Petition for Writ of Certiorari — Bradley E. King, Robin King, and Sarah King, Petitioners v. Florida
Supreme Court briefDec 18, 2024
Ask Donna
What actually matters in this document.
Text
}
■«
APPENDIX
la
APPENDIX A - OPINION OF THE THIRD
DISTRICT COURT OF APPEALS (“3RD D.C.A.”),
FILED SEPT. 18, 2024
IN THE DISTRICT COURT OF APPEAL
OF FLORIDA THIRD DISTRICT
3D2024-1359
Trial Court Case No. 21-CF-310A-P
BRADLEY E. KING,
Appellant(s),
v.
THE STATE OF FLORIDA,
Appellee (s).
IT IS HEREBY ORDERED that Appellee's
Motion to Dismiss Appeal for Lack of Jurisdiction is
granted, and this appeal from the Circuit Court for the
Sixteenth Judicial Circuit, Monroe County, Florida, is
hereby dismissed for lack of jurisdiction.
EMAS, SCALES and GORDO, JJ„ concur.
A True Copy
ATTEST
/s/ Mercedes Prieto
3D2024-1359 9/18/24]
Mercedes M. Prieto, Clerk
District Court of Appeal
Third District
5$ ggcn-osiRi
$
♦If
i*
f:
&
Z
05
N
!
:*
2a
Appendix A
CC: Crim Appeals MIA Attorney General
Monroe Clerk
Hon. Luis Garcia
Ivy R. Ginsberg
David George Hutchison
Bradley E. King
Robin King
Sarah King
NS
3a
APPENDIX B - OPINION OF THE FLORIDA
SUPREME COURT, DATED OCTOBER 17, 2024
SUPREME COURT OF FLORIDA
SC2024-1479
Lower Tribunal No(s).:
3D2024-1359;
442021CF000310000APK
BRADLEY E. KING
Petitioner(s)
v.
STATE OF FLORIDA,
Respondent(s)
Petitioner’s Notice to Invoke Discretionary
Jurisdiction, seeking review of the order or opinion
issued by the 3rd District Court of Appeal on
September 18,2024, is hereby dismissed. This Court
lacks jurisdiction to review an unelaborated decision
from a district court of appeal that is issued without
opinion or explanation or that merely cites to an
authority that is not a case pending review in, or
reversed or quashed by, this Court. See Wheeler v.
State, 296 So. 3d 895 (Fla. 2020); Wells v. State, 132
So. 3d 1110 (Fla. 2014); Jackson v. State, 926 So. 2d
1262 (Fla. 2006); Gandy v. State, 846 So. 2d 1141 (Fla.
2003); Stallworth v. Moore, 821 So. 2d 974 (Fla. 2002);
4a
Appendix B
Harrison v. Hyster Co., 515 So. 2d 1279 (Fla. 1987);
Dodi Publ’g Co. v. Editorial Am. S.A., 385 So. 2d 1369
(Fla. 1980); Jenkins v. State, 385 So. 2d 1356 (Fla.
1980).
No motion fox* rehearing or reinstatement will
be entertained by the Court.
A True Copy
Test:
SC2024-1479 10/17/2024
/s/ John A. Tomasino
Clerk, Supreme Court
5a
Appendix B
CASE NO.: SC2024-1479
Page Two
SC2024-1479 10/17/2024
TD
Served:
3DCA CLERK
MIAMI-DADE CLERK
MONROE CLERK
HON. LUIS GARCIA
IVY R. GINSBERG
BRADLEY E. KING
ROBIN KING
SARAH KING
6a
APPENDIX C - ORDER DENYING MOTION TO
COMPEL IN THE 16TH JUDICIAL CIRCUIT IN
MONROE COUNTY, FILED JULY 8, 2024
Filing# 202074543 E-Filed 07/08/2024 04:55:55 PM
IN THE CIRCUIT COURT OF THE 16th JUDICIAL
CIRCUIT, IN AND FOR MONROE COUNTY,
FLORIDA
CASE NO.: 2021-CF-310-AP
STATE OF FLORIDA,
Plaintiff,
And
BRADLEY KING,
Defendant.
ORDER DENYING MOTION TO COMPEL
THIS CAUSE came before the court upon the filing of
Defendant's Motion to Compel. The court, having,
reviewed the motion and being otherwise fully advised
in the premises, it is therefore,
ORDERED AND ADJUDGED as follows:
1. The Defendant, Bradley King filed a Motion to
Compel on June 17, 2024, with a closed case number
20CF59AP State of Florida vs. Juan Gonzalez. This
motion contains the incorrect style and case number.
7a
Appendix C
2. The Clerk of the Court filed this motion in closed
case number 21CF310AP - State of Florida vs. Bradley
King. This case was closed on January 10, 2023, and
was transferred to County Court case number
23MM59AP.
3. County Court case number 23MM59AP - State of
Florida vs. Brandley King was disposed of by the
Court on November 2, 2023.
4. The Motion to Compel the Monroe County Clerk of
the Court to delete Petitioner's name and affiliation
with case number 20CF59AP - State of Florida vs.
Juan Gonzalez is hereby DENIED. There is nothing in
this case file to indicate that Defendant Bradley King
is a party to this case.
5. The Motion to Compel Attorney#l, David
Hutchison, to finish the second and third parts of the
contractual agreement is hereby DENIED.
6. This order cancels the hearing currently scheduled
for July 30, 2024, at 10^30 a.m. via Zoom.
DONE AND ORDERED in chambers in Monroe
County, Plantation Key, Florida, this _8_ day of July
2024.
Is/ Luis Garcia
Luis M. Garcia, Circuit Judge
8a
Appendix C
Ce:
Dennis Ward, SA, dward@kevssao.org
Trey Evans, ASA, tevans@kevssao.org
David Hutchison, Esq., info@floridakevslegal.com;
Karen@floridakevslegal.com
Bradley King, myjehovah777@mail.com and 137 South
Courtenay Parkway, Unit 626, Merritt
Island, FL 32952
9a
Appendix C
IN THE CIRCUIT COURT OF THE SIXTEENTH
JUDICIAL CIRCUIT IN AND FOR MONROE
COUNTY, STATE OF FLORIDA
UPPER KEYS CRIMINAL DIVISION
Case Number 2020CF00059AP
State of Florida
vs.
Juan C Gonzalez
W/M, DOB: 06/07/1974
INFORMATION FOR:
1) Grand Theft (Motor Vehicle) 812.014 (2)(c)(6) (3 F)
2) Possession of Controlled Substance 893.13 (3 F)
3) Petit Theft 812.014(1) & (3)(a) (2 M)
4) Possession of Paraphernalia (Use) 893.147 lb (l M)
In the Name and by Authority of the State ofFlorida *
Dennis W. Ward, State Attorney for the Sixteenth
Judicial Circuit, prosecuting for the State of Florida in
defendant(s), with the intent to permanently or
temporarily deprive Jay D Moore or any other person
not the defendant(s) of the property or benefit there
from or to appropriate the property to the use of Juan
C Gonzalez or to the use of any person not entitled
thereto, contrary to Florida Statute 812.014(1) and the
10a
Appendix C
said Judicial Circuit, under oath, information makes
' that Defendant, Juan C Gonzalez on or about March
14, 2020, in the County of Monroe and State of
Florida, did knowingly obtain or use, or endeavour to
obtain or use a motor vehicle which was the property
of Jay D Moore, or any other person not the
defendants with the intent to permanently or
temporarily deprive jay D Moore or any other person
not the defendant(s) of the property or benefit there
from or to appropriate the property to the use of Juan
C Gonzalez or to the use of any person not entitled
thereto, contrary to Florida Statute 812.014(1) and
(2) (c)(6).
COUNT 2• And the said Dennis W. Ward, State
Attorney for the Sixteenth Judicial Circuit,
prosecuting for the State of Florida in the said
Judicial Circuit, under oath, further information
makes that Defendant, Juan C Gonzalez on or about
March 14, 2020, in the County of Monroe and State of
Florida, was unlawfully and knowingly in actual or
constructive possession of Testosterone Cypionate, a
substance classified under Florida Statute 893.03,
commonly known as anabolic steroids, a controlled
substance, contrary to Florida Statute 893.13.
COUNT 3: And the said Dennis W. Ward, State
Attorney for the Sixteenth Judicial Circuit,
prosecuting for the State of Florida in the said
Judicial Circuit, under oath, further information
makes that Defendant, Juan C Gonzalez on or about
March 14, 2020, in the County of Monroe and State of
11a
Appendix C
Florida, did knowingly obtain or use, or endeavour to
obtain or use a license plate of some vale, which was
the property of Eliu Menendez Permuy, or any other
person not the defendant(s), with the intent to
permanently or temporarily deprive Eliu Menendez
Permuy or any other person not the defendant(s) of
the property or benefit there from or to appropriate
the property to the use of Juan C Gonzalez or to the
use of any person not entitled thereto, contrary to
Florida Statute 812.014(1) and (3)(a).
COUNT 4■ And the said Dennis W. Ward, State
Attorney for the Sixteenth Judicial Circuit,
prosecuting for the State of Florida in the said
Judicial Circuit, under oath, further information es
that Defendant, Juan C Gonzalez on or about March
14, 2020, in the County of Monroe and State of
Florida, was unlawfully and knowingly in actual or
constructive possession of syringes, which was drug
paraphernalia being used, intended for use, or
designed for use in injecting, ingesting, inhaling, of
otherwise introducing into the human body a
controlled substance, contrary to Florida Statute
893.147(l)(b).
The State hereby "NO ACTIONS" all remaining
charges in this case.
/s/Luke Bovill
Luke Bovill
Page 1 of 2
12a
Appendix C
Assistant State Attorney
Florida Bar No. 95527
88820 Overseas Highway
Tavernier, Florida 33070
(305) 852-7170
Lbovill@keyssao.org
STATE OF FLORIDA,
COUNTY OF MONROE
Personally appeared before me, Luke Bovill, Assistant
State Attorney for the Sixteenth Judicial Circuit of
Florida who is personally known to me and whose
signature appears above, and who being duly sworn,
says that the allegations set forth in this Information
are based upon facts that have been sworn to as true,
and which, if true, would constitute the offense(s)
charged and further certifies that this prosecution is
instituted in good faith and based upon testimony
received under oath from the material witness or
witnesses for the offense(s).
Sworn to and subscribed to before me this 20 day of
March 2020.
/si JESSICA KILMURRAY
NOTARY PUBLIC, State of Florida
JESSICA MCNAMEE KILMURRAY
Commission # GG 946516
My Comm. Expires Jan 12, 2024
Bonded through National Notary Assn.
Page 2 of 2
13a
Appendix C
IN THE COUNTY COURT OF THE SIXTEENTH
JUDICIAL CIRCUIT IN AND FOR MONROE
COUNTY, STATE OF FLORIDA
UPPER KEYS CRIMINAL DIVISION
Case Number
■aAmsaji
igv-s.~-.ir—•
* **}
State of Florida
vs.
Bradley Eugene King
W/M, DOB: 10/16/1962
AMENDED INFORMATION FOR:
1) Battery 784.03(1) (1 M)
2) Battery 784.03(1) (1M)
In the Name and by Authority of the State of Florida:
Dennis W. Ward, State Attorney for the Sixteenth
Judicial Circuit, prosecuting for the State of Florida in
the said Judicial Circuit, under oath, information
makes that Defendant, Bradley Eugene King on or
about November 30,2021, in the County of Monroe and
State of Florida, did then and there actually and
intentionally touch or strike Adele Chico against her
will, or did intentionally cause bodily harm thereto
contrary to Florida Statute 784-03.
14a
Appendix C
COUNT 3: And the said Dennis W, Ward, State
Attorney for the Sixteenth Judicial Circuit,
prosecuting for the State of Florida in the said
Judicial Circuit, under oath, further information
makes that Defendant, Bradley Eugene King on or
about November 30,202L, in the County of Monroe
and State of Florida, did then and there actually and
intentionally touch or strike Charla Chico against her
will, or did intentionally cause bodily harm thereto,
contrary to Florida Statute 784.03.
The State hereby “NO ACTIONS" all remaining
charges in this case.
/s/ Trey Evans
Trey Evans
Assistant State Attorney
Florida Bar No. 1019996
88770 Overseas Highway, Suite 3
Tavernier, Florida 33070
(305) 852-7170
tevans@keyssao.org
STATE OF FLORIDA,
COUNTY OF MONROE
Personally appeared before me, Trey Evans, Assistant
State Attorney for the Sixteenth Judicial Circuit of
Florida who is personally known to me and whose
signature appears above, and who being duly sworn,
15a
Appendix C
says that the allegations set forth in this Information
are based upon facts, which if true, would constitute
the offense(s) charged, and that this prosecution is
instituted in good faith.
Sworn to and subscribed to before me this 9_day of
January 2023.
/s/ JESSICA KILMURRAY
NOTARY PUBLIC, State of Florida
JESSICA MCNAMEE KILMURRAY
Commission # GG 946516
My Comm. Expires Jan 12, 2024
Bonded through National Notary Assn.
16a
APPENDIX D - ORDER OF HEARING
CANCELLATION IN THE 16TH JUDICIAL CIR.,
FILED MAY 7, 2024
Filing# 197755832 E-Filed 05/07/202410:15:56 AM
IN THE CIRCUIT COURT OF THE SIXTEENTH
JUDICIAL CIRCUIT,
IN AND FOR MONROE COUNTY, FLORIDA
CASE NO.: 44-2021-CF-31O-AP
STATE OF FLORIDA,
vs.
BRADLEY EUGENE KING,
Defendant.
NOTICE OF CANCELLATION OF HEARING
The hearing on the Motion to Compel currently
scheduled for June 4,2024, at 9:30 a.m. is hereby
cancelled and removed from the docket. This case was
transferred to Misdemeanor in January 2023;
therefore, this Court no longer retains jurisdiction.
I HEREBY CERTIFY THAT a copy of this notice was
mailed/emailed to all parties on the Tuesday, May 7,
2024
17a
Appendix D
Bradley Eugene King
myj eho vah@key ssao. or g
David George Hutchison
info@fl.oridakeyslegal.com
kar e n@flor idakey sle gal. com
pleadings@floridakey sle gal. com
Trey Destin Evans
tevans@keyssao.org
ajones@keyssao.org
jkiImurray@keyssao.org
'44r8De%eF«000Si0^MRK’t)5?07/2d24 10:15:36 AM;
Wendy Dube, Judicial Assistant
44-2021-CF-000310-QG-0APK 05/07/2024 10:15:36 AM
18a
APPENDIX E - ORDER OF 16TH JUDICIAL
CIRCUIT COURT FOR IMMUNITY GRANTED
OCTOBER 31, 2023 AND CERTIFIED, DEC. 15, 2023
Filing# 185133135 E-Filed 10/31/2023 11:44:18 AM
IN THE COUNTY COURT OF THE SIXTEENTH
JUDICIAL CIRCUIT IN AND FOR MONROE
COUNTY, FLORIDA
Case No- 23-MM-59\AP
STATE OF FLORIDA,
Plaintiff
v.
BRADLEY KING,
Defendant.
ORDER GRANTING DEFENDANT'S MOTION TO
DISMISS DECLARATION OF IMMUNITY
This Cause came before the Court on the 10th day of
October 2023, upon the Defendant's Motion for
Declaration of Immunity and Dismissal pursuant to
Florida Statute 5776.031. The Court, having heard
argument and being otherwise fully informed in the
premises, finds and orders as follows:
1. The Defendant seeks to have the charges dismissed
based upon his statutory immunity pursuant to Fla.
stat. s776.031.
19a
Appendix E
2. The Defendant is charged with 2 counts of battery
upon the alleged victims, which occurred on or about
November 30, 2021.
3. The State has conceded the burden has shifted for
purposes of the Stand Your Ground Motion.
4. Testimony was taken from Adele Chico, Charla
Chico, Sarah King and the Defendant, Bradley King.
A cell phone video on the day of the alleged incident
was played in court and introduced as Defendant's #1.
This video was taken by the alleged victim of Count 1
(Battery on Adele Chico).
5. The testimony of Charla Chico established her
family company owns and rents real property located
at 173 Iroquois Street, Tavernier, Florida. The
Defendant and his family rented the subject property
in Key Largo on an annual basis. At the beginning of
the lease the Defendant and his family rented the
downstairs portion of the home located in Key Largo.
Prior to the incident in question the Defendant and
his family moved to the upstairs portion of the house.
Charla Chico, on behalf of the rental business, allowed
the Defendant to move the curtains from the
downstairs dwelling to the upstairs dwelling.
6. According to Charla Chico the Defendant was
always complaining of something, he was late on
payments and having trouble paying the rent. On
November 29, 2021, Charla notified the renters of an
inspection on November 30, 2021 by texting the
20a
Appendix E
Defendant and
downstairs door.
posting
a
notice
on
the
front
7. The video taken on November 30, 2021 shows
Charla Chico, her husband Peter and their daughter
Adele, being let into the home and coming up the
stairs. Upon coming up the stairs there is immediate
tension and yelling between Charla Chico and the
Defendant. At one point Mrs. Chico instructs either
her daughter or husband to take down the curtains.
When they fail to react, Mrs. Chico begins taking
down the curtains. Mr. King yells at Mrs. Chico to
stop taking down the curtains and to leave his house
immediately. Mr. King grabs Charla's phone and runs
down the stairs in an attempt to have Charla follow
him out of the home. It did not work.
9. Mr. King comes back into the house with the phone
and proceeds to throw it out the window over the
balcony. He testified he did this in an effort to have
Charla Chico go and retrieve the phone, thus leaving
the premises.
10. While Adele is filming the out of control situation,
Mr. King yells at Adele to leave his home and pushes
her with his body in an attempt to get her to leave the
property.
11. Adele Chico testified that Mr. King tried to kill her
mom and in response her mom stayed upstairs in the
house and locked herself in the bathroom.
21a
Appendix E
12. It is clear the Chico's came into the house to
conduct a lawful inspection of the home in accordance
with Chapter 83 Florida Statutes. However, Charla
Chico admitted she was angry when she came into the
tenant's home. Instead of merely inspecting the rental
property, Mrs. Chico started to and completed
removing the window curtains from the residence.
Mrs. Chico originally gave the Kings' permission to
have the curtains upstairs and then unilaterally
withdrew the permission when she started removing
the curtains.
13. It is also clear, based upon the testimony, that Mr.
King was a difficult tenant. He had filed complaints
about the Chicos with every agency he could think of,
to wit: the Department of Business and Professional
Regulations Division of Real Estate and The Florida
Housing Authority.
LAW
14. The Defendant must make a prima facia claim of
self-defense. The burden then shifts to the State to
prove by clear and convincing evidence Defendant is
not entitled to immunity based upon self-defense.
15. Here the State consented the Defendant had made
a prima facia claim of self-defense and the burden
shifted to the State.
16. The evidence presented by the State must be
credible. Memories must be clear and without
confusion. The sum total of the evidence must be of
22a
Appendix E
sufficient weight to convince the trier of fact without
hesitancy.
CONCLUSIONS
17. The State has failed to meet the shifted burden.
18. Here we have the alleged victims going into the
Defendant's rental premises for a lawful inspection.
However, the inspection turned into something more
once the alleged victim (Charla), began pulling down
the property of the Defendant (the curtains). Both
Charla Chico and Adele Chico were asked to leave the
rented home of the Defendant no less than 5 times.
19. There was clearly a confrontation involving
screaming and yelling between the Defendant, and
Charla and Adele Chico. The video shows Mrs. Chico
taking the curtains down and Mr. King repeatedly
asking Charla and Adele Chico to leave his home.
Both Charla and Mr. King advised they were going to
call the police.
20. When Mrs. Chico called the police, she can be
heard on the 91* 1- call advising the Defendant was
beating her up, tried to push her down the stairs, was
abusing her and her family and that he had a gun and
had threatened to use it. The police understandably
came to the home swiftly based upon the report.
21. The video played of the incident does not show any
23a
Appendix E
evidence of a felonious assault by the Defendant
attempting to push Charla Chico down the stairs. This
despite Mrs. Chico's continued description of the
incident as a "felony snatching". The video does show
the Defendant taking Charla's phone and ultimately
throwing it over the railing outside. The alleged
victims testified that the video does not depict the
entire incident.
22. It is convenient that every single felonious action
of the Defendant as alleged by Charla and Adele is not
on the video of the incident. A video both witnesses
testified was for the purpose of protection from the
Defendant.
23. The law in question allows someone the use of
reasonable force if the person is tortiously interfering
with property that is lawfully in the Defendant's
possession. That is exactly the facts we have herein.
The Defendant possessed the curtains lawfully. Mrs.
Chico was tortiously interfering with the Defendant's
property.
24. The actions of the Defendant were entirely
reasonable. An out of control landlord comes to the
Defendant's home for an inspection and starts to
remove personal property without proper authority.
Both Charla and Adele were asked to leave more than
once and instead of leaving continued to scream and
yell and increase the hostile situation occurring in
the rental home of their tenant.
24a
Appendix E
25. The actions of the Defendant taking the phone and
pushing both women in order to get them to stop
tortuously interfering with his property was
reasonable. The evidence presented causes great
hesitancy and does not meet the burden of clear and
convincing evidence.
IT IS THEREFORE ORDERED AND ADJUDGED
The Defendant's Motion to Dismiss based upon
immunity is GRANTED.
DONE AND ORDERED in Plantation Key, Monroe
County, Florida this Tuesday, October 31, 2023
‘V
"t.
5?
,i] f
t
t
, j1 i_____
m
.^
e 11:15:22 AM
JudP®2023-rMM^0M59430^0APK/10/31/2023
David G. Hutchison
PIeadings@FloridaKeyslegal.com
David George Hutchison
info@floridakeyslegal.com
karen@floridakeyslegal.com
pleadings@floridakeyslegal.com
Nick Gastesi; ngastesi@keyssao.org
Trey Destin Evans! tevans@keyssao.org
jkilmurray@keyssao.org; ajones@keyssao.org
25a
APPENDIX F - ORDER OF THE 16TH JUDICIAL
CIRCUIT COURT FOR DISMISSAL OF
RESTRAINING ORDERS, FILED MARCH 7, 2022
Filed March 7, 2022, 12:14 PM
IN THE CIRCUIT COURT OF THE SIXTEENTH
JUDICIAL CIRCUIT,
IN AND FOR MONROE COUNTY, FLORIDA
Case No: 2021-DR-423-P
Division: Plantation Key Family Court
CHARLA CAE CHICO,
Petitioner,
And
BRADLEY EUGENE KING,
Respondent,
ORDER OF DISSMISSAL OF TEMPORARY
INJUNCTION FOR PROTECTION
AGAINST ( ) DOMESTIC VIOLENCE (X) REPEAT
VIOLENCE ( ) DATING VIOLENCE ( ) SEXUAL
VIOLENCE ( ) STALKING
THIS CAUSE came before the Court on MARCH 7,
2022, upon Petitioner’s action for an injunction for
protection against: domestic violence! repeat, dating,
or sexual violence! or stalking. Based upon the
following circumstances, the Court dismisses the
Petition:
26a
Appendix F
a. ____ Petitioner failed to appear at the hearing
scheduled in this cause.
b. ____ Petitioner appeared at the hearing but
desires to voluntarily dismiss this action.
c.
iLJA&The evidence presented is insufficient
under Florida Law (sections 741.30, 784.046, or
784.046, or 784.0485, Florida Statutes) to allow
the Court to issue an injunction for protection
against domestic, repeat
Accordingly, the case is dismissed without prejudice.
DONE AND ORDERED in PLANTATION KEY,
Monroe County, Florida, on MARCH 7, 2022.
/s/Luis Garcia
LUIS M. GARCIA
CIRCUIT JUDGE
'k'k'k
THE RESPONDENT HAS A PENDING
COLLATERAL CRIMINAL CASE # 21-CF-310-AP •k'k'k
Florida Supreme Court Approved Family Law Form
12.980(e), Order of Dismissal of Temporary Injunction
for Protection Against Domestic Violence, Repeat
Violence, Dating Violence, Sexual Violence, or
Stalking (03/15)
27a
Appendix F
COPIES TO:
xxx Sheriff of Monroe County
Petitioner (or his or her attorney):
___ /by U.S. Mail
\/ by hand delivery in open court
____by e-mail to designated e-mail address(es)
Respondent (or his or her attorney):
forwarded to sheriff for service
v by hand delivery in open court
____by e-mail to designated e-mail address(es)
xxx State’s Attorney’s Office
xxx Other: E. LOGAN / DVC
xxx Rayme Suarez, pet’s atty
xxx David Hutchison, resp’s atty
I CERTIFY the foregoing is a true copy of the original
Order of Dismissal of Temporary Injunction as it
appears on file in the office of the Clerk of the Circuit
Court of Monroe County , Florida, and that I have
furnished copies of this order as indicated above.
28a
Appendix F
mm
\
De Yinfterk
(SEAL)
*SS;
Florida Supreme Court Approved Family Law Form
12.980(e), Order of Dismissal of Temporary Injunction
for Protection Against Domestic Violence, Repeat
Violence, Dating Violence, Sexual Violence, or
Stalking (03/15)
29a
APPENDIX G - NOTICE OF TRANSFER AND
AMENDED INFORMATION CF ERROR IN
MONROE COUNTY STATE ATTORNEY OFFICE,
FILED JANUARY 9, 2023
Filing# 164337523 E-Filed 01/09/2023 11:55:01 AM
IN THE CIRCUIT COURT OF THE SIXTEENTH
JUDICIAL CIRCUIT
IN AND FOR MONROE COUNTY, FLORIDA
UPPER KEYS CRIMINAL DIVISION
CASE No. 2021CF00310AP
STATE OF FLORIDA,
Plaintiff
vs.
BRADLEY EUGENE KING,
Defendant,
NOTICE OF TRANSFER TO COUNTY COURT
The State of Florida has filed an Information in
this case charging an offense which is a misdemeanor.
Therefore, the Clerk of Circuit Court is hereby
directed to transfer the case to the Clerk of the County
Court for further proceedings. The State of Florida
further requests that this case be scheduled for the
30a
Appendix G
next available arraignment docket before the County
Judge that will be assigned to this case.
I do certify that a copy hereof has been
furnished to David Hutchison Esq. by electronic
mail on the 9th day of January 2023.
Respectfully submitted
Dennis W. Ward, State Attorney
88770 Overseas Highway
Suite 3
Tavernier, Florida 33070
Tel. (305) 852-7170
Fax.
By: Isl Trev Evans
Trey Evans
Assistant State Attorney
Florida Bar No. 1019996
tevans@keyssao.org
31a
Appendix G
IN THE COUNTY COURT OF THE SIXTEENTH
JUDICIAL CIRCUIT IN AND FOR MONROE
COUNTY, STATE OF FLORIDA
UPPER KEYS CRIMINAL DIVISION
aoCFSq^g
Case Number '
State of Florida
vs.
Bradley Eugene King
W/M, DOB: 10/16/1962
AMENDED INFORMATION FOR:
1)
2)
Battery 784.03(1) (l M)
Battery 784.03(1) (1M)
In the Name and by Authority of the State of
Florida 77
Dennis W. Ward, State Attorney for the Sixteenth
Judicial Circuit, prosecuting for the State of Florida in
the said Judicial Circuit, under oath, information
makes that Defendant, Bradley Eugene King on or
about November 30, 2021, in the County of Monroe
and State of Florida, did then and there actually and
intentionally touch or strike Adele Chico against her
will, or did intentionally cause bodily harm thereto,
contrary to Florida Statute 784.03.
32a
Appendix G
COUNT 3^ And the said Dennis W. Ward, State
Attorney for the Sixteenth Judicial Circuit,
prosecuting for the State of Florida in the said
Judicial Circuit, under oath, further information
makes that Defendant, Bradley Eugene King on or
about November 30, 2021, in the County of Monroe
and State of Florida, did then and there actually and
intentionally touch or strike Charla Chico against her
will, or did intentionally cause bodily harm thereto,
contrary to Florida Statute 784.03.
The State hereby “NO ACTIONS"
all remaining charges in this case.
/s/ Trey Evans
Trey Evans
Assistant State Attorney
Florida Bar No. 1019996
88770 Overseas Highway,
Suite 3
Tavernier, Florida 33070
(305) 852-7170
tevans@keyssao.org
STATE OF FLORIDA,
COUNTY OF MONROE
33a
Appendix G
Personally appeared before me, Trey Evans, Assistant
State Attorney for the Sixteenth Judicial Circuit of
Florida who is personally known to me and whose
signature appears above, and who being duly sworn,
says that the allegations set forth in this Information
are based upon facts, which if true, would constitute
the offense(s) charged, and that this prosecution is
instituted in good faith.
Sworn to and subscribed to before me this
January 2023.
<\
day of
/s/ JESSICA KILMURRAY
NOTARY PUBLIC, State of Florida
JESSICA MCNAMEE KILMURRAY
Commission # GG 946516
My Comm. Expires Jan 12, 2024
Bonded through National Notary Assn.
Page 2 of 2
34a
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
IN THE COUNTY COURT OF THE SIXTEENTH
JUDICIAL CIRCUIT IN AND FOR MONROE
COUNTY, STATE OF FLORIDA
UPPER KEYS CRIMINAL DIVISION
j
Case Number 29W^;
State-of Florida
vs.
Bradley Eugene King
W/M, DOB: 10/16/1962
AMENDED INFORMATIONFOR:
1)
2)
Battery 784.03(1) (l M)
Battery 784.03(1) (1M)
In the Name and by Authority of the State of
Florida-'O
35a
Appendix H
Dennis W. Ward, State Attorney for the Sixteenth
Judicial Circuit, prosecuting for the State of Florida in
the said Judicial Circuit, under oath, information
makes that Defendant, Bradley Eugene King on or
about November 30, 2021, in the County of Monroe
and State of Florida, did then and there actually and
intentionally touch or strike Adele Chico against her
will, or did intentionally cause bodily harm thereto,
contrary to Florida Statute 784.03.
COUNT 3^ And the said Dennis W. Ward, State
Attorney for the Sixteenth Judicial Circuit,
prosecuting for the State of Florida in the said
Judicial Circuit, under oath, further information
makes that Defendant, Bradley Eugene King on or
about November 30, 2021, in the County of Monroe
and State of Florida, did then and there actually and
intentionally touch or strike Charla Chico against her
will, or did intentionally cause bodily harm thereto,
contrary to Florida Statute 784.03.
The State hereby “NO ACTIONS"
all remaining charges in this case.
/s/ Trey Evans
Trey Evans
Assistant State Attorney
Florida Bar No. 1019996
88770 Overseas Highway, Suite 3
Tavernier, Florida 33070
(305) 852-7170
tevans@keyssao.org
36a
Appendix H
STATE OF FLORIDA,
COUNTY OF MONROE
Personally appeared before me, Trey Evans, Assistant
State Attorney for the Sixteenth Judicial Circuit of
Florida who is personally known to me and whose
signature appears above, and who being duly sworn,
says that the allegations set forth in this Information
are based upon facts, which if true, would constitute
the offense(s) charged, and that this prosecution is
instituted in good faith.
^ day of
Sworn to and subscribed to before me this
January 2023.
/s/ JESSICA KILMURRAY
NOTARY PUBLIC, State of Florida
JESSICA MCNAMEE KILMURRAY
Commission # GG 946516
My Comm. Expires Jan 12, 2024
Bonded through National Notary Assn.
state
My hot'*1 <5t,d
»n full fom* atwi
Th>«
i /6»rti'CJrcojR
..****•«.
till
S'; CM
Page 2 of 2
*
■
n
I
37a
APPENDIX I - CHARGES INFORMATION BY
STATE ATTORNEY DENNIS WARD, FILED
DECEMBER 20, 2021
FILED FOR RECORD DEC. 20, 2021, 2:21 PM
IN THE CIRCUIT COURT OF THE SIXTEENTH
JUDICIAL CIRCUIT IN AND FOR MONROE
COUNTY, STATE OF FLORIDA
UPPER KEYS CRIMINAL DIVISION
Case Number 2021CF00310AP
State of Florida
vs.
Bradley Eugene King
W/M, DOB: 10/16/1962
INFORMATION FOR:
l)
2)
3)
Robbery by Sudden Snatching 812.131(1) & (2b)
(3 F)
Battery 784.03(1) (l M)
Battery 784.03(1) (l M)
In the Name and by Authority of the State ofFlorida:
Dennis W. Ward, State Attorney for the Sixteenth
Judicial Circuit, prosecuting for the State of Florida in
the said Judicial Circuit, under oath, information
makes that Defendant, Bradley Eugene King on or
38a
Appendix I
about November 30, 2021, in the County of Monroe
and State of Florida, did knowingly take away a
cellular phone, of some value, from the person or
custody of Charla Cae Chico, with the intent to
permanently or temporarily deprive Charla Cae Chico
or any other person not the defendant of the property,
when in the course of the taking, Charla Cae Chico
was or became aware of the taking, contrary to Florida
Statute 812.13l(l)and(2b).
COUNT 2- And the said Dennis W. Ward, State
Attorney for the Sixteenth Judicial Circuit,
prosecuting for the State of Florida in the said
Judicial Circuit, under oath, further information
makes that Defendant, Bradley Eugene King on or
about November 30, 2021, in the County of Monroe
and State of Florida, did then and there actually and
intentionally touch or strike Adele Chico, against the
will of Adele Chico, contrary to Florida Statute 784.03.
COUNT 3: And the said Dennis W. Ward, State
Attorney for the Sixteenth Judicial Circuit,
prosecuting for the State of Florida in the said
Judicial Circuit, under oath, further information
makes that Defendant, Bradley Eugene King on or
about November 30, 2021, in the County of Monroe
and State of Florida, did then and there actually and
intentionally touch or strike Charla Cae Chico,
against the will of Charla Cae Chico, contrary to
Florida Statute 784.03.
39a
Appendix I
The State hereby "NO ACTIONS"
all remaining charges in this case.
/s/ Joseph Mansfield
Joseph Mansfield
Assistant State Attorney
Florida Bar No. 610631
88820 Overseas Highway
Tavernier, Florida 33070
(3o5) 852-7170
jmansfield@keyssao.org
STATE OF FLORIDA,
COUNTY OF MONROE
Personally appeared before me, Joseph Mansfield,
Assistant State Attorney for the Sixteenth Judicial
Circuit of Florida who is personally known to me and
whose signature appears above, and who being duly
sworn, says that the allegations set forth in this
Information are based upon facts that have been
sworn to as true, and which, if true, would constitute
the offense(s) charged and further certifies that this
prosecution is instituted in good faith and based upon
testimony received under oath from the material
witness or witnesses for the offense(s).
Sworn to and subscribed to before me this 20th day of
December 2021.
/s/Angela G. Jones
ANGELA G. JONES
Notary Public * State of Florida NOTARY PUBLIC,
State of Florida
SMISj Commission # GG 920197
Xgffs*' My Comm. Expires Dec 16, 2023
'"""flooded through National Notary Assn.
40a
APPENDIX J - MOTION OF FLORIDA ATTORNEY
GENERAL’S OFFICE IN THE 3RD D.C.A., FILED
AUGUST 14, 2024
Filing# 204685752 E'Filed 08/14/2024 11:06:36 AM
IN THE DISTRICT COURT OF APPEAL
OF FLORIDA, THIRD DISTRICT
CASE NO: 3D24-1359
L.T. No. 21-CF-310-A-P
BRADLEY E. KING,
Appellant,
v.
THE STATE OF FLORIDA,
Appellee.
MOTION TO DISMISS APPEAL FOR LACK OF
JURISDICTON
Appellee, the State of Florida, by and through
undersigned counsel, pursuant to Florida Rule of
Appellate Procedure 9.300, hereby moves to dismiss
this appeal based on the Court’s lack of jurisdiction
and in support thereof states as follows.
40a
Appendix J
1. The Notice of Appeal filed on July 29, 2024, is from
an Order Denying a Motion to Compel rendered on
July 8, 2024.
2. This is a pre-trial order which the Appellant is not
authorized to appeal under Florida Rule of
Appellate Procedure 9.140(b) or under section
924.06, Florida Statutes (2023). Section 924.06
provides that
(l)A defendant may appeal from:
(a)A final judgment of conviction when probation
has not been granted under chapter 948, except
as provided in subsection (3)
(b)An order granting probation under chapter 948,'
(c)An order revoking probation under chapter948;
(d)A sentence, on the ground that it is illegal; or
(e)A sentence imposed under s. 921.0024 of the
Criminal Punishment Code which exceeds the
statutory maximum penalty ...
(2)An appeal of an order granting probation shall
proceed in the same manner and have the same
effect as an appeal of a judgment of conviction. An
appeal of an order revoking probation may review
only proceedings after the order of probation. If a
judgment of conviction preceded an order of
41a
Appendix J
probation, the defendant may appeal from the
order or the judgment or both.
(3)A defendant who pleads guilty with no express
reservation of the right to appeal a legally dispositive
issue, or a defendant who pleads nolo contendere with
no express reservation of the right to appeal a legally
dispositive issue, shall have no right to a direct
appeal.
§ 924.06, Fla. Stat. (2023).
WHEREFORE, the State respectfully requests that
this Court dismiss this appeal.
Respectfully submitted,
ASHLEY MOODY
ATTORNEY GENERAL
/s/IvvR. Ginsberg
IVY R. GINSBERG
Assistant Attorney General
Florida Bar No. 612316
Office of the Attorney General
One S.E. Third Avenue, Suite 900
Miami, Florida 33131
(305) 377-5441
PRIMARY: CrimAppMia@myfloridalegal.com
Secondary: Ivy.ginsberg@myfloridalegal.com
42a
Appendix J
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct
copy of the foregoing Notice of Appearance and
Designation of E-mail Addresses was furnished by
U.S. mail on August 13, 2024, to Bradley E. King,
137 South Courtnay Parkway Unit 626, Marritt
Island, Florida 32952, myjehovah77@mail.com.
CERTIFICATE OF COMPLIANCE
I HEREBY CERTIFY that the foregoing motion was
typed in Arial, 14-point font and is in compliance with
the word count limits in accordance with
Fla. R. App. P. 9.045(e).
/s/ Ivy R. Ginsberg
IVY R. GINSBERG
43a
APPENDIX K - NOTICE TO INVOKE
DISCRETIONARY JURISDICTION OF THE
FLORIDA SUPREME COURT, FILED OCT. 17, 2024
Filed October 17, 2024 1L58 AM
IN THE DISTRICT COURT OF APPEAL OF
FLORIDA, THIRD DISTRICT
FL SUPREME Court No.:________
THIRD D.C.A. No.: 3D2024-1359
L.T. No.: 2021CF310AP
BRADLEY E. KING, ROBIN
KING and SARAH KING,
Petitioners,
v.
THE STATE OF FLORIDA,
Respondents.
NOTICE TO INVOKE DISCRETIONARY
JURISDICTION OF SUPREME COURT
NOTICE IS GIVEN on this 17 day of October, 2024,
that BRADLEY E. KING, ROBIN KING and SARAH
KING, Petitioners, invoke the discretionary
jurisdiction of the Supreme Court to hear, through
oral argument, what the L.T. Court and the 3rd
44a
Appendix K
D.C.A. Court chose not to hear, expressly the usage of
Florida Statutes used by the State to indemnify ’
another man's crimes while leaving the Petitioners
without an option to pursue damages.
Is/ Robin King
Isl Bradley King
Bradley King, Pro-se
Robin King
Is/ Sarah King
Sarah King
Page 1 of 2
Petitioners reachable via e-mail:
myjehovah777@mail.com; Additional mailing address:
137 South Courtenay Parkway, Unit 626, Merritt
Island, FL 32952.
CERTIFICATE OF SERVICE
Petitioners HEREBY CERTIFY that a copy of the
foregoing Notice will be furnished by U.S. Mail /eMail, or in person on October 17_, 2024 to:
Third D.C.A.: 2001 S.W. 117th Ave., Miami, FL 33175.
Attorney General, Ashley Moody / Assistant Attorney
General, Ivy Ginsberg
One S.E. Third Avenue, Suite 900, Miami, Florida
33131
PRIMARY: CrimAppMia@myfloridalegal.com
Secondary: Ivy.ginsberg@myfloridalegal.com
45a
Appendix K
The Circuit Court for the 16th Judicial Circuit,
Monroe County:
Cc. Judicial Assistant, Wendy Dube.
(wendy.dube@keyscourts.net)
Cc. Riza Tabag. ( rtabag@monroe-clerk.com )
STATE OF FLORIDA:
Cc. State Attorney, Mr. Dennis Ward.
(dward@keyssao.org)
Cc. Assistant State Attorney, Mr. Trey Evans.
(tevans@keyssao.org)
ATTORNEY:
Cc. Mr. David G. Hutchison, EsquireJRFA#24-9885.
info@floridakeyslegal.com
Page 2 of 2
46a
Appendix K
IN THE DISTRICT COURT OF APPEAL
OF FLORIDA THIRD DISTRICT
3D2024-1359
Trial Court Case No. 21-CF-310-A-P
BRADLEY E. KING,
Appellant(s),
v.
THE STATE OF FLORIDA,
Appellee (s).
IT IS HEREBY ORDERED that Appellee’s
Motion to Dismiss Appeal for Lack of Jurisdiction is
granted, and this appeal from the Circuit Court for the
Sixteenth Judicial Circuit, Monroe County, Florida, is
hereby dismissed for lack of jurisdiction.
EMAS, SCALES and GORDO, JJ., concur.
A True Copy
ATTEST
/s/ Mercedes Prieto
3D2024-1359 9/18/24]
Mercedes M. Prieto, Clerk
District Court of Appeal
Third District
47a
Appendix K
CC^ Crim Appeals MIA Attorney General
Monroe Clerk
Hon. Luis Garcia
Ivy R. Ginsberg
David George Hutchison
Bradley E. King
Robin King
Sarah King
NS
48a
APPENDIX L - NOTICE GIVEN NOV. 21, 2022 OF
EVIDENTIARY HEARING SET FOR JAN. 9, 2023 IN
THE 16TH JUDICIAL CIRCUIT
Filing# 161675752 E-Filed 11/21/2022 04:46:03 PM
IN THE CIRCUIT COURT OF THE SIXTEENTH
JUDICIAL CIRCUIT
IN AND FOR MONROE COUNTY, FLORIDA
CRIMINAL DIVISION
Case No. 21-CF-000310-A-P
State of Florida
Plaintiff
v.
Bradley King
Defendant
RE-NOTICE OF EVIDENTIARY HEARING
PLEASE TAKE NOTICE that the evidentiary
hearing on Defendant's Motion to Determine
Immunity from Criminal Prosecution Under F.S.
§776.031 has been re-scheduled and is to be held as
follows:
Date:
Time:
Monday, January 9, 2023
1:30 p.m. to 3:30 p.m.
49a
Appendix L
LocationJudge:
Plantation Key Courthouse
88770 Overseas Highway
Tavernier, Florida 33070
Honorable Luis M. Garcia
The hearing previously set for Tuesday, November 29,
2022, at L30pm is CANCELLED.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of
the foregoing has been provided electronic mail on the
21st day of November 2022 to the Office of the State
Attorney, 88820 Overseas Hwy., Tavernier, FL 33070.
Respectfully Submitted,
/s/David G. Hutchison
David G. Hutchison, Esq.
Fla. Bar No. 997420
Hutchison& Tubiana, PLLC
P.O. Box 371262
Key Largo, FL 33037
(3o5) 451-0013
info@floridakeysle gal. com
50a
APPENDIX M - MOTION TO COMPEL (FIRST
PAGE ALTERED) IN THE 16TH JUDICIAL CIR.,
DATED JUNE 17, 2024
IN THE CIRCUIT COURT OF THE SIXTEENTH
JUDICIAL CIRCUIT,
IN AND FOR MONROE COUNTY, FLORIDA
UPPER KEYS CRIMINAL DIVISION
i
P
Case No: 2<)-#-59g
o r"
—
O
rv_
—1
30
—io
2s
03
o
"
pa
72
V
cr>
O
io
STATE OF FLORIDA,
vs.
BRADLEY EUGENE KING
W/M, DOB: 10/16/1962,
MOTION TO COMPEL
Comes now Pro-se Bradley E. King, as Petitioner and
Robin King, and Sarah King herein known as
"Petitioners". Since the mid 80’s, Petitioners have held
multiple licenses working directly with the Courts and
the State. Petitioner was given a job opportunity by
N.A.S.A.’s Engineering Division who agreed to a year's
vacation before coming back home to an acre of land to
build a house on and the last job that Petitioner would
ever need. Petitioners chose an annually Teased, [...]
51a
APPENDIX N - UNALTERED MOTION TO
COMPEL IN THE 16TH JUDICIAL CIR., FILED
JUNE 17, 2024
IN THE CIRCUIT COURT OF THE SIXTEENTH
JUDICIAL CIRCUIT,
IN AND FOR MONROE COUNTY, FLORIDA
UPPER KEYS CRIMINAL DIVISION
Case No: 20-CF-59-AP
STATE OF FLORIDA,
vs.
BRADLEY EUGENE KING
W/M, DOB: 10/16/1962,
MOTION TO COMPEL
Comes now Pro*se Bradley E. King, as Petitioner and
Robin King, and Sarah King herein known as
"Petitioners". Since the mid 80's, Petitioners have held
multiple licenses working directly with the Courts and
the State. Petitioner was given a job opportunity by
N.A.S.A.'s Engineering Division who agreed to a year's
vacation before coming back home to an acre of land to
build a house on and the last job that Petitioner would
ever need. Petitioners chose an annually-leased,
private residential home in an upscale neighborhood
in Plantation Key, Florida, only to find out afterwards
that the Landlord (a man well-known in the city and
even more so in the Courts as Drug Runner, Pete
52a
Appendix N
A.K.A Pedro Chico, who lived next door to Petitioners)
was about to start an illegal build-out of Petitioners'
leased home. Petitioners showed reluctance more than
once to allow "on-the-spot" entry without notice,
remodeling of block walls, the removal of six-foot long
jalousie windows and more within the home.
Petitioners, blowing the whistle by sending letters to
the Housing Authority and to the D.B.P.R., found
Landlords retaliated against said letters by subjecting
Petitioners to hazing and harassment with false
eviction letters, hate mail, robbery, and an unlawful
arrest by a dirty Cop on November 30, 2021. The
Petitioners were then left in the dark as the State
Prosecutor (who found out, in or about November
2022, about the arresting officer's dismissal from the
Police Force and the Petitioner's unlawful arrest)
chose to further abuse Petitioners by adding two
misdemeanors, and another man's felony that is found
in the style and case number at the heading of this
Motion. The fact that Petitioners were completely
exonerated by the Courts, leaves this CF error, and
the unlawful arrest on November 30, 2021, and other
errors made by the State in question. Further
grounds will state:
1.
Petitioners, who all had spotless records when
first moving to the Florida Keys, not knowing
anybody, leased for a year a home in an upscale
neighborhood in Plantation Key by a man known as
Pedro Chico (aka Pedro Chico-Ortez) who offered a
year’s lease.
53a
Appendix N
2.
This unfortunate, unknowing move by the
Petitioners into Mr. Chico’s annually Teased rental
home was where Petitioner, (Father of the King
family), was later unlawfully arrested and jailed on
November 30, 2021.
3.
Petitioner at that time was charged a single
third-degree felony when arrested by a Monroe County
Sherriff, Sergeant Nicholis Whiteman, who later was
seen as doing a favor for the well-known, wealthy
drug-runner, Mr. Chico.
4.
Petitioners will address this matter with more
detail below.
5.
On or about December 1, 2021, the Petitioner
announced to the Courts his Pro-Se status, so a bail
was granted by the Honorable, Judge Sharon
Hamilton.
On December 1, 2021, The Chicos sought after
6.
three permanent restraining orders; one for Mr. Chico
and two other household members. (Case #2021-DR423-P).
7.
Petitioner handled the alleged charge by
entering evidence in excess of a hundred pages (100) of
facts and documents to facilitate the first Hearing
concerning said restraining orders before Judge
Hamilton. In that Hearing, the Chicos also requested
that the Courts evict the Petitioners from said home!
54a
Appendix N
the request for eviction was denied (Zoom online
hearing dated on or about December 14, 2021).
8.
On December 23, 2021 (near Christmas Eve),
while Petitioners were on a Christmas vacation, Mr.
Chico left three (3) eviction notices on the front door of
Petitioners. The Chicos had a Sheriff follow through
with a quick eviction, and, in short, Petitioners were
evicted. This left Petitioners homeless when returning
from said vacation.
9.
Petitioner arranged and attended multiple
hearings before (Family court) Judge Hamilton, before
the Case was passed on to the Honorable Judge Luis
Garcia for the (CF) style case number of said arrest.
10.
On or about January 4, 2022, the State
Attorney set up an arraignment Hearing to be heard
before Judge Garcia where the Petitioner submitted at
that time his NOA to the Courts and developed his
own plea of “Not Guilty” and asking for a trial by jury.
11.
The Monroe County State Attorney, Dennis
Ward, chose to add at that above-mentioned
arraignment two (2) additional misdemeanors that the
Petitioner was assured by the arresting officer that he
would not be charged with, (case #2021- CF- 00310AP).
12.
Petitioner scheduled a meeting after the
arraignment and spoke for about an hour directly with
the Assistant State Attorney, Joe Mansfield, in the
/
55a
Appendix N
attempt to convince him of the unlawful arrest and to
drop all charges. (Hooray! It worked, but not until
Sergeant Whiteman, the arresting Officer, was found
out by an Internal Affairs Agent, Michelle Maxwell,
and Sergeant Askins who was present at the time of
the arrest, and who argued that it was the wrong
thing to do, hence Sergeant Whiteman was dismissed
from the Police Force in or about November of 2022.)
13.
Petitioners will address the dismissal
mentioned-above with more detail below.
14.
The Chicos, through false allegations,
demanded that a hearing take place on March 7, 2022
before Judge Garcia to determine permanent
restraining orders.
Petitioners hired on January 21, 2022,
15.
Attorney, David George Hutchison! FJA No.: 24-9885,
herein known as "Attorney #1" to help in testifying in
open court and to develop a strategy.
Petitioners filled in Attorney #1 on the work
16.
already done, and on the facts of the alreadyestablished case.
17.
Attorney #1 agreed on a retainer of fivethousand dollars ($5,000) and a three-part contractual
and verbal agreement:
(First) dismissal of the Restraining Orders!
• :
56a
Appendix N
(Second) dismissal of the Felony/Misdemeanor
charges;
(Third) getting back what was stolen from the
Petitioner’s family through malicious prosecution
with a 40\60 split.
18.
The First-part of the above-mentioned
agreement (permanent restraining orders) handled by
both Petitioners and Attorney #1 was heard, and as
Attorney #1 put it, “it was a hands-down victory”
dismissed quickly before Judge Luis Garcia on March
7, 2022. This was ‘easy-Pickens’ for Attorney #l's first
of three parts he agreed to and was paid for.
19.
On or about November 15, 2022, Sergeant
Whiteman was given an ultimatum by Internal Affairs
Director, Agent Michelle Maxwell, who stated to the
Petitioners while meeting with her on November 27,
2023 at the Monroe County Sheriffs Department (Key
West), “I informed Officer Whiteman to resign or else”.
20.
Petitioners were not made aware of Officer
Whiteman’s dismissal until November 21, 2023, when
first informed by Captain Derek Paul, who is over
Officer Whiteman’s former district.
21.
Petitioners will address Captain Derek Paul’s
statement with more detail below.
22.
On January 9, 2023, the State Attorney, Dennis
Ward, dropped the only charge the Petitioner was
arrested and placed in jail for (a third-degree Felony
57a
Appendix N
charge) on November 30, 2021 by Officer Whiteman.
This act should have ended this case for the obvious
reasons.
23.
The State Attorney charged on as Assistant
State Attorney (Mr. Trey Evans), erred in his January
9, 2023 attempt to transfer said case to the lower
Courts by improperly styling said case as # 20 - CF 59 - AP, keeping it active and allowing another man's
felony to be connected to the Petitioner. (Please see
attached transfer).
24.
Every so often, since January 9, 2023, and
forward, Attorney #1 would comment to the
Petitioners while meeting with them, “The State
Attorney could reopen the felony case at any time, so
you need us”.
25.
Petitioners believe the above-mentioned
statement of needing Attorney#l was a tool and a
scare tactic to keep control of the Petitioners, not
realizing until the November 21, 2023 discussion with
Captain Paul that the above-mentioned tool had
substance.
26.
Petitioners will address this tactical approach
by Attorney #1 with more detail below.
27.
On January 9, 2023, Attorney #1 stated he first
received the news of the State Attorney dropping the
felony charge. This was just weeks after Officer
Whiteman’s dismissal.
58a
Appendix N
28.
Attorney #1 called the Petitioners on January 9,
2023, at or about 10;30 a.m. informing them only of
the felony being dropped, not why, nor that the
arresting officer Sergeant Whiteman was dismissed
from duty.
29.
On January 9, 2023, while Attorney #1 spoke to
the Petitioners, Attorney #1 demanded the right to
clean-up what was left in the three-part contractual
and verbal agreement.
30.
The 'clean-up' that Attorney #1 was speaking of
wasA. The two misdemeanors the State applied at the
January, 2022 arraignment Hearing and has chosen
to continue in.
B. The agreed-upon litigation concerning Malicious
Prosecution charges with a 40/60 split.
31.
Attorney #1 simply did not want to give up the
twelve-thousand seven-hundred dollar ($12,700.00)
cash money amount (plus Petitioners' professional
court reporter services, which Petitioner paid for)
given for Attorney #l’s original three-part contractual
agreement of his fees and services.
32.
Petitioners met at Attorney #l’s request in his
office on about January 18, 2023 to sign a new
contract relating to the felony drop made by State
Attorney Dennis Ward, and said agreements in
59a
Appendix N
paragraph 29 with three-thousand five-hundred
dollars ($3,500.00) dollars as a retainer.
Attorney #1 then continued forward with said
33.
agreements.
34.
Petitioners were reassured in that meeting by
Attorney #1 who stated, “I will live up to the
remainder of the second and third parts of our original
agreement”.
35.
Attorney #l’s reassurance of performance that
day was not misread by any of the Petitioners who
have signed their signatures at the bottom of this
Motion to Compel.
36.
Before Petitioners go any further, please allow a
recap concerning the dismissal of the arresting Officer,
Sergeant Nicholis Whiteman.
37.
On or about November 15, 2022, marked the
arresting officer, Sergeant Whiteman’s, departure
from the Police Force for what Petitioners and Monroe
County Police Department are calling a wrongful
arrest, 'derelict of duty' among other riotous acts and
yet to be litigated.
In the beginning of said case, malicious
38.
prosecution by the arresting Officer Whiteman was
the most crucial part of the above-mentioned case to
confront, according to Agent Michelle Maxwell, an
Internal Affairs official at the Monroe County
60a
Appendix N
Sherriffs Office (Key West), whom the Petitioners met
with on or about November 27, 2023.
39.
Agent Maxwell suggested in that abovementioned meeting what Petitioners should have done
at the beginning of said felony case by stating: “You
should have come to me first about Sergeant
vJ
Whiteman’s wrongful arrest”. Petitioner replied, “I
first brought the history of this case to the presiding
Judge Sharon Hamilton, later to the Assistant State
Attorney, Joe Mansfield, and then again to Attorney
#1.”
40.
Agent Maxwell replied, “And they never told
you to come to me?” Petitioners answered, “No”. This
remark made by Agent Maxwell implied that all three
The Presiding Judge, Assistant State Attorney, and
Attorney #1, should have referred Petitioners to come
to Agent Maxwell.
41.
The above-mentioned Agent Maxwell also
stated to the Petitioners that she gave Sergeant
Whiteman an ultimatum on or about November of
2022 “to resign or else”.
42.
Agent Michelle Maxwell also stated, at the end
of the meeting on November 27, 2023, “if Sergeant
Whiteman didn’t resign, I would have fired him”.
43.
Petitioners also held a lengthy meeting on
November 21, 2023 with the Monroe County Sherriffs
Office Captain Derek Paul (several days prior of Agent
61a
Appendix N
Maxwell’s comments), discussing the unlawful arrest
by Sergeant Nicholis Whiteman and his dismissal
from the Force in great detail with police camcorder
video footage supplied by the State Attorney Mr. Trey
Evans and Petitioner's demand for the prosecution of
the Chicos (please see Complaint delivered to: Captain
Paul; Agent Michelle Maxwell; State Attorney's office,
Tom Walker; and Chief Sheriff, Rick Ramsey).
44.
Captain Paul responded in the November 21,
2023 meeting, “about ninety-seven percent (97%) of
the Officers in this County are clean; it is a shame
concerning Whiteman and his dismissal”.
45.
The Internal Affairs Agent, Michelle Maxwell,
did her job by hearing Sergeant Askins' rebuttal on
video and investigating the November 30, 2021 arrest,
and in the end, removing Sergeant Whiteman from
the force.
Petitioners spent several hours with the heroes
46.
of this case like Captain Derek Paul, Internal affairs
agent Michelle Maxwell, and of course Chief Ramsey,
while attempting to provide reasons to peruse said
complaint first given to Captain Deric Paul on
November 21, 2023.
47.
Petitioners spent about one hour on November
27, 2023 presenting this same above- mentioned
Complaint to State Attorney, Tom Walker, in his Key
West office pursuant to Agent Maxwell's request
thirty (30) minutes earlier regarding "swearing out
62a
Appendix N
arrest warrants" concerning the prosecution of the
Chicos.
48.
Mr. Walker seemed to get nervous at the end of
said meeting when Petitioners mentioned the name of
the drug runner, Pedro Chico, and then insisted that
he's not the one to prosecute the Chicos, review the
complaint, or swear-out arrest warrants, and that
Sherriff Ramsey would be the man to talk to.
49.
Chief Ramsey stated to the Petitioner on
November 29, 2023 while spending about one hour
with him and Captain Derek Paul, "Mr. Walker lied to
you. He is the one, and I don't know why he blew you
off." This conversation went on in the presence of
Captain Derek Paul.
50.
Paragraph 25 discusses Attorney #1. tactical
approach Furthermore, Petitioner will state:
51.
The above-mentioned information concerning
Sergeant Whiteman’s dismissal came in a host of ways
that Attorney #1 would have been privy to, such as:
1. (Why) The State Attorney dropped said
felony just weeks after Officer Whiteman’s dismissal.
2. (Why) The State Attorney dropped said
felony.
3. (Why) The State Attorney dropped said
felony and not the misdemeanors.
63a
Appendix N
4. (Why) Attorney #1, who stated over the
phone in January 2023 to Petitioners, "I am looking at
the notice of transfer and the amended information for
the two batteries that Assistant State Attorney, Trey
Evans, sent to me and you guys need to meet with me
later at the end of this month to discuss what's next".
Yet, later that month, when meeting Attorney# 1,
nothing was said about the obvious wrong year and
CF eri’or of the Amended Information Document or
the dismissal of Sergeant Whiteman.
52.
The “Why” questions mentioned above are fair,
and the Petitioners did ask Attorney #1 about the
above-mentioned "Why" questions before and after
said discussion with Agent Maxwell, and, each time,
all accounts got a response from Attorney #1 of, “I
don’t know why”.
53.
The Assistant State Attorney, Mr. Evans’, (CF)
transfer error mentioned-above is a huge problem in
the eyes of the Marathon Key Clerk of Courts and the
F.D.L.E. who both made the same statement, in
December 2023 “either the CF case is expunged or the
MM case (not both) can be expunged in a single
lifetime”. (Note '■ Petitioners are not asking the
F.D.L.E. to clean up the State's mess.)
54.
Despite the Arresting Officer being dismissed,
Attorney #1 demanded in January 2023 that his role
in Petitioners three-part contractual agreement was
not finished and went after the second part of said
contractual agreement (two misdemeanors within a
64a
Appendix N
CF eroded case) by arranging with the courts on May
10, 2023, a two and a half hour time slot for an
Immunity Motion to be heard (for case # 23-MM-59AP).
55.
On May 10, 2023, said Immunity Motion was
heard before Judge Hamilton, and Attorney #1 cut the
above-mentioned hearing short, finishing in about
thirty minutes.
56.
The courts denied the Motion, due to a lack of
evidence and testimony of the Petitioner’s Daughter,
Sarah King, who was present during the hearing, but
Attorney #1 would not allow to take the stand.
57.
Petitioner’s Daughter, Sarah King, witnessed
the November 30, 2021 incident and arrest first-hand.
58.
Petitioners, amazed at the lack of effort in both
involving the daughter, Sarah King, to take the stand
and performance, stated exactly that to Attorney #1.
59.
Attorney #1 apologized several days later in his
office to the Petitioners and stated, “I went blank in
the heat of the argument; I will set up another
Hearing”.
60.
Petitioners realized after said Hearing that
Attorney #1, a sharp individual, was dragging his feet
in his duties to defend Petitioners in a timely manner.
65a
Appendix N
A new Hearing was set for June 8, 2023, where
61.
the Assistant State Attorney, Mr. Evans, debated
technicalities of the case and demanded that Attorney
#1 give more information than he did in the prior May
10th Hearing.
62.
Attorney #1 asked and was granted a
Continuance in said Hearing with a comment from the
Judge of “keep Mr. King’s case moving forward”.
On or about July 6, 2023, Attorney #1 once
63.
again set aside a time slot for the above-mentioned
Immunity Motion to be heard. This time, the State
demanded that there was still a lack of details
involved in the Motion provided by Attorney #1.
64.
The courts gave yet more latitude to Attorney
#1 by granting him another Continuance.
July 10, 2023, Attorney #1, e-mailed Petitioners
65.
to settle-up their account in full, a total of Onethousand four-hundred and fifty dollars ($1,450.00).
Petitioners paid Attorney #1 said monies in full.
66.
Another Hearing was set for August 16, 2023, with
both sides in attendance, and a newly detailed
Immunity Motion was filed.
67.
Attorney #1 did not fulfill, once again, all that
was required by the State to understand what the
Immunity Motion would detail.
66a
Appendix N
68.
Attorney #1 and the Assistant State Attorney,
Mr. Evans, both asked the Judge for yet another
Continuance.
69.
The Honorable Judge Sharon Hamilton gave
both Attorney #1 and the Assistant State Attorney,
Mr. Evans, what they both wanted.
70.
Another Hearing was set to be heard on October
4, 2023.
71.
Petitioners then respectfully had to demand
that Attorney #1 have Sarah King (Petitioner’s
Daughter), who saw the November 30, 2021 incident
take place first-hand, give to the Courts what the
Courts stated in the May 10, 2023 Hearing was
needed.
72.
Sarah King’s acute and accurate full testimony
for the first time concerning the November 30, 2021
arrest was given on October 4, 2023.
73.
This time, Attorney #1 did finish said Hearing
on October 4, 2023 to the satisfaction of the courts.
74.
The Courts issued an Order on October 31, 2023
granting Petitioners’ Motion for Immunity and
dismissing the misdemeanors that the State added on
in the January 2023's amended information for Two
misdemeanor battery's with case #20-CF-59-AP.
67a
Appendix N
As mentioned in paragraph 25, concerning the
75.
tool being used by Attorney #1 and the abuse of it, and
what the State developed can be found in the CF error
detailed at the heading of this motion.
The State Attorney did not challenge the above76.
mentioned court decision in the 30-day period allotted,
sealing the deal on November 30, 2023 exactly two
years after the said arrest. (Please see attached copy
of the Order by the Honorable Sharon Hamilton
granting petitioners motion for immunity).
You would think Attorney #1 would say
77.
"Hooray!" for the Petitioners! not so.
78.
Attorney #1 seemingly continued to waffle to
this day in his second agreed-upon responsibilities to
finish handling the (CF) error made by Assistant State
Attorney Trey Evans.
79.
Attorney #1 simply has a three-part contractual
agreement to uphold concerning case #’s1. Case #1 : 2021-DR-423-P
(dismissed by Court
order signed by Judge Garcia)
2. Case #2 : 2021-CF-00310-AP (To be heard by
Judge Garcia, but dropped by the State)
(Assistant State
3. Case #3: 20-CF-59-AP
Attorney’s Mr. Evan's (CF) transfer error)
4. Case #4‘- 2023-MM-59-AP (Immunity Motion
granted by Judge Hamilton)
5. Malicious Prosecution Case # (yet to start
litigation)
■
68a
Appendix N
80.
A Monroe County Clerk in Marathon Key,
Florida commented and stamped (as certified
dispositions) certain copies of the recent immunity
hearing in December of 2023, but refused to stamp the
CF error (amended information/transfer document).
According to the Clerk, this was obviously a mistake
and that Petitioners need to take the Assistant State
Attorney’s CF error to an Attorney so the Court can
order the felony to be properly dropped otherwise the
felony of the one known as Juan Gonzalez, will always
be seen and connected to Petitioners name in the
Clerk's data base.
81.
The Clerk also stated, “The new number should
have been #23-MM-59-AP”.
82.
Petitioners case in its entirety should have been
dropped when the unlawful arrest and the dismissal of
Sergeant Whiteman was made known to the State.
83.
Agent Michelle Maxwell (the Attorney for the
Monroe County Sherriff) also stated at the abovementioned November 27, 2023 meeting concerning
Sergeant Whiteman, “The malicious prosecution
statute concerning the arresting officer involved in
this case will come to an end in the very near future”.
84.
This overwhelming comment, given to the
Petitioners, was brought to Attorney #1 at or about
the end of November 2023.
t
69a
Appendix N
85.
Attorney #1 disagreed with Agent Michelle
Maxwell.
86.
Attorney #1 is the Owner and founder of the
firm known as Hutchison and Tubiana, located in Key
Largo, Florida, with what he claims has practiced law
for over thirty years.
87.
Attorney #1 stated that he did the research on
said comment made by the Internal Affairs leading
Agent Maxwell; and he confidently stated, “Agent
Michelle Maxwell is wrong”, and that, "We have four
years from the time of the 2022 arraignment to file a
malicious prosecution case".
88.
This comment was to assure the Petitioners of
Attorney #l's involvement in the third part of said
contractual agreement.
89.
Attorney #1 continued to reaffirm to Petitioners
that they should simply wait until the first of the year
(2024) when holidays were over, and that at the
beginning of the new year, Attorney #1 would follow
through with said contractual agreement concerning
Malicious Charges.
i
On or about January 2, 2024, Petitioners spoke
90.
with Attorney #1 on the phone, who once again
reassured Petitioners of the direction concerning the
third part of said agreement, and the malicious
statutes, and that Petitioners should come back to his
*
70a
Appendix N
office on or about January 8, 2024 concerning said
agreements.
91.
On January 8, 2024, Petitioners came back as
scheduled to Attorney #l’s office and, spoke in further
detail of the mishandling of the Assistant State
Attorney (CF) error. Attorney #1 and his Wife (Karen)
developed an e-mail at or about 6^00 pm asking the
Assistant State Attorney to properly follow through
with the January 9th 2023 dropping of said felony.
Attorney #1 then assured petitioners that he
would fix it and he would get a simple 'agreed order'
done from Mr. Evans, and to come back in a couple of
weeks to sign on for the 40/60 final step of said
agreement because he had yet to develop said
contract.
92.
On January 23, 2024, Petitioners were told by
Attorney#l, who Petitioners now believe was stalling
for unknown reasons, to come back five times after
the January 23, 2024 meeting.
Once on February 15, 2025
Once on February 16, 2025
Once on February 19, 2025
Once on February 20, 2025
Once on February 21, 2025
93.
On February 21, 2024, as well as all the abovementioned February dates, Petitioners all came
respectfully and patiently back, to Attorney #l’s office
to sign said litigation contract and were told by
Attorney #1 in the beginning of this meeting, “I can’t
. ^
. *
71a
Appendix N
help you anymore” and that Petitioners should seek
after another Attorney, preferably a firm known as
‘Rubenstein’, or the firm ‘Morgan and Morgan’.
94.
Petitioners reminded Attorney #1 of his
contractual agreements that he was paid for.
Attorney #l’s response, once again, was, “I can’t
95.
help you” unless you would like to pay me both ways,
for attorneys fees and a 40/60 split.
Attorney #1 at that time went against said
96.
three-step agreement that he originally demanded
that Petitioners keep as mentioned in paragraph 29.
97.
Petitioner informed Attorney #1, "I’ll be taking
this to the Bar". Attorney #l’s response was
"Go ahead".
98.
Attorney #1 simply stated at the end of the
February 21, 2024 short meeting, “I know what our
agreements are; I can’t help you unless you pay both
ways”.
Such actions were initiated by a well-known
99.
drug runner, a dirty Cop then by an assistant State
Attorney's error, and most horribly by Attoi'ney #1,
who has failed to disclose information concerning
Sergeant Whiteman, and his dismissal this much
Petitioners believe Attorney #1 would of been privy to.
. »
72a
Appendix N
100. Attorney #1 also refusing to finish said (CF)
case errors or initiate the third step of his contractual
agreed-upon litigations that he was paid in full for.
In conclusion, "Too many supposed defense
lawyers do not care to rock the boat so as to garner the
wrath of the prosecutors with whom they work
regularly." In a 2007 case, Justin Hopson vs. New
Jersey State Police, is found to be a match to the
occurrence of abuse and retaliation that the
Petitioners suffered in this case and the actions of a
lordship of those who think they are going to keep
someone 'in line' or in the dark despite the rules of
engagement designed to protect the public. The Law
Bar, prompted by Attorney #1, replied as well in
stating: "The Supreme Court of Florida has ruled that
the disciplinary process and proceedings are not to be
used as a substitute for civil proceedings and
remedies. See The Florida Bar v. Della-Donna, 583 So.
2d 307 (Fla. 1989)." This makes it clear that a ruling
concerning neglect or malicious behavior from the
above-mentioned Attorneys would first come from the
lower Courts and any further actions would take place
afterwards. Furthermore, Petitioners understand
that this Honorable Court would know if the malicious
prosecution of a victim of an unlawful arrest (that
was acquitted and fully exonerated ) would be subject
to a statute where police cam-cording and testimony
would run out in a four year period of time as
described by Attorney #1 or not, and if the Assistant
State Attorney’s (CF) error, left unattended, would
leave the Clerk of the Courts and the F.D.L.E. without
.
0“
73a
Appendix N
remedy. Criminal case # 20-CF-59-AP, which is
completely unaffiliated with Petitioners unlawful
arrest, would impair Petitioners’ ability to apply to
N.A.S.A. for employment. Petitioners Pray for the
Courts to show mercy on the acquittal of the
Petitioner who was completely exonerated by both the
Criminal and Family Courts regardless of the State,
who should have known of Sergeant Whitman's
dismissal, but rather carried on their suit in 2023 by
an erred CF case number that Attorney #1 stated he
never saw. Thus, abusing Petitioners for two full years
before the Heroes of this case, who were found in the
Monroe County Police Department, saw the unlawful
Felony arrest by Sergeant Whiteman and dismissed
him from his duties as an officer. Petitioners pray this
Honorable Court consider signing two Orders:
First to direct the Monroe County Clerk to delete
Petitioners name and affiliation with one, Juan
Gonzalez, Case # 20-CF-59-AP, noted at the heading
of this complaint, and any misdemeanor charge due to
the November 30, 2021 unlawful arrest of which the
Petitioner was acquitted for.
Secondly, an Order to Compel Attorney #1 to finish
the second and third parts of the above-mentioned
contractual agreements that he was paid for in full;
this coupled with what the Courts see to be
appropriate and just before men and God.
«
74a
Appendix N
Dated: 6-17-2024
Bradley King Prcrse
Dated: 6-17-2024
Robin King
Dated: 6-17-2024
Sarah King
Petitioners reachable via e-mail:
mviehovah777@mail.com
Additional mailing address: 137 South Courtenay
Parkway, Unit 626, Merritt Island, FL 32952
I HEREBY CERTIFY THAT a copy of this notice
was mailed/emailed to all parties on the Monday, June
17, 2024.
Cc. State Attorney Mr. Dennis Ward, (e - mailed to:
dward@keyssao.org)
Cc. Assistant State Attorney Mr. Trey Evans.
(e - mailed to: tevans@keyssao.org)
Cc. Mr. David George Hutchison, esquire; RFA No.:
24-9885. ( e - mailed to: info@floridakeyslegal.com )
Karen@floridakeyslegal.com
J*
75a
Appendix N
Short List of Relevant State and Court Actions and
Attachments below (more available upon request):
Hearing in attendance dated on, December 14, 2021
Case # 2021 - DR - 423 — P ( Restraining Orders )
(Zoom online with Judge Hamilton)
Link:
httpsV/zoom.us/i/91279405272?pwd=NWZDaDlkZzZsZ
0F6WExRRXFDQExtUT09
State Attorney Filed Notice adding ■ on 2 batteries on
December 20, 2021, ( Felony / Misdemeanors )
Case # 2021 - CF - 00310 - AP
Eviction Notice (“Summons”), December 23, 2021
Case # 21 - CC - 159 - P
(Judge Garcia was appointed restraining orders’ case
after January 1, 2022)
Arraignment Hearing of said case, January 4, 2022,
Case # 2021 - CF * 00310 - AP
Court's Final Judgment for Eviction dated,
January 7, 2022, Case # 21 - CC — 159 — P
Hearing in attendance dated March 7, 2022
Case # 2021 - DR - 423 - P
Court Order Response dated March 7, 2022
Case #2021 - DR - 423-P
i
76a
Appendix N
Hearing dated January 9, 2023
Case # 2021 - CF - 00310 - AP
State Attorney’s Transfer dated January 9, 2023
2021 • CF - 00310-AP
Assistant State Attorney’s (CF) error January 9, 2023
Case # 20 - CF - 59 - AP (active)
Hearing in attendance dated May 10, 2023
Case # 23 - MM - 59 - AP
Court Order Response dated June 20, 2023
Case # 23 - MM - 59 - AP
Hearing in attendance dated June 8, 2023
Case # 23 - MM ■ 59 - AP
Court Order for continuance date July 6, 2023
Case # 23 - MM - 59 - AP
Hearing in attendance dated July 6, 2023
Case # 23 ■ MM - 59 - AP
Court Order for continuance date August 3, 2023
Case # 23 - MM - 59 - AP
Hearing in attendance dated August 16, 2023
Case # 23 - MM ■ 59 - AP
Court Order for continuance date September 7, 2023
Case #23 - MM - 59-AP
77a
Appendix N
Hearing in attendance dated October 4, 2023
Case # 23 ■ MM - 59 - AP
Court Order Granting Dismissal October 31, 2023
Case # 23 ■ MM ■ 59 - AP
Court Minutes noting: November 2, 2023
In regards of two batteries, “Crt Dismissed per crt
order”
Above-mentioned Court Order Finalized November 30,
2023, Case # 23 - MM - 59 - AP
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.