Motion for Summary Judgment in KLUB VIBEZ, LLC vs DORTHY PARIS| Trellis.Law

On August 17, 2022 a Motion-Secondary was filed involving a dispute between and for NEGLIGENT SECURITY in the District Court of Gadsden County.

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Filing # 179213800 E-Filed 08/08/2023 05:15:50 PM

IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT
IN AND FOR GADSDEN COUNTY, FLORIDA

DORTHY PARIS, entitled to appointment
as the Personal Representative of the Estate
of DRAVON SHEFFIELD deceased, and on
behalf of the survivors of DRAVON
SHEFFIELD,

Plaintiff,

VS. CASE NO. 22000532CAA

KLUB VIBEZ LLC,

Defendant.
/

PLAINTIFF’S RESPONSE TO DEFENDANT’S
MOTION FOR FINAL SUMMARY JUDGMENT

COMES NOW, DORTHY PARIS, as the Personal Representative of the Estate of

DRAVON SHEFFIELD, deceased, and on behalf of the survivors of DRAVON SHEFFIELD,

there being genuine issue of material fact at dispute Defendant, KLUB VIBEZ, LLC, is not entitled

to summary judgment pursuant to Florida Rules of Civil Procedure.

Introduction

On October 11, 2020, Mr. Sheffield went to Klub Vibez to see a local rapper that had made

it big time, “Bobby Fishscale”. Klub Vibez booked Rapper Fishscale and advertised that he would

be holding a concert at Klub Vibez on October 10, 2020. Klub Vibez was fully aware that it did

not have sufficient parking to accommodate all of the people it was inviting to this concert, but

Klub Vibez knew that it could direct all of the overflow traffic across the street and direct people

to park in the Armory parking lot, since it was such a large parking lot, which was Klub Vibez
customary practice. At no time did Klub Vibez get Gadsden County’s permission to make use of

the parking for Klub Vibez’s commercial benefit or for any reason whatsoever.

Mr. Sheffield went to Klub Vibez for the concert and could not park in Klub Vibez’s

parking lot because it is an extremely small parking lot, with several spots being reserved for VIP

parking. Mr. Sheffield was directed to park in the parking lot across the street. Mr. Sheffield had

just arrived back at his car when he was shot while standing next to the driver’s side door

Klub Vibez did not provide any security or off duty law enforcement for the parking lot

where it directed its patrons to park or knew that its patrons parked. Klub Vibez was on notice that

this was going to be large event in Quincy and there had been a rash of violent shootings in Quincy.

Members of the community encouraged Klub Vibez to cancel the concert due to the violent crime

that was occurring in Quincy at the time. See attached Exhibits.!

Klub Vibez failed to warn its customers that they would not be providing security for the

parking lot where they directed their patrons to park or knew their patrons parked, and as a result

Mr. Sheffield was killed from this foreseeable shooting.

Defendant makes two primary legal arguments in support of its Motion for Final Summary

Judgment

1 Klub Vibez Had No Legal Duty to Plaintiff for Criminal Acts Committed off Klub

Vibez’s Premises.

2. Klub Vibez is Not Liable for the Unforeseeable Criminal Acts of Third Party

Plaintiff DORTHY PARIS, as the Personal Representative of the Estate of DRAVON

SHEFFIELD, deceased, and on behalf of the survivors of DRAVON SHEFFIELD, contends that

' Mikhial Murray Affidavit (Exhibit 1), Troy Lee, Jr. Affidavit (Exhibit 2); Quincy Police
Department Records Certification (Exhibit 3); and Quincy Police Department Criminal
Investigation Records (Exhibit 4).
KLUB VIBEZ, LLC had a legal duty to Plaintiff for criminal acts that occurred adjacent to their

property. KLUB VIBEZ, LLC was liable for the criminal acts of a third party

Statements of Facts

Statement of Mikhial Murray

1 My name is Mikhial Murray, and I am over 18 years of age

2. On October 11, 2020, I was with my cousin Dravon Sheffield, and we went to

Klub Vibes

When we arrive to Klub Vibes and attempted to enter the parking we were

directed to park in the lot across street by security

We parked in the parking lot and entered Klub Vibes, after the club was over, we

walked back across the street to enter our vehicle.

When we got our vehicle, we heard loud shots, and I looked over and realized that

my cousin was shot and not moving.

When I looked up, I saw people hanging out of a car with a gun speeding out of

the Gadsden county parking lot.

Statement of Troy Lee, Jr.

1 My name is Troy Lee Jr. and I am over 18 years of age

2. On October 11, 2020, I went to Klub Vibes with my cousin, it was supposed to be

a big party that brought everyone in the city out.

We were leaving the club and walked across the Street to the parking lot that

security told us to park in because the parking lot for the club was full when we

got to the club.
4. When we got in the by the car, some other car starting shooting at us in the

parking lot.

Standard of Review

Florida has adopted the federal standard for summary judgment as of May 1, 2021. See in

re Amend. To Fla Rule Civ. Pro. 1.510, No. SC 20-1490 (Fla. April 29, 2021).

Summary judgment pursuant to Rule 56 of the Federal Rules of Civil Procedure is

appropriate when the pleadings, affidavits, and depositions demonstrate that there is no genuine

issue as to any material fact. Celotex Corp. v. Catrett, 477 U.S. 317 (1986). A motion for summary

judgment must be denied where there is a genuine dispute of material facts. Anderson v. Liberty

Lobby, Inc., 477 U.S. 242, 106 S.Ct. 2505 (1986). “At the summary judgment stage, the trial

judge's function is not himself to weigh the evidence and determine the truth of the matter but to

determine whether there is a genuine issue for trial.” /d at 243. The burden of establishing that

there is no genuine issue of material fact is on the moving party. Clark v. Coats & Clark, 929 F.2d

604 (11 Cir. 1991). The evidence must be viewed in the light most favorable to the non-moving

party. Augusta Iron and Steel Works, Inc. v. Employers Insurance of Wausau, 835 F.2d 855, 856

(11th Cir, 1988). The non-moving party must respond by affidavits or as otherwise provided in

Fed.R.Civ.P. 56. “[T]he evidence of the non-movant is to be believed, and all justifiable inferences

are to be drawn in his favor.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 106 S.Ct. 2505,

2510, 91 L.Ed.2d 202 (1986). A genuine issue of material fact will be said to exist “if the evidence

is such that a reasonable jury could return a verdict for the nonmoving party.” Anderson v.

Radisson Hotel Corp., 834 F. Supp. 1364, 1368 (S.D. Ga. 1993).
ARGUMENT

Florida law imposes a nondelegable duty on those in control of any premises to maintain

the premises in a reasonably safe condition based on that particular premises. Atl. Coast Dev.

Corp. v. Napoleon Steel Contractors, Inc., 385 So.2d 676, 679 (Fla. 3d DCA 1980); U.S. Sec.

Services Corp. v. Ramada Inn, Inc., 665 So. 2d 268, 269 (Fla. 3d DCA 1995)(“Ramada had a non-

delegable duty to the plaintiff, as Ramada's business invitee, to provide the plaintiff with

reasonably safe premises, including reasonable protection against third party criminal attacks”).

“[A] cause of action for premises liability does not hinge on legal title or ownership, but

rather on the failure of the party who is in actual possession or control to perform its legal

duty.” Regency Lake Apts. Assocs., Ltd. v. French, 590 So. 2d 970, 974 (Fla. Ist DCA 1991)

(emphasis omitted); see Burton v. MDC PGA Plaza Corp., 78 So. 3d 732, 735-36 (Fla. 4th DCA

2012). The level of control and responsibility is a factual issue to be resolved by the

jury. Thompson v. Gallo, 680 So. 2d 441, 443 (Fla. 1st DCA 1996).

“Visitors upon the private property of others fall within one of three classifications: they

are either trespassers, licensees, or invitees.” Post v. Lunney, 261 So. 2d 146, 147 (Fla. 1972)

“The classification is important because it determines the duty of care owed the visitor by the

property owner or occupier. He must not willfully and wantonly injure a trespasser; he must not

willfully and wantonly injure a licensee, or intentionally expose him to danger; and, where the

visitor is an invitee, he must keep his property reasonably safe and protect the visitor from dangers

of which he is, or should be aware.” Post v. Lunney, 261 So. 2d 146, 147 (Fla. 1972) There are

two types of Invitees under Florida law:

(1) An invitee is either a public invitee or a business visitor.
(2) A public invitee is a person who is invited to enter or remain on land as a
member of the public for a purpose for which the land is held open to the public
(Emphasis supplied.)
(3) A business visitor is a person who is invited to enter or remain on land for a
purpose directly or indirectly connected with business dealings with the possessor
of the land. Id. at 148.

It may be that on the facts in a particular case the determination of the category of the

plaintiff must be determined as a matter of law by the trial judge, as in other cases in this respect;

other causes will present a factual issue for the jury as to whether plaintiff is invitee, licensee

or trespasser under appropriate instructions. Wood v. Camp, 284 So. 2d 691, 696 (Fla. 1973). The

question of status may very easily be a matter for the jury where the facts on such question are in

dispute. Id. The distinction is only present when there are material facts at dispute related to the

plaintiff's status at the time of injury. Lynch v. Brown, 489 So. 2d 65, 66 (Fla. 1st DCA 1986)

(Holding Under the circumstances, Lynch's status was that of an invitee unless competent evidence

is presented to dispute that Lynch was invited by the tenant, in which case his status would be a

disputed question of fact).

A. Klub Vibez had a Legal Duty to Plaintiff for the Criminal Acts That Occurred on
the Property Adjacent to Theirs That They Used for Their Benefit.

After finding that the pub owner knew that his patrons customarily used adjacent premises

for parking in order to patronize the pub, the court stated:

“An invitor's duty normally extends only to its “premises.” However, we recognize
that in this case “the premises” may not be limited to the area actually owned or
leased by the Pub because its business activities extended beyond its legal
boundaries

A duty of reasonable care may be extended beyond the business premises when it
is reasonable for invitees to believe the invitor controls premises adjacent to his
own or where the invitor knows his invitees customarily use such adjacent premises
in connection with the invitation. Here, the record supports a reasonable inference
the Pub knew its parking lot was insufficient for its patron's use; additionally, the
Pub was aware its patrons customarily used the parking lot across the street while
patronizing it. The initial confrontation occurred at the entrance to this lot, which
had similarly overflowed.” Bordav. E. Coast Entm't, Inc., 950 So. 2d 488, 491 (Fla.
4th DCA 2007).
Indeed, we are unconvinced either Ember or other patrons of the Pub lost their invitee status

while waiting outside the Pub's legal boundaries. In the recent case of Alholm v. Wilt (1984),

Minn. App., 348 N.W.2d 106, the occurrence of an assault in a public alley behind the tavern did

not bar the tavern's liability. The Minnesota Appellate Court found a reasonable inference of

foreseeability of the attack due to the aggressive conduct of the patrons involved preceding their

departure from the tavern. Ember, 490 N.E.2d 764, 772 (emphasis added).

Similarly, the evidence in the present case shows that appellants knew their patrons

customarily used adjacent premises for parking in order to patronize the Rodeo Bar. Friend, the

security guard, admitted at trial that he had “suggested” that bar patrons park at Ingram's Fruit

Stand, and a bouncer testified that the security guards instructed bar patrons to park elsewhere,

such as at the fruit stand. Thus, appellants had a duty not only to its patrons who parked on the

premises, but also to those who parked on the adjacent lots in accordance with the instructions of

the security guards. The jury could well have found that the Holiday Inn and the bar were, in effect,

utilizing the adjacent parking lots rent free for their own business purposes.

Udy v. Calvary Corp., 162 Ariz. 7, 780 P.2d 1055 (1989), also provides support for the

proposition that harm caused, in whole or part, by an activity or condition on a particular premises

cannot be viewed as unforeseeable as a matter of law merely because it happens to manifest itself

beyond the property line. In Udy, the evidence showed that the Udys had asked their landlord on

numerous occasions for permission to erect a fence around their mobile home lot to keep their

small children out of the busy street adjacent to their leased property. On each occasion, the

landlord refused permission. Through no fault of the parents, their small child was hit by a truck

after he chased a ball into the street. The parents brought an action against their landlord on their
own behalf and on behalf of their child to recover for personal injuries suffered by the child. The

trial court granted summary judgment for defendants.

On appeal, the Arizona appellate court reversed and held in part that a landowner's duty to

his tenants is not circumscribed by the physical boundaries of the landlord's property as a matter

of law. Id., 780 P.2d at 1061. The court stated:

“The fact that Georgie's injury occurred beyond the boundaries of the leased
premises may well be relevant in determining whether the Landlord acted
reasonably, but it does not compel the conclusion that the Landlord owed Georgie
no duty of care in the first place.” Id., 780 P.2d at 1060.

Additionally, the court held:

“Whether the Landlord acted in accordance with its duty to Georgie is a question
that must be answered within the context of all the facts and circumstances of this
case...” Id., 780 P.2d at 1062.

We have determined that an opinion by this court extending an invitor's duty beyond the

premises actually owned or leased where the invitor has extended its business activities beyond its

legal boundaries would not conflict with any existing Florida decisions. Holiday Inns, Inc. v.

Shelburne, 576 So. 2d 322, 329-30 (Fla. 4th DCA 1991), dismissed, 589 So. 2d 291 (Fla. 1991).

In fact, Holley v. Mt. Zion Terrace Apts., Inc., 382 So.2d 98 (Fla. 3d DCA 1980), by

analogy supports such a position. The defendant in Holley argued that its liability was foreclosed

by the fact that the assault and murder did not take place in a common area it had the duty to

maintain, but rather inside the victim's apartment. Since the basis for the plaintiff's case was the

almost undisputed fact that the intruder could have entered the apartment only through the common

walkway adjacent to the victim's window, the court stated that it was for the jury to determine

whether the defendant's alleged breach of duty as to the areas outside the apartment was a legal

cause of what happened inside. The jury in the instant case also properly determined the issue of

whether appellants’ alleged breach of duty on its premises a legal cause of the shooting off its
premises was. Holiday Inns, Inc. v. Shelburne, 576 So. 2d 322, 329-30 (Fla. 4th DCA

1991), dismissed, 589 So. 2d 291 (Fla. 1991).

Because a proprietor of a lounge is bound to use every reasonable effort to maintain order

among its patrons and that duty may be extended to outside the premises, if the proprietor knows

his patrons normally use the adjacent premises in connection with the patronage of the Lounge, as

was shown in this case, there is a duty of reasonable care. Borda v. E. Coast Entm't, Inc., 950 So.

2d 488, 492 (Fla. 4th DCA 2007)

The fact that this parking lot was operated by the city does not, in and of itself, distinguish

this case from Shelburne. Although the city could also be responsible, that would not absolve the

night club from liability for negligently advising its patrons to park there, when it knew or should

have known of the danger. Marinacci v. 219 S. Atl. Blvd., 855 So. 2d 1272, 1273 (Fla. 4th DCA

2003).
The case cited above makes it clear that Klub Vibez had a legal duty to its patrons that it

directed to park and separately based on the fact that Klub Vibez’s agents knew patrons normally

make use of the parking lot for Klub Vibez’s benefit.

? Whether it was foreseeable that the cause of action would arise 100-feet off premises in the public park next door
where the landlord had invited and encouraged its tenants to use for its business purposes, is a question going
to proximate causation for the trier of fact to decide. However, the fact that the incident occurred off premises does
not abrogate the Defendant of liability as a matter of law on the factually specific situation here. Whitt v. Silverman.
788 So. 2d 210, (Fla. 2001); Nova Southeastem University v. Gross, 758 So. 2d 86, 88 (Fla. 2000), Marinacci v. 219
Se south Atlantic Boulevard, 855 So. 2d 1272, (Fla. 4th DCA, 2003); Holiday Inns. Inc. v. Shelburne, 576 So. 2d 322
(Fla. 4th DCA, 1991); Wakefield v. Winter Haven Management, 685 So. 2d 1348 (Fla. 2nd DCA, 1996); Johnson v.
Howard Mark Productions. Inc. 608 So. 2d 937, (Fla. 2nd DCA, 1992).
B. Defendant _Undertook the Responsibility to Provide Security Services_and
Therefore is Responsible Under the Undertaking Case Law.

“A third group, which is more analogous to the one before this Court, is premises liability

cases involving a criminal attack by a third party where defendants include a security provider.

See Vazquez v. Lago Grande Homeowners Ass'n, 900 So.2d 587, 2004 WL 2823096

(Fla. 3d DCA Dec. 8, 2004)(estate of non-resident of condominium, who died as a result of

shooting at condominium development, brought action against three defendants, including the

entity which provided security); Wells Fargo Guard Servs.. Inc., of Fla. v. Nash, 654 So.2d 155

(Fla. 1st DCA 1995)(victim of attack in parking garage of hospital sued entity which provided

security services pursuant to a contract with the hospital), quashed by 678 So.2d 1262 (Fla.1996);

Williamsv. Office of Sec. & Intelligence, Inc., 509 So.2d 1282 (Fla. 3d DCA 1987)(tenant brought

suit against entity providing security for apartment complex where she was raped in her apartment

at the complex); Fincher Investigative Agency, Inc. v. Scott, 394 So.2d 559 (Fla. 34 DCA

1981)(bag boy at grocery store brought action against security provider where he was injured

during robbery at store).

Burns spends much of its analysis discussing the duty of a property owner in these premises

liability cases. However, an analysis of the security provider cases indicates that the duty that arises

in such cases has a different basis than the duty of a landowner, that being the duty to guard against

crime as a particular undertaking of the security provider to do just that

The third district's opinion in Vazquez is most persuasive. In Vazquez, suit was brought by

the estate of a visitor to a condominium complex and by a resident of the complex. The visitor was

shot and killed while visiting the resident, who was also injured in the incident. Both the

condominium association and the security company were defendants. A jury verdict was returned

in favor of the plaintiffs; however, the trial court entered a judgment notwithstanding the verdict

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in favor of the defendants. The trial court's granting of the judgment notwithstanding the verdict

was based on the fact that there was no evidence presented by the plaintiffs of prior crimes. The

trial court concluded that such evidence was required in order to impose liability.

In reversing the trial court, the third district distinguished the responsibility of a landowner

to exercise reasonable care to secure its tenants from criminal activity from the duty owed by a

security company which has undertaken to secure the premises from criminal activity

In doing so the court stated:

“Tn the situation in which a duty to prevent harm from criminal activity arises only
as an aspect of the common law duty to exercise reasonable care to keep the
premises safe, prior offenses, giving rise to the foreseeability of future ones, may
be deemed indispensable to recovery. In contrast, the duty to guard against crime
in this case is founded upon particular undertakings and hence obligations of the
defendants to do so. As to this well-recognized, and entirely separate, basis of
liability, prior-offenses evidence is not necessary. This is simply because such a
requirement is entirely superfluous to the fundamental basis of the underlying claim
itself. “

C. The Violence Committed against Plaintiff
was foreseeable.

The application of the foreseeability test to intervening causes is normally the

responsibility for the trier of fact. Smith v. Grove Apartments, LLC, 976 So. 2d 582, 589 (Fla. 3d

DCA 2007).

Proximate causation may be determined as a matter of law. See DZE Corporation _v.

Vickers, 299 So. 3d 538, 540 (Fla. Ist DCA 2020) (“Generoso’s_criminal conduct was the sole

proximate cause of Appellees’ injuries as a matter of law.”); KJB Village Property, LLC v. Craig

M. Dorne, P.A., 77 So. 3d 727 (Fla3d DCA 2011) (“Proximate cause may be determined as a

matter of law where the evidence supports no more than a single reasonable inference.”).

The Florida Supreme Court offered a definition of “proximate cause” in McCain v. Florida

Power Corp., 593 So. 2d 500, 503-4 (Fla. 1992). In McCain, the Court stated, “harm is ‘proximate’

11
if prudent human foresight would lead one to expect that similar harm is likely to be substantially

caused by the specific act or omission in question...human experience teaches that the same harm

can be expected to recur if the same act or omission is repeated in a similar context.” McCain v.

Florida Power Corp., 593 So. 2d 500, 503-4 (Fla. 1992).

The Florida Supreme Court has stated that proximate causation is established “if prudent

human foresight would lead one to expect that similar harm is likely to be substantially caused by

the specific act or omission in question.... However, . itis immaterial that the defendant could not

foresee the precise manner in which the injury occurred or its exact extent.” Smith v. Grove

Apartments, LLC, 976 So. 2d 582, 588 (Fla. 3d DCA 2007).

Florida Courts have long held that foreseeability can be shown by establishing that the

defendant had actual or constructive knowledge of third-party crime on their premises. Hall v

Billy Jack’s, Inc., 458 So.2d 760, 762 (Fla. 1984). Florida Courts have also held that evidence of

crimes and police call logs are admissible and pertinent to determining foreseeability of third-party

crime. Paterson v. Deeb, 472 So. 2d 1210 (Fla. 1 DCA 1985). See also Czerwinski v. Sunrise

Point Condominium, 540 So. 2d 199, 201 (Fla. 3d DCA 1989).

Evidence of “lesser” prior crimes is also probative when determining foreseeability. Hardy

v . Pier 99 Motor Inn, 664 So. 2d 1095 (Fla. 1‘ DCA 1995).

Crimes against both persons and property are relevant to the issue of foreseeability, even

if the acts are lesser crimes than the one committed against the plaintiff. Czerwinski, 540 So. 2d at

201. Additionally, the law does not require “that the prior crimes occur at the same location, on or

about the premises, as the subsequent crime in order to be relevant to the foreseeability of the

later crime.” Id.; Paterson, 472 So. 2d 1210 (holding that evidence that the neighborhood was

experiencing a substantial number of breaking and entering’s was relevant to the foreseeability of

12
sexual attack on tenant). A specific violent criminal assault is foreseeable merely because prior

criminal acts have occurred. McCord v. Sentry Prot., Inc., 427 So. 2d 1132, 1133 (Fla. 5th DCA

1983)
Here, Klub Vibez was operating a nightclub at the time when there had been several

murders in Quincy related to ongoing gang feuds in Gadsden County. The gang feuds and the

resulting shooting were well known to the residents and business owners in Gadsden County.

D. Survivor, Dorthy Paris, is entitled to Recover for Mental Pain and Suffering From
the Date of Loss.

Florida Statute 768.21(4):

Each parent of a deceased minor child may also recover for mental pain and
suffering from the date of the injury. Each parent of an adult child may also recover
for mental pain and suffering if there are no other survivors.

Here, Dorthy Paris is entitled to recover for mental pain and suffering from the date of

injury

CONCLUSION

For the foregoing reasons, DORTHY PARIS, as the Personal Representative of the Estate

of DRAVON SHEFFIELD, deceased, and on behalf of the survivors of DRAVON SHEFFIELD,

by and through his undersigned counsel requests that this Court deny Defendant’s Motion for Final

Summary Judgment pursuant to Rule 1.510 of the Florida Rules of Civil Procedure and any other

relief the Court deems just and proper.

13
Respectfully submitted,

/s/ LOUIS J. BAPTISTE
LOUIS J. BAPTISTE, ESQUIRE
FBN: 126082
Primary E-mail: lb@websterandbaptiste.com
Secondary E-mail: jw@websterandbaptiste.com
WEBSTER + BAPTISTE
ATTORNEYS AT LAW, PLLC
1785 Thomasville Road
Tallahassee, FL 32303
T: (850) 597-7142
F: (850) 848-4655
ATTORNEY FOR PLAINTIFF

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing instrument has been
furnished via e-mail to all parties listed in the Florida Courts E-Filing Portal this 8" day of August,
2023.

/s/ LOUIS J. BAPTISTE
ATTORNEY

14
Exhibit 1
AFFIDAVIT

My name is Mikhial Murray, and | am over 18 years of age.

On October 11, 2020, | was with my cousin Dravon Sheffield, and we went

to Klub Vibes.

When we arrive to Klub Vibes and attempted to enter the parking we

were directed to park in the lot across street by security.

We parked in the parking lot and entered Klub Vibes, after the club was

over, we walked back across the street to enter our vehicle.

When we got our vehicle, we heard foud shots, and | looked over and

realized that my cousin was shot and not moving.

When | looked up, | saw people hanging out of a car with a gun speeding

out of the Gadsden County parking lot.

Mikhial Murray
STATE OF FLORIDA

COUNTY OF LEON

PERSONALLY APPEARED BEFORE AT the under ed authority, duly authorized to
take acknowledgment d administer oaths, Vikhial Murray aft first being duly sworn on c h.
depo: and says: that he is the individual described in and who executed the above and fe on
document, the statements contained there are true and correct and is personally known to or
has produc 1, and has/has not taken an oath.

WITNESS my hand and official seal in the County and State last aforesaid this _
day of Augu 202.

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Mikhial Murray Affidavit
Final Audit Report 2023-08-03

Created: 2023-08-08 :
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Status: Signed
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"Mikhial Murray Affidavit" History
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Exhibit 2
AL IDAVIT

My name is Troy Lee Jr. and | am over 18 years of age

On October 4 2020, | went to Klub Vibes with my cousin, it was

supposed to be a big party that brought everyone in the city out.

We saw security and police in front of the club.

4 We were leaving the club and walked across the Street to the parking lat

that security told us to park in because the parking fot for the club was

full when we got to the club,

When we got in the by the car, some othe ar Starting shooting at us in

the parking lot.

fgg
Troy Lee Jr,

STATE OF FLORIDA

COUNTY OF LEON

PERSONALLY APPEARED BEFORE ME, the undersi ned authority. duly authorized to
take acknowledgments and administer oath Lee Jr. after first being duly sworn on oath,
depases and sa that he is the individual deserib: -d in and who executed the above and foregoing
document. the statements contained therein are true and correct and is personally known to me or
has produced, and has/has not taken an oath

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day of August 2023

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Troy Lee Jr. Affidavit
Final Audit Report 2023-08-07

Created: 2028-08-03

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"Troy Lee Jr. Affidavit" History
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E, Document emailed to stophatingontroyS9@gmail.com for signature
2023-08-03 - 3:47:40 PM GMT

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2023-08-07 - 10:03:36 PM GMT- IP address: 68.59.78.217

@ Document e-signed by Troy lee (stophatingontroyS9@gmail.com)
Signature Date: 2023-08-07 - 10:03:38 PM GMT - Time Source: server- IP address: 68.59.78.217

& Agreement completed.
2023-08-07 - 10:03:38 PM GMT.

Adobe Acrobat Sign
Exhibit 3
Records Certification
THEREBY CERTIHY that I am the Public Records Custo
dian for Quincy Police Department.
I HEREBY CERTIHY that the attached are true and
correct copies of the originals thereof in my
custody as part of th official records of this offi ice related
to Dravon Sheffield.
IN TESTIMONY WHEREOF IJ have hereunto caused the
seal of the office to be affixed and my
name to be subscribdd.

Name Qn
—
YW 4fbren
Date Slx20h 3

Signature Pinte M Athan,

Notary Public State of Florida
q a Admetric Jones Moore
My Commission HH 362139
TH
Expires 3/25/2027
——s

sla 3
Exhibit 4
QUINCY POLICE DEPARTMENT PAGE 4 oF ——
VEHICLE RECEIPT FE EFE
DATE, DAY,“ TIME IMPOUNDED / TOWED INVENTORY NUMBER
ADDRESS OR EXACT LOCATION WHERE VEHICLE IMPOUNDED
{6SAY
ADL OCB
LD
i =
405 fi J
A gtd, tit h3 Liu Links opulrmte—>
WHERE VEHICLE WILL BE STORED
me
LL KOCATION OF KEYS

copes: v= VICTIM = OWNER = SUSPECT R= REPORTING PERSON P = DISCOVERING PERSON
Code | Name (Last, First, Middle) Race sex] Date of Birth | Address Phone Number(s)

iv ce 86 8. Kamion AD
(kina, Msndi i ‘ 1g LATE AA, EL 2A 33

|
VEHICLE INFORMATION
C ) NIA ( YT ventete TAG eer,
DG. STATE OF if STYLE
( ) SUSPECT
) victim
( ) MOTORCYCLE HO« EL MODEL
26‘Ay nm 7
Y-DA
¢ ) OTHER ee
e: |1 £ Le,
VEHICLE SECURED: RADIO EQUIPMEN BATTERY, TIRES:
( ) Yes ) NO J Yes ) NO MILEAGE
( ) Yes ¢ ) NO (77) ves { ) NO
VEHICLE (VIN) NUMBER TT aE TORE OF PRIVER
LCIZESSESHPAIAGSD Lg AING/ j jp fee
ESTIMATED VEHICLE VALUE: $ } oo Z
mon, SPECIAL FEATURES i
BODY DAMAGE. 2 minreotass_2) ¢ 2 | xf i ry 0 " 2 8 4 1]
BODY PARTS MISSING. t
RUSTIPRIMER 7
16
WINDOW DAMAGE STRIPESISCENES.
io 5
\\ * 3]
WINDOW MISSING. ee FOGISPOT LIGHTS
DECALIPLAQUE/STICKER OTHER,
7 6
PROPERTY LEFT IN VEHICLE
DESCRIBE ANY PROPERTY LEFT IN VEHICLE, INCLUDE QUANTITY
tries. big

we
=
HOLD ON VEHICLE: YES ( PURPOSE OF HOLD RELEASE DATE
) NO( | NCIC CHECK: YES() NO()
SIGNATUREEOFSEiziN
S-thindg
R&D NO, ‘SIGNATURE OF PERSON RECEIVED FROM
aS fe Z 3 a poa/D
re
od
‘SUPERVISOR SIGNATURE FOR AHOLD ORLY, Z
i v4
eT 15% ud eet
oo
et
THE ABOVE VEHICLE AND PROPERTY HAVE BEEN-RELEASED TO ME AND | FOUND THE CONDITION TO BE AS INDICATED
ABOVE.
SIGNATURE OF PERSON RELEASED TO
VEHICLE ( ) PROPERTY ( ) DATE & TIME.
WHITE: Evidence CANARY: Communications RINK” Parnele Rar nena = fa =
oat 8
QUINCY POLICE DEPARTMENT 4
PAGE atin OF ——
PROPERTY RECEIPT CASE NUMBER

TYPE OF CRIME OR INCIDENT DATE, DAY & TIME SEIZED PROPERTY NUMBER BIN

ADDRESS OR EXACT LOCATION WHERE PROPERTY SEIZED

TYPE OF PROPERTY: PHYSICAL EVIDENCE ( ) PERSONAL PROPERTY ( ) RECOVERED PROPERTY ( ) FOUND PROPERTY ( )
CODES: V= VICTIM = OWNER S= SUSPECT R= REPORTING PERSON P = DISCOVERING PERSON
Code | Name (Last, First, Middte) Race Sex Date of Birth Address | Phone Number(s)

SEIZED EVIDENCE ONLY
ITEM NUMBER, | QUANTITY DESCRIPTION (MAKE, MODEL NUMBER, SERIAL NUMBER)

i
FORWARD TO LAB: YES ( ) NO ( ) IF YES, ITEM NUMBER (S)
SIGNATURE OF SEIZING OFFICER & ID NO. SIGNATURE OF PERSON RECEIVED FROM

SIGNATURE OF PERSON RELEASED TO DATE RELEASED [TIME RELEASED
TERM(S) RELEASED, BY (TEM NUMBER PURPOSE / DISPOSITION
|
SIGNATURE OF PERSON RELEASED TO DATE RELEASED TIME RELEASED

TEMM(S) RELEASED, BY ITEM NUMBER | PURPOSE / DISPOSITION

PROPERTY SECTION
LAB NUMBER DATE SUBMITTED DATE RETURNED

J RECEIvEr IN PERSON ( ) EVIDENCE LOCKER ( ) IMPOUND YARD ( ) OTHER ( )

RECEIVED WITH SEAL: BROKEN ( ) INTACT ( ) SEAL: NOT BROKEN ( ) BROKEN BY RECEIVER ( ) EVIDENCE RESEALED: YES ( ) NO ( )
PROPERTY OFFICER DATE COURT CASE NUMBER CASE CLOSED DATE
anceneman ori
QUINCY POLICE DEPARTMENT PAGE 4 oF
VEHICLE RECEIPT CASE NUMBER
vn we i
s zB, < € C2 FL
TYPE OF CRIME OR INCIDENT DATE, DAY & TIME IMPOUNDED / TOWED INVENTORY NUMBER
.
ee a
2d v =
ADDRESS OR EXACT LOCATION WHERE VEHICLE IMPOUNDED 7
i

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Document Filed Date

August 08, 2023

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