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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APPENDIX

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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

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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

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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

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, j1 i_____

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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

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till

S'; CM

Page 2 of 2

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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

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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.

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