DEMAND FOR ADDIIONAL DISCOVERY

IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR LEE COUNTY FLORIDA

STATE OF FLORIDA CASE NO.: 16-000275CF

Plaintiff,

vs.

RANDAL ROSADO

Defendant.
__________________________/

DEMAND FOR ADDITIONAL DISCOVERY
COMES NOW the Defendant, Randal Rosado, and files this demand for additional discovery to which the Defendant is entitled pursuant to Rule 3.220(j) continuing duty to disclose, and by Brady v Maryland, 373 U.S. 83 (1963) and hereby demands full discovery disclosure including the following additional discovery:
1. A copy of the federal arrest warrant Defendant is charged with filing on or about May 22, 2015 against Circuit Judge John Duryea. Include federal court filing number and evidence that said document was created and filed by the Defendant.
2. A copy of the federal arrest warrant Defendant is charged with filing on or about May 22, 2015 against Clerk of Court for Lee County, Linda Doggett. Include federal court filing number and evidence that said document was created and filed by the Defendant.
3. A copy of the federal arrest warrant Defendant is charged with filing on or about May 22, 2015 against Attorney Steven Carta, Esq. Include federal court filing number and all evidence that said document was created and filed by the Defendant.
4. A copy of the federal arrest warrant Defendant is charged with filing on or about May 22, 2015 against Attorney Thomas Schulte, Esq. Include federal court filing number and evidence that said document was created and filed by the Defendant.
5. A copy of the federal arrest warrant Defendant is charged with filing on or about May 22, 2015 against Attorney James Judkins, Esq. Include federal court filing number and evidence that said document was created and filed by the Defendant.
6. A copy of the federal arrest warrant defendant is charged with filing on or about May 22, 2015 against Attorney Larry Simpson, Esq. Include federal court filing number and evidence that said document was created and filed by the Defendant.
7. A copy of the federal arrest warrant Defendant is charged with filing on or about May 22, 2015 against Kristy Davis, CFO for Florida UCC, LLC. Include federal court filing number and evidence that said document was created and filed by the Defendant.
8. A copy of the federal arrest warrant Defendant is charged with filing on or about May 22, 2015 against Daniel Nellius, CEO for Florida UCC, LLC. Include federal court filing number and evidence that said document was created and filed by the Defendant.
9. A copy of the “fictitious documents” from “International Court of Commerce” targeting Circuit Judge John Duryea dated on or about April 20, 2015, which the Defendant is charged. Include all evidence that the documents are fictitious and all evidence that the documents were created, delivered and/or filed by the Defendant, and evidence that if the documents were created, delivered and/or filed by the Defendant, that he had knowledge or reason to know the contents of any such documents or proceeding or the basis of any such actions to be fraudulent.
10. A copy of the “fictitious documents” from “International Court of Commerce” targeting Circuit Judge Joseph Fuller dated on or about October 27, 2014, which the Defendant is charged. Include all evidence that the documents are fictitious and all evidence that the documents were created, delivered and/or filed by the Defendant, and evidence that if the documents were created, delivered and/or filed by the Defendant, that he had knowledge or reason to know the contents of any such documents or proceeding or the basis of any such actions to be fraudulent.
11. A copy of the “fictitious documents” from “International Court of Commerce” targeting Clerk of Court for Lee County, Linda Doggett, dated on or about October 27, 2014, which Defendant is charged. Include all evidence that the documents are fictitious and all evidence that the documents were created, delivered and/or filed by the Defendant, and evidence that if documents were created, delivered and/or filed by the Defendant, that he had knowledge or reason to know the contents of any such documents or proceeding or the basis of any such actions to be fraudulent.
12. A copy of the “fictitious documents” from “International Court of Commerce” targeting Attorney Steven Carta, Esq., dated on or about October 28, 2014, which Defendant is charged. Include all evidence that the documents are fictitious and all evidence that the documents were created, delivered and/or filed by the Defendant, and evidence that if the documents were created, delivered and/or filed by the Defendant, that he had knowledge or reason to know the contents of any such documents or proceedings or the basis of any such actions to be fraudulent.
13. A copy of the “fictitious documents” from “International Court of Commerce” targeting Circuit Judge John Duryea dated on or about January 29, 2016, which the Defendant is charged with in counts 13-15. Include all evidence that the documents are fictitious and all evidence that the documents were created, delivered and/or filed by the Defendant, that he had knowledge or reason to know the contents of any such documents or the basis of any such actions to be fraudulent.
14. Chain of custody for evidence seized at Defendant’s residence located at 129 W. Main Street, Goshen, New York on June 28, 2016. This includes providing signed custody transfer of evidence documents between Michael Howard of FBI New York Hudson Valley RA Squad C-37 to Lee County Office of the State Attorney.
15. Chain of custody for the transfer of interrogation videos of the Defendant and his wife obtained on June 28, 2016 at the Village of Goshen Police Department in Goshen, New York by Detective Ryan Rich of Village of Goshen, FBI Agent Robert Foley (now employed as Assistant State Attorney for Lee County, Florida), and Lee County Investigator, Robert Nichols. The chain of custody should include the signature of the documents used to transfer video evidence from the property of the Village of Goshen Police Department to Lee County State Attorney’s Office.
16. Chain of custody for all evidence transferred from Lee County State Attorney to the Office of the Attorney General for Florida. This includes interrogation videos and transcripts referenced in paragraph 15 above, and other evidence now in possession of the Florida Attorney General and used in civil proceedings in Leon County, Florida.
17. Any organizational documents, corporate articles, IRS tax information or other documents pertaining to the registration of International Court of Commerce, specifically documents verifying the Defendant as an owner.
18. The official written offer (guilty plea) by Assistant State Attorney, James D. Miller, based on his email offer to the Defendant on July 19, 2017, as delivered to Defendant’s counsel, Sebouh Gourjian. The offer should include all stipulations, including the details of the additional charges threatened by Mr. Miller, and the stipulation to deny the Defendant his right to court access under the First and Fourteenth Amendment to the United States Constitution.
19. Any laws stating why the alleged victims should be exempt or given the ability to refuse participation in depositions or trial testimony under any circumstances, and why the Defendant is not given the right to face his accusers in this action.
20. Any forged real estate deeds and property information for Lee, Palm Beach or Collier counties, to which the Defendant has been accused of in news stories and reports from the Florida Office of Financial Regulation as fueled by the Office of the State Attorney and/or through its employees.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to the Clerk of Court at 1700 Monroe Street, Fort Myers, Florida 33901 and the Office of the State Attorney, 2000 Main Street, 6th Floor, Fort Myers, Florida 33902 on this 22nd day of December 2017.
By:/s/Randal Rosado
Defendant
2501 Ortiz Avenue
Fort Myers, Florida 33905

 

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