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SUPREME COURT OF FLORIDA
CASE NO.: SC06-1791
Lower Tribunal Case No. : 2006CF335
Nancy Jo Grant v The State of Florida and
The Florida Bar
__________________________________________________________________
Plaintiff Defendant(s)
MOTION TO REINSTATE AND AMEND COMPLAINT
AND
SECOND PETITION FOR WRIT OF PROHIBITION
The Plaintiff, Nancy Jo Grant filed a Motion to Reinstate and Amend Complaint filed 9/01/06 along with a Second Petition for a Writ of Prohibition against the State of Florida, specifically the Twelfth Judicial Circuit for reasons as follows:
1. The State of Florida/Twelfth Judicial Circuit has charged Plaintiff with violation of Florida Statutes 454.23; pertaining to the Unlicensed Practice of the Law and is being threatened 28 Counts totaling 140 years in prison. (Exhibit A)
2. Plaintiff has been arrested three times for the same indictment, June 29th 2006, March 5th 2007 and May 17th 2007. (Exhibit B)
3. For the June arrest Judge James S. Parker ordered a $50,000 bond. Plaintiff paid $5,000 to be released from jail. (Exhibit C) During the March and May arrests Plaintiff was not read her rights, but was released on ROR (Released on Own Recognizes); for the third arrest in May, Plaintiff was arraigned at before she was arrested.
4. Conditions of Plaintiff release where stipulated pertaining to a response letter from the Florida Bar dated 9/13/05. (Exhibit D)
5. Pursuant to this Court's the recent order dated May 18, 2007 Case No.: SC06-2370 The Florida Bar vs. Norman Elliot Kent, "the Seventeenth Judicial Circuit is exceeding its jurisdiction and usurping the exclusive jurisdiction of this Court with respect to the discipline of persons admitted to the practice of law in Florida." (Exhibit E)
6. The Twelfth Judicial Circuit thru its agents arrested and are prosecuting Plaintiff (Case No. 2006CF000335) for the unlicensed practice of law and are exceeding jurisdiction and usurping the exclusive jurisdiction of this Court with respect to the discipline of persons admitted to the practice of law in Florida.
7. Plaintiff claims the Florida Bar is not respecting the authority of this Court by not bringing Plaintiff's case to this Court for obvious reasons: (1) Plaintiff has been a civil rights activist due to the severe civil right violation committed upon Plaintiff by the State of Florida for taking her four children "illegally" in 1984. After a 6 month long battle with the Twelfth Judicial Circuit Judge James S. Parker was forced to returned Plaintiffs children after her story reached a national level (Exhibit F) (Plaintiff holds evidence which exonerates her from the false allegations in 1984); (2) Plaintiff is active in providing educational resources for those (inside and outside the walls) who choose to represent themselves "pro se" more correctly as "pro persona" or "sui juris" thru a non-profit corporation called the Florida Pro se Bar, Inc. (3) Plaintiff is "Jailer In Chief" (Director) of the Florida Judicial Accountability Initiative Law, which is registered with the Florida Department of State as a P.A.C., Political Action Committee commonly known as "Florida JAIL4judges"; (4) Plaintiff ran for DeSoto County judge in 2004, then was sued for qualifying and placed on the ballot, (Case No.:142004CA000335). Plaintiff in turn challenged Florida Statute 34.021,as unconstitutional in federal court (Case No.: 2:04-cv-290-FtM-29DNF) that a citizen should not have to be a member of the Florida Bar to run for a judicial office: (5) Plaintiff has challenged the legality of the Bar's corporate operations, (the Florida Bar is registered with the United States Patent Office, wherein it is shown that the Florida Bar [an arm of the Florida Supreme Court] is operating in commerce) (Exhibit G); (6) a lawsuit was recently filed against the Florida Bar SC07-400 in lieu of the fact that the Florida Bar was publishing negative propaganda against J.A.I.L., (7) Plaintiff collected information since the year 2000 which gave evidence of racketeering, closed door hearings, forced plea deals, bogus trials and warehousing inmates by the DeSoto County Court. March 22, 2006 Plaintiff went on record claiming the described illegal activities where being conducted in the DeSoto County Courthouse in conjunction with the DeSoto County Sheriff Office. Plaintiff further claimed the described illegal activities are repetitive throughout the State of Florida and the entire United States Criminal Justice System, therefore Plaintiff believes this is contributing to the Florida Bar not bringing an action to this Court for the Florida Bar is working in conjunction with the Twelfth Judicial Circuit to silence Plaintiff's complaints.
8. Three months after "blowing the whistle" on the corrupt practices of the court Plaintiff was arrested. A gag order was placed on Plaintiff by Judge James S. Parker, Plaintiff was told before audio visual in the booking room of the DeSoto County Sheriff's office, that Plaintiff "was not allow to-speak to any inmates or any inmate's family members about anything going on at the jail or courthouse". If he (Judge Parker) received word that Plaintiff had spoken to any inmates or any inmate's family members Plaintiff would be immediately jailed. Plaintiff's arrest directed attention away from the corrupt practices of the court; and was strategically orchestrated to prevent exposure, as to why county jails are so full, state prisons are growing at such a rapid pace, and "secret" civil commitment centers (concentration camps, such as Florida Civil Commitment Center in DeSoto County) are springing up all over America.
9. Another trial date is set for August 20, 2007. Two other trial dates were attempted October 30, 2006 and March 5, 2007, but no trials ensued.
10. Assistant State Attorney Donald Hartery created, "The States Proposed Jury Instructions" (Exhibit H) Plaintiff petitioned to have them dismissed, due to a number of civil right violations and a separation of powers issue violation, but was denied.
11. The United States Supreme Court, in Twining v. New Jersey, 211 U.S. 78, 29 S.Ct. 14, 24 (1908), stated that "Due process requires that the court which assumes to determine the rights of parties shall have jurisdiction. Citing Old Wayne Mut. Life Assoc. v. McDonough, 204 U.S. 8, 27 S.Ct. 236 (1907); Scott v. McNeal, 154 U.S. 34, 14 S.Ct. 1108 (1894); Pennoyer v. Neff, 95 U.S. 714, 733 (1877). Due Process is a requirement of the U.S. Constitution. Violation of the United States Constitution by a judge deprives that person from acting as a judge under the law. He/she is acting as a private person, and not in the capacity of being a judge. Any judge utilizing 'private corporate law' as opposed to the law of the Constitution of the United States is also in violation of the Due Process clause of the Constitution of the United States.
WHEREFORE, Plaintiff petitions this Court to allow Plaintiff to Amend/ Reinstate her case to be heard; for relief thru issuance of a Writ of Prohibition upon the State of Florida (Twelfth Judicial Circuit) prohibiting its agents' to utilize selective and malicious prosecution against the Plaintiff; Or Order the Florida Bar bring this case to be heard in the Florida Supreme Court as mandated by the Florida Constitution Article V sec. 15, and this Court in The Florida Bar vs. Norman Elliott Kent, May 18, 2007.
Respectfully submitted,
_________________________ Dated this _____ day of May, 2007.
Nancy Jo Grant, Pro se
803 E. Magnolia Street
Arcadia, Florida 34266
(863) 494-0363
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been mailed to by USPS to the following:
Judge Lee E. Haworth, 12th Judicial Circuit
2002 Ringling Blvd.
Sarasota, Florida 34237
(941) 861-7950
Earl Moreland, State Attorney, 12th Judicial Circuit
Criminal Justice Building
2071 Ringling Blvd. Suite 400
(941) 861-4400
George Waas
Special Counsel
Office of the Attorney General
PL-01 The Capitol
Tallahasee, Florida 32399-1050
(850) 414-3662
Andrew Mooney, President
Florida Bar Association, Inc.
512 12th Street W.
Bradenton, Florida 34205
Henry Cox III, President,
The Florida Bar
651 East Jefferson Street
Tallahassee, Florida 32399-2300
Donald H. Hartery, Assistant State Attorney 12th Judicial Circuit
Office of the State Attorney
Criminal Justice Building
2071 Ringling Blvd. 3rd FL
Sarasota, Florida 34237-7000
(941) 861-4323
State of Florida
Division of Risk Management
C/O Florida Department of Financial Services
200 E. Gaines Street
Tallahassee, Florida 32399-0300
State of Florida
Office of the Governor, Charlie Crist,
PL-05, The Capitol
Tallahassee, Florida 32399-0001
_______________________________ Dated this _____ day of May, 2007.
Nancy Jo Grant