIME:
Blood:
2nd
gf2tOL
TIME:
Urine:
Srd
gGIOL
TIME:
Breath:
Blood
Unable
Refused:
Analysis Results:
Breath Test Instrument:
Type:
Machine tt
Operator Name and I.D.ti
Date:
sAD LT DA VIS. DORELLE DA WN
ARREST REPORT
Pg 4 of 4
Jail H 2016008478
ADUT
Ronnie Fussell
Clerk of Circuit Court
/
ADD ON DOCKET
Date:
1,2016
Judge:
MOSE FLOYD
Q^LW/H ABJ.+5LEEA-*__ COST+50CC L+60LGTF
+3TNC+__ DOBS+__ CHT+50SOCIF+Q5AACC+ 20
50SAIEF+__ RCTF+__ SRS Sl0O|\lcM1O6 TO PAY
____ MOS.PROB.SAL.ARMY ‘
V
CONDS
VOlTv
P/A:
SHELDON FORTE
IN THE CIRCUIT COURT, FOURTH
JUDICIAL CIRCUIT, IN AND FOR
DUVAL COUNTY, FLORIDA
STATE OF FLORIDA,
Plaintiff,
VS.
CASE NO.: 16-2016-CF-6391
DIVISION: CR-B
PERCY ALLEN STOCKS,
Defendant.
/
MOTION TO INCUR COSTS FOR TRANSCRIPTS
COMES NOW the Defendant, Percy Allen Stucks, proceeding pro se, and
hereby respectfully moves this Honorable Court for its Order incurring costs for
transcripts taken on the following dates and in furtherance thereof Defendant will
show:
1).
I.
March 05, 2018 “Stand Your Ground Hearing”
II.
March 04, 2020
Defendant is pro se, and the court has previously found Defendant indigent
for costs.
2).
Defendant needs the aforementioned transcripts to assist in preparing an
adequate defense.
3).
Defendant request authorization for the fees established by law for a court
A-3/
reporter in this matter.
WHEREFORE, Defendant requests this Court enter an order authorizing
Defendant to incur costs for the aforementioned transcripts as set forth above.
Respectfully submitted and served,
/s/
Percy Allen Stucks, Appellant, Pro se
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I provided a true and correct copy of the
foregoing in to the hands of a jail official for mailing to the Office of the State
Attorney, 311 W. Monroe Street, Jacksonville, FL 32202 and to the Duval Clerk of
Court on this 21th day of April, 2020.
Is/
Percy AllemStucks, Appellant, Pro se
Jail No.: 2016081775
Duval Pretrial Detention Facility
500 East Adams St.
Jacksonville, FL 32202
/
/;?
Filing # 107227599 E-Filed 05/08/2020 10:19:56 AM
;
IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT
IN AND FOR DUVAL COUNTY, FLORIDA
STATE OF FLORIDA,
CASE NO.:
2016 CF 6391
v.
PERCY ALLEN STUCKS,
Defendant.
JUSTICE ADMINISTRATIVE COMMISSION’S RESPONSE
TO MOTION TO INCUR COSTS FOR TRANSCRIPTS
COMES NOW, the Justice Administrative Commission (“JAC”), by and through the
undersigned attorney and files this response to the above-cited motion as follows:
The Defendant is seeking authorization to incur costs to transcribe two hearings held in
1.
this matter.
2.
JAC can only pay due process costs pursuant to sections 29.007, 27.40, and 27.5304.
3.
As directed by section 27.425, Florida Statues and the General Appropriations Act, all
due process services should be subject to the Florida Statutes and the JAC contract, policies and
procedures. JAC objects to any compensation rate in excess of established rates.
4.
As for transcripts, JAC has no objection to regular paid rates. The Defendant should
only order those transcripts necessary for defense of the case.
5.
■
The uniform statewide rates are set forth in the General Appropriations Act. Court
reporting services cannot exceed these rates.
6.
If any due process providers desire direct payment, the JAC’s policies and procedures
require the vendor to execute the appropriate contract and follow JAC’s billing and audit
procedures to obtain payment.
•• r
1
A-n
7.
JAC does not request to participate in any hearing set on the motions. Should the Court
desire additional input, JAC may be reached toll-free at (866) 355-7902.
WHEREFORE, the JAC requests this Court, should it grant the Defendant’s motion,
also include in its order the specific due process services authorized, as well as hourly or per unit
rates and maximum fees approved, and that the provider be paid in accordance with rates, terms
and conditions set forth by Florida Statutes, and the JAC contract, policies, and procedures.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been sent by facsimile
email, and/or U.S. Mail on this 8th day of May, 2020 to:
Percy Allen Stucks (Legal Mail)
No. 2016-18775
Sent via U.S. Mail
Respectfully submitted,
ANA CRISTINA MARTINEZ
GENERAL COUNSEL
/s/ Christian D. Lake
CHRISTIAN D. LAKE
Assistant General Counsel
Justice Administrative Commission
227 North Bronough Street, Suite 2100
Tallahassee, FL 32301
Tel.: 850-488-2415
pleadings@justiceadmin.org
Florida Bar No.: 0134831
2
Ml
Division of Licensing
(850) 245-5500
(850) 245-5353 Pax
Post Office Box 5647
Tallahassee, Florida 32314-5647
4040 Esplanade Way, Suite 135
Tallahassee, Florida 32399
rJ
Florida Department of Agriculture and Consumer Services
Commissioner Nicole "Nikki” Fried
January 28, 2019
Mr. Percy Stucks Jr.
#2016018775
500 East Adams Street
Jacksonville, FL 32202
Dear Mr. Stucks Jr.:
In response to your public records request, enclosed is a copy firearms training certificate for
your Concealed Weapon or Firearm License W 1579081 pursuant to Section 790.06, Florida
Statutes.
Pursuant to Section 790.0601, Florida Statutes, the personal identifying information of an
individual who has applied for or received a license to carry a concealed weapon or firearm is
exempt from Section 119.07(1), Florida Statutes and Section 24(a), Article 1 of the State
Constitution (the Public Records Law). Accordingly, the information contained in this
correspondence is provided to you as the licensee.
Please call me at 850-245-5459 or email me at DOLPublicRec@FreshFromFlorida.com if you
need further assistance.
Sincerely,
Ashley Temes
Records Analyst
Enclosure
1-800-HELPFLA
Florida.
www.FreshFromFlorlda.com
A'b 3
wnai is r i au: i reatmeni ana neanng jor survivors
severe fca.uoiei can be very difficult New .
rage J or 10
How to Find Healina in
brain rJS ggj feRifewSo^f<http://bnokelanda®lgS
survivors provides important insights for
treatment and hope.
er Tra
uma (http://brickelanda
ssociates.com/healina-r
elationships-after-traum
What Does PTSD Feel
Like, and Who Can
i
Experience It?
We often think of PTSD as a risk for
soldiers, for people fighting in war, or
Jhose doing military service. Although it fc
a risk for them, PTSD can develop from
.any event that feels overwhelmingly^
threatening or scary to the person
aH
Do vou use drugs and a
Icohol to manage vour
emotions? (httoV/brickel
andassociates.com/usi
ng-druqs-alcohol-mana
ge-emotions-treatina-ad
dicts-as-people-in-oai
M
. involved. It can happen to anyone, at any
age, at home or anywhere.
Domestic violence, rape, child abuse and
neglect, terrorist attacks, natural
disasters, car accidents — these are iust
a few of the traumas that can lead to
PTSD^ It can also come from events that
appear far less dramatic — such as
ongoing bullying, a playground accident,
or a medical procedure during childhood.
It is important to recognize the myth that
only obviously life-threatening events
carry the risk of PTSD. Rather, PTSD is
the result of the reactions and/or
perceptions of the person traumatized.
The difference between PTSD and other
types of traumatic experiences is that
unwanted symptoms stay; they keep
returning and intruding on one’s present
awareness.
http://brickelandassociates.com/what-is-ptsd/
More on these topi
cs:
Addiction Treatment an
d Recovery (http://brick
elandassociates.com/c
ategorv/addiction-treat
ment-and-recoverv/)
ADHD (http://brickeland
associates.com/cateaor
v/adhd/)
Adolescents (htto://bric
kelandassociates.com/c
ateaorv/adolescents/)
Patina Violence (http://
brickelandassociates.co
m/cateaorv/datina-viole
nee/)
Depression (http://brick
elandassociates.com/c
ateqorv/depression/)
I v
6/1/2017
wiiat is
SD: Ireatment and Healing for Survivors
Page 4 of 16
(
v
Wh^rlaEenym^a~nTOtp://brickelanda^|ei^.^^nCefhn
Signs and Symptoms of
P^ncVeiandassociate
pygQ/p
sxom/category/domesti
c-violence/1
. PTSD is a specific kind of stress-related
Mental Illness (http://hri
disorder, diagnosed by mental health
ckelandassociates.com/
care professionals using a standard
guidebook, known as the DSM.
categorv/mental-illnes
s/1
No words can describe the debilitating
impact of severe trauma on survivors. But
Mental Illness Stigma
(http://brickelandassoci
ates.com/cateaorv/man
a diagnosis can help people with PTSD
seek appropriate treatment,
The DSM lists four clusters of symptoms:
tal-illness-stiama/i
Postpartum Depression
PPD (http.V/brickelanda
ssociates.com/categnr
y/postpartum-depressin
n-ppd/V
^Flashbacks
* Avoidance
PTSD (http://brickeland
-* Negative thoughts and Teel ings
• Hyperarousal
associates.com/cateqor
v/ptsd/1
Flashbacks
Flashbacks are the reactivated
memories, sensations, and emotions that
make a life-threatening or perceived
threatening or frightening experience
seem to be happening again. “Trauma
continues to intrude with visual, auditory,
and/or other somatic reality on the lives
of its victims,” explains psychologist
Babette Rothschild in her bestselling
book The Body Remembers. “Again and
again they relive the life-threatening
experiences they have suffered, reacting
in mind and body as though such events
were still occurring.” Flashbacks may
http://brickelandassociates.com/what-is-ptsd/
Relationships (http://hri
ckelandassociates.com/
cateaorv/relationships/)
Self-care (http://brickela
ndassociates.com/cate
gorv/self-care/')
Self-Harming Behavior
(http://brickelandassoci
ates.com/cateaorv/selfharmina-behavior/l
Sexual Assault (http://br
ickelandassociates.co
m/cateaorv/sexual-assu
m
Suicide (http://brickelan
dassociates.com/categ
orv/suicidefl
6/1/2017
What is PTSD: treatment and Healing tor Survivors
Page 5 of 16
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may be triggered by something incidental
landassociates. com/cat
in everyday life.
eqory/therapists/1
Flashbacks may occur with or without
Trauma-Informed Care
(http://brickelandassoci
ates.com/cateaorv/trau
conscious memory of the traumatic
event. They may involve memories that a
person can recall at will, also known as
ma-informed-care/1
explicit memories. They may also involve
those formed unconsciously such as
those that occur in early childhood.
Therapists refer to these as implicit
memories, which form mental models of
how the world works, even though a
person does not recall their origin.
Fortunately, perfect recall is not
necessary when working in therapy.
When overwhelming feelings occur in
situations where they simply don’t fit,
therapists can still help survivors resolve
and manage them.
Avoidance
Avoidance is a coping,strategy for PTSD
survivors.'Staying out of situations that
trigger overwhelming stress is one
strategy. Another way to avoid
reactivating an experience is by
“dissociating” or taking mental leave of
the body. This happens to a degree that
some PTSD survivors cannot even
describe sensations going on. This
coping strategy prevents many people
with PTSD from living in the present and
A-3H
http://brickelandassociates.com/what-is-ptsd/
6/1/2017
What is PTSD: Treatment and Healing tor Survivors
Tage t> ot it>
moving toward what they want in life the righttoMl safe and to{?ursue vitiap://briCkelandaSSOCiateS'COm^
is healthy and meaningful to them.
Hyperarousal
Some PTSD survivors experience
hyperarousal — a-feeling of always being
• on edge: They may feel anxious become busy all the time, or seem
unable to say no. There is intensive
energy — a foot is shaking whenever the
person tries to relax — or they may
overreact at a sound like a balloon
popping. They may dread making a
mistake for fear something terrible will
happen, even if part of them knows it isn’t
rational.
It is as if the body’s self-defense system
cannot be turned off: During the “fight,
flight or freeze” survival response, the
“senses become hypersensitive to better
smell, hear, see and taste the danger...
in preparation for further assessment and
response,” explains sensorimotor
psychotherapist and author Pat Ogden
(http://worthit2bme.com/fiahtfliahtimmobo
lize/therapeutic-window-of-tolerance/1. “In
the ideal resolution of the arousal, the
level returns to the parameters of the
optimum zone. However, this return to
baseline does not always occur, which
contributes significantly to the problems
with hyperarousal that are characteristic
of the traumatized person.”
http://brickelandassociates.com/what-is-ptsd/
6/1/2017
What is PTSD: Treatment and Healing for Survivors
_
=
Page 6 of 16
moving iowfird what they want in life the righttoKlsareandiopursuevitlaF:/*riC^elanClaSSOC'ateS'COm^
is healthy and meaningful to them.
Hyperarousal
Some PTSD survivors experience
hyperarousal — a feeling of always being
on edge. They may feel anxious become busy all the time, or seem
unable to say no. There is intensive
energy — a foot is shaking whenever the
person tries to relax — or they may
overreact at a sound like a balloon
popping. They may dread making a
mistake for fear something terrible will
happen, even if part of them knows it isn’t
rational.
It is as if the body’s self-defense system
cannot be turned off. During the “fight,
flight or freeze” survival response, the
“senses become hypersensitive to better
smell, hear, see and taste the danger...
in preparation for further assessment and
response," explains sensorimotor
psychotherapist and author Pat Ogden
(http://worthit2bme.com/fiahtfliqhtimmobo
lize/therapeutic-window-of-tolerance/V “In
the ideal resolution of the arousal, the
level returns to the parameters of the
optimum zone. However, this return to
baseline does not always occur, which
contributes significantly to the problems
with hyperarousal that are characteristic
of the traumatized person.”
http://brickelandassociates.com/what-is-ptsd/
6/1/9.017 23
rage / oi to
What is PTSD: Treatment and Healing for Survivors
ReCent gtigr &S »^?L®e4p://briCkelandaSsooiates.c0m)
new connections between brain, body,
and the processing of severe trauma.
These findings have enabled therapists
to develop more effective approaches
that help PTSD survivors better manage
and resolve hyperarousal.
Negative Thoughts and Feelings
One of the most difficult symptoms of
PTSD is a negatively altered mood.
Some people with PTSD may lose
interest in things that they want to enjoy,
be unable to concentrate, or feel that they
are wandering through life like a ghost. It
is normal for anyone to get swept up in
dark moods at times. But with PTSD
treatment, it is possible to learn new
ways to cope and observe the waves of
emotions without getting lost in them.
No matter how grim things look, know
that these symptoms are part of the
disorder. Brain research is shedding light
on changes in the brain’s structure and
function following the aftermath of
trauma. This information helps explain
why emotions and other symptoms occur
the way they do. It also leads to
treatments that can help PTSD survivors
manage symptoms and even strengthen
brain structures for the better.
PTSD and the Brain
'*
http://brickelandassociates.com/what-is-ptsd/
A ■%
!
What is PTSD: Treatinent and Healing for Survivors
Page 8 of 16
Neuroimaging, studies have revealed
importantstruc^lral ancPfiin^KjnaP'htt*3:^r'C*<e*an^aSS0C'ates'e0m^
differences between the brains of people
with PTSD and the brains of individuals
without PTSD. Research has studied
changes in three particular parts of the
brain and their role in the stress
response: the hippocampus,
ventromedial prefrontal cortex
(ventromedial PFC) and amygdala.-
The Hippocampus In PTSD
Survivors
The hippocampus may change the most
after severe traumatic stress. It regulates
memory, and the ability to distinguish
past from present. It stores and re
activates memories in response to certain
stimuli. The hippocampus of PTSD
survivors is measurably smaller, and
does not separate past and present or
read cues from one’s surroundings as it
otherwise would. This change may
explain the experience of flashbacks, or
sudden panic attacks. Fortunately new
ways to cope can be learned.
The Amygdala and Ventromedial
PFC in PTSD Survivors
The amygdala interacts with ventromedial
PFC — the part of the brain involved in
response to emotions and selfawareness. This latter area becomes
smaller and less able to regulate the
amygdala’s “fight-or-flight” signals. This
http://brickelandassociates.com/what-is-ptsd/
6/1/2017
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STATE OF FLORIDA
£9
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(©OllEtHOt
THE CAPITOL
TALLAHASSEE. FLORIDA 32399-0001
www.flgov.com
850-717-9418
Ron DeSantis
governor
September 13, 2019
Mr. Percy Stucks, Jr.
Prisoner ID# 2016018775
500 East Adams West
Jacksonville, Florida 32202
Dear Mr. Stucks:
Tbank you for contacting Governor Ron DeSantis.
With your legal concerns 1 an 2
^ Person who can best as^t you
Service which you may confcct by caWng ioU fe (gool M^nri^T" RC,erra'
651 East Jefferson Street, Tallahassee, Florida 32399 2300 v’n ^ ^
Wntmg t0
Florida Bar's website at www.florid/ha
^ You maX
visit the
Thank you again for contacting Governor DeSantis.
Sincerely,
J
Tyler Andrew
Office of Citizen Services
Executive Office of the Governor
TA/cas
A-37
STATE OF FLORIDA
©fftce of tfje <©oliernor
THE CAPITOL
TALLAHASSEE, FLORIDA 32399-0001
www.flgov.com
850-717-9418
Ron DeSantis
GOVERNOR
i.
i-
August 11, 2020
Percy Allen Stucks, Jr.
2016018775
500 East Adams Street
Jacksonville, FL 32202
Re:
Public Records Request
Dear Mr. Stucks:
Governor Ron DeSantis's Office of Open Government received your
request for records, a copy of which is enclosed for vour reference. However,
The Governor's Office is not the custodian of these records.
Thank you for contacting the Executive Office of the Governor.
Sincerely,
r
UuftOtO rOH/1
Courtney Hendricks
Office of Open Government
Executive Office of the Governor
Enclosure
A'3?
This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.