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  • 513 6-05-16 State V Trussell - Complaint For Quo Warranto

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    Jack Ryan
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    513 6-05-16 State v Trussell - Complaint for Quo Warranto

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    513 6-05-16 State v Trussell - Complaint for Quo Warranto

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    513 6-05-16 State v Trussell - Complaint for Quo Warranto

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    513 6-05-16 State V Trussell - Complaint For Quo Warranto

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    Jack Ryan
    513 6-05-16 State v Trussell - Complaint for Quo Warranto

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    Filing # 42334679 E-Filed 06/05/2016 10:38:17 PM. IN THE SUPREME COURT OF FLORIDA TERRY TRUSSELL, CASE NO. Plaintiff, v. Hon. Rick SCOTT, et.al. Defendant / COMPLAINT FOR QUO WARRANTO Plaintiff Terry Trussell sues defendant the Hon. Rick SCOTT and alleges: 1. This is an action for a writ of quo warranto. 2. The facts on which plaintiff relies are: (a) Plaintiff asked the Attomey General of Florida to institute this action in the name of the State, The Attorney General of Florida refused to do so on [date of refusal]. (b) Plaintiff was duly served a summons to appear for jury duty and was chosen for the Grand Jury and was duly appointed Grand Jury Forman of Dixie County for the April 21, 2104 term, took the oath of juror, and entered upon his duties as Grand Jury Forman. Electronically Filed Dixie Case # 14000201CFAXMX 06/05/2016 10:38:17 PM (©) Plaintiff was charged with 14 felony counts as retaliation, in Dixie County, and an investigation was opened against Plaintiff for his exercising his First Amendment rights to freely assemble and petition for redress. The Govemor of Florida by an initial Executive Order dated September 4, 2014, a copy being attached, appointed State Attomey Willie Meggs of the 2" Circuit to investigate and prosecute the crimes, of which the Governor himself was named as a victim in the 3 Judicial Circuit. The Supreme Court followed suit and named Judge Hankinson of the same circuit, the 2" Circuit, as the Judge to handle the case in the 3 Circuit, Dixie County. One of the purported victims is Governor Scott. The State Attomey and the Judge have known each other for years. The Judge worked with the State Attomey for over 10 years, and has not disclosed that fact to the defense. (4) On June 6, 2016, the trial of the plaintiff is set to begin in Dixie County at the Cross City Courthouse, Case No. 2014-201CF. An Executive Order 14-246 was entered on or about September 4, 2014, with a renewal request date of August 4, 2016, expired September 4, 2015. There is a 2” untimely Executive ‘unproduced” Order 15-202, dated October 14, 2015, expiring September 4, 2016. See attached Executive Orders. (e) Serious Discovery and due process violations. The main two documents at issue are two ‘true bills’ given to the clerk of court ~ who accidentally recorded in the public record then removed it, and replaced it with blank pages. The State to date has never given Defense the blank pages and the Clerk testified to this act. One major element of this crime is that to be a legal process - it must be filed or recorded. In this case it was initially recorded in error by the clerk’s admission, and then taken out of the official records without any court order or legal authority. This is a significant violationas FDLE Frank Linton testified that when he did his probable cause affidavit — he was under the impression the documents were filed in the official records and he didn't know it was removed or put into a private ‘blue’ file until asked questions at his December 3, 2015 Deposition. To date - the State has never produced the ‘blank public records,’ nor the Renewed Executive Orders extending his term for prosecution. The State is now purposefully misusing the term ‘filing’ and is trying to say that it is filed with the clerk since it is in her desk in a folder. That is not the legal definition, per the Statute at hand §843.0855 and the Clerks controlling Statute in relation handling documents in Chapter 28 of the Fla, Stat.. The 'two true bills’, since they have either been illegally removed, or were never meant to be filed, were either tampered with, or have never been legally filed or recorded. (£) The State also failed to produce the renewed Executive Orders 15-202, was well as any of the Executive Assignment Designations in this matter. See attached Executive assignments. The defendant is hereby requesting that this Honorable Court stay the matter until determination can be made on this Petition for Quo Warranto This matter originated in the Third Circuit, where the State Attorney Siegmeister, conflicted out of this matter due to the arrest of Trussell. Siegmeister is also a purported victim in this matter. (g) The Governor appointed Second Circuit State Attorney Meggs, while knowing he, the Governor was listed as a victim. Supreme Court appointed Second Circuit Hankinson, who worked with Meggs for over ten years and never disclosed this matter. See Supreme Court Certified Documents attached. (h) The initial and only disclosed Executive Order expired September 4, 2014 and was not timely renewed under the Florida Constitution and Florida Statute Chapter 27, While the jurisdiction was expired, State Attomey Meggs filed a response to Trussell's motion to continue in September 2014. Meggs apparently realized, a month later, that he had lost jurisdiction to try to case, and his office sent an email to the governor's office stating that they knew that the executive orders expired, requested it late in violation of the order, the constitution and the Fla. Stat., and untimely secured the undisclosed renewal. The governor then applied to the Supreme Court for renewal, not necessarily disclosing the untimeliness or the untimely request by the State Attomey Meggs, which was in violation of the order itself, the Constitution, and the state statute. This Honorable Supreme Court issued anew Executive Order non pro tune based on this request by the governor. (i) The state has violated discovery in this matter for not disclosing the primary Brady materials which completely negate essential elements of all the three different sections of the charged statute. The discovery violations are further set forth in the State filed, motion to exclude, motions to dismiss, and motion in limine in relation to the two documents at issue. The defendant has been severely prejudiced by the purported victim in this matter, the governor, being from Tallahassee, and the State Attomey and Judge, also being from Tallahassee, and applying Tallahassee 2" Circuit rules and procedures in the Third Circuit wherein Dixie County sits. State Attomey Meggs has violated his discovery obligations in never producing to date the renewed Executive Order that purportedly extended the term through September 2016. The State knew at the December 3, 2015 deposition of FDLE Agent Frank Linton that the defense was never provided with the renewed Executive Order, based on the questions and Megg’s non-verbal response to the line of questioning in relation to this significant jurisdictional issue. The state has not proven or provided proof of jurisdiction to the defense to be able to try this case. The defense had to personally go to the clerk of the Supreme Court and Governor's Office, to determine if an additional Executive Order had actually been entered or not. It is the State’s obligation to comply with the discovery obligations, and jurisdictional documents are very relevant to whether or not the case can be tried a is in Dixie County. (i) Other examples of the Brady violations include the fact that the state has not provided to date the defense proof that be two true bills at issue are not filed or recorded with the Dixie County Clerk and has in fact the State has been continually directing the witnesses to misuse the term ‘filed’ in order to mislead the fact finder of the true relevant legal definition of the term. The term file or recorded, as used in 843.0855 is defined in the clerk’s statute which defines the definitions of filed, recorded, official records, and public records. The State is apparently attempting to use the definition of filed or recorded, as set forth in §817. 035(1), which is not incorporated as a definition in §843. 0855. This misuse of the term filing, and not providing the completely exculpatory evidence in relation to the only two pieces of documentary evidence in this matter, are extremely prejudicial to the defendant in this matter. (k) Further the State has at least three times, apparently conditionally admitted assistant state attorneys to be present at hearings in this matter. The defense represents to this court that these appointments or assignments, have never been served on the defense (except the investigator early on), are not time stamped electronically, have no certificates of service, as all the other documents are in the court file, and have not necessarily been timely filed. Attached please find the document secured from the Governor's Office pursuant to the 119 request as an exhibit, Attached please find the document secured from the Clerk of the Supreme Court as composite Exhibit. Attached please find the three executive assignments that were previously not served on the defence. (k) Further discovery issues are, when defense attempted to set the deposition of the Governor, as the first witness in this matter, the state immediately converted the Governor from an “A” Witness to a *C’ Witness; thereby depriving defense the ‘opportunity to cross-examine the victim, against the Sixth amendment rights to confrontation, due process, effective assistance of counsel, and a fair trial. The State, in relation to all the other victims, except Siegmeister, were also prevented from, by the defense from deposing any of these reported victims; and now on the eve of trial, the Court is allowing the defense to call these un-deposed reported victims at trial. This completely deprived of the ability to conduct discovery or depositions in relation to these important witnesses. This completely deprives the defendant Trussell’s right to confront witnesses, is against the rights under the Constitution for affective of assistance of counsel, and to a fair trial. The unfair tactics by the State in relation to the discovery, the depositions, and the availability of documents, have completely prevent the Trussell from even have any appearance of a fair trial. (1) In fact, the Court intends on holding the trial tomorrow morning by allowing a key witness to sit as the clerk of the court to operate the court room to his left, then to walk past the Judge and sit in the witness chair, to testify at the trial, In order to achieve this goal the court did not quash this defense witness’s subpoena of this adverse witness’ however the Court denied defense’s right to sequester this important witness from the other witnesses. This witness is a deputy clerk Christy Johnson, who is the only way this would personal knowledge the Trussell did not file the documents purportedly filed, that no documents were filed in any court file, to the handling of the particular document at issue, as well as other important issue in the center of this case. This is a severe appearance of partiality toward the State, and an improper bolstering of state employees, directly tied to state witness Dana Johnson. The defendant cannot possibly have a fair trial under the circumstances, (m) Further the court has limited the trial to one-week period, knowing there are over potentially 90 witnesses on both sides. The apparent reason, as set forth at the June 1, 2016 hearing on the motion to quash 18 subpoenas, was that the Court needs to operate and have security and is limited in time and scope to a week although the defense has repeatedly requested at least two weeks. A copy of the audio from the hearing is available on DVD and an on-line link to be provided, as a transcript is still not available. It is unfair and violates the defendant’s constitutional ights to a fair trial, to deprive him of his proper trial preparation, to deprive Defense of enough time at trial to present his case, to prevent Defense from deposing witnesses then to allows them to testify at trial in order to surprise or prejudice the Defense, to allow the improper appearance of partiality toward the State to occur. The court fully intends to deny Defense the right to sequester all witnesses, and to limit the defense time to an unreasonably short time, given the circumstances of this matter. Also on June 1, 2016, the court ruled on 18 motions to quash, and most of the sherifié that have been deposed in this matter were quashed although there may be relevant information at trial. The court is completely denying the defendants due process rights, and forced proffers, against the Defense rights to due process. The proffer was forced upon defense. As a result, the court quashed the subpoenas of the numerous sheriffs, solely in order to operate the courthouse, because it’s a small courthouse and security is needed. Again this violates the defendant’s constitutional right to confrontation, due process, effective assistance of counsel, and a fair and impartial trial. (n) The defense is being charged with 14 felony counts and this is tantamount to a death sentence given the defendant's age of 72 years old. Based on the actions of the court throughout this matter, however specifically in relation to this absolutely and improper impartiality violation and limitation of time on a fair trial; the defense is filing separate motion to change venue to Broward County in order to have proper unbiased court and State as well as to allow sufficient time and security to hold a trial that will entail more than one week of limited testimony. (0) Further, since this is a case of first impression, and there are no jury instructions, the court still has not determined most of the instructions nor the defenses in this matter, thereby continuing to deprive the defendant of his ability to properly prepare for trial. (p) Plaintiff asks the Governor of Florida to terminate the Executive Orders that are allowing State Attorney Meggs to prosecute this matter in the manner in which he is prosecuting it, given the discovery issues and the non-production of relevant exculpatory evidence, the complete deprivation of due process, rights to confront witnesses, impartial and fair trial, and effective assistance of counsel. (q)To date, nothing has been done by the Governor except to file motions to quash his subpoenas to attend hearings and trial, although he is a purported victim of this case, again as significant violation of Trussell’s sixth amend rights to confrontation, and a right to a fair trial. (®) Plaintiff is rightfully entitled to a fair trial, with impartial Court and no undisclosed relationship between the Judge and the Prosecutor, and the Governor; which substantially prejudices the Plaintiff, as the Defendant in the State Case. Further, given the untimely request to renew the Executive Orders, and the fact Meggs prosecuted the case without jurisdiction at times, and did not disclose the expired order or any subsequently renewed orders, or the proper discovery; Plaintiff is entitled to have the jurisdiction taken away from State Attorney Meggs and have the case reassigned to a Judge in Broward and a Judge without any appearance of partiality, as well as a new Prosecutor's Office being appointed in south Florida, far away from the potential appearance of impropriety and lack of impartiality. Further, there should be no undisclosed relationship between the Judge and the Prosecutor. The Third and Second Judicial Circuits are not possible for a fair trial. South Florida is best location as the undersigned resides and works there, and the Defendant is a temporary resident in South Florida when needed. 3. Plaintiff seeks a writ of quo warranto ousting State Attomey Meggs and Judge Hankinson. MEMO OF LAW The writ of quo warranto is authorized by Article V, § 5(b) of the Constitution. The Quo Warranto is the proper proceeding for testing the governor’s authority to issue Executive Orders. WHILEY V. Scott, SC1 1-592 (Fla. 8.16.2011). Whiley seeks a writ of quo warranto, and it is clear that the Florida Constitution authorizes this Court as well as the district and circuit courts to issue writs of quo warranto, See art. V, $§ 3(b)(8), 4(b)(3) and 5(b), Fla. Const. The term “quo warranto” means “by what authority,” and the writ is the proper means for inquiring into whether a particular individual has improperly exercised a power or right derived from the State. See Fla. House of Reps. v. Crist, 999 So.2d 601, 607 (Fla.2008); Martinez, 545 So.2d at 1339. This Court “may” issue a writ of quo warranto which renders this Court's exercise of jurisdiction discretionary. Art. V. § 3(b)(8), Fla. Const. Furthermore, the Court is limited to issuing writs of quo warranto only to “state officers and state agencies.” /d. The Governor is a state officer. See art. III, § 1(a), Fla. Const. (“The governor shall be the chief administrative officer of the state....”)d., p.6. The phrase “supreme executive power” is not so expansive, however, and to grant such a reading ignores the fundamental principle that our state constitution is a limitation upon, rather than a grant of, power. See, e.g., Lee, 274 So.2d 881, 882 (Fla.1973); Bd. of Pub. Instruction v. Wright, 76 So.2d 863, 864 (Fla.1955). Id, p II. A writ of quo warranto is a proper remedy for contesting the authority of public officers and agencies to take action in their official capacities. Crist v. Florida Association of Criminal Defense Lawyers, Inc.,__So. 2d___, 33 Fla.L, Weekly $172, $177, n.3 (Fla. March 13, 2008). See also State ex rel Butterworth Kenny, 714 So. 2d 404, 406 (Fla. 1998) (“Attorney General Robert A. Butterworth petitions this Court for a writ of quo warranto seeking to prevent the Office of the Capital Collateral Regional Counsel for the Southern and Norther Regions (CCRC), respectively, and the other named respondents from representing death row inmates in civil rights lawsuits and to require withdrawal of their representation from all such pending civil cases. We have jurisdiction.”) (footnote omitted), See also Martinez v. Martinez, 545 So. 2d 1338 (Fla. 1989): Quo warranto is the proper method to test the “exercise of some right or privilege, the peculiar powers of which are derived from the State.” Winter v. Mack, 142 Fla. 1, 8, 194 So. 225, 228 (1940). Compare, eg., State ex rel Smith v. Brummer, 426 So. 2d 532 (Fla. 1982) (quo warranto issued because public defender did not have authority to file class action on behalf of juveniles in federal court), cert. denied, 464 U.S. 823, 104 S.Ct. 90, 78 L.Ed. 2d 97 Id. at 1339. (1983); Orange County v. City of Orlando, 327 So. 2d 7 (Fla. 1976) (legality of city’s actions regarding annexation ordinances can be inquired into through quo warranto); Austin v. State ex rel. Christian, 310 So. 2d 289 (Fla. 1975) (power and authority of state attomey should be tested by quo warranto). Testing the governor’s power to call special sessions through quo warranto proceedings is therefore appropriate. WHEREFORE plaintiff REQUESTS THIS COURT GRANT THE Quo Warranto against Governor Scott, cancelling the Executive Orders appointing State Attorney Meggs and preventing him from continuing the prosecution of the State vs. Trussell matter in Dixie County, FL., as well as replace Judge Hankinson with a South Florida Judge. CERTIFICATE OF SERVICE I HEREBY CERTIFY a true and correct copy of the above motion has been served this day, 5® day of June 2016, to al parties listed on the following Service List Respectfully submitted, Inger Garcia, Esq, Garcia Legal Group Attorney for Trussell 4839 Volunteer Road: #514 Davie, Florida 33330 Cellular: (954) 394-7461 Tel.: (954) 894-9962 Fax: (954) 446-1635 Service mail:attorney @ingergarcia.com Attorney @FloridaPotLawFirm.com By: /s/ Inger M. Garcia, Esq Inger Garcia, Esq. (FBN:0106917) SERVICE LIST William N. Meggs ‘All other on e-filing list Leon County Courthouse 301 8. Monroe Street Tallahassee, Florida 32399 email: hurstm@ileoncountyfl gov Pam Bondi Office of Attorney General via e-mail ‘STATE OF FLORIDA Office of the Governor ‘THECAPTTOL ‘TALLAHASSEE, FLORIDA 32399-0001 mic scorr 850-488-7146 ‘GOVERNOR, AFFIDAVIT 1, SUSAN SMITH, the Criminal Justice Liaison and Victims’ Rights Coordinator for the Executive Office of the Governor, attest that I am authorized to make a certification as to the authenticity of the materials contained herein, and hereby certify that the attached documents, compiled in response to the Subpoena for Deposition Duces Tecum issued on January 4, 2016, are true, exact, complete, and unaltered copies of the document(s) now existing within the records of the Executive Office of the Governor of the State of Florida pertaining io the executive assignment of William N. Meggs, State Attorney for the Second Judicial Circuit of Florida, to the Third Judicial Circuit of Florida through Executive Order 2014-246, pursuant to Section 27.14, Florida Statutes, and the extension of that executive assignment through Executive Order 2015- 202. The attached documents were made, received, and kept in the ordinary course of business by the Executive Office of the Governor. Under penalties of perjury, I swear and/or attest that the foregoing statement is true to the best of my knowledge. Print Name L. Smite = tfialie Page 1 of 2 STATE OF FLORIDA COUNTY OF LEON The foregoing instrument was sworn before me this. (a day of Nonany 2016, by Susan Smith, who A is personally known to me; OR ——has produced____....+_+=+=——_____asidentification. Enclosures. Page 2 of 2 « OFFICE OF THE STATE ATTORNEY THIRD JUDICIAL CIRCUIT OF FLORIDA Jeffrey A. Siegmeister, State Attorney 400 S.E. Court St Live Oak FL, 32063 Serving the Counties of Sesunnes, Hamilton, Disic, Lafayette, Taster, (386) 362.2320 Medison end Colma FAX (386) 362-3370 September 2, 2014 Susan Smith Executive Office of the Govemor 209 The Capito! SEP 09 204 400 South Monroe Strest Tallahassee, FL 32309-0001 RE: EXECUTIVE ASSIGNMENT REQUEST DDE CO. TERRY TRUSSELL 5 if Ms. Smith: gain requesting an executive assignment on the above reference case due to the 4 __eurent nature of the charges. g=z gS Krsna ening he reat ae oot acta Sincerely, See ‘A. Siegmeister State Attomey JASI eke Copy to: Bo Whinokur, Executive Office of the Govanor STATE OF FLORIDA OFFICE OF THE GOVERNOR EXECUTIVE ORDER NUMBER 14-246 WHEREAS, the Honorable JEFFREY A. SIEGMEISTER, State Attomey forthe Third Judicial Circuit of Florida, hes advised Governor RICK SCOTT that a criminal case is Pending against Terry Trussell in Dixie County; and WHEREAS, the Honorable JEFFREY A. SIEGMEISTER has also edvised the Governor that he is listed as a victim and a witness in the case; and WHEREAS, the Honorable JEFFREY A. SIEGMEISTER. to avoid a conflict of interest or any appearence of impropriety, bas voluntarily disqualified himself and has requested the executive assignment of another Suate Attomey with fespect fo the investigation and prosecution of this case and all related matters; and WHEREAS, the Honorable WILLIAM N. MEGGS, State Attomey for the Second Aodiciat Circuit of Florida, has agreed to accept an executive assignment in tis matter, and WHEREAS, itis inthe best interest of the State of Florida and ofthe ends of justice that the Honomble WILLIAM N. MEGGS discharge the duties ofthe Honorable JEFFREY A. SIEGMEISTER, pursuant to section 27.14, Florida Stanues. NOW, THEREFORE, 1, RICK SCOTT, Gover of Florida, in obedience to my solemn constitutional dury to “take care that the laws be fithfully executed” and pursuant to the Constitution and laws of the State of Florida, issue the following Executive Order, effective immediately: ‘Section |. The Honomble WILLIAM N. MEGGS, State Attomey for the Second Judicial ‘Cireuit of Florida, referred to as the “Assigned State Attorney,” is assigned to discharge the ati of the Honorable JEFFREY A. SIEGMEISTER, State Attomey for the Third Judicial Circuit of Florida, as they relate as they relate to the investigation, prosecution and all imatiers related to Terry Trussell. Section 2, ‘The Assigned Susie Attomey or one or more Assistant State Attomeys and Investigators, who have been designated by the Assigned State Attorney, shall proceed immediately to the Third Judicial Circuit of Florida, and are vested with the authority 10 ‘perform the duties prescribed herein. Section 3, All residents of the Third Judicial Circuit are requested, and al! public officials are directed. 10 cooperate and render whalever assistance is necessary to the Assigned State ‘Attorney, so that justice may be served. ‘Section 4, The period of this Executive Assignment shall be for one (1) year, to and including September 4,2015. Section 5. The Assigned State Attomey shall notify the Govemor on or before August 4, 2015, if additional time is required. IN TESTIMONY WHEREOF, I have ‘hereunto set my band and have caused the Great Seal of the State of Florida to be affixed at Tallahassee, this 4th day of September, 2014 RICK ;, GOVERNOR, ATTEST: SECRETARY OF Fi TIL sayy Ty Jen ‘avs i 2956 WY n- d3S HU aaa ‘vans “3 Smith, Susan From: Jan Whatley Sent: Friday, October 09, 2015 2:46 PM. Te: ‘Smith, Susan Subject: Executive Order 14.246 ‘Attachments: '20151006143500647 pat Attached isa letter requesting an extension or renewal of the above Executive Assignment. The Order expired on 9/4/15 ‘and we overlooked getting the extension. Thanks. Jan Whatley ‘State Attomey’s Office (606-6016 DIRECT LINE (606-6006 FAX Tamuuanece, Promina 32990-2530 Ornet oF SraTe ATrORNEY October 9, 2015 Honorable Rick Scott ‘Governor of the State of Florida Room 209, The Capito! Tallahassee, FL. 32399-0001 ATTN: Susan Smith RE: Executive Order # 14-246 / Terry Trussell Dear Governor Scott: This letter is to request that an extension or renewal be granted in the above styled Executive Order. The Order expired on September 4, 2015. The case is currently ‘set for trial the week of February 1, 2016 and an extension is needed in order to proceed with the prosecution. ‘Thank you for your assistance in this matter. ‘Sincerely, Libba 71 Wey? WILLIAM N. MEGGS State Attomey From: ‘Smith, Susan ‘Sent: Monday, October 12, 2015 8:27 AM : ‘an’ ‘Subject: RE: Executive Order 14-246 Susan L. Smith (Criminal Justice Liaison & Victims’ Rights Coordinator Executive Office of Governor Rick Scott ‘The Capitol, Suite 209 ‘Tallahassee, FL 32399-0001 Phone: 850.717.9310 Direct; 850.717.9311 Fax: 850.488.9610 From: Jan Whatiey [malito:Whatley@leoncountyfl.gov) ‘Sent: Friday, Octaber 09, 2015 2:46 PM. To: Smith, Susan Subject: Executive Order 14-246 ‘Attached is a letter requesting an extension or renewal of the above Executive Assignment. The Order expired on 9/4/15 ‘and we overlooked getting the extension. Thanks. Jan Whatley State Attomey's Office (606-6016 DIRECT LINE (606-6006 FAX Smith, Susan From: Smith, Susan Sent: Weanesday. October 14.2075 2.19 PM To: Jan Whatey: Maconna Robes (madonna roberts @sa? state f1us) Subject: Executive Order 15-262 extending EO 74-246 re Terry Trussel Attachments: ‘SUG-BIZHUB1S10°414113 pat ‘The original is being maited today Susan L, Smith Criminal fustice Liaison & Victims’ Rights Cooedinator Executive Office of Governor Rich Scott The Capitol, Suite 20° Tallahassee, FL32299-0001 Phone: 850717 9310 Direct, 8507179311 Fax 850.188.9610 Boee From: CAP209.GBIZHUBC454 @eog.mytiorida.com (mailto. CAP2OSLGBIZHUSCAS4 @eog mytiorida.com} Sent: Wednesday, October 14, 2015 2:12 AM ‘To: Smith, Susan Subject: Message from LG-BIZHUB ‘Smith, Susan Sone Wecrosdoy Otber 14, 2015 2:26PM To: ‘Jan Whatley’ : ect: RE: Executive Order 15-202 extending EO 14-246 re: Tery Trussell You are welcome. Susan L Smith (Criminal justice Liaison & Victims’ Rights Coordinator Executive Office of Governor Rick Scott ‘The Capitol, Suite 209 Tallahassee, FL 32395-0001, Phone: 850.717.9310 Direct: 850.717.9311 Fax: 8504889610 mestetiatertoiasen Frome: Jan Whatley [maitto:Whatiey@teoncountyfl gov) Sent: Wednesday, October 14, 2015 2:23 PM ‘To: Smith, Susan ‘Subject: Executive Order 15-202 extending EO 14-246 re: Terry Trussell ‘Thank you Susan Jan Whatley State Attomey's Office 606-6016 DIRECT LINE {906-5006 FAX> >> “Smith, Susan” 10/14/2015 2:19 PM >>> ‘The original ls being mailed today. Susan £. Secith Executive Office of Covernor Rick Scott ‘The Capitol, Suite 209 ‘Tallahassee, FL 32399-0001 Phone: 850.717.9310 Direct: 850.717.9911 Fax: 8504889610 Sent: Wednesday, October 14, 2015 2:12 AM To: Smith, Susan Subject: Message from LG-BIZHUB BNHZIG-91 Woy aBessay ssa{ans <0 epuolshyy Boe@yuws werNs> Vesns "4uus 01 Wa SEL Stor ‘bt sage120 ‘Aepseupayn vag {Wer epueihui Soo@ese2enHzigorsozev>:0;1#W) wor epvoysusBO3BysrrenKEIeDNEOtENs too oeremca nts a mec oa vont tert 20}¢uIpIOND IGF SUEDE 2 wosswr7 29nsny yuna yrs “7 wosns *900 202-61 voruasea 10 © ind osczosicusienHzis-o1s ‘mwounseny tesstu, hua 21 SrZ-Pt OF Surpuexe Z07-9, sapic an: Wn28%9 -WaULUBSsy Asuiouy meg 40 voIsuERXS “390Iqng 7 ven a1 OL We CS 1 6102 ©, 299080 feesInUL ues UES wus suo: uesng mS IN THE SUPREME COURT OF FLORIDA INRE: EXECUTIVE ASSIGNMENT OF STATE ATTORNEY APPLICATION FOR APPROVAL OF EXTENDED ASSIGNMENT RICK SCOTT, Govemor of Florida, files this application pursuant to Section 27.14, Florida ‘Stanutes, for an order approving an extension of the executive assignment of a State Attorney for an additional period of one (1) year. In support ofthis application, itis respectfully shown: L By Executive Order 14-246, the Honorable WILLIAM N. MEGGS, the State Attorney for the Second Judicial Circuit, was assigned to the Third Judicial Circuit of Florida to represent the State of Florida conceming charges pending against Terry Trussell. 2. The Assigned State Attorney has advised the Governor thatthe duties required by the previous executive assignment have not yet been completed as trial is scheduled the week of February 1, 2016. 3. The Assigned State Attorney bas further advised the Governor that an extension of this ‘assignment is necessary in order to complete the duties prescribed therein. 4, Asevidenced by the terms of Executive Order 15-202, a copy of which is attached hereto, it has been found and determined that itis in the best interest of the State of Florida and of the ends of justice that Executive Order 14-246 be extended for an additional period of one (1) year, with approval of this Honorable Court, pursuant to the provisions of section 27.14, Florida Statutes. WHEREFORE, this Honorable Court is requested to approve an extension of the executive ‘assignment of the Assigned State Attomey for an additional period of one (1) year, to and including ‘September 4, 2016, Dated this 14th day of October, 2015. Respectfully submitted, sistant General Counsel Offfice of the Governor ‘The Capitol, Room 209 Tallahassee, Florida 32399 Florida Bar No. 1019824 STATE OF FLORIDA OFFICE OF THE GOVERNOR EXECUTIVE ORDER NUMBER 15-202 WHEREAS. the Honorable WILLIAM N. MEGS, State Atiomey for the Second Judicial Circuit of Florida, was previously assigned hy Executive Order 14-246 to the Third Judicial Circuit of Florida to represent the State of Florida concerning charges pending against Terry Trussell; and WHEREAS, the Assigned State Attomey bas advised the Governor that the duties required by the previous executive assignment have not yet been completed as trial is scheduled the week of February 1, 2016; and WHEREAS, the Assigned State Aftorney has further advised the Governor that an extension of this assignment is necessary in order to complete the assigned duties; and WHEREAS. itis in the best interests of the State of Florida and of the ends of justice thet the assignment of the Assigned State Attomey be continued with respect to the above matters, pursuant 0 section 27.14, Florida Statutes, NOW, THEREFORE, |, RICK SCOTT, Governor of Florida, in obedience to my solemn ‘constitutional duty to “take care that the laws be faithfully executed," and pursuant to the Constitution ‘and laws of the State of Florida, issue the following Executive Order: Section 1. Executive Order 14-246 is reaffirmed and the executive assignment is extended for an additional period of one (1) year, to and including September 4, 2016. et S150 “Faue290 40 Sep qe 2936) at Fs ay on apy s ‘suey SUAS spuNsag ANE | GO THA A IRGONTPPR (U-yNT "p ISMNY’ azogay 30 Un : gh JO AXVITWDAS FU] ae pangs 189 aoY Pt OWLISALNT 09) AU JOU Heys SseIORYy LStiLV pozinbas st + ates pouinsy aay “Wort, Soe CHa Supreme Court of Florida Ofte ofthe let $00 Sout Deval Soe Tatas, Pera 32591827 ewan h Tossasna, PHONE NUMBER’ (850) 489-0128 seat wor fondsuprenecont femmes October 15, 2015 Honorable Rick Scott, Governor ‘The Capitol Tallahassee, Florida 32399 Dear Governor Scott: We are in receipt of your application and EO15-202 received October 15, 2015, requesting the issuanice of an order from this Court approving the extended ‘assignment of Honorable William N. Meggs, State Attorney for the Second Judicial Circuit to the Third Judicial Circuit of Florida. The request for an extension has been granted and a copy of the order is enclosed for your files. John A. Tomasino JATivbv Enclosure cc: Honorable William N. Megas Honorable Jeffrey A. Seigmeister Florida State Archives IN THE SUPREME COURT OF FLORIDA ‘THURSDAY, OCTOBER 15, 2015 INRE: EXECUTIVE ASSIGNMENT OF STATE ATTORNEY ! ORDER APPROVING EXTENDED ASSIGNMENT ‘This matter came on to be heard before the Court upon the Application for Approval of Extended Assignment filed by RICK SCOTT, Governor of Florida, pursuant to section 27.14, Florida Stanutes. The application shows good and sufficient cause for approval of an extension of Executive ‘Onder 14-246 in that the duties required by the previous executive assigament have not yet beea completed. Executive Onder 15-202, extending by one (1) additional year the assignment of Honorable WILLIAM N. MEGOS, State Attomey for the Second Judicial Circuit to the Third Judicial Circuit, to and incloding September 4, 2016, is approved effective, nunc pro tanc, September 4, 2015. ‘Honorable RICK SCOTT Honorable WILLIAM N, MEGGS Honorable Jeffrey A. Siegmeister Florida State Archives ‘A True Copy a 193 IN THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT OF FLORIDA. EXECUTIVE ORDER # 14-246 oe IN RE: EXECUTIVE ASSIGNMENT CT dos SU Lua a3ud Hf COMES NOW Wiltiam N. Megs, Assigned State AtfrieY by Assignment to the Third Cicuit of Florida, for all purposes related to the investigation, prosecution, and representation of the State of Florida in ail matters Pertaining to or arising from the allegations made against Terry Trussell, and hereby ; DESIGNATES Assistant State Attomey Eddie D. Evans, as authorized ! in Section 27.14, Florida Statutes, to proceed forthwith to the Third Judicial Circult of Florida and is vested with the authority to perform all duties and responsibilities | related to this matter. Respectfully submitted, Qa iri? WILLIAM N. MEGGS ‘State Second Circuit IN THE CIRCUIT COURT OF THE owen JUDICIAL CIRCUIT OF EXECUTIVE ORDER # 15-202 (Extension of #14-246) IN RE: EXECUTIVE ASSIGNMENT € wd U2 ay Sid COMES NOW Willie N. Megas, Assigned State Ago De recutve Assignment to the Third Circuit of Florida, for all purposes related to the Investigation, prosecution, and representation of the State of Florida in all matters pertaining to or arising fiom the allegations made against Terry Trussell, and hereby DESIGNATES Assistant State Attomey John E. Campbell, as authorized in Section 27.14, Florida Statutes, to proceed forthwith to the Third Judicial Circuit of Florida and is vested with the authority to perform all duties and responsibilities related to this matter. Respectfully submitted, Lhe. Tes WILLIAM N. MEGGS State. ‘Second Judicial Circuit 3 46 IN THE CIRCUIT COURT. IE THE ERR OIC. cance s EXECUTIVE ORDER. a RE B B85 52 IN RE: EXECUTIVE ASSIGNMENT zor 9 = 2 ee DERIGNATION g2° 5 g COMES NOW William N. Megs, Assigned State Attomey by Executive ‘Assignment to the Third Circuit of Florida, for ail purposes related to the investigation, proseoution, and repressniation of the State of Florida in al matters pertaining to or arising from the allegations made ageinst Terry Truseel, and hereby DESIGNATES Investigator Erika Buckley, as authorized In Section 27.14, Florida Statutes, to proceed forthwith to the Third Judicial Circuit of Florida ‘land |e vested with the authority to perform ail duties end responsibiities related to ‘this matter. Respectfully submitted, (ithe. THA he. Las Saeed ductal Crit Supreme Court of Florida 2015-15 WHEREAS, it officially has been made known to me that it is necessary to the dispat of business of the THIRD JUDICIAL CIRCUTT OF FLORIDA that a judge be temporarily assigned to duty in that court to review and sign, if appropriate the arrest warrant of: State of Florida vs. Terry George Trussell NOW. THEREFORE, JORGE LABARGA, under authority vested in me as Chief “Justice of the Supreme Court of Florida, under articte V, section 2 of the Constitution of Florida, and the rules of this Coun promulgated thereunder, do hereby assign and designate THE HONORABLE JAMES C, HANKINSON, CIRCUIT JUDGE of the SECOND JUDICIAL CIRCULT OF FLORIDA. to proceed to the THIRD JUDICIAL CIRCUIT OF FLORIDA, to hear, conduct. try, and determine the above cause, which shall be presented t0 the judge as a temporary judge of said court, and thereafter to dispose of all matters considered by the judge in said cause, inchaing Issues of fees and costs arising out of said cause, but excluding other cause, JUDGE HANKINSON, under and matters subsequently raised that are collateral to by virtue ef the authority hereof, is hereby sested with all and singular the powers and prerogatives conferred by the Constitution and laws ofthe State of Florida upon a judge of the ‘court to which the judge is hereby assigned, DONE AND ORDERED at Tallahassee, Florida. on August 28, 2014. ATTEST: Warrant? ‘Agency Case# _TL-11-0119 Officer L.D.# 1150 In the County Court ‘Criminal actions under e570: Dixie County, Florida charge Simul egal rest STATE OF FLORIDA Degree of Charge _3rd ws. Statute No. _843.0855 Dow 10/26/43 Sex Wale Terry Trussell. COMPLAINT Race Male Hgt 63" _ 1660 NE 364% Ave Old Town, FL 32680 ‘Wet _225 Hair Bald Byes “Hazel SSN _424-56-526 Address, IN THE NAME AND BY THE AUTHORITY OF THE STATE OF FLORIDA: Before me, the undersigned authority, personally appear FDLE Special Agent Frank Linton, who, first being duly sworn says that one this 21" day of 2014, A.D. , in Leon County, Florida, the aforesaid defendant: contrary to Sec. 843.0855, F.S. contrary to the statute, rule regulation or other provision of law in such ease made and provided, and against the peace and dignity of the State of Florida, _——_— ‘Special Agent Frank Linton, Complainant ‘Sworn to and subscribed before me this day of August , 2014. ee “Fudge, Assiatant State Attorney or Notary Public In the County Court pee On TLS — Officer LD.# _1150 Dixie County, Florida Crictinal ations Sader ooh of law or through use of Charge _simulated legal process STATE OF FLORIDA Degree of Charge 3% vs. ‘Statute No, _ 843.0855 DOB _10/26/1943 Sex _Male Terry George Trussell WARRANT — Race White 1660 NE 364” Ave Old Town, FL 32680 Wet 225 Byes “Hazel ‘Address, IN THE NAME AND BY THE AUTHORITY OF THE STATE OF FLORIDA: ‘TO ALL AND SINGULAR THE SHERIFFS OF THE STATE OF FLORIDA: WHEREAS, « complaint has this day been filed before me by FDLE Special Agent Frank Linton, who, being first duly sworn says that one the 21 day of August, 2014 A.D. , in Dixie County, Florida, the aforesaid defendant Terry George Trussell contrary to the statute, rule regulation or other provision of the law in such case made and provided, and against the peace and dignity of the State of Florida. THESE ARE, THEREFORE, to command you to arrest instanter the aforesaid defendant and bring bim or her before me to be dealt with according to law. Given under my hand and seal this day August of 2014 ,. County IN THE COUNTY COURT DIXIE COUNTY, FLORIDA eee CO Ty ee ‘THE STATE OF FLORIDA, PLAINTIFF ‘Temy George Trussell Defendant 1660 NE ae ‘Ave Old Town, FL 32680 Address A WARRANT a Charge and Statute Number 43,0855 Criminal actions under color of law or through Use of simulated legal process ‘THE AMOUNT OF BAIL IN THIS CASE ($ HEREBY SET IN THE SUM OF se Received the Warrant on the day of a 5 ‘and served same on the day of 20, by delivering a true copy of same to the within named defendant, —_ Sherif, ‘County, Florida By: Deputy Sheriff Supreme Court of Florida 2015-17 WHEREAS, il officially has heen made known to me that itis necessary to the dispatch of business of the THIRD JUDICIAL CIRCUIT COURT OF FLORIDA that a judge be temporarily assigned to duty in the matter of: State uf Florida vs. Terry George Trussell NOW, THEREFORE, 1. JORGE LABARGA, under authority vested in me as Chief Justice of the Supreme Court of Flotida. under article V. section 2 of the Constitution of Florida and the rules of this Court promulyated thereunder, do hereby assign and designate THE HONORABLE JAMES C, HANKINSON, CIRCUIT JUDGE of the SECOND JUDICIAL, CIRCUIT OF FLORIDA, to proceed to the THIRD JUDICIAL CIRCUIT OF FLORIDA. tw hear. conduct, try. and determine the above cause, which shail be presented to the judge as a temporary judge of said court, and thereafter to dispose of all matters considered by the judge in said cause. including issues of fees and costs arising out of said cause. but excluding other matters subsequently raised that are collateral to said eause. JUDGE under and by virtue ofthe authority hereof, is hereby vested with all und singular the powers and prerogatives conferred by the Constitution and laws af the State of Blorida upon a judge of the court to which the judge is hereby assigned. DONE AND ORDERED at Vallahassee, Florida, on September 3, 2014, F JORGE LABARGA ERT OF FLORIDA ATTEST: Supreme Court of Florida 2015-23 WHEREAS, it off of business of the THIRD JUDICIAL CIRCUIT COURT OF FLORIDA that a judge be ially has been made known to me that itis necessary to the dispatch temporarily assigned to duty in that court to hear the case of: State of Florida vy. Terry George Trussell Case Number: 14-201 CF NOW, THEREFORE. 1, JORGE LABARGA. under authority vested in me as Chief Justice of the Supreme Court of Florida, under article V, section 2 of the Constitution of Florida, and the rules of this Court promulgated thereunder, do hereby assign and designate THE HONORABLE JAMES C. HANKINSON, CIRCUIT JUDGE of the SECOND JUDICIAL CIRCUIT OF FLORIDA. to proceed te the THIRD JUDICIAL CIRCUIT OF FLORIDA, to ie. which shall be presented to the judge as 9 hear, conduct, try, and determine the above temporary judge of said court, and thereafter to dispose of all matters considered by the judue in said cause. including issues of fees and costs arising out of said cause, but excluding other matters subsequently raised that are collateral jo said cause. JUDGE HANKINSON, under and by Virtue of the authority hereof. is hereby vested with all and singular the powers and prerogatives conferred by the Constitution and laws of the State of Florida upon a judge of the court to which the judge is hereby assigned. DONE AND ORDERED at Fallahassee, Florida. on September 17. 2014. JORGE LABARGA URT OF FLORIDA { CHIBE fUsti9 { SUPREME ¢ ATTEST: ax COURY Supreme Court of Florida office ofthe Clerk soo Sou Dural Soret “aanavoe Fs 325091027 Jour 4 Yoseasno Prone Munen (8504980125 ce wow floridasupremecourt.org ‘win Bere CR, . eusna SANS October 15, 2015 Sher arroasty Honorable Rick Scott, Governor The Capitol Tallahassee, Florida 32399 Dear Governor Scott: We are in receipt of your application and EO1S-202 received October 15, 2015, requesting the issuance of an order from this Court approving the extended assignment of Honorable William N. Meggs, State Atiomey for the Second Judicial Circuit to the Third Judicial Circuit of Florida, The request for an extension has been granted and a copy of the order is enclosed for your files. fon A. Tomasino JATvby Enclosure ce: Honorable William N. Meges Honorable Jeffrey A. Seigmeister Florida State Archives IN THE SUPREME COURT OF FLORIDA. ‘THURSDAY, OCTOBER 15, 2015 INRE: EXECUTIVE ASSIGNMENT OF STATE ATTORNEY / ORDER APPROVING EXTENDED ASSIGNMENT ‘This matter came on to be heard before the Court upon the Application for Approval of Extended Assignment filed by RICK SCOTT, Governor of Florida, pursuant to section 27.14, Florida Statutes. The application shows good and sufficient cause for epproval of an extension of Executive (Onder 14-246 in that the duties required by the previous executive assignment have not yet been completed. Executive Order 15-202, extending by one (1) additional year the assignment of Honorable WILLIAM N. MEGGS, State Attorney for the Second Judicial Circuit to the Third Judicial Circuit, to and including September 4, 2016, is approved effective, nunc pro tunc, September 4, 2015. ce: Honorable RICK SCOTT IN THE SUPREME COURT OF FLORIDA INRE: EXECUTIVE ASSIGNMENT OF STATE ATTORNEY / APPLICATION FOR APPROVAL OF EXTENDED ASSIGNMENT RICK SCOTT, Governot of Florida, files this application pursuant to Section 27.14, Florida Statutes, for an order approving an extension of the executive assignment of a State Attorney for an additional period of one (1) year. In support ofthis application, it is respectfully shown: 1, By Executive Order 14-246, the Honorable WILLIAM N. MEGGS, the Stato Attorney for the Second Judicial Circuit, was assigned tothe Third Judicial Circuit of Florida to represent the State of Florida concerning charges pending against Terry Trussell. 2. The Assigned State Attorney has advised the Governor that the duties required by the previous executive assignment have not yet been completed astral i scheduled the week of February 1, 2016. 3, The Assigned State Attorney has further advised the Governor that an extension of this assignment is necessary in order to complete the duties prescribed therein. A, Asevidenced by the terms of Executive Order 15-202, a copy of which is attached hereto, ithes been found and determined that it is in the best interest of the State of Florida and ofthe ends of justice that Executive Order 14-246 be extended for an additional period of one (1) yea, with approval of this Honorable Court, pursuant to the provisions of section 27.14, Florida Statutes. WHEREFORE, this Honorable Cour is requested to approve an extension of the executive assignment of the Assigned State Attomey for an additional period of one (1) year, to and including, September 4, 2016. Dated this 14th day of October, 2015. ‘The Capitol, Room 209 Tallahassee, Florida 32399 Fiorida Bar No. 1019824 IN THE SUPREME COURT OF FLORIDA INRE: EXECUTIVE ASSIGNMENT OF STATE ATTORNEY i ORDER APPROVING EXTENDED ASSIGNMENT ‘This matter came on to be heard before the Court upon the Application for Approval of Extended Assignment filed by RICK SCOTT, Govemor of Florida, pursuant to section 27.14, Florida ‘Statutes. The application shows good and sufficient cause for approval of an extension of Executive Order 14-246 in thatthe duties required by the previous executive assignment have not yet been completed. Executive Order 15-202, extending by one (1) additional year the assignment of Honorable WILLIAM N. MEGGS, State Attomey for the Second Judicial Cireuit to the Third Judicial Circuit, to and including September 4, 2016, is approved. ce: Honorable RICK SCOTT Honorable WILLIAM N. MEGGS Honorable Jeffrey A. Siegmeister Florida State Archives A True Copy ‘TEST: John A. Tomasino Clerk, Supreme Court STATE OF FLORIDA OFFICE OF THE GOVERNOR EXECUTIVE ORDER NUMBER 15-202 WHEREAS, the Honorable WILLIAM N. MEGGS, State Attomey for the Second Judicial Cireuit of Florida, was previously assigned by Executive Order 14-246 to the Third Judicial Circuit of Florida to represent the State of Florida conceming charges pending against Terry Trussell; and ‘WHEREAS, the Assigned State Attorney has advised the ‘Governor that the duties required by the previous executive assignment have not yet been completed as tral is scheduled the week of February 1, 2016; and WHEREAS, the Assigned State Attomey has further advised the Governor that an extension of this assignment is necessary in order to complete the assigned duties; and WHEREAS, it is in the best interests of the State of Florida and of the ends of justice that the assignment ofthe Assigned State Attomey be continued with respect tothe above matters, pursuant to section 27.14, Florida Statutes. NOW, THEREFORE, I, RICK SCOTT, Governor of Florida, in obedience to my solemn constitutional duty to “take care thatthe laws be faithfully executed,” and pursuant to the Constitution ‘and laws of the State of Florida, issue the following Executive Order: Section 1. Executive Order 14-246 is reaffirmed and the executive assignment is extended for an additional period of one (1) year, to and including September 4, 2016. porinfag si ati Log asnny ateang 20 a uassy af TURNS WHE 8. MEGS Texsananves, Prosnion Ornes ar Stare ATTORNEY October 9, 2015, Honorable Rick Scott Governor of the State of Florida Room 209, The Capitol Tallahassee, FL 32399-0001 ATTN: Susan Smith RE: Executive Order # 14-246 / Terry Trussell Dear Governor Scott: This letter is to request that an extension or renewal be granted in the above ‘styled Executive Order. The Order expired on September 4, 2015. The case is currently ‘set for trial the week of February 1, 2016 and an extension is needed in order to proceed with the prosecution. ‘Thank you for your assistance in this matter. Sincerely, Lila 71 Phtyy? WILLIAM N. MEGGS: State Attorney WNMiw STATE OF FLORIDA OFFICE OF THE GOVERNOR EXECUTIVE ORDER NUMBER 14-246 WHEREAS, the Honorable JEFFREY A. SIEGMEISTER, State Attomey for the Third Judicial Cireuit of Florida, has advised Governor RICK SCOTT that a criminal case is pending against Terry Trussell in Dixie County; and WHEREAS, the Honorable JEFFREY A. SIEGMEISTER has also advised the Govemor that he is listed as a victim and a witness in the case; and WHEREAS, the Honorable JEFFREY A. SIEGMEISTER, to avoid a conflict of interest or any appearance of impropriety, has voluntarily disqualified himself and has requested the executive assignment of another State Attorney with respect to the investigation and prosecution of this case and all related matters; and WHEREAS, the Honorable WILLIAM N, MEGGS, State Attomey for the Second Judicial Circuit of Florida, has agreed to accept an executive assignment in this matter, and WHEREAS, itis inthe best interest of the State of Florida and of the ends of justice that the Honorable WILLIAM N. MEGGS discharge the duties of the Honorable JEFFREY A. SIEGMEISTER, pursuant to section 27.14, Florida Statutes. NOW, THEREFORE, I, RICK SCOTT, Governor of Florida, in obedience to my solemn constitutional duty to “take care that the laws be faithfully executed,” and pursuant to the Constitution and laws of the State of Florida, issue the following Executive Order, effective immediately: ‘Section |. ‘The Honorable WILLIAM N. MEGGS, State Attomey for the Second Judicial Circuit of Florida, referred to as the “Assigned State Attorney,” is assigned to discharge the duties of the Honorable JEFFREY A. SIEGMEISTER, State Attomey for the Third Judicial Circuit of Florida, as they relate as they relate to the investigation, prosecution and all ‘matters related to Terry Trussell. Section 2, ‘The Assigned State Attomey or one or more Assistant State Attomeys and Investigators, who have been designated by the Assigned State Atiomey, shall proceed immediately to the Third Judicial Circuit of Florida, and are vested with the authority to perform the duties prescribed herein. ‘Section 3, All residents of the Third Judicial Circuit are requested, and all public officials are directed, 1 cooperate and render whatever assistance is necessary to the Assigned State Attorney, so that justice may be served. ‘Section 4. ‘The period of this Executive Assignment shall be for ane (1) year, to and including ‘September 4, 2015. or belore August 4, WHEREOF, 1 have oa 25:6 WY 4 d35 HO = THE SUPREME COURT OF [ee 23} FLORIDA 500 SOUTH DUVAL STREET ‘TALLAHASSEE, FLORIDA 32399-1927 (650) 488-0125 Recelpt Number: R 2016-1025819 desue Dot: os/ian0i6 Form of Payment: Cash Name: INGER MICHELLE GARCIA Check Namber: Lower Tribunal Case Nambers: 4039 VOLUNTEER RD Davie, FL 33330 Note: Service Type Case Number Case Style —_— Photocony $6.00 ‘Total: $6.00 Page Lof 1 RERPLECOEPES pat 6 68pm Harton mean, unless I was testifying before the grand jury on 2 the case. 3 @. Did -- do you recall Mr. Trussell telling you 4 that he had a problem hearing? 5 A. No. 6 Q. Have you worked on any governor-appointed 7 gases before, where a governor appoints somebody by ° Ge 9 A. You mean like if there's a different 10 prosecutor appointed, like Mr. Meggs is on this one? u Q. Yes. 12 A. I don't remember. - 13 Q. Did you see the (xaeetescimmmem in this case? 4 A. No. If£ I did, I don't recall seeing it. 15 Q. Have you ever looked at the FDLE probable 16 cause affidavit in this case? 17 A. I don't know if I saw the probable cause 16 affidavit or not. 19 Q. Did you have anything to do with preparing 20 it? 21 A. No. 22 Q. Did you ever see the FDLE investigative 23° reports in this case? 24 A. No. 2s Q. Do you remember having any conversations with COMPILED DEPOS pat Frank Linton Yaw een ee © © 10 12 13 14 15 16 17 13 19 20 21 22 23 28 25 sheriff, we got back in our car and left. 2 Do you know what they gave him at the time of the arrest? A No, I was on my way back to Tallahassee. @ So you don't know if he received the affidavit and/or the ten warrants and complaints? A Ne. @ Do you have any idea when he received those or how he received those? A Ne. @ Have you ever seen the other handwritten warrant or the other single-page warrant before? A No. @ When is the first time that you had any contact with the State Attorney's Office? A Which one? @ I guess Meggs' office, that's been assigned to the case. a T believe it was -- we had a meeting Mr. Meggs, I think it was either the day of the ‘executive order assigning him the case, we turned the discovery over to him. That was the first time. It was myself and some other individuals from FDLE met just so if Mr. Meggs had any questions. @ Do you know who else was with you at that FOR THE RECORD - TALLAHASSEE, FLORIDK§e:1075-23 of 243 foc se-GuoneNGIMOTE ‘SHSSWHVITWL - CHOOT aBL vod peaetoosse euoauios sem at yng -- sem 31 zeyZeyM ‘ou 3oeKe ey FequoweT a,uop T -- euceMoSs sem aT ¥ ~- 8 OxTT STYI ST '3T patty .feua, ABS Nok yoy ‘UOTIROTITIeTO JO 3Tq aTIITT e386 03 quem asno r -austTy 8 sazeymAue 0G 3,UpTp eseo sya os pur sourTTTZ esoys gusind 04 Gutob 2,tezem em qUTOd stY2 7e 3ey3 pautwTeIep sem IT puP *SUOTRRBTISOAUT |ATINIeXE FO soTIFO eya ut ToIebraseaut ue y3tm yeu Tf -- sem 37 os pue ‘ano aoTTzU0S 03 pey em og ‘ase> sy3 UT UTIOTA sya eq PTNOM T veaebyaseaut ATenotago 3,uvo T pue ‘s3ueumo0p buTsserey z8yR0 ‘mouy nok ‘TTpo 9m aeyM pey ASYE ‘catneMeT Aes 03 auen 3,uop T -- petty pey Aeyy “ou asutebe yzomzoded | | TT 03 webeq Aaya asneseq suoTaeAtassAuT aaTancexg JO ADT33O ay] 02 AT paTTazaz aqtym Tostaradng qebY qeroeds pue g1eshu -- esneoag at perzayex Ty €03 aues aT sem oUN pue ‘azey2 at aus OW “ARYO 3 a cApogkue Aq suotze6t3senur satanoexg ey JO BOTFIO ay 03 DaTTeyaz Tans ased stTyI sem *s2uTT esos BuoTe Pue TOUTES ay3 wOIy TapIO BATINoEKe Ue 26 09 eney Aaya qeya /sses0zd atoym e s,at puy ov e | sz be ez cea Tz 4 BT at LT 9t ST bt et at ou oT ger ey ole en ORT ae 303 $0d30 GsTISWOO eng sorei-guomMOTMOTE 'AESSWHVTTVL - CHOOMA AHL wos erg, “yeu peastied Tlessnay ‘aH JT os “AR¥O 0 sz vagnaeas | $2 eptzotg Aue aaeStaseaut 03 Aqtxousne sya sey -- yon | ¢z Aqqerd ued @1dg 3euI Juswe7Inbez ou s,azeu3 Ing ‘gIIdT roa UTUIM PUBT TITM suoTaebrysenuT uotgdnrz09 atrand asoys | Tz 30 301 © ‘Fepro enTanoexs ue Buraey Jo squewertnbez | oz aya pue ag0z3e 243 pue ewta eya sey gag esneseg | 6T SOUT] JO JOT & ‘STeTOTZFO peqsete WITM MON gt ssaseo Aue | iT eqeBtaseaut ues quewgzedep eottod Aue ‘eoTzyo s,zgtzeus | oT Auy ‘stya eaebtaseaut ues g7cg ATuc Aes qeya soanaeas | ct aqe3s sya UT BuTY;0U s,ezaua os suoT|STpstant TeuTStz0 | pT TTeo am 3eyn Xue savy aou esop grag = uota0tpetant | et ou aney om ‘anusn xzedozd eyz at st -- prnom | zt I ‘sah ‘os fsTeTOTJZo paqsetse AT[etsadse zo uotTadnz109 TL ottqnd Aupaehtaseaut up aot utem © aavy op am ¥ oT esanset acoyy aqehtqseaut o2 uoTaotpstine | 6 usin Agtaue zedord oy3 aTag SI gamnoo Jo 428T2 aya waTm sustqord zo Aant puez6 © yatm swetaozd ‘nowy nog '30 uoTadnzz09 ot1gnd zey3te -- siya Jo uoTgRbeTTe ue YIM Nox 02 amo 09 orem suSSMOS JT sUOTIPBeTTE go adXa asaya eqebtaseaut og gol s,amqg at st 8 ‘STITq anz3 eseya uodn 08 pue ano of o2 SuToB jou sem Apoqeuios 3ey3 eans aa mM eH © @ aye 02 Sem ‘TTeD euoyd 243 Jo sno03 UTeW ZnO sem 3eUa WORT wes wt $0430 GTNAMOD oMOIMOIA ‘HESSWEVTTYE - GYOOTE AHL Yor ert jo gis @atanoexe ay3 03 quensand at jo azeme ATsnotTago sem wouzanoy ey3 -- sem ay 3eYI pue ‘TTTq enz3 Buz Jo ZZeAS JO Jatyo S,FoUTeAoD ayi petstiou em ‘TeTT zee peqeas ZO TSTTIVS passnostp I sy ‘“preog Tooyss aya peTsTIow Koya yUTYA 1 “prB0q ToouDs aya AJTIOU ‘prBAYDeG RTOS S,ABYR BOUTS ‘eLTIZ0 Ba; TTEUS YR 4eT BU PUTY om =~ 8,J3T7eyS 2y3 OM NoUY a,UOp T pue -- anetTeq I pue ‘qsezze ay Jo azeme sem reastombeTs “mM ‘TIO ¥ epeasequos exem surgota ou Aqm mowy nok og gagnaeas ya UT suTa9TA ney nox g3oez700 ‘eanqezs 9ya JO quamatTe auo ATUo s,2ey1 ezeMe az,nok ang a ‘paquezzeM jou sum MeTAZeIUT UL ‘aT BUTTTS ©3 pescazucO ay eou0 ‘uTebe - eouo SBM 3T 3eU2 TET em epemaTaTequT ey a,usem Kym fwpqoya aya ey xagstamats “mo gros 8 TAT pamataez ey ueym uosuTyuRR abpne pue Tesunos esnoy-ut uo Ayex 03 pey om ‘aserze ui qeaze peautodde cem sotzz0 ,sBben «mi esneseq aseo Sty3 Uo sauepTnh Aouz0q3e |9e3s OU PEY aM ‘PTeS I OxTT *poqutodde 306 201330 ,sbhen “3H pue zTesuTY pesnoez ay a0uQ *3no IND ATeqaTduoD sem ay ‘ON “ON ¥ zasneo atqeqord SuruTwzaqap 09 suoTangyzquoo ety 3 e3eTeT 3e4R yeqsteubets “TW YITM suoTzeszeAucD Tey20 AUY n © aaoe 389 we HI apd SCd30 GINAWOO COMPILED DEPOS rat Frank Linton 883 ene Seer aw oe 11 32 13 14 15 16 7 16 19 20 21 22 23 24 25 166 arrest, and Major Harden said he would take care of it; and we thanked them and got in our cars and left. © Okay, So FDLE had no involvement whatsoever an any other warrants served or any other documents prepared or -- a Noe G => signed by any sheritts? No. Q Okay. We're going te go to Linton Exhibit Number 19, It's an investigative report Number 11 dated 9/4/2014. A Okay. @ What is this report for? A It's just memorializing the executive order signed by the Governor appointing the Honorable William Meggs to the case. It basically indicates that Governor Rick Scott on September 4th signed the Executive Order 14-246 appointing State Attorney Meggs to the pending criminal case against Mr. Trussell. I got the Dixie -- or I got the executive order from the Dixie County clerk of court. © The designation, the executive assignment you're talking about which is the second attachment to this report? ae ess FOR THE RECORD - TALLAHASSEE, FLORIDAp

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