Excessive Workload Litigation
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Third District Court of Appeal
Third District Court of Appeal
Opinion, July 7, 2010
Response to Petition and Cross-Petition
State’s Petition for Writ of Common Law Certiorari
Third District Order Granting Motion to Stay and Order for PD to respond
PD11 Reply in Support of Cross-Petition for Writ of Certiorari
Supplemental Response to State's Motion & Motion to Unseal the Transcript
Trial Court
Order Denying Public
Defender’s Motion to Declare Section 27.5303(1)(d), Florida Statutes,
Unconstitutional and Granting Public Defender’s Motion to Withdraw. October
29, 2009
State’s Motion to Stay Order Granting Public Defender’s Motion to Withdraw
State’s Response to Motion to Withdraw
State’s Response to Request for Judicial Notice
State’s
Appendix & Exhibit 1
State’s Exhibit 2
State’s Exhibit 3
State’s Exhibit 4
State’s Exhibit 5
State’s Exhibit 6
State’s Exhibit 7
Motion to
Withdraw and to Declare Section 27.5303(1)(d),Florida Statutes, Unconstitutional
Exhibit A to Motion to
Withdraw
Exhibit B to Motion to
Withdraw
Exhibit C to Motion to
Withdraw
Exhibit D to Motion to
Withdraw
Exhibit E to Motion to
Withdraw
Exhibit F to Motion to
Withdraw
Memorandum of Law in
Support of Motion to Withdraw
Request
for Judicial Notice
Notice of Filing of Amended Affidavit of Jay Kolsky in Support of Motion to
Withdraw
Affidavit of Antoine Bowens filed September 11, 2009
Supplemental Affidavit of Carlos Martinez filed September 21, 2009
Florida Supreme Court
Order Accepting Jurisdiction, May
19, 2010
Brief of
Respondent (State of Florida) on Jurisdiction
Brief of Petitioner
(PD-11) on Jurisdiction
Notice of
Intent to Invoke Discretionary Jurisdiction
Third District Court of Appeal
Motion for Clarification
PD-11's Motions to
Certify Questions of Great Public Importance
State of Florida's Response to Motion to Certify
Third District Court of Appeal
Decision
Invitation to Respond with Supplemental Material
PD-11's Response
State's Response
State's Brief (Petition
for Certiorari)
Response to State's Petition
for Certiorari
State's Reply
Regional Counsel's Brief
(Petition for Certiorari)
Appendix to Regional Counsel's
Brief/Petition
Answer Brief - Response to
Regional Counsel's Petition
Nov. 10, 2008, Order Setting Briefing Schedule and Oral Argument for
March 30,
2009
PD-11's Motion to Dissolve Stay and
Further Expedite Appeal
Appendix to Motion to
Dissolve Stay and Further Expedite Appeal
Order Denying
PD-11's Motion to Dissolve Stay
Supreme Court of Florida September-November 2008
Order Dismissing
Certification for Lack of Jurisdiction
Order Denying
all Motions as Moot Because of Lack of Jurisdiction
State’s
Response to Order to Show Cause
Appendix to State’s Response to Order to Show Cause
Public Defender’s
Reply to State’s Response to Order to Show Cause
Appendix
A to Public Defender’s Reply
Appendix
B to Public Defender’s Reply
PD-11
Unopposed Motion to Expedite Appeal
Appendix to Unopposed Motion to Expedite the Appeal
Public
Defender’s Motion to Dissolve Stay
Appendix
to Public Defender’s Motion to Dissolve Stay
State’s Response
to Motion to Dissolve Stay
Appendix
to State’s Response to Motion to Dissolve Stay
Office of Criminal
Conflict Counsel’s Motion to Intervene
Office of
Criminal Conflict Counsel’s Amended Objection to Dissolving the Stay
Third District Court of Appeal, September 2008
PD's Response to
State's Emergency Motion for Stay
Appendix
to PD's Response to State's Emergency Motion for Stay
Public Defender’s
Suggestion for Certification of Case to Supreme Court of Florida
Appendix to PD's
Suggestion for Certification
Trial Court
Order on Motion to
Appoint Other Counsel, September 3, 2008
Public
Defender’s Closing Statement Submitted After Evidentiary Hearing, August
2008
State
Attorney’s Closing Statement Submitted After Evidentiary Hearing, August
2008
Circuit Court Administrative Order Consolidating PD-11’s Motions to Appoint
Other Counsel
State
Attorney’s Response to Motion to Appoint Other Counsel
Index to Appendix to State Attorney’s Response
Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F
Exhibit G
Exhibit H
Exhibit I
Exhibit J
Exhibit K
Exhibit L
Exhibit M
Public Defender’s Reply to State Attorney’s Response to Motion to Appoint Other
Counsel
Motion to Appoint Other Counsel Due to Conflict of Interest
Memorandum of Law in Support of Motion to Appoint Other Counsel
Appendix of
Exhibits Part 1 of 3.pdf
Appendix of
Exhibits Part 2 of 3.pdf
Appendix of
Exhibits Part 3 of 3.pdf
Notice of Hearing
on Motion to Appoint Other Counsel
American Council of
Chief Defenders (ACCD) Resolution Concerning Excessive Public Defender Excessive
Caseloads in Miami-Dade County, Florida June 5, 2008
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