Petition for Writ of Certiorari — Bradley E. King, Robin King, and Sarah King, Petitioners v. Florida

Supreme Court briefDec 18, 2024

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Text

OR-GINAl

filed

No.

DEC 1 8 2024

In tlje Supreme Court of tlje Hutteb States

SUPREEMEFCQnRTLnQK

BRADLEY E. KING, ROBIN KING AND SARAH

KING,

Petitioners,

vs.

STATE OF FLORIDA,

Respon den t(s).

On Petition For A Writ Of Certiorari To The Florida

Third District Court of Appeals

PETITION FOR A WRIT OF CERTIORARI

Bradley King

Robin King

Sarah King

137 South Courtenay Pkwy,

Unit 626

Merritt Island, FL 32952

MyJehovah777@mail.com

Pro Se

RECEIVED

DEC 2 6 2024

QUESTIONS PRESENTED

In Monroe County, FL, Judge Luis Garcia of the

Sixteenth Circuit issued a denial order refusing to

hear Petitioners and made a “sweeping” pardon of

multiple parties from their legal duties and escape

from damages after Mr. Bradley King, the Petitioner

charged by the State, was fully acquitted. This “cover

up” by the State Attorney’s Office, was in conjunction

with the Petitioners’ attorney, and an arresting officer

dismissed by Internal Affairs from the Police Force,

who accommodated a wealthy drug runner in the FL.

Keys from Miami, against Mr. King, after he “blew the

whistle” on the drug runner and his Enterprises. This

implicates important constitutional and statutory

concerns arising from 1st Amendment Freedom of

Speech, Landlord-Tenant Law, government overreach,

and rights for damages in “Stand Your Ground” cases,

such as for “whistle blowers”. Nevertheless, the Third

District Court of Appeals (D.C.A.) in Miami incorrectly

denied jurisdiction. This was timely reported to the

Florida Supreme Court, which gave a No. SC20241479, but denied discretionary review the same day

Petitioners filed, stating, “No motion for rehearing or

reinstatement will be entertained by the' Court”,

rendering Petitioners unable to submit their brief

within the normally allotted ten days. This stifling of

Petitioners’ Freedom of Speech, avoiding damages and

due process will continue, absent court intervention.

The questions presented are:

Whether the Supreme Court should compel the

Third D.C.A. to overturn Judge Garcia’s Order filed

Questions Presented

July 8, 2024, that it be disannulled, and that an

evidentiary hearing date be reset, so that Petitioners

will have a chance to be heard in their entirety in the

Sixteenth Circuit and/or Third D.C.A. (“3rd D.C.A.”).

2. Whether Judge Garcia using fraudulent documents

in order to incorrectly deny that the State has imposed

damages on Mr. King, and to pardon just about

everybody involved concerning damages in his July 8,

2024 order, violates State laws entitling Petitioners to

damages.

3. Whether the State, Sixteenth Circuit Court, and

Petitioners’ attorney were in misconduct to take

exactly two full years (rather than 120 days) after the

unlawful arrest (November 31, 2021) of Mr. King, in

order to accomplish Mr. King’s trial and full acquittal

for the same and/or closely related conduct that

underlies the criminal and misdemeanour charges.

4. Whether the state and Sixteenth Circuit were in

misconduct to attempt to run out certain statutes of

limitations for Petitioners to file for malicious

prosecution, especially after Mr. King’s arresting

officer was found to be doing favours for a group of

Landlords: a well-known, wealthy drug runner, his

wife, and adult daughter (the “Chico Enterprises”),

who all three were found falsely, maliciously alleging

heinous crimes against Mr. King in court.

111

Questions Presented

5. Whether Mr. King should be able to charge the

State for not receiving a speedy trial, and for nearly

two or more unnecessary additional years of such

continuing damages on Mr. King and his family after

the case and all charges should have been dropped

completely and closed as soon as the unlawful

arresting officer was dismissed, known to the State.

6. Whether police officers’ and any others’ video and

audio devices’ recordings from the date of the arrest,

November 31, 2021, are still within the statute(s) of

limitations for Mr. King to use in court for purposes

regarding damages.

Whether abused tenants acting in good faith

should have right to warrants for the arrest of

harassing Landlords.

Whether the State Attorney Office of Monroe

County is using fully acquitted cases, such as Mr.

King’s, to indemnify other men’s crimes, specifically,

for such as the case number, 20-CF-59-AP of another

man, Juan Gonzalez, issued wrongly to Mr. King, filed

on legal record January 9, 2023, as a drop to county

court from the No. 21-CF-310-A-P, months after Mr.

King’s arresting officer was dismissed (in or about

November 2022). The corrected number used for later

acquittal was 2023'MM‘59\AP.

9. Whether Mr. King has a right to claim damages

against the State for this wrong 20-CF-59-AP felony

Questions Presented

issuance showing on Mr. King’s record for about 2

years now, inhibiting his ability to get jobs,' and

whether it should be erased by court order from

Mr. King’s record, which was clean for 62 years with

security-clearances and a NASA engineering job offer.

10. Whether Mr. King has a right to claim damages

for his cases, which upon dismissal of the arresting

officer, charges were not fully dropped due to the

unlawful arrest, nor was Mr. King notified by anyone

(the State, the Judges, nor Mr. King’s own hired

Attorney) of the dismissal of the arresting officer, nor

was Mr. King’s case dropped completely, nor was he

fully acquitted in the Sixteenth Circuit until exactly 2

full years after the unlawful arrest.

11.

Whether Mr. King’s prior attorney David

Hutchison should be reprimanded by the Bar, and/or

disbarred, and also recompense for damages to Mr.

King, for malpractice by playing along with the State,

and dirty cop to accommodate and protect a wellknown, wealthy, malicious drug runner and the rest of

“Chico Enterprises” for nearly three years from lawful

justice.

12. Whether prior convicted-felon drug runners and

their Enterprises should be able to continue

personally leasing property as landlords to American

families without first informing tenants of their

felonious background, since landlords require

background checks of tenants.

PARTIES TO THE PROCEEDING AND RELATED

PROCEEDINGS

The parties to the proceeding below are as follows:

Petitioners are Bradley E. King (“Mr. King”), Robin

King, and Sarah King. The respondent is the State of

Florida (“The State”): Florida Attorney General.

The related proceedings below are:

In the Sixteenth Circuit Court, Monroe County, FL:

1. Charla Cae Chico and Bradley Eugene King,

2021-DR-423-'P (Order of TROs Dismissal,

March 7, 2022)

2. State of Florida v. Bradley King, No.2021-CF310-AP (State dropped charge January 9, 2023,

giving incorrect No. 20-CF-59-AP)

3. State of Florida v. Bradley King, Correct No.

2023-MM-59-AP (Immunity order, Oct.31, 2023)

4. Bradley E. King v. State ofFlorida,

No. 21-CF-310-A-P (order issued May 7, 2024)

5. Bradley E. King v. State of Florida, 21-CF-310AP / 20-CF-59-AP (order issued July 8, 2024)

In the Third District Court of Appeals in Miami, FL:

6. Bradley E. King v. State ofFlorida,

No. 3D2024-1359 (order issued Sept. 18, 2024)

In the Florida Supreme Court:

7. Bradley E. King v. State ofFlorida,

No. SC2024-1479 (order dated Oct. 17, 2024)

TABLE OF CONTENTS

Page

QUESTIONS PRESENTED

PARTIES TO THE PROCEEDING AND RELATED

PROCEEDINGS.......................................... v

TABLE OF CONTENTS

,vi

TABLE OF APPENDICES

TABLE OF CITED AUTHORITIES

OPINIONS BELOW

JURISDICTION

CONSTITUTIONAL AND STATUATORY

PROVISIONS INVOLVED....................

INTRODUCTION

I. The lower courts’ orders are facially invalid

A. The

3rd

D.C.A.

incorrectly

denied

jurisdiction to hear the case and the Florida

Supreme Court incorrectly denied review

and conflict with the trial court

B. Mr. King’s Freedom of Speech and 14th

Amendment have been imposed upon

unconstitutionally.......... ........................

Vll

Table of Contents

Page

STATEMENT

I. Background

II. Proceedings Below

REASONS FOR GRANTING THE PETITION

I. The lower courts’ opinions raise important,

novel questions of law that the Court should

resolve

A. The State issued the wrong case No.,

indemnifying another man’s felonies

B. Long after the dirty cop was dismissed from

the Force, all charges on Mr. King were

dropped per FL Statute 776.031, then

Mr. King was informed of the officer’s

dismissal and that it was beyond statutes of

limitations for Mr. King to pursue certain

damages inflicted by the State, Petitioner’s

attorney and the Chicos.

C. Judge Garcia incorrectly denied Mr. King’s

damage claims per an order, using fraud

ulent docs, refusing hearing, all after Judge

Garcia’s order of‘lack of jurisdiction’

ENDING REASONS

V1U

Table of Contents

Page

I. There Is a Significant Possibility of Inadequate

Expungement due to State-inflicted damage.

II. There is a likelihood of irreparable harm absent

Court intervention.

III. Absent the overturn of the Third DCA’s order

denying hearing Mr. King regarding Judge

Garcia’s July 8th Order, Mr. King and his family

may be required to bear the burdens of damages

never to be recompensed.

IV. State Attorney Offices continuing in said

conduct, will inflict grave injuries/damages on

thousands of American families.

V. The balancing of equities strongly favors Court

intervention.

VI. This case presents an appropriate vehicle to

resolve these lofty issues.

CONCLUSION

TABLE OF APPENDICES

Page

OPINION OF THE THIRD

APPENDIX A

DISTRICT COURT OF APPEALS (“3RD D.C.A.”),

FILED SEPT. 18, 2024

APPENDIX B

OPINION OF THE FLORIDA

SUPREME COURT, FILED OCT. 17, 2024

APPENDIX C - ORDER DENYING MOTION TO

COMPEL IN THE 16TH JUDICIAL CIRCUIT

(“CIR.”) IN MONROE COUNTY, FILED JULY 8,

2024

ORDER

HEARING

APPENDIX

CANCELLATION IN THE 16TH JUDICIAL CIR.,

FILED MAY 7, 2024

16a

APPENDIX E

ORDER OF 16TH JUDICIAL

CIRCUIT COURT FOR IMMUNITY GRANTED

OCTOBER

31,

2023

AND

CERTIFIED,

18a

DECEMBER 15, 2023

APPENDIX F - ORDER OF THE 16TH JUDICIAL

CIRCUIT

COURT

FOR

DISMISSAL

RESTRAINING ORDERS, FILED MARCH 7, 2022

(Hearing transcript available upon request).

25a

* .

TABLE OF APPENDICES

PAGE

APPENDIX G - NOTICE OF TRANSFER AND

AMENDED INFORMATION CF ERROR IN

MONROE COUNTY STATE ATTORNEY OFFICE,

FILED JANUARY 9, 2023

29a

APPENDIX H - CERTIFIED DISPOSITION (REDSTAMPED, ALTERED AND INITIALLED BY

CLERK ON JAN.

29,

2024) AMENDED

INFORMATION CF ERROR IN MONROE

COUNTY STATE ATTORNEY OFFICE, DATED

JAN. 9, 2023

34a

APPENDIX I - CHARGES INFORMATION BY

STATE ATTORNEY DENNIS WARD, FILED DEC.

20, 2021

37a

APPENDIX J - MOTION OF FLORIDA ATTORNEY

GENERAL’S OFFICE IN THE 3RD D.C.A., FILED

AUGUST 14, 2024

40a

APPENDIX

NOTICE

INVOKE

DISCRETIONARY JURISDICTION OF THE

FLORIDA SUPREME COURT, FILED OCT. 17,

2024

43a

APPENDIX L - NOTICE GIVEN NOV. 21, 2022 OF

EVIDENTIARY HEARING SET FOR JAN. 9, 2023

IN THE 16TH JUDICIAL CIRCUIT

48a

TABLE OF APPENDICES

PAGE

APPENDIX M - MOTION TO COMPEL (FIRST

PAGE ALTERED) IN THE 16TH JUDICIAL CIR.,

DATED JUNE 17, 2024

50a

UNALTERED MOTION TO

APPENDIX N

COMPEL IN THE 16TH JUDICIAL CIR., FILED

JUNE 17, 2024

51a

TABLE OF AUTHORITIES

Page

CASES

Hillman v. Maretta,

569 U.S. 483, 489 (2013)

Justin Hopson vs. New Jersey State Police,

(2007 Case#i:03-CV-5817)....................

King v. Chico and Chico Enterprises,

16th Cir., Monroe County, FL, 2021*2023 ...4,13,14

Massachusetts v. Env’t Prot. Agency,

549 U.S. 497, 505*06 (2007)........

U.S. CONSTITUTION, STATUTES, RULES

28 U.S.C. § 1257(a)

U.S. Const. First Amendment

U.S. Sup. R. P. 10(a)

U.S. Sup. R. P. 14(b)(iii)

Fla. Stat. § 776.031

Fla. Const, art. IV, § l(c)

Ch. 83 * Florida Landlord & Tenant Act & Laws....2*3

• ‘

Xlll

Cited Authorities

Page

OTHER AUTHORITIES

Gerald Kogan & Robert Craig Waters, The Operation

& Jurisdiction of the Florida Supreme Court,

18 Nova L. Rev. 1151 (1994)

-2, 6

Anstead, Kogan, Hall & Waters, The Operation &

Jurisdiction of the Supreme Court of Florida,

Reprinted from 29 Nova L. Rev. 431 (2005)

2,6

McGimsey and Littleton, Expert Q&A on Seeking or

Opposing Certiorari in US Supreme Court

Michelle Maxwell, Internal Affairs Office

Monroe County Sherriff Rick Ramsey and Captain

Derek Paul

Petitioner respectfully prays a writ of certiorari issue

to review the judgement of the Third District Court of

Appeal in Miami, FL for the Florida Supreme Court,

in regards to a 16th Judicial Circuit Court order.

OPINIONS BELOW

In these cases from the state courts, none have been

found publically “published” or “reported”:

The district court’s opinion denying to hear the

motion in King v. State, case No. 3D2024-1359, on

Sept. 18, 2024, is reproduced at Appendix (“App.”) A,

at la-2a. The Florida Supreme Court’s opinion affirms

a like denial to hear the motion per a final order in

King v. State, case No. SC2024-1479, dated Oct. 17,

2024, reproduced at App. B, at 3a-5a.

JURISDICTION

The date on which the FL Third District Court

made a decision on Petitioners’ case was September

18, 2024 (App. A). The timely appeal for a hearing in

the 16th Circuit or 3rd D.C.A. was therewith denied. A

timely Notice to Invoke Discretionary Review along

with the D.C.A order was timely filed within 30 days

in the Florida Supreme Court, dated October 17, 2024.

Just hours after, the Florida Supreme court dismissed

the notice without allowing the normally allotted 10

days within which to submit a brief, contrary to Fla.

R. App. P. 9.120(d), nor should the court have issued

an opinion that early. The opinion/final order is at

App. B. Petitioners now bring this petition this 85th

day after the 3rd D.C.A, Sept. 18, 2024, decision. This

Court has jurisdiction under 28 U.S.C.§1257(a).

Constitutional and Statutory

Provisions Involved

The constitutional and statutory provisions

involved in this case are: U.S. Const. 1st, 5th, 6th and

14th Amendments and the Due Process Clauses; Fla.

Const, art. IV, § 1(c); Fla. R. App. P. 9.030(a)(2)(a)(i)

and (v); Fla. R. App. P. 9.120; F.S. §776.031; Chapter

83 - Florida Landlord and Tenant Act and Laws.

INTRODUCTION

The rule of law comprised within this Court’s

binding precedent and our U.S. Constitution’s

Freedom of Speech and upholding of due process laws

preserve uprightly ordered liberty and protection for

all Americans. Petitioners’ case involves important

limits of constitutional, statutory, and precedential

concerns, now, after Mr. King’s recent victory of full

acquittal in a landmark ‘Stand Your Ground’ case,

State v. King (No. 2023-MM-59-AP), that was dropped

from criminal to misdemeanour charges in the

Sixteenth Circuit Court, Monroe County, FL. The case

was based on the Florida Supreme Court’s coinciding

landmark decision in Falco v. State, 407 So.2d 203

(Fla. 1981) and the legislative intent described by the

House and Senate committee notes regarding F.S.

§776.031. This case was thrown out of court, but not

before a very long, hard, unlawful mess was made for

Petitioners’ (having acted in good faith) to now recoup

from

mentally,

physically,

financially

and

diplomatically, seeking from this Court lawful

restitution and to report unjust and malicious process,

that due process may be vindicated in Florida, so that

thousands of other Americans may not suffer as we

Petitioners have by corrupt Landlords who refuse to

abide by Chapter 83 - Florida Landlord and Tenant

Laws, and by associated local government officials

dealing with wealthy drug runners from the Miami

and Monroe County areas. As our 14th Amendment of

the U.S. Const, goes, “nor shall any State deprive any

person of life, liberty, or property, without due process

of law; nor deny to any person within its jurisdiction

the equal protection of the laws.”

Review of a state-court judgment is sought, lest

such methods should become more prevalent in the

other states as well, so please see the below matter of

an order dated September 18, 2024 in the Third

District Court of Appeals (“3rd D.C.A.”) in MiamiDade County, FL'

I. The lower courts’ orders are facially invalid.

C. The 3rd D.C.A. incorrectly denied jurisdiction to

hear the case and the Florida Supreme Court

incorrectly denied review, and conflict with the

trial court.

The 3rd D.C.A. incorrectly denied jurisdiction to

hear the case motion set forth by Petitioners, claiming

it was pre-trial when, on the contrary, Petitioners filed

a thorough appeal with exhibits to the 3rd D.C.A. as

in the context below (i.e. in the “Statement” through to

“Conclusion”), showing that the charges on Mr. King

were dropped to county court on January 9, 2023, and

trial took place October 4, 2023, and per court order in

the 16th Cir. dated October 31, 2023, he was granted

immunity, attaining his full acquittal completed (with

no rebuttal from the State for 30 days thereafter) by

November 30, 2024. This was exactly two years after

the unlawful arrest of Mr. King on November 30, 2021

by Officer Nicholis Whiteman found to be doing

favours for a group of Landlords: a well-known,

wealthy drug runner, his wife, and adult daughter

(comprising the “Chico Enterprises”), who all three

were found falsely, maliciously alleging heinous

crimes in court against their tenant, Mr. King for

‘Standing his Ground’ against them three inside his

own home, in presence of Mr. King’s daughter, Sarah,

as a witness, while the Landlords video-recorded their

own illegal activities including their theft of personal

property lawfully in Mr. King’s possession inside his

home.

The 3rd D.C.A.'s order stating "Lack of

Jurisdiction" due to the case being "pre-trial" conflicts

with the 16th Circuit trial court's actual proceedings

exhibited to the 3rd D.C.A, in that there was indeed a

trial for this case. The 3rd D.C.A.'s order also conflicts

with Judge Garcia's new order dated July 8, 2024, in

which he made an order with a ‘sweeping’ pardon of

all liable parties for damages, using Mr. King’s old

case number he had just a few weeks prior struck

down stating, “This court no longer retains

jurisdiction”, per his court order dated May 7, 2024,

thus, reneging on this first claim as described in detail

below.

Mr. King’s case numbers “directly related” in

accordance with U.S. Sup. R. P. 14(b)(iii) are detailed

in the below “Statement” and “Reasons”, including: (a)

2021-DR-423-P; (b) 2021-CF-310-AP; (c) 20-CF-59-AP;

(d) 2023-MM-59-AP. The major issues are that:

(l) Mr. King did not receive a speedy trial in

accordance with Florida due process nor with the U.S.

Const. 6th Amendment, but rather more than eight

months with each of case numbers (b) and (d) above,

while the case number (c) issue is still unresolved.

With violation of the speedy trial rule, any charge

should have been dismissed sooner than they were.

(2) Mr. King was unlawfully arrested November 30,

2021, and Internal Affairs investigated and dismissed

Mr. King’s arresting officer in around November 2022,

only found out by Mr. King after exactly two years

(November 2023) when he was fully acquitted, causing

certain statutes of limitations for malicious

prosecution terms to be run out. Instead of all charges

being automatically dropped in November 2022 due to

the unlawful arresting officer, the State decided to

‘charge on’ and added a new case number (c, above)

20-CF-59-AP belonging to a completely separate man

Juan Gonzalez, to Mr. King’s case on January 9, 2023,

which should have already had full acquittal. Facially,

this method would be useful by the State to indemnify

Gonzalez, who was convicted of high crimes.

(3) Such actions made outside of due process by the

lower courts, State Attorney’s Office, collaborating

with private attorneys, local wealthy drug runners

and others in Monroe County, if continued, along with

unlawful arrests, will inflict upon innocent Americans

dire physical, mental, financial and diplomatic harm.

If this apparent loophole in Florida spreads

nationwide, many more than just the Petitioners will

be harmed if such methods are left unchecked.

Monroe County’s current “Case Summary” from

the Records Clerk as of December 9, 2024 for Mr.

King, lists only some of the said related case numbers

and a few items. One relevant item “Notice given

Nov. 21, 2022 of the Evidentiary Hearing set for

Jan. 9, 2023 in the 16th Judicial Cir.” is reproduced at

App. L, at 48a. This shows the trial that was set for

January 9, 2023, before the charges were dropped

from Criminal to County Court, so the trial was

fulfilled at the County level, instead, more than eight

months later due to intentional neglect by Petitioners’

attorney playing along with the State to run out

certain statutes of limitations regarding the unlawful

arrest and malicious prosecution by the wealthy drug

runner and his Enterprises. Such actions are facially

being sanctioned by the 3rd D.C.A. by passing off the

case for a “Lack of Jurisdiction” due to Petitioners’

motion being received “pre-trial”. On top of this, the

3rd D.C.A.’s response was very vague and not

specifying statutes within their order when trial did in

fact take place as was exhibited to them, contrary to

that court’s claim agreeing with the State Attorney

General’s Office whose motion with the detailed

statutes which the Florida Supreme Court sought is

reproduced at App. J, at 40a-42a in this petition.

The 3rd D.C.A. (in regards to U.S. Sup. R. P.

10(a)) "has so far departed from the accepted and

usual course of judicial proceedings, or sanctioned

such a departure by a lower court, as to call for an

exercise of this Court’s supervisory power".

A timely Notice to Invoke Discretionary Review

along with the 3rd D.C.A order was timely filed within

30 days in the FL Supreme Court, dated Oct. 17, 2024.

Just hours afterwards, the court dismissed the notice

without allowing the normally allotted 10 days to

submit a brief, contrary to Fla. R. App. P. 9.120(d), nor

should the court have issued an opinion that early.

The opinion/final order is at Appendix B, at 3a below.

In Fla. Const, art. IV, § 1(c), the constitution provides

that the opinion must be rendered “not earlier than

ten days from the filing and docketing of the request,

unless in [the Court’s] judgment the delay would

cause public injury.” There was no notation from the

FL Supreme Court regarding “public injury”, and

rather wrote “No motion for rehearing or

reinstatement will be entertained by the Court”,

signed solely by the Clerk, rendering Petitioners

unable to submit a timely brief.

Thus, these three lower courts’ (16th Cir., 3rd

D.C.A. and FL Supreme) orders are facially invalid

and conflicting. (For example, Hillman v. Maretta, 569

U.S. 483, 489 (2013) (stating that the Court granted

certiorari “to resolve a conflict among the state and

federal courts”)).

However, if this court somehow sees these three

courts’ orders as not conflicting, please consider the

great public importance of the proceedings below and

their unruly implications foreseen to only expand in

government overreach, absent court intervention. (For

example, Massachusetts v. Env’t Prot. Agency, 549

U.S. 497, 505-06 (2007) (stating that, notwithstanding

the absence of any conflicting decisions, “the unusual

importance of the underlying issue” persuaded the

Court to grant certiorari).)

D. Mr. King’s Freedom of Speech and 14th

Amendment have been imposed upon

unconstitutionally.

Not allowing Mr. Kang’s unique scenario of this

petition to be heard in the 16th Cir., 3rd D.C.A. nor FL

Supreme courts, despite his full acquittal, as

Petitioners have been “whistle blowers” on the said

actions working outside of due process, is clearly

imposing upon Petitioners’ Constitutional, 1st

Amendment Freedom of Speech. Petitioners seek this

court’s intervention that they may be allotted the

privilege of being heard in court, and pursue lawful

damages restitution from the State or other parties

and alert this Court of said misconduct that they may

further protect the American people.

Similar to the full statement and list of stated

points/reasons through to the conclusion below was

submitted to the 3rd D.C.A. by “Appellants”, now

changed to “Petitioners” along with the appendices’

designations.

STATEMENT

I. Background

Petitioners Bradley E. King, Pro-Se, and family, are

victims of an easily-proven cover-up within the

judicial system, who filed twice, in the Sixteenth

Judicial Circuit of Monroe County in 2024, essentially

the same Motion to Compel, for damages: first filed on

May 1st where the presiding Judge struck down that

Motion by a Court Order dated May 7, 2024 stating,

“this Court no longer retains jurisdiction” of Case #

2021-CF-00310-AP; and the second time filed on June

17th where Petitioners this time used a different Case

# 20-CF-59-AP and style given to the Petitioners by

the State on January 9, 2023. The L.T. Judge chose to

pardon Petitioners prior attorney of two years and

eight months worth of damages spoken of in both

motions, in his Order dated July 8, 2024 by changing,

on his own, the Petitioners’ Case # 20-CF-59-AP to his

preferred Case # 2021-CF-00310-AP, and style to

“Defendant”, Oddly enough, the Judge just got done

striking down his chosen Case number and Style by

his own Order dated May 7, 2024. Further, the Judge

unknowing used fraudulent documents as exhibits in

his Order dated July 8, 2024 to justify his actions.

Petitioners pray for this Court to compel the 3rd

D.C.A. to overturn the Court Order dated July 8, 2024

and reset the evidentiary hearing that was set for July

30, 2024 “National Whistle Blower Day.” Said hearing

Petitioners pray will have a chance to be heard in its

entirety.

II. Proceedings Below.

In Petitioners’ Defence, we state:

The Petitioners filed on May 1, 2024 a Motion to

Compel, Case # 2021CF310AP, and was set for

Hearing on June 4, 2024.

The Petitioners’ Motion filed on May 1, 2024

was cancelled on May 7th by the Honourable Luis

Garcia of the L.T. Courts with the Judge stating “this

Court no longer retains jurisdiction” over Case # 442021-CF-310-AP a.k.a. Case #

44-2021-CF-00031000-0APK (please see App. D).

On June 17, 2024, Petitioners Bradley, Robin

and Sarah King filed essentially the same Motion to

Compel using Case # 20-CF-59-AP (of which page ‘one’

was ‘doctored up’ not by Petitioners at App. M, at 40a),

and using a similar Case known as Hopson v. State of

New Jersey Case #B03-CV*5817 as a similar case to

reference.

The Petitioners presented themselves as

Petitioners in both above-mentioned Motions to

Compel.

Both Motions filed on May 1st and June 17th

describe Plantation Key’s well-known, wealthy “Drug

Runner”; a “Dirty Cop”; a State Prosecutor; the

Monroe County Courts, and Petitioners’ prior

Attorney, Mr. Dave Hutchison, Founder and C.E.O. of

the firm known as Hutchison and Tubiana, who used

Case # 2021CF310AP and Case # 20-CF-59-AP to

their advantage to this very day (please see

paragraphs #1 through #100 of App. N, 41a-52a).

REASONS FOR GRANTING THE PETITION

I. The lower courts’ opinions raise important, novel

questions of law that the Court should resolve

A. The State issued the wrong case No. (20-CF-59AP), indemnifying another man’s felonies.

Both Motions to Compel filed described the

Attorneys and divisions of the Judicial system who

refused to disclose to the Petitioners the facts behind

the November 30, 2021 unlawful arrest of Petitioner

Bradley King, and the arresting Officer Sergeant

Nicholis Whiteman, dismissal from the Police Force

when found out to be a “Dirty Cop” thus all case

history should have been dismissed at that time,

rather, the State Attorney and the L.T. Courts chose

to, ‘charge on’ with the below case numbers to this

Day:

Case #1: 2021-DR-423-P (dismissed on March 7, 2022

by Judge Garcia’s Court Order that day).

Case #2: 2021-CF-00310-AP (Dropped by the State on

January 9, 2023 due to the dismissal of the “Dirty

Cop”, but reopened by Honorable Luis Garcia in July

2024). a.k.a. # 2021-CF-310-AP, a.k.a. # 21-CF-310AP , a.k.a. # 44-2021-CF-310-AP , a.k.a. # 44-2021CF-000310-00-0APK (shortened variations noted

above).

Case #3: 20-CF-59-AP (State Attorney’s (CF) Amended

Information error dated and doc stamped by the Clerk

of Courts twice, once on January 9, 2023 and again on

January 29, 2024)

a.k.a. # 2020-CF-00059-AP

(shortened variation noted above).

Case #4: 2023-MM-59-AP (Immunity Motion granted

by Judge Hamilton for Petitioner’s full acquittal).

The Petitioners filed on June 17, 2024,

essentially, the same Motion to Compel as Petitioners

filed on May 1st, instead under the CF error Case

Number 20-CF-59-AP given to the Petitioner by the

•

State on January 9, 2023 (please see App. G, at 29a33a, and App. N, at 51a-77a).

Petitioners’ June 17, 2024 Motion to Compel

with the CF error Case Number was scheduled by the

Judge’s Judicial Assistant to be heard by Zoom on

July 30, 2024, at 10^30 a.m. (please see App. C, at

6a-15a).

The above-mentioned CF error Case Number

20-CF-59-AP given to the Petitioner, Bradley King, by

Monroe County State Attorney’s office in the second

page of the Notice of Transfer and Information doc,

filing Number 164337523, E-filed on 1/9/2023, is, in

fact, part of the Damages spoken of in both Motions to

Compel.

10.

The crime of that CF error Case Number # 20CF-59'AP given to the Petitioner, in itself, and with

other factors, caused the Petitioners to have lost their

level of security developed within the government and

international relations, and are in-part, considered

damages that the Petitioners’ prior Attorney, Mr.

Dave Hutchison, Esquire, was paid to care for, but in

the end, refused. Unfortunately, that prior Attorney

on February 21, 2024 chose to tell the Petitioners to

“Go to somebody else” (please see paragraphs 5 - 23,

28 - 35, 62 - 67, and 76 - 100 of the motion, App. N).

11.

The facts behind the CF error Case Number 20CF-59-AP, and how it was used by the State

Prosecutors and the L.T. Courts, are easily proven by

additional documentation that the Courts have yet to

see, but would have been made privy to if said Motion

to Compel’s Evidentiary Hearing scheduled for

July 30, 2024 was not denied (please see paragraphs

19 - 26, 36 — 49, and paragraph 53 of App. N).

12.

The State, the Courts and even Petitioners’

Attorney left the Petitioners in the dark concerning

the “Dirty Cop’s unlawful arrest and dismissal on or

about November, 2022, Case # 2021CF310AP a.k.a.

Case # 442021CF000310000APK. At that time, all

parties should have informed the Petitioners of the

unlawful arrest, and dismissal of the “Dirty Cop”,

rather they all chose not to, and continued charging on

to this day (please see App. N, at 51a-77a, paragraphs

1-4, 10-14, 25, and 50-53 ).

13.

Both State and Petitioners’ Attorneys, dragging

their feet in open court, were seen to be so obvious

that the Honorable Sharon Hamilton sta'ted more than

once, “Keep Mr. King’s case moving forward”, which

seemed to have no effect (please see paragraphs 54 79 of App. N ).

B. Long after the dirty cop was dismissed from the

Force, all charges on Mr. King were dropped

per FL Statute 776.031, then Mr. King was

informed of the officer’s dismissal and that it

was beyond statutes of limitations for Mr. King

to pursue certain damages inflicted by the

State, Petitioner’s attorney and the Chicos.

14.

The heroes and reasons for Damages found in

the CF error Case Number both Motions to Compel

filed by the Petitioners speak of in depth and bravery

found in The Monroe County Sheriffs Department,

who diligently found the facts of the Petitioners’ Case

disturbing, and why the Petitioner, Bradley King, was

unlawfully arrested and jailed on November 30, 2021.

It was they who decided to give the matter over to

Internal Affairs (please see App. N, at 51a-77a

paragraphs 12, 19, and 36 - 49).

15.

Sergeant Nicholis Whiteman of the Monroe

County Sheriffs Department was found to be a “Dirty

Cop”.

His involvement with the wealthy Drug

Runner, and the unlawful arrest of the Petitioner

Bradley King on November 30, 2021, along with other

heinous acts caused Sergeant Nicholis Whiteman to be

given an ultimatum to resign, or, as the Internal

Affairs’ Agent, Michelle Maxwell, Esquire, put it “I

would have fired him” (please see App. N, paragraphs

12, 19-21, and 36-46).

16.

This above-mentioned fact, along with the fact

that all parties involved kept the Petitioners ‘in the

dark’ of this unlawful arrest, and dismissal of the

“Dirty Cop”, and what had become of Case # 44-2021CF-310-AP a.k.a. 442021CF000310000APK, continued

on for twelve (12) full months, prosecuting the

Petitioners with a case that was dismissed and clearly

dropped in 2022, further incriminating the Petitioner

Bradley King with another man’s felony Case Number

20-CF-59-AP issued by the State Attorney on January

9, 2023 (please see paragraphs 12, 25 — 28 , 50 - 54,

80-84, 91-93 of App. N, at 51a-77a).

17.

Petitioners, made aware of the abovementioned facts on November 21, 2023 by the

Plantation Key’s Captain of the Monroe County

Sheriffs Department, Derek Pa\il, have now every

reason to ask for damages, and to show that the

deliberate intentions of the State Prosecutors and

Petitioners’ prior Attorney was to run out the Statute

of Limitations surrounding the Police camcorders,

audio and video footage before a suit concerning

malicious prosecution and damage charges could be

filed (please see paragraphs 43 - 45, and 54 - 100 of

App. N, at 51a-77a).

18.

The November 30, 2021 unlawful arrest of the

Petitioner, Bradley King, and the facts brought forth

in this Petition, as well as other factors described

below, serves as reason why this is so important to be

personally presented to the 3rd D.C.A.

C. Judge Garcia incorrectly denies Mr. King's

damage claims per an order, using fraudulent

documents, refusing hearing, all after Judge

Garcia’s order of‘lack of jurisdiction’.

19.

Three more points to consider as to why the

L.T. Order dated July 8, 2024 sent to the Petitioners

in three different ways should be overturned. (Please

see App. C, at 6a-15a.)

The Honorable Luis Garcia chose,

without permission of the Petitioners, to switch out

Case Number and Style of Petitioners’ June 17th

Motion to Compel (App. N) to a Case Number and

Style that he himself struck down by Court Order just

weeks prior (App. C, at 6a-15a, App. D, at 16a-17a, an

App. M, at 50a). This ‘doctoring up’ of the Judge’s new

Case Number and Style that the Judge used in his

Order dated July 8, 2024 did cripple Petitioners’

Motion to Compel right for damages.

The Honorable Luis Garcia unknowingly

produced fraudulent documents in the Court Order

dated July 8, 2024 and should be seen for what they

are and not to be ‘candy-coated’ (Please see App. C).

The L.T. Judge changed both Case

Number and Style of his Court Order dated July 8,

2024, despite Petitioners’ efforts to promote June

17th’s Motion Case Number and Style in a different

manner for the purposes of damages that rightfully

belonging to the Petitioners, but denied by the L.T.

Judge who ‘doctored up’ said June 17th Motion within

his Court Order dated July 8, 2024, which was sent

once again on July 29, 2024 via email to Petitioners.

20.

The question as to why the Honorable Luis

Garcia had in an unorthodox manner chosen to add

fraudulent Documents as his exhibits concerning his

July 8, 2024 Order when Denying Petitioners’ Motion

to Compel is in question, and can only be construed

that the L.T. Judge wanted this matter to come before

the 3rd D.C.A.

21.

This much should be enough to overturn the

Honorable Luis Garcia’s Order Denying the

Evidentiary Hearing concerning the Motion to Compel

filed on June 17, 2024, but there is more.

22.

The above-mentioned documents which are

dated January 9th, 2024 and signed by the Assistant

State Attorney, Mr. Trey Evans, and those entered in

as exhibits by the L.T. Judge’s Order dated July 8,

2024 are fraudulent. The Petitioners are respectfully

requesting the opportunity to personally present this

case to the 3rd D.C.A. The Petitioners are supremely

confident that we can give clear convincing proof of

said fraud.

23.

The Court Order dated July 8, 2024, if not

challenged, will provide a way to succeed for the State

and prior Attorneys, who played a role in dragging

their feet purposefully and neglectfully for two full

years, while working outside of what is known as a

“timely manner”. This, combined with their hope to

have gotten away with the running out of certain

Statutes of Limitations concerning Police Cam, audio,

and records of this clearly malicious prosecution, has

yet to be recognized.

There seems to be a paradox: Petitioners’

Motion to Compel filed on May 1, 2024, Case Number

2021CF310AP was struck down with prejudice by the

L.T. Judge on May 7, 2024 due to the Courts not

retaining jurisdiction of said case. Oddly enough, on

June 17, 2024, when Petitioners filed essentially the

same Motion to Compel, and using the CF error Case

Number mentioned in that June 2024 Motion, a

conflict of interest was found within the L.T. Judicial

system. Namely, the Judge who chose to take that

Jurisdictional Number and Style that he just finished

striking down, and used it to his own advantage as his

new Case Number and Style used in his Court Order

dated July 8, 2024, despite his prior Order in May

2024, stating that his Court no longer retains

Jurisdiction over said Case Number. The Judge

proceeds on by rendering a closed ruling with an

opinion on July 8th, cancelling the Evidentiary

Hearing that was set for July 30, 2024 (“National

Whistle Blower’s Day”), but not before pardoning just

about everybody involved concerning damages that

Petitioners have a right to. The Honorable Luis Garcia

continues on by unknowingly adding fraudulent

documents of which the Petitioners can provide in

person clear and convincing proof are fraudulent. I

would like to quote Law, but this is an Honorable L.T.

Judge of whose position I respect, so Petitioners pray

that those of the Third District Court of Appeal see

the destruction caused by the L.T. Court Order dated

July 8, 2024, and consider overturning it due to a lack

of Jurisdiction, but if that Court Order Case #

442021CF000310000APK is seen to somehow have

retained jurisdiction when clearly Judge Garcia states

in his May 7th Court Order that his court does not

retain Jurisdiction of said Case Number, then please

consider overturning the Pardoning of those involved

in what is close to three years of damages found in the

CF error and other areas of Petitioners’ June 17th

Motion to Compel, and allow Petitioners to reschedule

the evidentiary hearing denied by the L.T. Court

Order. God bless all of those considering the

Petitioners’ respectful request.

The Petitioner Bradley King Pro-se and family

request to personally present this case before the 3rd

D.C.A. or the court deemed appropriate.

ENDING REASONS

I. There Is a Significant Possibility of Inadequate

Expungement due to State-inflicted damage.

II. There is a likelihood of irreparable harm absent

Court intervention.

III. Absent the overturn of the Third DCA’s order

denying hearing Mr. King regarding Judge

Garcia’s July 8th Order, Mr. King and his family

IV. may be required to bear the burdens of damages

never to be recompensed.

V. State Attorney Offices continuing in said

conduct, will inflict grave injuries/damages on

thousands of American families.

VI. The balancing of equities strongly favors Court

intervention.

VII.

This case presents an appropriate vehicle

to resolve these lofty issues.

CONCLUSION

The petition for a writ of certiorari should be granted.

Respectfully submitted,

Bradley King

Robin King

Sarah King

137 South Courtenay Pkwy,

Unit 626

Merritt Island, FL 32952

MyJehovah777@mail.com

Pro Se

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.