Saturday, March 31, 2018

Some Reflections on Journalism By Roger Cohen (New York Times)

Thanks to former CNN International anchor Brian James Nelson for sharing this NY Times column.



Some Reflections on Journalism
By Roger Cohen
March 30, 2018

When I was young and in Buenos Aires, fair city, melancholy city, a friend said to me: “Journalism’s a cheap shot for you.” I never asked what she meant but I never forgot it either. I think she meant that journalism tends to stop where artistic creation begins, and that is the realm of deeper truths.

Buenos Aires was awakening to the scope of a national nightmare. Every conversation seemed to end in tears as parents, haunted by terrible imaginings, recalled their children who had been “disappeared” by the military junta. That many of the thousands of corpses were dumped from planes into the Atlantic between 1976 and 1983 was not yet known.

I sat and listened. That’s what journalists do: listen through silences, awaiting a clue. Students summoned by police for questioning (“shouldn’t take more than a half-hour”), never to be seen again. Students bundled into Ford Falcons on Avenida Corrientes. Pregnant women killed only after delivering babies that childless military couples would take.

Argentina, so rich, so plundered, was haunting. Buenos Aires, in its elegance, reminded me of Flaubert’s remark about style, that it’s “the discharge from a deeper wound.” Distance weighed on Argentines. It was a form of banishment.

A woman draped in the Argentine flag alongside a silhouette representing the “disappeared” during a demonstration in Buenos Aires on March 24 marking the 42nd anniversary of the country’s military coup.CreditMartin Acosta/Reuters

I told the story in the way that seemed most revealing to me: from within the anguish of the people I met. The intersection of personal and national psyches has always constituted the richest point of journalistic inquiry for me.

I stuck to what I knew. But facts can be inadequate. I recall two people, a man and a woman, seated at a restaurant in war-ravaged Beirut. The waiters folded the linen napkins with great care, a small act of defiance. Yes, that was verifiable. But what was passing between the couple, what inhabited the small magical space separating their fingertips, and how had it momentarily blotted out the shelling?

The war was one thing, wartime another. It may be debated where the greater truth lay. As Amos Oz, the Israeli novelist, once put it, “Facts at times become the dire enemies of truth.” Picasso’s “Guernica” is a poor factual account of what happened in a Basque village on April 26, 1937, and a magnificent rendering of what has happened in every village that was ever bombed in any war. The painting is a perfect journalistic dispatch, if measured by how much universal truth it contains.

That, however, is not what journalists are about most of the time. Their realm is facts. Stubborn facts, the kind that bring down governments, usher barbarians to judgment. We are living a great journalistic flowering, provoked by the contempt for the truth, and often for the Constitution, of Donald Trump’s White House. In the unending task of keeping the Republic, journalists have made a difference.

Perhaps that’s what it comes down to: making a difference, in some small but important way. Sure, journalism can be a “cheap shot” when it’s self-congratulatory, or voyeuristic, smug or shallow. (“Fake news” is not journalism.) The journalist evokes suffering and moves on; the suffering tends to endure.

There’s a moment in the movie “Gandhi,” when the fictional New York Times correspondent, Vince Walker, having witnessed the brutal British assault on a nonviolent protest by Gandhi supporters at the Dharasana Salt Works, phones in his dispatch. He’s sweating, under pressure, close to tears, as he communicates the last graph: “Whatever moral ascendancy the West held was lost here today. India is free for she has taken all that steel and cruelty can give, and she has neither cringed nor retreated.”

It’s all there: the head and the heart fused, lucidity and emotion, a nudge to history from a correspondent bearing witness. To be there at the cusp of change is a rare gift. Everything in journalism has changed except the essential.

When I was very young, I’d go to the Kruger National Park in South Africa. It seemed nature was slow, with sudden bursts of acceleration. Nothing moved as the heat of the day rose. Then the air quickened. An eagle soared, elephants charged. Life then was a question of waiting and timing. It might idle for several years before packing several into a single one.

Journalism is like that, lulls and accelerations, adrenaline and troubled questioning. What do I recall? Finding two of those stolen Argentine children in Paraguay, being there at Pinochet’s downfall, chronicling the Bosnian war until at last NATO intervened, giving voice to brave Iranians in 2009: the moments when words seem vital.

This week, after a botched attempt at an execution last month, the State of Alabama and lawyers for Doyle Lee Hamm reached a private settlementthat will spare his life. I’d written a column called “Death Penalty Madness in Alabama.” Bernard Harcourt, Hamm’s lawyer, told me, “Without your piece, I don’t think we’d be where we are today. It made all the difference.”
A single life saved, that feels like enough for a lifetime, even if the novel is yet to come.

Deputy JEREMY BANKS' Lawsuit DISMISSED; FDLE Agent Rusty Rodgers Can Now Seek Attorney Fees and Damages

Justice for Michelle O'Connell update:  A federal judge has found FDLE Special Agent Rusty Ray Rodgers had probable cause to detain and search Deputy JEREMY BANKS for homicide of Michelle O'Connell.





On Good Friday/Passover, in a strongly-worded 22-page order, a federal judge has rejected the remaining element of St. Johns County Sheriff DAVID SHOAR's five year intimidation and retaliation  campaign over the Michelle O'Connell homicide case.

Yes, it's finally over.  United States District Court Judge Brian J. Davis has DISMISSED St. Johns County Sheriff's Deputy JEREMY BANKS' civil rights lawsuit against FDLE Special Agent Rusty Ray Rodgers.

Judge Davis previously dismissed BANKS' complaint as failing to state a claim upon which relief can be granted, under Rule 12(b)(6) of the Federal Rules of Civil Procedure.

He allowed BANKS' lawyer, ROBERT McLEOD, II to file an amended complaint. Then came days of deposition and competing motions to resolve the case without trial (summary judgment under Federal Rule of Civil Procedure 56).

Some 3000 pages of evidence were filed for and against duelling summary judgment motions.

In his March 30, 2018 order, Judge Davis roundly rejected BANKS' claims that Rodgers violated his civil and constitutional rights, finding that any reasonable law enforcement officer would have found probable cause that JEREMY BANKS had killed Michelle O'Connell and would have obtained a search warrant. Judge Davis said that alleged "bias" by the career FDLE agent did not amount to a hill of beans, that superficial "errors" were not meaningful, and that BANKS' lawyer had repeatedly misled the Court:

In a lengthy footnote on page 10, Judge Davis wrote:





Judge Davis held:
  • Many of BANKS' claims are "unsupported by citation to the record."
  • [M]ere conclusions and unsupported factual allegations are legally insufficient to defeat a summary judgment motion."
  • Agent Rodgers did not violate BANKS' Fourth Amendment rights to be safe from unreasonable searches and seizures when he obtained search warrants from Judge Charles Tinlin. 
  • The record is "fraught with aspersions of untruthfulness and bad motive," but special Agent Rodgers was supported by probable cause that BANKS committed homicide.
  • Within one month of the death of Michelle O'Connell, BANKS posted on Facebook, "When did I become the things I used to hate?  I'm stranded to this ship, left to fall with the crash of the waves." 
  • Based on undisputed material facts in a 3000 page record, BANKS' lawsuit is DISMISSED.
Why this matters:  On November 13, 2013, eleven (11) days before The New York Times article, and fifteen days before the PBS Frontline story, Sheriff DAVID SHOAR caused a local lawyer to file a harassing lawsuit on his deputy's behalf, which was dismissed on March 30, 2018.    

That is four (4) years, four (4) months, and seventeen (17) days (just shy of 1600 days).

The SLAPP civil rights and malicious prosecution lawsuit was hatched by SHOAR and his henchmen, who found a louche local lawyer to file it.   T

SHOAR's harassing lawsuit was initially filed in our local circuit court, but was removed to federal court, where one complaint was dismissed and the second complaint was just dismissed based on summary judgment.

With the ineluctable logic in Judge Davis' Good Friday/Passover decision, the United States Department of Justice Criminal Division, its Public Integrity Section, the Federal Bureau of Investigation, FBI Corruption Task Force, and a federal Grand Jury will likely not be examining Sheriff DAVID SHOAR's misconduct, including making materially false and misleading statements to federal agents, in violation of 18 U.S.C. 1001.   Will Governor RICK SCOTT fire SHOAR?

Not quoting from the summary judgment order at all, the Record's 399-word story was as follows, notably BOTH unadorned by a byline or quotations from the 22 page order:

Federal judge dismisses Banks’ lawsuit against Rodgers
By The Record
Posted at 7:04 AM
Updated at 7:04 AM

Another chapter in the years-long controversy surrounding the death of a St. Johns County sheriff’s deputy’s girlfriend came to a close this week when a federal judge dismissed the deputy’s lawsuit against the Florida Department of Law Enforcement agent who had investigated the death.

U.S. District Court Judge Brian Davis of the Middle District of Florida, in an order filed Friday, granted Agent Rusty Ray Rodger’s motion for final summary judgement in the case filed against him by Jeremy Banks.

“It is ordered and adjudged that pursuant to this Court’s Order, entered March 30, 2018, judgement is hereby entered in favor of the Defendant Rusty Ray Rodgers, and against Plaintiff, Jeremy Banks, that the Plaintiff take nothing and the action be dismissed on the merits,” the subsequent judgement reads.

Banks had been suing Rodgers for violating his civil rights during Rodgers’ investigation into the death of Michelle O’Connell, alleging, among things, that Rodgers had provided false information to obtain search warrants and unlawfully detained Banks at one point during the investigation.

O’Connell, 24, was found the evening of Sept. 2, 2010, in Banks’ home suffering from a gunshot wound through her mouth.

Rodgers was assigned to the case by FDLE after O’Connell’s family raised concerns about the original investigation — conducted by the St. Johns Sheriff’s Office — that ultimately concluded the death was a suicide.

The gun that killed O’Connell was Banks’ service weapon, and her family has said that she wouldn’t have harmed herself. Banks, who placed the 911 call the night she died saying that she shot herself, maintains his innocence.

The case, which has since been reviewed by multiple medical examiners, remains classified as a suicide, and at least two special prosecutors have looked at it and found there is not enough evidence to bring criminal charges against Banks.

O’Connell’s death has also been the subject of two lengthy articles from The New York Times and a PBS Frontline documentary.


The most recent New York Times story, published in June 2017, painted St. Johns County Sheriff David Shoar as having waged a public campaign to discredit Rodgers and his investigation into the death.

Friday’s order also denied Banks’ attorney Mac McLeod’s motion, filed in March 2017, to strike Rodgers’ pleadings and defenses and enter a default judgement against Rodgers.

Editor’s Note: This is a developing story; check The Record later this week for further reporting.





Edward Adelbert Slavin
  • Edward Adelbert Slavin
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1. A mere 399 words on the Good Friday final Order in Banks v. Rodgers? Are you kidding me? 
2. Still no link to the 22-page final decision by United States District Court Judge Brian J. Davis? Waiting for Sheriff DAVID SHOAR's "spin?" Report the news without fear or favor, please. Your loyal readers will say, "Thank you.'"
  • 12 hours ago
Xavier Excellence
  • Xavier Excellence
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@Edward Adelbert Slavin all Federal Court documents are availible online to view. 

Idiot.
  • 6 hours ago
Edward Adelbert Slavin
  • Edward Adelbert Slavin
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1. I read it. I quoted it. On my blog 3/31/2018
2. BUT Record did NOT read it. Record did NOT quote United States District Court Judge Brian J. Davis's 22-page order granting summary judgment, finding FDLE agent Rusty Rodgers had probable cause to believe Jeremy Banks committed homicide. Still NOT posted, TWO (2) days after Court's MSJ decision on Good Friday/Passover. Why?
3. Excellent point, "@Xavier Excellence," "all Federal Court documents ARE available online to view" on pacer.gov, a paywall site. Thus, in 2014, I advised Record to get pacer.gov account. So why didn't the Record post/quote the MSJ order in a timely manner and post a link?? Read more here:
http://cleanupcityofstaugustine.blogspot.com/2018/03/deputy-jeremy-banks-lawsuit-dismissed.html
4. You called me an "idiot." "@Xavier Excellence," who are you and why are you violating ToS by using false name?
5. Please, describe, explain and articulate your reasons for calling me an "Idiot?" Is this your first post? 
6. Are you a local official? 
7. What are your credentials? 
8. Is "Xavier Excellence" a nomme de guerre for Sheriff David Shoar, who legally changed his name from "Hoar" in 1994?
9. Shoar could only emit inarticulate pejoratives in response to NY Times and PBS Frontline investigative articles by three-time Pulitzer Prize winner Walt Bogdanich.
10. So will "@Xavier Excellence" identify itself? Apologize for calling me an "idiot?" Stop violating ToS? Or will it "just sit there in its wrongness and be wrong?"
11. Will the Record finally print an article on Easter Monday, April 2, 2018, finally reporting what Judge Brian J. Davis actually wrote on Good Friday/Passover in 22-page MSJ order?
12. Or will the Record continue its mendacious mediocrity on this story under GateHouse, as under Morris?« less

12. Or will the Record continue its mendacious mediocrity on this story under GateHouse, as under Morris?« less
  • 2 hours ago
Patty Oconnell
  • Patty Oconnell
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@Edward Adelbert Slavin I will apologize for Excellence. No doubt it is a uneducated person who has low self esteem and hates Justice For Michelle O’Connell.
  • 54 minutes ago
Edward Adelbert Slavin
  • Edward Adelbert Slavin
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@Patty Oconnell 1. First-time poster, “Xavier Excellece” is quite troubled by Judge Davis’s Good Friday/Passover MSJ order in Banks v. Rodgers, calling me “Idiot” after Midnight Easter Sunday morning.  
2. Who is it?  
3. Pray for “Xavier Excellence” this morning.  
4. “Xavier Excellence” knows about the pacer.gov federal court decision website, but apparently NOT about its paywall. “Xavier Excellence” probably does NO research by itself, or it would known that. 
5. Is pacer.gov a paywall “too far,” one that skeleton Record staff could not possibly penetrate on Good Friday, delaying any actual newspaper story until Easter Monday or later? Is GateHouse that impecunious/understaffed that it can’t/won’t report a landmark judicial decision until days later, AFTER giving Sheriff Shoar all of Easter weekend to concoct a response with his deputy and his lawyer? Are you kidding me? 
6. “Xavier Excellence”--Posting to call me “Idiot” after Midnight on Easter Sunday morning--what an angry, dark, twisted soul is “Xavier Excellence.”  
7. I think we might have an idea who it might be -- someone who “hates Justice for Michelle O’Connell.” Sheriff Shoar? Mac McLeod?  
8. Please “come out” of your man-cave and identify yourself, “Xavier Excellence.” Now.  
9. Who are you, “Xavier Excellence?”  
10. Waiting patiently for you to sign your own name to your calumny. 
11. Remember: t’was on Easter Sunday morning, April 20, 2014 that ex-Judge ROBERT KEITH MATHIS (son of segregationist judge who jailed “St. Augustine Four” children) posted as ”“old dog,” about Michele O’Connell case, stating that the FBI has “no jurisdiction.” 
12. Thanks to Record Editor Craig Richardson for later wisely ending anonymous comments: this resulted in MATHIS’ angry posting as “old dog” being publicly revealed« less
SJCinformer007
  • SJCinformer007
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Well, it is TIME for a FRESH START, this wall that has been blocking JUSTICE has FALLEN!

THIS CIVIL RIGHTS LAWSUIT WAS NOTHING MORE THAN A LAYER OF OBSTRUCTION by SHERIFF DAVID SHOAR!

THE MASTERMIND BEHIND THIS POST COVER-UP, IS the HOLDER of the ELECTED OFFICE of ST JOHNS COUNTY SHERIFF DAVID SHOAR!

IT IS TIME FOR A FULL FBI INVESTIGATION OF THE MURDER OF MICHELLE O'Connell by St Johns County Sheriff s Deputy Jermy Banks!

MURDER and EVIDENCE TAMPERING by JERMY BANKS!

IT IS TIME FOR THE FBI TO COME INTO ST JOHNS COUNTY and START FROM THE BEGINNING of THIS MURDER of a BEAUTIFUL WOMAN, a MOTHER, a DAUGHTER, a SISTER, and a GREAT FRIEND TO MANY PEOPLE ... WHOSE NAME IS MICHELE O'Connell ...

MICHELE O'Connell's MURDER DESERVES a 100 % COMPLETE INVESTIGATION INTO THE ENTIRE POST COVER-UP THAT WAS LED by SHERIFF DAVID SHOAR. Sheriff David Shoar did COMMIT at LEAST THREE FIRST DEGRE FELONIES in this POST COVER-UP of the MURDER of MICHELLE, by DEPUTY JERMY BANKS! SHOAR ALSO HAD OTHER HELP FROM the NOW CURRENT CHIEF of the ST AUGUSTINE BEACH POLICE DEPARTMENT. ROBERT HARDWICK WAS CHIEF INVESTIGATOR AT THE TIME and ALSO COMMITTED FIRST DEGREE FELONIES IN THIS COVER-UP. ROBERT HARDWICK and DAVID SHOAR ARE DIRTY COPS GOING BACK 20 YEARS AGO.

HARDWICK and SHOAR BOTH NEED TO NOW PAY THE PRICE FOR THEIR CRIMES COMMITTED IN THIS POST COVER-UP!« less
  • 1 hour ago (edited)
SJCinformer007
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SAR QUOTE:

The case, which has since been reviewed by multiple medical examiners, remains classified as a suicide, and at least two special prosecutors have looked at it and found there is not enough evidence to bring criminal charges against Banks.

1) THE MEDICAL EXAMINERS BOTH BOTCHED THEIR DUTIES and BOTH WERE CHARGED in a CIVIL PROCEDURE FOR THE ERRORS.
2) NEITHER of the TWO SPECIAL PROSECUTORS TOOK THE EVIDENCE THEY HAD BEFORE A GRAND JURY.
3) The FIRST SPECIAL PROSECUTOR, BRAD KING, OWN WORDS PROVE HE FAILED HIS DUTIES AS A STATE ASSISTANT ATTORNEY.
4) THE SECOND STATE SPECIAL PROCTOR, JEFF ASTON OUT of ORLANDO, WAS UNDER CRIMINAL INVESTIGATION HIMSELF FOR MIS-USE OF GOVERNMENT PROPERTY and WOULD HAVE DONE ANYTHING TO HELP RICK SCOTT AS TO NOT GET REMOVED FROM OFFICE

BRAD KING and JEFF ASTON HAD A DUTY and an OBLIGATION TO TAKE THE CASE BEFORE A GRAND JURY PERIOD!

THEY BOTH PROVED TO BE NOTHING MORE THAN CODE of COVER-UP ...« less
  • 1 hour ago (edited)
SJCinformer007
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777.03 Accessory after the fact.— IN MURDER CASES ... FIRST DEGREE FELONY ...

http://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0700-0799/0777/Sections/0777.03.html

both David Shoar, Robert Hardwick and County Attorney Patrick McCormack committed First Degree Felonies in the POST COVER-UP of the MICHELLE O'CONNELL!

MICHELLE O'CONNELL WAS MURDERED by SJC SHERIFF s DEPUTY JERMY BANKS!

MICHELLE O'CONNELL s MURDER WAS COVERED-UP ...
and
that POST COVER-UP, 1st DEGREE FELONIES, WERE LED by SHERIFF DAVID SHOAR PERIOD!

IT IS TIME FOR ALL INVOLVED TO FACE JUSTICE!« less
  • 51 minutes ago (edited recently)
Edward Adelbert Slavin
  • Edward Adelbert Slavin
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Please post PDF copy of order granting summary judgment to Special Agent Rodgers. Thanks.




-----
Still waiting on Record to report the news.  Is it waiting on another handout from Sheriff SHOAR?

Sheriff DAVID SHOAR's website trumpets this ugly travesty of a harassing lawsuit, with materially false and misleading documents created and available at public expense for your edification about SHOAR's extraordinary obstruction of justice on behalf of Deputy BANKS:

Dear Reader, 
Since 2010, many of our citizens have become aware, primarily through the media, of the death of Michelle O’Connell, a 24-year old, St. Johns County woman.  This is a tragic case with many complexities.  There is a tremendous amount of documents and information related to this case available and unfortunately the media is limited by time and space on what they can report.  In the spirit of full disclosure and transparency we have decided to provide through our website as much information as we can.  
 
It will take a serious commitment of time and thought to thoroughly review all of the documents contained in, The St. Johns County Sheriff’s Office: “Review of Michelle O’Connell’s Death Investigation. I ask that you read these documents in chronological order; thus giving you the full understanding of the documented events. Though reading and processing all of this information may be time consuming, I can assure you that the information and narrative is compelling.
I believe that the information contained in these extensive files is vitally important on many different levels and our citizens should have an opportunity to read, research, and make their own assessment. We never want to lose sight of the fact that though this case is tragic in many different ways with a few different victims; the most tragic aspect is that a young woman died prematurely on September 02, 2010, leaving behind a young child.
Thank you for your interest and time.
 

David B. Shoar, Sheriff
 
*PLEASE BE AWARE THAT SOME PHOTOGRAPHS IN THE O’CONNELL CASE REVIEW ARE GRAPHIC*
Item #1O'Connell Case TimelineTimeline
Item #2Case Findings by a Special Prosecutor Appointed by the GovernorFindings
Item #3SJSO's Case ReviewCase Review
Item #4Initial Letter from Sheriff Shoar to Commissioner Bailey filing a complaint against the conduct of Agent Pape and RodgersBailey Letter 1
Item #5Followup Letter to Commisioner Bailey from Sheriff ShoarBailey Letter 2
Item #6Civil Rights Complaint Filed by Sheriff Shoar Against Agents Pape and RodgersFBI Letter
Item #7Director Sanz's Letter Acknowleding Receipt of Sheriff Shoar's Initial ComplaintSanz's Letter 1
Item #8Sheriff Shoar's Response to Director Sanz's LetterSanz's Letter 2
Item #9Letter from Sheriff Shoar to Director Sanz Regarding Conduct of FDLE AgentsSanz's Letter 3
Item #10Larry Dixon (Stepfather of Banks) Formal Letter of Complaint to the FDLE about Agent Rodgers' ConductDixon Letter
Item #11Attorney McCleod's (Banks' Attorney) Formal Letter of Complaint about Agent Rodgers' ConductMcLeod Complaint
Item #12Scott O'Connell Sworn StatementO'Connell Statement
Item #13Banks' Formal Notice of Intent to File a Lawsuit Against Agent Rodgers and FDLEBanks' Intent for Lawsuit
Item #14O'Connell's Formal Notice of Intent to File a Lawsuit against Agent Rodgers and FDLEO'Connell's Intent for Lawsuit
Item #15Report by Jim Casey on SJSO's Case ReviewCasey Report
Item #16Report by Joel Matthews on SJSO's Case ReviewMatthews' Report
Item #17Sheriff Shoar's Letter to Bogdanich Summarizing his Agencies Contacts with Bogdanich and Reasons why he would not have an "One the Record Interview with him."Sheriff's Letter to Bogdanich 1
Item #18Sheriff Shoar's Letter to an Attorney with the New York Times about his Contacts with BogdanichNew York Times Attorney's Letter
Item #19Governor's Executive Order Appointing Special Prosecutor Bill Cervone to Investigate Agent Rodgers for "Official Misconduct"Governor's Executive Order
Item #20Letter from Sheriff Shoar to Special Prosecutor Bill CervoneCervone Letter
Item #21Bogdanich's Letter to Sheriff ShoarBogdanich’s Letter to Sheriff Shoar
Item #22Sheriff Shoar's Second Letter to BogdanichSheriff's Letter to Bogdanich Letter 2
Item #23Banks' Official Lawsuit against FDLE and RodgersBanks Lawsuit against FDLE
Item #24Sheriff Shoar's Most Recent Correspondence with BogdanichSheriff's Recent Correspondence to Bogdanich 3
Item #25Bogdanich's list of Questions for Sheriff Shoar (Sheriff Shoar did not answer these questions to Bogdanich but he is providing them to the General Public)Bogdanich Questions/ Sheriff Shoar’s Responses
Item #26O'Connell Civil Lawsuit vs. FDLE RogersO'Connell Lawsuit
Item #27Dismissal of Banks' Lawsuit (Procedural Issue)Order of Dismissal
Item #28Banks' Refiling of LawsuitFiled_Second_Amemded_Civil_Action
Item #29Press Release 072915Press Release 072915
Item #30SA Ashton Letter to Governor ScottSA Ashton Letter to Governor Scott
Item #31Investigative Report O'ConnellInvestigative Report
Item #32Cervone Investigation Regarding Agent RogersCervone Report
Item #33FDLE Internal Investigation Regarding Agent RogersInternal Report
Item #34March 23 press releasePress Release
Item #35Motion to StrikePlaintiff's Motion to Strike
Item #36Homicide Prosecutor's Affidavit of Agent Rogers UntruthfulnessMark Johnson


Here's the federal court docket sheet, which tells a different story (note that Sheriff SHOAR never gave a deposition):



U.S. District Court
Middle District of Florida (Jacksonville)
CIVIL DOCKET FOR CASE #: 3:14-cv-00065-BJD-MCR


Banks v. Rodgers et al
Assigned to: Judge Brian J. Davis
Referred to: Magistrate Judge Monte C. Richardson
Case in other court: 7th Judicial circuit, St. Johns County, FL, CA13-1672
Cause: 42:1983 Civil Rights Act

Date Filed: 01/15/2014
Date Terminated: 03/30/2018
Jury Demand: Both
Nature of Suit: 440 Civil Rights: Other
Jurisdiction: Federal Question
Plaintiff 
Jeremy Banksrepresented byLeslie H. Morton  
The McLeod Firm
Suite 140
1200 Plantation Island Dr S
St Augustine, FL 32080
904/471-5007
Email: lmorton@themcleodfirm.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Robert L. McLeod , II  
The McLeod Firm
Suite 140
1200 Plantation Island Dr S
St Augustine, FL 32080
904/471-5007
Fax: 904-461-5059
Email: mmcleod@themcleodfirm.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

V.
Defendant 
Rusty Ray Rodgers
an individual 
represented byAmanda J. Woods  
Sheppard, White & Kachergus, PA
215 Washington St
Jacksonville, FL 32202
904/356-9661
Fax: 904/356-9667
Email: sheplaw@att.net
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Bryan E. DeMaggio  
Sheppard, White, Kachergus, & DeMaggio PA
215 Washington St
Jacksonville, FL 32202
904-356-9661
Fax: 904-356-9667
Email: sheplaw@sheppardwhite.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Chelsea R. Winicki  
Kubicki Draper
Suite 1400
76 South Laura Street
Jacksonville, FL 32202
(904) 396-0062
Fax: (904) 396-0380
Email: crw@kubickidraper.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Elizabeth Louise White  
Sheppard, White, Kachergus, & DeMaggio PA
215 Washington St
Jacksonville, FL 32202
904/356-9661
Fax: 904-356-9667
Email: sheplaw@sheppardwhite.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Jonathan W. Graessle  
William S. Graessle, PA
4th Floor
219 Newnan St
Jacksonville, FL 32202
904/353-6333
Fax: 904/353-2080
Email: wsgraessle@fcol.com
TERMINATED: 12/16/2014
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Matthew R. Kachergus  
Sheppard, White, Kachergus, & DeMaggio PA
215 Washington St
Jacksonville, FL 32202
904/356-9661
Fax: 904/356-9667
Email: sheplaw@sheppardwhite.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

William J. Sheppard  
Sheppard, White, Kachergus, & DeMaggio PA
215 Washington St
Jacksonville, FL 32202
904/356-9661
Fax: 904/356-9667
Email: sheplaw@sheppardwhite.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Defendant 
Florida Department of Law Enforcement
TERMINATED: 07/22/2015
represented byCandace W. Padgett  
Vernis & Bowling of North Florida, P.A.
4309 Salisbury Road
Jacksonville, FL 32216
904/296-6751
Fax: 904/296-2712
Email: cpadgett@florida-law.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Leonard Thomas Hackett  
Vernis & Bowling of North Florida, PA
4309 Salisbury Rd
Jacksonville, FL 32216
904/296-6751
Fax: 904/296-2712
Email: lhackett@florida-law.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Counter Claimant 
Rusty Ray Rodgers
an individual 
TERMINATED: 10/09/2015
represented byAmanda J. Woods  
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Bryan E. DeMaggio  
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Chelsea R. Winicki  
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Elizabeth Louise White  
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Jonathan W. Graessle  
(See above for address)
TERMINATED: 12/16/2014
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Matthew R. Kachergus  
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

William J. Sheppard  
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

V.
Counter Defendant 
Jeremy Banks
TERMINATED: 10/09/2015
represented byLeslie H. Morton  
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Robert L. McLeod , II  
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED

Date Filed#Docket Text
03/30/2018118 JUDGMENT in favor of Rusty Ray Rodgers against Jeremy Banks. Signed by Deputy Clerk on 3/30/2018. (Attachments: # 1 Exhibit Blank Bill of Cost Form)(PAM) (Entered: 03/30/2018)
03/30/2018117 ORDER DENYING 88 Plaintiff's Motion to Strike Defendant's Pleadings and Defenses with Prejudice, for Entry of Default Judgment on Liability Issues, and Awarding Attorney's Fees and Costs for Fraud on the Court; GRANTING 91 Defendant's Motion for Final Summary Judgment. The Clerk shall enter judgment accordingly and close this file. Signed by Judge Brian J. Davis on 3/30/2018. (AMP) (Entered: 03/30/2018)
07/10/2017116 NOTICE by Jeremy Banks re 98 Memorandum in opposition, 88 MOTION to Strike Defendant's Pleadings and Defenses with Prejudice, for Entry of Default Judgment on Liability Issues, and Awarding Attorneys' Fees and Costs for Fraud on the Court and Incorporated Memorandum of Law Notice of Re-Filing Deposition Transcripts (Attachments: # 1 Exhibit Deposition.Rodgers.12.05.14.Pt.1 (pp.1-55-Vol.I), # 2 Exhibit Deposition.Rodgers.12.05.14.Pt.2 (pp.56-105-Vol.I), # 3 Exhibit Deposition.Rodgers.12.05.14.Pt.3 (pp.106-160-Vol.I), # 4Exhibit Deposition.Rodgers.12.05.14.Pt.4 (pp.161-212-Vol.II), # 5 Exhibit Deposition.Rodgers.12.05.14.Pt.5 (pp.213-273-Vol.II), # 6 Exhibit Deposition.Rodgers.09.18.15.Pt.1 (pp.274-323-Vol.III), # 7 Exhibit Deposition.Rodgers.09.18.15.Pt.2 (pp.324-373-Vol.III), # 8 Exhibit Deposition.Rodgers.09.18.15.Pt.3 (pp.374-425-Vo.III), # 9 Exhibit Deposition.Rodgers.09.18.15.Pt.4 (pp.426-456-Vol.III), # 10 Exhibit Deposition.Rodgers.09.18.15.Pt.5 (pp.457-479-Vol.III), # 11 Exhibit Deposition.Rodgers.09.18.15.Pt.6 (pp.480-505-Vol.IV), # 12 Exhibit Deposition.Rodgers.09.18.15.Pt.7 (pp.506-532-Vol.IV), # 13 Exhibit Deposition.Rodgers.09.18.15.Pt.8 (pp.533-582-Vol.IV), # 14 Exhibit Deposition.Rodgers.05.06.16.Pt.1 (pp.583-629-Vol.V), # 15 Exhibit Deposition.Rodgers.05.06.16.Pt.2 (pp.630-673-Vol.V), # 16 Exhibit Deposition.Banks.12.03.14.Pt.1 (pp.1-104-Vol.I), # 17 Exhibit Deposition.Banks.12.03.14.Pt.1 (pp.105-177-Vol.II), # 18 Exhibit Deposition.Banks.12.03.14.Pt.1 (pp.178-274-Vol.II), # 19 Exhibit Deposition.Banks.02.02.16.Pt.1 (pp.275-303-Vol.III), # 20 Exhibit Deposition.Banks.02.02.16.Pt.2 (pp.304-333-Vol.III), # 21 Exhibit Deposition.Banks.02.02.16.Pt.3 (pp.334-363-Vol.III), # 22 Exhibit Deposition.Banks.02.02.16.Pt.4 (pp.364-387-Vol.III), # 23 Exhibit Deposition.Banks.02.02.16.Pt.5 (pp.388-414-Vol.IV), # 24 Exhibit Deposition.Banks.02.02.16.Pt.6 (pp.415-444-Vol.IV), # 25 Exhibit Deposition.Banks.02.02.16.Pt.7 (pp.445-477-Vol.IV), # 26 Exhibit Deposition.Banks.02.02.16.Pt.8 (pp.478-501-Vol.IV), # 27 Exhibit Deposition.Banks.02.03.16.Pt.1 (pp.502-552-Vol.V), # 28 Exhibit Deposition.Banks.02.03.16.Pt.2 (pp.553-600-Vol.V), # 29 Exhibit Deposition.Banks.02.03.16.Pt.3 (pp.601-651-Vol.V), # 30 Exhibit Deposition.Banks.02.03.16.Pt.4 (pp.652-697-Vol.V), # 31 Exhibit Deposition.Scott.O'Connell.12.02.14.Pt.1 (pp.1-105-Vol.I), # 32 Exhibit Deposition.Scott.O'Connell.12.02.14.Pt.2 (pp.106-190-Vol.I), # 33 Exhibit Deposition.Scott.O'Connell.12.02.14.Pt.3 (pp.191-217-Vol.II), # 34 Exhibit Deposition.Brutnell.11.17.16.Pt.1 (pp.1-37), # 35 Exhibit Deposition.Brutnell.11.17.16.Pt.2 (pp.38-72), # 36 Exhibit Deposition.Brutnell.11.17.16.Pt.3 (pp.73-108), # 37 Exhibit Deposition.Brutnell.11.17.16.Pt.4 (pp.109-134), # 38 Exhibit Deposition.Hobin.02.04.16.Pt.1 (pp.1-41), # 39 Exhibit Deposition.Hobin.02.04.16.Pt.2 (pp.42-77), # 40 Exhibit Depoisition.Hobin.05.04.16.Pt.1 (pp.78-112), # 41 Exhibit Depoisition.Hobin.05.04.16.Pt.2 (pp.113-134), # 42 Exhibit Deposition.Tolbert.02.22.17.Pt.1 (pp.1-28), # 43 Exhibit Deposition.Tolbert.02.22.17.Pt.2 (pp.29-59), # 44 Exhibit Deposition.Tolbert.02.22.17.Pt.3 (pp.60-90), # 45 Exhibit Deposition.Tolbert.02.22.17.Pt.4 (pp.91-118), # 46 Exhibit Deposition.Tinlin.10.30.15.Pt.1 (pp.1-32), # 47 Exhibit Deposition.Tinlin.10.30.15.Pt.2 (pp.33-58), # 48 Exhibit Deposition.King.12.01.15.Pt.1 (pp.1-31), # 49 Exhibit Deposition.King.12.01.15.Pt.2 (pp.32-59), # 50 Exhibit Deposition.King.12.01.15.Pt.3 (pp.60-88), # 51 Exhibit Deposition.King.12.01.15.Pt.4 (pp.89-109), # 52 Exhibit Deposition.Cole.12.15.17.Pt.1 (pp.1-34), # 53 Exhibit Deposition.Cole.12.15.17.Pt.2 (pp.35-80), # 54 Exhibit Deposition.Cole.12.15.17.Pt.3 (pp.81-122), # 55 Exhibit Deposition.Cole.12.15.17.Pt.4 (pp.123-161), # 56 Exhibit Deposition.Bolante.10.30.15.Pt.1 (pp.1-36), # 57 Exhibit Deposition.Bolante.10.30.15.Pt.2 (pp.37-71), # 58 Exhibit Deposition.Bolante.10.30.15.Pt.3 (pp.72-101), # 59 Exhibit Deposition.Bolante.10.30.15.Pt.4 (pp.102-140), # 60 Exhibit Deposition.Tilley.12.01.15 (pp.1-69-Vol,I), # 61 Exhibit Deposition.Tilley.05.10.16 (pp.70-99-Vol.II), # 62 Exhibit Deposition.Clark.07.27.16.Pt.1 (pp.1-34), # 63 Exhibit Deposition.Clark.07.27.16.Pt.2 (pp.35-71), # 64 Exhibit Deposition.Hardwick.05.26.16.Pt.1 (pp.1-42), # 65 Exhibit Deposition.Hardwick.05.26.16.Pt.2 (pp.43-83), # 66 Exhibit Deposition.Hardwick.05.26.16.Pt.3 (pp.84-118), # 67 Exhibit Deposition.Faircloth.06.23.16.Pt.1 (pp.1-33), # 68 Exhibit Deposition.Faircloth.06.23.16.Pt.2 (pp.34-66), # 69 Exhibit Deposition.Faircloth.06.23.16.Pt.3 (pp.67-106), # 70 Exhibit Deposition.Gladson.Pt.1 (pp.1-39), # 71 Exhibit Deposition.Gladson.Pt.2 (pp.40-81), # 72 Exhibit Deposition.Gladson.Pt.3 (pp.82-119), # 73 Exhibit Deposition.Morris.Pt.1 (pp. 1-41), # 74Exhibit Depositiion.Morris.Pt.2 (pp.42-82), # 75 Exhibit Deposition.Morris.Pt.3 (pp.83-129))(Morton, Leslie) (Entered: 07/10/2017)
07/10/2017115 ORDER GRANTING 114 Joint Motion to Stay Pretrial Deadlines. No later than July 14, 2017, all documents the parties wish the Court to consider must be filed with the Court under seal or on the public docket. The Fifth Amended Case Management and Scheduling Order 87 is VACATED and this case is REMOVED from the August, 2017 trial term. Signed by Judge Brian J. Davis on 7/10/2017. (AMP) (Entered: 07/10/2017)
07/05/2017114 Joint MOTION to Stay Pre-trial Deadlines re: 87 FIFTH AMENDED CASE MANAGEMENT AND SCHEDULING ORDER, by Rusty Ray Rodgers. (Winicki, Chelsea) Modified on 7/6/2017 to create docket entry relationship. (TMC) (Entered: 07/05/2017)
05/26/2017113 ENDORSED ORDER: 111 Plaintiff's Motion for Leave to File a Response to Defendant's Reply to Plaintiff's Memorandum of Law in Opposition to Defendant's Motion for Final Summary Judgment is DENIED. Signed by Judge Brian J. Davis on 5/25/2017. (AMP) (Entered: 05/26/2017)
05/22/2017112 RESPONSE to Motion re 111 MOTION for leave to file Response to Defendant's Reply to Plaintiff's Memorandum of Law in Opposition to Defendant's Motion for Final Summary Judgmentfiled by Rusty Ray Rodgers. (DeMaggio, Bryan) (Entered: 05/22/2017)
05/19/2017111 MOTION for leave to file Response to Defendant's Reply to Plaintiff's Memorandum of Law in Opposition to Defendant's Motion for Final Summary Judgment by Jeremy Banks. (Morton, Leslie) (Entered: 05/19/2017)
05/16/2017110 NOTICE of Filing Deposition Transcripts by Jeremy Banks re 101 Notice (Attachments: # 1 Exhibit, # 2 Exhibit)(Morton, Leslie) Modified on 5/17/2017 to edit text (PAM). (Entered: 05/16/2017)
05/16/2017109 NOTICE of Filing Deposition Transcripts by Rusty Ray Rodgers (Attachments: # 1 Exhibit, # 2 Exhibit)(Winicki, Chelsea) Modified on 5/17/2017 to edit text (PAM). (Entered: 05/16/2017)
05/16/2017108 REPLY re 98 Memorandum in opposition to Defendant Rusty Rodgers' motion for Final Summary Judgment filed by Rusty Ray Rodgers. (Winicki, Chelsea) Modified on 5/16/2017 to edit text (PAM). (Entered: 05/16/2017)
05/16/2017107 NOTICE of Objection to Plaintiff's Notice of Filing Deposition Transcripts by Rusty Ray Rodgers (Winicki, Chelsea) Modified on 5/16/2017 to edit text (PAM). (Entered: 05/16/2017)
05/15/2017106 NOTICE of Filing Deposition Transcripts re 91 MOTION for summary judgment by Rusty Ray Rodgers (Attachments: # 1 Exhibit AA (vol 1), # 2 Exhibit AA (vol 2), # 3 Exhibit AA (vol 3), # 4 Exhibit AA (vol 4), # 5 Exhibit AA (vol 5), # 6 Exhibit I (1 of 2), # 7 Exhibit I (2 of 2), # 8 Exhibit J (vol 1), # 9 Exhibit J (vol 2), # 10 Exhibit J (vol 3), # 11 Exhibit J (vol4), # 12 Exhibit J (vol 5), # 13 Exhibit Q, # 14 Exhibit R, # 15 Exhibit W)(Winicki, Chelsea) Modified on 5/16/2017 to edit text and link correctly (PAM). (Entered: 05/15/2017)
05/08/2017105 ENDORSED ORDER: 103 Defendant, Rusty Ray Rodgers' Motion for Leave to File a Reply to Plaintiff's Memorandum of Law in Opposition to Defendant Rusty Ray Rodgers' Motion for Final Summary Judgment is GRANTED. Defendant may file a Reply of no more than seven (7) pages on or before May 16, 2017. Signed by Judge Brian J. Davis on 5/8/2017. (AMP) (Entered: 05/08/2017)
05/05/2017104 MEMORANDUM in opposition re 103 Motion for Leave to file document filed by Jeremy Banks. (Morton, Leslie) (Entered: 05/05/2017)
05/04/2017103 MOTION for leave to file reply to 98 MEMORANDUM in opposition re 91 Motion for summary judgment by Rusty Ray Rodgers. (Winicki, Chelsea) Modified on 5/5/2017 to edit text(PAM). (Entered: 05/04/2017)
04/28/2017102 NOTICE by Jeremy Banks re 100 Notice (Other), 98 Memorandum in opposition Amended Notice of Filing Redacted Exhibits (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit)(Morton, Leslie) (Entered: 04/28/2017)
04/28/2017101 NOTICE by Jeremy Banks re 98 Memorandum in opposition, 88 MOTION to Strike Defendant's Pleadings and Defenses with Prejudice, for Entry of Default Judgment on Liability Issues, and Awarding Attorneys' Fees and Costs for Fraud on the Court and Incorporated Memorandum of Law Notice of Filing Deposition Transcripts (Attachments: # 1 Exhibit, # 2 Exhibit, # 3Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit, # 14 Exhibit, # 15 Exhibit, # 16 Exhibit, # 17 Exhibit, # 18 Exhibit, # 19 Exhibit, # 20 Exhibit, # 21 Exhibit, # 22 Exhibit, # 23 Exhibit, # 24 Exhibit, # 25 Exhibit, # 26 Exhibit, # 27 Exhibit, # 28 Exhibit, # 29 Exhibit, # 30 Exhibit, # 31 Exhibit, # 32 Exhibit, # 33 Exhibit, # 34 Exhibit, # 35 Exhibit, # 36 Exhibit, # 37 Exhibit, # 38 Exhibit, # 39 Exhibit, # 40 Exhibit, # 41 Exhibit, # 42 Exhibit, # 43 Exhibit, # 44 Exhibit, # 45 Exhibit, # 46 Exhibit, # 47 Exhibit, # 48 Exhibit, # 49 Exhibit, # 50 Exhibit, # 51 Exhibit, # 52 Exhibit, # 53 Exhibit, # 54 Exhibit, # 55 Exhibit, # 56 Exhibit, # 57 Exhibit, # 58 Exhibit, # 59 Exhibit, # 60 Exhibit, # 61 Exhibit, # 62 Exhibit, # 63 Exhibit, # 64 Exhibit, # 65 Exhibit, # 66 Exhibit, # 67 Exhibit, # 68 Exhibit, # 69 Exhibit, # 70 Exhibit, # 71 Exhibit, # 72 Exhibit, # 73 Exhibit, # 74 Exhibit, # 75 Exhibit)(Morton, Leslie) (Entered: 04/28/2017)
04/26/2017100 NOTICE by Jeremy Banks re 98 Memorandum in opposition Redacted Exhibits (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit)(Morton, Leslie) Modified on 4/27/2017 (PAM). Counsel directed to re-file exhibits in a redacted format and file complete transcripts and deposition. Modified on 5/1/2017 (PAM). Doc. 6 , 7 , 8 removed due to personal identifiers. See Doc. 102 (Entered: 04/26/2017)
04/25/201799 ENDORSED ORDER: The parties shall file the complete depositions corresponding to any filed deposition excerpts on or before May 15, 2017. Signed by Judge Brian J. Davis on 4/25/2017. (AMP) (Entered: 04/25/2017)
04/24/201798 MEMORANDUM in opposition re 91 Motion for summary judgment filed by Jeremy Banks. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit, # 14 Exhibit, # 15 Exhibit, # 16 Exhibit, # 17 Exhibit, # 18 Exhibit, # 19 Exhibit, # 20 Exhibit, # 21 Exhibit, # 22 Exhibit, # 23 Exhibit, # 24 Exhibit, # 25 Exhibit, # 26 Exhibit, # 27 Exhibit, # 28 Exhibit, # 29 Exhibit, # 30 Exhibit, # 31 Exhibit, # 32 Exhibit, # 33 Exhibit, # 34 Exhibit, # 35Exhibit, # 36 Exhibit, # 37 Exhibit, # 38 Exhibit, # 39 Exhibit, # 40 Exhibit, # 41 Exhibit, # 42 Exhibit, # 43 Exhibit, # 44 Exhibit, # 45 Exhibit, # 46 Exhibit, # 47 Exhibit)(Morton, Leslie) Modified on 4/25/2017 (PAM). Counsel directed to re-file exhibits due to dates of births, deposition and transcript excerpt, and etc. Modified on 5/1/2017 (PAM). Doc. 19 and 21 removed due to personal identifiers. See Doc. 102 Modified on 5/1/2017 (PAM). See Doc. 101 for Complete transcripts and or depositions. (Entered: 04/24/2017)
04/24/201797 ENDORSED ORDER: Plaintiff's Motion for Leave to File a Response in Excess of Twenty (20) Pages 96 is GRANTED. Plaintiff may file a response not to exceed twenty-seven (27) pages to 91 Defendant's Motion for Summary Judgment. Signed by Judge Brian J. Davis on 4/24/2017. (AMP) (Entered: 04/24/2017)
04/21/201796 MOTION for Leave to File Excess Pages by Jeremy Banks. (Morton, Leslie) (Entered: 04/21/2017)
04/19/201795 NOTICE of unavailability of counsel by Rusty Ray Rodgers from May 16, 2017 to May 29, 2017. (Winicki, Chelsea) (Entered: 04/19/2017)
04/14/201794 MEDIATION report Hearing held on 4/12/2017. Hearing outcome: Impasse. (PAM) (Entered: 04/14/2017)
04/06/201793 RESPONSE to Motion re 88 MOTION to Strike Defendant's Pleadings and Defenses with Prejudice, for Entry of Default Judgment on Liability Issues, and Awarding Attorneys' Fees and Costs for Fraud on the Court and Incorporated Memorandum of Law filed by Rusty Ray Rodgers. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L)(Winicki, Chelsea) (Entered: 04/06/2017)
03/31/201792 SUMMARY JUDGMENT NOTICE re 91 MOTION for summary judgment by Rusty Ray Rodgers. Signed by Deputy Clerk on 3/31/2017. (DLC) (Entered: 03/31/2017)
03/30/201791 MOTION for summary judgment by Rusty Ray Rodgers. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21Exhibit U, # 22 Exhibit V, # 23 Exhibit W, # 24 Exhibit X, # 25 Exhibit Y, # 26 Exhibit Z, # 27 Exhibit AA, # 28 Exhibit BB)(Winicki, Chelsea) (Entered: 03/30/2017)
03/30/201790 ENDORSED ORDER: Defendant's Motion for Leave to File a Motion in Excess of Twenty-Five (25) Pages 89 is GRANTED. Defendant may file a motion for summary judgment not to exceed thirty (30) pages. Signed by Judge Brian J. Davis on 3/30/2017. (AMP) (Entered: 03/30/2017)
03/29/201789 MOTION for leave to file a Motion in Excess of Twenty-Five pages by Rusty Ray Rodgers. (Winicki, Chelsea) (Entered: 03/29/2017)
03/23/201788 MOTION to Strike Defendant's Pleadings and Defenses with Prejudice, for Entry of Default Judgment on Liability Issues, and Awarding Attorneys' Fees and Costs for Fraud on the Court and Incorporated Memorandum of Law by Jeremy Banks. (Attachments: # 1 Appendix, # 2 Appendix, # 3 Appendix)(Morton, Leslie) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 03/23/2017)
01/11/201787 FIFTH AMENDED CASE MANAGEMENT AND SCHEDULING ORDER: Discovery due by 3/1/2017; Dispositive motions due by 3/30/2017; Conduct mediation hearing by 4/17/2017; Pretrial statement due by 7/12/2017; Final Pretrial Conference set for 7/19/2017 at 10:00 AM in Jacksonville Courtroom 12 C before Judge Brian J. Davis; Jury Trial set for trial term commencing on 8/7/2017 at 9:00 AM in Jacksonville Courtroom 12 C before Judge Brian J. Davis. Signed by Judge Brian J. Davis on 1/11/2017. (AMP) (Entered: 01/11/2017)
12/12/201686 ORDER GRANTING 85 Renewed Joint Motion for Continuance and Motion for Extension of Deadlines. The Court's Fourth Amended Case Management and Scheduling Order 81 is VACATED and a Fifth Amended Case Management and Scheduling Order will enter forthwith. Signed by Judge Brian J. Davis on 12/12/2016. (AMP) (Entered: 12/12/2016)
12/09/201685 JOINT MOTION for continuance and MOTION for extension of deadline in the fourth amended case management and scheduling order by Rusty Ray Rodgers. (Winicki, Chelsea) Motions referred to Magistrate Judge Monte C. Richardson. Modified on 12/12/2016 to edit text(PAM). (Entered: 12/09/2016)
12/01/201684 ORDER Denying Without Prejudice 83 Joint Motion for Preliminary Pretrial Conference. Signed by Judge Brian J. Davis on 11/30/2016. (AMP) (Entered: 12/01/2016)
11/22/201683 JOINT MOTION for miscellaneous relief, specifically Preliminary Pretrial Conference by Jeremy Banks. (Morton, Leslie) Modified on 11/22/2016 to edit text (PAM). (Entered: 11/22/2016)
11/03/2016Mail addressed to Terrance E. Schmidt marked Return to Sender, Insufficient Address, Unable to Forward re: 81 Fourth Amended Case management and scheduling order. Mail resent to Terrance E. Schmidt at new address of Bledsoe, Jacobson, Schmidt, Wright & Sussman at 501 Riverside Avenue, Suite 903, Jacksonville, FL 32202. Chambers notified. (PAM) (Entered: 11/03/2016)
10/25/201682 CASE REFERRED to Mediation. (PAM) (Entered: 10/26/2016)
10/25/201681 FOURTH AMENDED CASE MANAGEMENT AND SCHEDULING ORDER: Discovery due by 11/30/2016; Dispositive motions due by 12/30/2016; Conduct mediation hearing by 1/17/2017; Pretrial statement due by 4/12/2017; Final Pretrial Conference set for 4/19/2017 at 10:00 AM in Jacksonville Courtroom 12 C before Judge Brian J. Davis; Jury Trial set for trial term commencing on 5/1/2017 at 9:00 AM in Jacksonville Courtroom 12 C before Judge Brian J. Davis. Signed by Judge Brian J. Davis on 10/25/2016. (AMP) Modified on 12/13/2016 (PAM). Vacated Per Order Doc. 86 (Entered: 10/25/2016)
10/05/201680 ORDER GRANTING IN PART 78 Joint Motion for Continuance. The Court's Third Amended Case Management and Scheduling Order 77 is VACATED and a Fourth Amended Case Management and Scheduling Order will enter forthwith. Signed by Judge Brian J. Davis on 10/3/2016. (AMP) (Entered: 10/05/2016)
09/13/201679 NOTICE Cancellation of Deposition by Rusty Ray Rodgers (Winicki, Chelsea) Modified on 9/14/2016 to edit text (PAM). (Entered: 09/13/2016)
08/30/201678 JOINT MOTION to Continue Trial by Rusty Ray Rodgers. (Winicki, Chelsea) Modified on 8/30/2016 to edit text (PAM). (Entered: 08/30/2016)
05/09/201677 THIRD AMENDED CASE MANAGEMENT AND SCHEDULING ORDER: Discovery due by 9/30/2016; Conduct mediation hearing by 10/17/2016; Dispositive motions due by 10/31/2016; Pretrial statement due by 2/15/2017; Final Pretrial Conference set for 2/22/2017 at 10:00 AM in Jacksonville Courtroom 12 C before Judge Brian J. Davis; Jury Trial set for trial term commencing on 3/6/2017 at 9:00 AM in Jacksonville Courtroom 12 C before Judge Brian J. Davis. Signed by Judge Brian J. Davis on 5/9/2016. (AMP) Modified on 10/11/2016 (PAM). Vacated Per Order Doc. 80 (Entered: 05/09/2016)
05/02/201676 RESPONSE re 75 Order on motion to extend time filed by Jeremy Banks. (Morton, Leslie) (Entered: 05/02/2016)
11/06/201575 ORDER Granting 74 Joint Motion to Extend Case Management Deadlines and Trial Date, with instructions to the Clerk. The Court's Second Amended Case Management and Scheduling Order is VACATED and a Third Amended Case Management and Scheduling Order will be entered. On May 2, 2016, the parties shall file a joint notice as directed in this order. Signed by Judge Brian J. Davis on 11/6/2015. (AMP) (Entered: 11/06/2015)
11/04/201574 JOINT MOTION to extend time to Case Management Deadlines and Trial Date by Rusty Ray Rodgers. (Winicki, Chelsea) Motions referred to Magistrate Judge Monte C. Richardson. Modified on 11/5/2015 to edit text (PAM). (Entered: 11/04/2015)
10/09/201573 ORDER dismissing without prejudice Defendant's cause of action and counter-claim against Plaintiff. The Clerk is directed to terminate Counter Claimant Rodgers and Counter Defendant Banks from the Court docket. Signed by Judge Brian J. Davis on 10/9/2015. (AMP) (Entered: 10/09/2015)
09/14/201572 NOTICE of Dismissal Without Prejudice by Rusty Ray Rodgers (Sheppard, William) Modified on 9/15/2015 to edit text (PAM). (Entered: 09/14/2015)
09/08/201571 ANSWER and affirmative defenses with Jury Demand to 56 Amended Complaint (Second), COUNTERCLAIM against Jeremy Banks by Rusty Ray Rodgers.(Sheppard, William) (Entered: 09/08/2015)
08/28/201570 SECOND AMENDED CASE MANAGEMENT AND SCHEDULING ORDER Granting 69 Motion to Extend Case Management Deadline for Discovery. The following settings and deadlines shall apply: Discovery due by 2/1/2016; Dispositive motions due by 3/4/2016; Conduct mediation hearing by 5/2/2016; Pretrial statement due by 7/13/2016; Final Pretrial Conference set for 7/20/2016 at 10:00 AM in Jacksonville Courtroom 12 C before Judge Brian J. Davis; Jury Trial set for trial term commencing on 8/1/2016 at 9:00 AM in Jacksonville Courtroom 12 C before Judge Brian J. Davis. Signed by Judge Brian J. Davis on 8/27/2015. (AMP) (Entered: 08/28/2015)
08/17/201569 MOTION for Extension of Time to Complete Discovery by Rusty Ray Rodgers. (Winicki, Chelsea) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 08/17/2015)
08/10/201568 ENDORSED ORDER granting 67 Motion for Extension of Time to File Response. Defendant Rodgers shall respond to the Second Amended Complaint no later than September 8, 2015. Signed by Magistrate Judge Monte C. Richardson on 8/10/2015. (ADM) (Entered: 08/10/2015)
08/06/201567 MOTION for Extension of Time to File Response/Reply to Plaintiff's Second Amended Complaint by Rusty Ray Rodgers. (Winicki, Chelsea) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 08/06/2015)
07/22/201566 ORDER Denying 57 Defendant Rodgers' Motion to Dismiss; Granting 59 Defendant FDLE's Motion to Dismiss; Denying as Moot 63 Defendant Rodgers' Renewed Motion to Stay Discovery. Counts II and III of the Second Amended Complaint are DISMISSED without prejudice and the Clerk is DIRECTED to terminate the FDLE as a party to these proceedings. Signed by Judge Brian J. Davis on 7/22/2015. (AMP) (Entered: 07/22/2015)
06/09/201565 AMENDED CASE MANAGEMENT AND SCHEDULING ORDER. The following deadlines and settings shall apply: Discovery due by 12/1/2015; Dispositive motions due by 1/4/2016; Conduct mediation hearing by 3/1/2016; Pretrial statement due by 5/18/2016; Final Pretrial Conference set for 5/25/2016 at 10:00 AM in Jacksonville Courtroom 12 C before Judge Brian J. Davis; Jury Trial set for trial term commencing on 6/6/2016 at 9:00 AM in Jacksonville Courtroom 12 C before Judge Brian J. Davis. Signed by Judge Brian J. Davis on 6/8/2015. (AMP) Modified on 6/9/2015 (AMP). (Entered: 06/09/2015)
05/04/201564 RESPONSE in Opposition re 63 MOTION to stay discovery filed by Jeremy Banks. (McLeod, Robert) (Entered: 05/04/2015)
04/20/201563 RENEWED MOTION to stay discovery by Rusty Ray Rodgers. (Winicki, Chelsea) Motions referred to Magistrate Judge Monte C. Richardson. Modified on 4/21/2015 to edit text (PAM). (Entered: 04/20/2015)
04/02/201562 RESPONSE in Opposition re 59 MOTION to dismiss for failure to state a claim Plaintiff's Second Amended Complaint filed by Jeremy Banks. (McLeod, Robert) (Entered: 04/02/2015)
04/02/201561 RESPONSE in Opposition re 57 MOTION to Dismiss Plaintiff's Second Amended Complaint and Supporting Memorandum of Law filed by Jeremy Banks. (McLeod, Robert) (Entered: 04/02/2015)
03/20/201560 Minute Entry for proceedings held before Judge Brian J. Davis: PRETRIAL AND CASE MANAGEMENT CONFERENCE held on 3/20/2015. Court Reporter: Shelli Kozachenko (EAM) Modified text on 3/20/2015 (EAM). (Entered: 03/20/2015)
03/19/201559 MOTION to dismiss Plaintiff's Second Amended Complaint by Florida Department of Law Enforcement. (Hackett, Leonard) Modified on 3/20/2015 to edit text (PAM). (Entered: 03/19/2015)
03/19/201558 CASE MANAGEMENT REPORT. (McLeod, Robert) (Entered: 03/19/2015)
03/19/201557 MOTION to Dismiss Plaintiff's Second Amended Complaint and Supporting Memorandum of Law by Rusty Ray Rodgers. (Winicki, Chelsea) (Entered: 03/19/2015)
03/05/201556 SECOND AMENDED COMPLAINT against Florida Department of Law Enforcement, Rusty Ray Rodgers with Jury Demand. filed by Jeremy Banks.(McLeod, Robert) Modified on 3/6/2015 to edit text (PAM). (Entered: 03/05/2015)
02/24/201555 ORDER finding as moot 53 Motion to Quash. See order for details. Signed by Magistrate Judge Monte C. Richardson on 2/24/2015. (DLC) (Entered: 02/24/2015)
02/24/201554 NOTICE of withdrawal of motion by Rusty Ray Rodgers re 53 Emergency MOTION to quash Plaintiff's Subpoena for Deposition, Issued to Rusty Ray Rodgers and Motion for Protective Order filed by Rusty Ray Rodgers (Attachments: # 1 Exhibit)(Winicki, Chelsea) (Entered: 02/24/2015)
02/24/201553 EMERGENCY MOTION to quash Plaintiff's Subpoena for Deposition, Issued to Rusty Ray Rodgers and Motion for Protective Order by Rusty Ray Rodgers. (Attachments: # 1 Exhibit)(Winicki, Chelsea) Modified on 2/25/2015 to edit text (PAM). (Entered: 02/24/2015)
02/23/201552 ORDER denying as moot without prejudice to refiling, if necessary, 46 Motion to Compel responsive documents and better responses from Defendant Rusty Ray Rodgers. See order for details. Signed by Magistrate Judge Monte C. Richardson on 2/23/2015. (DLC) (Entered: 02/23/2015)
02/17/201551 ENDORSED ORDER VACATING the Court's 30 Case Management and Scheduling Order and Referral to Mediation, in light of 49 the Court's Order granting the parties' Joint Motion for Pretrial Conference and Case Management. On or before March 19, 2015, the parties shall file a renewed [5-1] Case Management Report, setting forth proposed deadlines to govern this cause. Signed by Judge Brian J. Davis on 2/17/2015. (AMP) (Entered: 02/17/2015)
02/13/201550 NOTICE of Hearing: Pretrial and Case Management Conference are set for 3/20/2015 at 9:00 AM in Jacksonville Courtroom 12 C before Judge Brian J. Davis.(AMP) (Entered: 02/13/2015)
02/13/201549 ORDER Granting 16 Motion to Dismiss; Granting 43 Joint Motion for Pretrial and Case Management Conference; Denying 48 Motion to Reassign Case. Counts I, II, III, V and VI of the Amended Complaint are DISMISSED without prejudice. Plaintiff shall file an Amended Complaint on or before March 5, 2015. Signed by Judge Brian J. Davis on 2/13/2015. (AMP) (Entered: 02/13/2015)
02/02/201548 MOTION to Reassign Case from Track Two Status to Track Three Status by Jeremy Banks. (McLeod, Robert) (Entered: 02/02/2015)
01/30/201547 RESPONSE to Motion re 46 First MOTION to Compel Def to Produce Documents and Provide Complete Responses to First Request filed by Rusty Ray Rodgers. (Attachments: # 1 Exhibit)(Winicki, Chelsea) (Entered: 01/30/2015)
01/16/201546 MOTION to Compel Defendant to Produce Documents and Provide Complete Responses to First Request by Jeremy Banks. (Attachments: # 1 Exhibit Pls Request for Production of Documents, # 2 Exhibit Def. Response to Pls First Request for Production of Documents)(McLeod, Robert) Motions referred to Magistrate Judge Monte C. Richardson. Modified on 1/16/2015 to edit text (PAM). (Entered: 01/16/2015)
12/16/201445 ENDORSED ORDER granting 44 Motion to Withdraw. Jonathan W. Graessle, Esq. is relieved of any further responsibility as counsel for Defendant Rusty Ray Rodgers in this matter. However, Mr. Graessle shall comply with all applicable obligations on withdrawing counsel, including any applicable Bar rules. Signed by Magistrate Judge Monte C. Richardson on 12/16/2014. (ADM) (Entered: 12/16/2014)
12/16/201444 UNOPPOSED MOTION for to withdraw as attorney for Defendant by Rusty Ray Rodgers. (Graessle, Jonathan) Motions referred to Magistrate Judge Monte C. Richardson. Modified on 12/16/2014 to edit text (PAM). (Entered: 12/16/2014)
12/05/201443 JOINT MOTION for pretrial conference and case management conference by Jeremy Banks. (Morton, Leslie) Motions referred to Magistrate Judge Monte C. Richardson. Modified on 12/8/2014 to edit title (BD). Modified on 12/8/2014 to edit text (PAM). (Entered: 12/05/2014)
11/17/201442 ORDER denying 35 Motion for Sanctions and discharging 37 Order to Show Cause. Signed by Magistrate Judge Monte C. Richardson on 11/16/2014. (ADM) (Entered: 11/17/2014)
10/30/201441 ORDER granting 40 Motion to extend time only to the extent that Plaintiff's expert report disclosure deadline is January 5, 2015, and Defendants' expert report disclosure deadline is February 2, 2015. All other terms and deadlines as set forth in 30 Case Management and Scheduling Order, as amended, shall remain intact. Signed by Magistrate Judge Monte C. Richardson on 10/30/2014. (ADM) (Entered: 10/30/2014)
10/29/201440 MOTION to extend time to disclosure of expert reports by Jeremy Banks. (Morton, Leslie) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 10/29/2014)
10/27/201439 RESPONSE TO ORDER TO SHOW CAUSE filed by Rusty Ray Rodgers. (Winicki, Chelsea) (Entered: 10/27/2014)
10/23/201438 NOTICE of compliance re: 36 Order by Jeremy Banks (McLeod, Robert) Modified on 10/23/2014 to edit text (PAM). (Entered: 10/23/2014)
10/06/201437 ORDER taking under advisement 35 Motion for Sanctions. Defendant shall show cause by October 27, 2014 regarding expenses. Signed by Magistrate Judge Monte C. Richardson on 10/6/2014. (ADM) Modified on 11/17/2014 (PAM). Discharged Per Order Doc. #42 (Entered: 10/06/2014)
10/06/201436 ORDER directing Robert L. McLeod, II to be admitted by 11/3/2014. See Order for details. Signed by Magistrate Judge Monte C. Richardson on 10/6/2014. (ADM) (Entered: 10/06/2014)
10/02/201435 NOTICE of withdrawal of motion to compel and renewal of MOTION for sanctions by Jeremy Banks re 33 First MOTION to Compel Deposition of Defendant Rodgers filed by Jeremy Banks (Morton, Leslie) Modified on 10/3/2014 to edit text (PAM). Modified on 10/3/2014 to change event. Chambers notified (PAM). (Entered: 10/02/2014)
09/30/201434 ENDORSED ORDER directing Defendants to respond to 33 Plaintiff's Motion to Compel no later than October 7, 2014, or the Motion will be deemed unopposed. Signed by Magistrate Judge Monte C. Richardson on 9/30/2014. (ADM) (Entered: 09/30/2014)
09/10/201433 MOTION to Compel Deposition of Defendant Rodgers by Jeremy Banks. (Morton, Leslie) Motions referred to Magistrate Judge Monte C. Richardson. Modified on 9/10/2014 to edit text (PAM). (Entered: 09/10/2014)
08/01/201432 ENDORSED ORDER granting 31 Motion to extend time. The Case Management and Scheduling Order 30 is amended to the extent the deadline for filing motions to add parties or to amend pleadings is extended until 20 days after the Court's order on Defendant's Motion to Dismiss. All other terms and deadlines in the Case Management and Scheduling Order shall remain intact. Signed by Magistrate Judge Monte C. Richardson on 8/1/2014. (ADM) (Entered: 08/01/2014)
07/31/201431 MOTION to extend time to File Motions to Add Parties or to Amend Pleadings by Rusty Ray Rodgers. (Winicki, Chelsea) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 07/31/2014)
05/06/201430 CASE MANAGEMENT AND SCHEDULING ORDER: Discovery due by 2/2/2015; Dispositive motions due by 3/2/2015; Conduct mediation hearing by 4/1/2015; Pretrial statement due by 6/17/2015; Final Pretrial Conference set for 6/24/2015 at 10:00 AM in Jacksonville Courtroom 12 C before Judge Brian J. Davis; Jury Trial set for trial term commencing on 7/6/2015 at 09:00 AM in Jacksonville Courtroom 12 C before Judge Brian J. Davis. Signed by Judge Brian J. Davis on 5/5/2014. (Attachments: # 1 Mediation Report Form, # 2 Docket Sheets)(AMP) Modified on 2/18/2015 (PAM). Vacated Per Order Doc. # 51 (Entered: 05/06/2014)
04/30/201429 ORDERED: Defendant's Objection 22 to the Magistrate's April 8, 2014, Order is OVERRULED. Signed by Judge Brian J. Davis on 4/30/2014. (AMP) (Entered: 04/30/2014)
04/29/201428 MEMORANDUM in opposition re 22 Notice (Other) Defendant, Rusty Ray Rodgers' Objection to Magistrate's Order and Motion for Reconsideration filed by Jeremy Banks. (McLeod, Robert) (Entered: 04/29/2014)
04/24/201427 CERTIFICATE of interested persons and corporate disclosure statement by Rusty Ray Rodgers. (Winicki, Chelsea) Modified on 4/25/2014 to edit text (PAM). (Entered: 04/24/2014)
04/24/201426 CASE MANAGEMENT REPORT. (McLeod, Robert) (Entered: 04/24/2014)
04/24/201425 CERTIFICATE of interested persons and corporate disclosure statement by Florida Department of Law Enforcement. (Padgett, Candace) Modified on 4/25/2014 to edit text (PAM). (Entered: 04/24/2014)
04/23/201424 CERTIFICATE of interested persons and corporate disclosure statement by Jeremy Banks identifying Corporate Parent McLeod Law Firm, P.A., Corporate Parent Vernis & Bowling of North Florida, P.A., Corporate Parent FDLE, Corporate Parent Kubicki Draper, Corporate Parent Sheppard, White & Kachergus, P.A., Other Affiliate William J. Sheppard, Other Affiliate Robert L McLeod, Other Affiliate Leonard Thomas Hackett, Other Affiliate Jeremy Banks, Other Affiliate Rusty Ray Rodgers, Other Affiliate Leslie H. Morton, Other Affiliate Chelsea Winicki, Other Affiliate Candace Padgett for Jeremy Banks.. (McLeod, Robert) (Entered: 04/23/2014)
04/17/201423 REQUEST for oral argument on Notice of Objection to Magistrate's Order and Motion for Reconsideration by Rusty Ray Rodgers. (Winicki, Chelsea) (Entered: 04/17/2014)
04/17/201422 OBJECTION to Magistrate's Order and Motion for Reconsideration and Memorandum in Support by Rusty Ray Rodgers (Winicki, Chelsea) Modified on 4/18/2014 to edit text (PAM). (Entered: 04/17/2014)
04/08/201421 ORDER denying 17 Motion to stay discovery. Signed by Magistrate Judge Monte C. Richardson on 4/8/2014. (ADM) (Entered: 04/08/2014)
04/04/201420 RESPONSE in Opposition re 17 MOTION to stay discovery and Relief from Case Management Reporting Requirements Pending Disposition of Dispositive Motion to Dismiss filed by Jeremy Banks. (McLeod, Robert) (Entered: 04/04/2014)
03/31/201419 REQUEST for oral argument re 16 MOTION to Dismiss Plaintiff's Amended Complaint and Supporting Memorandum of Law in Opposition by Jeremy Banks. (McLeod, Robert) (Entered: 03/31/2014)
03/31/201418 MEMORANDUM in opposition re 16 Motion to dismiss Amended Complaint filed by Jeremy Banks. (McLeod, Robert) (Entered: 03/31/2014)
03/21/201417 MOTION to stay discovery and Relief from Case Management Reporting Requirements Pending Disposition of Dispositive Motion to Dismiss by Rusty Ray Rodgers. (Winicki, Chelsea) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 03/21/2014)
03/17/201416 MOTION to Dismiss Plaintiff's Amended Complaint and Supporting Memorandum of Law by Rusty Ray Rodgers. (Winicki, Chelsea) (Entered: 03/17/2014)
03/06/201415 ORDER denying as moot 8 Motion to stay discovery. Signed by Magistrate Judge Monte C. Richardson on 3/6/2014. (ADM) (Entered: 03/06/2014)
03/05/201414 ANSWER and affirmative defenses to 12 Amended Complaint by Florida Department of Law Enforcement.(Padgett, Candace) Modified on 3/6/2014 to edit text (PAM). (Entered: 03/05/2014)
03/05/201413 ORDER denying as moot 6 motion to dismiss. Signed by Judge Brian J. Davis on 3/4/2014. (AMP) (Entered: 03/05/2014)
02/24/201412 AMENDED COMPLAINT against Florida Department of Law Enforcement, Rusty Ray Rodgers with Jury Demand. filed by Jeremy Banks.(PAM) (Entered: 02/24/2014)
02/24/201411 ENDORSED ORDER granting 10 Motion for Leave to File. The Clerk of Court shall file the amended complaint attached to the Motion as a separate document. Signed by Magistrate Judge Monte C. Richardson on 2/24/2014. (ADM) (Entered: 02/24/2014)
02/21/201410 MOTION to Amend Complaint by Jeremy Banks. (Attachments: # 1 Exhibit Amended Complaint)(McLeod, Robert) Modified on 2/24/2014 (PAM). (Entered: 02/21/2014)
02/12/2014ENDORSED ORDER granting 7 Motion for Extension of Time to File Response. On or before 2/21/14, Plaintiff shall file a response to the Motion to Dismiss. Signed by Magistrate Judge Monte C. Richardson on 2/12/2014. (ADM) (Entered: 02/12/2014)
02/11/20148 MOTION to stay discovery And Relief From Case Management Reporting Requirements Pending Disposition Of Dispositive Motion To Dismiss by Rusty Ray Rodgers. (Winicki, Chelsea) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 02/11/2014)
02/11/20147 MOTION for Extension of Time to File Response/Reply as to 6 MOTION to Dismiss Plaintiff's Complaint and Supporting Memorandum of Law by Jeremy Banks. (McLeod, Robert) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 02/11/2014)
01/28/20146 MOTION to Dismiss Plaintiff's Complaint and Supporting Memorandum of Law by Rusty Ray Rodgers. (Winicki, Chelsea) (Entered: 01/28/2014)
01/22/20145 NOTICE of designation under Local Rule 3.05 - track 2. Signed by Deputy Clerk on 1/22/2014. (Attachments: # 1 Case Management Report Form, # 2 Consent Letter and Form)(EAM) (Entered: 01/22/2014)
01/21/20144 NOTICE of Appearance by William J. Sheppard on behalf of Rusty Ray Rodgers (Sheppard, William) (Entered: 01/21/2014)
01/15/20143 ANSWER and affirmative defenses to 2 Complaint by Florida Department of Law Enforcement.(SJW) (Entered: 01/21/2014)
01/15/20142 COMPLAINT against Florida Department of Law Enforcement, Rusty Ray Rodgers with Jury Demand filed by Jeremy Banks.(SJW) (Entered: 01/21/2014)
01/15/20141 NOTICE OF REMOVAL from 7th Judicial Circut, St. Johns County, FL, case number CA-13-1672-55 filed in State Court on 11/13/2013. Filing fee $ 400, receipt number JAX011253 filed by Rusty Ray Rodgers. (Attachments: # 1 Exhibit, # 2 Civil Cover Sheet)(SJW) (Entered: 01/21/2014)