uonce IVloore 10-CF-1733 DISCOVERY BINDER #5

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IN THE OFFICE OF THE STATE ATTORNEY

IN AND FOR HILLSBOROUGH COUNTY/ STATE OF FLORIDA

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4 - - - - - - - - - - - - - -X

IN RE:

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SAO INVESTIGATION

- - - - - - - - - - - -X

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SWORN STATEMENT OF:

APRIL R. TAYLOR

TAKEN:

Pursuant to Notice

TIME:

Beginning at 10:00 a.m. Concluded at 11:04 a.m.

DATE:

Monday/ February 8/ 2010

PLACE:

Law Office of James H. Buzbee 802 W. Martin Luther King/ Jr.

Boulevard - Suite D Plant City/ Florida 33563

BEFORE:

RALPH D. MILLS/ CVR/ CP Notary Public

State of Florida at Large

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Certificate of Reporter

APPEARANCES:

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On behalf of the State:

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HON. JAY PRUNER Assistant State Attorney

419 N. Pierce St., Third Floor Tampa, Florida 33602

(813) 272-5400

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5

6

7 ALSO PRESENT:

8 MR. TERRY DELISLE, SAO Investigator

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CON TEN T S

PAGE

Examination by Mr. Pruner
Examination by Mr. Delisle
Further Examination by Mr. Pruner
Further Examination by Mr. Delisle
Further Examination by Mr. Pruner
Certificate of Oath MTT.T._~ 'O-r:t'D(,)'D'l'1TlI.lf"'! f"'tDt"\TTn Tl\Trt

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EXHIBITS

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EXHIBIT NO. :
For the State:
Exhibit A (Uncontested Divorce Documents)
Exhibit B (Quitclaim Deed 2009022815)
Exhibit C (Quitclaim Deed 2009005571)
Exhibit D (Quitclaim Deed 2009022816) AT PAGE

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Exhibit E (Assignment of Mortgage 20090587860)

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Exhibit F (Assignment of Mortgage 2009058784)

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1

APRIL R. TAYLOR,

2 was called as a witness, and being duly sworn by the

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Notary, was examined and testified as follows:

~- ~~ ~---~~-~~~ ~ ~ -~~- ~ ~- ~ ~~-~- ~~~~- -~ -~- ~ - - ~ ~ ~~-~~~- ~

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4 DIRECT EXAMINATION

5 BY MR. PRUNER:

6

7

8

9

Q

Please state your name.

A

April Renee Taylor.

Q

And your occupation?

A

Legal assistant and the office manager

10 for James Buzbee.

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12

13

Q

And the physical location of Mr. Buzbee's

office?

A

802 West Martin Luther King, Jr.

14 Boulevard, Suite D, Plant City, Florida 33563.

15

Q

About how long have you been working for

16 Mr. Buzbee?

17

A

I have been here since January the 28th

18 of -- it's seven years, seven years.

19

Q

And before that were you also employed in

20 the legal field?

21

A

Oh, yes.

In LaBelle, Florida I worked

22 for Owen Luckey.

23

Okay.

Q

We're here to take a sworn

24 statement from you in an ongoing investigation that

25 involves the death of a person by the name of Abraham

ICIlPJ

1 ............. \ "'--'"

1

Shakespeare and some dealings by --

2 (Brief pause in the proceedings.)

3 BY MR. PRUNER (resuming):

5

~-~---~~~----~~~--~-----~+--.~----~--~-~-~-~~---~----~~---~------~ ~-

4 Q We're here to take a sworn statement rom

5 you in an ongoing investigation into the death of

6 Abraham Shakespeare and some dealings conducted by a

7 person by the name of Deedee Moore and Howard Stitzel

8

and others.

Did you know a person by the name of

9 Howard Stitzel back in February of 2009?

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12

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A

Yes.

Q

Can you tell me approximately how long

you had known him?

A

I've known him since I came to work for

Mr. Buzbee.

Actually, when Mr. Buzbee is out of state,

15 I actually used Howard to go over my documents, sign,

16 so we had close interactions all the time with Howard.

17

Q

So you were familiar with him by name and

18 by sight and by working with him?

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20

A

Oh, absolutely.

Q

And did you know Deloris, or her name is

21 not Deloris but Deedee Moore?

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23

A

Yes.

Q

And how was it that you first came into

24 contact with her?

25

A

Not personally, it was only on a business

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9

Q

Okay.

And did that, the fact that he

basis.

And the first time I actually met her was

2 February 11th.

3

Q

Of 2009?

5

6

2009, yes.

Q

Okay.

Let's talk about that date of

February 11th of 2009.

Did you see Mr. Stitzel on that

7 day?

8

A

Yes.

Q

When and where and tell us about the

10 circumstances.

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13

A

We start work at 8:30.

When I got here

him and Deedee was in the parking lot in a black

Mercedes.

And as soon as I got out of the truck, of

14 course, he got out to meet me, and that's when he

15 explained that he needed my help to prepare a bunch of

16 documents.

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18

19

Q

Okay.

Was he the driver of that vehicle?

A

No, Deedee was.

Okay.

I'm sorry.

And so he approached

Q

20 you outside the office or inside?

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A

At first it was outside because I was

22 walking up and he was just explaining why he was

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waiting for me out there.

25 showed up early that morning to make that kind of \ Ct\..p5'

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3 closely with Howard.

,<,

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request, was that alarming to you or unusual?

A

No, not for -- no, because we work

Q

Okay.

So did Mr. Stitzel come into the

5 office?

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7

A

Yes.

Q

And did he request that you perform any

8 type of legal work for him?

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A

Yes.

13 uncontested divorce, and then we prepared two deeds, an

Q

Tell us, tell me about that.

A

Okay.

We done Deedee or Dorice Moore's

divorce.

We did every document start to finish, an

14 Assignment of Mortgage and a Promissory Note.

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Q

Okay.

Let's I guess talk first about the

16 uncontested divorce.

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18

A

Okay.

Q

I have a stack of documents here that you

19 just presented to me a few minutes ago before we

20 started and we'll attach these as Exhibit A to the

21 sworn statement.

22 (The document referred to was

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marked as State's Exhibit A for

24 identification.)

25 BY MR. PRUNER (resuming):

7

In..,....,,\ _ ...... _ ... _ .....

Okay.

Was there anything unusual about

1

Q

8 Does this stack of documents comprise all

2 those documents that you prepared for Mr. Stitzel at

3 his direction in Dorice D. Moore's uncontested divorce?

4 5

A Q

Yes.

6 either the documents as Mr. Stitzel had instructed you 7 to prepare them or about the contents?

8 9

A

Actually it was a pretty standard

uncontested divorce.

There was a few issues that I,

10 that we did change up and I can show you really quick.

11 12

Q A

Okay.

All of these are very standard documents

13 except the only thing that we modified was this Joint

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Stipulation for Waiver of Mandatory Disclosure.

In an

15 uncontested divorce we can waive everything that's

16 mandatory disclosure except for a Financial Affidavit.

17

And I told Howard that, and he said, "No,

18 waive it." And I said, "Well, I don't know the

19 language to waive it because it's not something we can 20 do." And then this right here, he read that off to me. 21 And this is what we changed because he didn't want to

22 23 24 25

I'm sorry.

do the Financial Affidavit. because I'm like

And I started questioning

Okay, hold on one second. Oh.

Q A

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Q

Okay.

Had you ever prepared any such a

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Q

And when you say "this right here" you're

2 referring to enumerated paragraph number one on a

3 document entitled Joint Stipulation for Waiver of

4 Mandatory Disclosure?

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A

Yes.

6

Q

And that language in paragraph number one

7 reads, "Any and all Financial Affidavits required

8 pursuant to Florida statutes 61.et.sequeter and the

9 Florida Family Law Rules of Civil Procedure"?

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A

Yes.

11

Q

Okay.

And you're indicating that is out

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of the normal practice for preparing an uncontested

13 divorce and its documents?

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A

Yes.

15

Q

And educate me.

Financial Affidavits

16 would include what?

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A

All your assets and liabilities.

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Q

And is your understanding that in this

19 type of uncontested divorce both parties to the

20 uncontested divorce would have to make such formal

21 complete financial disclosure?

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A

Yes, they do.

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24 waiver of Financial Affidavits and disclosure in any,

25 in your many years of being a legal secretary or legal

t107

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And he said no, this is his law

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assistant?

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A

The waiver, yes.

Actually waiving the

3 Financial Affidavit, no, that was something that we

don't, it's not allowed.

You have to file it.

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And I interrupted you.

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Okay.

You were

Q

6 going on with your explanation of this document and

that morning.

Tell me about any other unusual

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8 procedures or contents of these documents.

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A

Whenever

because we first started with

10 the divorce, so, but I started, but he'd also just

11 mentioned this other stuff so I knew that there was

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property involved, so I questioned him and the fact of

13 why we were waiving the financial.

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15

Q

Howard Stitzel?

16 that it was his law license and to not -- because I was

A

Yes, Howard Stitzel.

And he just told me

17 worried about Mr. Buzbee, even though Mr. Buzbee,

18 because he had no knowledge of this.

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20

Mr. Buzbee was not in the office.

He

21 already told Howard that but Howard said, "It's okay, I

wasn't scheduled to be in yet.

And I actually had

22 just need you."

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Because when you're starting to waive

24 something I knew was wrong, I was like, I was worried

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about Mr. Buzbee.

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A

No, and I didn't ask.

I just figured it

license, it was going to be his bar number on the

2 bottom of each paper.

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Q

Meaning Mr. Stitzel's?

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A

Yes.

5

Q

Okay.

Was Ms. Moore in the office at the

6 time of the creation of, drafting and creation of these

7 divorce documents?

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A

No, she was not.

She stayed in the

parking lot, and that was what was really weird.

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He

10 kept, every time I had a question as far as what the

11 child's Social Security number was or the child, where

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the child was born, because that's some of the things

13 that I need in these documents, he wouldn't know it so

14 he would have to run out and ask her.

15 And at one point, and how I know it was

16 actually Deedee in the vehicle was Howard was taking a

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really long time out there.

So I went out to the car

18 and I had asked her some questions that I needed for,

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you know, to finish the paperwork.

I just figured it

20 was faster and get 'er done.

21

Q

Did either Howard Stitzel or Deedee Moore

22 ever give you an explanation of why she just didn't

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come inside?

25 was not his law office so he didn't want to take it

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A

She was a lot cleaner and, I mean, she

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over like it was.

Is that -- had you seen her before that

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Q
day?
A
Q
in person or
A
No.
Q No.

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No.

No, I have not.

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Have you seen her since that day either

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on any media reports or anything?

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No, I've not seen her in person.

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9 Did she -- did you address her as Deedee

10 or Ms. Moore when you went out there?

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A

Yes.

Yes, I did.

Because I assumed it

was her being the fact that that's whose paperwork and

13 she had the answers that I needed.

14 Q Okay. Have you seen her on the

15 television news in the last several weeks?

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A

Yeah, the Internet.

Q

And from seeing the published photos of

18 Ms. Moore on the Internet or published news accounts,

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19 are you certain then that the person who was sitting in

20 the Mercedes outside of Mr. Buzbee's practice or office

21 on February 11th of 2009 was, in fact, Dorice Deedee

22 Moore?

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A

Yes .

Q

Okay.

I t"\ ... ....,. \

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was a very well-kept person back then.

I mean her --

2 she doesn't look quite as kept now but

3

Q

So when you confronted Mr. or asked

4 Mr. Stitzel about the waiving of the Financial

5 Affidavits, he responded in words or substance that it

6 was his law license and his bar number and not

7 Mr. Buzbee's?

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A

Uh-huh.

13

Q

Is that correct?

13 that I knew it was wrong so I questioned it and he just

A

Yes, sir.

14 assured me, because Mr. Buzbee didn't know what we were

Q

What did you take that to mean or how --

A

I didn't take it any way.

I just took it

15 doing and I didn't have time to clear it through him.

16 I mean, is it customary that we would, I

17 would help Howard or any other attorney in the past?

18 Absolutely.

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Q

Sure.

They were friends.

A

It's very common.

I'm a paralegal.

I can actually do this back and forth

22 all day long with no attorney here and just have them

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proof it.

Q

All right.

A

It just, it started getting -- and to

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I mean, he was like really

give the whole picture of the day Howard come in in

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shorts, a buttoned-up Hawaiian shirt, and it was

3 the reason I know, explicitly remember, because it was

4 really big on him.

5 And there was rumors flying about Howard

about drugs and stuff.

So, of course, being me

6

7 thinking I'm on a friend level with him, we actually

8 talked about it, about drug use, and he brought to

light all of his weightloss and everything.

9

So

Q

Did he acknowledge having a drug problem

11 at that time?

12

A

No, what -- we didn't talk explicitly.

13 never said, "Do you," what it was was there was some

14

characteristics that day.

Like he had some sores on,

15 I'm not, I'm not, I don't know everything about drugs

16 but I'm not ignorant either, he had some sores on his

17

arms.

He would sit there while we were doing this and

18 as he would get really nervous and go (indicating).

19

Q

You're showing me he would pick at his

20 forearm?

21

22

23

A

Yes, he would.

Yeah, like, there was

like a little sore there.

There was like two or three

actually.

And he drank, I'll never forget it, he drank

24 two Cokes and ate two bags of chips while he was here

25

while I did this paperwork.

14

and

I

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He actually had a different date

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hungry and thirstYt and I was like wow.

Q

Was there any other unusual provision in

3 these divorce documents that you prepared for

4 Mr. Stitzel on that day?

5

A

When we prepared them he asked me to

15

6 preparet he asked me to look up with the judge what was

7

the next uncontested dissolution date.

I did and I

prepared

there waSt you have to have 20 days from

9 the day you file it to the day you can have a final

10 hearingt so the next available date I could get it on

11 was March 11th .

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13

That was 30 days from the day I was

preparing it.

And that waSt and I explained to Howard

14 that's if the husband had to sign these and it has to

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be filed 20 days before.

So I gave him a ten-day

16 leeway to get all that done before this hearing.

17 And I also brought up the fact that they

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have to have a parenting class.

I saidt "That's a

19 really short notice to get a parenting class done."

20 But I know Judge Sexton; she wouldn't agree to this

21 divorce without it, so I went ahead and done the Notice

22 of Hearing.

23

He said, "Well, if I can't get it done I

24 won't file it." And when I looked it up after the fact

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he didn't file this.

1

2

3

4

so --

Q

Okay.

As far as the Notice of Hearing?

A

Yes.

Q

Okay.

Did Mr. Stitzel sign any of these

5 divorce documents in your presence?

6

7

A

No.

Q

Did Dorice Deedee Moore sign any of these

8 divorce documents in your presence?

9

A

No, because I would not notarize so he

10 didn't bring her in.

11

12

Q

All right.

And do you have any personal

knowledge as to whether you or the Law Offices of Jim

13 Buzbee received any compensation for preparing these

14 divorce documents?

15

16

A

No, we did not.

Q

Okay.

And as far as you knew, in

17 February 11th of 2009 was Mr. Stitzel or Ms. Moore a

18 client in any fashion of the Law Offices of James

19 Buzbee?

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21

22

23

24

25

A

No.

Q

He was not?

A

No.

Q

And she was not?

A

No, neither one has ever been a client.

Okay.

You've also indicated that on that

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Q

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1

date you prepared, at Mr. Stitzel's request and

2 direction, a number of documents, Quitclaim Deeds, an

3 Assignment of Mortgages; is that correct?

4

5

6

A

Yes, and a Promissory Note.

Q

Okay.

A

I was fixing to say something about, oh,

7 if you, and to back this up, if you need the proof of

8 the day that this, how I know the exact day all this

9 stuff was done is our computer date stamps something

10

when it's done.

The software we use, it's called Pro

11 Doc .

12

13

Q

Sure.

A

So that's how I know exactly what date

14 all this was done.

15

Q

All of these documents that we're talking

16 about?

17

18

19

A

Yes.

Now, the deeds and stuff, no,

17

because we don't do them in the software.

I actually

20 on that, the computer crashed so I don't have the exact

21

do my own deeds outside the software.

And the thing is

date stamped on these.

That's why I printed off the

22 executed copies because, now, I've got the computer

23

still here.

So I don't know if you all, that's very

24 evident if you all need it but --

25

Q

That's all right.

But is it correct

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4

1

He says, "No, no,

\q?,)

10 Deed which is stamped by the Clerk of Court's Office as

18 that all these Quitclaim Deeds that you've presented to

2

me this morning and the Assignments of Mortgage were

all done on the same date?

A

Yes, they were.

Because after this it

5 was over, and I told Mr. Buzbee about him being in here

6 and me doing this, we were -- I was very well-advised

7 to never do it again.

8

I see.

Let me show you what you've given

Q

9 me a few minutes ago, a document entitled Quitclaim

11 instrument number 2009022815 .

12

13

14

15

16

17

A

Yes.

Q

Okay. Did you prepare this document?

A

Yes, I did.

Q

At Mr. Stitzel's request and direction?

A

Yes, I did.

Q

And tell me about it.

Anything unusual

18 about the preparation of that document?

19

A

Actually, yes, there was two things.

20 Instead of us re-typing the full legal, he had the

21 legal on another piece of paper and said, "Just put it

22 as attached, an attached legal." We did that .

23

The second thing was is he, whenever I

24 originally had went into the Quitclaim, it had January

25

on it and I changed it to February.

I .............. \

1 leave it to January." So I went back and put it back

2

to January.

I knew immediately that was wrong and I

3 would never

4 5

Q A

And why is that wrong?

Because I knew it wasn't -- there was no

6 way the deed could be executed on a January date when 7 it was already February 11th.

8

Q

Okay.

But at Mr. Stitzel's insistence

9 you did put the date of January 11, 2009?

10

A

No, I did not.

I did not put the 11th.

11 That was wrote in by the notary or someone .

12 13 14

Q A

I see.

I put January, 2009.

I see.

Is there anything else? Is

Q

15 there, is it unusual for the legal description of the 16 property to which the Quitclaim Deed applies to be on a 17 separate piece of paper other than the body of the

18 actual Quitclaim Deed?

A

No, that's actually -- I've seen it done

19 20

multiple times.

That I really didn't question as

21 wrong. 22

Q

Okay.

Did you have any personal

23

knowledge of any of the information set forth in this

24 document?

25

A

No. All I knew it was, I had to

19

1

20 specifically ask where the property lied because that's

2 where you have to put this, and that's the only way I

3 knew it was even property in Polk County.

4

Q

Okay.

Had you ever had any contact with

5 Abraham Shakespeare about this document?

6

7

A

No, I had not.

Q

And for the record this Quitclaim Deed,

8 the instrument number that I've referred to a minute

9 ago, will be attached to the sworn statement as Exhibit

10 B.

11 (The document referred to was

12

marked as State's Exhibit B for

13 identification.)

14 BY MR. PRUNER (resuming):

15

Q

Was this document signed by anybody in

16 your presence?

17

A

No, it was an unexecuted document when it

18 left here.

19

Q

Did you have anything to do with the

20 filing of this document?

21

22

23

24

25

A

No, I did not.

Q

Or the recording?

A

No, I did not.

Q

Okay.

A

It was, the only thing I can say is they

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1

And it, well, it does say, in fact, deed

10 page of this cumulative document, Leah King, what looks

11

12

13

14

15

16

17

18

19

was here at 8:30.

21 It took us approximately a couple of

20 doesn't specify what it's notarizing, which is very odd

2 hours to finish all the paperwork, and it's recorded at

3 3:15 on the same day that I prepared it.

4 And you know that by looking at the

7

Q
stamped
stamped
County?
A
Q Okay.

There is a notary page, the second

5 information up in the upper right-hand corner

6 by Richard M. Weiss, Clerk of Court in Polk

8

Yes, sir.

9

to be Leah D. King.

Does Ms. King, did Ms. King work

for the Law Offices of Jim Buzbee at that time?

No, I'm not aware of who she is.

A
Q
page, page 2?
A
a generic
Q
A Okay.

So did you prepare that notary

I am not completely sure because this is

Okay.

-- notary.

If you'll notice, this notary

21 to me whenever I looked at this recorded document

22 because immediately I started looking at different

23

24

little points.

25 first thing, so, yes, actually then this one is

1 2 3 4

probably a good valid notary.

Q A Q

Okay.

Except for the date.

Anything else about this document that

5 you found interesting or unusual?

6 7

No, it was pretty standard.

When he come

A

in it was simple.

He just said, "Attach this one." We

8 used his home address at the time because he did not

9

have an office.

That's when he told me that him and,

10 which I had already kind of knew that he wasn't with 11 Byrd & Stitzel anymore simply because I was at the gym

12 13

a couple of, you know, in January.

I seen the signs come down that night and

14 I was like, I kind of thought that was, I'm like, oh, 15 there's something going on over there.

16

So when he come in that day and, like I

17 said, we talked about all of it and he told me that, he 18 told, he flat out told me that when he finished these 19 documents this was the start of his new law office.

20 And one of the papers that you won't find

21 here that, because it's not recorded and, like I said,

22 23

the computer crashed, is a Promissory Note.

I did a

Promissory Note for him from, it was the Abraham

24 Shakespeare something, it wasn't him personally.

25

Q

LLC?

\q6\

.... II"T'"T T,.... T-..T'""I ...... _ ...... rPI ............ _ ------

22

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

1

Okay. Any further conversation that he

A

Yeah.

It was as a business.

It was for

2 $30,000.

3

Q

And tell me what that document set out.

4

A

It was just a Promissory Note.

5

Q

From whom to whom?

6

A

From Abraham Shakespeare to or from, I'm

7 sorry, it would be from Howard, D. Howard Stitzel to

8 Abraham Shakespeare, LL whatever, I don't remember.

9

Q

LLC?

A

Yeah, it was a business.

Q

Indicating an indebtedness from

Mr. Stitzel to the Abraham Shakespeare entity?

A
Q
A
Q
A
Q
or - -
A
Q
again?
A
Q Yes.

Okay. And you did type that out?

Yes.

Was that executed in your presence?

No.

Did you ever see a recorded copy of that

No.

-- have you ever seen that document

No.

25 had about this would be the start of his new practice?

\~~~)_

1\.JrTT T ("'1 T\T:TT"'\r"\.T"\rT'1"T"''"A.T,... """T""'Io_TTT""'Io

I _""I"'" \

23

1

And I'm like,

Did he explain what that meant?

2

A

Well, the whole context of the story was

3

we was talking about his drug use.

And I had told him,

4 I said, "Howard, why don't you go take a drug test.

Don't open it."

Because, you know, he was still kind

5

6 of insisting that he wasn't.

7

Not insisting.

He didn't specifically

8 say, "April, I don't do drugs," but you can tell he was

9 still reluctant to admit anything.

10 So I kind of just told him, because he

11 was talking about all the buzz and all the different

12

attorneys that was letting him down, and, you know,

13 that he appreciated me doing this for him and I didn't

14 turn my back on him, dah, dah, dah.

15 And I said, "Well, why don't you go take

16 a drug test, don't open it, and go to the bar

17 association meeting and put it on the table and let

18

19

20

them open it."

I said, "It will stop all this." And

he was like, "I'm not doing that.

No, there's no way."

I said, "Well, Howard, you got to admit

21 they're," I said, "You've lost a lot of weight." And

22 he's like, "Well, I've been trying to lose weight."

23

24

And he says, "I look good, don't I?" And

he stood up and he turned around for me.

25 "Well, you do look good but, you know, there's a lot

\Q;S3

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24

2

3

1

up.

I mean, if I didn't know how to do something or

surrounding the reason why you're losing the weight."

And, you know, just, we were just talking

as friends.

We had talked before just, you know, we

4 had a lot of dealings with each other over seven

10

5 years

6

Q

Sure.

-- over different legal stuff.

So, I

7

A

8 mean, did he ever tell me his personal family life?

9 No, but --

Q

Did he tell you anything on that date or

11 in any other conversation about his relationship with

12

Deedee Moore, his business or legal relationship with

13 Deedee Moore or personal relationship?

14

A

No.

It was just that this, the only

15 thing, like I said, the only thing was that when he

16 finished all this for Deedee, because that's who

17 brought him here, whenever we finished this this was

18 he just kept assuring me that this was the start of

19 his, that he was going to get back on his feet and he

20 was going to show everybody.

21

22

23

24

Because like I told Howard, I respected

Howard as an attorney.

Howard was a very smart

25

attorney when he was in his day before he got messed

25 wording I could call Howard, if he was in the office he

V11r'l

1

could tell you wording off the top of his head.

I

2 mean, he was good in his day.

3

Q

Did he tell you anything about the

4 $30,000 that he was to receive that was evidenced by 5 this Promissory Note?

6

A

No, he just said that was what, how he

7 was going to restart his law firm.

8

Q

With the funds that were documented by

9 that Promissory Note?

10

A

Yes. And it wasn't recorded so I don't

11 know if they didn't follow through with it or what .

12

But he just said that when he finished this stuff that

13 he was going to be back on his feet.

14

Q

All right. Anything else about this

15 Quitclaim Deed or the conversation pertaining to it 16 with Mr. Stitzel that we haven't talked about?

17

A

No, unless you want to talk about after

18 fact things.

19 20 21

Q A

Well, go ahead.

Not at the time we recorded it, like I

said, it was an unexecuted document.

Now, if you go

22 back and you look, that's why I wanted to print this .

23 24 25

Okay.

When Howard left here that day I noticed

Q A

Okay. Okay.

Excuse me for interrupting again.

1\IrTT Tn T"\'r'1T"'\'-"T"'\t"'M"T"""" __ --_ .............

26

1

Q

27 When you say "this" you're referring to a

2 copy of a Quitclaim Deed which we'll identify and

3 attach to this sworn statement as Exhibit c.

4 (The document referred to was

5 marked as State's Exhibit C for

6 identification.)

7 BY MR. PRUNER (resuming):

8

Q

That is in the form that the Law Offices

9 of Jim Buzbee uses and that you prepared; is that

10 correct?

11

12

13

A

No.

Q

No?

A

Exhibit C is a Quitclaim Deed prepared by

14 the Law Offices of Byrd & Stitzel.

15

Okay, I see.

Okay.

And, go ahead and

Q

16 explain.

17

A

After he left here and I knew -- I didn't

18 know who Abraham Shakespeare was, of course, I didn't

19 know until I seen it on the or read it on the newspaper

20 that, or on the Internet, that he was even a lottery

21 winner.

22

23

24

25

But after he left, "he" meaning Howard

left this office, I called over because the assistants

in every law office, we all talk.

I mean, we know

what's going on.

I mean, it's just part of it. So I

Iqgb

MTT.T.c! "0 .... "0(""\"0.,.,,1\1,... """[)r"\TTT"'l T1\Trt

10"'\ '""1"'7'""1 101.11

1

2

called over there and I talked to Lori --

Q

Excuse me.

Let me turn this off.

Well,

3 let me take this, excuse me.

4 (Phone call interruption.)

5 BY MR. PRUNER (resuming):

6

Q

You were going to explain or were in the

7 process of explaining Exhibit C, the Quitclaim Deed,

8 and make observations by comparison with Exhibit B.

9 Please, continue.

10

11

12

A

Okay.

As I said, when I left here it was

28

an unexecuted document .

But with everything going on

13 drug speculation, the first thing I did, of course, was

and knowing the way he was when he was here and the

14 call Lori Collins at Stitzel & Barnhill at the time,

15 now it's Stitzel & Barnhill or, I mean, Byrd 7

16 Barnhill.

17 And she had told me that the last day he

18

worked over there was January the 18th.

And that's

19 what led me to speculate that he back-dated this to

20 January the 11th, which is exactly 30 days before I

21

did.

It throws it back to the time he was actually

22 there in a law firm versus nowhere.

23

And I just explained the way he was, and

24 she just told me, yeah, that's why he was kicked out of

25 there[ not showing to court and stuff like this. So,

\q30

1

A

Both of these, both of these witnesses on

ICf~

and, but if you look, his signature here to there,

they're different.

2

They're nowhere near the same.

3

Q

Who? What signature of whom?

4

A

Abraham Shakespeare.

The characteristics

5

are nowhere near the same.

The slants are different,

6 they're--

7

Q

And this Quitclaim Deed, Exhibit C,

8 prepared the 9th day of January 2009 is the document

9 that you're using to compare Mr. Shakespeare's

10 signature; is that right?

11

12

A

Uh-huh.

Yes, sir.

Q

And who is the lady that you spoke with

13 at--

14

A

Lori Collins, she's the notary on that

15 Quitclaim Deed.

16

17

18

19

20

Q

Exhibit C, the Quitclaim Deed?

A

Yes, sir.

Q

Okay.

A

And, of course, their assistants are no

longer there.

They let both, they let all of their

21 assistants go at Barnhill because of it being, it got

22 really slow for all law firms so, unfortunately, they

23

24

25

lost

Q

So Ms. Collins

MTT.T._C! PRDnD'T'Tl\TI"" roDI"'\TTT) T"'T""

29

10

11

12

13

3

jCJJ'9

1

30 the deed, Exhibit C, were actually the legal assistants

2 at that office.

Q

Oh, so Lori Collins is not there any

4 longer?

5

No.

Unfortunately, she lost her job.

A

6

Q

Have you heard through the grape vine if

7 she's employed?

8

A

Actually she called me after she got laid

9 off and gave me her cell number so if I ever heard of

another, you know, attorney.

And I -- it's somewhere

in my office.

I --

Q

Okay.

Maybe we'll talk about that after.

A

I didn't think I should call her now.

14 don't want to mess any waters up anywhere.

15

16

Q

No, I appreciate that.

Let me go back to

Exhibit B, this Quitclaim Deed.

Did either -- well,

17 you've indicated earlier that nobody attached any

18 signatures to that document?

19

20

A

No, sir, no document.

I

Q

Do you know of an individual by the name

21 of Doug Hancock who appears to be one of the witnesses?

22

23

A

No, sir.

It looks kind of bogus to me.

And the reason I say, if you look at his signature on

24 the same day he executed the two deeds that left our

25 office, they're not the same.

MILLS REPOR'T'TN~ ~RnTTP TlI.T(",

(Q1")\ ')'7') "10"1A

Okay.

Let me show you a document that

1 2

Q A

What's not the same, ma'am?

The way that he -- it looks like somebody

3 tried to forge a name or tried to come up with a name

because there's no, the consistency is not there.

4 5

Look

at the point in the R, there's no point.

You know, it

6 looks like they tried to come up with a name.

7

Oh, I see.

Okay.

Anything else about

Q

8 Exhibit B or C that you think is significant or odd?

9 10

No, sir.

No, sir.

A Q

Okay.

And again, the Law Offices of Jim

11 Buzbee or you individually did not, were not

12

compensated for the preparation of Exhibit C; is that

13 correct?

14 15

A Q

No, we were not.

16 will be attached to this statement as Exhibit D, a

17 Quitclaim Deed on the upper right-hand corner bearing 18 instrument number 2009022816.

19 (The document referred to was

20 marked as State's Exhibit D for

21 identification.)

22 BY MR. PRUNER (resuming):

23

Q

Did you prepare this document at

24 Mr. Stitzel's request and direction on the 11th of 25 February 2009?

MILLS R RPnR'T'Tl\Tr:! r:!"OIlTTD Tl\Tro

31

1

2

A

Yes.

Q

Okay.

Is there anything about this that

3 you'd like to comment on or any information?

4

A

The only thing, as I said, that he had me

5 do on both these deeds is the date.

6

Q

And the document indicates the blank day

7 of January as you prepared it, correct?

8

A

Correct.

But it was done February the

9 11th.

10

11

12

13

Q

And about that you have no uncertainty?

32

A

No, there is no uncertainty.

I know it

14 knowledge about any of the information contained in the

was done that day.

Q

Okay.

Did you have any personal

15 document?

16

A

No.

No, sir, there again, because most

17 of the stuff we do is Hillsborough County so I had to

18

verify, again, verify which county.

That's how I know

19 it was Polk County at the time because that's not most

20

of our divorces that we're doing these deeds in.

And

21 see, if you'll notice, they're Quitclaim Deeds, not

22 Warranty Deeds.

23

And theY're Quitclaim Deeds because most

24 of the time in a divorce we're doing it by Quitclaim

25 Deed and I know a lot more about a Quitclaim than a

)o;t(;

MILLS REPORTING GROUP_ TNr

1

warranty.

A Quitclaim is really not near as good as a

2 Warranty Deed. And they should have been a Warranty

3 when you're transferring outside of people that's not

4 kin like that, but --

5

Q

And educate me why.

Why is it better to

6 us a Warranty rather than a Quitclaim Deed?

7

A

I don't know all the legal things of how

8 you would say it, but I just know that Mr. Buzbee has

9 always taught me in a divorce when we're just taking

10 one person's interest, like both people have an

11 interest in this property and you're only taking one

12

person off so, therefore, it's still within the same,

13 like, start.

14 So kind of you can do the Quitclaim

15 versus if you're having parties over here that has it

16

and you're transferring it way over here to.

So, no,

17 there's no reason, there's no connection, it's just a

18 flat out transfer, it would be a Warranty Deed.

19

Q

I see.

Okay.

And again --

20 A And he didn't ask me to do a Warranty or

21 a Quitclaim, he wanted deeds so naturally I'm going to

22 do a Quitclaim Deed because I have them stored in my

23

computer because of divorces .

Whereas, Warranty Deeds

33

24 the language is a little different, so I didn't want to

25 go through because I'm not really good at the words

~qq.;t

MILLS RF.POR'T'TNr:! r:!P()TTO Tl\TI"'

Q

I gotcha. And again, this document, this

1

that's in Warranty Deeds and to which ones have to be

2 changed every time you do a new deed, whereas, a

3 Quitclaim Deed I can pull one up and I know exactly 4 throughout all this what I have to change.

5

6 Quitclaim Deed, Exhibit D, was not signed in your

7 presence by any of the individuals, Mr. Shakespeare or 8 the witnesses?

9 10

A Q

No, it was not.

And the notary, Leah D. King, was not

11 present and did not execute the notary in your

12 13 14

presence; is that correct?

A

No, she did not.

Q

Okay.

Anything about this Quitclaim Deed

15 that we haven't spoken about that's interesting or 16 significant in your mind?

17 18

A

Basically you're looking at the same

things.

I mean, it's all after the fact.

After, you

19 know, things you immediately start looking at the

20

signatures.

And even this signature to the one that is

21 the same one that I prepared, executed on the same day 22 are different.

23

Q

Okay.

Did you know anything about

24 Shakespeare & Associates, LLC or American Medical 25 Professionals, LLC?

MILLS REPORTTNn nRnnc TN~

(Q1.' ,,)'7")_101A

34

1

2

A

No.

No, he had to give me all of that

because I didn't know.

Like I said, I knew, I can

3 remember because, unfortunately, Shakespeare is a name

4 you don't forget.

5

6

Q

Right.

A

So when he was in here I knew the names.

7 And that's just like, when we go to the next document,

8 the Assignment, I can tell you from my, I mean, my

9 memory I know for a fact that this is the particular

10

document that we done because of the name.

The name is

11 one that it's just it sticks out there .

12

Q

Okay.

As to Exhibit D, did you learn

13 from Mr. Stitzel, or any other person that day, of

14 Ms. Moore's, Deedee Moore's relationship with American

15 Medical Professionals?

16

A

Just what he was telling us while he was

17 here.

18

19

Q

What did he say about that relationship?

A

Just that this, it was all in the same,

20 Deedee Moore owned American Professionals and that was

21 part of the reason we were doing these documents.

22 And because I had done this also, and he

23

had briefly told me before we started doing the

24 documents in the divorce that's how I knew he had to

25 have a financial in that, in that divorce because I

\ qqC!

MILLS RF.POR'T'TNr:! r:!R()TTP Tl\.Tr'

(Q1"2 \ ')'"7')_10111

35

10

1

So I was like, "You've gotta tell,

knew she had property.

2

Q

Okay.

3

A

And that's why I questioned, you know,

4 you got to have that financial because the husband's

entitled to half of anything she owns.

5

I mean --

6

Q

So you're indicating that these deeds

7 indicate that Ms. Moore had property interests that

8 were not, that should have been reported in a Financial

9 Affidavit attached to these divorce documents?

A

Correct.

And that's why he was trying to

11 hurry the divorce because to get it filed before she

12

gained the interest in it.

But for some reason they

13 felt it very -- a need to record these on the same day

14

15

16

they prepared them.

They didn't

36

Q

Is that unusual?

17 trying to do over here I would have thought why are you

A

Well, yeah.

I mean, knowing what he was

18 recording this deed so fast when if you're trying to

19

20

hide it from your husband to not split it up.

That's

21 was trying to tell Howard you can't do this what you're

what I thought it was in the beginning.

That's why I

22 doing without that.

23 Then that's why I was like -- but he

24

back-dated it.

25 you've gotta do that Financial Affidavit," that it

/995

MTT.T.!=: RRP()P'T'Tl\T~ ~DnTTn T""Trt

10

11

12

13

14

1

A

-- I was so focused on the divorce and

/{}tJy

didn't make sense.

But there again, I knew it wasn't

2 Mr. Buzbee or me and I was never going to execute these

3 documents.

4

Q

So was it your thought that what didn't

5 make sense was that he was back-dating these Quitclaim

6 Deeds which was inconsistent with what you thought was

7 his motive concerning the divorce documents --

8

A Yes.
Q - - which was to hide assets?
A Yes.
Q Okay.
A Yeah. It didn't make sense he was trying
to do two things. It was like he was trying to do two 9

things.

But you can't put the cart before the horse if

15 your goal here is that.

16

Q

Did Mr. Stitzel on that date or Ms. Moore

17 ever indicate to you why Mr., why Shakespeare &

18 Associates was transferring the properties and the

19 mortgage, the Assignments of Mortgage to American

20 Medical Professionals?

21

22

23

24

25

A

No, he never said and I didn't, honestly,

question.

I was because of my background in legal,

I've done divorce for ten years --

Q

Yes.

In"""\ ",r;"'" "10.,A

37

10

1

instrument number, as indicated in the upper right-hand

38 what was wrong there that, honestly, this is just other

2 stuff to me.

3

Okay.

Did he ever speak about an Assets

Q

4 Purchase Agreement that Deedee Moore or American

5 Medical Professionals had executed to Abraham

6 Shakespeare?

7

A

No.

8

Q

Or Shakespeare & Associates?

9

A

No.

Q

Or Shakespeare, Abraham Shakespeare, LLC?

11 These are all different entities .

12

13

14

A

Yeah.

See, no, he -- I didn't know, like

I said.

Any of the business things that you see on

here is what he had me do.

And if you'll notice on

15 these Assignments of Mortgage, which will now be I

16 guess E and F or E --

17

Q

Okay.

Let's look, let's move on to that.

18 We'll designate as Exhibit E for this sworn statement

19 Assignment of Mortgage which is identified as

20

instrument number 2009058786

is that my hand shaking

21 so much as stamped by the Clerk of Court in Polk

22 County, and Exhibit F, an Assignment of Mortgage,

23

24 corner, 2009058784.

25 (The documents referred to were

I qr:i')

MILLS REPORTING GROUP. TNl'

1

2

3

4

39 marked as State's Exhibits E and F

for identification.)

BY MR. PRUNER (resuming):

Q

Okay.

You prepared at Mr. Stitzel's

5 request and direction both of these two Assignments of

6 Mortgage; is that correct?

7 A Yes.

8 Q And neither of these documents were

9 executed in your presence; is that correct?

10

11

12

13

14

15

A

No, sir, they were not.

Okay.

Tell me about these documents.

Q

anything unusual or

A

The only thing I can tell you that is way

off was is he had me take off a notary.

He had me take

it off.

That's why you see half this page is blank

16 right here and this is moved down.

17

18

Q

On Exhibit F?

A

Yes.

Because I was trying to even up the

19 page because he had me take the notary off, and you

20 don't do that.

21

Q

Take a portion of the documents where the

22 notary would notarize the signatures?

23

24

A

Yes.

Q

He did not -- or you did that at his

25 direction on both Exhibits E and F?

In'1""'\\ _,...,_ -",_",11

Is

1

A

Yes.

2

Q

Okay.

3

A

E and F was, yes, they were done exactly

4

the same.

All I, when I run it, all I did was just do

5 it the first time and then I just changed the name in

6 the OR book and page.

7

Q

Now, on Exhibit F there is attached to

8 this document a notary page; is that correct?

9

A

Yes, there is.

But that was not on here

10 when it left here.

11

12

Q

Okay.

So you prepared --

A

And this should not be.

When you're

13 doing these legal documents you should not have a

14 notary on a full page by itself when you've got this

15

much space.

It should be -- there was one here but I

16 took it off.

17

Q

Did you ask Mr. Stitzel about why he

18 wanted that off?

19

20

21

A

Yes.

Q

What did he say?

A

Yeah, because I was, I knew 100 percent

22 that was wrong .

23

24

25

Q

Okay.

A

And there again, he just said, "Just

do --" he said, "Just do it.

I'm going to take care of

/911

40

1

all this."

"Okay, you take care of it." But I knew

2 that was wrong.

3

Q

And when you say it's wrong, is it just

4 wrong as a matter of form or is there some, some

5 additional

6

A

You have to have a notary on an

7 Assignment because that person is assigning, you're

8 assigning a debt or an asset or whatever you're

41

9 assigning whether it be, this happens to be a mortgage,

10 but you're giving something away.

11

12

Q And if the notary portion of the document

is on the same page as the actual assignment language,

13 is that done so that there is no doubt that the notary

14 is

15

A

Yes, that that notary actually, actually

16 notarized this document.

17

18

19

Q

This document?

Right.

Now, this notary that's attached,

A

she doesn't even acknowledge what she notarized.

So

20 really this notary could have been taken off of any

21 document and placed onto there.

22

23

24

25

Q

And you're referring to the notary page,

the second page on Exhibit F, correct?

A

Yes, I am.

Q

And there is no description for, in the

~

1 language, "I hereby certify," what document the

2 signature is placed on that she's notarizedi is that --

3 4

A Q

Right.

Okay. And does that --

5 A And there again, this has a notary date

6 of January the 16th. That notary date is on nothing

7

else anywhere.

I mean, that date -- because look.

8 he put the 16th in there.

9 10 11 12

Q A

Okay.

And the one thing that I have to question

on this document, like I said, when it left here it was

blank, is this address.

I'm not sure where that

13 address is.

14

Q

You mean the "607 South Alexander Street,

15 Suite 205 South" up in the upper left-hand corner of 16 Exhibit F?

17 18 19

A Q A

Yes, sir.

42

Okay.

Because when we prepared all the

Oh,

20 documents Howard gave me his home address, and I'm not 21 sure if, I cannot remember if he put, had me put that 22 on there that day or if he took that document from here

23 24 25

and changed it hisself.

Q Okay. Is there any different font

anything that you could-tell?

or

XD(

1

2

3

4

5

A

No, it doesn't look like a different

font.

The notary is definitely.

Q

Sure.

A

The notary is not the same color, not the

same nothing.

I mean, that notary was definitely

6 attached from another document but

7

Q

Okay.

Pertaining to Exhibit F, the

8 individuals, it's hard to, well

9 A That's Howard Stitzel.

10 Q Howard Stitzel indicates he's witnessing

11

12

13

14

15

16

17

the Assignment of Mortgage?

A Yes.

Q

And a person whose name is

A

That's the notary, Linda Kick

Q

Kickliter?

A

Yes.

Q

Is it unusual for a notary to also be a

18 witness to the, this document?

43

19 A Not on some documents. On some documents

20 we can. I'm a notary in this office, and because we

21 only have two girls in this office and Mr. Buzbee,

22 there is times when on certain documents I have to do

23

24

25

both, but on certain documents you can't.

Q

Okay.

A

Like a Will you can't because you have to

~O~

44

1

self-proof it with two additional witnesses and a

2 notary.

3

4

5

Q

Did you know Ms. Kickliter?

A

No.

Q

Okay.

On Exhibit E, also witnessed by

6 both Ms. Kickliter and Mr. Stitzel, all of these --

7 A And I did not print the notary page, I'm

8 sorry. I just ran out of time on printing.

9 Q Oh, you mean this morning?

10

A

Yes.

See, because it's one of two pages.

11 There is a notary page attached to this in the Official

12

13

Record.

Q

Okay.

You printed these off the Polk

14 County Clerk of Court website?

15

16

17

A

Yes, I did.

Q

Okay.

A

Because like I said, these documents, all

18 of the real estate documents that you see, the deed,

19 the Promissory Note, which I did not find recorded

20 which I know I did that day, and these Assignments was

21

22

23

24

on the computer, my computer that crashed.

Now, we

saved the hard drive.

I don't know.

Q

Okay.

A

I mean, if date is that important it's

25 there.

MTT T C" rlT:1T"\"'T'\rT"1"'T"' ...... - -- ----

1

Okay.

And both yours, as you've

Q

2 indicated before, you're certain that these documents

3 were prepared by you at Mr. Stitzel's instruction and

4 direction on February 11th, 2009?

5

6

A

Yes.

And I do know because it was only

one day.

Now, he has called several times since and he

7 asked me, you know, to get coverage, ask Mr. Buzbee to

8 cover a case, you know, cover a hearing or ask me what

9 a judge's number is because he hasn't had a secretary.

10 So there has been multiple times since

11 these documents he's called and asked me, you know, a

12

13

14

judge's number --

Q

Sure.

A

-- or a court reporter's number or

15 something like that.

16

Q

Again, these documents E and F, the

17 Assignments of Mortgage, were you either individually

18 or was Jim Buzbee's law firm compensated for your

19 preparation of these documents for Mr. Stitzel?

20

21

A

No.

45

Q

Okay.

And when they, these documents E

22 and F left your office, none of the signatures were on

23

24

25

the front pages of these Assignments; is that right?

A

No, they were not.

MR. PRUNER:

Okay.

Mr. Delisle, any

;(Co~.

1\JI'TT T ('"t T"l~T"'\"T"'\rT"I""""- -- ----

1

9

Mr. Buzbee's office had the ability and the paper and,

questions?

2 EXAMINATION

3 BY MR. DELISLE:

4

Q

Do you know if he uses anybody else to do

5 what you did for him, any other attorney --

6

7

A

No.

Q

-- or legal assistants or anything in

8 town?

A

No.

I think he used, he uses me because

10 him and Mr. Buzbee were really good friends prior to

11

12

this and he knows that I don't question it.

And

there's been mUltiple times in the past he can call me

13 and I can do a document.

14 Not saying nobody else in town can

15

16

because they can.

Any legal assistant that's done

46

anything for any amount of time can do it.

But he just

17 knows that, he knew that I would do it and not, I mean,

18 questioned it.

19

Like I say, we were kind of not friends

20 to go out and ever have a drink or anything like that,

21 but, I mean, we were friends enough to where he knew

22

23

when he called me that I could do this.

And he knew

24 you know, everything that it could be done.

25 Q On previous occasions when you've done

eccs-

1

A

And he knew -- as a matter of fact, he

2

47
something for him, were those also at no charge?
A Yes, we've never charged.
Q So the no charge is just a common
exchange between attorneys and friends or whatever? 3

4

5

Right.

Because like I say, with

A

6 Mr. Buzbee if he was out of state on vacation we would

have Howard sign like a Notice of Appearance.

7

If we

8 had a case and I just needed to get it on another

9 docket and the judge needed a Notice of Appearance

10 Howard would sign it for us, you know.

11

12

Q

Okay.

A

It's just we've used other attorneys, you

13 know, also to sign.

14

Q

Okay.

So it wasn't unusual not to

15 charge?

16

17

Oh, yeah.

A

No, we never.

Q

I mean, what I'm trying to get at is he

18 didn't say, "Hey, you know, I don't want to pay for

19 this one," or whatever, "Let's do this one under the

20 table"?

21

22

23

A

Yeah, no, there wasn't no trying to hide.

Q

Okay.

24 didn't have any money that day. And I can prove I

25 didn't get any compensation because he had to borrow ~cXJ0

1\/fTT T ("'I T'liT":"lT"\_T'"\ .................. _ -- ----

At some, at some point, and also because

1

five dollars for gas, which I don't know why because

2 Deedee was out there.

3

4 he was here for a couple of hours, Deedee was here when 5 we were doing all the divorce stuff because he had to

6

go out there several times.

I even had to go out there

7 and ask a question or two and I just bent down in the 8 door and asked.

9 And I noticed at the time, because I told

10 Mr. Buzbee, of course, when Mr. Buzbee come in, I, of

11 12

So I told him, and I even

course, told him what I done .

I mean, this is his

office; I have to tell him.

13 made mention that he was in the car because, with the 14 girl, with the, she was very well-kept, very pretty, I 15 mean, nice.

16

Her hair was, you know, bushy blonde.

17 was kind of, to me it's an '80's look, not current but, 18 you know, the bushy blonde hair, but very nice clothes, 19 black Mercedes, you know, she spoke very well.

20

She, you know, she didn't speak like she

21 didn't know, I mean, she spoke, she carried herself 22 very well, she spoke with authority and like she knew

23

what she was doing.

24 FURTHER EXAMINATION

25 BY MR. PRUNER:

MTT.T CI T')T":1T"\"T'"\rT1'T"'''- -- ----

48

It

1

Q

These two Assignments of Mortgage, did

49

2 Mr. Stitzel indicate to you why Abraham Shakespeare was

3 assigning these mortgages to American Medical

4 Professionals?

5

6

7

A

No.

Q

Okay.

A

No.

And if you'll notice on all of the

8 newer Assignments that was done by, I'm not, if it's

9 Howard I really don't think so, because all the new

10 Assignments it was basically my assignment because I

11 did this first one, I did it and but she added stuff

12

13

14

15

right here.

Q

Who did?

A

Deedee.

And she always has it returned

to Deedee Moore so that tells me one thing.

When you

16 take a document to the Clerk's Office for recording,

17 they return it to whoever prepared it unless whoever

18 there drops it off says, "I want it returned to me," so

19 she had to drop these off at the Clerk's Office.

20

21

22

23

That's why it's returned.

You see this return?

Q

Uh-huh.

A

That's the Clerk's return thing.

Q

The handwritten "R" next to the name

24 Deedee Moore, Post Office Box 433?

25

Yes.

It is customary when an attorney

~C(r3

A

MTT T C'" T'l 'l.'tT"\,.....'I"""\rT"I...,... ......... - -- - ---

10

1

But, like he didn't get, like, where the ,aoo'1

prepares something it always goes back to the attorney

2

because we have to make copies for our files and then

3

we mail the original deeds and such back to the client.

4

But we have to have that to finish up our files.

5

Q

Now, you indicated that insofar as the

6 divorce documents there were times that day when you

7 went out and spoke with Deedee Moore to obtain

8 information from her; is that correct?

9

A

Yes.

Q

Do you remember what type of information

11 you were getting from her?

12

13

14

15

A

Howard come in, he had the date of

marriage.

I'm just trying to go over in my head that

day.

And I don't know, I'm -- I've got one of these

minds where I remember stuff.

It's crazy.

I swim in

16 divorces all night long.

50

17 When he corne in he had the standard stuff

18 which every attorney -- and it just, it was kind of a

19 joke to me at the time because what he got is very

20 common of the information Mr. Buzbee gets in a call, in

21 a meeting, and then the client always has to corne back

22 to my office because there's always the pieces that

23

they never get.

That's why it was a joke to me at the

24 time and I was thinking typical attorney.

25

1 2 3

child was born.

51 You have to have the county and state

in which the child was born.

You have to have the

child's Social Security, which he didn't have.

And

4 that was one of the pieces he went back to the car to 5 get he didn't get. So you'll notice on the child's

6 Social Security number it says "To be produced."

7 It was on -- he had where, I don't think

8

he got where they

okay.

You have to also put the

9 county where they separated, like if it was in the -- 10 you have to put, because our county is a big county and 11 it's split by 301, we have to put, if they were

12

separated in the East Division of a county you have to

13 put that it was in the East Division so this judge can

15 that. 16

14

handle it.

So I had to go ask that, little things like

Okay.

Did you have to ask Ms. Moore any

Q

17 questions to complete the documents entitled like 18 Quitclaim Deeds or Assignments of Mortgage?

19

No.

She left at some point and was in a

A

20 car because he had to call her for his, "his" meaning 21 the husband's, address.

22 23

Q

Okay.

Did you have any other type of

conversation at all that day with Ms. Moore other than

24 what we've talked about?

25

A

No.

No.

MTT_T C D'LITlr\nm...-'JI.Tr"I r"I"'''T'TT'''\.

1

about him was simply when I called Lori Collins about

MR. PRUNER:

Mr. Delisle, I think I

2

interrupted you.

3

MR. DELISLE:

No.

4 BY MR. PRUNER (resuming):

5

Q

Have you spoken with Mr. Stitzel since

6 February 11th about these several documents that you

7 prepared for him on February 11th?

8

A

No.

9

Q

How about Deedee Moore, have you ever

10 have a conversation with Deedee Moore since that day?

11

12

13

A

No.

I've never personally had one

outside of Howard with her, never.

Q

Did you ever have any conversation with

14 Abraham Shakespeare about any of these transactions?

19

20

21

22

23

A
Q
A
Q
with him?
A
Q
A 16 Have you ever met him?

18 Have you ever had a conversation at all

No.

Okay.

The only conversation I've ever had even

24 the documents to, because of Howard, the way things

25 were that day, and that we had done documents for him

XU

52

1

wasn't that popular.

She's like, "I am not giving all

for Abraham and Deedee.

That was it.

2

Q

On any other date do you recall ever

3 preparing any type of document for Mr. Stitzel

4 pertaining to American Medical Professionals, LLC that

5 you can recall?

6

A

I don't believe so, but we'd have to look

7 back at my computer.

8

I see.

On any other date did you ever

Q

9 have any conversations with Mr. Stitzel about Deedee

10 Moore?

11

12

A

No.

The only other conversations I've

had period is -- and her name is one of those weird

13 names and she actually turns out she went to school

14

with my sister-in-law.

Well, when she got the big

15 house in Lakeland, she actually called my cousin

53

16 because they all went to school together, and it was we

17 were all sitting around kind of joking is what it was,

18 because she called and wanted everybody's phone numbers

19 and addresses because she wanted to do a reunion party

20 at her house since she got the big house.

21

And I remember my cousin was like, "She's

22 crazy if she thinks," because I guess in school she

23

24 these addresses out to that crazy woman." And then

25 months later it was like, whoa, when we heard her name

;;;20/?-.

1

Q

Did you know Johnnie L. or Joyce V.

;Q{3

again on the radio.

2

Sure.

On any conversation did

Q

3 Mr. Stitzel ever describe his relationship with

4 Mr. Shakespeare or anything else about Mr. Shakespeare?

5

A

No, never.

6

Q

Okay.

7

A

I didn't know he had represented Abraham

before.

I knew, like I said, I knew he was doing work

8

with Deedee, that's why I didn't see no conflict.

If,

9

10 because had I known he had done work for Abraham

11 before, well, we know we can't do paperwork, it's a

12

13

14

15

conflict unless you get a conflict letter.

Q

I gotcha.

Conflict of interest?

A

Yeah.

Q

Okay.

Does the name Judith Haggins mean

16 anything to you?

17

18

19

20

21

22

23

A

Haggins?

Q

H-a-g-g-i-n-s?

A

No.

Q

Okay.

A

Regans is one of the assignments I done.

Q

Right.

A

And that name is just one of those really

24 weird names that you won't forget.

25

54

1

2

Regans?

A

No, because -- well, the reason why,

3 after it was over Mr. Buzbee said that name sounded

4 really familiar to him and he thought we had done some

5

work for Regans.

So we had to search our files to make

6 sure that I didn't create a conflict in our office.

7

Q

Okay. And I'm looking at the other

8 Assignment, did you know Deborah J. or Ronald J.

9 Knight?

10

11

12

A

No.

MR. PRUNER:

Mr. Delisle, anything else?

MR. DELISLE:

Yeah, just one thing.

13 FURTHER EXAMINATION

14 BY MR. DELISLE:

15

Q

Prior to doing these documents for

55

16 Howard, had you ever prepared documents for him before?

17

18

A

Yes.

Q

Had he ever asked you to alter those

19 documents in the way that you were altering these?

20

A

No.

21 FURTHER EXAMINATION

22 BY MR. PRUNER:

23

24

Q

And again

A

If I -- the stuff that we had done before

25 it was all just very simple, it was never to this

NIL!

1\If'T'"T T"'" T""II.oy-(T""II._T""II. ....... __ ... _ -- ----

10

1

Q

Okay.

I don't know if I asked you this

degree.

The only reason it was to this degree was

because he did not have a law office.

And I knew the

2

3 situation and he -- I feel sorry for the man.

4

Like I said, I respected him as an

5 attorney as far as when he was on his game he was on

his game.

He's a very smart man.

Wording, like

6

Mr. Buzbee is good at grammar things.

7

If you ever have

8

a grammar question Mr. Buzbee's the man.

Like if I had

9 a question and Mr. Buzbee was in court about something

that was a legal wording, I'd call Howard.

Howard was

11 good at it .

12

13

I mean, and I just respected Howard and

that.

So when he come to me needing all this work and

56

14 he was telling me that this is his, this is his, to get

15 back on his feet and he was going to get his law office

16

back and he was going to show Johnnie Byrd.

And this

17 is just a personal thing of how I feel about Johnnie

18 Byrd is I just felt like Johnnie took advantage of

19 Howard and took business from Howard.

20 I felt that that was Howard's law office.

21

It was Howard's law office before.

I'm sorry, but I

22 just, you know, so that's why when Howard come to me I

23

24

did it, you know.

25 about these two Assignments of Mortgage, but were you

,~OJS

MTT T C'I T'lT:'1T"\r"\T""torT1"T"'II.T"'" _T"'t._ ....... ._

1

57 individually compensated or was the Law Offices of Jim

2 Buzbee compensated for the preparation of these?

3 4 5

A Q A

No, nothing. Okay.

We gave, actually gave him five dollars

6 and Mr. Buzbee had to give me the five dollars back.

7

8 day? 9

Q

Do you know how Howard Stitzel left that

No, I don't know how he left.

But I do

A

10 know he came, he came back later or either I seen him 11 later that day or something because he was in his

12

Camry, his gold Camry that he drove.

He come back in

13 that, which he came back several times after this just, 14 just talking.

15 16

felt bad.

I mean, he stopped in several times.

After this happened there was a tift or

17 whatever and between him and Mr. Buzbee, and that's 18 when we were told to absolutely do no more work for 19 him.

20 But he had called several times for like

21

numbers and stuff and I just told him.

So he come back

22 to talk to Mr. Buzbee because he realized that there

23

was something that he needed to talk to him about.

24 was a personal --

25

Q

Sure.

MTT T C" Dt:::"IT'\r'\T"lrnT'II.T""" _T""Io_","'T"">..

He

It

1 2

A

-- tift.

Kind of an ending question, is there

Q

3 anything you've stated today that you'd like to

4 clarify, add to, correct, delete, modify, or whatever 5 adjective you want?

6

A

No.

I just want to make it clear that,

7 yes--

8 9

Q A

Yes.

-- the documents were done on February

10 11th but they were all unexecuted when they left here.

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

(The sworn statement was concluded at 11:04 a.m.)

MR. PRUNER: Okay.

Thanks for your

cooperation today.

THE WITNESS:

I appreciate it.

Thank you.

58

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

1

CERTIFICATE OF OATH

2

STATE OF FLORIDA

3

COUNTY OF HILLSBOROUGH

4

I, the undersigned authority, certify that APRIL

5

R. TAYLOR personally appeared before me on February 8,

6

2010, and was duly sworn.

7

WITNESS my hand and official seal this 22nd day

of February, 2010.

8

.

C:;L. d 1,. V. O'n~ ----~~~~------------------

9

RALPH D. MILLS, CVR, CP

Notary Public, State of Florida

Commission No. DD659841

Expires: May 2, 2011

59

2

1

CERTIFICATE OF REPORTER

STATE OF FLORIDA

3

COUNTY OF HILLSBOROUGH

4

I, RALPH D. MILLS, CVR, CP, certify that

5

I was authorized to and did report the foregoing sworn

6

statement of APRIL R. TAYLOR, and that the transcript

7

is a true and complete record of my stenomask notes

8

thereof.

9

I further certify that I am not a

10 relative, employee, attorney, or counsel of any of the

11 parties, nor am I a relative or employee of any of the

12

13

14

15

16

17

18

19

20

21

22

23

24

25

parties' attorney or counsel connected with the action,

nor am I financially interested in the action.

DATED this 22nd day of February, 2010.

a~ l:L-rnLtr

------- -------------------

RALPH D. MILLS, CVR, CP

1\ATT T (""1 T""'IT-::'1T""1I""'\.~rT'1.,_ ... T __ ...... _ .............

60

IN THE CIRCUIT COURT OF THE THIRTEENTH mDICIAL CIRCUIT, IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

Case No.: ==-20~0~9:._-D=R,--- _

Division: !=:E~as::.!:t/~R~ _

IN RE THE MARRIAGE OF:

DORICE D. MOORE, Wife,

and

JAMES D. MOORE, Husband

NOTICE OF HEARING

PLEASE TAKE NOTICE that on March 11,2009, at 9:00 a.m., or as soon thereafter as counsel can be heard, Wife's Petition for Dissolution of Marriage will be heard in the above referenced case, before the Honorable Susan Sexton, in Chambers at the Hillsborough County Courthouse, 302 N. Michigan Avenue, Courtroom P-2, Plant City, Florida. Five (5) minutes have been reserved for this hearing .

PLEASE GOVERN YOURSELF ACCORDINGLY

Respectfully submitted,

By: _

D. Howard Stitzel, III, Esquire Florida Bar No. 818674

4205 West Keysville Road Plant City, Florida 33567

Tel. (813) 495-8400

Attorney for Wife

CERTIFICATE OF SERVICE

I certify that a copy of this document was hand delivery to the person listed below on February __ , 2009.

James D. Moore

Via hand delivery with petition

D. Howard Stitzel, III, Esquire Attorney for Wife

nWIRlTNo_..L

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT, IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

Case No.: =20,,-,0=9---,-D=R,-- _

Division: ~E=a=st:...:/R=- _

IN RE THE MARRIAGE OF:

DORICE D. MOORE, Wife,

and

JAMES D. MOORE, Husband

JOINT STIPULATION FOR WAIVER OF MANDATORY DISCLOSURE

The parties file this Joint Stipulation for Waiver of Mandatory Disclosure and agree to waive mandatory disclosure of the following:

1. Any and all financial affidavits required pursuant to Florida Statutes §6l.et. seq. and

• the Florida Family Law Rules of Civil Procedure.

2. Rule 12.285( d)(2): All federal and state income tax returns, gift tax returns, and

intangible personal property tax returns filed for the past 3 years.

3. Rule 12.285(d)(3): IRS forms W-2, 1099, andK-l for the past year, ifthe income tax

return for that year has not been prepared.

4. Rule 12.285(d)(4): Pay stubs or other evidence of earned income for the 3 months

prior to service of the financial affidavit.

5. Rule 12.285(d)(5): A statement identifying the amount and source of all income

received from any source during the 3 months preceding the service of the financial affidavit required by this rule if not reflected on the pay stubs produced.

6. Rule 12.285(d)(6): All loan applications and financial statements prepared or used

within the 12 months preceding service of the financial affidavit required by this rule, whether for the purpose of obtaining or attempting to obtain credit or for any other purpose.

7. Rule 12.285(d)(7): All deeds within the last 3 years, all promissory notes within the

last 12 months, and all present leases, in which the party owns or owned an interest, whether held in the party's name individually, in the party's name jointly with any other person or entity, in the party's name as trustee or guardian for any other person, or in someone else's name on the party's behalf.

8. Rule 12.285(d)(8): All periodic statements from the last 3 months for all checking

accounts, and from the last 12 months for all other accounts (for example, savings accounts, money

market funds, certificates of deposit, etc.), regardless of whether or not the account has been closed, including those held in the party's name individually, in the party's name jointly with any other person or entity, in the party's name as trustee or guardian for any other person, or in someone else's name on the party's behalf.

9. Rule 12.285( d)(9): All brokerage account statements in which either party to this

action held within the last 12 months or holds an interest including those held in the party's name individually, in the party's name jointly with any person or entity, in the party's name as trustee or guardian for any other person, or in someone else's name on the party's behalf.

10. Rule 12.285( d)(10): The most recent statement for any profit sharing, retirement,

deferred compensation, or pension plan (for example, IRA, 401(k), 403(b), SEP, KEOGH, or other similar account) in which the party is a participant or alternate payee and the summary plan description for any retirement, profit sharing, or pension plan in which the party is a participant or an alternate payee.

11. Rule 12.285(d)(1l): The declarations page, the last periodic statement, and the

certificate for all life insurance policies insuring the party's life or the life of the party's spouse, whether group insurance or otherwise, and all current health and dental insurance cards covering either of the parties and/or their dependent children .

12. Rule 12.285(d)(12): Corporate, partnership, and trust tax returns for the last 3 tax

years if the party has an ownership or interest in a corporation, partnership or trust greater than or equal to 30%.

13. Rule 12.285( d)(13): All promissory notes for the last 12 months, all credit card and

charge account statements and other records showing the party's indebtedness as of the date of the filing ofthis action and for the last 3 months, and all present lease agreements, whether owed in the party's name individually, in the party's name jointly with any other person or entity, in the party's name as trustee or guardian for any other person, or in someone else's name on the party's behalf.

14. Rule 12.285( d)(14): All written premarital or marital agreements entered into at any

time between the parties to this marriage, whether before or during the marriage.

15. Rule 12.285( d)(15): All documents and tangible evidence supporting any claim that

an asset or liability is nonmarital, for enhancement or appreciation ofnonmarital property, or for an unequal distribution of marital property.

16. Rule 12.285(d)(16): Any court orders directing the party to pay or receive spousal or

child support .

James D. Moore

3443 South Forbes Rd Dover, Florida 33527

Dorice D. Moore 3447 South Forbes Rd Dover, Florida 33527

I. CASE STYLE

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT, IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

IN RE THE MARRIAGE OF:

Case No.: =c20~0~9:_-D~R,-- _

Division: =E~as~t/C..!.R~ _

DORICE D. MOORE, Wife,

and

JAMES D. MOORE, Husband

Judge: Susan Sexton

II. TYPE OF CASE (Place an x in one box only. Ifthe case fits more than one type of case, select the most definitive.)

Domestic Relations Torts Other Civil

_ Simplified dissolution X Dissolution

_ Professional malpractice Contracts

_ Products liability Condominium

_ Auto negligence _ Real property/

_ Other negligence mortgage foreclosure Eminent domain

_ Support - IV-D

_ Support - Non IV-D UIFSA - IV-D UIFSA - Non IV-D

_ Challenge to proposed constitutional amendment

Domestic violence

Other

Other domestic relations

III. IS JURY TRIAL DEMANDED IN COMPLAINT?

Yes XNo

DATE: February ,2009

--

SIGNATURE OF ATTORNEY FOR PARTY INITIA TING ACTION

IN THE CIRCUIT COURT OF THE THIRTEENTH mDICIAL CIRCUIT, IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

Case No.: 2=-0,,-,0,,-,,9_;-D==R,-- _

Division: =:EC!:!:as;!!t/i..!R~ _

IN RE THE MARRIAGE OF:

DORICE D. MOORE, Wife,

and

JAMES D. MOORE, Husband

ANSWER AND WAIVER

JAMES D. MOORE, Respondent, answers the Petition filed herein and states as follows:

1. The parties have amicably settled their differences and have executed a Marital

Settlement Agreement and Respondent requests that said Agreement be made a part of any Final Judgment of Dissolution of Marriage entered in this cause.

2. Respondent neither admits nor denies any of the allegations of the Petition filed

herein, but does not desire to interpose any further defense to same.

3. This matter should proceed ex-parte to Final Judgment.

4. Respondent grants to Petitioner the right to proceed in this cause to Final

Judgment upon approval by the undersigned of any final order to be submitted to the court and waives any time periods for setting the action for trial or for entry of a Final Judgment.

James D. Moore, Respondent 3443 South Forbes Rd Dover, Florida, 33527

CERTIFICATE OF SERVICE

I certify that a copy of this document was mailed to D. Howard Stitzel, III, Esquire on February 11, 2009 .

James D. Moore, Respondent

IN THE CIRCUIT COURT OF THE THIRTEENTH mDICIAL CIRCUIT, IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

Case No.: =20~0=9,--,-D=R,-- _

Division: ""E=as=tlC"'-R""-- _

IN RE THE MARRIAGE OF:

DORICE D. MOORE, Wife,

and

JAMES D. MOORE, Husband

UNIFORM CHILD CUSTODY JURISDICTION AND ENFORCEMENT ACT (UCCJEA) AFFIDAVIT

I, Dorice D. Moore, being sworn, certify that the following statements are true:

1. The number of minor children subject to this proceeding is one. The name, place of birth, birth date, and sex of this child; the present address, periods of residence, and places where this child has lived within the past five (5) years; and the name, present address, and relationship to the child of each person with whom the child has lived during that time is:

THE FOLLOWING INFORMATION IS TRUE ABOUT CHILD #1:

Child's Full Legal Name: Robert James Moore

Place of Birth: Brandon, Hillsborough Date of Birth: 1113/1995 County, Florida

Sex: Male

Robert James Moore's Residence for the past 5 years:

Dates Address (including city and Name and present address

(From/to) state) where child lived of person child lived with

Relationship to child

111/2004- Present

Dorice D. Moore 3447 S. Forbes Rd Dover, Florida 33527

Mother

3447 S. Forbes Rd Dover, Florida 33527

2. Participation in custody proceedings:

I HA VE NOT participated as a party, witness, or in any capacity in any other litigation or custody proceeding in this or any other state, concerning custody of a child subject to this proceeding.

3. Information about custody proceedings:

I HA VE NO INFORMATION about any custody proceeding pending in a court of this or any other state concerning a child subject to this proceeding.

4. Persons not a party to this proceeding:

I DO NOT KNOW OF ANY PERSON not a party to this proceeding who has physical custody or claims to have custody or visitation rights with respect to any child subject to this proceeding.

5. Knowledge of prior child support proceedings:

The child described in this affidavit is NOT subject to existing child support orders in this or any state or territory .

6.

I acknowledge that I have a continuing duty to advise this Court of any custody, visitation, child support, or guardianship proceeding (including dissolution of marriage, separate maintenance, child neglect, or dependency) concerning the child in this state or any other state about which information is obtained during this proceeding.

I understand that I am swearing or affirming under oath to the truthfulness of the claims made in this affidavit and that the punishment for knowingly making a false statement includes fines and/or imprisonment.

Dated:

---------------------------------

Dorice D. Moore 3447 S. Forbes Rd Dover, Florida 33527 Ph.: 813-495-8400

STATE OF FLORIDA

COUNTY OF HILLSBOROUGH

Sworn to or affirmed and signed before me on by Dorice D. Moore.

NOTARY PUBLIC or DEPUTY CLERK

[Print, type or stamp commissioned name of notary or clerk]

Personally known Produced identification

Type of identification produced _

IN THE CIRCUIT COURT OF THE THIRTEENTH mDICIAL CIRCUIT, IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

Case No.: ::.20"'-'0:<.::9:._-D=R'--- _

Division: =E""'a"'-'stl"-'R=-- _

IN RE THE MARRIAGE OF:

DORICE D. MOORE, Wife,

and

JAMES D. MOORE, Husband

NOTICE OF SOCIAL SECURITY NUMBER

I, Dorice D. Moore, Wife, certify that my social security number will be produced at hearing.

This notice is being filed in a dissolution of marriage case in which the parties have a minor child in common. The minor child's name, date of birth, and social security number are:

Name: Robert James Moore Birth date: January 13, 1995

Social Security Number: To be produced

Disclosure of social security numbers shall be limited to the purpose of administration of the Title IV -D program for child support enforcement.

I understand that I am swearing or affirming under oath to the truthfulness of the claims made in this notice and that the punishment for knowingly making a false statement includes fines and/or imprisonment.

Dated: February 11, 2009

Dorice D. Moore Wife

3447 S. Forbes Rd. Dover, Florida 33527

STATE OF FLORIDA

)

COUNTY OF HILLSBOROUGH

) )

SWORN TO AND SUBSCRIBED before me, this __ day of February, 2009, by Wife, Dorice D. Moore, who is personally known to me or who has produced a Florida driver's license as identification.

NOTARY PUBLIC

Respectfully submitted,

By: _

D. Howard Stitzel, III, Esquire Florida Bar No. 818674

4205 West Keysville Rd

Plant City, Florida 33567

Tel. (813) 495-8400

Attorney for Wife

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT, IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

Case No.: =20"'-'0=9----'-D=R'-- _

Division: East/R

==~~-------------------

IN RE THE MARRIAGE OF:

DORICE D. MOORE, Wife,

and

JAMES D. MOORE, Husband

PETITION FOR DISSOLUTION OF MARRIAGE

Wife, DORICE D. MOORE, by and through the undersigned attorney, files this Petition for Dissolution of Marriage and states as follows:

1. This is an action for dissolution of the bonds of marriage between the parties in the

above-styled cause, specifically Petitioner, Dorice D. Moore, hereinafter called "Wife," and Respondent, James D. Moore, hereinafter called "Husband." .

2. The parties have been residents of Florida for more than six (6) months prior to the

filing of this Petition.

3. The parties were married to each other on May 1, 1992, at Plant City, Hillsborough

County, Florida, and have cohabited together as husband and wife until their final separation on or about January 13, 2008.

4. The marriage of the parties is irretrievably broken.

5. The minor child common to both parties is:

Name: Robert James Moore

Place of Birth: Brandon, Hillsborough County, Florida Birth date: January 13, 1995

Sex: Male

6. The parties anticipate entering into a Marital Settlement Agreement which will

resolve all issues, including parental responsibility, support and a division of assets and liabilities.

7. Both parties are over the age of eighteen (18) years and neither is, nor within a period

of thirty (30) days immediately prior to this date has been, enlisted in the military service of the

United States as defined by the Servicemembers Civil Relief Act of 2003.

WHEREFORE, Wife, DORICE D. MOORE, respectfully requests that this Honorable Court:

A. Dissolve the marriage of the parties; and

B. Ratify the Marital Settlement Agreement between the parties and incorporate its terms

into any Final Judgment entered herein.

Dorice D. Moore Wife

STATE OF FLORIDA )

)

COUNTY OF HILLSBOROUGH )

• SWORN TO AND SUBSCRIBED before me, this _ day of February, 2009, by Wife,

DORICE D. MOORE, who is personally known to me or who has produced a Florida driver's license as identification.

NOTARY PUBLIC

Respectfully submitted,

By: _

D. Howard Stitzel, III, Esquire

Florida Bar No. 818674

4205 West Keysville Rd

Plant City, Florida 33567

Tel. (813) 495-8400

Attorney for Wife

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT, IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

Case No.: =o..20~O~9;__c-D=R,-- _

Division: =E"",a~st,,-,,/R~ _

IN RE THE MARRIAGE OF:

DORICE D. MOORE, Wife,

and

JAMES D. MOORE, Husband

MARITAL SETTLEMENT AGREEMENT

This Agreement is made in connection with an action for dissolution to be filed between James D. Moore, referred to as "Husband" and as "Father" herein, and Dorice D. Moore, referred to as "Wife" and as "Mother" herein, who are sworn and agree as follows:

WHEREAS, the parties hereto were married to each other on or about May 1, 1992, in Plant City, Hillsborough County, Florida;

WHEREAS, the following child involved in this action has been born to or adopted by the parties:

Name

Robert James Moore

Date of Birth January 13, 1995

WHEREAS, no other children were adopted, and none are expected;

WHEREAS, Wife expects to file a petition for dissolution ofmarriage, and this Agreement is intended to be introduced into evidence in such action, to be incorporated in a Final Judgment entered therein;

WHEREAS, the parties acknowledge that irreconcilable differences exist, that the marriage is irretrievably broken, and that the parties intend to live separate and apart from each other;

WHEREAS, the parties wish to settle between themselves, now and forever, their respective rights, duties, and obligations regarding property, liabilities, and child;

WHEREAS, each party has read this Agreement and understands its terms and consequences, and each party believes that this Agreement is fair, just, and reasonable, and in the best interest of the child;

WHEREAS, each party has assented to this Agreement freely and voluntarily, without coercion or duress;

NOW, THEREFORE, in consideration of the mutual covenants, promises and undertakings set forth herein, and for other good and valuable consideration, the parties have agreed and do hereby agree as follows:

ARTICLE I PARENTING PLAN

1.1 The parties agree that the provisions contained in this Marital Settlement Agreement,

including the Time-Sharing Schedule constitute a Parenting Plan intended to govern the relationship between the parties relating to the decisions to be made regarding the child.

ARTICLE II JURISDICTIONAL ISSUES

2.1 The Thirteenth Judicial Circuit in Hillsborough County, Florida has continuing

jurisdiction over the child pursuant to the applicable Florida Statutes and the Uniform Child Custody Jurisdiction and Enforcement Act.

2.2 Florida is the home state and the state of habitual residence of the child. Accordingly,

Florida is the sole jurisdictional state to determine child custody, parental responsibility, timesharing, rights of custody, and rights of access concerning the child under the Parental Kidnapping Prevention Act (PKP A), under the International Child Abduction Remedies Act (ICARA), and under the Convention on the Civil Aspects of International Child Abduction enacted at The Hague on October 25, 1980.

ARTICLE III PARENTAL RESPONSIBILITY

3.1 Each party recognizes the deep love, devotion, and dedication of the other to the

child. Each party also recognizes that the other has a right and responsibility to participate in major matters relating to the education, health, welfare, and upbringing of the child. The parties agree to use their best efforts to cooperate in such matters, and that any rights, duties or responsibilities set forth herein shall not be exercised to frustrate or control the other parent.

3.2 Father and Mother shall have shared parental responsibility and shall retain full

parental rights and responsibilities with respect to the child.

3.3 Father and Mother shall consult and reasonably cooperate with each other, and share

the decision-making responsibility regarding the following general areas: (a) education; (b) camp and extracurricular activities; ( c) college, vocational or other post-secondary education; (d) medical,

dental and surgical treatment; and (e) psychological or psychiatric evaluation or treatment.

3.4 Each parent shall have the following specific rights and/or duties with respect to the

child:

(a) the right to receive information from the other parent concerning the health,

education, and welfare of the child;

(b) the duty to inform the other parent in a timely manner of significant

information concerning the health, education, and welfare of the child;

( c) the right to consult with school officials concerning the child's welfare and

educational status, including school activities;

(d) the right to attend school activities;

(e) the right to be designated on the child's records as a person to be notified in

case of an emergency;

(f) the right of access to medical, dental, psychiatric, psychological, and

educational records of the child;

(g) the right to consult with a physician, dentist, psychiatrist, psychologist, or

other health care provider of the child; and

(h) the right to consent for the child to medical, dental, and surgical treatment

during an emergency involving immediate danger to the health and safety of the child.

ARTICLE IV TIME-SHARING SCHEDULE

4.1 The parties agree that it is in the best interest of the child for both parties to have

frequent and continuing contact with the child, and the parties shall spend time with the child at times they have mutually agreed to in advance. If the parties cannot agree then they shall rotate custody of the minor child on a weekly basis commencing Sunday evening at 6:00 p.m. and continuing until to following Sunday at 6:00 p.m.

ARTICLE V

GENERAL PROVISIONS RELATING TO THE CHILD

5.1 Communication with Child. Any parent shall be entitled to reasonable contact with

the child by regular or cellular telephone, and the other parent will exercise reasonable efforts to make the child available for such telephone contact.

5.2 Relocation of Child. It is acknowledged that in the event that a parent seeks to

relocate the principal residence of the child subject to this order more than 50 miles away from the

current residence as provided by Section 61.1300 I ofthe Florida Statutes, such parent shall comply with the provisions of Section 61.13001 by either (a) obtaining written agreement in accordance with 61.13001(2) of the Florida Statutes from the other parent, and any other person entitled to time-sharing, or (b) serving a Notice ofIntent to Relocate signed under oath and penalty of perjury in accordance with Section 61.13001(3) of the Florida Statutes, giving the other parent, and any other person entitled to time-sharing, 30 days to object to the relocation and to request a determination by the Court.

5.3 Warning. IF A PARENT ATTEMPTS TO RELOCATE THE PRINCIPAL

RESIDENCE OF THE CHILD AND FAILS TO COMPLY WITH SECTION 61.13001(3) OF THE FLORIDA STATUTES REGARDING THE NOTICE OF INTENT TO RELOCATE, SUCH PARENT MAYBE SUBJECT TO CONTEMPT AND OTHER PROCEEDINGS TO COMPEL THE RETURN OF THE CHILD, AND SUCH NON-COMPLIANCE MAYBE TAKEN INTO ACCOUNT BY THE COURT IN A SUBSEQUENT DETERMINATION OF THE PARENTING PLAN OR THE TIME-SHARING SCHEDULE, OR BOTH.

5.4 Notice of Parent's Relocation or Change of Residence. Either parent must give prior

written notice at least thirty (30) days before the day that he or she is to relocate or change residence (regardless of whether the residence ofthe child will change). Such notice must be made to the other parent by certified mail, return receipt requested, and must include the new address.

ARTICLE VI CHILD SUPPORT

Child Support

6.1 The parties agree that it is in the best interest of the minor child and in light of the

time sharing plan agreed to no child support shall be payable by either party to the other party at this time.

Uncovered Health Care Expenses

6.2 "Uncovered Health Care Expenses" means all ordinary, reasonable and necessary

expenses not covered by insurance and incurred for medical, health, dental, psychological or psychiatric care on behalf of the child who is the subject ofthis agreement, including but not limited to hospitalization, prescriptions, physicians, dentists, orthodontics (including braces), contact lenses and eyeglasses, examinations, and insurance copayments, and which are incurred while either party has a legal duty to support such child.

6.3 Uncovered Health Care Expenses shall be divided by the parties as follows: Father

shall pay fifty percent (50%), and Mother shall pay fifty percent (50%). A party who pays for an Uncovered Heath Care Expense or receives notice of the same shall submit to the other party proof of payment or such notice within fifteen (15) days of payment or receipt of notice. Within fifteen (15) days after the other party receives such notification, the other party shall reimburse the paying party or pay the billing party directly for his or her share of the expense, as applicable.

ARTICLE VII RETIREMENT

7.1 Each party shall receive any and all benefits existing by reason of his or her past,

present, or future employment or military service, including but not limited to any profit-sharing plan, retirement plan, Keogh plan, pension plan, employee stock option plan, 40 I (k) plan, employee savings plan, military retired pay, accrued unpaid bonuses, or disability plan, whether matured or unmatured, accrued or unaccrued, vested or otherwise, together with all increases thereof, the proceeds therefrom and any other rights related thereto. The other party hereby waives and releases any and all claims or interest therein.

ARTICLE VIII

DIVISION OF OTHER ASSETS AND LIABILITIES

Division of Other Assets

8.1 The parties have already divided all marital property in an agreeable and satisfactory

manner prior to the execution of this Agreement. Each party shall have exclusive ownership in all items of property that are currently in his or her possession or control, and the other party waives and releases any and all claim or interest in such items .

Division of Liabilities

8.2 Any obligation or liability that is not listed herein shall be the responsibility of the

party that incurred the same, and the party that incurred the same shall indemnify the other party and the property of the other party harmless from liability therefor.

8.3 N either party shall hereafter incur any obligation or liability for which the other party

will be liable.

General Provisions

8.4 Other Information or Instruments. Each party agrees to provide to the other party any

necessary information or to execute and/or deliver any instrument or document necessary to transfer title or interest in property consistent with this Agreement.

8.5 Nondischargeable in Bankruptcy. All terms of this Agreement pertaining to the

division of marital property, including but not limited to any hold harmless or indemnification provisions, are specifically intended by the parties to be nondischargeable in the event ofbankruptcy.

ARTICLE IX NO ALIMONY

9.1

Both parties waive any claim for alimony, whether temporary, "bridge-the gap,"

rehabilitative, permanent, or lump sum. No provision of this Agreement should be construed as payment of alimony by either party.

ARTICLE X TAX ISSUES

Dependency Exemption for Tax Years Subsequent to 2009

10.1 The dependency exemption for dependents for tax years subsequent to the dissolution of the marriage shall be claimed by Wife.

ARTICLE XI

COURT COSTS AND ATTORNEY'S FEES

11.1 Any costs of court, including the filing fee for the petition for dissolution, will be borne by the party incurring the same.

11.2 Each party will be responsible for his or her own attorney's fees incurred herein.

ARTICLE XII GENERAL PROVISIONS

12.1 Written Notice of Change ofInformation. Any parent shall give written notice to the other party by registered or certified mail of any intended change in the following information: (a) name, (b) marital status, (c) residence address, (d) mailing address, (e) home telephone number, (f) name of employer, (g) address of employment, or (h) work telephone number. Such written notice must be provided no later than thirty (30) days before a change of any of the foregoing information; provided, however, if the party does not know or could not have known of the change in sufficient time to provide such prior notice, the party shall provide written notice ofthe change on or before the fifth day after the date that the party knew of the change.

12.2 Mutual Release. Each party waives, releases and relinquishes any actual or potential right, claim or cause of action against the other party, including but not limited to asserting a claim against the estate of the other party or to act as a personal representative of such estate, except as otherwise provided for in this Agreement or arising hereunder.

12.3 Resolution of Future Disputes. In the event of any disagreement regarding an issue between the parties, the parties shall first confer and exercise reasonable efforts to resolve such a dispute. Except in an emergency, before a party files legal action regarding an issue of any such dispute or regarding modification of any terms and conditions of this Agreement, that party shall make a good faith attempt to submit the dispute or controversy to mediation.

12.4 Reconciliation. In the event of a reconciliation or resumption of marital relations, this Agreement or its provisions shall not be abrogated in any way without further written agreement of the parties.

12.5 No Oral Agreements. The parties agree that this Agreement constitutes the entire agreement of the parties, that this Agreement supersedes any prior understandings or agreements between them, and that there are no representations, warranties, or oral agreements other than those expressly set forth herein.

12.6 No Waiver of Breach. The failure of a party to insist on strict performance of any provision of this Agreement shall not be construed to constitute a waiver of a breach of any other provision or of a subsequent breach of the same provision.

12.7 Severability. This Agreement is severable, and if any term or provision is determined to be unenforceable, this shall not render the remainder of the Agreement unenforceable.

12.8 Other Acts. Each party agrees to timely perform such other acts that are reasonably necessary or that may be reasonably requested by the other party to effectuate the provisions ofthis Agreement.

12.9 Survival of Agreement; No Merger. This Agreement may be offered into evidence by either party in an action for dissolution of marriage, and may be incorporated by reference in a final judgment entered therein. Notwithstanding incorporation, this Agreement shall not be merged in such judgment but shall survive the judgment and be binding on the parties .

12.10 Remedies for Enforcement. The terms and provisions of this Agreement are enforceable in contract, in addition to any remedies for enforcement that may also be available under any final judgment of dissolution of marriage entered between the parties.

I, DORICE D. MOORE, certify that I have been open and honest in entering into this Agreement. I am satisfied with this Agreement and intend to be bound by it.

Dated: February 11,2009

DORICE D. MOORE

STATE OF FLORIDA

COUNTY OF HILLSBOROUGH

Sworn to or affirmed and subscribed before me on by DORICE D .

MOORE.

NOTARY PUBLIC - STATE OF FLORIDA

Printed Name of Notary

Personally known Produced identification

Type of identification produced _

I, JAMES D. MOORE, certify that I have been open and honest in entering into this Agreement. I am satisfied with this Agreement and intend to be bound by it.

Dated: February 11, 2009

JAMES D. MOORE

STATE OF FLORIDA

COUNTY OF HILLSBOROUGH

Sworn to or affirmed and subscribed before me on by

JAMES D. MOORE.

NOTARY PUBLIC - STATE OF FLORIDA

Printed Name of Notary

Personally known Produced identification

Type of identification produced _

February 11, 2009

James D. Moore

3443 South Forbes Rd Dover, Florida, 33527

Re: Dorice D. Moore v. James D. Moore, Case No. 2009-DR- in the Thirteenth Judicial Circuit, Hillsborough County, Florida

Dear Mr. Moore:

Attached, you will find a Petition for Dissolution Of Marriage, a Marital Settlement Agreement and an Answer And Waiver we have prepared on behalf of your Wife.

It is your Wife's feeling that this matter can be resolved amicably and quickly with minimal cost to both of you. In order to avoid any embarrassment to you we are "serving" these papers via hand delivery by your Wife. It is necessary for you to send an acknowledgment that you accept the service or to have an attorney do so on your behalf. If we do not receive such an acknowledgment from you within two (2) weeks, we will proceed to have you served through the ordinary channels.

We believe the Marital Settlement Agreement is a straightforward and fair settlement of all issues. If you agree with its terms, sign it and the Answer and Waiver and return them to us so that we can have the agreement ratified by the Court. I advise you to have these documents reviewed by an attorney of your choice.

We will be happy to discuss any changes to the agreement you may desire and will expect to hear from you or your attorney shortly.

Sincerely yours,

D. Howard Stitzel, III, Esquire

DHS/art

Enclosures: Petition, Marital Settlement Agreement, Answer And Waiver

This Instrument Prepared by and return to:

Name: D. Howard Stitzel, III 4205 W Keysville Road Plant City, Florida 33567

INSTR # 2009022a~5

BK 07814 PGS 2098-2100 PGCs)3 RECORDED 02/11/2009 03:15:07 PM RICHARD M WEISS, CLERK OF COURT POLK COUNTY

DEED DOC 714.00

RECORDING fEES 27.00

RECORDED BY 1'1 Johnson Property Appraisers Parcel Number(s): 24-28-07-000000-014040

QUITCLAIM DEED

THIS INDENTURE, made this _JL_ day of January, 2009, by and between, Shapkespeare and Associates, LLC, party of the first part, and American Medical Professionals, PEO, LLC, ~ whose post office address is: PO Box 433, Sydney, Florida, of the County of Hillsborough, in the State of Florida, party of the second part.

WITNESSETH: That the said party of the first part, for and in consideration of the sum of Ten ($10.00) Dollars, and other valuable considerations, lawful money of the United States of America, to the party of the first part in hand paid by the said party of the second part, the receipt whereof is hereby acknowledged, has remised, released and quitclaimed to the said party of the second part, its heirs and assigns forever, all the right, title, interest and claim of the said party of the first part in and to the following described land in Polk County, Florida, to wit:

SEE ATTACHED LEGAL DESCRIPTION AS EXHIBIT "A"

SUBJECT TO Covenants, restrictions, easements of record and taxes for the current year. Said property is not the homestead of the Grantor (s) under the laws and Constitution of the State of Florida in that neither Grantor (s) or any members of the household of Grantor (s) reside thereon.

This Deed was prepared based solely on information provided by grantee(s) and no title examination or research was requested or performed,

TO HA VE AND TO HOLD the above described premises, with the appurtenances, unto the said party of the second part, its heirs and assigns forever.

IN WITNESS WHEREOF, the said party of the first part has executed this deed under seal on the date aforesaid.

Signed, sealed and delivered in the presence of:

Shakespeare and Associates, LLC

fJi,rqb!lh? ~/(esoe£..1f

Abraham Lee Shakespeaie, Managing Member 9340 Redhawk Bend Dr

Lakeland, Florida 33810

Witne 0 Granto~~ IJl9fIJ to~

~

Book7814/Page2098

CFN#2009022815

Page 1 of 3 ~Ol{/

STATE OF FLG:rDA

COUNTY OF _ _i3_.__"_,_I.:_((_ _

I HEREBY CERTIFY, That on this day, before me, an officer duly authorized in the State aforesaid and in the County aforesaid to take acknowledgments, personally appeared Abraham Lee Shakespeare to me known to be the person described in and who executed the foregoing instrument, and has acknowledged before me that he executed the same as his free act and deed for the uses and purposes therein stated and that he had the corporate authority to do so as managing member of Shakespeare and Associates, LLC. Personally known V or type of identification produced

C( ;-/"n~ ./), ,'v Q~ L! ~l 'L .

WITNESS my hand and official seal in the County and State last aforesaid this Signed, sealed and delivered this I ('hi day of January, 2009, in the presence of:

~rG~ .

N0"'Z Signajr. i

LEAHD.KING

Notary Pubtic. Slate of Florida My comm. expires JUIMI 21, 2009 No. OD 443312

Book7814/Page2099

Printed Notary Name

CFN#2009022815

Page 2 of 3 d.o'-(J_

FULL LEGAL Exhibit "A"

- .

Begin 30 :feat Nozoth of the South".~ oomel!' of' the Southwest 11' ~ the NOJ;-tbeilat 1/4 o£ Seotion 7, ~own.hip 28 South, bnge 24 Baat, PoU County, FJ.oricla, lind J:Un »azoth 178 'Nt: !hence East. 28 ~ •• t.; lrhenoa Morth 24°16' •• at, 98.66 ~ .. t for a point o~ beginning :for th1. deeor1ption: nence rUl1 SOuth 68°07' Ba.t 218 f'eet, more OJ: le"., to Lake Pa:rkeJ:; Thenl;8 run :in II Hor~.t:eJ:ly direction a10Jl9 Lake P.ukeZ' a distance of 81 fe.t; theAoe Z"Qft nozth 68"07' W.at, 218 t .. t. 1aO~ oX'

1 ••• , th.nce ran South 24·16' W •• t, 65 ~ .. t to point of beq1DDia9 of this de.cription, 1 ••• .nd .x~t z-ight"'of-way for Lak. Parker Drive. :a.ing II pa~t of V. S. GOV.rNlleDt Lot 2 (fl.'actiollill. w.st 1/2 o:f Korth •• at l/t) of said S.ction 7, Township 28 SOU~, Range 24 Ballt, Polk Coonty, Flodda •

AKA 1418 w. LtLka Parke%' Drive, r..akelaDc:l, J'L 33805

Book7814/Page2100

CFN#2009022815

Page 3 of 3 ~o<j_3

This OG':'Pmellt Prepared By and Retum to:

JOHNNIE B. BYRD, JR. BYRD & STITZEL P.A.

206 NORTH COLLiNS STREET PLANT CITY FL 33563 (813) 759-1224

INSTR # 2009005571

BK 07795 PG 1292 PG(s)l RECORDED 01/13/2009 01:54:28 PM RICHARD M WEISS, CLERK OF COURT POLK COUNTY

DEED DOC 4,585.00 RECORDING FEES 10.00 RECORDED BY S Wilson

Par." ID N .... bor:

Quitclaim Deed

ThIs Quitclaim Deed, Made this 9th day of January

Abraham. Lee Shakespeare, a single man

,2009 A.D.,

Between

of the Counly of Po~k ,

f7~American Medica~ Professionals PEO, Inc. \v the laws of the State of Florida

whose add res s is: P.O. Box 433, Sydney, FL 33587

Slate of Flori.da ,grantor, and , a corporation existing under

of the Counly of Hillsborough , Slate of Florida , grantee.

WItnesseth that the GRANTOR, for and in consideration of the sum of

------------------------TEN DOLLARS ($10)----------------------- DOLLA~,

and other good and valuable consideration to GRANTOR in hand paid by GRANTEE, the receipt whereof is hereby acknowledged, has

granted, bargained and quitclaimed to the said GRANTEE end GRANTEE'S heirs, successors and ",signs forever, the following described land, situate,

lying and being in the County of Po~k Slate of Florida to wit:

Parcel Identification Number: 042723-000728-000050 & 042723-000728-000250

Lot 5 and Tract A, Redhawk Bend according to the map or plat thereof recorded in Plat Book 131, Page 6, public records of Polk County, Florida.

Subject to taxes and assessments for 2008 and subsequent; covenants, condItions, restrictions, easements, reservations and limitations of record. if any •

To Have and to Hold the same together with all and singular the appurtenances thereunto belonging or in anywise appertaining, and all the estate, right. title, interest, lien, equity and claim whatsoever of grantor, either in law or equity, for

I//J/C?&#? L«e .J&R'e.r6:'-~

Abraham Lee Shakespeare

P.O. Addre •• : 9340 Redhawk Bend Drive, L.keIa ..... FL 33818

(Seal)

STATE OF Florida COUNTY OF Polk

day of

January

,2009 by

Book7795/Page1292

CFN#2009005571

.Jt4!k e

EXM8lT NO •. __

Page 1 of 1 ,-.~ •. ·.~.~_~E_rollt .. ·.· · .... _~f ... ~dJL(

This Instrument Prepared by and return to:

Name: D. Howard Stitzel, III 4205 W Keysville Road Plant City, Florida 33567

INSTR # 2009022816

BK 07814 PGS 2101-2102 P6(5)2 RECORDED 02/11/2009 03:15:07 PM RICHARD M WEISS, CLERK OF COURT POLK COUNTY

DEED DOC 700.00

RECORDING FEES 18.50

. RECORDED BY M Johnson

Property Appraisers Parcel Number(s): 27-28-09-822000-02140U

QUITCLAIM DEED

THIS INDENTURE, made this JL_ day of January, 2009, by and between, Shapkespeare and Associates, LLC, party of the first part, and American Medical Professionals, PEO, LLC, t.-whose post office address is: PO Box 433, Sydney, Florida, of the County of Hillsborough, in the State of Florida, party of the second part.

WITNESSETH: That the said party of the first part, for and in consideration of the sum of Ten ($10.00) Dollars, and other valuable considerations, lawful money of the United States of America, to the party of the first part in hand paid by the said party of the second part, the receipt whereof is hereby acknowledged, has remised, released and quitclaimed to the said party of the second part, its heirs and assigns forever, all the right, title, interest and claim of the said party of the first part in and to the following described land in Polk County, Florida, to wit:

LOTS 14, AND 15, BLOCK BJT MILLERS'S SUBDIVISION ACCORDING TO THE MAP OR PLAT THEREOF AS RECORDED IN PLATBOOK4,PAGES 87, PUBLIC RECORDS OF POLK COUNTY, FLORIDA.

SUBJECT TO Covenants, restrictions, easements of record and taxes for the current year. Said property is not the homestead of the Grantor (s) under the laws and Constitution of the State of Florida in that neither Grantor (s) or any members of the household of Grantor (s) reside thereon.

This Deed was prepared based solely on information provided by grantee(s) and no title examination or research was requested or performed.

TO HA VE AND TO HOLD the above described premises, with the appurtenances, unto the said party of the second part, its heirs and assigns forever.

IN WITNESS WHEREOF, the said party of the first part has executed this deed under seal on the date aforesaid.

Signed, sealed and delivered in the presence of:

Shakespeare and Associates, LLC

Abraham Lee Shakespeare, Managing Member 9340 Redhawk Bend Dr

Lakeland, Florida 33810

Page 1 of 2 o<oL/5~'

Book7814/Page2101

CFN#2009022816

STATEOFFLO~

COUNTY OF {--6llL

--~~------------

I HEREBY CERTIFY, That on this day, before me, an officer duly authorized in the State aforesaid and in the County aforesaid to take acknowledgments, personally appeared Abraham Lee Shakespeare to me known to be the person described in and who executed the foregoing instrument, and has acknowledged before me that he executed the same as his free act and deed for the uses and purposes therein stated and that he had the corporate authority to do so as managing member of sq_akeM'eare ~d Associates, LLC. Personally known ....- or type of identification produced

J-lcr,1£.. 'br; /ea fA~}t...

l..EAHD.KINO

Notary Public. Slate of Florida My camm. ixpires June 21, 2009 No.OD443312

Printed Notary Name

Book7814/Page2102

CFN#2009022816

Page 2 of2 ;;Cf../fo

Prepared by:

D. Howard Stitzel III

607 S. Alexander Street, Suite 205 S Plant City, Florida 33563

IHSTR • 2009058786

~K 07851 PGS 0eS7-0258 PG(s)2 RECORDED 94/81/2889 94;34:53 PM RICHARD " WEISS, CLERK OF COURT POLK COUNTY

RECORDING FEES 18.50

RECORDED BY C King

ASSIGNMENT OF MORTGAGE

KNOW ALL MEN by these presents that on this 16t1t day of January 2009, Abraham L.

Shakespeare, individually, hereby assigns that certain Mortgage by & between Debra J. Knight and Ronald J. Knight and Abraham L. Shakespeare dated that 4t1t day of April 2007 and recorded at O.R. Book 7246, Page 0194 through Page 0197 of the Public Records of Polk County, Florida to American Medical Professionals, PEO, LLC to have and to hold in fee simple forever; and further Assignor hereby covenants that Abraham Lee Shakespeare has the lawful authority to assign said mortgage for value and that he is the absolute, sole owner of said mortgage, that he has good right, title and lawful authority to assign, sell and/or convey said mortgage to American Medical Professionals, PEO, LLC and that Assignor fully warrants total and absolute ownership of said mortgage and the legal right and ability to assign the aforesaid mortgage and will defend the same against all claims of all persons whomsoever .

- ...

~,94·~

Witness

~~

Witness

DEEDEE MOORE

POST OFFICE BOX 433 SYDNEY I FL 33587

EXHI8ITNO.4,.

:ll'I'~~ft,1(

Book7851/Page257 CFN#2009058786

Page 1 of 2 ~Ol/7

IHSTR # 2009058784

8K 07851 PGS 0253-0234 PG(s)2 RECORDED 84/01/208~ 04:34:53 PM RICHARD M WEISS, CLERK OF COURT POLK COUNTY

RECORDING FEES 18.58

RECORDED BY eKing

Prepared by:

D. Howard Stitzel Ill

607 S. Alexander Street, Suite 205 S Plant City, Florida 33563

ASSIGNMENT OF MORTGAGE

KNOW ALL MEN by these presents that on this 16th day of January 2009, Abraham L.

Shakespeare, individually, hereby assigns that certain Mortgage by & between Johnny L. Ragins AND Joyce V. Ragins, and Abraham L. Shakespeare dated that 14th day of May 2007 and recorded at O.R. Book 07293, Page 2204 through Page 2207 of the Public Records of Polk County. Florida to American Medical Professionals, PEO, LLC to have and to hold in fee simple forever; and further Assignor hereby covenants that Abraham Lee Shakespeare has the lawful authority to assign said mortgage for value and that he is the absolute, sole owner of said mortgage, that he has good right, title and lawful authority to assign, sell and/or convey said mortgage to American Medical Professionals, PEO, LLC and that Assignor fully warrants total and absolute ownership of said mortgage and the legal right and ability to assign the aforesaid mortgage and will defend the same against all claims of all persons whomsoever .

R \:)(®C>.M. 'wI=-..5h a\Se..s9AAXtAbraham L. Shakespeare

DEEDEE MOORE POST OFFICE BOX 433 SYDNEY, FL 33587

Book7851/Page253

CFN#2009058784

Page 1 of 2 :2o<{'6

••

STATE OF FLORIDA

COUNTYOF ~~ t._)

I HEREBY CERTIFY, That on this day, before me, an officer duly authorized in the State aforesaid and in the County aforesaid to take acknowledgments, personally appeared Abraham Lee Shakespeare to me known to be the person described in and who executed the foregoing instrument, and has acknowledged before me that he executed the same as his free act and deed for the uses and purposes therein stated. personally known or type of identification produced

-----------------------------

WI1NESS my hand and official seal in the County and State last aforesaid this Signed, sealed and delivered this I (P day of January, 2009, in the presence of:

~J~'2n' t(_~

Notary Signature

Printed Notary Name

Book7851/Page254

CFN#2009058784

Page 2 of2 ,t;()~9

10

11

12

13

14

15

16

17

18

19

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1

ORIGINAL

IN THE OFFICE OF THE STATE ATTORNEY

IN AND FOR HILLSBOROUGH COUNTY, STATE OF FLORIDA

2

3

4

- - - - - - - - - - - - - -X

IN RE:

5

6

SAO INVESTIGATION

- - - - - - - - - - - -X

7

8

9

SWORN STATEMENT OF:

JAMES HARDY BUZBEE, ESQ.

TAKEN:

Pursuant to Notice

TIME:

Beginning at 11:09 a.m. Concluded at 11:20 a.m .

DATE:

Monday, February 8, 2010

PLACE:

Law Offices of James H. Buzbee 802 W. Martin Luther King, Jr.

Boulevard - Suite D Plant City, Florida 33563

BEFORE:

RALPH D. MILLS, CVR, CP Notary Public

State of Florida at Large

MILLS REPORTING GROUP, INC.

(813) 272-1814 XJs.:J

10

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22

23

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1 APPEARANCES:

2

2

On behalf of the State:

3

HON. JAY PRUNER Assistant State Attorney

419 N. Pierce St., Third Floor Tampa, Florida 33602

(813) 272-5400

4

5

6

7 ALSO PRESENT:

8 MR. TERRY DELISLE, SAO Investigator

9

CON TEN T S

PAGE

Examination by Mr. Pruner

3

Certificate of Oath

14

Certificate of Reporter

15

MILLS REPORTING GROUP, INC.

(813) 272-1814

1 2

was called as a witness, and being duly sworn by the

JAMES HARDY BUZBEE, ESQ.,

3 Notary, was examined and testified as follows:

4 EXAMINATION

5 BY MR. PRUNER:

6

Please state your name and occupation,

Q

7 sir.

8

A

James Hardy, H-a-r-d-y, Buzbee,

I'm an attorney, 802 West Martin Luther

9

B-u-z-b-e-e.

10 King, Jr. Boulevard, Suite D, plant City, Florida.

11

Q

How long have you been licensed to

12 practice law in Florida, sir, approximately?

13 14

A

Thirty-eight, 39 years.

Do you know a fellow by the name of

Q

15 Howard Stitzel?

16 17

A

Yes, sir.

Q

In February of 2009 how would you

18 describe your relationship with Mr. Stitzel at that 19 point?

20 21

A

Strained.

Q

Okay.

Yeah, I, at that point I thought that he

22

A

23 may have stolen a watch from me so I didn't have

24

anything to do with him at that, on a normal basis.

25 had been real close friends, but for maybe almost a

3

We

MILLS REPORTING GROUP, INC.

(813) 272-1814 c)OS;L

10

11

1

each of you cover professional responsibilities for

year before that we had not been doing anything

2

together.

3

Q

And in February of 2009 did you represent

4 Mr. Stitzel in any form or fashion as an attorney in

5 your profession?

6

A

No, sir.

7

Okay.

Have you ever had an

Q

8 attorney/client relationship with Mr. Stitzel where you

9 represented him?

I don't think so.

I don't know.

A

I

didn't do his divorce.

I sat in on some conferences

12 with some other lawyers when he was getting divorced

13

from Veronica Stitzel.

14 And he called me when this investigation

15 heated up and wanted me to do something, and I said --

4

16 do something about any representing and I said, "No, we

17

have a very serious conflict here.

You drug me into

18 this by getting these documents done," and I just

19

20

suggested that he call Mr. Lansky.

That was it.

All right.

At some point before February

Q

21 of 2009, did you have a friendship with Mr. Stitzel?

22

23

24

A

Yes.

Q

And as a result of that friendship, did

25 each other, court appearances or such, things of that

MILLS REPORTING GROUP, INC.

(813) 272-1814

XJ53

1

2

3

nature?

A

Occasionally, yeah.

Q

And were there times when you allowed

4 Mr. Stitzel access to your office to, for maybe for

5 your legal assistant to prepare documents for him or

6 anything of that nature?

7

A

No, I don't think so, not before this

8 incident.

9

Q

Okay.

And the incident we1re talking

10 about is an incident that Ms. Taylor, your legal

11 assistant, indicated occurred on February 11th of 2009

5

12 where Mr. Stitzel and Ms. Deedee Moore appeared outside

13

of your office waiting for Ms. Taylor, your legal

14 assistant, upon her arrival to work that day.

15

Did you know that Mr. Stitzel was, and

16 Ms. Moore were coming by your office that morning?

17

18

A

No, sir.

Q

Okay.

Ms. Taylor has indicated that

19 she's prepared a number of documents that are attached

20 to or will be attached to these statements, Exhibits A

21

through F inclusive.

Did you have anything to do with

22 the preparation of any of these documents?

23

24

25

A

No.

I believe everything was already

completed when I got here.

Q

All right.

MILLS REPORTING GROUP, INC.

(813) 272-1814

;;tJS'-{

1

No.

I mean, he said he was going to

A Either that or she was finishing up the

2

answer and waiver on a divorce.

3

Q

Did you have any conversation that day

4 with Mr. Stitzel about these documents that Ms. Taylor

5 presented or prepared at his request and direction?

6

A

Yeah, just general conversation I did.

7 And let's see, I was like, "What are you doing here?"

8 You know, "Why are you bringing this?"

9

And he told me, in summary, that

10 Ms. Moore was going to loan him $30,000 and give him a 11 place to have a law office and, you know, try to get 12 back on the right track because he had been having a

13

rough time financially and personally.

14

Q

One of the documents that Ms. Taylor

15 indicated she prepared was a Promissory Note in the

16 amount of $30,000 from Mr. Stitzel to I believe Abraham

Shakespeare, LLC or perhaps Deedee Moore.

17

It's not one

18 of the documents that's in this pile of documents in 19 front of you.

20

Is that what, the conversation that led

21 to him indicating that Deedee Moore was loaning him

22 30 , 000, is tha t what --

23

A

I never saw the note.

24

Q

Okay.

You never saw the Promissory Note?

25

A

MILLS REPORTING GROUP, INC.

(813) 272-1814 0l0,-'55

6

1

2 3

4

5

6

borrow the money from her, she was going to lend him

the money, but I never actually saw that note.

Q

Okay.

And I was aware that they had typed up a

A

divorce.

Ms. Moore did not, didn't take part in any

conversation that I had with Stitzel.

I didn't realize

7 that he had or was never told that he had represented 8 Shakespeare also.

9

Q

Okay.

You've indicated a few minutes ago

7

10 that sometime in the last several weeks -- well, let me

11 start that over.

12 You've indicated that you had a

13

conversation with Mr. Stitzel since February 11th about

14 him having put you in the middle of this situation with

15 the preparation of these documents?

16

A

No.

He called me and said, "There's a

17 helicopter over my law office and there's a bunch of

18 patrol cars here." He left it as a phone message first

19

and he didn't leave a phone number.

I don't know if he

20 was too excited or he thought I had it or what, but he

21 didn't leave a number.

22 So I called my office on my cell phone. 23 April located an old number we had for him, which was

24

532-0108, and I dialed that number and he answered.

25 So, and then I told him that I felt we had a conflict

MILLS REPORTING GROUP, INC.

(813) 272-1814 8OS70

1

2

of interest.

I said, "I was going to get with you to

3 see if you'd get straight with me," and he knew what I

4 meant about the watch, "and then I was going to go to

5

Grady Judd.

But since they're already there, you know,

6 you need to get another lawyer to talk to you."

7 And I suggested Glen Lansky because Glen

8 has been a Polk County prosecutor and he's physically

9 close to where Howard's home is I guess, eight or ten

10 miles apart from where the office is.

11

Q

In any conversation you've ever had with

12 Mr. Stitzel did he ever indicate that there was any

13

impropriety in the manner in which the documents

14 prepared by your legal secretary on February 11th of

15 2009 in the manner they were prepared or in the manner

16 of the transactions themselves? That was --

17

A

I don't even think I understand the

18 question.

19

20

Q

I don't even think I understand that

question as it came out.

Anytime you've spoken with

21 Mr. Stitzel since February of 2009, did he ever

22 acknowledge or imply or admit that there was something

23 shady about the transactions

24

25

A

No.

Q

-- the documentation that Ms. Taylor

MILLS REPORTING GROUP, INC.

(813) 272-1814

~0

8

2

3

1

Can you tell us on the

prepared?

A

No.

He just told me he was borrowing the

money from her.

When he left the phone message, which

4 I've still got saved, he said, "It's about, you

10

5 probably read in the papers about Abraham Taylor, the

6 guy," I mean, "Abraham Shakespeare, a fellow I

7 represented on a child support case and that Deedee

8 Moore that they're talking about on TV."

9

He said that's what he thought they were

coming to see him about.

And I wasn't aware that he

11 ever represented Abraham himself; I understood he was

12 representing Deedee .

13

Q

Has he ever told you about his

14 professional relationship or financial relationship

15 with Deedee Moore, other than the fact that she was

16 going to loan him $30,000?

17

18

A

No.

Q

Has he ever discussed with you in any

19 other conversation Abraham Shakespeare?

20

No, I don't talk to him.

A

I mean, I'm

21 through with him.

22

Q

And I know from a previous conversation

23 you and I had off the record the incident concerning

24

the watch that you described .

25 record what that incident involved and what led there

MILLS REPORTING GROUP,

(813)

272-1814

~O$

INC.

9

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