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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Law Offices of the Public Defender
Eleventh Judicial Circuit of Florida
1320 NW 14th St., Miami, FL 33125
Phone: 305.545.1600

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