To Whom It May Concern:

Pursuant to the Florida Sunshine Law, I hereby request the following records:

all documents related to Division of Risk Management Claim #20012039580.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 10 business days.

Sincerely,

Michael Locke

Thank you. I don't know if it was implied that I'm requesting any records related to communication between the Division of Risk Management and the 18th Judicial Circuit, but I am.

1. On 7/31/2020 my ex filed a petition for protection.
2. On 8/3/2020 I e-mailed the assigned claims adjuster Lori Cross-Smith to inform her 180 days had passed since my written notice.
3. On 8/4/2020 the previously mentioned petition for protection was granted on an ex parte temporary basis.

I don't know if the 3 facts above are connected, but based on what I have at this point it seems likely due to the fact that an ex parte temporary injunction is an emergency requiring immediate action and there was no action for 4 days on the petition.

"From: Gregory Hansen <ghansen@sa18.org>
Date: Tue, Mar 22, 2022 at 9:28 AM
Subject: Re: Locke v. Locke Final Order status following Dec. 16th trial completion
To: leslie@leslieannlaw.com <leslie@leslieannlaw.com>, service@spacecoastfamilylaw.com <service@spacecoastfamilylaw.com>
Cc: Edmond Law, LLC. <edmondtriallaw@gmail.com>

Ms. Ferderigos; I am the Assistant State Attorney handling the criminal cases involving your client, Michael Locke. I am preparing a modified bond condition order which needs to reflect the findings of the family law proceedings which concluded Dec. 16, 2021.

I have reviewed the Open Court Minutes following the trial of that matter and I see where the Judge directed you to prepare the Final Order in conformance with her orally announced rulings. I do not, however, see any Final Judgement in BECA nor do I see any Notice of Hearing set to address any objections to a proposed order.

Could you please advise whether a proposed Order has been submitted to Judge Recksiedler for her consideration. Mr. Locke has been granted permission to reside in the marital home by the presiding criminal Judge Bookhardt and I have been tasked with preparing an Amended Bond Condition Order setting forth all of his current conditions of bond.

If there is no Final Order in the family law case, I intend to use the rulings as announced in the Open Court Minutes of December 16, 2021 to prepare my proposed Amended Bond Conditions Order. Thank you in advance for your time and attention to this important matter.

P.S. I am copying Ms. Locke’s family law lawyer and Mr. Locke’s criminal case lawyer so all counsel will be aware of the steps I am taking in an effort to get an enforceable Amended Bond Conditions Order in place. TY.

Gregory S. Hansen

Fla. Bar #460095

Asst. State Attorney

2725 Judge Fran Jamieson Way

Bldg. D

Viera, Florida 32940-6605

(321)617-7510 Ext. 55615

ghansen@sa18.org"

“The Court finds the testimony of Jaymie Gaucher, Director of Center for Child Development (hereinafter "Center"), indicated that the Mother was responsible for the refusal of the Center to release Wilder to his Father during the Father's timesharing. The Mother directed the Center not to release Wilder to his Father. As a result of her direction, the police were called…Ms. Gaucher testified Wilder was happy to see his father, had no fear of him and wanted to leave with his Father at the time of the incident. According to Ms. Gaucher, based on her observations, the Father has always had positive behavior with Wilder. The Court found it concerning that Ms. Gaucher took the Mother and the minor child into her office with her, rather than being with both parents or remaining in a neutral area until everything was resolved. The Court finds it most important from Ms. Gaucher's testimony that Wilder wanted to go with his Father on the day the Father showed up to pick him up. The Mother was responsible for the Police becoming involved at the child's school based on her instructions to the Center not to release the minor child to the Father…” 05-2017-DR-054881, Doc # 443, factors a and c.

“The Court finds in August of 2020 after injunction had been granted, Wilder acted out two (2) weeks later when he was initially given contact with his Father then abruptly denied contact with his Father by the Mother. Wilder's behavior improved during the Fall 2021 once Wilder was able to have consistent contact with his Father. When Wilder received a referral in the Fall of 2021 was when the Mother failed to allow video contact between Wilder and his Father.” 05-2017-DR-054881, Doc # 443, factor h.

"The Court finds it concerning a Petition for Stalking Violence injunction filed only for the protection of the Mother, not on behalf of the children was at a later date amended to add the children without amending the petition or notice to the Father as to the merits behind adding the children. It was this amended injunction that ultimately led to the Father having no physical contact with his children for close to two (2} years. The Court also takes issue that the Father was arrested for allegedly violating a permanent injunction for the Mother's protection when the injunction had never been served on the Father prior to his arrest." 05-2017-DR-054881, Doc # 443, Factors m.

"The Court does not agree that the videos submitted into evidence provide any evidence of aggressive or abusive behavior of the father. In fact, the Court finds the Mother's perception and testimony regarding these videos as skewed. The Court is concerned and calls into question the credibility of the Mother's testimony given her demeanor while testifying, and exaggerated perception of the events she testified to in these videos. The Court finds in the video of the drop off at the baseball field the Mother was the first to yell at the Father. Furthermore, when the Mother requested the Father to step back, the Father stepped back immediately and did exactly what the Mother requested. The Court did not find the Father was the first to engage in confrontational behavior towards the Mother. The Court finds the Mother appeared to me more the aggressor towards the Father.
The Court finds the second video was not as the Mother depicted. Upon reviewing the video, the Court finds the Father's statement that he is going to kill the Mother was not a credible threat, but rather said in anger and not with the literal intention of actually wanting to kill the Mother. Further in listening to the video, the mother's testimony regarding the child's statement he hated the Father because the Father told the child it was time to go home while the child was playing with a lego was not credible. Upon review of the video, the child told the story very matter of fact and stated he did not want his Father to think he feared him. To the contrary, the child did not appear to be scared of his Father. In fact, the child appeared to care deeply for his Father and stated he did not want his Father to get arrested or hurt. When the Court originally heard the testimony of the Mother prior to seeing the video, the Court expected the video to depict a much worse circumstance based upon how the Mother described this incident. The Mother's testimony was exaggerated and extremely skewed from what the Court saw when watching the video. In fact, in the second video, it was the Mother making demands of the Father to put the children down and the Father immediately obeyed doing exactly as she requested of him. Nothing suggests the Father was inappropriate with the children in any manner from the videos.

The Court weighed the mother's exaggerated perception of the photographs and videos as well as her demeanor when weighing the Mother's testimony in its entirety. The Court found her less credible in portions of her testimony.

The Court finds the Father under all these circumstances during the pendency of this case accepted responsibility, he was straight forward, and the Court finds the Father to be extremely credible in his testimony.” 05-2017-DR-054881, Doc # 443, factor s.

To Whom It May Concern:

Please find enclosed a check for $30.65 to satisfy the fee associated with the attached public records request.

Thank you.

Please see document labeled "Notice.pdf"

Please see attached PDF labeled "842020 Injunction Issues.

https://www.rev.com/transcript-editor/shared/S766mBLqin4B7bUorgwQN-Ju5D-VfxjFYpwxijt2840ERtYUweocahivsGZ72h9Ry1KTiXviOp7faCDYnvtJ4rmcFsI?loadFrom=SharedLink

So after however long of recounting the allegations contained in the petition for injunction, attorney Deborah Smith is stopped by the presiding judge and told said allegations do not support an injunction. It’s at that time that the Petitioner starts to recount various allegations, notably none of which were included in a divorce pretrial statement filed by attorney Deborah Smith approximately a year after the highlighted testimony of Petitioner.

"The Court finds it concerning a Petition for Stalking Violence injunction filed only for the protection of the Mother, not on behalf of the children was at a later date amended to add the children without amending the petition or notice to the Father as to the merits behind adding the children. It was this amended injunction that ultimately led to the Father having no physical contact with his children for close to two (2} years. The Court also takes issue that the Father was arrested for allegedly violating a permanent injunction for the Mother's protection when the injunction had never been served on the Father prior to his arrest." 05-2017-DR-054881, Doc # 443, Factors m.

Presentation of a complaint to government concerning its conduct is central to the right to petition such government for the redress of grievances against it. Cate v. Oldham, 450 So. 2d 224 (Fla. 1984 ). Report to an arm of government, concerning a matter within the purview of the agency's responsibilities, serves a "legitimate purpose" within meaning of stalking statute, regardless of the subjective motivation of the reporter. Respondent's complaints and reports to governmental entities was constitutionally protected activity not included within the meaning of course of conduct under stalking statute. Right to petition was originally granted solely to petition the judiciary, but has been extended to all departments of the government. Right to petition a judicial officer to take official action in the exercise of its powers is guaranteed by the First Amendment, which includes the right to notify the appropriate agencies about violations of the law. Curry v. State, 811 So. 2d 736 (Fla. Dist. Ct. App. 2002). A finding of "no legitimate purpose" to a given action, for purposes of the statute defining stalking, including cyberstalking, must not only comport with common sense, it must also be evidenced by a complete lack of usefulness or utility. The First Amendment's freedom of speech and right to petition the government for redress protects the right of the political irritant to voice his opinions as much as it protects any citizen's right to do so. The First and Fourteenth Amendments embody profound national commitment to the principle that debate on public issues should be uninhibited, robust, and wide-open, and that it may well include vehement, caustic, and sometimes unpleasantly sharp attacks on government and public officials. Publicly expressing anger toward an elected official is not a basis for entry of an injunction; in public debate, elected officials must tolerate insulting remarks-even angry, outrageous speech-to provide breathing room for the First Amendment freedom of speech. Logue v. Book, 297 So. 3d 605 (Fla. Dist. Ct. App. 2020), review denied, No. SC20-1063, 2021 WL 276145 (Fla. Jan. 27, 2021 ).

Conservative America, I could be one of your kids. Conservative America, the Federalist Society thinks just like this. Conservative America, let me tell my story at the Desantis rally and see how many hugs I get.

My schedule allows me to phone bank for Governor Desantis or Mr. Patronis’ as much as a person possibly good. I support both wholeheartedly and thank them for everything they’ve done to make Florida the best and freest state in this country.

I apologize if this isn’t the appropriate office to contact, but I strongly feel given the current climate of events in the country that I have to explicitly state I have no intention whatsoever of engaging in any kind of illegal act involving violence or threats of violence. That no matter what I fully intend at all times to handle any current or potential grievance with a private citizen or an agency of the government (Federal, State, or Local) mmm within the bounds of the American legal system. Unfortunately my experience to this point has been that what a person says will most likely be twisted and distorted, so my hope and intent with utilizing muckrock has and continues to be that my actual words are publicly available.

Please allow this message to serve as notice regarding violations of Florida Statutes 1014.04(1) and 1014.04(4).

https://www.muckrock.com/foi/brevard-county-182/formal-and-informal-complaints-120360/

https://www.muckrock.com/foi/brevard-county-182/animal-services-records-for-127-delvalle-st-melbourne-beach-fl-32951-126666/

https://www.muckrock.com/foi/melbourne-10493/complaint-from-paige-locke-on-5102022-128803/

https://www.rev.com/transcript-editor/shared/QI9nieUFQQ2E_XD8eqCe8rjusHeludfwoapOzNQdOHTQUdS4eU9GhB2brVnViyWt6s7apodond57BMxKbMWb-1Y2f9w?loadFrom=SharedLink

“THE COURT:· Okay.· I just want to make sure. Now, you indicated there was a lengthy quote, you can't recall it, but it was through My Family Wizard and you notified the State Attorneys Office, and it was elaborate. What was the what was the subject of the quote?
THE WITNESS:· I've notified the State Attorneys Office on several messages he sent me. On that quote, I don't know if I have -I e-mailed them to the -- Greg Hansen and I don't typically get a response from him, so this most recent quote was something about what he wanted the kids superpower to be.
THE COURT:· I don't think I have any further questions.” Page 40 of Motion to Dissolve Iinjunction 04-22-2022_full-1.

1. An ex parte temporary injunction was granted on 8/4/2020 by Judge Charles Roberts.
2. The final hearing for the injunction was set for 8/28/2022 with Judge Robert Segal to preside.
3. An evidentiary hearing takes place before Judge Charles Roberts on 8/5/2020 regarding separate pending issues between the parties. 05-2017-DR-054881-XXXX-XX, doc#461, page 33
4. On 8/8/2020 Respondent files a motion to dissolve the ex parte temporary injunction. 05-2020-DR-036701-XXXX-XX, doc# 12
5. On 8/11/2020 the Court issues an order on the motion to dissolve that reaffirms the originally scheduled 8/28/2020 hearing date. 05-2020-DR-036791-XXXX-XX, doc #15
6. No evidentiary hearing takes place prior to the issuance of the order on the motion to dissolve.
7. “Any such ex parte temporary injunction is effective for a fixed period not to exceed 15 days. A full hearing, as provided in this section, shall be set for a date no later than the date when the temporary injunction ceases to be effective. The court may grant a continuance of the hearing before or during a hearing for good cause shown by any party, which shall include a continuance to obtain service of process. An injunction shall be extended if necessary to remain in full force and effect during any period of continuance.” Florida Statute 784.0485(5)(c)
8. “[a] party against whom a temporary injunction has been granted may move to dissolve or modify it at any time. If a party moves to dissolve or modify, the motion shall be heard within 5 days after the movant applies for a hearing on the motion.” Fla. R. Civ. P. 1.610(d).
9. “A person who willfully violates an injunction for protection against stalking or cyberstalking issued pursuant to s. 784.0485…” Florida Statute 784.0487(4)(a)
10. “The plain language of the statute is unequivocal that good cause must be shown prior to any extension and continuance." Sanchez v. Saenz, 320 So.3d 926 (Fla. App. 2021)
10. “…the current statute does not provide for the issuance of a series of temporary injunctions in lieu of a permanent injunction…” Bacchus v. Bacchus, 108 So. 3d 712, 714 (Fla. 5th DCA 2013).
12. “We first examine the statute's plain meaning, resorting to rules of statutory construction only if the statute's language is ambiguous. Holly v. Auld, 450 So.2d 217, 219 (Fla. 1984).” Lopez v. Hall, 233 So. 3d 451, 453 (Fla. 2018)
13.. "Under the stalking statute, the final hearing is to be held within fifteen days unless good cause is shown for a continuance." Dean v. Bevis, 322 So.3d 167 (Fla. App. 2021)
14. An ex parte temporary injunction "...allows a petitioner to receive an ex parte temporary injunction, effective for 15 days at most, and requires that a full hearing occur on a date ‘no later than the date the temporary injunction ceases to be effective,’ unless good cause is shown... Because of the statutory timeline provided... it will be impossible... to obtain a ruling... in a situation where a temporary injunction is granted and a full hearing must occur at most 15 days later…” Lopez v. Hall, 233 So. 3d 451, 453-54 (Fla. 2018)

Good cause was never shown in case # 05-2020-DR-036701 justifying the final hearing taking place 24 days after an ex parte temporary injunction was entered. No argument can be made that good cause existed due to an evidentiary hearing taking place a day after the ex parte temporary injunction was entered. It is unequivocal that the plain language of the applicable statute does not allow for the Court to enter an ex parte temporary injunction exceeding 15 days without first showing good cause. It is unequivocal that in order for an injunction to of been violated, it is required that said injunction was issued pursuant to FS 784.0485. It is unequivocal that the injunction issued in case # 05-2020-DR-036701 was not issued pursuant to FS 784.0485. It is unequivocal that the plain language of the applicable statute is such that the ex parte temporary injunction entered in case # 05-2020-DR-036701 was of no effect, and by extension, the final injunction entered in case # 05-2020-DR-036701 is of no effect. Due to as much, the final injunction currently in place should be immediately voided, and any criminal prosecutions that stem from either injunction are of no merit and should be immediately dismissed.