DISTRICT COURT OF APPEAL, FIFTH DISTRICTSTATE OF FLORIDA

Case Number: 5D12 -4159

DANIEL F. WALSH,Appellant,

vs.

OLGA T. WALSHAppellee,

L.T.IN THE CIRCUIT COURT OF THE SEVENTHJUDICIAL CIRCUIT, N AND FOR ST. JOHNSCOUNTY, FLORIDACASE NUMBER: DRO7-l665

INiTIAL BRIEF OF APPELLANT DANIEL F. WALSH

Daniel F. Walsh2656 Stem Drive South

Atlantic Beach, Florida 32233

c:c 2 ! 2012

DiS;øFAPPE.ALFrH DiSTRICT

TABLE OF CONTENTS:

Table of Citations .................................. i

Issues Presented for Review ......................... 2, 3

Statement of the Case and Facts ....................... 3, 4

Summary of the Argument ............................4, 5

Argument ...............................5, 6, 7, 8, 9, 10

Conclusion.......................................... 10

Certificate of Service ................................. 11

Certificate of Compliance with Font Requirement ........... 11

TABLE OF CITATIONS: Page

Diffenderfer y. Diffenderfer,491 So. 2d 265 (Fla.1986) ................................ (2)

Mattera y. Mattera629 So. 2d 1106, 1108 (Fia. 4th DCA 1994) ....... (2)

Staton y Staton,710 So. 2d 744, 745 (Fia. 2d. DCA 1998) ......... (2)

Trepp y Trepp964 So. 2d 206 (Fia. 5th DCA 2007) ................. (4)

Bongiorno y. Yule920 So.2d 1209, 1210 (Fia. ist DCA 2006) ...... (5)

Cunningham y. Cunningham,918 So.2d 412, 414-15 (FIa. 2d DCA 2006) ...... (5)

Statutes And Other Legal Authorities: Page

Florida Statute 61.075, 6 1.075, (6), (d) ....... 2, 4

Florida Statute 61.08, (1) .............................. 2

Florida State 61.08, (2), (h) ............................. 3

Florida Statute 61.08 .................................. 4, 7

Fiorida Statute 61.08, (4) .............................. 5

Florida Statute 837.02, 817 ........................... 9

Florida Rules of Professional Conduct 4-8.4, (a,b,c,d) 9

The Fiorida Bar Journal, October, 2004 Volume LXXVIII, No. 9, Overview of FioridaAlimony, by Victoria M. Ho and Jennifer L. Johnson ......... 4Attachments : (A, p.3), (B, p.4), (C, p.5 ), (D, p.6), (E, p.6), (F, p.7), (G, p.8), (H, p.8),(I, p.9), (J, p.9), (K, p.9), (L, p.10),

ci)

ISSUES PRESENTED FOR REVIEW:

1) Former Husband, Daniel Walsh was denied any share of equitable distribution

according to Florida Statute 61.075 including all subsections there within, and more

specifically in reference to Florida Statute 61 .075, (6), (d) - Distribution of retirement

plans upon dissolution of marriage - All vested and non-vested benefits, rights, and

funds accrued during the marriage in retirement, pension, profit-sharing, annuity,

deferred compensation, and insurance plans and programs are marital assets subject to

equitable distribution, (Staton y Staton, 710 So. 2d 744, 745 (Fla. 2d. DCA 1998),

(Differender y Differender, 491 So. 2d 265 (Fia. 1986).

2) Lump sum alimony is recognized under Florida Statute 61.08 (1) - In a proceeding

for dissolution of marriage, the court may grant alimony to either party, which alimony

may be bridge-the-gap, rehabilitative, durational, or permanent in nature or any

combination of these forms of alimony. In any award of alimony, the court may order

periodic payments or payments in lump sum or both. Lump sum alimony payments,

even though non-modifiable and payable in installments, may be enforced by contempt

if the court fmds the parties intended to establish alimony for support rather than

property settlement (Mattera y. Maltera, 629 So.2d 1 1 06 (FIa. 4th DCA 1994).

3) In the order on appeal the lower court states, " typically normal alimony for support

is tax deductible to the payor and tax includable to the payee as is not the case in this

matter". Former Husband states, "typically" is a word that implies neither fact, nor

(2)

exclusivity which is not referenced in any manner under Florida Statute 61.08 (2), (h). -

The tax treatment and consequences to both parties of "any alimony award", including

the designation of all or a portion of the payment as a nontaxable, nondeductible

payment.

4) The court alleges that the "record reflects" the Former Wife was to pay the $25,000

non modifiable lump sum alimony from the sale proceeds of the primary residence.

Former Husband has no idea what record the court is looking at, but it certainly isn't

walsh y walsh. In any case, nothing of the sort is mentioned in the Final Judgment, and

in fact the Former Husbands primary residence wasn't even for sale during this time.

Simply put, the courts justification that the primary residence was to be sold in order for

the Former Husband to receive the lump sum alimony as ordered is irrelevant in this

case (see attachment, (A), (1-10).

STATEMENT OF THE CASE AND FACTS:

This appeal arises from an order by the Seventh Judicial Circuit Court, St. Johns County

Florida, in an order striking recommendations of magistrate; order granting judgment for

monetary damages deemed appropriate by Former Husband. In May of 2012, General

Magistrate Mensh a highly respected Judicial Officer who was nearly appointed a Judge

in 2010 by the Governor determined that the Former Wife was indeed in willful

contempt ofnot paying the Former Husbands $25,000.00 non modifiable lump sum

alimony which was signed and ordered by Judge Alexander in October 2008

(3)

(see attachment (B), (1-5). Upon the "exceptions hearing" September 17, 2012, Judge

Alexander determined the $25,000 non-modifiable lump sum alimony as "equitable

distribution", and not as "support alimony" based on the selling of the Former Husbands

primary residence, and the tax structure within the fmal agreement; thus fmding the

Fonner Wife not in contempt. As stated in the Florida Bar Journal ; Lump-sum alimony

can be awarded to either effectuate the division of property or "to provide for support".

When lump-sum alimony is used for support, the court must make specific fmdings of

special circumstances to warrant such an award. In particular, the payor spouse must be

able to pay the lump-sum award without creating a financial difficulty in his business or

otherwise. Lump-sum alimony can be used as a tool to accomplish permanent alimony,

rehabilitative alimony, or bridge-the-gap alimony. A lump-sum alimony award can be

accomplished in periodic payments ( The Florida Bar Journal, October, 2004 Volume

LXXVIII, No. 9, Overview of Florida Alimony, by Victoria M. Ho and Jennifer L.

Johnson).

SUMMARY OF ARGUMENT:

Former Husband states that equitable distribution was neither established, nor equally

distributed, and in fact, the Former Husband has received nothing according to Florida

Statute 61 .075 or 61 .08, and was forced into penury ( (Trepp y Trepp, 964 So. 2d 206.

(Fia. 5th DCA 2007). Equitable Distribution may be structured as any form of alimony

(4)

in special circumstances such as lump sum alimony which qualifies it as support

(Bongiorno y. Yule, 920 So. 2D 1209, 1210 (Fla. ist DCA 2006). Former Wifes pro

bono attorney Diane Paull made an offer to Former Husband in July 2012, in the amount

of$100.00 per month in a negotiated attempt in Former Wifes obligation towards the

lump sum alimony owed. It's evident that even the Former Wifes attorney views this

$25,000 non modifiable lump sum alimony as "support al—nony", as she should, since

this attorney negotiated the terms in the Final Judgment in October 2008 (see attachment

C ). After 25 years ofmarriage, which is considered long term under Florida Statute

6 1 .08 (4), Former Husband should have receiyed some form of support alimony, and in

this case it is non-modifiable lump sum alimony. At the time of diyorce Former Husband

was flot working, and a full time student. Currently, the Former Husband is

unemployed, renting a room, is a disabled 55 year old, a fuiltime student (senior), has no

health insurance, and has become an obyjous yictim ofthe economic disparity in

reference to the lower courts most recent order (Cunningham y� Cunningham, 9 1 8 So. 2d

412, 414-15 (Fla. 2dDCA2006).

ARGUMENT:

Former Husband requests that the Higher Court reverse the trial courts decision that the

$25000 lump sum alimony in question as not being determined as equitable distribution

based on the Former Husbands share ofthe marital home as stated in the Judges order,

but rather was structured as support alimony, and acknowledged as such by General

(5)

Magistrate Denise Mensh. Florida State Certified Mediator Ned Price structured this

lump sum alimony as "support alimony" to protect the Former Husband or the Former

Wife in case a situation like this were to arise. The material evidence from the Former

Husband's previous attorney Beth Terry, substantiates that this is indeed "support

alimony" (see attachment D). Also, Florida State Mediator Ned Price intentionally

structured the first payment of $5,000 in lump sum alimony to be paid (6) six weeks

after the fmal judgment which was signed and ordered by Judge Alexander. This was

negotiated and agreed upon by both the Former Husband and Former Wifes attorney

Diane Paull, and the most recent offer of $100.00 per month in July 2012 from the

Former Wifes pro bono attorney confirms this as "support alimony". Since Former

Husband was unemployed, and a full time college student, the first lump sum payment

of $5000 (6) weeks after the Final Judgment was signed is an appropriate form of

support alimony that was needed to sustain the Former Husband in making the transition

from being married to being single after his long term marriage of 25 years had now

ended. In not receiving the first payment of $5,000, and leaving his primary residence as

required in the Final Judgement, the Former Husband was forced to live in a rental

property that was neither livable, nor suitable for his best buddy Duke, Former

Husband's dog that he has not seen in over (3) years (see attachment (E), (1,2). The

Higher Court must ask, why would the Former Wife and her attorney agree to sign the

terms of the lump sum alimony according to the Final Judgment, and fail to pay the

(6)

Former Husband (6) weeks later? Again, our home was not for sale, so obviously the

Former Wife had the ability to pay the $5,000 installment or the agreement would not

have been signed by Former Wife under the advice of her attorney. There is that

possibility the Former Wife and her attorney conspired in never paying the Former

Husband in the first place, which apparently is the case. Former Husband suggests to the

Appealate Court to recognize that there are defiencicies in Florida Statute 61.08, and

Former Husband's interview on Dan Rather World News Tonight in 2010 will verify this

(see attachment (F), (1,2). Former Husband is fully aware that the alimony laws are

interpreted with a degree of speculation which in many cases "typically" lack conformity

throughout the state of Florida. Perhaps we need to start by identifying equitable

distribution as "lump sum equitable distribution" so as we don't confuse it with "lump

sum alimony". Former Husband is a member of Florida Alimony Reform Inc., and

someone who has been instrumental in reforming 61.08 for the past (4) years, which

currently includes our efforts in eliminating permanent alimony. Such confusion is

uncalled for, and will be presented as so in the Florida Legislature early next year.

Another issue is using such words as "typically", which neither defme fact nor

exclusivity, and if erroneously construed can be very detrimental to ones livlihood as it

is in this case. Please understand that the Former Husband is not critizing ones opinion,

what the Former Husband is referring to is that the Former Wife was granted Former

Husbands home, has a secure job, has a pension, has two good eyes, and inherited total

(7)

security from this divorce. Whereas, the Former Husband was left with one blind eye (an

elbow from basketball) that may of been rectified had the resources been there, and his

dignity. The courts most recent suggestion in attaching the $25,000 lump sum alimony

as a lien on Former Wife's primary residence as "security" for the Former Husband may

be construed by some as somewhat delusional, if not embarrassing in making such a

suggestion. This consideration by the court implies further evidence why this lump sum

alimony was structured as support alimony since the Former Husband is now

impoverished (see attachment (G), (1-6). Why the court would continue to put the

Former Husband in such a dire predicament of need, one has to wonder how something

so simply structured by the State of Florida can inflict a sense of desperation on a

persons livelihood. Also, in the Judge's most recent order it appears there may be a

feeling of "ill will" towards Former Husband in his attempt to recuse the Honorable

Judge in 2008 Perhaps the Judges direct connection with the St. Johns County School

District, Former Wife's employer, would have one to believe that a conflict of interest

still persist as it did in 2008. Former Husband apologizes but keep in mind the Former

Husband is from Luzerne County, Pennsylvania, and politics can be influential, as it is in

St. Augustine, and the "Kids For Cash" ordeal is just one example of such (see

attachment (H), (1,2). Obviously when fraud and perjury are involved as it is with this

case, it's difficult to determine what is fair and just for those who rely on the decisions of

others that may or may not be aware that such behavior exist. In fact it creates a sense of

(8)

resentment and distaste for the entire Judicial System because a few bad apples take it

upon themselves in violating the laws they are sworn to uphold. On the surface this case

should have been one of simplicity since it was structured by a Florida State Mediator

that cost both parties nearly $2,000.00. Instead, these legal proceedings were concocted

with complicity, conspiracy, fraud, deceit, and even threats of terrorism on Former

Husbands well being. Former Wifes attorney Diane Paull continues to use every means

possible including a total disregard for the legal system itself in denying the Former

Husband what was signed and ordered in October 2008. In the process this attorney has

violated both Florida Statutes 837.02-Perjury in official proceedings and Florida

Statutes, Title XLVI Crimes, Chapter 817- Fraudulent Practices, and willfully

desecrated the Florida Rules of Professional Conduct 4-8.4, (a,b,c,d), (see attachments,

(I), (1-5), (J), (1-3). Such behavior on behalf of anyone, especially an attorney is a

disgrace to the profession, and the appropriate sanctions should be treaty as so. It's hard

to imagine that this behavior by an attorney was deliberately manufactured in order to

prevent the Former Husband from receiving what was mediated, signed and ordered in a

court of law under the guidance of a certified Florida mediator. This person conspired to

defraud the court, and continues to do so. Such attacks on Former Husbands person by

Attorney Diane Paull, both as an official of the court and pro se, were intiated due to the

fact the Former Husband made the Florida Bar aware that this attorney was apparently

using indecorous tactics against her clients in 2008 (see attachment K). At times it's

(9)

hard to accept when anyone loses their 25 year marriage, especially if one never wanted

the marriage to end in the first place. It makes it even more difficult to accept fighting

for "Justice" that apparently no longer exists while the bad apples working within the

legal system continue to prey on the weak and vulerable. It's evident that the Former

Husband is not the only victim of such abuses ( see attachments (L), (1,2).

CONCLUSION:For the foregoing reasons, the Former Husband asks that the order on appeal be reversedbased on the facts and material evidence that the lower court erred in issuing the order ofstriking the General Magistrates record of findings and recommendations, and an orderfor monetary damages.

Daniel F. Walsh, Pro Se2656 Stern Drive SouthAtlantic Beach, Florida 32233Tel: 904-235-1764 / walshic5O(aaotcom

(10)

CERTIFICATE OF SERVICE

I certify that copies of the foregoing has been furnished by certified mail, this't" day of December, 2012, to:

Attorney Diane L. Paull

1510 2nd Street SouthJacksonville Beach, Florida 32250

Olga T. Walsh42 Sailfish DrivePonte Vedra Beach, Florida 32082

( The Appellants Brief has also been submitted to the Folio Weekly, 9456 Philips Hwy,Suite 11, Jacksonville, FL 32256-1351, The Beaches Leader, 1114 Beach Blvd.,Jacksonville Beach, Florida 32250, Florida State Representative Eric Eisnaugle, 2212Curry Ford Road , Orlando, FL 32806-2422, Florida State Senator John Thrasher, 9485Regency Square Blvd., Suite 108 Jacksonville, FL 32225-8145, Lyndon Barnes Johnson(LBJ), Department of Education Building, 400 Maryland Ave, SW Washington, DC20202, Special Agent Joe Noone, Federal Bureau Of Investigation, P. 0. Box i i 04,Scranton, Pennsylvaina, 18501, Secretary Janet Napolitano, Department of HomelandSecurity, U.S. Department ofHomeland Security, Washington, DC. 20528).

CERTIFICATE OF COMPLIANCE WITH FONT REQUIREMENT

I certify that this brief was typed in 1 4-point Times New Roman font.

Daniel F. Walsh2656 Stem Drive SouthAtlantic Beach, Florida 32233904-235-1764

(11)

710

IN RE: THE MARRIAGE OF

OLGA T. WALSH, Wife,

and

DANJEL F. WALSH, Husband

C)L 5LIw A

IN T flLRJCOURT, SEVENTHRTD1k:Lkfrc&?tIT, IN AND FOR

iSiC9ULcDACASR?iOe .: -DJr :i r-

..- -

r(I):)i re

This matter came on to be heard on Wife's Petition for Dissolution of Marriage and

Husband's Counter-Petition for Dissolution ofMarriage. The Court finds that the parties reached

an agreement in mediation with Ned Price, Mediator, resolving all issues pertaining to Wife's

Petition for Dissolution of Marriage and Husband's Counter-Petition for Dissolution of

Marriage. The parties' agreement has been incorporated herein. There are no other matters or

issues between the parties to be resolved by the Court. The Court has subject matter jvrisdiction

over this matter and personal jurisdiction of the parties. The parties' mathage is irretrievably

broken Whereupon, ­t is hereby ORDERED and ADJUDGED as follows:

1) DISSOLUTION OF MARRIAGE: The marriage of the parties, DANIEL F. WALSH,

Husband, and OLGA T. WALSH, Wife, is hereby dissolved. Each party is restored to the statu.s

of being single and unmarried.

2) CHILDREN IDENTIFICATION: Two (2) minor children were born during the marriage.

The children are both sui juris and, as such, there are no issues pertaining to child support,

custody, timesharing, or visitation.

:4ñ/HUSBAND

EPage i of IO

Walsh y Walsh Dissolution of MarriageCase No. DRO7-1665

y,3) LUMP SUM ALIMONY: Wife shall pay to Husband the total sum of $25,000.00 as and for

non-modifiable and non-extendable lump sum alimony. Wife shall satisfy this lump sum

obligation by paying Husband the sum of $5000.00 on or before December 15, 2008 and the

remaining $20,000.00 on or before December 15, 2009. Said lump sum alimony shall not be tax

includable to Husband or tax deductible to Wife.

4) ALIMONY: Except as otherwise set forth herein, each party hereby waives now and forever

any and all claim to alimony from the other in the nature of spousal support, be it temporary,

rehabilitative, permanent, nominal, lump sum, bridge the gap, or periodic. The parties

acknowledge that this waiver is irrevocable and that there shall exist no change in circumstance

whatsoever which would permit either party to obtain alimony from the other. The parties

further agree that neither party may apply to the court of a modification of this provision.

5) MARITAL HOME: As and for equitable distribution, Wife shall be awarded all right, title

and interest in the marital home located at 42 Sailfish Drive, Ponte Vedra Beach, Florida 32082

(hereinafter Marita1 Home"), more particularly described as:

Lot 23, Block 3, DELEON SHORES UNIT THREE, according to plat thereof asrecorded in Map Book 12, page 36 of the public records of St. Johns County,Florida.

V-,Beginning November 1, 2008 Wife shall pay the first (Ist) mortgage to Indy Mac, and the second

(7fld) mortgage to Wachovia, as well as all taxes, insurance, assessments and similar charges

against the marital home, if any, and hold Husband harmless therefrom Husband shall pay both

mortgages and bring them current through October 3 1 , 2008. Within ten ( 1 0) days, Husband

shall execute any documents needed to effectuate the intent of this Paragraph, including signing

ofQuit Claim or Special Warranty Deed conveying his interest in the marital horneto-the Wife.A;,';!

­\/'J-/'Y ( (Xv-HUSBAND IFE

Page2 of 10Walsh y Walsh Dissolution of Marriage

Case No. DRO7-1665

Absent Husband's compliance with the duty to sign such Deed, this Consent Final Judgment

shall act as and for an instrument of conveyance and any subsequent third party may rely on this

Judgment as a document of conveyance. Wife hereby owns all right, title and interest in the

marital home and shall retain all equity in the marital home, without further claim by Husband.

Husband shall vacate the marital home no later than December 15, 2008 and Wife shall

thereafter have the exclusive possession (in addition to ownership) of the marital home. Husband

shall ensure that his brother vacates the marital home no later that October 28, 2008.

6) HUSBAND'S VEHICLE: Husband shall have sole ownership and possession of the 2001

Hyundai Sonata. Husband shall be responsible for any indebtedness owed on this vehicle and he

shall indemnify, defend and hold Wife harmless from any liability arising therefrom. Husband

shall also be responsible for having insurance on this vehicle. Wife shall execute a motor vehicle

power of attorney or any other document conveying her interest in this vehicle to Husband

within ten (10) days of being requested by Husband.

7) WIFE'S VEHICLE: Wife shall have sole ownership and possession of the i 996 Chrysler

Town and Country. Wife shall be responsible for any indebtedness owed on this vehicle and she

shall indemnify, defend and hold Husband harmless from any liability arising therefrom. Wife

shall also be responsible for having insurance on this vehicle. Husband shall execute a motor

vehicle power of attorney or any other document conveying his interest in this vehicle to Wife

within ten ( i 0) days of being requested by Wife.

8) RETIREMENT: Each party relinquishes and waives their right to any interest they may have

in any pension, profit sharing, retirement, 401-K, annuity, stock, bond, note, checking account,

savings account in the name of the other party or held for the benefit of the other party.i(j,•' (r .Y

HUBAND WFEPage 3 of iO

Walsh V Walsh Dissolution of MarriageCaseNo. DRO7-1665

9) PERSONAL PROPERTY: Wife shall maintain sole ownership and possession of the

personal property in the marital home that she now has in her possession except that Husband

shall possess and own the computers, two (2) televisions, one-half (1/2) of the crystal from

Europe, bis tools, the back porch furniture, a bed, and sorne of the fam•ly photographs. Each

party shall own and possess his or her items of property free and clear from any claim of the

other party.

10) INTANGIBLE ACCOUNTS: Except as otherwise provided herein, each party shall retain

as his or her sole property all checking, savings, securities accounts, individual retirement

accounts, cash, receivables, insurance policies, pension/profit sharing plans, credit union,

investment, stocks, bonds, trust accounts and other intangible accounts in his or her name.

I 1) CONVEYANCE OF PROPERTY: Except as provided for otherwise in this agreement, in

the event of the failure or refusal of either party to assign, convey or transfer the property herein

ordered to be assigned, conveyed or transferred within ten (1 0) days from the entry of the

Consent Fi¤al Judgment, in this case, then. and in such event, the Consent Final Judgment shall

actand stand as and for an instrument ofconveyance regarding such items according to the terms

of the Consent Final Judgment, provided that the provisions of this paragraph shall in no way be

construed to deprive either party hereto of any right or remedy that he or she may have under the

laws to enforce the accomplishment of such conveyance.

12) DEBTS: Except as otherwise set forth herein, Husband shall be solely responsible for the

debts and obligations that are in his individual name and he shall indemnify and defend and hold

Wife harmless from any liability arising therefrom. Except as otherwise set forth herein, Wife

shail be solely responsible for the debts and obligations that are in her indiv‹dualpame. and she

,;( i rt1.,

FTSBAND (WIFEPage4oflo

Walsh y Walsh Dissolution of MarriageCase No. DRO7-1665

shall indemnify and defend and hold Husband harmless from any liability arising therefrom.Neither party shall incur any indebtedness for which the other party could be liable in the future.

EACH PARTY HAS BEEN ADVISED THAT NOTWITHSTANDING TRE

FOREGOING AGREEMENT AND ASSUMPTION OF DEBT BY ONE

PARTY AND INDEMNIFICATION OF THE OTHER PARTY, THISAGREEMENT IS NOT BINDING ON THIRD PkRTY CREDITORS

(MORTGAGE COMPANIES, CREDIT CARD COMPANIES, ETC.) AND, TN

THE EVENT OF A DEFAULT IN PAYMENT, CREDITORS HAVE THERIGHT TO SEEK RECOVERY FROM ANY PARTY WHICH WAS

ORIGINALLY RESPONSIBLE ON THE DEBT.

I 3) FUTURE CONDUCT: Each party is hereby enjoined, prohibited and restricted frommaking, publishing, soliciting or otherwise obtaining or disseminating any statements,publications or other communications of any kind or nature. whether direct or indirect,personally or through any 3 regarding either party's character, reputation, employment,education, standing in the community, and any other matter that may reflect adversely on theother party's reputation. Neither party shall not take any action that may reflect negatively oneither party's employment. in any manner. Both parties are restrained and enjoined fromharassing, assaulting, battering, stalking, or committing any act of domestic violence.

14) ATTORNEYS FEES: Each party shall be responsible for his or her owen attorney fees andcosts.

i 5) MEDIATION FEES: Each party shall equally divide and pay for the entire cost ofcontiiued mediation which took place on October 1 8, 2008 with Ned Price. '

L)

(_L'(HUSTAJ'D-..WIFE

Page 5 of 10Walsh y Walsh Dissolution of Marriage

Case No. DRO7-1665

16) WAIVER OF APPEARANCE: Husband hereby waives his appearance at and notice of the

Final Hearing and consents to entry of Consent Final Judgment of DŒssokition of Marriage.

17) FURTHER ASSURANCES AND IMPLEMENTING DOCUMENTS: Each party, without

additional consideration, shall execute any instruments or documents, and at any time reasonably

requested by the other party, that are necessary and proper to effectuate th•s Agreement I Consent

Fina] Judgment of Dissolution of Marriage.

18) UNDERSTANDING OF THE PARTIES: Each party fully understands the facts and his or

her legal rights and obligations and is signing this Consent Final Judgment of Dissolution of

Marriage freely, voluntarily, intending to be bound by it.

19) FINANCIAL DISCLOSURE: Each party has made a sufficient disclosure to the other as to

his or her income, assets, and liabilities and overall financial condition. There is no other

information requested or required by either party so as to in any way delay either party's desire

to agree to the terms herein.

20) EFFECTiVE DATE OF AGREEMENT HEREThI, ENTIRE AGREEMENT AND NON-

MERGER: The parties acknowledge and agree that the agreement contained in this Consent Final

Judgment of Dissolution of Marriage shall be enforceable and binding upon the parties as of the

date the last party signs this document below, even if this Consent Final Judent has not yet been

entered by the Court. Further, the parties understand and acknow'edge that this is the entire

agreement by and between the parties. Further, by affixing their signatures hereon, the parties agree

that this document shall be construed and enforceable as a Settlement Agreement whether entered as

an order of the Court or not. That is, they each agree to be bound by the terms of this Settlement

Agrement/ Consent Final Judgment of Dissolution of Marriage and each acknowledge that they;i ) /'¡"

(HUSBAND

Page 6 of 10Walsh y Walsh Dissolution of Marr•age

Case No. DRO7-1 665

have agreed to the same for good and valuabk consideration. They agree that this Settlement

Agreement constitutes a ful and final settlement of all issues, including property and financial

issues, between them and they hereby each release the other from any claims which could have been

resolved in this action or in this judgment, except as provided herein. Once this Consent Final

Judgment is entered by the Court, however, the agreements contained herein shall not merge intothe judgment, and shall remain separately enforceable as a binding agreement between the parties,

except as provided herein.

2 1) INCORPORATION OF JUDGMENT: The parties agree that the terms of their agreement

as set forth herein shall be made a part of the Consent Final Judgment of Dissolution ofMarriage.

22) FURTHER ACKNOWLEDGEMENT: Both parties agree and acknowledge that Ned LPrice did not afford either one of them independent legal advice. Both parties furtheracknowledge that Ned L Price provided mediat•on services only so as to facilitate an amicable

resolution with regard to their domestic issues. Ned I. Price has maintained a position ofneutrality and has allowed both of us to exercise our right of self determination. Lastly, we havebeen fully informed as to the Rule of Confidentiality and agree to be bound by it. Both parties

agree that the mediator has not given either of them any advice or told them what they should do

in arriving at the terms of this Agreement.

23) SELF EXECUTION: In the event of the failure or refusal of either party to assign, convey

or transfer the property herein ordered to be assigned, conveyed or transferred, within ten ( I O)

days from the date of the entry of this Consent Final Judgment in this case, then, in such event,this . Consent Final Judgment shall act and stand as and for an instrument of conveyance

¡___BAND

Page7oflOWalsh y Walsh Dissolution of Marriage

Case No. DRO7-1665

regarding such items according to the terms herein, provided that the provisions of this paragraphshall in no way be construed to deprive either party hereto of any right or remedy he or she mayhave under the laws to enforce the execution and delivery ofsuch conveyance.24) GENERAL RELEASES: Except as otherwise provided in this Consent Final Judgment:

A. Each party releases the other from all claims, including any claims for alimony,demands, due debts, rights, or causes of action up to the date ofthis Consent Final Judgment;B. Each party irrevocably releases and relinquishes all claims, rights, and interests whichthe party may now have or may hereafter acquire in any property, real, personal, or mixed, of theother party, whenever and however such property may have been or may be acquired by saidother party, and each party represents that all ofsaid property, real, personal, or mixed, owned byeither party at the time of their marriage or subsequently acquired, separately or together, andowned by the parties or either of them at the time of their separation or acquired thereafter, hasheretofore been equitably divided and apportioned between them and each party hereby ratifiesand affirms their respective decision;

C. Each party waives, releases, and relinquishes all rights that he or she may now have orhereafter acquire as the other partys spouse under the present or future laws of any jurisdiction:i. To elect to take against any will or codicil ofthe party now in force;

ii. To share in other partys estate and to exercise any right of dower or curtsy heor she may now have or hereafter acquire in the other party's estate;

iii. To act as administrator or executor of the other party's estate except only asprovided by uIl or codicil executed after the date of this Agreement/Consent Final Judgment ofDissolution of Marriage;

D. Each party waives, releases, and relinquishes all homestead rights, and protection orexemptions he or she may otherwise be afforded under Article I O, Section IV of the FloridaConstitution as it pertains to any and all obligations of either party to the other under thisAgreement/Consent F•nal Judgment; i.e., judgments by one party against the other shall attach tosuch party's interest and homestead.

tv'

((.HUSBANDWiFE

Page 8 of IOWalsh y Walsh Dissolution of Marriage

Case No. DRO7-1665

25) RESERVATION OF JIJPJSDJCTION: This Court specificallyreserves and retains

jurisdiction of' this case and the parties to modifyand/or enforce par…graphs 2 through 15 as

allowable by law.

2

F1tfSBAND

DONE and ORDERED,in Chamber3, St. Augustine, St. Johns County, Florida,

this;y of t11I4\/ 2008.

-CIRCUIT O TJIJDGE

Page9ofl–Walsh y Walsh Dissolution of Marriage

Case No. DRO7-1665

YIFE

CONSENT OF TIlE PARTIES

The parties hereby consent to the entry of this order. Further, by affixing their signatureshereon, the parties agree that this document shall be construed and enforceable as a SettlementAgreement whether entered as an order of the Court or not. Further, each party by signinghereunder attests that they have read the foregoing, and sought or has had the opportunity to seeklegal counsel regarding this Agreement. They understand that the provisions to which they haveagreed may be different than would have been ordered if they submitted their case to the Court,but they instead have freely and voluntarily agreed to be bound by this Agreement and ConsentFinal Judgment of Dissolution of Marriage.

DATED this i 8thday of October, 2008 at Jacksonv•lle, Duval County, Florida.

.

1' .4« ¨' f ; f/

I I . i J ; 'J I

DA¥IEL WALSHHUSBAND

Diane Paul], EsquireFlorida Bar No.: 645605i 5 1 0 Second Street South, Suite AJacksonville Beach, Florida 32250Attorney for Wife

Daniel F. Walsh42 Sailfish DrivePonte Vedra Beach, Florida 32082In Proper Person

// cf

HUSBAND

-

'L '�t. C �'.

OLGA WALSHWIFE

.. á _�_) (•

�jt3TAEPAULLT)W[FE'STORNEY

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/ 4'•pI.PRICEM•DIATOR

Page lOof 10Walsh V Walsh Dissolution of Marriage

Case No. DRO7-1665

/�( &LL'

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f"IN THE CIRCUIT COURT, SEVENTHJUDICIAL CIRCUIT, IN AND FORST. JOHNS COUNTY, FLORIDA

CASE NO. DRO7-1665DIVISION: 57

IN RE: THE MATTER OF:OLGA T. WALSH,

Petitioner,and

DANIEL F. WALSH,Respondent.

REPORT OF FINDINGS AND RECOMMENDATIONS OF THE GENERAL MAGISTRATE

Upon the Former Husband's Motion for Contempt and Enforcement as being filed before the

Court on April 5, 2012, and the matter being referred to the General Magistrate on April 12, 2012, a

hearing was held before the General Magistrate on May 29, 20 1 2 . The following were present at the

hearing: Olga Walsh, Former Wife; Diane Paull, Attorney for the Former Wife; Daniel Walsh, Former

Husband.

Pursuant to the testimony and documentary evidence presented to the General Magistrate, the

following report and recommendation shall be submitted. The parties are notified that they shall have

ten ( i O) days from the date of service of these Findings and Recommendations to file any Exceptions to

the entry of an Order approving these Findings and Recommendations. The original Exceptions to the

Findings and Recommendations ofany party shall be filed with the Clerk ofthe Court with copies to

the General Magistrate and to opposing party andlor counsel. Should no timely Exceptions to the

Findings and Recommendations be received, a proposed Order and a copy of the Findings and

Recommendations will be forwarded to the Judge for appropriate action. The parties are further

notified that service ofthis Report and Recommendations is deemed effective as ofthe date of mailing.

The testimony of the parties has been digitally recorded, and the recording of this hearing is

specifically incorporated in and made a part of this report. A CD of the proceedings is available to the

Court and to the parties for preparation ofa transcript. Upon written request and appropriate fee, a

copy ofthe CD will be forwarded to the requesting party. Request forms and procedures may be

obtained from the General Magistrate's office, the Digital Court Reporters' Office, or the Family Law

Clerk's office. The completed form may be mailed or hand-delivered to the Digital Court Reporter's

DRO7-1 665

office at 4010 Lewis Speedway Blvd., Suite 290, St. Augustine, FL 32084. A check or money order inthe amount of $20.00 made payable to the State of Florida must be included along with a postage paidmailer for the CD, The requesting party makes his/her own arrangements for a transcript of the CD.

A. FINDINGS OF FACT AND CONCLUSIONS OF LAW:

The General Magistrate hereby finds and concludes as follows:1. This Court has jurisdiction over the parties and subject matter herein. A Consent Final

Judgment ofDissolution of Marriage was entered on October 1 8, 2008. The Former Wife wasordered to pay to the Former Husband the total sum of $25,000.00 "as and for non-modifiableand non-extendable lump um alimony." The Former Wife was ordered to pay $5,000.00 on orbefore December 15, 2008 and the remaining $20,000.00 on or before December 15, 2009.

2. The Former Wife withdrew her motion to continue this hearing.

3. The Former Husband alleges the Former Wife is in contempt for failing to pay alimony asordered.

a. The Former Husband testified he was unemployed at the time of the Final Judgment.

b. The Former Husband testified the Former Wife has made no effort to pay the alimony orcomply with the Final Judgment.

c. The Former Husband asserts the Former Wife is able to pay the alimony because she

received the marital residence, has a salary of$28,000.00, has a pension, and has

accrued leave time from her employment.

d. The Former Husband asserts he is entitled to the lump sum alimony that was negotiatedby the parties at mediation.

e. The Former Husband testified the Former Wife has not paid any alimony, and he is inneed of the financial support. The Former Husband is unemployed, and needs surgeryto reattach his retina.

f. The Former Husband requests a payment plan be implemented in lieu of the FormerWife being incarcerated for non-payment.

g. The Former Husband testified he has no source of income and is receiving food stamps.

h. The Former Husband refused to answer questions regarding how he came into

possession ofthe Former Wife's pay stubs.

2

DRO?- 1665

4. The Former Wife denies the allegation of willful contempt.a. The Former Wife testified that since the entry of the Final Judgment she has had to pay

debts that the Former Husband was ordered to pay.

b. The Former Wife is employed at Ocean Palms during the school year and works for theParks and Recreation Department over the summer.

c. The Former Wife testified she does not have the money to pay the Former Husbandalimony.

d. The Former Wife testified she filed for bankruptcy due to financial hardship, and is notable to get a loan to pay the obligation.

e. The Former Wife testified her vehicle has high miles and she borrowed money to makerepairs to it.

f. The Former Wife testified she has no extra money for luxury items or vacations.g. The Former Wife testified she cannot afford to pay the Former Husband more than

$5.00 or $10.00 per month towards the lump sum alimony.h. The Former Wife testified she does not have any assets that she can liquidate to pay the

alimony. The Former Wife does not have access to any retirement accounts.i. The Former Wife testified she did not authorize the release of her employment records

to the Former Husband and does not know how he obtained them.

i. The Former Wife has not tried to sell the marital home because ofthe poor housingmarket.

k. The Former Wife testified she tries to get side jobs such as cleaning houses.1. The Former Wife testified the mortgage on the residence went up due to the increases in

homeowner's insurance and property taxes.

m. The Former Wife testified the Former Husband is able to work but has never wanted towork outside the home.

n. The Former Wife testified she earned $22,000.00 last year, including her summer job.5 . The original order for payment of alimony or child support creates a presumption that the

obligor has the present ability to pay the alimony or support and to purge himselfor herselffrom the contempt. At the contempt hearing, the obligor shall have the burden ofproofto showthat he or she lacks the ability to purge himself or herself from the contempt. Section

DRO7-1665

6 1 . i 4(5)(a), Florida Statutes. The Former Wife is presumed to have the ability to pay alimonyas negotiated by the parties and ordered by the Court. The Former Wife's financial affidavitfiled Februaiy 14, 2008 indicates she has the same employment now as she did at the time ofthe Final Judgment. The only evidence from the Former Wife to rebut the presumption of herability to pay alimony was that she has suffered financial hardship and has paid debts on behalfofthe Former Husband. The Former Wife did not present any competent substantial evidenceregarding such debts or their amounts, nor did she present any court order requiring her to paysuch debts. While the Former Wife appears now to believe she does not have the ability to paythe alimony, her testimony in that regard is not sufficient to overcome the presumption of herability to pay. It is not relevant to the motion seeking enforcement of alimony whether theFormer Wife feels the Former Husband is voluntarily imemployed as the parties negotiated forthe non-modifiable lump sum alimony and their agreement was adopted by the Court. Neitherparty appealed the Final Judgment. The General Magistrate finds the Former Wife is in willfulcivil contempt as she has failed to rebut the presumption of her ability to pay alimony.

6. The Former Husband did not present any evidence regarding the Former Wife's ability to purgeherself of the contempt. In fact, the Former Husband specifically requested a payment plan beestablished in lieu ofany incarceration to compel compliance. The Former Wife's suggestionthat she only pay $10.00 per month towards the alimony would require the Former Husbandwait over 200 years to be paid in full. The lump sum alimony amount of $25,000.00 was due tobe paid in full on or before December 15, 2009. The General Magistrate has considered theparties' respective claims of financial hardship and finds that a monthly payment of $500.00 isreasonable.

7. The Former Husband did not present any evidence in support of his claim for attorney's fees setforth in his motion.

IL RECOMMENDATIONS:

The General Magistrate hereby recommends to the Court that ari order be enteredproviding for the following:

I. The Former Husband's Motion for Contempt and Enforcement shall be granted.

4

DRO7-1665

2. The Former Wife shall be adjudicated in willful civil contempt for failing to pay alimony asordered.

3. The alimony arrears shall be established in the amount of $25,000.00 as of May 29, 2012. The

Former Wife shall pay the alimony arrears at the rate of $500.00 per month beginning July 1,

2012 and continuing each month thereafter until paid in full. Consistent with the Consent Final

Judgment, this lump sum alimony shall not be tax includable to the Former Husband or tax

deductible to the Former Wife.

4. All payments shall be made to the Florida State Disbursement Unit, P.O. Box 8500,

Tallahassee, FL 32314-8500, and shall include any applicable fees. Counsel for the Former

Wife shall prepare a Support Information Sheet to assist the Clerk in establishing the account.

5. The Former Husband may submit an Income Deduction Order consistent with these

recommendations.

6. Any and all prior orders not inconsistent with the present order/recommendation shall remain in

full force and effect.

Recommended in St. Johns County, Florida this 3th day of May,O12.

DENISEE. MENSH fGENERAL MAGISTkATE

I HEREBY CERTIFY that two copies ofthe Findings and Recommendations afthe GeneralMagistrate have been furnished by U.S. Mail this 3p+ day ofMay, 2012, to the following:

Daniel Walsh, 2656 Stern Drive South, Atlantic Beach, FL 32233Diane L. Paull, Esquire, 1510 2nd Street, Suite A, Jacksonville Beach. FL 32250

GENE S IS TANT

5

k'from: Diane Paull dpaull@simpsonpaull.comto: walshie5Ogmai1.comdate: Fri. Jul 6. 2012 at 12:55 PMsubject: Walsh y. Walsh - Exceptions Hearing Important mainly because of the words inthe message.

Dear Mr. Walsh.

I am in receipt of your Motion for Continuance filed in the divorce case, asking the Court to continuethe hearing set for August 8th� would like to propose a settlement of the alimony matter, which, ifagreeable, would eliminate the need for any further hearings.I propose that Olga will pay you $100 per month towards the lump sum alimony due of $25,000.Additionally, she will give you a 3rd mortgage on the former marital home, due when she sells thehouse. If agreeable, we would document this settlement with a Court Order and an Income DeductionOrder to Ms. Walsh's employer to pay you the $100 directly.

Please let me know if you are interested in realistic settlement, which would then remove the needfor the hearing set for August 8th� Thank you.Diane L PauU, Esq.

SIMPSON & FALLI, P.L.

Attorneys and Coi nsciors at Law

nd1510 2 St. S., Suite A

Jacksonville Beach, FL 32250

Tel: (904) 24.97288; Fax: (904D 249-1779

Email: dpaulisimpsonpaull.com

EMAIL FOR SERVICE OF PLEADINGS: seice@simpsonDaull.comThis email is intended only for the individual or entities named within the message and may contain legally privileged and confidentialinformation. 1f you properly received this email as a client or retained expert, please hold it in confidence to protect the attorney-client orwork product privileges. If the reader of this message is not the intended recipient, any review,

c2//) jifr

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Hi Dan,

If your former wife has already filed bankruptcy, then you should be gettingnotice thereof as a creditor of hers. Further, once her bankruptcy isfiled, an automatic stay of collection efforts is instituted and you wouldneed to seek relief from that stay to continue on in the family courtcollection efforts. Other exceptions to all of this may apply depending onwhat type of bankruptcy she files and how the court (bankruptcy or family)may interpret the nature of the debt owed to you. A bankruptcy attorneywould know the ins and outs of this better than I.

In the meantime until we receive notice of any bankruptcy and/or stay, I

will send out the notice of the subpoena to the School District and then thesubpoena to them when the time expires.

I understand that Ned set it up as m9 topr2uor her, but if thecourt is pressed with the issue, it will make the ultimate Tion on what

'. it is --- alimony or property division, regardless of the label in the final

7 judgment. As for the info on the pension and sick/vac time, maybe they toldNed that or showed him documents during the mediation process.

Do you want me to offer to Paull the cashing in of the sick/vac time to pay( you the $5,000? And then a security on the pension for the $20,000? Please

note that we can enter into an Order on the pension to give you the money,but you will not see the pension monies until she is proper retirement age.

/ If she has a 401(K) or 403(b) plan, we can enter into an Order to get a

/ transfer to you pretty quickly. There would be some tax consequences, butwe could take that into account when determining the amount to be

'- transferred.

Let me know what you want me to do about an offer, if any.

Have a nice weekend too.

Eeth M. TerryLaw Office of Beth M. Terry, P.A.1824 Atlantic BoulevardJacksonville, FL 3220"?(904) 399-5354 phone(904) 399-5341 faxbeth@bethmterrvop corn

rf

LnMUNICIPAL CODE COMPLIANCE DIVISION

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Whcrt Honda Bgin.

R&deistiel - I1nt Notice

ROSSO JOHN P II PrWt D.e: My 16. 200929I yAp.alNc3ION ST Case Numbec: 2009-160172JACKSONVILLE. 1'L 32224-.500I

Rrnence Adrit: 2917 EAIJ.RINGTON ST

RE: 1671020010

LepI D,cflpdoE 36-25-26E .20 PT NEI!4 0E N11li4 RECO OR 12953-2224

Thc rcrorncd popaty wag inipcctcd aed Fowid Io be in viola:ioo orowpicr J 19 0I10 Municipal Pnpeny Safety undMnirttcnancc Code, undfor Cbop*e 745 Jacktouc:lIc Addccutlog aed Street Mainiog Rc8dalioot.

A lirtal inupoerion will be made opproutuatdy thirty (30) dayt Oum tite pelo dale arndt notice Tboeere. we or5e you to Stallwarb as sooC as poSutbk. Yow Failure lo coeTcct litt' tiled ciolatiogu within :bc allotted time wtll conStitute a Claus V offeisel6alost Use City, sod will sobjecs you to prosecutIon and/or lInar. au well as other penultics aed inspection feci peevisted in the

Codc.

Irlite ploperty st sucuied and the sIllily sciolte O disconnected peine to compliaace with lite abose slolatiunu, lite peeporty (naynot be rooccaptsrd sEil It l inspected and cenilted itt cotn‡iliance. The Code arqueen puss to tender a copy of this notice lo anyprospective purchaser. reeler or larsen aube property. peioc si indi mise Inserent in tite properly passed loththu. We hacecarefully cotoidnerd the nurser atid extent o¡lbe action erqwerd by this suiten, sod feel that the time alinoed is aduquaze andraguonalk. Ifyou Feel litai the Code has been wisconulertod. or that lb. Sleeti application ofilse Code will entine you unduehardship, you are entitled to appeai thu cotter by llEnO a petition rara hcarie before the Special Magisowec withet 13 slays hornreceipt. Errera lar the ftlittg of tech petition arr asaibbla l'ram thu ollice, upon raquant. and payment of, 5)0.00 Ittinig Ice,

NOTE: lt it YOUR RESPONSIBILITY to arI) for FInal mapeclisa if owlaliottu arc curresiesi before the cumpharec dalenteiwioited above lImiten Iban one inupeetsea is required lu eblain compliance, you sic required to pay a Ice of 550.00 for cachmnpocthtas, PRIOR lo the perlonnuasce otutects, lt is enportant thai yoti NOT uU foc the fowl tospectios until ill -utniinenu hasebean connoted, but rot inter than llar compliance date mentioned gtove, io usaid illspectton litca. However, you MAY request twoadssoly ­npcctioes or tite canuuIIalioo, free of charge, ai soy lime prior to lite scheduled rc..eapccciort daI referenced above. Ifadditional impectasa um required arel inattaled by this offtcc. fur pnuuecutioe pnrposrs. Ihr inspection fees will be made

a pii1 oftbc chargen filed with the entai or Municipal Code Enftatxment Board.

if you haue soy quraliuws. please contact OlF'scer Rohcii Walsh at 1904> 391-2372

Sincerely,

GeorlIe T Tawse -Supivisor

CageR 2109.1*9172 'Pug. I nfl (tItO)

ONVIRONIETAL,%NDCOMPLIAN(EDEPARrMEr4T100' toMranuo•,.se, 01s .75w. S)le tJ/3 Jarh,00c9n FL 30207 Phmn: 904 301,3600 Fou O0O3 t'sa 'am catinI

t

MUNICIPAL CODE COMPLIANCE DIVISION

aa% n4Where Floiida Begins.

Residential - First Notice

Violation Category - Exterior Violatlona

Violation SubCategory - Roof

Location of Violation Description of Violation Remedy

Roof Roof structure is deteriorated, damaged, or otherwise unsound. Repair or Rei

Roof Roofing is deteriorated or roofing materia! is not securely affixed to the mof.j Repair or Replace

Roof Roof leaking. Repair or Replace

Violation Category - Interior Violations

Violation SubCategory - Interior Ceilings

Location of Violation Description of Violation Remedy

Kitchen Ceiling is in insanitary condition. Repair or Replace

Entire Ceiling height less than minimum seven feet for habitable room. Correct

Kitchen Ceiling is sagging or otherwise unsound. Repair or ReplaceEnd of violation(s) listing

Case #: 20119-160172 - Page 2 of 2 (M tO)

ENVIRONMENTAL AND COMPLIANCE DEPARTM ENT1801 Art Museum Drive, Bldg. 3500. Suite 200 Jacksonville, FL 32207 Phone. 004.301 3600 Fax: 904.396.1744 www.cOj.net

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1/24/2012 6:12 AM

IN RE: THE MARRIAGE OF

OLGA T, WALSH ( Former Wife),

and

Daniel F. Walsh (Former Husband)I

D  f4S)iES1 * ti: sjj ))&1 (S)P '4!J

N THE CIRCUIT COURT, SEVENTHJUDICIAL CIRCUIT, IN AND FORST. JOHNS COUNTY, FLORIDACASE NO : DRO7- 1665DIVISION: 57

Former Husband just recently received his mail, and apologizes to the court for this delay in his

response to the most recent court order. Former Husband feels this would be the appropriate monetary

damages pertaining to the costs associated in not receiving the $25,000.00 non modifiable lump sum

alimony that was to be payable (6) weeks after the Final Judgment was signed and ordered on October

29, 2008 by the Honorable Judge Alexander. The courts reference to case law in determining "equitable

distribution" appear to be accurate because ofthe specificity in each case, but appears to be irrelevant

in this case for the lack ofspecificity. Also, the Former Husband does not see any case law mentioned

in determining whether this is "support alimony". The court should be reminded that the Former

Husband never received any part of "equitable distribution" according to the Final Judgment, which

coincidentally was signed four (4) years this month. In the Judge's most recent order the court uses the

term "typically" which like "usually" are words that show neither exclusivity, nor fact in determining

this alimony. Typically is based solely on your Honor's "belief" that the tax treatment and

consequences are "interpreted" as equitable distribution and not "support alimony". Florida Statute

61.08, (2), (h) -The tax treatment and consequences to both parties of"any alimony " award, including

the designation ofall or a portion ofthe payment as a nontaxable, nondeductible payment.

(Former Husband ask the court does this refer to "Typically")?

(1)

In any case, the Former Husband wifl accept the Judges decision on finding the Former Wife not foundin contempt and the Judges assumption that this non modifiable lump sum alimony was formulated as"equitable distribution", and not "support alimony" (if) all the terms are included and accepted by thecourt in receiving Monetary Damages. Keep in mind, the $25,000.00 that the court suggests to attach asa lien on the Former Husbands home is nothing more than a "perception" on the courts part that theFormer Husband will eventually receive what is owed in the future. If history is any indication in thesecourt proceedings, this is nothing more than an "illusion" in ones mind.

LUMP SUM ALIMONY1) Former Husband would ask the court to order the $25,000.00 lump sumalimony as a Qualified Domestic Relations Order , or (QDRO) for security purposes, and as a remedyofreceiving his fair share of "equitable distribution, Diffenderfer y. Diffenderfer, 456 So.2d 1214(Fia. ist DCA 1984), The Florida Chapter oftheAmerican Academy ofMatrimonial Lawyers submitsthis Brief, as amicus curiae, in support of the position that a trial judge should treat a spouse'sentitlement to retirement benefits as a marital assets and therefore subject to equitable distribution,applying the same criteria for such distribution as is applied to all other marital assets. Former Wife'spension was mediated and included in the $25, 000.00 non modifiable lump sum alimony ( seeattachment ( C).

This QDRO, as part of the "equitable distribution" will also protect the Former Husband if FormerWife decides to vacate the home in case of foreclosure proceedings, and the Former Husband will thenget nothing. Former Husband does have evidence that Former Wife has been behind on her mortgagepayments. The home is no longer an asset; thus there is "no security" if one cannot sell the house assuggested in the Judges most recent order. At the present time we may refer to the home as a "toxicasset". Former Husband has offered (2) options below towards monetary damages. Either option wouldbe appropriate in this matter.

(3)

((f1

OPTION 1:

Student loans =$ 45,000.00 - this has prolonged Former Husband from graduating as a Senior fromthe University of West Florida, and has negatively affected his studies; thus costing Former Husbandmore school loans in which to live off of (see attachment ( D), 1, 2, 3).Hospital Bills = $ 44,000.00 - Former Husband's (2) night stay at Shands Hospital, plus having a (31/2) hour operation performed on his left eye. Former Husband cannot make any payments since hedoes not have any extra funds available ( see attachment ( E).

Fraud = (Option 2), ( see attachment ( F ), I , 2,).

Perjury = (Option 2), ( see attachment ( G ), 1, 2, 3, 4, 5, 6).

Former Husband's Dog Priceless - Former Husband has not been able to see his dog in over (3)years.

Former Husband's Living Conditions $2,800.00 - Former Husband was forced to live in a dwellingafier vacating his home according to the Final Judgment that was neither healthy, nor livable ( seeattachment ( H).

Cost of rectifying blind left eye = $5,000.00 - $10,000.00 - Former Husband is and was unable toreceive proper medical attention for his detached retina. Former Husband lacks the financial resourcesfor an evaluation, and is currently blind in the left eye. Shands quoted husband for a prosthetic eye ifneed be ( I was told by my surgeon, Dr. Lawrence Levine, Shands Hospital, Jacksonville, Florida).Cost of renting S 6,800.00 - Former Husband was unable to purchase his own home. FormerHusband had multiple properties over the past several decades, and $25,000.00 in non modifiable lumpsum alimony would have been plenty for Former Husband to attain his own personal shelter. Becauseof not receiving any of the court ordered non modifiable lump sum alimony, Former Husband wasforced into penury, and is now on food stamps ( see attachment ( I).

(4)

OPTION (2):

The Former Wife's Pro Bono Attorney Diane L. Paul! will sign a sworn affidavit in reference to

WALSH y WALSH, CASE NO. - DRO7-1665. In doing so, Former Husband will relinquish all claims

to his $25,000.00 non modifiable lump sum alimony including all monetary damages associated herein

or thereafter

I, Diane L. Paull under sworn testimony has intentionally and irrefutably committed perjury and fraud

in the case of WALSH V WALSH, CASE NO., DRO7-1665. My behavior as a Florida court official

in this particu!ar case is not only embarrassing, but also humi!iating to those in the legal profession who

abide and uphold the ethics and standards required under the Florida Rules of Professional Conduct.

By signing the sworn affidavit, I, Diane L. Paul! will no longer practice law in the State of Florida. In

return, by signing this sworn affidavit Former Husband, Daniel F. Walsh will not pursue any criminal

charges against me, nor pursue any type of lega] action against my person. I am aware and

acknowledge that the local media has evidence of my bad behavior, as does F.B.I., Specia! Agent Joe

Noone in Scranton, Pennsy!vania whom I called and spoke with to verify this. This statement of the

phone ca!l to the Special Agent was also witnessed and heard by the local media including The Fo!io

Weekly who attended another case involving myself and Former Husband, Daniel F. Walsh, in

PAULL y WALSH 16-2012-DR-0151-DVXX, Duval County, F!orida, pertaining to Former Husbands

political blog. I, Diane L. Pau]l also refused to cooperate in doing a feature story for a local newspaper

involving my dea!ings with Former Husband, Daniel F. Walsh over the past ( 4 ) years . Furthermore, I

realize that the Former Husband has material evidence to acknow!edge my guilt, and his extensive

research in the "Kids For Cash" ordeal in Luzerne County, Pennsylvania only solidifies my guilt ( see

attachment ( J ). ( Foi-mer Husband will have a legal document written to this affect if this option

is chosen).

(5)

LFormer Husband is willing to accept S i 00.00 per month through the Florida Disbursement Unit

beginning November 1, 2012 from the Former Wife, who will sign and agree to this. This $100.00 is tocontinue each and every month until the Former Wife reaches her 62nd birthday, which is February 10,

2013. At this time Former Wife is eligible to retire and also collect social security benefits according toher state pension plan and under Federal law. I'm sure the St. Johns County School District as the

Judge well knows, will accommodate Former Wife with another job within the District if Former Wife

were to retire ( see attachment ( K ), 1, 2 ). Former Husband will accept a lump sum payment ofhalf( 50% ) ofwhat was owed in the original divorce settlement. That is $12,500.00 to be paid in full. The

Former Husband wants security, and protection after being put in such a life threatening situation for

the past four (4) years. Ifthis is acceptable, Former Husband will have a legal document written to this

effect by a licensed attorney In conclusion ; when there is bad behavior there needs to be

consequences, not only for my Former Wife, but for anyone.

For the record, the Former Husband had also made a proposal to the Former Wife in having the

Former Husband return to his home in an attempt to reconcile any differences for a (6) month

trial basis. Former Wife refused. This ­s documented in the courts transcripts and the $20.00 CD

of the General Magistrates hearing on May 29, 2012.

CERTIFICATE OF SERVICE

I certify that copies of this document (s) were mailed on October 20 1 2 and furnished to:Olga T. Walsh, 42 Sailfish Dive, Ponte Yedra Beach, Florida 32082Ms. Diane L. Paull, 1510 2nd' Street South, Jacksonville Beach, Florida 32250Special Agent, Joe Noone, Federal Bureau ofinvestigation, P.O. Box 1104,Scranton, Pennsylvania i 850

/acxtd' ¥;eA&ADaniel F. Walsh2656 Stern Drive SouthAtlantic Beach, Florida 32233Tel : 904-235-1764walshie50cao1.com

. ivi L 7-7: 7I I

/

OEhe ibrida imt5-3JflIOflLUCY C. TALLEY

Publisher

FRANK.M. DENTON.

EditorROBERT E. MARTIN

General Msnager

MICHAEL P. CLARKEd%torial Page Edit&

JACKSONViLLE � WEDNESDAY FEBRUARY 23, 2011WWW.JACKSONVILLECOM

More opinions online

See our Opnon Page hog. You will find comments front ed¡toria board membersand cotumnists, extra materias, syndicated cokmns as soon as we receive themand letters from readers that don't make the paper. Just go to this website:jacksonville.com/opinion.

[II'1lff1J2ltI1

Teli the FBIis a cancer for taxpayersthat poisons the systemfor everyone.

Thats a big reason why it's impor-tant to make it easy for the public toreport it to authorities in a positionto combat it.

The Jacksonville division oldieFBI has launched a new corruptiontip line that encourages people toreport bribes, kickbacks or otherillegal activities that involve peoplewho use their public offices forper-sonal gain.

And it doesn't matter if thoseofficials are elected appolntŠd orunder contract to do work for thegovernment.

It's the law

The FBI notes it is a violation offederal law for officials at any levelof government to ask for or receiveanything of value in exchange for- or because of - any official act.

But those secretive deals are oftenhard to detect and even more cha!-lenging to prove without th‚ help ofpeople who can alert authorities.

The FBI says contract fraudsurrounding the federa! stimulusmoneyls ofparticular concern.

Ahniit hcilfnfthe estimated 9,4

CONTEiCT THE FBI

I FBI JacksonviHe Public CorruptionTip Line: 1-888-722-1225

u Via e-mail: jacksonviUe(ƒiic.fbi.govPtace "Public Corruption up" in thesubject line.

a For more on corruption th‚FBI •s looking for, visit http://

.

jacksonville.fbi.gov/priorities.htm

CITY EIHLCS HOTLINC

a (904) 630-1015

sible action or to the state atomnevor federal authorities. The city eth-ics system can help diffuse prob-lems before they reach the Ffllslevel of concern.

Strangely, some public officialsthink ethics should he self-polic-ing, an attitude they don't rake withother crimes.

Yet, there are more than enoughexamples of corruption among pub-lic officials.

The biggest city scandal in recentyears involves allegations of btib-ery, conspiracy, mail fraud, moneylaundering and lying ro the FBIreardIn the nort and its fnrnir

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was required ta stand onits own merits, and hacted on guiding principlesand established provisionsof the time, Mr. Wolfson

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- ----------- * - . , - Š2sLkithe property was currently ment in our City befor sale, meaning was it upheld?listed and/or posted forsale, Mr. Wolfson resp¢nd- L•ndley Tolberted that the property- was Atlantic Beach

Piss RoomPaul Corey

Justin Wray

Glenn Gaffney

John Zrbisky

D33

To the edftoñ-

-I have spent the past IS niontbs - inLuzerne Count% .PenyIvania tesearch.ng and investigati¤g ��- the 'Kfds fox Cash"ordeal ¡n which -se•Šral —dges - aridlawyers were gettingldckb acks Incarcerat-ing juveniles in a detention center inwMclitbeywexe investors.

The one thing- that was learned frommy experienceis the-role the FBI playedin bringing d•wn t he "culture of c”rrtip-tiOn'1 In that cot—ttywhich happens to bemy homtowi During this time frametbe Peds had infiltrated and brought to)ustice over 30 ' power brokers' and localgovernment offlcials that had either con-spirect to commit fraud or committedaimes- against Its citizens

In my last letter to The Beaches Leaderseveral years -ago, I talked about thecleansing process that must take placebefore we can move on This Is nw talc-ing piace, but as' expected the sanie'power brokers" who contributed to thiseconOmic messi are now positioningthemselves onceagain to take advantageof a very 'vulnerable - sItuation.Coinddentaily, several m”nths ago the -FBI set up shop here in jacksonvllle andcreated a h¢t1ii•e <iekZ8i88S-722-1225>(I'-888-72Z-1225) on public corrup-tiOi1L I WDUId suggest to anyone that hasthe stightestinformation on possible vio-lationa In the public sector, includingpublic officials please coitavt the FBI- Th : ere Ls noth•ngto fear,, for the top lawenforcement agency in the country has

evidence that violations have beencommitted, and many of the 'power brokets" are now being monitored Keep Inm¤d,- tse- other consumer protectionagencies, such as the Florida AttorneyIenera1 are politically Influenced and aregoing to be biased toward specihc casesthat-they are investigating. The FBI on theother hand does not answer to any pohtical party or "power brbkersM, and that iswhy they have a civil rjtS -dtvisi”n.

lt is imperative that the Arneican peo-pie understand what is happening in this-country, and if this "culture of coftupt•onwis not dealt with, we will all suffer direconsequences as a democracy. Of coursethere are those who believe that veryshortly this corruption will be obliteratedby sonething much more powerful thanus mere mortals. In  ny case, there is riota politician(s) that can change what ishappening at this point, "only the peop1ecan make the necessary changes, and itstarW with knowing oneseIf -

Several years ago the public was warnedin the The Beaches Leader what was goingto happen with the

economy1 and unfor-tunately this scenario became a realty.Again, the public Is getting an adva•icewarning on- a scenario that will b farworse than the economy if this "cultureof corruption" cleansing process is notachieved.we know this.. because it's inthe book...have a good day.

Dan WalshAtlantic Beach

YOUR VIEWS ARE WELCOMEAre you a BŠaches

resident interested ­n writing a guest column forThe Leader? Send an e-mail to:editor@beachesIeader.com

L Li 1-U--i,..

fectly reasonable to inguidelines for manaithe tree canopy. Wthese guidelines spi11 cprivate property, smanagement quickly grtates toward tyranny. Ifacing a panel of my neibois who genuinely bellit's their moral obligatto force me to obtapproval to trim my otrees.

It did not seem to mato these folks that I inot actually violated

-

canons of the ordinancequestion.

Their issue was that siiI liad not asked pennissito dq that which Is perle'y permlss•ble -J mustpunished. - -

- How dare I take the i:tiative t¢ protect my farly and neighbors fr6m: tpotenUal- damage of failbranches. :Writing t.ch‚ck for the fine feels lirm allowing a bullystrong-arm my Iunmoney;

-

It seems like we have Icfaith Iii - the cognitive abity of ¢urfellow huflibeings. Regulations ha'implicitly told us for

-

long-that w‚, - and peci-ly th‚ other guy, cantt itrusted to make andresponsible - for our osdecisions that we reflexivly abide the altruistIc ideaof transferring more atmore-muscle to the centrauthority.

-

One day soon, we mwake up to - discover thwe've opened ' the wroreyelid f1rst, according tone-w ordin-a*ice regulatmnsleep habits.

Rest assured, there wibe some gr¢wn-up-kicwho-used-to-eat-paststandliig there ready tsend us to the prjndpaioffice for a reprimand.

With apologies to PatricHenry, as- for me, give inliberty or else you can tal<over my yard care!

Cary QuidNeptune Bead

,

-

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------'--- -- - --- --.------ ---. - -. - -- S------ - --- -- --'- - - ----- -e- - - ---- ------ -.. .-'- -.--- -.----- --- '._'-'

j

-

IN RE THE MARRIAGE OF.OLGA T. WALSH, Wife,

M?P7T

IN THE CIRCUIT COURT, SEVENTH/' i)JUDICIAL CIRCUIT, IN AND FOR UST, JOHNS COUNTY FLORIDA

CASE NO.: DRO7-1665DIVISION: 57

andDANIEL F. WALSH. Husband.

ORDER GRANTiNG INJUNCTIVE RELIEF

THIS CAUSE came before the Court upon a motion for injunctive relief againstthe Husband due to his actions in threatening to file suit against the St. Johns CountySchool District and to have the Wife fired from her job at Ocean Palms ElementarySchool. The Husband has made threats against the Wife and Wifes counsel and hasrecently filed a Bar complaint against the Wife's attorney. The Bar complaint appearsto be an absolute waste of time and upon query by the Court as to what the groundsare in the Bar complaint, the Husband claims the Wife's attorney has engaged inabusive behavior." When asked to explain, he could offer no explanation other thanDiane Paull, Attorney at Law, is "abusing us financially." lt appears the Bar complaintby the Husband is a malicious waste of The Florida Bar's investigative officer.

The Court has asked the Husband to give it evidence that the Wife's attorneyhas publicty slandered him, for which the Husband has no answer. His previousattorney filed a Motion for Leave to Withdraw and a trial on the parties' dissolutionaction has been scheduled for September 2008.

J/_ The Court has also received credible evidence that the Husband has threatened( the Wife that he will contact her employer to have her fired and it is the Husband whoagrptIy has engaged in defamatory conduct against the Wife's attorney and against

? the Wife. Said behavior includes calling the Wife's attorney's office and asking il theWife's attorney was 'going through menopause." (He also threatened the Wife'sattorney by stating she should "watch [her] back" and "don't cross Danny Walsh.øThese actions run the distinct risk of irreparable harm and support art injunction against

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the Husband. Accordingly, it is

ORDERED AND ADJUDGED AS FOLLOWS:

C/i .

I . The Husband is enjoined from contacting the St. Johns County SchootBoard or by and through any third party regarding any defamatory comments againstthe Wife and/or damaging the Wife's character or reputation with the St. Johns CountySchool Board.

2. The Court awards the Wife attorney's fees and costs for the filing of thismotion and the Wife's attorney may file an affidavit in regard to her costs and fees forthe preparation of this motion and attendance at hearing held on June 17, 2008.

DONE AND ORDERED ­n Chambers at St. Augustine, St. Johns County, Florida,this 18th

day of JUNE 2008.

JOHN M. ALEXANDER, Circuit Judge

Conformed copies furnished to:Diane L. Paull, Attorney, 1510 2nd Street, South, Jacksonville Beach, FL 32250Daniel F. Walsh, 42 Saitfish Dr., Ponte Vedra Beach, FL 32082The Florida Bar, 651 E. Jefferson St., Tallahassee, FL 32399-2300 (file #2008-00-934(4b))

2

‡E. . /'INTHE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT,

N AND FOR ST. JOHNS COUNTY, FLORIDA

Case No.: DRO7-1665Division: 57

IN RE THE MARRiAGE OF:

OLGA T. WALSH,Wife,

and

DAN1L F. WALSH,Husband. ?

______--j -:;

VERIFiED MOTION FOR INJUNCTIVE RELIEF .

COMES NOW Wife, OLGA T. WALSH, by and through her aftoi DIA L.

PAULL ESQ., and for her Emergency Vetified Motion for Injunctive Relief aJusd,

DANIEL F. WALSH, states as follows:

I . Dissolution of marriage proceedings are currently pending between the parties

before this Honorable Court.

2. Husband is contacting Wife's employer, threatening to file suit against the St. /) j/Johns County School District in an effort to have Wife fired from herjob. 'tr

\

3, Husband has published and otherwise made public written statements that contain / '

libelous and false statements about Wife's counsel's professional licensure. Such statements

have been published by Husband with the intent to defame Wife's counsel and subject her to

shame, embarrassment, and ridicule in ber profession.

#. Husband has made verbal threats against Wife and Wife's counsel, warning them

..' them would be "serious" consequences for "crossing" him and Wife and ber counsel better__) "watch her back". Such statements were heard by third parties at Wife's counsel's office, who

became justly fearful for counsel's safety.

t Husband has filed a grievance with the Flonda Bar, false'y maligning Wife's

counsel to her professional licensing entity. In that grievance, Husband has stated he will take

his battle to (lie "media" to continue to defame Wife's counsel and, further, plans to file "a class

action lawsuit" against Wife's counsel.

. .

STATE OF FLORIDA, COUNTY OF DUVAL:

SWORN TO AND SUBSCRIBED before me, tbisΠday of June, 2008, by OLOA T.WALSH, Wife, who is personally known to me or who has produced a Florida drive?s license asidentification.

Kathlun A. Skoblow Notary Public' � CommIseo. # 00451 782

t( /Ex*essspt.mber7 2009MSJJSII

Respectftlly Submitted:

SIMPSON & PAULL, PL.

UIREAttorney for Wife

Florida Bar No. 064560515102nd St. S., Suite AJacksonville Beach, FL 32250Tel: (904) 249-7288; Fax (904) 249-1779

CERTIFICATE OF SERVICE

I CERTIFY a copy of this Motion for Injunctive Relief was mailed to the Husband,Daniel F. Walsh, at 42 Sailfish Dr., Ponte Vedra Beach, FL 32082, on lune 2008.

L. PA QUIREAttorney for Wife

I

(,iIt ¨¡'J

Walsh:

I

/1

:

(

Diane nrc yu going through menonuse.,,eau i ask you that? re yogoing through menopause? You need to just chill outlets work together and get this thing over with bui please do not doan1hing hehind Dan Walsh's back anymore there is alwaysgoing to be consequences renwrnber that 0k? and we will get readsfor June 17th 0K?

Dtane Paall: M. Walsh fvou dont refrain from liablc statcncnLs I wilL ask 1udAieander to instrt:ct you accordingly

Dan Walsh: Thats fine

L)•;ne Pa:ill. \rd you are noi abk ti) CiilitiiCI 111V cIiiit Lu anvw av s¡iae o; orinrcaictiiig liiese proceed:iigs and thus you are on nonce You will notspeak o my dient Olga WuLib on the n1ato;s al al i or bee sanctions forsupport do I maie tisclf clear

Dm \Vais•:: t loc niv wut she is a good woman 1he would just uci soniccounseling. hats al I I i an

1)ianc Paull Ir \Valsb ifvou ever make any statements about ne again that are ftilse

or libel there vilt rue co:lsequCilces

Dan 'Vaish: 00h vea sonimc luke rie no" ;Ii�ts erv tilerapeutic its workiug So ie willha talking with you Diane you take cale of ourseIfaiid llave agood weekend Pli go puay for ou

Diane Paul!: Welt we i Il have che ude dccidc than

Dan Walsh: Thais tine von ake care of yourself

//

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(t3cc7

Case: 3:09-bk-05806_PMG

Debtor: Olga Walsh

Select Creditor

O Daniel F. Walsh O Creditor not listeddo Diane Paull, Esq.1510 Second Street South, AJacksonville Beach, FL 32250

J A NO &I

át<kLIfTC111

Debtor Olga WalshCase Number 3:09-bk-05806-PMG

CreditorAddress where notices

should be sent

Telephone Number:

Daniel F. Walshe/o Diane Paull, Esq.1510 Second Street South, AJacksonville Beach, FL 32250

IO Payment Address differs from Notice Address

CreditorCreditorAddress where paymentsshouldbe sent _________________________________________

(City, State, Zip)

Telephone Number:

Authorized Agent ofCreditor:

Name___________________________________Title___________________________________Address, City, State, Zip

Telephone Number(813-555-1212)

O Check this box to indicate that thisclaim amends a previously filed claim.

Court Claim Number:

FiledonH U

O Check box if you are aware thatanyone else has filed a proof ofclaim relation to your claim.Attach copy of statementgiving particulars.

1. Amount ofClaim as ofDate Case Filed: ____________Ifall or part ofyour claim is secured, complete item 4 below; however, if all ofyour claim is unsecured,do not complete item 4.

3:09-bk-05806-PMG Olga Terezia WalshCase type: bk Chapter: 7 Asset: No Vol: y Chief: Paul M. Glenn

Date filed: 07/15/2009 Date of last filing: 07/18/2009

Robert D WilcoxWilcox Law FirmEnterprise Park4190 Belfort Road, Suite 315Jacksonville, FL 32216904-281-0700904-513-9201 (fax)rwilcox@wilcoxlawfirrn. cornAssigned: 0 7/15/2009

Attorneys

Olga Terezia WalshP.O. Box 144representingPonte Vedra Beach, FL 32004(Debtor)

/1

fr'1

JOH% F. H,.Ms JR.ECl TP.1áhkECIfI

Mr. Daniel F, Walsh42 SaiLfish DrivePonte Yedra Beach. FL 32082

THE FLORIDA BAR651 EsrJFflRo STREET

Tunsu, FLORIDA 32399-2300

May 16. 2008

Re: Ms. Diane Lynn Paull; RFA No. 08-19621

Dear Mr. Walsh:

($50) 561-5600

Your inquiry concerning the conduct ofthe above member ofthe Bar has been analyzed and hasbeen determined to be a matter which warrants finiher invtigation. The Supreme Court ofFlorida has adopled mIes that require the allegations be signed and under oath. In order tocomply with this ruic you mu.0 sign the oath below and return it to us by May 27, 200$ before'we can proceed with an investigation.

Under penalty of perjwy, I declare that the facts contained in the inquiry submitted to TheFlorida Bar concerning Ms. hull are true, correct and complete.

;4(,. ¨Li ¨i/4L J-12-o / fMr. Daniel F. Walsh Date

1f you do not complete and return the oath foim (o us, we may be unable to proceed with theinvestigation. A copy of the rule imposing this obligation (3-7.3(c)) may be found on the Bar'sweb site at www.floridabar.org.

Also. if you have documents that you feel support your allegations. please provide copies ofthem when you return the oath.

Thank you for your cooperation.

Sincerely.

t�G(i E3Z4A7Heidi E. Brewer. Bar CounselAttorney Consumer Assistance Pmgrain

¯

1- ')

TRACY M RIZZO 16-2011-CA-008530-XXXX-MAOther Ne'gIigence -Othr

Division: CVD

Party(s)

Full Name Party Type Sex . Race DOB License # AddressRZO,TRACY ;;;;;i ----

. --:'' -r'

[DEFENDANTL

Case Fee(s)

r;;ji ; ;;;;i;;; [i€dT aiTIn I

Docket(s)

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. 10/18/2011

10/18/2011

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10/19/2011

: 10/19/2011

‡ 10/19/2011

10/19/2011

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- 10/19/2011

11130/2011

11/30/2011L.. _.__._

Count Description

DEMAND FOR JURY TRIAL-OTHER NEGLIGENCE - OTHER

00 ON RECEIPT NUMBER 1412225

- - ISUMMONSISSUED WILLIAME DOYLEPA

SUMMONS ISSUED DIANE L PAULL

SUMMONS ISSUED' SIMPSON & PAULL, PL

CASE FEES PAID: $4OE00 ON RECEIPT NUMBER 1412563MOTION TO DISMISS WILLIAM E. DOYLE, ET. AL.ANSWER , DEFS AND AFFIRM DEFS/DEFTS DIANE L PAULLAND SIMPSON & PAULL PL/ATTY

wd: dianeeaufl

Forwarded messageFrom: Debra Dempsey <debraIdempseygmaI. corn>Date: Fn, Oct 7,2011 at 1:13 PMSi.bject: thane peuHTo: walshie5Oqrnail. corn

http://rnail aol coin'3 5322-11 1/ao1-6/en-us/rnail/P¤nMessaaspx

Do you ha anymore information aboti her. She screwed me and today i found o&. another cilent too. The fist isIor! She will come after me if you give her my name and my childrenare at risk!