One request. 875 days. No written order.

Husband's own counsel, Vivian Cortes Hodz, had a withdrawal motion on file since December 3, 2024,
set for hearing thirty-four days out on January 6, 2025. On December 11 at 4:09 PM she filed an
expedited motion. At 5:22 PM on December 11, chambers offered three dates, December 13, 16 and 18. At 9:08 PM, counsel confirmed the earliest, December 13 at 4:30 PM, stating only that she and opposing counsel were available.

At 11:17 PM that night the client objected in writing. He asked for more time, described the
prejudice, said "I have never practiced in circuit or county Court in my life," waived his
attorney-client privilege, and stated his unavailability. At 9:09 AM the next morning chambers
confirmed the December 13 setting for 4:30 PM. Eight minutes later he objected again, expressly: "I
object to the hearing occurring without me." Nothing changed.

The hearing went ahead on December 13 at 4:30 PM, two days and twenty-one minutes after the
expedited motion, on one-day notice, per the court's own recital in its order. The expedited
motion rested its urgency on the client's own conduct and allegations, which it said "necessitate the Court's immediate attention"; no basis for moving the date up appears in the order or in the transcript. Judge Ayers
granted the withdrawal from the bench over Husband's objection and cancelled the January 6 setting
from the bench. A motion for judicial default premised on the unanswered petition was filed at 8:32
that same morning (N-013), and Husband answered self-represented three days later. Whether the
extended response deadline fell on the hearing date itself is not pinned in the records reviewed,
and the sequence does not depend on it. [DENIED]

Due process means notice and a real chance to be heard, and for a withdrawal that means notice timely enough for the client to respond (Garden v. Garden). The lawyer who wants out over the client's objection carries the burden of justifying it under Rule 4-1.16(b); the client carries nothing. Moving a hearing up twenty-four days rests on a stated emergency. The expedited motion said the client's conduct and allegations “necessitate the Court's immediate attention” and, in the same filing, “There are no other hearings scheduled in the matter.” Judge Ayers later said so herself: setting it “in one day's notice might have been a little soon.”

a withdrawal motion that had been set thirty-four days out was heard twenty-four days early, on one day's notice, on a motion that rested its urgency on the client's own conduct; the client had objected in writing twice before it began, and it ended his representation.

- Doc 056, the 12/3/24 withdrawal motion.
- Doc 058 paras. 1, 5, and 8, the 12/11/24 4:09 PM expedited motion; p. 4 recites that counsel "has sought all appropriate extensions of time and communicated the same so as to ensure no interim prejudice to the Husband,"
- Doc 167, the Wednesday 12/11/2024 11:17 PM EST objection email, with the privilege waiver at p. 2.
- Doc 168, the Thursday 12/12/2024 9:17 AM EST objection, which embeds the court's own 12/12 9:09 AM setting email eight minutes before it.
- Doc 100 para. 1, the court's own "one-day notice" recital, and Doc 100 as the 1/13/25 re-grant despite that recited notice.
- Doc 158, transcript of the December 13, 2024 hearing, Tr. 17:13-17. Doc 090, transcript of the December 19, 2024 hearing, Tr. 16:22-24.
- Doc 109, transcript of the January 9, 2025 hearing, Tr. 15:20-16:3 for the quoted concession that one day's notice "might have been a little soon."
- Doc 059 p. 2 and Doc 061 p. 3, opposing counsel's written refusal of any further extension: "I cannot agree to an extension of time. He should be required to adhere to the same standards."
- Doc 075, the 8:32 AM default motion of 12/13/24. Doc 079, Husband's self-represented answer of 12/16/24.
- Doc 214 p. 1, Filing #227245890, the 10/21/24 email from counsel, found 8/7/26; quoted in text at N-023.
- The velocity distribution under the successor judge: N-123 (about 4 hours, a non-party's proposed order), N-128 (19h54m, opposing counsel's exit order), N-134 (about 25 hours, an order billing Husband $3,000), against N-139, where a filed motion, a proposed order, and acceptance of the court's own offered dates drew no hearing, no order, and no reply.
- Related decision points: N-151.

Full card on the map · Under Judge Ayers page

The written ruling chambers had promised for December 16, 2024 never issued. The email said instead,
"At this juncture, the Court is not issuing a ruling." What filled the sixty-three days from hearing
to order was a memorandum Davis filed six days late, over an objection the court never ruled on
(N-007).

At the December 19 hearing Judge Ayers said: "nobody has asked me to do anything with the premarital
agreement or separation agreement. So at this juncture I'm not ruling on them with respect to
anything because it's not in front of me, but as far as I'm concerned they're both in full force and
effect and that would limit your discovery requests, Mr. Hanson." On the discovery objection she
ruled: "I've sustained it actually. So that discovery is not going to be produced." Four months later
she described the same ruling in her own words: "the only substantive ruling that I've made is you
can't get your discovery because we've got the two agreements."

On December 30 she e-signed the order sustaining Wife's amended objection and killing the Chase
non-party subpoenas. Paragraph 3 of that order declined to rule on whether either agreement is valid,
because the issue "has not been challenged by either Party or properly brought before the Court."

The effect ran both directions. Husband got no bank records, and the records Wife had not produced
stayed unproduced (N-006). Wife also owed no reciprocal discovery on the agreements that shut the
subpoenas off. The court had named the missing step at the hearing, saying the agreements stand
"unless you file something otherwise." Husband filed exactly that. No judge has ruled on it since
(N-019, N-033). [DENIED: the discovery was cut off on the strength of agreements the same ruling
refused to adjudicate]

Under Casto, an agreement whose terms are unreasonable for one spouse raises a presumption of concealment or lack of knowledge, and the burden shifts to the spouse defending it; testing the terms takes the financial records. Wife's own petition concedes the disclosure Casto asks the defending spouse to show: no financial disclosures accompanied the October 2023 agreement. A subpoena is how a party gets records the other side will not hand over, and killing one takes a stated ground. The ground stated here was the agreements themselves.

the court said it was not ruling on the two marital agreements because nobody had asked it to, and in the same breath used those agreements to shut off the discovery that would test them.

- Doc 090, transcript of the December 19, 2024 hearing, Tr. 4:3-11, 6:5-8, and 7:14-16 for the quoted rulings; Tr. 12:14-25 (the "Nope." exchange at 12:22-24), 13:2-5, 13:9-10, and 13:25-14:2 ("It's killing me to watch what it's doing to them").
- Doc 091 Ex. A p. 14, the Heyward email of 12/16/24 9:30 AM. Its sentence opens "At this juncture, the Court is not issuing a ruling," and that opener travels with any use of the quote.
- Doc 192, transcript of the April 22, 2025 hearing, Tr. 29:6-9, the judge's own later description of the same ruling.
- Doc 093, "Order Sustaining Wife's Amended Objection," e-signed by Judge Ayers 12/30/2024 4:03:22 PM. Decretal para. 2 names DIN 28 and 29 only. Para. 3 declines to rule on validity, quoted above. Doc 102's notice corroborates the 12/30 order date.
- Doc 158, transcript of the December 13, 2024 hearing, Tr. 10 and 19.
- Doc 203 para. 5, no financial disclosures with the October 2023 agreement. The record's own name for that instrument is the Marital Separation Agreement dated 10/8/23; "postmarital" and "post-marital" are aliases; Judge Ayers says "postnuptial" on the record and quoted material stays verbatim.
- Doc 090 Tr. 7:19-20 for the counsel-relayed refusal to void, "He said no. She's not willing to do it," Doc 205, Wife's deposition of April 2, 2025, Tr. 132:21 for the sworn refusal and Tr. 133:6-8 for the figures as Wife stated them.
- Doc 146 para. 107 for the affidavit arithmetic, citing Docs 34 and 43: Wife's disclosed assets over liabilities at $104,611 against Husband's in excess of $800,000. The $104,611 is her disclosed net worth; the $100,000 is the payment she received under the agreement. Two different figures, and they should not be read as one.
- Doc 181 (4/23/25) para. 2, bolded, on the reissued subpoenas. The second set did not exist for another sixty days (N-034).
- Docs 127 and 129 for the challenge-chain dispositions (N-028). A template artifact appears at p. 2 of the challenge chain, an unfilled "[Wife's Name]" writ-of-bodily-attachment block.
- Division check: every Ayers-era transcript cover and Doc 054 read "Division D"; Division A is the post-reassignment designation.

N-007, N-019, N-033, N-006

Full card on the map · Under Judge Ayers page

On 4/1/25 Husband filed a notice opposing Wife's guardian ad litem, psychological evaluation, and vocational-file motions, attaching a magazine article warning that "There is always a risk that a Guardian ad Litem will make recommendations that are not in a child's best interest". He raised it at the 5/29/26 hearing; Wife's counsel objected on relevance, Judge Felix agreed, and the question was narrowed to whether the witness had read that article. She had not. Doc 337 granted the appointment on 6/25/26 on findings that mention neither cost, risk, ability to pay, nor the notice; its only cost sentence divides an unstated amount equally. Doc 351 then ordered "$6,000.00 within 3 days of entry of this Order" at $325 per hour, with no cost evidence and no mention of the notice. 498 days from filing to 8/12/26, with no engagement in any order. [IGNORED]

Section 61.16(1) requires a finding of what each parent can pay before a cost is imposed on him, and section 61.401 requires the court to find, on the movant's showing, that the appointment serves the children. The objection here was timely: captioned as opposition to the motion it opposed, it sat on the docket over a year before either order issued, and was raised aloud in court. It sat through three hearing days and two orders and drew no sentence.

Husband's written objection to the cost and risk of a guardian ad litem sat on the docket 450 days before the order granting one and 478 days before the order pricing it at $6,000; neither order mentions cost, risk, or ability to pay.

- Doc 169 (Filing #220088124, e-filed 4/1/25 5:32:32 PM, 3 pp.); the article text is at pp. 2-3, including the sentence that a party "will have spent thousands of dollars on an investigation and report that could cost them custody of their beloved child."
- 5/29/26 Tr. 38:6-17, 38:24-39:2, 39:4-9, 39:21-24 (relevance objection, "I agree," narrowing, and the sustained speculation objection on the follow-up question).
- Doc 337 (2 pp.) and Doc 351 (5 pp.), both read in full, neither referencing Doc 169, the article, cost evidence, or ability to pay.
- Doc 345 (3 pp.), no reference. Doc 342 p. 5.
- Caution on file: Doc 169's certificate of service carries a stale "13th day of December, 2024" template date; the 4/1/25 clerk stamp controls and every day count here uses it.
- DINs 346-350 and 352-359 are absent from this tree, so the absence of an order on Doc 342 (the reconsideration motion raising this a third time) is stated as to this record, not as a certified docket absence.
- Related decision points: N-038, N-134.

N-134, N-038, N-125

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The judge offered "the camera footage" as proof about her own conduct, then answered "No, sir" when asked to get it.

On April 4, 2025 Judge Ayers volunteered courthouse-camera footage to disprove an alleged eye-roll: "I will go get the camera footage and do it because I have not rolled my eyes at you." Husband asked her to pursue that footage. At the close of the hearing he asked again; she answered, "No, sir," and when he pressed, said he was "crossing the line" and ended the hearing. The footage has never been produced to Husband, and no court or party has ever examined it on the record (N-103 records the defendants' statement that someone viewed it, without saying who). This is the April 4, 2025 courthouse video, called the video in later cards: courthouse demeanor footage, not a recording of the proceedings. [DENIED]

Evidence a judge volunteers about her own conduct is evidence she has put in issue; once she points to a record as her own proof, it has to be reachable by the other person in the room, and the Florida Constitution presumes a judicial-branch record open with the burden of any exemption on the custodian. The same footage is the object of the records litigation that follows, later confirmed to exist and withheld (N-053). The alleged eye-roll rests on Husband's sworn firsthand account in a verified motion later granted as legally sufficient.

the judge offered the courthouse camera footage as proof about her own conduct, and when Husband asked her to go get it she said "No, sir" and ended the hearing, and it has never been produced.

- Doc 198 Tr. 75:12-16 and 75:15-17 (the volunteered footage and Husband's request that she get it), and Tr. 193:9-14 (the refusal, "No, sir," then "you're crossing the line. This hearing is ended.").
- Doc 183 p. 10, the verified second disqualification motion carrying the sworn eye-roll account under its own heading, filed 4/24/25 and granted as legally sufficient 4/28/25 (N-047).

N-053, N-076, N-157, N-156, N-018

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On October 24, 2025 at 7:14 AM Husband filed an emergency motion asking the court to enter orders on two pending filings: the sanctions motion (Doc 239) and the motions to record hearings (Doc 245). The court's own October 14 handling order had said the Doc 245 motions "will be addressed on October 17, 2025 at 12:00 p.m." (Doc 247); the new motion stated that no order issued after that hearing. At 8:52 AM, 98 minutes after filing, Judge Felix signed a checkbox handling order with one box checked: "The matter is not an emergency and should be handled in the normal course." The boxes for an expedited hearing, for denial, and for abuse of the emergency process were left blank. The next setting of either motion for an evidentiary hearing was the April 17, 2026 omnibus day, 175 days later; in between, both appeared only on case management conference notices. Both are now among ten matters noticed for an eight-hour hearing on October 9, 2026, and as of September 26, 2026 no order deciding either appears in the case file (N-057, N-011). [IGNORED]

A motion asking a court to rule on matters it has already promised to address draws a ruling, a hearing date, or a reason. The court's own form offered routes to each: an immediate order, a hearing, an expedited hearing for a time-sensitive matter, even denial as legally insufficient. The box checked reached only the label: "The matter is not an emergency and should be handled in the normal course." Ninety-eight minutes, and both underlying requests stayed undecided.

Husband asked the court to enter orders on his sanctions motion and his motions to record hearings; the court had said it would address the recording motions on October 17, 2025; 98 minutes later a checkbox form marked the request "not an emergency" and sent it to the normal course, and neither motion was set for an evidentiary hearing for another 175 days

- Doc 250, Filing #234369865, e-filed 10/24/25 7:14:23 AM (page image)
- Doc 251, emergency motion handling order, e-signed by Judge Felix 10/24/25 8:52:13 AM; one box checked (page image)
- Doc 247, e-signed 10/14/25 2:56:59 PM, "Other" box checked: the Doc 245 motions "will be addressed on October 17, 2025 at 12:00 p.m." (page image)
- Doc 250 p. 4, paras. 18 and 23 (page image)
- Doc 276 (Wife's amended notice, 2/20/26), setting Docs 239 and 245 for the 4/17/26 evidentiary hearing (page images); Docs 252, 256 and 261 list both only for case management conferences
- DIN 361 (7/30/26): ten matters, including Docs 239 and 245, noticed for 10/9/26
- Day count: 10/24/25 to 4/17/26 is 175; the two stamps are 1 hour 37 minutes 50 seconds apart
- Related decision points: N-057, N-011, N-056

N-057, N-056

Full card on the map · Under Judge Felix page

The question whether Davis would agree to an earlier, separate hearing on Husband's motion to compel came up three times in the same 2/3/26 hearing. Each time Davis declined, on the record: "No, sir, I do not, respectfully". When Husband pointed out the court could simply order the hearing, Judge Felix answered: "But I want his consent". He explained that he preferred to coordinate between the parties, and Davis had not agreed. Judge Felix then set everything, the discovery motion included, for the general 4/17 date, promising to take it first. It was argued first that day, and he never ruled on it (N-090). [DENIED]

A court has inherent authority to set its own docket and needs no party's consent to hear a pending motion. On 2/3/26 Judge Felix asked Davis whether he would agree to a separate, earlier hearing on Husband's 20-month-old discovery motion; Davis declined each time, twice stating, "No, sir, I do not." The motion was folded into the general 4/17 calendar instead, so Davis's refusal, not the court's own docket authority, decided when it would be heard.

asked to set an earlier hearing on a 20-month-old motion to compel, the court put the question to opposing counsel three times, was told "No, sir, I do not," and said "But I want his consent"; a court needs no permission to hear a motion.

- Doc 279, the certified transcript of the 2/3/26 hearing.
- Tr. 14:1-19 (first ask and both refusals, 14:14 and 14:17): "Mr. Davis, would you agree to setting that matter individually before?" / "No, sir, I do not, respectfully," and again "No, sir, I do not".
- Tr. 18:21-23 (court's recap: "I've heard the request before. I asked Mr. Davis if he would agree to that and he said no").
- Tr. 21:1-20 ("But I want his consent" at 21:8; coordination sentence at 21:12-14: "I prefer to coordinate between the parties and the counsels with regards to hearings and Mr. Davis has not agreed to that.").
- Tr. 21:16-20 and 23:4-6 (everything set for the 17th, "We'll do that first"). Tr. 9 (surrounding discovery/guardian ad litem argument).
- Transcript runs Tr. 1-24; hearing concluded 12:24 p.m.

N-003, N-090

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On 4/17/26, after 23 months, Judge Felix orally ordered three years of Rule 12.285 disclosure. He set 30 days but left Wife free to object, after her counsel raised the prenuptial and postnuptial agreements, and said: "I didn't order this discovery and say you have to produce -- you don't -- I'm not precluding any right to make an objection." He entered no written order. Later the same day, asked about the same motion, he said: "We already handled that matter." No written ruling exists in the record. Nothing was produced in the 30 days the court set, or since. When Husband moved in July 2026 simply to have that bench ruling reduced to writing, that motion drew no order either (N-133). [WON-THEN-NULLIFIED]

A court that grants a motion to compel compels something. Rules 12.285 and 12.350 exist so a party owed financial disclosure gets it. Here disclosure was ordered from the bench, every objection was left open, and nothing was written down. A court speaks through written orders, so an oral grant never entered cannot be enforced or appealed. The motion is the first-filed motion in the case (N-003).

after 23 months the motion was finally heard and granted from the bench, and the grant moved nothing: the court said, "I didn't order this discovery and say you have to produce -- you don't -- I'm not precluding any right to make an objection," and entered no written order.

- 4/17/26 Tr. 73, 114-116, 120-121, and 344 (the "We already handled that matter." line at Tr. 344)
- Unwritten-ruling family, cited as a family whenever any one is used: N-060 and N-074 (the stay lift), NEW-P5 (the quash order, not entered until 56 days after the ruling), N-133 (the entry motion ignored)
- Related decision points: N-073.

N-133, N-003, N-073

Full card on the map · Under Judge Felix page

The judge Husband is suing decided whether he could keep Husband's case; his order does not mention that he is a defendant in it.

Judge Felix is a named defendant in Husband's pending public-records suit (25-CA-010255). Doc 329, the motion to disqualify him on that ground, was filed at 12:00 AM on 6/10/26. At 8:34 AM Davis filed a fee request limited to the fees of responding to the motion (Doc 330). At 9:27 AM, 9 hours and 27 minutes after the filing, Judge Felix denied the motion to disqualify himself (Doc 331). He cited rule 2.330(i), called the motion "legally insufficient," and stated that he is able to be fair and impartial. He never addressed the separately pled (e)(2)(C) interest ground or the due-process argument. [DENIED]

The Constitution decides this one: no man may judge his own case (Murchison), and recusal is required where the probability of bias is too high to be constitutionally tolerable (Caperton; Williams). Where a court rule and the federal Constitution conflict, the Constitution controls (U.S. Const. art. VI, cl. 2). Doc 329 pleaded the status ground under Rule 2.330(e)(2)(C), distinct from the earlier prejudice motion, and asked for findings under Caperton. The order ruled as a successor judge under subdivision (i), certified its own fairness, and never mentions the defendant status the motion was about.

the motion pled a status ground the rule treats separately, that the judge was himself a named defendant in a pending case; the order denying it 9 hours and 27 minutes after filing called the motion "legally insufficient" and never mentions that ground

- 10255 Doc 038 p. 1, the caption naming "JUDGE MATTHEW FELIX" as a defendant.
- Doc 329 (filed 12:00 AM 6/10/26).
- Doc 330 (8:34 AM).
- Doc 331 (9:27 AM), with the DIN confirmed by a docket pull.

N-059, N-069, N-091, N-108, N-113

Full card on the map · Under Judge Felix page

"Any postings to social media about the case shall be immediately removed," ordered with no motion or hearing.

The 7/23/26 order appointing a guardian ad litem (Doc 351) was entered as a five-page document, only the odd pages of a nine-page order. On 8/3/26 the guardian ad litem wrote Judge Felix that "several of the pages of the Order are missing" and asked for a complete copy. The next day Judge Felix entered a nine-page Amended Order; no paragraph was deleted or reworded, only the restored pages and signature block changed.

Obligations never before served came into existence against Husband on 8/4/26: a waiver of the section 61.403(1) notice requirement, blanket self-executing authority over confidential records, a waiver of the hearsay rules, a duty to fund the guardian's counsel in advance, a prospective waiver of all claims, and: "Any postings to social media about the case shall be immediately removed". No motion, notice, or hearing preceded any of it. The fifteen-day rehearing window closed 8/19/2026. [PENDING]

A restraint on speech about one's own case is presumptively invalid and requires findings of a compelling interest served by the least restrictive means (Romero, 2d DCA); relief no motion requested denies due process (Neumann; Delgado). This order's one finding is that a guardian is in the children's best interest; it says nothing about speech, claims, hearsay, or records. Eleven paragraphs of obligation first reached Husband on 8/4/26, on a non-party's letter asking only for a complete copy. Whether they bind him before service is the live question.

four pages of obligations Husband had never been served, among them a ban on posting about his own case, first reached him on August 4, 2026, entered on a non-party's letter with no motion, no notice, and no hearing

- The guardian ad litem's letter to Judge Felix, "Correspondence to Judge Felix 26.08.03.pdf," 1 p., dated August 3, 2026, Via E-Portal, signed over the title GUARDIAN AD LITEM, copying both parties.
- Full quote: the order "appears to have at some point been printed double-sided, but only one side of each page was captured when it was signed and uploaded into Hover."
- Amended Order, 8/4/26, all 9 pp.; text layers unusable, no OCR used, so the delta was built from page images.
- Doc 351 as entered, all 5 pp.; the Clerk's e-filing footer numbers those five pages 1 through 5 consecutively, so nothing was lost in transmission; four of five page transitions break mid-sentence.
- Doc 337 (2 pp.).
- DIN 365 confirmed from a docket screenshot; Clock-In Event Date 08/04/2026, creation 08/05.
- Rule text pulled 8/17/26 from three concordant secondary sources rather than from the official flcourts publication.
- No certified Clerk copy of Doc 351 is held, so the five-page defect is shown here from a downloaded PDF rather than from the record.
- Process comparison: the appointment itself consumed roughly 15 hours of hearing time across three dates before a two-page order issued; the paragraphs added on 8/4 consumed no hearing time at all. A non-party appointee's letter drew action from the court in one day, while Husband's own first-filed discovery motion stood at 827 days as of August 21, 2026 with no ruling (N-003).
- The guardian ad litem asked only that a complete copy be entered; she did not ask for an amended order, and what the amendment added is the court's act, not hers.
- N-125 carries the grant event; this is a downstream decision point.

N-148, N-151, N-003, N-019

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Husband put the chief judge on notice three times: by email on January 22, 2025, by letter on February 12, 2025, and again on March 11, 2025. The March 13, 2025 answer from the Administrative Office of the Courts General Counsel confirmed receipt of all three, stating "the chief judge does not possess any independent investigative powers," and directing him instead to file a motion in the case or pursue the appellate process. The closing position was that Judge Sabella is "unable to take any action on your behalf in this matter." The remedies named were the case itself and the appeal, the judge complained of and the court that had already declined the record. Nothing followed the March 13, 2025 answer, and nothing has followed in the seventeen months since. [IGNORED: receipt acknowledged, then no administrative response]

Rule 2.215(b) places administrative supervision of a circuit's judges and dockets on its chief judge, a duty that exists because a litigant cannot supervise the judge assigned to him. Written receipt plus a stated position of inability puts the office on both sides of the record: it knew, it wrote back, and it fixed its position in writing. Being unable to act “on your behalf” is a different thing from being unable to examine a docket and require a report.

told three times in writing that its own circuit had a problem, the chief judge's office answered that it has no investigative powers and pointed Husband back to the judge he was complaining about

- Doc 120 (letter of 2/12/25) with Docs 121 to 122 (exhibit chain), per the V8 report.
- Doc 154 (Katchuk, 3/13/25), fully transcribed by eye (V11), which is the source of all three quoted sentences and of the confirmation that the 1/22, 2/12 and 3/11 emails were received.
- Interval anchors, stated because the sentence turns on which one is used: from the 3/13/25 answer to 8/20/26 is seventeen months and seven days; from the first notice of 1/22/25 to the same date is eighteen months and twenty-nine days. The prose runs from the answer.

N-068

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Court administration withheld the April 4, 2025 hearing video as security footage without ever stating a fact that makes it one.

On August 21, 2025 the 13th Circuit's administrative office confirmed in writing that "a video record does exist" for the April 4, 2025 hearing, and withheld it as confidential surveillance video without ever stating that the recording is a security-system record, the fact its own exemption requires. The same letter said no records existed for the seven other hearings requested that year. A September 8, 2025 letter restated the exemption in verbatim-identical words while ignoring the questions built to test it. The same defendants later admitted in discovery that no court order determines the video confidential (RFA responses, 5/15/26). The video has never been released. The same records category drew a different ground the next year: for a later set of seven hearing dates the office said the footage had already been overwritten under a 30-day retention schedule (N-057). [DENIED: access refused on an exemption whose factual basis was never given]

Article I, section 24 presumes the record open and puts the burden on the office that withholds it, which must state a written basis. The exemption invoked, section 119.071(3)(a), reaches security-system records, but the office has never stated that this recording is one, a predicate that takes one sworn sentence. In ten months of litigation, no affidavit from court administration or its defense counsel makes that showing. The recording is the one Judge Ayers herself invoked and then declined to pursue (N-042).

the court confirmed the hearing video exists, then withheld it on an exemption whose factual basis it has never stated, through ten months of litigation

- Justice letter 8/21/25 (10255 Doc 6 p.14; Doc 083 Exs. D and E).
- Letter 9/8/25 (Doc 6 p.44; exemption paragraph verbatim identical to 8/21/25).
- RFA No. 4 admission that no court order determines confidentiality (5/15/26 RFA responses).
- 2026 overwriting ground and retention schedule at N-057 (schedule text p. 255 of 258).
- Defense filings swept for the affidavit negative: Doc 013, Doc 038, Doc 040, Doc 053, Doc 054, Doc 055, Doc 056, Doc 063, Doc 065, Doc 070, Doc 072, Doc 075, Doc 077, Doc 083, and the Responses to Request for Admissions served 5/15/26 (101 pages across the set).
- Sweep documented in the 8/20/26 verification memo on the 10255 defense filings; the negative reaches that set and no further.
- Seven other hearings that year drew a "no records" response in the same letter.

NEW-P1, N-157, N-042, N-098

Full card on the map · Court Oversight and Conflict Judges in the Sixth Circuit page

On August 31, 2025 Husband asked in writing which camera system captured the April 4, 2025 hearing, whether the courtroom microphones connect to it, what the video captures, and why routine surveillance video exists for exactly one hearing of the eight requested. A letter dated September 8, 2025, received by mail, re-asserted the security exemption in the same words as the office's August 21, 2025 response, citing the judicial-branch rule, the security-system statute, and a 2015 attorney general opinion. It engaged none of the four questions, and it stated: "the court's position to your follow-up request has not changed." The August 21 letter had opened: "Chapter 119, Florida Statutes, does not apply to records of the judicial branch of government." Months later, in court discovery, the same defendants admitted in writing that no court order determines the video confidential (N-053), and their one-word denial that nobody had viewed the footage before this denial named no viewer, no date, and no authority (N-103). At the August 17, 2026 hearing their counsel said: "We didn't need to attach an affidavit" (NEW-P11). No affidavit or other sworn statement appears in any defense filing in this case as swept through September 17, 2026. [IGNORED]

The exemption invoked here reaches only records that actually are security-system information. That is a factual predicate, and it can be tested. Article I, section 24(a) presumes the record open and puts the burden of proving the predicate on the custodian asserting it. Each of the four questions on file had a short answer if the predicate is true. Stating that answer was the office's burden, and the letter left it unstated.

the security exemption was re-asserted by letter over a recording that no sworn statement in the record, as swept, identifies as security-camera footage, while the four questions built to test that sat eight days old and unanswered

The September 8 letter: 10255 exhibit DIN 6 p. 44 (170 pages). Husband's September 12 reply attaching it: DIN 6 pp. 21-22. The August 21, 2025 letter, pp. 1-2, in the matter's correspondence file; the September 8 letter repeats its exemption paragraph word for word, although it dates its antecedent to "August 26, 2025." The May 15, 2026 responses to requests for admission, Nos. 2, 4 and 6. The August 17, 2026 certified transcript, 16:4-7. Affidavit sweep, September 26, 2026: eighteen defense documents, 117 pages (Docs 013, 038, 040, 053, 054, 055, 056, 063, 065, 070, 072, 075, 077, 083, 094, 098, the September 17, 2026 First Amended Response, Filing 257283141, and the May 15, 2026 responses). Zero affidavits, declarations under penalty, sworn statements, notarizations, jurats or custodian certifications. Every "affidavit" hit sits inside the reproduced Radford block quote or a summary-judgment rule recital.

N-053, NEW-P11, N-157

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Five emails withheld as "confidential under judicial immunity" in a records lawsuit that seeks no damages.

The Office of the Attorney General appeared for the judicial defendants in the records mandamus (N-071) and asserted judicial immunity as a ground for withholding judicial records. It first appears in Doc 040, filed January 8, 2026: "With respect to the Court's mental impressions which may, or may not have been expressed in the records, they are protected by judicial immunity, their personal impressions are protected and not subject to disclosure." It broadens on February 2 in Doc 055: "For the records to which the Thirteenth Judicial Circuit is the custodian of records, Judicial immunity would apply to many of the requested records," and, on page 6, "those are not available for release based on judicial immunity, if such records exist." Doc 065 repeats both on March 4. On April 1 the motion to stay all of Husband's discovery carried it into discovery: "With respect to the Court's mental impressions involved in this litigation, they are protected by judicial immunity and not subject to discovery." That motion produced the stay (FNEW-A4, N-081). Counsel argued it aloud on April 13. It is absent from the May 15 admissions and from Doc 083 of May 26. The August 27 order then required a record-by-record statement of the "specific constitutional, statutory, or rule-based basis" for each withheld record. On September 10 the office listed five withheld emails and wrote beside each: "This document is confidential under judicial immunity." On September 17 an amended response replaced each of those five labels with Rule 2.420(c)(1), which it called "very closely related to judicial immunity," and kept the immunity memorandum. As of September 26, 2026, no order rules on the position. [PENDING]

The office's own April 1, 2026 motion describes judicial immunity as a doctrine that "protects judges from liability for damages for acts performed in the course of their judicial capacities." This petition seeks records, not damages. In each of its first three responses, the office wrote the custodian's duty to "provide the grounds for the exemption and include the statutory cite for the exemption" in the paragraph just before the immunity assertion, and supported the assertion with case law alone. As of September 26, 2026, no order rules on the position.

the lawsuit asks for records, not damages; the Attorney General's office answered with judicial immunity, a doctrine its own filing describes as protection "from liability for damages"; applied to records, the argument makes judges immune from their constitutional duty to open them. The office carried it from its first response to a September 10, 2026 filing that labeled five withheld records "confidential under judicial immunity"; a week later it relabeled the same five under Rule 2.420(c)(1), a rule it called "very closely related to judicial immunity"

Doc 040 pp. 4, 6 (e-filed 1/8/26 4:40 PM); Doc 055 pp. 4, 6 (Filing # 240817260, e-filed 2/2/26 5:17 PM); Doc 065 pp. 5, 7 (e-filed 3/4/26 5:46 PM); Doc 072 pp. 4-5 (Filing # 245071283, e-filed 4/1/26 12:33 PM), including the Limehouse "liability for damages" sentence; 4/13/26 certified transcript (Lexitas 446278) 21:19-22; Doc 095 (8/27/26) p. 4, para. II(d); Doc 098 (Filing 256803151, e-filed 9/10/26 3:52 PM) p. 4; First Amended Response (Filing 257283141, e-filed 9/17/26) pp. 2-4 and footnote 1 ("Amended to include previously omitted paragraph and corrected authority and case law"). Absence: the 5/15/26 admissions, 4 pages, read in full; Doc 083, 26 pages, keyword scan. The immunity paragraphs cite Parrotino, Johnson v. Harris, Forrester v. White, Kalmanson, Mireles, Berry, Fong, Richman, Limehouse, State v. Lewis and DHSMV v. Marks. Signer on every filing: Jessica Schwieterman, Senior Assistant Attorney General, under Attorney General James Uthmeier.

N-048, N-058, N-071

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On March 10, 2026 the judicial defendants served their initial disclosures in the records mandamus, e-filed the next day. The complete contents: four witnesses, Chief Judge Sabella, Judge Ayers, Judge Felix, and a fourth named "RICK MELINDI" as spelled in this filing; one document, listed as "Public Records that were previously provided to Plaintiff and filed in this case on October 15, 2025, located on the docket as DIN 6"; no anticipated damages; no insurance. [PARTIAL]

Initial disclosures exist so each side learns, without having to ask, what the other intends to rely on. In a case about withheld records, the custodian carries the burden of justifying the withholding. The single document these disclosures list is the plaintiff's own court filing. The contested video, the exemption decision, the searches and the missing logs appear nowhere in it. The same weeks show the same pattern: served discovery on those subjects drew no answers by its deadline (N-081), and three weeks after naming its witnesses the office moved to stay all discovery (FNEW-A4).

in a lawsuit about withheld records, the defendants' entire document disclosure was the records production the plaintiff himself had already filed with the court 146 days earlier

Doc 070, Notice of Serving Initial Disclosures, 25-CA-010255, Filing #243572846, certificate of service March 10, 2026, e-filed March 11, 2026 2:26 PM, served under Rule 1.280. The name as filed is "RICK MELINDI"; the companion fee letters are signed Richard T. Melendi, Chief Deputy Court Administrator (N-068). The disclosed document is Husband's own DIN 6 filing of 10/15/25, filed 146 days before the 3/10/26 service date of these disclosures (10/15/25 to 3/10/26).

FNEW-A4, N-081, N-053, N-058

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On April 1, 2026 the Office of the Attorney General, defending the Thirteenth Circuit and its judges in the records mandamus, filed a Motion for Protective Order to Stay Discovery. On the discovery question the motion says: "discovery is improper for a mandamus proceeding as the documents subject to the litigation have been filed with the Court as part of the initial filing or are confidential and have not been provided in accordance with the Florida Statutes." The sentence gives the litigation's documents two possible states, filed with the court, or confidential and not provided in accordance with the Florida Statutes. On judicial records it says: "With respect to the Court's mental impressions involved in this litigation, they are protected by judicial immunity and not subject to discovery." The motion was the noticed matter at the April 13, 2026 hearing. On April 28, 2026 Judge Coleman stayed all of Husband's discovery except requests for admission, depositions included (N-081). The August 27, 2026 order kept the stay in place. [DENIED]

Article I, section 24(a) puts the burden of justifying a withholding on the custodian, and section 119.11(1), which the defendants invoke, gives a records case priority. A protective order requires good cause. The motion was filed while the defendants' own thirty-day discovery deadline was running, and that deadline expired with nothing answered and nothing objected to (N-081). The same motion carried the judicial-immunity position from disclosure into discovery (NEW-AG1). The one channel the stay left open, requests for admission, later produced the written admission that no court order makes the video confidential (N-053).

in a records case the defendants themselves litigate under chapter 119, whose section 119.11(1) requires the court to "set an immediate hearing, giving the case priority over other pending cases," the office moved to stop all discovery into who watched the withheld video and who decided to withhold it, and the court stopped all of it except requests for admission

Doc 072, Motion for Protective Order to Stay Discovery, 25-CA-010255, "Filing # 245071283, e-filed 04/01/2026 12:33:22 PM," six pages; the quoted "or" clause at p. 5 and the immunity sentence at p. 4 (page images). Signed "/s/ Jessica Schwieterman," Senior Assistant Attorney General, Florida Bar No. 116460, under "JAMES UTHMEIER, ATTORNEY GENERAL," certificate of service April 1, 2026. The stay order is Doc 080, signed 4/28/26 (N-081); Doc 095 p. 5, para. III(a), keeps it. The served discovery and its expired deadline are at N-081 (Filing #244103616). The defendants' own invocation of chapter 119: Doc 094 p. 1 and Doc 098 p. 1. Section 119.11(1) is quoted from the 2026 Florida Statutes.

N-081, NEW-AG1, N-058

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On November 26, 2025 the Second District denied the motion to supplement the record with the April 4, 2025 courthouse video, the video Judge Ayers herself invoked and then declined to pursue (N-042), and the recusal documents, naming no panel and giving no reasoning. Husband moved for rehearing of that order on December 1, 2025; the court denied rehearing on January 27, 2026, again naming no judge. Two more followed the same pattern, April 6 and May 12, 2026 (N-087, N-101). Asked in writing to identify who decided, the court refused: writing for Chief Judge Lucas on July 27, 2026, Clerk Kuenzel answered that no document reflects which judges participated, and any unfiled record is confidential under rule 2.420(c)(1). Chief Judge Lucas wrote the same on July 14, and Marshal Haynes again on August 4, 2026 (N-149); Clerk Kuenzel had denied the same category on June 3, 2026 (N-114). Four written refusals, and not one name on any of the orders. [DENIED]

Rule 9.200(f) lets a party supplement an incomplete record. Two orders from the same court kept the courthouse video out, and a third denied rehearing; none names a panel and none gives a reason. Asked in writing which judges decided, the court refused four times. Article I, section 24(a) puts the burden of proving an exemption on the custodian, and a bare rule citation carries none of it.

the appellate court kept the courthouse video out of the record in orders that name no judge and give no reason, and when asked who decided, answered that no such record is filed anywhere a party can reach

- As pleaded at complaint para. 30E.
- 11/26/25 order denying Appellant's "Motion to Supplement the Record with Video of 4/4/25 Hearing and Recusal Documents", filed 2D2025-1936 docket 041: issues "BY ORDER OF THE COURT", carries Kuenzel certification, names no judge.
- 1/27/26 order denying "Motion for Rehearing, Rehearing En Banc, for Clarification, for Formal Written Order, and/or Certification" under Rules 9.330/9.331, filed 2D2025-1936 docket 042; no judge named.
- Chief Judge Lucas's 7/14/26 letter and Marshal Haynes's 8/4/26 email.
- Clerk Kuenzel's 6/3/26 email on file as native PDF; her 7/27/26 response held only as a mailbox text capture, no page image, quoted at N-114 on that basis.
- Video's origin at N-042; withholding of it at N-053.
- Related decision points: N-115.
- Husband's December 1, 2025 motion for rehearing "of its November 26, 2025, order denying Appellant's 'Motion to Supplement the Record with Video of 4/4/25 Hearing and Recusal Documents'" (Filing 236689274), 2D2025-1936 docket 046.

N-042, N-087, N-114, N-053

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Asked whether a judge he is suing may keep deciding his divorce, Husband got one sentence: the petition "is denied."

On February 10, 2026 a panel of Villanti, Sleet, and Smith denied the prohibition petition seven days after it was filed, and one day after the fee posted. The order reads: "Petitioner's petition for writ of prohibition is denied." No opinion, no order to show cause, no response ever required. The petition had asked for a writ "disqualifying Judge Matthew Felix and all judges of the Thirteenth Judicial Circuit from presiding over Case No. 24-DR-001150 and directing a transfer of venue to a neutral circuit pursuant to Fla. Stat. s. 47.122", and named the Thirteenth Judicial Circuit itself as a respondent. The order does not mention venue, transfer, section 47.122, or the circuit as an entity; its caption lists only the two spouses. Judge Felix remained presiding. The structural question this petition raised has now been put to three courts and answered by none (N-059). [DENIED]

Prohibition exists to stop a judge from presiding where disqualification is required, and the Constitution controls over any rule that would let him stay. The petition put a structural question to the court: may a judge who is a named defendant in Husband's pending suit keep deciding Husband's case. The one-sentence denial names its judges and answers nothing else. It required no response, and it is silent on the second thing the petition asked for, transfer of venue under section 47.122. Judge Felix kept presiding.

the petition asking whether a judge who is a defendant in one case may keep presiding over the related one was denied in a single sentence, seven days after filing and one day after the fee posted, with no response ever required from anyone

- Denial order 2/10/26, 2D2026-0279 docket 001, p.1, and copy at docket 008, Mary Elizabeth Kuenzel clerk certification, served on Hillsborough Clerk, Davis, Felix, Hanson.
- Petition of 2/3/26, 2D2026-0279 docket 007, PDF pp. 4-5, 16, 26-27, verified: prayer at section III, para. 44 and WHEREFORE clause: "remanding with instructions to transfer venue to the Sixth Judicial Circuit in Pasco County, or another neutral venue".
- 2D2026-0279 docket sheet, text layer, seven entries, no order-to-show-cause and no response entry.
- Disqualification ruling this followed: N-069. Structural-conflict spine: N-059.

N-138, N-069

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On July 20, 2026 Husband asked the Second District's clerk, under the court's own Internal Operating Procedures, whether any judge is recused in his cases, naming four matters. On July 27, 2026 Clerk Kuenzel answered, "On behalf of Chief Judge Lucas": "You have asked whether any judge is recused in your cases. Judge Andrea Teves Smith is recused in case no. 2D2025-0681." That is the whole answer. No effective date. No statement whether that judge participated in anything in that case before the recusal took effect. Nothing at all about 2D2025-1936 or 2D2026-0279. On July 30 Husband asked for the date the recusal took effect, whether the judge participated in any order before it, and whether any judge is or has been recused in 2D2025-1936, 2D2026-0279 or 2D2026-1955. On August 20, 2026 the Clerk answered the question about the other cases in the present tense only, 'no judges are recused in these cases,' leaving 'or has been recused at any point' unanswered, and answered the date and participation questions with an exemption: 'Any responsive records are confidential and exempt pursuant to rule 2.420(c)(1).' The Court's own letterhead on the July 14, 2026 letter lists exactly one judge named Smith, ANDREA TEVES SMITH, and N-078 records the February 10, 2026 prohibition denial in 2D2026-0279 as issued by a panel of Villanti, Sleet, and Smith. If that is the same judge, then a judge recused in one of this requester's cases sat on the panel that denied prohibition in another. The date that would test it is the date the Court now withholds as exempt. [PARTIAL]

Article I, section 24(a) of the Florida Constitution presumes judicial-branch records open and puts the burden of justifying any withholding on the custodian. The Court's own Internal Operating Procedures, section 1.7, invite exactly this question: a party may ask the clerk whether any judge is recused in the party's case. A judge who is disqualified in a case steps aside from it,. The lawful path was one sentence long: answer as to each case the inquiry named, and state the effective date of any recusal disclosed.

asked under the court's own procedures whether any judge is recused in four named cases, the court disclosed one recusal in one case and gave no date it took effect; asked a second time, it said no judge is now recused in the other cases, left unanswered whether one had been, and said any record of the date is exempt

The clerk's 7/27/26 email, read from the native Gmail message (id 19fa51c4eab02f25, 3:45 PM ET) on 9/26/2026 and matching both tree captures verbatim. The clerk's 8/20/26 reply (Gmail id 1a01fbd3a01d2ddd, filed under Public_Records\by_agency\2D-DCA) answering the 7/30/26 follow-up. The judge roster naming ANDREA TEVES SMITH appears on the page image of the 7/14/26 Lucas letterhead, p. 1. The N-078 panel composition is confirmed on the face of the order, checked against the page image from the rendered page on 9/26/2026: Husband supplied the 2/10/26 prohibition-denial order in 2D2026-0279 on 8/20/26 and it was filed at that case's docket 008, and it names the panel, "VILLANTI, SLEET, and SMITH, JJ., Concur.", over the certification of Mary Elizabeth Kuenzel, Clerk. The four-case inquiry of 7/20/26 under IOP section 1.7. The same 7/27/26 email is the response quoted at N-114 and N-066. Question Protocol, asked 7/30/26 and answered 8/20/26 (date: exempt under 2.420(c)(1); other cases: no judge recused): the effective date of the 2D2025-0681 recusal, her participation before it, and recusals in the two related cases. A date and a yes or no closes the question. A refusal, after the Court volunteered the fact of one recusal, marks the recusal record itself as withheld. An answer that no record of the effective date exists establishes that the Court does not document when its judges step aside.

N-078, N-114

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"Upon receipt of payment, I will proceed with the review": $313 before the court would look for Husband's records.

On August 4, 2026 the Second District's marshal answered a request pending since July 20. Two categories drew a blanket exemption as confidential and exempt. Four lines later the same email reads: "Or records 'referencing me by name.' I have attached two administrative records referencing you by name." One attachment is a Teams message reading, in full, "Pro Se, Christopher Hanson has arrived". On August 4 the telephone-records category drew only that the logs contain phone numbers and voicemails would be reviewed as part of the same process, with no existence statement and no denial; on August 20 the marshal answered it: "There are no responsive phone logs." Everything further was priced at $313.00, payable before any review would proceed. No privilege log, no list of what is withheld, and no description of the search have ever issued. [PARTIAL]

Article I, section 24 presumes records open and puts the burden of proving an exemption on the withholder; an unstated basis is an unmet burden, and a price is not a basis. A categorical exemption's test is whether it is applied categorically. Here the same officer, over the same category, on the same day, asserted the exemption and then attached two records of that description four lines later. Everything else was priced at $313, payable before any review would begin, for records nobody had yet said exist.

the appellate court's custodian asserted a blanket exemption over records "referencing me by name," attached two records of exactly that description in the same email, and put everything else behind $313 in advance

- The marshal's 8/4/26 email with both attachments, produced by the court itself.
- The 7/20/26 request and 7/21/26 acknowledgment in the quoted chain of the same PDF.
- On the telephone-records category, the same email neither produced a record, nor stated one exists, nor cited an exemption. Her 8/20/26 2:40 PM email answered the category: "There are no responsive phone logs." (quoted chain in the marshal's 9/29/26 email PDF, p. 3).
- Full quote: "Telephone records (call detail logs) contain phone numbers. Voicemails will be reviewed as part of the email process above."
- Full quote: "The charge for this time is $313.00. Upon receipt of payment, I will proceed with the review of these e-mail messages and attachments."
- The unattributed supplement denials at N-066 (denied without panel name or reason).
- Cross-links N-115 (the request chain) and N-138 (the IOP provision).

N-115

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A sworn 25-page complaint about Wife's lawyer closed in six days; the lawyer was not asked to respond.

Husband signed a 25-page written complaint against Wife's counsel Scott Davis on February 18, 2025. Six calendar days later, Bar Counsel Allie F. Huston closed it: "The matters upon which your allegations are premised present questions of law and involve a dispute over which a court has jurisdiction." No response cycle began; Davis was never asked to respond. The letter disclosed no review process, no timeframe, and no reconsideration path, and started a one-year clock on the file's destruction. Every Bar decisional letter to Husband on this file came by U.S. mail with no email address, while the same bar counsel answered him by email three times on status alone, deciding nothing (NEW-P6). On files where Husband was respondent or complainant elsewhere, the Bar emailed him; he asked why this file alone came by mail, and no answer is in the record. [DENIED: closed without a response cycle]

Bar counsel 'must investigate' a sworn written complaint and may dismiss only 'after complete investigation.' Husband's 25-page complaint was signed under penalties of perjury on the Bar's own form. Six days later it was closed with no question put to Davis and no rule named; the letter offered resubmission only if a court first made a supporting finding. The presiding judge had said she does not discipline lawyers and declined to question Davis (N-046); her successor has refused to make findings six times (N-091).

the regulator closed a 25-page written complaint against Wife's lawyer in six days without ever asking him to answer it, and told the complaining lawyer to come back once a court made the finding that court has since refused to make

- Huston closure letter 2/24/25, RFA 25-6861, at 1150 Doc 200 p. 29 of 42, filed by Davis himself 6/4/25, Filing #224549972; also at Leon ROA p. 103.
- The complaint signed 2/18/25; Exhibit A is the 2/12/25 Chief Judge letter, Exhibit B is Wife's 12/13/24 motion for a psychological examination, Filing #212815329, incomplete in the filed copy.
- The grammatical subject of the quoted sentence is "The matters upon which your allegations are premised," never "the allegations".
- Rule 3-7.3(b) is quoted in full from the current rule (June 30, 2026 / July 1, 2026 edition); Rules 3-7.3(a), (c) and (d) are read in the same June 30, 2026 edition (print pp. 115-117).
- The 15-day and 10-day windows come from the Bar's public ACAP process page, which is NOT yet captured and filed as a record.
- Six calendar days and four business days both computed from 2/18/25 to 2/24/25; the federal complaint's "six business days" at paras. 2 and 49 is wrong and four is both accurate and stronger.
- Husband's quoted question is at p. 2 of his 6/10/26 6:58 AM email to Bar leadership re the Davis grievance and conflicts, as sent; that email's text layer is ciphered. The document itself does not show a delivery failure (N-124).
- Good-standing certificate: Cynthia B. Jackson, CFO, 8/7/26, CTM-428037.
- The 12/19/24 pre-affirmation of Davis by the same court sits at N-018.
- Court-side receipts for the locked exit: N-046 (4/22/25), N-091 (4/17/26 Tr. 181).
- Husband's own standing: admitted 9/28/2007, active, in good standing, 10-Year Discipline History: None. The only Bar complaint ever filed against him came nine months later, from the judge who had been disqualified from this case (N-032, N-064).
- Related decision points: N-121.

N-126, NEW-P6, N-055, N-077, N-105, N-116, N-011, N-018

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On 9/24/25 the Bar sustained its own closure. Its Director of Intake described three internal reviews of the closure: by a Senior Staff Attorney, by the Director of Intake, and by the Chair of Grievance Committee 13A. The letter stated: "While your disagreement with the outcome of the Bar's investigation is duly noted, there is no further review afforded to closed files and no right to appeal... Further correspondence from you regarding this matter will be placed in the file without response." A day earlier the Chair had made the same point in her own sustaining letter, copying Davis on it. A later public-records request for the file that review would have generated produced, from the closed file, one email about a typographical error (FNEW-B1). The Bar has never reconciled this account with its later, inconsistent statements about the same closure (N-105, N-116). [DENIED]

Three reviews were described in the 9/24/25 letter: a Senior Staff Attorney investigation, a Director of Intake review, and a Grievance Committee Chair review. A review that examined a closure leaves a record, and a closed file is public under the Bar's own rule. No product of any of the three appears in any Bar letter, filed paper or brief. Later Bar statements run against the letter: a filed paper said the Bar 'did not act' (N-105); its Deputy General Counsel said the file was 'disposed of' (N-116).

the Bar described three internal reviews of the closure but produced no record of what any of them did, and told the complainant that anything further he wrote would go in the file without response

- Schuyler letter 9/24/25, Leon ROA p. 641: also states "Extensive rules, procedures, and policies exist to ensure that bar complaints are fully aired, investigated, and reviewed at multiple levels," and "The review of your allegations against Mr. Davis included investigation by a Senior Staff Attorney, review of the closure by the undersigned as Director of Intake, and a review by the Chair of Grievance Committee 13A."
- Gangi letter 9/23/25, Leon ROA p. 641 vicinity and Bar file copy: "I am also copying Mr. Davis on my response so that the attorney is aware that an additional review of this matter has taken place and that I am sustaining the former decisions to close this file as proper and correct."
- Both filed by the Bar's own counsel as Composite Exhibit A to the 1/27/26 motion to dismiss, judicial notice requested at ROA p. 626.
- Answer Brief admissions at 1D2026-0728 Answer Brief p. 24 (PDF p. 30), filed 6/30/26, signed M. Hope Keating: file "was closed without further investigation" and review "limited to the submissions and court records."
- Huston letter 5/6/25, Doc 200 p. 1 (single-Director, up-to-60-days process). Standing Board Policy 15.75 gives complainant 30-day review windows and sets no time standard for the Bar's own reviews.
- "Three-level review" is NOT the letter's phrase and is barred, as are "three-layer," "three-stage," "three-tier"; name the letter's own three steps instead.
- Later inconsistent statements at N-105 (5/22/26) and N-116 (6/5/26). Produced set at FNEW-B1.
- Related decision points: N-126.

N-031, N-105, N-116, N-126

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On 12/1/25 Husband put four written questions to the Bar's Deputy General Counsel about the production from the closed file: whether the Bar had sent or received any communication with Davis beyond the one produced email; if so, what rule provision took that correspondence outside the Rule 3-7.1(b) public record; if not, to confirm that in writing; and whether the Bar would provide a privilege or confidentiality index for anything in the file it treated as outside the public record. On 12/15/25 at 9:15 AM, eight minutes after his morning follow-up, the reply came back in full: "Mr. Hanson: As my correspondence dated November 24 stated, you have been provided the entire public record under Rule 3-7.1(b), Rules Regulating The Florida Bar. This matter is closed. Thanks." Two substantive sentences. Neither answers any of the four questions. The 11/24 correspondence it points back to had said something more: "the bar is not an investigative agency like law enforcement. Our investigative resources are limited. You need to have the court in the underlying litigation make an evidentiary finding that the attorney you complained about committed misconduct." Two days after that reply, on 12/17/25, Husband filed his mandamus petition in Leon County. Fifty-seven days after the questions were asked, the Bar answered the first one for the first time, in its motion to dismiss that suit: "Such records were not provided because they do not exist" (N-077). [REFUSED]

A custodian that withholds records states the basis. A privilege is asserted, not implied. The Bar's own filed paper concedes that Rule 2.420 governs its records, and that rule requires an identified basis for any withholding and a written basis for any refusal. Each of the four questions had a yes-or-no or a document as its answer. The Bar's later court filing proves the answer existed and could be stated in one line, because the Bar stated it in one line. The complainant got it only after he sued, and only in a document written to a court. The refusal was also pre-authorized: three months earlier the Bar had put in writing that further correspondence "will be placed in the file without response" (N-055).

four written questions, each answerable with a yes, a no, a rule citation, or an index; the entire reply was that he had already been given everything and that the matter is closed; the first real answer came 57 days later, in a paper addressed to a judge

The 12/15/25 response is an EMAIL, not a letter: from Richard Courtemanche, Deputy General Counsel, to Husband's personal email address with the ACAP mailboxes and one Bar address in copy, Monday December 15, 2025 at 09:15 AM EST, subject "RE: Christopher Hanson -Continue follow up Deficiencies in Public Records Response: W015656-111025." The only copy in the record is embedded at page 282 of 285 of the exhibit bundle to the Verified Petition for Writ of Mandamus, Filing #237979141, e-filed 12/17/2025 08:40:29 PM. It replies to Husband's own 9:07 AM follow-up that same morning, so it closes a chain rather than answering the 12/1/25 email standing alone. The 11/24/25 Courtemanche quote is at Leon ROA p. 44 (source spells "investigative"; the Bar's briefs render "investitive"). The 12/1/25 four questions are independently narrated inside N-077. The 1/27/26 statement is at Leon ROA p. 634 (motion internal p. 10), footnote 4 same page. Rule 2.420 concession at the same footnote. Rule 3-7.1(b) defines the closed-file public record to include reports, correspondence, papers, recordings, and transcripts of hearings furnished to, served on, or received from the respondent "or the complainant"; the full subdivision is quoted at FNEW-B1 from the current rule.

N-077, N-055, FNEW-B1

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On 6/5/26 the Bar's Deputy General Counsel stated that the records of RFA 25-6861 "have been disposed of pursuant to judicial branch and bar records retention schedule and are no longer available." Appeal 1D2026-0728 was pending when he wrote it. His letter names no disposal date, no schedule provision and no authorizer.

Eleven days later, a second Davis complaint's closure letter calendared that file for disposal too, one year out, in the same words: "In light of the foregoing, this file has been closed effective June 16, 2026. Pursuant to the Bar's records retention schedule, the computer record and file of this matter will be disposed of one year from the date of closure." What matters is what was disposed of during a pending appeal, and the three facts the statement leaves out. [DENIED]

Records subject to a pending appeal cannot be destroyed while it is pending, and a custodian who says a record is gone can state when it went, under what provision, and on whose authority. Article I, section 24(a) presumes records open and puts that burden on the custodian. The file reported destroyed would show how the complaint at N-031 was handled, which the Bar's own papers describe three ways (N-055, N-077, N-105). None of the three required facts appears here.

the Bar reported the file destroyed while the appeal about that very file was pending, and named no disposal date, no schedule provision and no one who authorized it

- Courtemanche letter 6/5/26, request W016446-060426; the $89.36 Category 2 charge recomputes exactly as $65.89 attorney plus $23.47 clerical.
- Wackes letter 6/16/26 p. 2 for the second file's clock, wording identical to Huston 2/24/25 p. 1.
- Huston retention sentence at Leon ROA p. 103; Schuyler restatement at Leon ROA p. 642, 7/16/25, filed by the Bar's own counsel as Composite Exhibit A with a judicial-notice request at ROA p. 626.
- Closure 2/24/25, one year from closure is 2/24/26; records request made 11/10/25; Leon petition filed 12/17/25; dismissal order entered 2/13/26 and rehearing denial 2/24/26, the same calendar day the announced disposal date fell.
- Authorities the Bar relies on for declining to identify records: Bivens v. Tony, 368 So. 3d 16 (Fla. 4th DCA 2023) and Doe v. DeSantis, 390 So. 3d 1245 (Fla. 1st DCA 2024); reporter cites for both not yet confirmed.
- The Leon action's pendency is stated here against the 2/24/26 disposal date; the arithmetic has not been independently rechecked.

N-150, FNEW-B2, N-055, N-132, N-079, N-105

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The judge's office asked the Bar's lawyer for the dismissal order the day before Husband's opposition was filed.

On February 4, 2026 the judicial assistant to Judge Dempsey emailed the Bar's counsel: "Please provide an order in word granting the Motion to Dismiss." Counsel returned a draft the same day. Husband filed his opposition the next day and asked for a hearing. On February 13 the court entered final judgment for the Bar, adopting the Bar's own grounds, whose operative assertion, that the records "were not provided because they do not exist," is not sworn. Husband moved for rehearing on February 19; on February 24 it was denied for lack of any legal or factual basis, with no further motions allowed and the file ordered closed. The certified docket's hearing table is empty; no hearing was ever held. The court added the grounds itself; the Bar's draft had granted the motion in one line. The signed order recites having considered a response that did not exist when the order granting the motion was solicited. [DENIED]

Rule 1.630(d)(2) told the court what a petition showing a prima facie case gets: an alternative writ and a return. A motion is decided after the response is in, and a court that asks the winning side to draft the order does so after deciding. Here the sequence ran backward: order requested from the Bar's counsel first, opposition filed second, final judgment for the Bar signed third, reciting a response that did not exist when the order was requested. Husband asked for a hearing four times in writing; none was set.

the court solicited the dismissal order from the Bar's counsel the day before Husband's opposition was even filed, granted the dismissal without ever holding a hearing, and denied rehearing with the file ordered closed

- Chambers email chain of 2/4, 2/5, and 2/19/26.
- Both orders and the certified Leon progress docket (First DCA record pp. 4-5, 769-770, 775).
- The Bar's motion (pp. 625-638): "for all the reasons articulated in the Defendants' Motion to Dismiss,".
- Husband's response (pp. 644-713).
- Draft-vs-signed comparison by exact text extraction, not OCR.
- Rehearing denial: "no legal or factual basis,".

N-077, N-055

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Four filings met one amended petition. Only the first was compelled by service; each later window was opened by a court act.

At the January 13 conference the court reset the clock although a response was already on file: "even though they did file a response in opposition, technically I can't consider that," it said. Husband objected that he had already had far more than twenty days since service. The court took responsibility for the delay and reset the clock anyway.

The successor judge then vacated that writ and reissued it with a March 4 return date. The third response arrived on the deadline day; when Husband moved to strike the second as untimely, the ruling was that the third "supersedes the February 2, 2026 Response in Opposition."

The first response, the only one compelled by service, raised none of the exemption grounds the video dispute now turns on. Husband's alternative, to vacate in part, was declined. [IGNORED]

Article I, section 24(a) of the Florida Constitution grants the right of access to records and puts the burden of any exemption on the state actor asserting it, and the judicial-branch rule makes review of a denial expedited. A defense left out of the first response is waived. The first response, the only one compelled by service, raised none of the exemption grounds the video dispute now runs on; those grounds arrived in windows opened by court acts, and the last permitted response came seventy-one to seventy-five days after service.

one amended petition drew four responsive filings; each extra chance for the answering defendants came from a court act rather than any motion they filed, and the first response, the only one compelled by service, raised none of the exemption grounds the video dispute now runs on

- Doc 40 p. 1 stamp (first response, 1/8/26, at 20 days from claimed 12/19/25 service; the Clerk's counsel gives 12/23/25, discrepancy preserved)
- Doc 51 Tr. 14:4-7, 14:18-15:6, 15:7-12 (the "I got to give them the twenty days" continuation, and Husband's on-record objection, "they've had a lot more than twenty days since they've been formally served")
- Doc 55 p. 1 stamp and title (2/2/26, again at 20 days)
- Doc 61 p. 3 n.3 (the court's own delay footnote; compares the reset only against a partial vacatur and does not address enforcement of a writ already answered)
- Doc 62 p. 2 para. 3 (the 3/4/26 return)
- Doc 65 p. 1 stamp and title (3/4/26, deadline day)
- Doc 73 p. 2 (the supersession ruling)
- Doc 66 Tr. 31:16-33:1, 33:2-9, 45:9-11, 70:5-18 (the vacate-and-restart origin and Husband's on-record alternative, "You can vacate the order in parts," declined; N-075)
- Doc 40 read in full, all ten pages, for the grounds negative
- Doc 054, the Clerk's unopposed motion for extension of time (e-filed 1/30/26 11:28 AM), and Doc 059, the order extending "Defendants" to March 4, 2026, "noting Plaintiffs consent"; the AG-represented answering defendants filed no extension motion
- Total responses by all defendants: four, including the Clerk's
- Arithmetic, both service dates: from 12/19/25, 12 + 31 + 28 + 4 = 75; from 12/23/25, 8 + 31 + 28 + 4 = 71; 26 + 4 = 30
- Service-date conflict inside the defense's own papers: Doc 040 para. 3 states "On December 19, 2025, Plaintiff served," and Doc 054 para. 2 states that "Plaintiff appears to have effected service of process for several other defendants in this case on December 23, 2025."

N-075, N-070, N-080

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Asked to name one disputed fact, the judge answered: "So, don't ask me to explain those matters to you."

At a 37-minute Zoom conference on July 24, 2026, the motion for entry of the peremptory writ and a motion for rehearing on the discovery stay were both pending. Husband asked for entry or a statement of what remained in dispute. Counsel for the circuit asked for a final hearing; she was not asked to identify an issue of fact.

The court stated it had found issues of fact requiring a final hearing. Husband asked directly what those issues were. The court answered: "Those issues are contained and delineated within their response. If you can't comprehend it or you don't agree with it, then the rule regarding summary judgment is the procedural vehicle available to you." It routed Husband to summary judgment and closed with no ruling on either pending motion. The writ-entry motion had been filed 100 days earlier and remained unruled after the hearing. [IGNORED]

A court that holds issues of material fact remain identifies them, because the party has to be able to meet them. Access to public records is a right under Article I, section 24(a), the judicial-branch rule makes review expedited, and the burden of establishing confidentiality sits with the party asserting it, who after the writ must come forward with facts. The sufficiency of the return is decided before any trial; Husband had withdrawn his summary-judgment motion to stand on the motion for the writ.

the court held that facts were still in dispute and, asked three lines later to name one, pointed to a document instead: "Those issues are contained and delineated within their response," and then "don't ask me to explain those matters to you"

- Certified 7/24/26 transcript, Guldin RPR, certified 8/1/26, signed electronic transcript.
- Cites: 4:17-20, 8:5-8, 9:4-21, 9:22-10:3, 10:11-16, 12:15-24, 13:3-5, 15:25-16:9, 20:25-21:12, 23:8-16, 24:13-25:16, 25:19-22, 26:15-21, 27:8-18, 28:17-22, 32:11-14, 33:10-21, 34:8-9.
- Reporter anomaly at 9:7; that clause is not quoted here.
- Husband: "I think that the law is clear that it's time to enter the writ or at least provide some clarification on what the Court sees as a genuine issue of material fact." (9:22-10:3.)
- Husband directly: "What are the issues of material fact based upon any of defendant's responses?" The court's fuller answer included, "So, don't ask me to explain those matters to you."
- Counsel for the circuit, asked whether she meant a final hearing or summary judgment hearing, answered "No, your Honor, a hearing as in a final hearing." She then said "Thank you, your Honor": the whole of the respondents' participation.
- The confidentiality-burden rule Husband raised drew one remark, "And (e)(1) is a matter for the Appellate Court jurisdiction; right?", and was not returned to.
- The court also stated: "You have not had to wait for hearings. You have not had to wait for responses. You have not had to wait for orders." That is testable against the docket, where the writ-entry motion had sat unruled 100 days.
- Docket numbers are as spoken on the record and are not independently confirmed.
- A public redacted version of the transcript is on file. The court agreed to have its assistant coordinate hearing time on the two pending motions and stated Husband could propound discovery with objections ruled on as brought.
- Related decision points: N-080.

N-053, NEW-AG1, N-089, N-098, N-127

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UF's processing file, produced later under a second records request, shows how the search for Husband's first request was built. On March 30, 2026 at 11:29 AM the records custodian wrote to UF Information Technology: 'Can you please handle the email search for this request? The person did not ask for attachments.' The search covered two mailboxes only, Cuillier and Bambauer, and email only: no text messages, no chat, no other written channel. The time frame was set at December 1, 2024 to March 26, 2026, the request date, while the request ran to 'the date this request is fulfilled.' The IT return came back the same afternoon: 'This search concluded with 103 message(s), which resulted in 330 page(s). No attachments were included.' The request itself, quoted in the custodian's own instruction, had asked for all written communications, including emails, text messages, Signal/WhatsApp messages, memoranda and notes, on personal devices too. UF's position is on the face of its own acknowledgment, which carried a standing note: 'Email searches will not include attachments unless specifically requested.' Whether that request 'specifically requested' attachments is the point the note and the instruction decided against the requester without saying so. A hit-distribution chart in the same file shows that 98.26% of the messages the whole 21-term search returned contained the bare word 'Hanson'; the other twenty terms added almost nothing. That is the 103-message universe every later UF card inherits: the stalled search and the closure at 53 pages (N-096, N-097), the surname withholding (N-100), and the extraction built out of the same set three days after completeness was declared (N-099). [PARTIAL]

The Constitution presumes the records open and puts the burden of justifying any narrowing on the agency. The scope of a search is set by the request's terms. The narrowing here happened in writing, inside UF's own processing file, before the search ran: attachments out, every channel but email out, two mailboxes in, and a date window closing on the request date. What the excluded scope held was never searched, so nobody can say what it contained. UF's later completeness statements (N-096, N-120) describe what this scope returned, not what existed.

before UF's search ever ran, its records office told the IT staff that the requester had not asked for attachments, and scoped the search to two mailboxes and to email alone; the request had asked for written communications

UF's W018964 production, produced July 17, 2026, emails_1.pdf: pp. 2 and 38 (custodian instruction, 3/30/2026 11:29:17 AM, with the request language quoted beneath it), pp. 23-24 and 36-37 (UFIT return, 3/30/2026 12:48:13 PM), p. 222 (hit distribution). Petition appendix App. 8 (UF's 3/26/2026 acknowledgment, carrying the request text and the note 'Email searches will not include attachments unless specifically requested'), Filing 250752293, PDF p. 9. UF response numbers digest, 7/31/26. Checked against the page image 9/26/2026: emails_1 pp. 2, 23 and 38, App. 8; earlier 8/19/2026 ledger for the remaining pages.

N-120

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Husband asked UF for records referencing his case numbers, the judges in those cases, and surveillance video. On May 4, 2026, UF Information Technology wrote to the records custodian that the search "stalled before completing the search of Professor Bambauer's mailbox" and that seventeen messages should have been included previously.

Four and a half hours later the records custodian marked the request complete, and within minutes UF wrote to Husband: "This completes the public records request." What was produced was fifty-three pages, entirely correspondence between Husband and UF representatives, containing no UF-internal email and no record authored by Bambauer.

The custodian's July 7 affidavit presents May 4 as a clean completion. It says nothing about the stalled search, the seventeen missed messages, the 621-page April 24 batch (N-094), or the 88-page extraction built three days later (N-099). The whole sequence surfaced only because Husband filed a second records request. [DENIED]

The Florida Constitution presumes the records open and puts the burden on the agency to justify what it holds back. When a custodian is told its search failed, good faith leaves two doors open: finish the search and respond, or produce what exists and identify the gap. The record shows a third door. At four weeks, the only explanation UF had was the one its lawyer wrote for the custodian that day: the request was "undergoing the legal review" (N-093). At five and a half weeks, its own IT office reported the search had stalled. Four and a half hours after that notice, the request was closed.

UF's own IT office wrote at 10:40 that morning that the search had stalled and that seventeen messages should have been included; four and a half hours later the records office marked the request complete and wrote, "This completes the public records request"

- emails_1.pdf pp. 93, 119, 199 (the 10:40 AM UFIT stall notice at p. 119; a 7:40 AM rendering of the same message also exists, both reported)
- W018964_Granicus.pdf pp. 6-7 (status Completed/Closed 5/4 3:11:24 PM)
- Production email 5/4 3:22 PM (App. 13-15)
- Custodian's affidavit para. 8, sworn to the best of his knowledge and unnotarized; both copies on file are the same two-page, eight-paragraph document (Response Ex. A, PDF pp. 16-17; Doc 006 Ex. C, PDF pp. 30-31)
- Intervals: 10:40 AM to 3:11:24 PM is 4h31m; 3:11:24 PM to 3:22 PM is 10 minutes 36 seconds, which is why the prose says "within minutes" and never "eleven minutes after"; 3/9/26 precedes the 3/26/26 request by 17 days

N-097, NEW-0826-3, NEW-0906-U6, N-100

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UF closed the request at 53 pages the same afternoon its lawyers logged 109 more pages "for review and release approval".

On May 4, 2026, UF's IT office reported that the first search had stalled and that a rerun had run to completion. Minutes later the General Counsel's office confirmed receipt of 109 rerun pages, plus seventeen messages that should have been included previously, copied them to a drive folder for review and release approval, and asked whether to prepare an invoice.

That afternoon the request was marked Completed/Closed, and UF produced fifty-three pages and called the request complete (N-096). The 109 pages and the seventeen messages appeared in no production, affidavit, or motion until September 2, 2026, when UF's counsel delivered them to the judge for in camera review, described in his own inventory, and not to the requester. Three days later a second file was built and routed the same way, to a drive folder for release approval, and it too was never released (N-099). [IGNORED]

The Constitution presumes the records open and puts the burden of justifying a withholding on the agency. A custodian must let the requester inspect non-exempt records located, and state a basis for anything held back. A located record stays responsive after the request is closed. UF's office asked how many pages, for an invoice; the answer went to a review-and-release folder, and closure followed that afternoon at fifty-three pages. UF has never disclosed that the 109 pages exist.

the rerun that finished after the stalled search returned 109 pages and 17 recovered messages that same morning; UF's lawyers put them in a folder for review and release approval and asked about an invoice, and that afternoon UF closed the request at 53 pages

- emails_1.pdf p. 119: Wood to Hines and Quillen, 5/4/26 11:11:08 AM, 109 rerun pages excluding attachments, copied to the PRR drive at W018463-032626\Fr UFIT 05-04-26, with the invoice question; the same page carries the UFIT 10:40 AM stall-and-rerun notice and the seventeen-messages line
- W018964_Granicus.pdf p. 6: status Completed/Closed 5/4 3:11:24 PM
- Production email 5/4 3:22 PM (petition App. 13-15)

N-096, NEW-0906-U5, N-094

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On May 7, 2026, three days after UF declared Husband's request complete, Associate Counsel Amy Quillen asked UF Information Technology to pull results for the case numbers, the judges' names, and surveillance video, and to "provide those results as a separate pdf." IT delivered the same morning: sixteen messages, eighty-eight pages. Within the hour, UF's legal assistant recorded in writing: "I have copied the records to Amy Q's PRR U: Drive to be reviewed by the General Counsel and for approval to be released." The release never happened.

The next day Husband demanded those records and a privilege log. UF produced neither, and no UF filing through its August 10, 2026 case management statement mentions the file; UF's August 31, 2026 hearing exhibit list includes the two May 7 emails from its legal assistant that name it (Exhibits Z and EE). UF produced the correspondence that created, named, transmitted, and filed the extraction, but not the extraction. [IGNORED]

The records law gives a custodian two lawful moves with a located record: produce it, or withhold it under a stated exemption with the required written statement. UF's counsel created a file of exactly the disputed material and made neither move. The next day UF told Husband that what it had not produced was records of other people named Hanson (N-100). One sentence saying where the 88 pages went would settle it. It has never been written.

three days after declaring the records request complete, UF's own lawyer asked for the disputed records "as a separate pdf"; UF's staff routed the 88-page file "for approval to be released"; it was never released or logged, and no UF filing mentioned it until UF's August 31, 2026 exhibit list included the emails that name it

- UF email production emails_1.pdf pp. 267-268: the Quillen 9:16 AM request (p.268), the Quiros 10:11 AM delivery, and the Wood 10:28 AM routing email (p.267), naming the file ISS-444193-W018463-032626-16-88-opt-SpecificKeywords.pdf and flagging a possible invoice "based on the number of pages"
- Full Quillen request: "can you pull out the results with the search terms 13th Circuit, 2025-CA-002469, 25-CA-10255, Judge Kelly Ayers, Judge Matthew Felix, and surveillance video? If yes, please provide those results as a separate pdf."
- keyword chart same page (Hanson 113 messages, 98.26%)
- p. 190; Exhibit D to Doc 006 searched in full (479 pages, text layer plus eye for the 27 pages without one)
- the never-released scope statement checked against UF's four filings, each read in full: not the protective-order motion, not its exhibits, not the response to the order to show cause, not the 8/10/26 case management statement
- UF's 8/31/26 Exhibit List (Filing 256089009) lists the 5/7 Wood emails that name the file as Exhibits Z and EE (PDF pp. 2, 156-158, 181-182)

N-100, NEW-0826-3, NEW-0906-U5, NEW-0906-U6, N-096

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Asked again and again to name any concern about the children, Davis named none, then filed four motions against Husband in one day.

On December 13, 2024, the day Husband's counsel exited on one-day notice over his objection (N-014), Davis filed four motions between 7:31 AM and 1:45 PM: a motion to compel, a judicial default, a guardian ad litem, and a psychological evaluation of Husband. The evaluation motion is unverified; its only allegation about Husband not drawn from his own earlier filing is that his conduct had "become increasingly unstable and erratic." Both child-related motions quote his sentence about withholding payment "certainly in part out of anger and frustration" and stop before the rest of that sentence, which explained he did it to get Wife to produce the bank statements. The very next paragraph of that filing reads: "The last thing Respondent wanted to do was to make this ugly and spend money on lawyers that could be spent on or saved for the children ... He has gone to great lengths of which he is very proud to put the children first." The default was abandoned within six weeks. The compel was granted in part. The guardian ad litem was granted eighteen months later with no unfitness finding. The psychological-evaluation motion has never been resolved. [IGNORED: evaluation prong never resolved]

A motion must have a good-faith basis when filed; what Wife's side did with its own motions is the measure. Husband offered signed medical releases and evaluation attendance, no compulsion needed; Davis declined on the record, stating they wanted a guardian ad litem instead (N-016). The appointment order that finally issued made no findings on Husband's fitness, ordered no evaluation, and stated no concern about the children. The other three motions: abandoned, granted in part, never resolved.

four motions against Husband in one day, two of them quoting his own sentence about withholding a payment and stopping at "out of anger and frustration," before the words that say he did it to get the bank statements

- Docs 067 (7:31 AM), 075 (8:32 AM, para. 7.b), 069 (11:12 AM, p.2 para. 6), 077 (1:45 PM, p.2 paras. 4-6, para. 10).
- Doc 22 para. 26 (the truncated sentence).
- Doc 118 Tr. 9:14-16.
- Doc 138 (partial grant, 2/19/25); source audit on file.
- Related decision points: N-044. Doc 22 para. 27, p. 4 (the paragraph after para. 26); the quotation’s ellipsis omits one clause about health and changes no meaning.

N-001, N-011

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