Filing # 41172101 E-Filed 05/06/2016 11:09:57 AM. IN THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT, IN AND. FOR DIXIE COUNTY, FLORIDA. STATE OF FLORIDA CASE NO. 14-201-CF vs. TERRY GEORGE TRUSSELL, Defendant f TRAVERSE TO DEFENDANT'S MOTION TO DISMISS COMES NOW the State and files this Traverse to the Defendant's Motion to Dismiss. In support thereof, the State would show as follows: #1 Denied - Jeffery Siegmeister and Dana Johnson had absolutely nothing to do with the investigation and arrest of Terry Trussell: In fact, State Attorney Siegmeister removed himself and his office from any involvement after the arrest of Terry Trussell Dana Johnson merely forwarded copies of suspicious document to the Dixie County Sheriff. On page 2 of the Defendant's motion, he mixed an argument on immunity as a ground for dismissal which does not to comply with the 3.190(c)(4) motion. It should be noted that the statutory Grand Jury took no action, i.e. no indictments, no presentments so no action qualifies for any immunity. #3 Denied - The State had received information that Terry Trussell was going to refuse to enter the well of the courtroom. If he did appear and refused, the state was prepared to move the Court to hold him in contempt. Further, neither the Court nor the State knew Terry Trussell by sight and he did not come forward when his name was called. He was not identified until after the judge left the courtroom. Electronically Filed Dixie Case # 14000201CFAXMX 05/06/2016 11:09:57 AM#4 Denied ~ The charges against Terry Trussell have nothing to do with his role as a Statutory Grand Juror. #5 Denied - Demurrer — Does not allege any facts, #6 Denied ~ See State v. Michael Bamishin #7 Denied ~ Common Law Grand Juries are not recognized in Florida law. #8 Demurrer—Not relevant to Trussell #9 — Demurrer — Not relevant to Trussell. #10 Demurrer — Not relevant to Trussell #11 Denied — Defendant Trussell is charged with the counts that apply to his actions. #12 Denied ~ Does not allege factual matter in'dispute. Does not comply with Rule 3.190(c)(4). #13. & 14 _Demurrer ~ The State is without knowledge of Trussell's marital status or civic endeavors which also are not relevant to his charges. #15 Denied - Not relevant to Trussell’s charges. #16,17,18,19,20 Denied — The State is not labeling Trussell a sovereign citizen or loyalist. His affiliations are not relevant to his charges. The State is labeling Mr. Trussell as a Defendant. #21 Denied — Trussell’s charges do not relate to his position on a Statutory Grand Jury. #22 Denied — Siegmeister's belief are not relevant to Defendant Trussell's charges. #23 Denied — Not relevant to the Trussell’s charges.#24 Denied — Does not comport with Rule 3.190(c)(4). Not relevant to Trussell's charges. #25 & 26 Denied — Not relevant to Trussell’s charges. #27 Denied — Trussell's charges are not related to the Statutory Grand Jury. #28 Denied - The Defendant has no right under the First Amendment to file false and unlawful documents in the Dixie County Clerk's Office. #29 Denied — Not relevant to the charges against Defendant Trussell and does. not comport with Rule 3.190(c)(4), #30 Denied in Part and Admitted in Part'= The State is without knowledge of Larry Klayman's universe, Trussell was selected according to the Rules of Court for the Grand Jury. He was not elected by his follow Grand Jurors. #31 Denied — Trussell's selection to the Statutory Grand Jury merely gave him one vote out of twenty-one or a quorum of fifteen. #32 Denied — All that Trussell's selection to the Statutory Grand Jury granted him was to follow the instructions and honor his oath, #33 Admitted ~ Demurrer — Defendant Trussell is not charged with any acts done as a member of the Statutory Grand Jury. #34 Denied — Defendant Trussell is not being prosecuted as a member of any class. His charges arise out of his act of fling simulated legal process. #35 Demurrer — This statement makes no sense. #38 Denied - Dana Johnson reported what she believed to be a crime and conducted herself according to her training and experience. The court filing by Defendant Trussell still remains in the Dixie County Clerk’s Office.#37 Admitted #38 Denied - Dana Johnson removed the two True Bills from the Book and Page Record but they are stil filed in the Dixie County Clerk's Office #39 Demurrer - Not relevant to the charges against Defendant Trussell #40 Demurrer - The State is without knowledge and the statement is not relevant to Trussell’s charges #41 Denied ~ Trussell’s charges do not arise out of the Statutory Grand Jury service. #42,43,44,45,46,47,48,49 Denied — None of these grounds comport with Rule 3.190(c)(4) alleging factual matters in dispute. #50 Denied — Trussell is not charged with acts involving his status as a Statutory Grand Juror except for his deception in gaining access to the courthouse. #51 Denied — Trussell was not elected to any position with the Statutory Grand Jury. WHEREFORE, the State requests that this Court deny the Defendant's Motion to Dismiss. Respectfully submitted, Js/ William N. Megas WILLIAM N. MEGGS Assigned State Attorney Leon County Courthouse 301 S. Monroe Street Tallahassee, FL 32399-2550 (850) 608-6000 FL Bar No: 224545 $a02_leon@leoncountyfi.gov‘The foregoing Traverse was acknowledge before me on May 6, 2016, by William N. Megs, State Attorney, Second Judicial Circuit of the State of Florida, who is known to me and did take an oath stating good faith in filing the foregoing Traverse and certifying that testimony was received under oath from the material witness or witnesses for this offense. Littler Ty WILLIAM N. MEGGS' State Attorney Sworn to and subscribed before me this 6" day of May, 2016. jas plo hobo itary Public, State of Florida A\ Large THNETe UTLEY & Eanes Expires Oolber 28, 2017 ERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via electronic mail to Inger M. Garcia, Esquire, 4839 Volunteer Road, #514, Ft. Lauderdale, FL 33330, attommey@ingergarcia.com and by U.S. Mail this the 6th day of May, 2016. Js/ William N. Megas WILLIAM N. MEGGS- Assigned State Attorney