Legal Document: JONES, TICHNIA vs LAMAR COMPANY LLCNotice of Appeal of:

On September 29, 2017 a MOTION TO - FOR - APELLANT MOTION TO REVIEW EVIDENCE FACTS IN CASE was filed involving a dispute between Jones, Robert, Jones, Tichnia, and Lamar Company Llc, for Civil in the District Court of Hillsborough County.

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IN THE THIRTEENTH CIRCUIT COURT FOR
HILLSBOROUGH COUNTY, FLORIDA CIVIL APPELLATE DIVISION

T1CH1N1A JONES,
Appellant
Civil Appeal number: 17-CA_98 fa
Division -X :U
VS. as -;
41r..' 1-
no -4:53
LAMAR COMPANY, LLC, 29
-3
Appellate Co: r"""'5 C O
»§ _____ "'i"f

-so .333
APPELLANT MoTIoN~TQ REVIEW EVIDENCE FACTS IN CACSE ~:

In this Appellate Opinion it talk's about June 13, 2017, Lamar did
received an judgment was issue With=out prejudice which mean Jones can legal
retile the complaint with different case number.
On June 13, 2017 evidence fact's attorney fee was not establish and did not show
any entitlement Attached-A. Afterwards, on July 24, 25, 2017 evidence fact's Ms.
Jones the prevailing party trial court entered Judgment for Jones to take possession
of it's rental property due to Lamar failure respond to refilled Eviction Summons
Compliant trial court having Lamar to vacate rental premises which at this time
Lamar has been Evicted for over 55-days into September 18, 2017 before. Eviction
was removed and set to side Attached- B.
On September 14, 2017 evidence fact's during the Eviction time, trial court
determined attorney fee edge ability and the amount of fees at evidentiary hearing
which landlord Agent attend by this time contract remained Terminated, therefore
the evidence facts show attorney fees cannot be applied on September 14, 2017 for
September 25, 2017, judgment with clearly Voided contract cannot be enforced.
SEE: 159 So.3d 953
District Court of Appeal of Florida,
Fifth District.
The BANK OF NEW YORK MELLON, etc., Appellant, v. Hector B/IESTRE, etc.,
et. al., Appellees [1] no authority existed to so p award
in favor of mortgagors, notwithstanding prevailing party I provision in
mortgage, and

[2] award was not appropriate under the inequitable conduct doctrine.
,f

Reversed.

Which this judgment Jones timely appealed, and Jones is request an Reversal of
this judgment.
Although, talk about prevailing party in contract, there is [n]o such language
writing about if an party prevail in civil litigation the prevailing party will be
entitle to recover attorney fee for any civil litigation involving contract [n]o such
language, Attached-C
Attorney fee: provision must clearly be read, Such as: In the event any litigation
arise out of breach this contract the prevailing party shall be entitled to recover
reasonable attorney fees and costs, there is no such language in this
contract in which judgment was timely appeared, Md court' erred in finding
such prevailing party language writing words in contract on September 14, 2017.
In paragraph #9 fact's in contract LES SEE/ Jim Mashas/Tenant/Lan1ar/ agree to
indentify LESSOR/Ms. Jones/Landlord from [A]LL claims of injury and
damages, including cost and expenses, including ATTORNEY FEESIOLESSOR
/Ms. Jones/Landlord. Ms. Jones is not to be punish for any attorney fees protected
by paragraph #9. With no element requirement, Ms. Jones is Not third party, This
contract was timely appealed the writing in the contract clearly read both parties or
Hee Rom attorney fees- this. is an. none prevailingparty contract, this is Bias to
charge Jones attorney fees and there- is- evidence Jones. state about these attorney
fees are fake not real fee and made-up requesting trial court to dismiss these fake
charges attorney fees serial DISPUTE'S about attorney fees this is why the appeal
was Hled for attorney fees cannot be all of fees that the Md court did
err under the law and showing' Md courityyhat an attorney fee provision looks.
Attached-D.
Also, there is talk about Ms. Jones not appear at evidentiary hearing, yes
Landord Agent did appear which has povsig attorney toile fend [a]ny issues
the rental property and colleqtrgnt payment'"s and enforce contract according to Fla
Statute Chapter 83 section.-Q6, ach and every time landlord Agent was denied,
this landlord Agent is the person go mns and operate the. rental property.

Although, there was two party's to on tract sign other party Jim Mashas/tenant did
not appear to evidentiary hearing on' Q9/1 4/2017, counsel cannot be a witness for
it's client signature on contract, md 'ow erred by not dismiss' Jim Mashas/Lamar
for attorney fees edge ability ~trial court dismiss Jones' claim for late
fees and Jim Mashas have not appegij pot one time of any hearing, but md court
accepted the contract with-out witness, trial court could not question Jim
Mashas rather he or not sign contract, Jim Mashas did not attend contract signing
day on 09/27/2016 he sent has employee, trial court do not have verification, this is
call Bias. There are serial grounds for Jones' fearful there were not going to have a
fair trial with this Judge, Jones' tiled Affidavit under Fla. Statute Chapter 38
section 10 for Judge to recusal himself Judge relilse this was timely appealed,
Attached-F
SEE: 530 So.2d 1107 District Court of Appeal of Florida,
Third Distdct.
Norman FUNT, Esquire, Linda Koenigsberg, Esquire, and Luis Stabinski &
Associates, P.A., f/k/a Stabinsld & Fust, P.A., Petitioners,
v.
Honorable Joseph NADLER, as of the Eleventh Judicial Circuit Court, in
and for Dade County, Florida and Maria Valero, Respondents.

Petitioners moved to disqualify trial M basis of ~. The Circuit Court for
Dade County, Joseph M. Nadler, J., to disqualify himself, and litigants
petitioned for Writ of certiorari. The District Court of Appeal held that where a trial
.us- ,»;,.makes parties aware of circumstances that might raise questions as to his
ability to be impartial, and spontaneously commits to himself on a motion of
a party, a Subsequent and timely motion for must be granted.

Remanded.
This judgment was timely appeal by Jones' requesting an Reversal of Judge rent.

About the Rule 1.540 which was filed and when We call Judge Williams
office has secretary she refused to set a court date and said they do not have control
over the case, for me to Wait on the appeal, and you can check the call record and
see Jones call Judge office direr time's trying to get a court date she denied me all
three times including Jones tried to set a COM date for court cost she talk rude real
fast and would not give Jones a court date, if you check the record you see .Tones
never had a court date you will see the request for court date but you will not see
court date set, the only time Jones can go to court when Lamar filed for an court
hearing, this is Bias. All Florida Laws applies to proteetall Florida tax payer's.

COPY SENT: JULIE L. BALL
P.O BOX 3604
LAKELAND, FLA, 33802
SELF-REPRESENTED LITIGANTS (PRO SE)
TICHINIA JONES OR ROBERTJONES
PLO BOX 89832 Tampa, Fl, 33689
Funt v. Nadler, 530 So.2d 1107 (1988)
13 Fla. L. Weekly 2203

=Nature and Effect in General
530 So.2d 1107
District Court of Appeal of Florida, Teal juageas action warranted disqualification
Third District. where trial jiiilge looked beyond legal
sufficiency of verified motion for
Norman FUNT, Esquire, Linda Koenigsberg, disqualification and challenged truth of motion's
Esquire, and Luis Stabinski &Associates, PA., allegation of bias.
f/k/a Stabinski & Fund, PA., Petitioners,
v.
Honorable Joseph NADLER, as Judge of the Cases that cite this head note
Eleventh Judicial Circuit Court, in and for Dade
County, Florida and Mama Valero, Respondents.

No. 88-832.

Sept. 20, 1988. Attorneys and Law Firms

*I l 07 Stephens, Lynn, Klein& McNicholas and Debra J.
Snow and Robert M. Klein, Miami, for petitioners.
Synopsis
Petitioners moved to disqualify trial judge on basis of Robert A. Ginsburg, Co. Arty., and Roy Wood, Asst. Co.
liiiis. The Circuit Court for Dade County, Joseph M. Arty., for respondent, Joseph Nadler.
Nadler, J., to disqualify himself; and litigants
petitioned for writ of certiorari. The District Coup of Daniels and Hicks and Joseph C. Brock, Miami, for
Appeal held that where a trial juii§é makes parties aware respondent Maria Valero.
of circumstances that might raise questions as to his
ability to be impartial, and spontaneously commits to Before HUBBART and FERGUSON, JJ., and COWART,
rgécgise himself on a motion of a party, a subsequent and JOE A., Jr., Associate Jinee.
timely motion for must be granted.
Opinion
Remanded.

PER CURIAM.

West Head notes (2)
111 Where trialjudge makes the parties aware of
circumstances that might raise a question as to his ability
to be impartial and spontaneously commits to refuse
UI Jlidgéii himself on a motion of a party, a subsequent and timely
S=Deter.mination of Obi actions
motion for iieeusiil must be granted. It is held in such
cases that the invitation to make the motion *Ill speaks
louder than a subsequent disclaimer of bias. Pismrino v.
Where trial judge makes parties aware of
Ferguson, 386 So.2d 65 (Fla. 3M DCA l980).
circumstances that might raise a question as to
his ability to be impartial, and spontaneously
121 Further, the trial judge exceeded the proper scope of
commits to recluse himself on motion of a party,
subsequent and timely motion for lfécusal
inquiry when he looked beyond die legal sufficiency of
must be granted.
the verified motion for disqualification and challenged the
truth of the was allegation. That action alone would
warrant disqualification. Bu/7a§= v. Rudd, 366 So.2d 440
2 Cases that cite this head note (Fla.l978). Mc:/mgement Corp. of Am. v. Grossman, 396
So.2d 1169 (Fla. 3M DCA l98l).

Because we grant the petition for writ of prohibition, the
post-motion order setting the cause for a jury trial must
121 Judg ¢;5 also be reversed.Sfimpson Compiling Scale Co. v. Knzzck,
'42; f
James V. Theo bald, 557 So.2d 591 (1990)
15 Fla. L. Weekly D215

557 So.2d 591
District Court of Appeal of Florida,
Third District. Attorneys and Law Firms

Charles C. JAMES, M.D., and James Medical *592 Horton, Perse & Ginsberg, and Arnold R. Ginsberg,
Center, P.A., a Florida Professional Association, Miami, and William Huggett, and Anna Scomavacca,
Appellants, Coral Gables, for appellants.
V_
Karen THEOBALD, Appellate. Cooper, Wolfe & Bolo tin, and Sharon L. Wolfe, Miami,
and Sims, Purdy, Weiss and Weinstein, and Jay S. Weiss,
No. 88--3058_ LeKach & Klitzner, and Craig Lekach, Fort Lauderdale,
for appellate.
Jan. 1é, 1990.
Before COPE, LEVY, and GERSTEN, JJ.
Rehearing M85 March 30,1990.
Pinion

Synopsis GERSTEN, Judge.
Patient brought medical malpractice action against
physician and medical center for injury to her finger
resulting from removal of wart. The Circuit Court, Dade This is an appeal from the denial of a motion for a new
County, Jon Gordon, J., entered directed verdict of trial on liability and damages in a medical malpractice
liability and jury awarded damages. Defendants appealed. action. We reverse.
The District Court of Appeal, Gersten, J., held that
recusal motion and supporting affidavits were legally Appellee, Karen Theo bald, brought the underlying action
sufficient, requiring judge to grant motion. for malpractice against appellants, Charles James, M.D.,
and James Medical Center, P.A., for an injury to her
Reversed and remanded with kxstructions. finger resulting Hum the removal of a wan. This
straightforward case was complicated by the withdrawal
of appellants' first attorney, the pro se appearance of
appellant Dr. James, on behalf of himself and the P.A.,
and the hospitalization of the appellants' ultimate
West Head notes (1) attorney, which caused several continuances and
prevented appellants loom obtaining discovery.

ll] J\i§lgeS The trial judge resisted further continuances. When the
4»==Sufficiency of objection, affidavit, or motion appellants' attorney was hospitalized on the eve of a
scheduled trial, the trial itidge, in apparent disbelief of the
motion and supposing affidavits were attorney's illness, telephoned the attorney's physician to
legally sufficient, requiring judge to grant ask whether the attorney was actually ill. Grudgingly, the
motion; motion included affidavits alleging trial court reset the trial, but advised the litigants that no
jijilgéis against parties' attorney because further continuances would be granted. However,
attorney had represented client who had sued appellants' attorney notified the com, in writing and by
jiiilgg while judge was in private practice and the presence of an associate, that appellants' attorney had
parties also included requisite affidavit that a conflict with a previously scheduled com appearance in
motion had been made in good faith. West's Jacksonville, for an older case. The trial court refused to
F.S.A. RCP Rule l.432(d); West's F.S.A. continue the case.
38.10.
Prior to the last set trial date, appellants filed a motion for
the recusal of the trial judge. The motion included
2 Cases that cite this head note affidavits which alleged that the jiulge was biased against
appellants' attorney because the attorney had represented

~wf .el'f
James v. Theo bald, 557 So.2d 591 (1 990)
15 Fla. L. Weekly D215

a client who had sued the judge, while the judge was in proceeding makes and tiles an
private practice. Together with the motion, appellants also affidavit stating that he fears he
included the requisite affidavit that the motion had been will not receive a fair trial in the
made in good faith. court where the suit is pending on
account of the prejudice of the
Immediately poor to the beginning of trial, the court judge of that court against the
denied the motion, stating: applicant or in favor of the adverse
pony, the judge shall proceed no
I have reviewed this motion for further, but another judge shall be
disqualification. have reviewed designated.. [Emphasis added].
the motion and I believe it is not
legally sufficient. The grounds are The purpose of this section is to free tribunals from bias
not legally (sic) and/or they have or prejudice. Suarez v. Stale,95 Fla. 42, 115 So. 519
been otherwise waived. (1928). Judges have no discretion once the legal
requirements have been met. The facts alleged in the
The trial commenced as scheduled with neither appellants motion for disqualification must be taken as true, Gieseke
nor their attorney present. Appellee put on her case, and v. Grossman, 418 So.2d 1055 (Fla. 4th DCA 1982),
the deposition of Dr. James was read into the record. The Raybon v. Bzzrnelle, 135 So.2d 228 (Fla.l961), and if
court then entered a directed verdict of liability and the legally sullicient, the judge must disqualify himself As
jury awarded the appellate $259,000 in damages. A motion the Florida Supreme Court enunciated in Hays lip:
for a new trial was denied and this appeal ensued.
Every litigant is entitled to nothing
Rule 1.432, Florida Rules of Civil Procedure, addresses less than the cold neutrality of an
the disqualification ofjildges. Subdivision (d) provides: impartial judge. It is the duty of
Courts to scrupulously guard this
The judge against whom the right and to reliain from attempting
motion is directed shall determine to exercise jurisdiction in any
only the legal sufficiency of the matter where his qualification to do
motion. The judge shall not pass so is seriously brought in question.
on the truth of the facts alleged. If
die motion is legally sufficient, the Hays lip v. Douglas, 400 So.2d at 557 (quoting Stale ex
judge shall enter an order of rel. Davis \/_Parks, 141 Fla. 516. 194 So. 613, 615
disqualification, and proceed no (l939)).
further in the action. [Emphasis
added] We find that the motion and supporting affidavits were
legally sufficient, and the proper procedure, in light of the
To determine whether a motion to disqualify a judge is serious allegation of bias, was for the judge to grant the
legally suiiicient, the court must first tom to the literal motion. We also find, based on the circumstances of this
requirements of rule 1.432, Florida Rules of Civil case, that the motion was timely filed. Because we decide
Procedure and section 38.10, Florida Statutes (1987). that a new trial is in order, we do not address appellants'
/~/Q):.s'/Ip v. Doug/as, 400 So.2d 553 (Fla. 4th DCA 1981). other contentions.

in order to disqualify a judge for prejudice, section 38. l 0, Accordingly, we reverse and remand with instructions
Florida Statutes requires an affidavit be filed with the that the case be reassigned to another judge for a new
court that states the facts and the reasons for the belief trial.
that bias or prejudice exists, and that an accompanying
certificate of counsel of record also be tiled to the effect
that such affidavit and application are made in good faith.
The motion in this case complied with these requirements. All Citations

*593 Section 38. 10, Florida Statutes also provides: 557 So.2d 591, 15 Fla. L. Weeldy D215

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xx

IN THE couNtY COURT IN AND HILLSBORUGH COUNTY Division CIVIL

ROBERT JONES

PLAINTIFF

DIVISION L

vsnsus CASE 17-CC-012407
cn
rn
THE LAMARCOMPANY, L. L. C, 82:
¢C> =<
38 523
DEFENDANT °':-:
.§'z EE
"I
4.- =o
AFFIDAVITS .|.~

REQUEST REVIEw ON CASE
Under Florida Statutes Chapter 38 Section 10

This hearing took place on June 2, 2017 was set for a foal hearing with
>Honorab1e Juddb t A-1 which is the contracte Michael s. Williams.

After reviewing Exhibit A and Exhibit t with The Lamar

Company Lessee/Jim Mash ray and an Lesser/Tichinia Jones the property owner these
are the two parties to the contract that is on record as you view Exhibit A-1 of the
contract signing as the Lessee name is Jim Mashra he signs this contract.
Jim Mash ray did not appear in person in court on June 2_ 2017, this is the defense
who dm not appeared, the one witness wh ho did appear was Rich Behrle is
defense Exhibit-B Rich Behrle and his
general manager name is Jim Mash ray,
nine is not sign on this contract, being the g
ads 'm paragragh.12 on the contact stat es General Manager must sign contract for
binding, thé1eforé Jim Mash ray must a pear in person to be cross-examine by the
4.

same procedural defect [N]O contract witness in court available which is defense
witness Jim Mash ray failure to appear,Julie Landrigan Bawl is defense attorney
which is a license attorney was told by the court to bring her witness also she failed
to have her witness present in court, also contract contain two parties was
instructed to be there in court not just one witness to the contract.
Commercial Property Agent Rob Jones is sending a copy to the administration to
prevent this final judgment for being taking place have this error be reviewed and
stop by another Judge as are other rulings of the trial court that took place.
Judge Michael S. Williams was very Bias and showed favor to The Lamar
G°m Y~
"caemrcial Property Agent Rob Jones is requesting a continuance to be Re-
Granted for the second oral motion Agent Rob Jones requested time to review the
defense attorney cases search list which defense attorney presented at the trial
which Judge Michael S. Williams Denied that continuance request for no reason
and did not have a reason when Agent Rob Jones ask him for one reason.
Defense attorney gave her own opinion not the Fla. Statute Law but her on
personal opinion on how she believe that Commercial Property Agent Rob Jones , us

cannot present evidence at trial level when there is no such Florida Law Statute at
Commercial status level states such of thing, Agent Rob Jones told Judge that's
"not right what she Said, but Judge Michael S. Williams said "Pm not sure if that's
right or not but I will put that in my notes write that down also," If Judge Michael
S. Williams was not sure of her opinion that she made up, then he had a reasonable
of doubt to believe the attorney, but Judge Michael S. Williams show The Lamar
Company attorney favor again.
Judge Michael S. Williams took what defense attorney said to block and prevent
Agent Rob Jones loom presenting evidence at trial once more bias.
Rule 2.160 (d) sets forth the following bases for a disqualification motion, at least
one of which must be shown in the motion: 1. That the party fears that he or she
will not receive a fair trial or hearing because of specifically described prejudice or
bias of the Judge.

WHEREFORE, The Plaintiffs' respectfully requests that the Court enter an
order disqualifying the Judge Michael S. Williams over this cause and providing for
the reassignment of the case to another Judge of this Court, all in accordance with
section 38.10, Florida Statutes and Rule 2.160 of the Florida Rules ofJudiciaI
Administration. in addition, the plaintiffs ask the court to hold evidence and to
protect the information contained within it until this motion is resolved.

CQMMBRCIAL PROPERTY/

AGENT

SENT COPY TO:
JULIE LANDRIGAN BALL, ESQUIRE
P;O BOX 3604
LAKELAND, FL 33802
'i

IN THE COUNTY COURT IN AND HILLSBORUGH COUNTY CIVII_DiVi$iQn

TICHINIA JONES & ROBERT JONES
PLAINTlFF'S
DIVISION
VERSUS CASE 17-CC-012407

THE LAMAR COMPANY, L. L. C.
DEFENDANT
'09 eve:
fell
"3s :=
Q91 so;':
so
gg;
121 fn
Motion For Disqualijimtion -1.
co:

:¢
F8 .14 -;
FOR JUDGE: MICHAEL.S. WILLIAMS ar -4
.so

Commercial Property Agent Robert Jonas as submitted facts and
f@@§9n$~th§t bias a a faver exists.

Comes. Now; Tichinia Jones & Robert Jones, pro-se Litigant an moves for
disqua l'fi
| location of Judge MICHAEL S. WILLIAMS because the said Judge is bias and
show favor to The Lamar Company L, L, C.
Against the Commercial Property Agent R0 art Jones, thereafter, on .lone 2, 2017
there was a final hearing set for trial on. a failure to pay late fee payments as
contract states.
Judge Michael S. Will'lams told Agent Rob Jones he has the burden to prove his
case, Agent Rob Jones ask Judge Michael S. Williams that he. would like to call the
defense witness first, Judge Michael S. Williams told Agent Rob Jones, "no" he
cannot call the defense witness Rich Behrle Real Estate Manager first, Agent Rob
Jones ask Judge why he cannot call the defense witness first Judge Michael S.
Vllj,ll.iBm$ said "if I put him, the defense witness on the stand it's going to be
liearsay" but that was not the only and real reason because Judge: Michael. S.
Williams know the defense witness Jim Mash ray who signed his name as the
Lessee on the contract was not present in court also Jim Mash ray had a failure to
1:

appear also, Judge Michael S. Williams focus only on Agent Rob Jones witness
Tichinia Jones so he could be bias and show favor to The Lamar Company by
granting The Lamar Company a Final Judgement win over the property Agent Rob
Jones, base only on Agent Rob Jones witness failure to appear when you have
both contract signer ponies Tichinia Jones and Jim Mash ray had a failure to
appear.

Rule 2.160 (d) sets forth the following bases for a disqualification motion, at
least one of which must be shown in the motion: 1. That the pony fears that he or
she will not receive a fair trial or hearing because of specifically described
prejudice or bias of the Judge.

WHEREFORE, The Plaintiffs' respectfully requests that this Administration
enter an order disqualifying the Judge Michael S. Williams over this cause and
providing for the reassignment of the case to another Judge of this Court, all in
accordance with section 38.10, Florida Statutes and Rule 2.160 of the Florida
Rules of Judicial Administration.
In addition, the plaintiffs ask the court to hold evidence and to protect the
information contained within it until this motion is resolved.

I RCIAL PRQBERTY
~'~ul

/ME
SENT COPY TO:
JULIE LANDRIGAN BALL, ESQUIRE
P.O BOX 3604
LAKELAND, FL 33802
IN THE COUNTY COURT
IN AND HILLSBORUGH COUNTY Division - CIVIL
Case No: 17-cc-012407
TICHINIA JONES & ROBERTJONES Appeal No: 17-CA-009049
PLAINTIFF(S)

ma
(VERSUS) 1:- C-3.
°~l
C:
£-~'
LAMAR COMPANY, L.L. C '2"f"{

DEFENDANT(S)
c: of __.
§1

:U
-4 'U c"
U) :z ff.
ft? J*

TO THE COURT OF ADMINISTRATIVE
PLAINTIFF MOTION FOR olsquAul=v

The Plaintiff and. the. Progeny Agent which is Robert Jones- has Power of Attorney
to act in the behalf of (Principal)Tichinia Jones in any and all legal action at any
level with,
DURABLE POWER OF ATTORNEY
Under Fla; Statute Chapter 5601 section 1
My Agent Roh Jones (POF) powers shall include the power to:
I. Institute, supervise, prosecute, defend, intervene in, abandon, compromise,
arbitrate, settle, dismiss and appeal from any and all legal, equitable, indicial in
administrative. hearings, actions, suits,proceedings, attachments, arrests or
distresses, involving me in any way.
4. Manage, insure, improve, repair, collect rents, execute leases, or take any
other action that a landlord might take, with respect to any interest of mine in
real estate located at: 1745 E. Hillsborough Avenue, Tampa, Fla 33610 Judge
Michael S. Williams wastotally aware that Tichi nia Jones had a property Agent
with Power of Attorney.
Under Fla. Stat. chapter 38 section 10
COMESNOW, Plaintiff(s) motions to have Judge Michael S. Williams
remove from this case, states the following reasoning: On. July 7, 2u17 Plaintiff
refilled the eviction case to Evict Lamar from the property for Failure. to Pay Late
Fee Payments as the contract states in paragraph 2, but Lamar refused to respond
to the summons complaint at this time the County Court enter and Default
é'

1. The "American Rule" provide that" in the absence of legislation providing
otherwise,litigants mustpav._their_own.attornev's fees."
2. Indeed, Florida Courts have held that attorney's fees. are not recoverable
unless a Statute or a Contract specifically authorizes their recovery.
3. In other words, if a Statute or Contract is silent as to entitlements to
attorney's each party must bear its own fees and cost.. The Plaintifl(s) motion
to have this prejudice Judge Michael S. Williams remove from this case under Fla.
Statute Chapter 38 section 10, as you will End Plaintiff request a hearing on this
case judge did not responded to motion at all, but judge Grant's all the Defendant
motion just as always and everyone can clearly see their motions are against the
Fla. Statute Law, not only did the defense attorney intentionally misused the- Fla.
Statute Chapter 55 section 10 she adds the word Title Claim to the Fla. Statute
Chapter 55 section 10 where there is no talk about change of the Title Claim or
Deed in this Fla. Stat. Chapter 55 section 10 and there is no talk about Levy to any
one property for any reasoning whatsoever there are no words in this chapter 55. 10
like auction off real estate property, side real estate property, bid on read estate
property, foreclose on read estate property, wet of Execution for property the Fla.
Statute Chapter 55.10 have none of these in there Fla. Statute attach as Exhibit -A,
this court will see defense attorney wrote and adds that word Title Claim to make it
say and do what she wants it to say and do, because the Fla Statute Chapter 55
section 10 speaks on paragraph (7) Any party having an interest in such security orthef
property from which the lien was transferred may at any time, and any number of times, Hle a
complaint in chancery in the Circuit Court of the Counts where such security is deposited for
an Drder:
(a) To require additional security;
(b) To require reduction of security;
(c) To require change or substitution of sureties;
(d) To require payment or discharge thereof; or
(e) Relating to any other matter affecting said security.
These is the option for the higher Circuit Court [N]ot lower County Court
This court will do kind defense attorney use Fla. Statute Chapter 695 séctienll
clearly reads Circuit Court [N]ot lower County Cost is small claims cases only
See: 695.11 Instruments' deemed to be recorded from time of
All instruments which are authorized or required to be recorded in the office of the
*l

Clerk of the Circuit Court of any county in the State of.Florida, which is attached.
THEREFORE, Pldntiff(s) is requesting this COURT OF ADMINISTRATIVE

to please remove this illegd lien on plaintiff Red Estate Property and order Lien
Rel

Case Info

Judge

MICHAEL S WILLIAMS Track Judge’s New Case

Case No.

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Document Filed Date

June 19, 2018

Case Filing Date

September 29, 2017

County

Parties

BALL , JULIE LANDRIGAN Attorney for the Defendant
JONES, ROBERT Plaintiff
JONES, TICHNIA Plaintiff
LAMAR COMPANY LLC Defendant
Thomas Daugustinis Attorney
Benjamin Hardin Attorney
Robert Chilton Attorney
Sergio Florez Attorneys for Plaintiffs
Harley Herman Attorney
Robert Cooper Attorney
William Hardin Attorney
Robert Cintron Attorney
Benjamin Winter Attorney
Daniel Fox Attorney

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