On April 22, 2020 a
Party Discovery
was filed
involving a dispute between
and
Gilliam, Carlos William,
in the District Court of Charlotte County.
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Filing # 123580541 E-Filed 03/23/2021 11:16:11 AM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
STATE OF FLORIDA,
Plaintiff,
Case No. 20-681-F
VS.
CARLOS W. GILLAM,
Defendant.
cine |
N R E SUBPOEN.
R TES NY BY DCF INVESTIGA
COMES NOW, Defendant, CARLOS W. GILLIAM, by and through his undersigned
attorney, and hereby files this Motion for Order to Permit Subpoena for Testimony by Florida
Department of Children and Families (DCF) Investigators at court hearing(s) in this cause, and
as grounds therefore, states:
1. The following minor child is subject to this proceeding:
= Jate of Birth
2. Carlos Gilliam is the INE the child and] the chitc’s zy
3. On or about April 21, 2020, Defendant/Father was arrested for Aggravated
Battery knowing the victim was pregnant.
4. Shortly thereafter, DCF investigated the case because the child was present when
the alleged indecent occurred.
5. DCF Investigator, Mary Perez, was assigned to the case.
6. Investigator Mary Perez spoke with the Defendant, the alleged victim, and the
child.
7. Investigator Mary Perez also observed the physical appearance and demeanor ofall of the parties.
8. Said investigator has relevant information on this case, but is unable to testify
absent a court-issued subpoena.
WHEREFORE, Defendant respectfully requests the Court enter an order permitting the
issuance of subpoena for testimony by DCF investigator on the case.
Respectfully Submitted,
LAW OFFICE OF ERIC A. REYES, P.A.
Eric A. Reyes, Esquire
FBN: 815047
1435 Collingswood Blvd. Suite B
Port Charlotte, Florida 33948
Tel: 941-624-3644
Attorney for Defendant
Email:
Z CAT.
1 HEREBY CERTIFY that a true and correct copy of the foregoing bas been tiled and
furnished via email to the Assistant State Attorney as listed on the e-portal on thi: f
March, 2021.
Eric A. Reyes, Esquire
Document Filed Date
March 23, 2021
Case Filing Date
April 22, 2020
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Filing # 123580541 E-Filed 03/23/2021 11:16:11 AM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA STATE OF FLORIDA, Plaintiff, Case No. 20-681-F VS. CARLOS W. GILLAM, Defendant. cine | N R E SUBPOEN. R TES NY BY DCF INVESTIGA COMES NOW, Defendant, CARLOS W. GILLIAM, by and through his undersigned attorney, and hereby files this Motion for Order to Permit Subpoena for Testimony by Florida Department of Children and Families (DCF) Investigators at court hearing(s) in this cause, and as grounds therefore, states: 1. The following minor child is subject to this proceeding: = Jate of Birth 2. Carlos Gilliam is the INE the child and] the chitc’s zy 3. On or about April 21, 2020, Defendant/Father was arrested for Aggravated Battery knowing the victim was pregnant. 4. Shortly thereafter, DCF investigated the case because the child was present when the alleged indecent occurred. 5. DCF Investigator, Mary Perez, was assigned to the case. 6. Investigator Mary Perez spoke with the Defendant, the alleged victim, and the child. 7. Investigator Mary Perez also observed the physical appearance and demeanor ofall of the parties. 8. Said investigator has relevant information on this case, but is unable to testify absent a court-issued subpoena. WHEREFORE, Defendant respectfully requests the Court enter an order permitting the issuance of subpoena for testimony by DCF investigator on the case. Respectfully Submitted, LAW OFFICE OF ERIC A. REYES, P.A. Eric A. Reyes, Esquire FBN: 815047 1435 Collingswood Blvd. Suite B Port Charlotte, Florida 33948 Tel: 941-624-3644 Attorney for Defendant Email: Z CAT. 1 HEREBY CERTIFY that a true and correct copy of the foregoing bas been tiled and furnished via email to the Assistant State Attorney as listed on the e-portal on thi: f March, 2021. Eric A. Reyes, Esquire