Excessive Workload Litigation
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Pleadings in the Third District Court of Appeal
State’s Petition for Writ of Common Law Certiorari
Third District Order Granting Motion to Stay and Order for PD to respond
PD11 Reply in Support of Cross-Petition for Writ of Certiorari
Supplemental Response to State's Motion & Motion to Unseal the Transcript
Order Denying Public Defender’s Motion to Declare Section 27.5303(1)(d), Florida
Statutes, Unconstitutional and Granting Public Defender’s Motion to Withdraw
Order Denying Public
Defender’s Motion, October 29,
2009
State’s Motion to Stay Order Granting Public Defender’s Motion to Withdraw
State’s Response to Pleadings filed in Trial Court, August 3, 2009
State’s Response to Motion to Withdraw
State’s Response to Request for Judicial Notice
State’s
Appendix & Exhibit 1
State’s Exhibit 2
State’s Exhibit 3
State’s Exhibit 4
State’s Exhibit 5
State’s Exhibit 6
State’s Exhibit 7
Pleadings filed in Trial Court, August 3, 2009
Motion to
Withdraw and to Declare Section 27.5303(1)(d),Florida Statutes, Unconstitutional
Exhibit A to Motion to
Withdraw
Exhibit B to Motion to
Withdraw
Exhibit C to Motion to
Withdraw
Exhibit D to Motion to
Withdraw
Exhibit E to Motion to
Withdraw
Exhibit F to Motion to
Withdraw
Memorandum of Law in
Support of Motion to Withdraw
Request
for Judicial Notice
Notice of Filing of Amended Affidavit of Jay Kolsky in Support of Motion to
Withdraw
Affidavit of Antoine Bowens filed September 11, 2009
Supplemental Affidavit of Carlos Martinez filed September 21, 2009
Pleadings filed in Florida Supreme Court re the Third District Court of Appeal
Decision (Case No. SC09-1181)
Brief of
Respondent (State of Florida) on Jurisdiction
Brief of Petitioner
(PD-11) on Jurisdiction
Notice of
Intent to Invoke Discretionary Jurisdiction
Motion for Clarification
Motion for Clarification
Motions to Certify Questions of Great Public Importance
PD-11's Motions to
Certify Questions of Great Public Importance
State of Florida's Response to Motion to Certify
Third District Court of Appeal Decision
Third District Court of Appeal
Decision
Responses to Court's Invitation to Provide Supplemental Information
Invitation to Respond with Supplemental Material
PD-11's Response
State's Response
Petitions/Briefs on the Merits in the Third District Court of Appeal.
State's Brief (Petition
for Certiorari)
Response to State's Petition
for Certiorari
State's Reply
Regional Counsel's Brief
(Petition for Certiorari)
Appendix to Regional Counsel's
Brief/Petition
Answer Brief - Response to
Regional Counsel's Petition
Preliminary Proceedings on Return to the Third District Court of Appeal
Nov. 10, 2008, Order Setting Briefing Schedule and Oral Argument for March 30,
2009
PD-11's Motion to Dissolve Stay and
Further Expedite Appeal
Appendix to Motion to
Dissolve Stay and Further Expedite Appeal
Order Denying
PD-11's Motion to Dissolve Stay
The Supreme Court of Florida Dismissed this Case for Lack of Jurisdiction,
Sending the Case Back to the Third District Court of Appeal, November 7, 2008
Order Dismissing
Certification for Lack of Jurisdiction
Order Denying
all Motions as Moot Because of Lack of Jurisdiction
Pleadings in the Supreme Court of Florida After that Court Issued Order to Show
Cause Why Case Should Not be Dismissed for Lack of Jurisdiction, October 2008
State’s
Response to Order to Show Cause
Appendix to State’s Response to Order to Show Cause
Public Defender’s
Reply to State’s Response to Order to Show Cause
Appendix
A to Public Defender’s Reply
Appendix
B to Public Defender’s Reply
Pleadings in the Supreme Court of Florida After the Third District Court of
Appeal Left Stay in Effect and Certified this Case to the Supreme Court of
Florida September-October 2008
PD-11
Unopposed Motion to Expedite Appeal
Appendix to Unopposed Motion to Expedite the Appeal
Public
Defender’s Motion to Dissolve Stay
Appendix
to Public Defender’s Motion to Dissolve Stay
State’s Response
to Motion to Dissolve Stay
Appendix
to State’s Response to Motion to Dissolve Stay
Office of Criminal
Conflict Counsel’s Motion to Intervene
Office of
Criminal Conflict Counsel’s Amended Objection to Dissolving the Stay
Pleadings in the Third District Court of Appeal, September 2008
PD's Response to
State's Emergency Motion for Stay
Appendix
to PD's Response to State's Emergency Motion for Stay
Public Defender’s
Suggestion for Certification of Case to Supreme Court of Florida
Appendix to PD's
Suggestion for Certification
Trial Court Order, September 3, 2008
Order on Motion to
Appoint Other Counsel
Written Closing Statements, Submitted After Evidentiary Hearing, August 2008
Public
Defender’s Closing Statement
State
Attorney’s Closing Statement
Orders and Subsequent Pleadings, July 2008
Circuit Court Administrative Order Consolidating PD-11’s Motions to Appoint
Other Counsel
State
Attorney’s Response to Motion to Appoint Other Counsel
Index to Appendix to State Attorney’s Response
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Exhibit L
Exhibit M
Public Defender’s Reply to State Attorney’s Response to Motion to Appoint Other
Counsel
American Council of
Chief Defenders (ACCD) Resolution Concerning Excessive Public Defender Excessive
Caseloads in Miami-Dade County, Florida June 5, 2008
Initial Pleadings by Public Defender, Eleventh Judicial Circuit of Florida, June
2008
Motion to Appoint Other Counsel Due to Conflict of Interest
Memorandum of Law in Support of Motion to Appoint Other Counsel
Appendix of
Exhibits Part 1 of 3.pdf
Appendix of
Exhibits Part 2 of 3.pdf
Appendix of
Exhibits Part 3 of 3.pdf
Notice of Hearing
on Motion to Appoint Other Counsel
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