Preview
Filing # 122085276 E-Filed 02/25/2021 02:52:13 PM
IN THE CIRCUIT COURT OF THE
FOURTEENTH JUDICIAL CIRCUIT, IN AND FOR
BAY COUNTY, FLORIDA
SHAE KRISTINE MURDOCK,
Plaintiff,
vs.
CASE NO.: 2019 CA 004417
CITY OF LYNN HAVEN, and
LEONARD FRANCIS HINSON, individually,
Defendants.
a
——esesi‘“‘“‘i‘i‘i‘iéC
DEFENDANT CITY OF LYNN HAVEN’S NOTICE OF FILING
Defendant City of Lynn Haven, through its undersigned counsel, gives notice of filing the
following document in support of its Motion for Summary Judgment:
1. Affidavit of Charles Enfinger dated February 18, 2021.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true copy of the foregoing was served by e-Filing with the
Clerk of Court and via Florida e-Filing Portal to the following, this 25th day of February, 2021.
Marie A. Mattox Jeffrey S. Carter
Katherine L. Viker Jeff Carter, P.A.
MARIE A. MATTOX, P.A. P.O. Box 228
203 N. Gadsden Street Panama City, Florida 32402
Tallahassee, Florida 32303 Tel: (850) 387-0787
marie@matoxlaw.com jeff@jeffcarterpa.com
katherine@mattoxlaw.com service@Jeffcarterpa.com
marlene@mattoxlaw.com (Counsel for Defendant, Hinson)
michelle@mattoxlaw.com
(Counsel for Plaintiff)
s/ J.
David Marsey
J. DAVID MARSEY
Florida Bar No.: 0010212
E-mail: dmarsey@rumberger.com (primary)
docketingorlando@rumberger.com and
kradysecy@rumberger.com (secondary)
KAYLA E. PLATT RADY
Florida Bar No.: 0117896
E-mail: krady@rumberger.com (primary)
docketingorlando@rumberger.com and
kradysecy@rumberger.com (secondary)
RUMBERGER, KIRK, & CALDWELL, P.A.
101 North Monroe Street, Suite 120
Tallahassee, Florida 32301
Tel: 850.222.6550
Fax: 850.222.8783
Attorneys for Defendant, City of Lynn Haven
2
14741508.v1
IN THE CIRCUIT COURT OF THE
FOURTENTH JUDICIAL CIRCUIT, IN AND FOR
BAY COUNTY, FLORIDA
SHAE KRISTINE MURDOCK,
Plaintiff,
vs.
CASE NO.: 2019 CA 004417
CITY OF LYNN HAVEN, and
LEONARD FRANCIS HINSON, individually,
Defendants.
a —esa( ii
AFFIDAVIT OF CHARLES ENFINGER
STATE OF FLORIDA
COUNTY OF BAY
BEFORE ME, the undersigned authority, personally appeared CHARLES ENFINGER,
who being first duly sworn, deposes and says:
1. I am over the age of 18. I am of sound mind and am fully competent to make this
Affidavit. I have personal knowledge of the facts stated herein and they are true and correct.
2. I am currently a law enforcement Lieutenant with the Lynn Haven Police
Department and have held this rank since December 1, 2019. Prior to my promotion to Lieutenant,
I was a law enforcement Corporal and held that rank from April, 2018 — December 1, 2019. Ihave
a total of 9 years’ experience as a sworn law enforcement officer.
3. On or around September 4, 2018, I was a law enforcement Corporal assigned to
investigate allegations of stalking and threats made to Leonard Francis Hinson. During the
investigation, Hinson provided a sworn recorded statement reporting criminal conduct by Shae
Kristine Murdock, with whom he had been involved in a personal romantic relationship.
4. Pursuant to my investigation, I prepared, among other things, an application for
warrant and an affidavit of probable cause supporting the application. On September 4, 2018, I
4. Pursuant to my investigation, I prepared, among other things, an application for
warrant and an affidavit of probable cause supporting the application. On September 4, 2018, I
presented the warrant application and affidavit to a judge who issued arrest warrants for aggravated
stalking and extortion or threats. True and accurate copies of the application, affidavit, and signed
warrants are attached to this Affidavit as Exhibit A.
5. Pursuant to the arrest warrant, Shae Kristine Murdock was arrested and transported
to the Bay County Jail.
FURTHER AFFIANT SAYETH NAUGHT.
/. A ff “a A
vsbatewtSeet an sesso
CHARLES ENFINGER |; /
STATE OF FLORIDA
COUNTY OF BAY
The foregoing instrument was sworn to and acknowledged before me this [9
/ 0. day of
Fepeuney _, 2021, by Charles Enfinger. _
cay g,, JuliaCuff “Signature pf Notary
>STATEOFFLORIDA “Jel a faSTAMP~(- CNAME
goa, NOTARY PUBLIC | ; -
encewoe c GG349223 spreescsaieeusrssionmmeiene
tba arr DSRS te
neeomen
Saree Exeos 5/14/2023 PRINT, TYPE
OF NOTARY
OR
Personally Known
OR Produced Identification.
Type of Identification Produced
-2-
FFAGGAN-'O 9-418 _
. . ; IN COUNTY COURT
Received this Warrant this day of BAY
: ‘?<2:
A.D. 20 and executed STATE OF FLORIDA
it on the day of -VS-
A.D. 20 by arresting the within named SHAE KRISTINE MURDOCK
oo eS OO
_and having now before the Court, tobe . |SSN| IMM | Height/ 5°07" [Weight] 120 _|
dealt with according to law, this day of [Hair] BRN | Eyes| BRN
ThA.D. on20 Adress)
TD
784.048(3)
Sheriff: . | Investigator; CHARLES ENFINGER LH12_
| Deputy Sheriff: | CASE #: 2018-005161
STATE OF FLORIDA
COUNTY OF: BAY ; |
To all and singular the Sheriffs Office or Constables of the State of Florida:
WHEREAS, INVESTIGATOR CHARLES ENFINGER , has this day made oath that one,
SHAE KRISTINE MURDOCK did . ,
Probable Cause Narrative Defendant's Photo (If Available)
willfully, maliciously, and repeatedly follow, harass or cyberstalk Leonard Francis Se Peg.eee
Hinson, and did make a credible threat, with the intent to place Leonard Francis ee
Hinson or Leonard Francis Hinson's child, sibling, spouse, parent or dependent in ms Cig \Gy See
reasonablefearofdeath or bodily injury, |: hEoo SONG awes
we are- ceN, sume heez
bp oe
ae
. |
_Contrary to Florida Statute __784.048(3) and against the peace and dignity of the State of Florida.
These are therefore to command you forthwith to arrest the said,
.
_ SHAE KRISTINE MURDOCK
}
_,
and bring
Givenhimunder
* before
my mehandto and
be dealt
officialwithseal,according,
.
this
.
ut{9 law.day of !
A.D. 20\ X
Other Conditions of Release gf, BULLKONs4 + COUR
Aide SVey OFHEciRcuIT COURS County Jud
“oa
xf
eA
Se ,
arate Lake eS ltwskdrcui/County
yeueg
Judge
:
Report Printed By: Fritze, Alice Page 4 of 17
tela 1
eeeerememeennmaunneseamemecensimmanmmey
4B
Preview
Filing # 122085276 E-Filed 02/25/2021 02:52:13 PM IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT, IN AND FOR BAY COUNTY, FLORIDA SHAE KRISTINE MURDOCK, Plaintiff, vs. CASE NO.: 2019 CA 004417 CITY OF LYNN HAVEN, and LEONARD FRANCIS HINSON, individually, Defendants. a ——esesi‘“‘“‘i‘i‘i‘iéC DEFENDANT CITY OF LYNN HAVEN’S NOTICE OF FILING Defendant City of Lynn Haven, through its undersigned counsel, gives notice of filing the following document in support of its Motion for Summary Judgment: 1. Affidavit of Charles Enfinger dated February 18, 2021. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing was served by e-Filing with the Clerk of Court and via Florida e-Filing Portal to the following, this 25th day of February, 2021. Marie A. Mattox Jeffrey S. Carter Katherine L. Viker Jeff Carter, P.A. MARIE A. MATTOX, P.A. P.O. Box 228 203 N. Gadsden Street Panama City, Florida 32402 Tallahassee, Florida 32303 Tel: (850) 387-0787 marie@matoxlaw.com jeff@jeffcarterpa.com katherine@mattoxlaw.com service@Jeffcarterpa.com marlene@mattoxlaw.com (Counsel for Defendant, Hinson) michelle@mattoxlaw.com (Counsel for Plaintiff) s/ J. David Marsey J. DAVID MARSEY Florida Bar No.: 0010212 E-mail: dmarsey@rumberger.com (primary) docketingorlando@rumberger.com and kradysecy@rumberger.com (secondary) KAYLA E. PLATT RADY Florida Bar No.: 0117896 E-mail: krady@rumberger.com (primary) docketingorlando@rumberger.com and kradysecy@rumberger.com (secondary) RUMBERGER, KIRK, & CALDWELL, P.A. 101 North Monroe Street, Suite 120 Tallahassee, Florida 32301 Tel: 850.222.6550 Fax: 850.222.8783 Attorneys for Defendant, City of Lynn Haven 2 14741508.v1 IN THE CIRCUIT COURT OF THE FOURTENTH JUDICIAL CIRCUIT, IN AND FOR BAY COUNTY, FLORIDA SHAE KRISTINE MURDOCK, Plaintiff, vs. CASE NO.: 2019 CA 004417 CITY OF LYNN HAVEN, and LEONARD FRANCIS HINSON, individually, Defendants. a —esa( ii AFFIDAVIT OF CHARLES ENFINGER STATE OF FLORIDA COUNTY OF BAY BEFORE ME, the undersigned authority, personally appeared CHARLES ENFINGER, who being first duly sworn, deposes and says: 1. I am over the age of 18. I am of sound mind and am fully competent to make this Affidavit. I have personal knowledge of the facts stated herein and they are true and correct. 2. I am currently a law enforcement Lieutenant with the Lynn Haven Police Department and have held this rank since December 1, 2019. Prior to my promotion to Lieutenant, I was a law enforcement Corporal and held that rank from April, 2018 — December 1, 2019. Ihave a total of 9 years’ experience as a sworn law enforcement officer. 3. On or around September 4, 2018, I was a law enforcement Corporal assigned to investigate allegations of stalking and threats made to Leonard Francis Hinson. During the investigation, Hinson provided a sworn recorded statement reporting criminal conduct by Shae Kristine Murdock, with whom he had been involved in a personal romantic relationship. 4. Pursuant to my investigation, I prepared, among other things, an application for warrant and an affidavit of probable cause supporting the application. On September 4, 2018, I 4. Pursuant to my investigation, I prepared, among other things, an application for warrant and an affidavit of probable cause supporting the application. On September 4, 2018, I presented the warrant application and affidavit to a judge who issued arrest warrants for aggravated stalking and extortion or threats. True and accurate copies of the application, affidavit, and signed warrants are attached to this Affidavit as Exhibit A. 5. Pursuant to the arrest warrant, Shae Kristine Murdock was arrested and transported to the Bay County Jail. FURTHER AFFIANT SAYETH NAUGHT. /. A ff “a A vsbatewtSeet an sesso CHARLES ENFINGER |; / STATE OF FLORIDA COUNTY OF BAY The foregoing instrument was sworn to and acknowledged before me this [9 / 0. day of Fepeuney _, 2021, by Charles Enfinger. _ cay g,, JuliaCuff “Signature pf Notary >STATEOFFLORIDA “Jel a faSTAMP~(- CNAME goa, NOTARY PUBLIC | ; - encewoe c GG349223 spreescsaieeusrssionmmeiene tba arr DSRS te neeomen Saree Exeos 5/14/2023 PRINT, TYPE OF NOTARY OR Personally Known OR Produced Identification. Type of Identification Produced -2- FFAGGAN-'O 9-418 _ . . ; IN COUNTY COURT Received this Warrant this day of BAY : ‘?<2: A.D. 20 and executed STATE OF FLORIDA it on the day of -VS- A.D. 20 by arresting the within named SHAE KRISTINE MURDOCK oo eS OO _and having now before the Court, tobe . |SSN| IMM | Height/ 5°07" [Weight] 120 _| dealt with according to law, this day of [Hair] BRN | Eyes| BRN ThA.D. on20 Adress) TD 784.048(3) Sheriff: . | Investigator; CHARLES ENFINGER LH12_ | Deputy Sheriff: | CASE #: 2018-005161 STATE OF FLORIDA COUNTY OF: BAY ; | To all and singular the Sheriffs Office or Constables of the State of Florida: WHEREAS, INVESTIGATOR CHARLES ENFINGER , has this day made oath that one, SHAE KRISTINE MURDOCK did . , Probable Cause Narrative Defendant's Photo (If Available) willfully, maliciously, and repeatedly follow, harass or cyberstalk Leonard Francis Se Peg.eee Hinson, and did make a credible threat, with the intent to place Leonard Francis ee Hinson or Leonard Francis Hinson's child, sibling, spouse, parent or dependent in ms Cig \Gy See reasonablefearofdeath or bodily injury, |: hEoo SONG awes we are- ceN, sume heez bp oe ae . | _Contrary to Florida Statute __784.048(3) and against the peace and dignity of the State of Florida. These are therefore to command you forthwith to arrest the said, . _ SHAE KRISTINE MURDOCK } _, and bring Givenhimunder * before my mehandto and be dealt officialwithseal,according, . this . ut{9 law.day of ! A.D. 20\ X Other Conditions of Release gf, BULLKONs4 + COUR Aide SVey OFHEciRcuIT COURS County Jud “oa xf eA Se , arate Lake eS ltwskdrcui/County yeueg Judge : Report Printed By: Fritze, Alice Page 4 of 17 tela 1 eeeerememeennmaunneseamemecensimmanmmey 4B