I THE CIRCUIT COURT OF THE FIRST JUDICIAL CIRCUIT

I AD FOR WALTO COUTY, FLORIDA

FAMILY LAW DIVISIO

JOH CARROLL

Petitioner Case o.: 01DR00423
Former Husband,
vs.

JOSETTE CARROLL
Respondent
Former Wife

____________________________________________/

PETITIOERS MOTIO TO COMPEL PRODUCTIO OF DOCUMETS AD
TRUTHFUL ASWERS TO DISCOVERY BY FORMER WIFE

Petitioner Former Husband, pursuant to Florida Rules of Civil Procedure 1.380,
requests the Court compel the Respondent Former Wife to produce an accurate and
complete Florida Family Law Rules of Procedure Form 12.902 (b) or (c), Financial
Affidavit as required by Florida law.
1. The Former Wife became a trustee and beneficiary of the Valentine J.
Rhodes, Unified Credit Trust U/A on July 29, 1999. The Former Wife concealed this
financial windfall from her then Husband, John Carroll.
2. The Former Wife filed her 1
st
Financial Affidavit on September 12, 2001.
This was Josette Carrolls first fraudulent and incomplete financial affidavit making no
mention of her status as beneficiary under the trust.
3. Relying on the Former Wifes false filings, the parties entered a voluntary
dissolution on October 2, 2002.
4. The former husband discovered the former wife had been secretly






disrupting his business arrangements and capitalizing upon them by purchasing millions
of dollars of property as beneficiary and trustee of said trust (Exhibit A).
5. Former Husband filed his Supplemental Petition to Modify on September
3, 2003.
6. The Court ordered Josette Carroll to appear at mediation along with an
authentic financial affidavit on September 3, 2003.
7. Josette Carroll did not appear at the mediation, and did not file an
authentic financial affidavit.
8. Mediation was re-set, John Carroll filed his updated financial affidavit and
Josette failed to appear at mediation or file her financial affidavit. The Mediator filed his
report of same on November 12, 2003.
9. Former Husband filed his renewed Supplemental Petition to Modify Child
Support on March 31, 2004 along with his current financial affidavit.
10. Former Wife failed to deliver her Financial Affidavit and John Carroll
filed his Emergency Verified Motion Requiring Financial Affidavit on May 14, 2004.
11. June 23, 2004, the Court ordered Josette Carroll to appear at Mediation
and have her authentic Financial Affidavit for the mediator.
12. July 26, 2004, Josette Carroll canceled the Mediation, and did not appear
or file an authenticated Financial Affidavit.
13. On October 8, 2004, Former Husband filed his Amended Supplemental
Petition for Modification of Child Support.
14. April 7, 2005 in response to the Former Husbands Motion to Compel and
for Contempt against Former Wife, the Court Ordered the Former Wife to surrender






certain documents to the Court Appointed Special Master, Bart Fleet, Esq. for his review
regarding Josette Carrolls involvement in said trust.
15. On May 9, 2005, the Special Master issued his report to the Court wherein
he stated, The Special Master has not been provided copies of any annual accountings
for the Unified Credit Trust. Consequently, the Special Master does not know what
assets are (or have been owned) by the Unified Credit Trust.
16. The Special Master went on to say that the Former Wife, Josette Carroll is
both a Trustee and a Beneficiary of said trust, and entitled to distributions of income for
her health, maintenance, education, support and comfort.
17. Thereafter the Former Husband suffered a suggestion of bankruptcy.
18. Over the next 30 months ending on July 2008 the Former Husband paid a
total of $128,000.00 in support through the DOR and staved off bankruptcy.
19. On January 20, 2009 the Former Husband liquidated the bulk of his
deposit in the courts registry and paid a lump sum of $59,500.00 to the Former Wife.
20. DOR continuously refused to set a hearing on the unrepresented Former
Husbands Petition to Modify Child Support.
21. On September 29, 2009, Josette Carroll moved into a 4,148 square foot
home, owned by her trust, which is classified as a distribution gain according to the
Internal Revenue Code (Exhibit B).
22. On December 12, 2011 the Former Husband liquidated his deposit in the
Courts registry by paying Josette Carroll $5,500.00.
23. Former Husband filed no asset Chapter 7 Bankruptcy October 2012.
24. It is now 2 weeks before the final hearing on Petitioner John Carrolls






Supplemental Petition to Modify Child Support, and Respondent Former Wife continues
to refuse to file her accurate and truthful Financial Affidavit.
WHEREFORE, the Petitioner, Former Husband John Carroll prays the Court will:
Enter an Order consistent with Florida Rule 1.380(b)(2)(A), Ordering that the
allegations made by John Carroll that Josette Carroll receives continuous benefits from
the Trust regarding the documents requested or any other designated facts shall be taken
to be established for the purposes of the action in accordance with Carrolls claims;
Enter an Order consistent with Florida Rule of Civil Procedure 1.380(b)(2)(B),
refusing to allow the Former Wife to support or oppose designated claims or defenses, or
prohibiting Josette Carroll from introducing designated matters in evidence;
Enter an Order consistent with Florida Rule of Civil Procedure 1.380(b)(2)(D),
finding Josette Carroll in Contempt of Court for failing to obey this Courts Orders and
Floridas Rules regarding Financial Affidavits of the Parties to Child Support
proceedings.
I HEREBY CERTIFY that a copy of the foregoing was forwarded to
Department of Revenue, PO Box 2250, Crestview, FL. 32536 by regular mail on this 1st
day of April, 2013.

_____________________________
John Carroll
Box 1215
Santa Rosa Beach, FL 32459

pdf.aspx http://orsearch.clerkofcourts.co.walton.fl.us/ORSearch/RecordDetails/pdf...
1 of 1 4/3/2013 3:58 PM
PARCEL
MAP
GENERATE OWNER LIST
BY RADIUS
RECENT SALES IN THIS AREA
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RETURN TO MAIN SEARCH PAGE WALTON HOME
OWNER NAME VALENTINE J RHODES UNIFIED TODAY'S DATE April 01, 2013
MAILING ADDRESS CREDIT TRUST PARCEL NUMBER 01-3S-20-34030-000-0060
139 RHODES CV MILLAGE GROUP South Walton Fire (7)
SANTA ROSA BEACH, FL 32459 TOTAL MILLAGE 9.703
PROPERTY USAGE SINGLE FAM (000100)
LOCATION ADDRESS 93 BLUE CORAL DR ACREAGE 0.542 ACRES
2012 CERTIFIED TAX ROLL
JUST VALUE
OF LAND
LAND VALUE
AGRICULTURAL
BUILDING
VALUE
TOTAL
MISC
VALUE
JUST OR
CLASSIFIED
TOTAL
VALUE
ASSESSED
VALUE
EXEMPT
VALUE
TAXABLE
VALUE
HOME
STEAD
50,872 0 298,807 1,200 350,879 350,879 0 350,879 N
LAND INFORMATION
LAND USE NUMBER OF UNITS UNIT TYPE SEC-TWN-RNG
SFR 1.000 UT 1-3S-20
SHORT LEGAL
LOT 6 PINES OF BLUE MOUNTAIN BEACH PB 6-21 OR 1056-228 OR 2608-2567 OR 2819-3673
BUILDING DATA
BUILDING # TYPE
TOTAL
AREA
HEATED
AREA
BED
ROOMS
BATHS
PRIMARY
EXTERIOR
SECONDARY
EXTERIOR
HEATING COOLING
ACTUAL
YEAR
BUILT
000100 4,148 3,142 4 3.5 VINYL N/A FORCED-AIR DUCTED CENTRAL 2002
MISCELLANEOUS DATA
DESCRIPTION
DIMENSIONS
LxWxH
UNITS YEAR BUILT
CONCRETE 0 x 0 x 0 1 UT 2002
SALES DATA
SALE DATE BOOK PAGE PRICE INSTRUMENT QUALIFICATION
IMPROVED?
(AT TIME OF
SALE)
GRANTOR GRANTEE
10-29-2010 2852 4021 100
QUIT CLAIM
DEED
UNQUALIFIED YES RHODES BRENDA S
VALENTINE J RHODES UNIFIED
CREDIT TRUST
09-16-2009 2826 3541 271,900 SW UNQUALIFIED YES
THE BANK OF NEW YORK AS
TRUSTEE FOR THE
RHODES BRENDA S
05-05-2009 2819 3673 800
WARRANTY
DEED
UNQUALIFIED YES
BRIGGS ROBERT *MM* &
BRIGGS DELYTE *SW*
THE BANK OF NEW YORK AS
TRUSTEE FOR THE
04-28-2004 2608 2567 375,000
WARRANTY
DEED
QUALIFIED YES KOURY RICHARD W
BRIGGS DELYTE W (UW)&
ROBERT A BRIGGS (MM)
The Walton County Property Appraiser's Office makes every effort to produce the most accurate information possible. No warranties, expressed or implied, are provided for the data herein, its use or
interpretation. The assessment information is from the last certified tax roll. All data is subject to change before the next certified tax roll. Website updated: March 5, 2013
RECENT SALES IN THIS AREA
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2002 by the County of Walton, FL [ Website design by qpublic.net
Walton County Record Search http://64.234.218.210/cgi-bin/waltondisplay.cgi?KEY01-3S-20-34030...
1 oI 1 4/1/2013 11:15 AM