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APPLICATION FOR NOMINATION TO THE COUNTY COURT

(Please attach additional pages as needed to respond fully to questions.)


DATE:
fr

November 5, 2015

Florida Bar No.:

GENERAL:
1.

Name

0434280

Social Security No.:


Betsy B^nson

E-nnaii: _BetsyB_ensonEsg^maiLcom

Date Admitted to Practice in Florida:

October 17, 1984


IVS.-^M^tu

Date Admitted to Practice in other States:


2.

.Ai

N/A

State current employer and title, including professional position and any public or

judicial office.

Howard Finketstein, Esq. Public Defender, Seyenteenth _Jydicial Circuit


^-

3.

Business address:

th
201 SE 6m
Street, Suite3872

City Fort Lauderdale

County JBrpward

Telephone (954) 831-8672


4.

State

FAX

FL

ZIP 33301

(954)831-8866

Residential address:
,-f^lwMf,,^Itm/^,

City
Since

County _BR
November 27,1997

State FL

ZIP

Telephone
ff/^^WM^v

5.

Place of birth: Miami, Florida


Date of birth:

May 14, 1959

Age:

6a.

Length of residence in State of Florida: J-ifelong resident

6b,

Are you a registered voter? [X] Yes D No


If so, in what county are you registered?

7.

Marital status:
If married:

56
II.ULIU.T

B reward

siasie

v.w.v.^u^

Spouse's name

N/A

Date of marriage

N/A
"- - ~ff --.-^"^^-^

Spouse's occupation

N/A
.-/tlM^F.U.WWA'A-AM^

If ever divorced give for each marriage name(s) of spouse(s), current address for each
former spouse, date and place of divorce, court and case number for each divorce.
N/A

Rev.l00209-OGC

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Children

8.

Name(s)

9.

Age(s)

Occupation(s) Residential address(es)

N/A

Same

Military Service (including Reserves)


Service

Branch

Highest Rank

Dates

N/A

N/A

N/A

N/A

Rank at time of discharge

N/A

Type of discharge
-.^.-.-.-.nT--L-

Awards or citations
HEALTH:

10' ^^^^e?^J??Ste?-t(!.-/-lep?nf!,nt .upon..the, use of "arcotics, drugs, or


intoxicating beverages? If yes, state the details, including the date(s).

No.

Ha, During _the^last ten years have you been hospitalized or have you consulted a

rofess;,onaLr ha''^oureceived trea'mentor a d'^n"^ from a professional for^ o-f


Lhl;.fo?owmgi..K!eptomama- patholo9ical ".- Compulsive Gambling: "Pedophilia;
ExhibitionismorVoyeurism?
No
Yes D

lf,y^l.a.rl8w^rj!:y_es^pleas? directach.such professional, hospital and other facility to


fumish. thl chaH"pereon.of the commis,sion' any information' the" Commission" may
^ueslwth-:,espe,c'to. -y-h^pital.zation, consultation, treatment ord,agno
r;prfesston.al"jncludes ,a phVsiclan. PSVChia^. Psychologist, Psychothe7api,t
Mental Health Counselor.]

Please describe such treatment or diagnosis.


N/A

11 b. In the past ten years have any of the following occurred to you which would interfere with
your ability to work in a competent and professional manner?
Experiencing periods of no sleep for 2 or 3 nights
Experiencing periods of hyperactivity
.

Spending money profusely with extremely poor judgment


it

Suffered from extreme loss of appetite


2

Rev. I0020.9-OGC

or

Issuing checks without sufficient funds

Defaulting on a loan

Experiencing frequent mood swings

Uncontrollable tiredness

Falling asleep without warning in the.middle of an activity


No

Yes

If yes, please explain.


12a. Do you currently have a physical or mental impairment which in any way limits your
ability or fitness to properly exercise your duties as a member of the Judiciary in a
competent and professional manner?

Yes D

No

12b. If your answer to the question above is Yes, are the limitations or impairments caused by
your physical or mental health impairment reduced or ameliorated because you receive
ongoing treatment (with or without medication) or participate in a monitoring or
counseling program?

Yes D No D
Describe such problem and any treatment or program of monitoring or counseling.
13.

During the last ten years, have you ever been declared legally incompetent or have you
or your property been placed under any guardianship, conservatorship or committee? If
yes, give full details as to court, date and circumstances.
No.

14.

During the last ten years, have you unlawfully used controlled substances, narcotic
drugs or dangerous drugs as defined by Federal or State laws? If your answer is "Yes,"
explain in detail. (Unlawful use includes the use of one or more drugs and/or the
unlawful possession or distribution of drugs. It does not include the use of drugs taken
under supen/ision of a licensed health care professional or other uses authorized by
Federal law provisions.)
No.

3
Rev. 100209-OGC

15.

in the past ten years, have you ever been reprimanded, demoted, disciplined, placed on
probation, suspended, cautioned or terminated by an employer as result of your alleged
consumption of alcohol, prescription drugs or illegal use of drugs? If so, please state the

circumstances under which such action was taken, the name(s) of any persons who took
such action, and the background and resolution of such action.
No.

16,

Have you ever refused to submit to a test to determine whether you had consumed

and/or were under the influence of alcohol or drugs? If so, please state the date you
were requested to submit to such a test, the type of test required, the name of the entity
requesting that you submit to the test, the outcome of your refusal and the reason why
you refused to submit to such a test.
No.

17.

In the past ten years, have you suffered memory loss or impaired judgment for any
reason? If so, please explain in full.
No.

EDUCATION:

18a. Secondary schools, colleges and law schools attended.


Schools

Archbishop Curtey
High School, Miami,
FL

C/ass Standing

Dates of Attendance

Degree

no info
available

1973-1977

High School
Diploma

University of Florida

1977-1978

Rotlins College

1978-1981

Bachelor of Arts

1981-1984

Juris Doctorate

Nova Southeastern

University

18b, List and describe academic scholarships earned, honor societies or other awards.
Senior Class President, Archbishop Curley High School
NON-LEGAL EMPLOYMENT:
19.

List all previous full-time non-legal jobs or positions held since 21 in chronological order
and briefly describe them.
Date

Pos/Y/bn

Employer

Address

1993-1994

Owner/Editor

OutPages, Inc.

no longer in business

1989-1991

Owner

Big Bang

no longer in business

Rev. 100209-OGC

PROFESSIONAL ADMISSIONS:
20.

List all courts (including state bar admissions) and administrative bodies having special
admission requirements to which you have ever been admitted to practice, giving the

dates of admission, and if applicable, state whether you have been suspended or
resigned.
Court or Administrative Body

Date of Admission

Federal Bar

1992

LAW PRACTICE: (If you are a sitting judge, answer questions 21 through 26 with reference
to the years before you became a judge.)
21.

State the names, dates and addresses for all firms with which you have been associated

in practice, governmental agencies or private business organizations by which you have


been employed, periods you have practiced as a sole practitioner, law clerkships and
other prior employment;
Address

Name of Firm

Position

Dates

Please see
attached.

22.

Describe the general nature of your current practice including any certifications which
you possess; additionally, if your practice is substantially different from your prior

practice or if you are not now practicing law, give details of prior practice. Describe your
typical clients or former clients and the problems for which they sought your semces.
Please see attached.
23.

What percentage of your appearance in courts in the last five years or last five years of
practice (include the dates) was in:
Area of Practice

Court

Federal Appellate

Civil

Federal Trial

Criminai

Federal Other

Family

State Appellate

Probate

Other

State Trial

100 %

State Administrative

State Other

%
5

Rev. 100209-OGC

Answer to Question 21 - LAW PRACTICE


Position

Name of Firm

Law Clerk

Benson, Ray and May

Address

Dates

1 Fin'l Plaza #1600, FTL, 33301 1981-1984

Certified Legal Intern, State Attorney's Office; Broward County Courthouse

1984

Asst. Public Defender, Alan H.SGhrejber, P.O. Broward County Courthouse

10/84-12/88

Asst. Public Defender, Jo<y3AtRadi@:L P,D,

Orange County Courthouse

1/1989-10/92

POB 120910, FTL 33312

1/93-10/94

Asst, Public Defender Howard Finkejstein, i.D. Broward County Courthouse

10/94-2004

Staff Attorney

LeRai Aid of Broward

Adjunct Professor
Trial Advocacy course
Lawyers Skills and Values
Psychology and Criminal
Procedure

Shepard Broad Law

2001-2003

3305 College Ave. Davie, FL 33304

Cej^er, ^Nova'S&uttiCBSfern
Partner

^rny McGrotty, ASSQC.

524 SW 10th Ave, FTL 33312

Asst. Public Defender Howard Fint<dst(3n"i, P.D. Broward County Courthouse

2004

2005-present

Q.uestion 22: Describe the general nature of your current practice, including any certifications
which you possess. Additionally, if your current practice is substantially different from your prior
practice, or if you are not now practicing law, give details of your prior practice. Describe your
typical clients, or former clients and the problems for which they sought your services.
Since 2011,1 have handled death penalty cases exclusively on behalf of Mr. Finkelstein's office.
am certified to try death penalty cases pursuant to the Supreme Court's guidelines as codified
in the Florida Rules of Criminal Procedure. These cases are very involved on many levels,
namely: fact investigation in discovery, research into scientific issues, the vetting, use, and
examination of experts, and myriad legal issues involving admissibility of evidence, the
constitutionality of Florida's death penalty scheme and its application to my client's case, and
the State's evidence to support it. The cases are time intensive in and out of the courtroom.
Our defense team is the last advocate of our client.
From 2009 to 20111 handled 'direct file' cases for Mr. Finkelstein. All children who were

charged as adults and could not afford counsel were defended by myself and Ms. Nadine
Girault. I challenged the State's decision to charge children in adult court on numerous
occasions. I also worked with Maria Schneider, Chief Assistant State Attorney, to avoid direct
filing my client's cases through juvenile sanctions, placement in programs, and other alternative
resolutions. I tried several juvenile cases in adult court. I also worked with the Department of
Juvenile Justice in hopes of redirecting children into other programs.
From 2005 to 2009 I trained new hires for Mr. Finkelstein. I worked with young lawyers on
discovery, motion practice, trial preparation, client relationships, and trial. I helped young
lawyers prepare and argue motions to suppress, dismiss, compel, participated in many hearings
and trials with young attorneys and consulted on attorney promotions and placements.
From 2004-2005 I partnered with attorney Amy McGrotty in a firm focusing on real estate
transactions, mainly foreclosures, evictions and closings. I worked with clients to close real

estate transactions, review and approve real estate documents, advocate on behalf of clients
regarding fees and costs for closing, resolve title issues, and explain complex mortgage and
bank transactions. I handled commercial and residential evictions in Dade and Broward courts.

From 1993 to 2004 I worked for Public Defender Alan S. Schreiber as a trial attorney in several
felony divisions and as the supervisor of the domestic violence divisions. I appeared before
Judge Geoffrey Cohen/ Judge Lee J. Seidman and Judge Robert Lee on a regular basis. I advised
and supervised felony and misdemeanor lawyers on their caseloads. I went to trial regularly
and co counseled with lawyers at trial. I handled major crimes in the division while working
with young lawyers.

From 1991-1993 I was a staff attorney for Legal Aid of Broward County. My focus was on
obtaining social security and unemployment benefits for those who had been denied benefits.
researched the effects of disabilities and the treatments and medications for them, the

availability of work or retraining in tight of the client's age and limitations, and prepared for
hearing on behalf of the client. I also researched unemployment issues and prepared witnesses
and clients for administrative hearings on these claims.
From 1989-19911 was a division lawyer and was before several Orange County Circuit Judges
on behalf of Joe DuRocher, Public Defender in the Ninth Circuit.

From 1984-1989 I was a trial attorney in several misdemeanor divisions and in the felony
division of Judge Harry Hinckley and Judge Mark E. Polen here in Broward as an assistant to Mr.

Schreiber, the Public Defender in Broward County.

%
100 %

TOTAL

24.

100 %

TOTAL

In your lifetime, how many (number) of the cases you have tried to verdict or judgment
were:

Jury?

approx. 91

Arbitration? 0

Non-jury?

Administrative Bodies?

10

^-.^-A"."

25. Within the last ten years, have you ever been formally reprimanded, sanctioned
demoted: disciplined, placed on probation, suspended or terminated by an employer or
tnbunaTbefo7elwhJch you have appeared? If so, please state the circumstances under
which~such action was taken, the date(s) such action was taken, the ^name(s) of any

persons who took such action, and the background and resolution of such action.
No.
26.

In the last ten years, have you failed to meet_any_ deadline imposed by court order or

received'notice that you have not complied with substantive requirements of any
business or contractuai arrangement? If so, please explain in full.
No.

(Questions 27 through 30 are optional for sitting judges who have served 5 years
or more.)

27a. For your last 6 cases, which were tried to verdict before a juryor arbltrationPanelortrie(;i
ioVdgmentbefo.eaiudge, list the names and telephone numbers of trial counsel on all
sides and court case numbers (include appellate cases).

Case No. 10-000170CF10A Def: Bruce Price, Assistant State Attorney: John
Countryman, Esq. (954) 831-6955

Case No. 07-23026CF10A Def: Ronald Smith Assistant State Attorney: Peter Holden,
Esq. (954) 831-6955

Case No. 08-22027CF10A Def: Terrance Taylor, Assistant State Attorney: Neva Smith,
Esq. (954) 831-6955

Case no. 09-18637CF10A State vs. Elton Walters, Assistant State Attorneys: Steven
Zaccor, Esq. and Thomas Coleman, Esq. (954) 831-6955
Case No. 11-10935CF10A State vs. Leroi Morris, Assistant State Attorney: Greg
Rossman, Esq. (954) 424-3306

Case No. 14-8623CF10A State vs. Kirk Nelson Tang Yuk, Assistant State Attorney:
Michael Horowitz, Esq. (954) 831-6955

27b. For your last 6 cases, which we re settled in mediation or settled wlthout mediation or

trial,''list the names and telephone numbers of trial counsel on all sides and court case
numbers (include appellate cases).
6

Rev. 100209-OGC

State of Florida vs. Stanley Beasley 11-14361CF10A Assistant State Attorney Alberto
Ribas, Esq, (954)831-6955
State of Florida vs. Patricia Brennan 14-7488CF10A Assistant State Attorney Thomas
Coleman (954) 831-6955
State of Florida vs. Cecil Weekes 09-14395CF10A Assistant State Attorney Sherry Tate
(954) 831-6955
(I have no other cases that have settled without trial in the last five years. I have

succeeded in obtaining death waivers and then gone to trial on a life maximum).
27c. During the last five years, how frequently have you appeared at administrative hearings?
0 average times per month
27d.

During the last five years, how frequently have you appeared in Court?
20 average times per month

27e, During the last five years, if your practice was substantially personal injury, what
percentage of your work was in representation of plaintiffs? N/A%

Defendants?

%
28.

If during any prior period you have appeared in court with greater frequency than during
the last five years, indicate the period during which this was so and give for such prior
periods a succinct statement of the part you played in the litigation, numbers of cases
and whether jury or non-jury.
Same frequency.

29.

For the cases you have tried to award in arbitration, during each of the past five years,
indicate whether you were sole, associate or chief counsel. Give citations of any
reported cases.
N/A

30.

List and describe the six most significant cases which you personally litigated giving
case style, number and citation to reported decisions, if any. Identify your client and
describe the nature of your participation in the case and the reason you believe it to be
significant. Give the name of the court and judge, the date tried and names of other
attorneys involved.
Please see attached.

31.

Attach at least one example of legal writing which you personally wrote. If you have not
personally written any legal documents recently, you may attach writing for which you
had substantial responsibility. Please describe your degree of involvement in preparing
the writing you attached.
I wrote the attached Motion.

PRIOR JUDICIAL EXPERIENCE OR PUBLIC OFFICE:

32a. Have you ever held judicial office or been a candidate for judicial office? If so, state the
court(s) involved and the dates of service or dates of candidacy.
-I
/

Rev. 100209-OGC

am currently a candidate for the office of County Court Judge, Group 13.
32b.

List any prior quasi-judicial sen/ice:


Position Held

Name of Agency

Dates

Types of issues heard:

32c. Have you ever held or been a candidate for any other public office? If so, state the office,
location and dates of sen/ice or candidacy.
N/A
32d.

f you have had prior judicial or quasi-judiciai experience


d)

List the names, phone numbers and addresses of six attorneys who appeared
before you on matters of substance.

N/A
t.

(ii)

Describe the approximate number and nature of the cases you have handled
during your judicial or quasi-judicial tenure.

N/A

(iii)

List citations of any opinions which have been published.

N/A

(iv)

List citations or styles and describe the five most significant cases you have tried
or'heard/ldentify the parties, describe the cases and tell why you believe them to

be significant. Give dates tried and names of attorneys involved.


N/A

(V)

Has a complaint about you ever been made to the Judicial Qualifications
Commission? If so, give date, describe complaint, whether or noUherewas_a

fmd'ing'"of"'probabie "cause, whether or not you have appeared before the


Commission, and its resolution.
N/A

(VI)

Have you ever held an attorney in contempt? If so, for each instance state name

of attorney, approximate date and circumstances

N/A

(vii)

If you are a quasi-judicial officer (ALJ, Ma9istrate-General,Master?' have you ever


been disciplined or reprimanded by a sitting judge? If so, describe.

N/A
8

Rev. 100209-OGC

Case: State of Florida vs. Terrence Taylor


Case No. 08-22027CF10A

First Degree Murder

Hon. Martin Bidwill, Trial Judge


Assistant State Attorney: Ms. Neva Smith, Esq.

Defense Team: Assistant Public Defenders George Reres,Esq., Melisa McNeili, Esq. and myself
Jury Trial May30-June 15, 2012

Mr. Taylor was charged with bludgeoning a friend to death in furtherance of the crime of

robbery. The State sought death in this case. Our mitigation investigation revealed that
Terrence was the son of a drug addicted mother and an absentee father. Terrence was one of

several children, all of whom were in and out of foster care. Terrence's one stable home, that
of his Aunt Mozie was taken from him when his mother regained custody, oniy to lose him to
the justice system. Terrence was arrested at age 15 for aggravated battery. We found the

'victim' in this case who said that the incident was mutual combat between two school boys,
not a second degree felony. No one had consulted the victim when Terrence was committed to

the juvenile justice system. Shortly after his release from commitment, Terrence was arrested

for purse snatching. At sixteen years old, he was filed on as an adult and sentence to ten years
prison. Within a year of his release, Terrence was arrested in this case. We made a
presentation to the State Attorney's office that outlined the life of our client. Just one month

before our trial was to commence, the State Attorney agreed that the death penalty was not
appropriate in Mr. Taylor's case. The day we told our client that his life was not in jeopardy was
unforgettable.

The trial raised numerous issues regarding the reliability of cell site evidence/ the credibility of a
case based entirely on circumstantial evidence/ and other evidentiary issues.
The jury found Mr. Tayior guilty as charged and he was sentence to life in prison without the
possibility of parole. This case is presently on appeal.

Case: State of Florida vs. Elton Walters


Case no. 09-18637CF10A

Charge: 1. First Degree Murder, 2. Armed Burglary, 3. Armed Robbery 4. Sexual Battery
Hon. Jeffrey Levenson, Trial Judge
Mr. Steven Zaccor, Esq., Mr. Thomas Coleman, Esq. Assistant State Attorneys
Asst. Public Defenders Melisa McNeill, Esq. and myself- Defense
th

th

October 14In - November 7, 2013 Jury Trial, March 5ln - March 13, 2013 Penalty Phase

This case involved a brutal murder where the State sought the death penalty. The case was
very involved - we filed over 150 motions involving suppression of evidence; Florida's death
penalty process and its constitutionality, the aggravators the State intended to present, and the
evidence we sought to put before the jury during the guilt and penalty phases,
Mr. Walters was 62 years old at the time of the murder. He had led an exemplary life; 35 years
with Amtrak, a pension, 3 children, two grandchildren, a wonderful reputation in the Caribbean
community in Dade County, and loving, close friendships from all over the United States and his
home country of Trinidad.
The victim was a 92 year old woman who lived in the townhomes that Mr. Walters worked in as
a maintenance man. She lived independently. She was found by her granddaughter after calls
to her went unanswered. The evidence against Mr. Walters was substantial; forensic evidence
placed his DNA at the scene, the items stolen from the victim's home were in Mr. Walters'
truck, and Mr. Walter's confession.

The jury found Mr. Walters guilty on two of the three counts.
The penalty phase in this case lasted over a week. We presented 34 character witnesses who
testified that Mr. Walters had changed their lives for the better, that he continued to be a
fundamental part of their lives, and that Mr. Walters' death would deeply affect them. After
deliberating for nine minutes, the jury unanimously recommended life without parole for Mr.
Walters.

Case: State of Florida vs. Leroi Morris Case no. 11-1490CF10A First Degree Murder, Second
th

th

Degree Murder, Armed Robbery April 28ln through May 7ln, 2014
Judge Jeffrey Levenson, State Attorney Greg Rossman Co-counsel Melisa McNeill

These charges stem from a robbery during which Mr. Morris' codefendant and the victim were
killed. Our defense was that Mr. Morris did not know that a robbery was to take place. We

argued a motion to dismiss based on the lack of evidence that Mr. Morris knew of the robbery
or the existence of a firearm, or his codefendant's intent to use the firearm. The Jury found Mr.
Morris guilty as charged and he was sentenced to life in prison without parole. This case is on
appeal.

<s

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(3

FINANCIAL HISTORY
1.

State the amount of gross income you have earned, or losses you have incurred (before
deducting expenses and taxes) from the practice of law for the preceding three-year
period. This income figure should be stated on a year to year basis and include year to
date information, and salary, if the nature of your employment is in a legal field.
Please see
attached

Employee
Earnings
Current year to date

Statement

List Last 3 years

2012 attached

2013 attached

2014 attached
-^f.

2.

State the amount of net income you have earned, or losses you have incurred (after
deducting expenses but not taxes) from the practice of law'for the preceding three-year
period. This income figure should be stated on a year to year basis and include year to
date information, and salary, if the nature of your employment is in a legal field.
Current year to date
List Last 3 years
-Wfr-^ ^rW.-.WW.WA-.-.-.v.

3.

State the gross amount of income or loses incurred (before deducting expenses or
taxes) you have earned in the preceding three years on a year by year basis from all
sources other than the practice of law, and generally describe the source of such income
or losses.

Current year to date


List Last 3 years

State the amount of net income you have earned or losses incurred (after deducting
expenses) from all sources other than the practice of law for the preceding three-year
period on a year by year basis, and generally describe the sources of such income or
losses.

Current year to date


List Last 3 years

14

Rev. 062414-OGC

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IN THE CIRCUIT COURT OF THE


17TH JUDICIAL CIRCUIT IN AND FOR

BROWARD COUNTY, FLOmDA


STATE OF FLORIDA,
CASE NO. 11017904CF10A
Plaintiff
JUDGE:

BOBER

vs.

KEVIN PRATT
7
Defendant

SECOND AMENDED MOTION FOR TRANSCRIPT OF GRAND JURY

PROCEEDINGS WITH SUPPORTING DOCUMENTATION (CAP #2A)

The Accused, through the undersigned attorney, requests an Order authorizing the court
reporter to provide a transcript of the Grand Jury proceedings resulting in the Indictment in this
case, and as grounds therefore states the following:
1.

The Defense specifically demands a transcript of witness Camile Hamilton's

Grand Jury testimony.


2.

Mr. Pratt will demonstrate a particularized need for the transcript of the testimony

based on the facts and law as set out in this motion and introduced at hearing in this matter.
3,

Mr. Pratt is accused in the Indictment of three counts of 1st Degree Murder and 1

count of Attempted 1st Degree Murder. The State of Florida is seeking the death penalty.
4.

The Office of the Public Defender has been appointed to represent Mr. Pratt.

5.

On February 20, 2015, hearing was held on Mr. Pratt's Motion For Grand Jury

Testimony ofCamile Hamilton. On that date, and on February 26, 2015, this Honorable Court
ordered that the State provide Mr. Pratt with the transcript of the Grand Jury testimony ofCamile
Hamilton. On July 1, 2015, the Fourth District Court of Appeals ordered an in camera review of

the transcript ofCamile Hamilton's testimony before the grand jury that resulted in the
Indictment of Mr. Pratt.

FACTS:

On or about August 17, 2009, Ms. Camile Hamilton, Davion Bishop and Nekitta

Hamilton were approached by an individual at gunpoint in the driveway of 9581 Encino Street,
Miramar, Florida. Eventually the perpetrator forced those individual inside and upstairs to the
master bedroom of the home which was occupied by Faith Bisasor. The perpetrator shot each

of the four individuals in the head. Injuries sustained to Davion Bishop, Nekitta and Faith
Bisasor were fatal. Ms. Camile Hamilton survived the assault and when she became conscious

she went downstairs and contacted a neighbor who subsequently called 911. Ms. Camile
Hamilton was taken to Memorial Regional Hospital where she received medical care. Ms.

Camile Hamilton is the only surviving victim of this incident and the only eyewitness.
Over the course of this investigation and during case preparation (excluding grand jury

testimony) Ms. Camile Hamilton has given twelve (12) independent sworn statements, including
her deposition taken on April 4, 2014. Additionally, Detective Toyota advised in his sworn

deposition that he took several additional unrecorded statements from Ms. Camile Hamilton.
The documented statements were taken from August 16, 2009 until April 4, 2014.

During the course of an ongoing deposition, the defense has discovered countless
additional times that Ms. Hamilton has contacted law enforcement, been contacted by la\\.

enforcement, given additional information to law enforcement, or been given additional


information by law enforcement that were not recorded on audio or video, or documented in
reports.

The reports and transcripts reflect that Ms. Hamilton has given over 12 sworn statements
in this case. During those statements that were made available to the defense, Ms. Hamilton has

given materially inconsistent responses in the many areas. Florida Statutes Section 905.27(1 )(a)
provides for an exception to the normal secrecy provide grand jury testimony in order to
ascertain "whether it is consistent with the testimony given by the witness before the court.
Because of the material inconsistencies in Ms. Hamilton's statements, this Court should order

Ms. Hamilton's grand jury testimony to be disclosed. Ms, Hamilton has been inconsistent in the
following areas:
L Camile Hamilton's Location During the Initial Confrontation.
a. Camile Hamilton stated to Detective Toyota that she was in the driveway saying
goodbye to Nekitta Hamilton and Davion Bishop when the perpetrator came up from
behind (Ex 1, p 1, par. 3).
b. On 8/17/09, Camile Hamilton stated that she was 'outside with him, taking some stuff
from the car' (Ex 2, p 1 (bottom).
c. On 8/22/09 Camile Hamilton stated that she was by the driver's door when the
perpetrator approached her (Ex 6, p 2),
d. On 8/26/09, Camile Hamilton stated that she was by the passenger side and trunk
when the perpetrator approached (Ex. 8, p. 18),
e.

On 8/31/09, Camile Hamilton stated that she did not notice where the perpetrator

came from, and that the first time she noticed him was when he was next to the car (Ex.
9, pl).
f. On 8/17/09, Camile Hainilton stated that the perpetrator walked up to them with a gun
in his hand (Ex. 2, p 2),

If

g. On 9/9/09, Camile PIamilton stated that the perpetrator took the gun out while they
were outside (Ex. 10, p 3).
h. On 8/31/09 Camile Hamilton stated that she was by the passenger side door when the

perpetrator approached (Ex. 9, p 1).


*

1.

On 9/9/09, Camile Hamilton stated that she did not remember if she closed the car

door before going inside, but was certain she did not lock the door (Ex. 10, pp 7,14).

On 1/04/10, Camile Hamilton stated that the trunk was closed, that she was on the

passenger side, and the door was in between the perpetrator and Camile Hamilton. She
further indicated that he door was closed (Ex. 11, pp 250,252,271).

k. On 4/4/14, Camile Hamilton stated that she was standing by the driver's side door
when the perpetrator approached (Ex. 13, pg. 32,11. 21, 25, pg. 33,11. 8-9).
1.

On 4/4/14, Camile Hamilton stated that she brought the groceries into the house

before she was confronted by the perpetrator (Ex. 13, p 30,1. 14).
II. Whether the Perpetrator Was Wearing a Mask.
a.

Camile Hamilton stated to Detective Toyota that the perpetrator was not wearing

a mask (Ex. l,p 2, par. 5).


b.

On 8/17/09 Camile Hamilton stated that the perpetrator was wearing a mask (Ex.

3, p 3).
c.

On 8/17/09, Camile Hamilton repeated that the perpetrator was wearing a mask

(Ex. 4, pl).
d.

On 8/18/09, Camile Hamilton stated that the perpetrator was not wearing a mask,

but something covering his mouth (Ex. 5, p 4).


e.

On 8/18/09. Camiie Hamilton stated that the perpetrator was not wearing a mask.

He was using his shirt and a piece of cloth to cover his face (Ex. 5, p 4).
f.

On 8/24/09, Camile Hamilton stated that the perpetrator was not wearing a mask.

Camile Hamilton agreed that the perpetrator pulled his shirt up over his face (Ex. 7, p 8).
g

On 8/31/09, Camile Hamilton stated that the perpetrator was not wearing a mask

(Ex. 9, p 3).
h.

On 9/9/09, Camile Hamilton stated that the perpetrator was not wearing a mask,

except for in the very beginning (Ex. 10, p 10).


III. Whether the Perpetrator's Face Was Concealed, and. If So, How.
a. On 8/17/09, Camile Hamilton stated that the perpetrator was wearing a hat (Ex. 3, p
3).

b. On 8/18/09, Camile Hamilton stated that the perpetrator's face was covered (Ex. 5, p
4).
c.

On 8/17/09, Camile Hamilton stated that the perpetrator wore something covering just
his mouth (Ex. 3, p 3, line 2).

d. On 8/22/09, Camile Hamilton stated that the perpetrator was not wearing a hat (Ex. 6,
P6).
e.

On 9/9/09, Camile Hamilton stated that the perpetrator dropped his shirt from his
mouth when he took the gun out (Ex. 10, p 7-8).

f. On 1/4/10, Camile Hamilton stated that the perpetrator was wearing a stocking on his
head (Ex. 11,2.21).
g. On 4/4/14, Camile Hamilton stated that she could not recall the perpetrator wearing a
hat or making the statement that the perpetrator wore a hat (Ex. 13, pg. 55, 11. 15-17).
h. On 4/4/14, Camile Hamilton stated that the perpetrator was wearing a hoodie (Ex. 1 3,

p 34,11. 18-23).
1.

On 8/24/09, Camile Hamilton gave a description to forensic sketch artist, John


McMahon. The description did not include a hat, stocking or other head covering on
the perpetrator (Ex. 14, sketch).

fr

On 8/26/09, when asked if the sketch was accurate, Camile Hamilton replied, 'of
course' (Ex. 8, p 17).

IV. If and When the Perpetrator's Face Was Initially Exposed.


a. On 8/17/09, Camile Hamilton stated that she did not look at the perpetrator (Ex. 4, p
1).

b. Camile Hamilton gave a description of the perpetrator to Detective Toyota (Ex. 1, p


3, par. 5).
c.

On 1/4/10, Camile Hamilton stated that the best look she got at the perpetrator was
when he approached them outside (Ex. 11, p 288).

d. On 1/4/10, Camile Hamilton stated that the perpetrator asked her 'is this the face you
would never forget?' and that she answered'yes' (Ex. 11, 1:31).
e. On 4/4/14, Camile Hamilton stated that a couple of days after she participated in a

live lineup, (prior to her grand jury testimony), she pulled up Mr. Pratt's booking
photo online and viewed it (Ex. 13, p 127).
V. Whether the Perpetrator Used Vulgar Language, and, If So, What, and
Where the Statements Were Made

a. Camile Hamilton gave statements on 8/17/09, (two), and 8/18/09. Camile Hamilton
made no reference during those statements regarding the perpetrator saying anything (Ex.
2, 3, 4 and 5).

b. On 8/22/09, Camile Hamilton slated that the perpetrator said: 'shut the fuck up,' 'get
the fuck upstairs,' 'where the fuck is your money,' 'get the fuck over here/ 'you have to

suck my penis, 'shut the fuck up,' and 'I am going to fuck you up' (Ex.6 pg. 2, 11,1518,23,29).
c.

On 8/24/09, Camile Hamilton stated that the perpetrator said 'you fucking

something' after she shot at him (Ex.7, p. 3).

d. On 8/26/09, Camile Hamilton stated that the perpetrator said 'What the fuck is that, get
the fuck inside' (Ex. 8, p 2).
e. On 8/31/09, Camile Hamilton stated that the perpetrator said 'get the fuck inside, I
want money,' 'get the fuck upstairs, he would 'kill them all' because he 'wanted money/
'gonna kill you fuckers,' 'wanted her to suck his dick and wanted to fuck,' and 'you
fucking bitch' (Ex. 9, p 2,3,4).
f. On 9/9/09, Camile Hamilton stated that the perpetrator said 'I'm gonna kill you fuck,
'cause I want money' (Ex 10, p 5).
g. On 4/4/14, Camile Hamilton stated that she had earlier asserted that vulgar language
was used 'because of'her condition' (Ex. 13, p 87,11. 23-25, p 88,1.1).
VI. Whether Ms. Hamilton Looked at the Perpetrator.
a.

On 8/17/09, Camile Hamilton stated that she did not look at the perpetrator (Ex. ^,, p
92).

b. Camile Hamilton gave a description of the perpetrator to Detective Toyota (Ex. 1, p


3,, par. 5).
c.

On 1/4/10, Camile Hamilton slated that the best look she got at the perpetrator was
when he approached them outside (Ex. 11, p 288).

d. On 9/8/11, After the live lineup, Det. Toyota asked Camile Hamilton, 'is this the face

you told me you would never forget?' She answered 'yes' (Ex. 12, p 2,11. 21-25).
On 4/4/14, Camiie Hamilton stated that a couple of days after she participated in a

e.

live lineup, (prior to her testimony before the grand jury), she pulled up Mr. Pratt's
booking photo online and viewed it (Ex. 13, p 127).
On 4/4/14, Camile Hamilton stated that when she was asked to do the composite

f.

picture, 'I was out of it" (Ex. 13, p 56,1. 4).

g. On 8/26/09, when asked if the sketch was accurate, Camile Hamilton replied, 'of
course'(Ex. 8, p 17).
VII.

Whether the Perpetrator was Wearing Gloves

a. On 8/17/09, Camile Hamilton stated that she did not remember if the perpetrator was
wearing gloves (Ex. 4, p 1).

b. On 8/17/09, Camile Hamilton stated that the perpetrator was wearing gloves. (Ex. 4
p.6)
c.

Later in the 8/17/09 statement, Camile Hamilton agreed with Detective Toyota that
the gloves were yellow (Ex, 4, p 6).

d. On 8/18/09, Camile Hamilton stated that the perpetrator was wearing gloves (Ex. 5,
p6).
e. On 8/22/09, Camile Hamilton stated that she did not remember if the perpetrator was
wearing gloves (Ex. 6, p 7).

f. On 9/9/09, in response to Det. Toyota's question, 'I guess you're... 100 percent, you
said he wasn't wearing gloves right?' Camile Hamilton. Responded, 'don't
remember him wearing any gloves" (Ex. 10, p 8, 11).

g. On 9/9/09, Camile Hamilton had no response to Det. Toyota's question, 'Do you
ever mention anything about his hands?' (Ex. 10, p 8).
h. On 1/4/10, Camile Hamilton stated, 'His hand was shaky. His nails were a little bit
longer than these. And his hand was sweaty... (Ex.11, p 256,276,289).
*

1.

Detective Toyota's rough notes reflect the following: "Camile Hamilton


.. .remembers (perpetrator) not wearing gloves, she remembers b/c he tried to cover
fact {sic} with hood she could see fingemails" (Ex. 15, p 30).

J.

On 4/4/14, Camile Hamilton stated that the perpetrator was not wearing gloves (Ex.
13, P 36,11. 14-16).
vm.

Whether the Perpetrator Was Wearing a Hat.

a. On 8/17/09, Camile Hamilton stated that the perpetrator was wearing a hat (Ex.3, p
3).
b. On 8/18/09, Camile Hamilton stated that the perpetrator had on a blue cap (Ex. 5, p
7).

c. On 8/22/09, Camile Hamilton stated that the perpetrator was not wearing a hat (Ex.
6, p 6).
d. On 9/8/11, Camile Hamilton stated that the perpetrator was wearing a stocking on
his head (Ex. 12,p3 11.7-9).
e. On. 4/4/14, Camile Hamilton stated that she couid not recall the perpetrator wearing a
hat or making the statement that the perpetrator wore a hat (Ex. 13, p 55 11,15-17).
f. On 4/4/14, Camile Hamilton stated that the perpetrator was wearing a hoodie (Ex.
13, p 341. 18-23).
g. On 8/24/09, Camile Hamilton gave a description to forensic sketch artist, John

McMahon. The description did not include a hat, stocking or other head covering
for the perpetrator (Ex. 24, p 60,1.20, Ex. 14, sketch).
h. On 8/26/09, when asked if the sketch was accurate, Camile Hamilton replied, 'of
course.' (Ex. 8, p. 17)

IX. Description of the Perpetrator's Clothing.


a. On 8/17/09 Camile Hamilton stated that the color of the perpetrator's shirt was black
(Ex. 3, p 3).

b. On 8/18/09, Camile Hamilton stated that she did not know about the shirt (Ex. 1 L p
113).

c. On 8/22/09, Camile Hamilton stated that the perpetrator's shirt was black (Ex. 6, p
6).

d. On 8/31/09, Camile Hamilton stated that the perpetrator had on a second shirt and

that the top shirt was 'khaki shorts like.' (Ex. 9, p 4). She further stated that the
undershirt was black. (Ex. 9, p 4).

e. On 4/4/14, Camile Hamilton stated that the shirt was black (Ex. 13 p 34, 11. 12-13).
f. On 8/17/09, Camile Hamilton stated that the perpetrator was wearing pants (Ex. 3, p
3).

g. On 8/18/09, Camile Hamilton staled that the perpetrator was wearing shorts. Camile
Hamilton further stated that tlie shorts were blue, denim type (Ex. 5, p 113).

h. On 8/22/09, Camile Hamilton stated that the perpetrator was wearing khaki baggy
shorts that were worn low (Ex. 6, p 6).
*

1.

On 1/4/10, Camile Hamilton stated that the perpetrator was wearing plaid shorts that
were -pretty baggie' (Ex. 11, pp 252, 289-290).

10

t
a

On 4/4/14, Camile Hamilton stated that the perpetrator was wearing black shorts
(Ex. 13, p 34,11. 5-8).

k. On 8/22/09 Camile Hamilton stated that the perpetrator was wearing a dark colored
jacket (Ex. 6, p 139).
1.

On 8/24/09, Camile Hamilton stated that the perpetrator wore a hooded jacket (Ex.7,
p126).

m. On 8/22/09, Camile Hamilton stated that the perpetrator was wearing the hood when
he approached Camile Hamilton, Nekitta Hamilton, and Davion Bishop outside (Ex.
6, p 7).

n. On 1/4/10, Camile Hamilton stated that perpetrator's hood was down when he
approached Camile Hamilton, Nekitta Hamilton and Davion Bishop (Ex. 11, p 289).
X. Physical Description of the Perpetrator's Height, Skin Tone, Mouth, Facial Hair.
1. Description of the Perpetrator's Height
a. On 8/17/09, Camile Hamilton stated that the perpetrator was around 5'6" (Ex. 3, p 3).
b. On 8/18/09, Camile Hamilton stated that the perpetrator was 5' 10" (Ex. 5, p 157158).
c. On 4/4/14, Camile Hamilton stated that the perpetrator was 6' tail (Ex. 13, p. 56, 11.
7-18).
d. On 4/4/14, Camile Hamilton stated that a couple of days after she participated in a
ive lineup, (prior to her testimony before the grand jury), she pulled up Mr. Pratt's
booking photo online and viewed it. The booking information contains height and
weight (Kx. 13, p. 127).
e. On 9/9/09, Camile Hamilton stated, 'you know, I forgot him 'cause I see people on

11

the road, and 1 look at them. I don't know how I'm alive' (Ex. 10, p 9).
2. Description of the Perpetrator's Skin Tone
a. On 8/17/09, Camile PIamiiton described the perpetrator alternatively as black,
American black and dark skinned (Ex. 3, pp.3, 6).
b.

On 8/18/09, Camile Hamilton described the perpetrator as black and dark skinned
(Ex.5, p 110,112,115).

c.

On 8/22/09, Camile Hamilton described the perpetrator as black, medium to dark


skinned (Ex. 6, p 5).

d. On 8/31/09, Camile Hamilton described the perpetrator as dark skinned (Ex. 9, p 5).
e. On 9/9/09, Camile Hamilton described the perpetrator as dark skinned (Ex. 10, p 9).
3. Perpetrator's Mouth

a. On 8/24/09, Camile Hamilton worked with forensic sketch artist John Smith over
several hours to create a composite sketch of the perpetrator. Camile Hamilton
agreed with the result. When asked whether the sketch was accurate, Camile
Hamilton complained about the mouth, stating it did not look right. She had no
complaints regarding the lack of facial hair in the sketch (Ex. 11,p.285).
b.

On 8/26/09, when asked if the sketch was accurate, Camile Hamilton replied, 'of
course' (Ex. 8, p 17).

4. Facial Hair

a. Camile Hamilton stated that the perpetrator had a light mustache (Ex. 1, pp. 3, 5).
b. The attached Florida Identification photo shows Mr. Pratt with a full beard on

9/24/09 Just 39 days after the incident (Ex. 16, Florida Identification card photo).
c. On 8/24/09, Camile Hamilton worked with forensic sketch artist John Smith over
12

several hours to create a composite sketch of the perpetrator. Camile Hamilton


agreed with the result. When. asked whether the sketch was accurate, Camile
Hamilton complained about the mouth, stating it did not look right. She had no
complaints regarding the lack of facial hair in the sketch (Ex. 24, p 60,1.20, Ex. 14,
Ex. 11 p 285).
d. On 8/26/09, when asked if the sketch was accurate, Camile Hamilton replied, 'of
course' (Ex. 8, p. 17).
e.

The composite sketch generated in this case shows a thin mustache (Ex. 14).

f. On 8/16/09, the day of this incident, Mr. Pratt was stopped by Off. Gomez of the
Miami Dade Police Department. A field interview report was generated. Under
'physical description/ for the sub category FACE, Ofc. Gomez noted, BearcHGoatee.
(Ex. 17).

g. On 8/23/09, Mr. Pratt was stopped by Ofc. Sanjay Raja of the West Palm Beach
Police Department. A field interview card noted hair factaKfall .beard (Ex 18).
h. On 9/1/09, Mr. Pratt was stopped by Ofc, Vertefeuille of the West Palm Beach Police
Department. A field interview card indicated hair facial/ full beard (Ex. 19).

1.

On 5/1/09, Mr. Pratt was stopped by Ofc. C. Tomas of the West Palm Beach Police
Department. A field contact card was generated which reflects hair facial, full beard
(Ex.20).

j. On 5/4/09, Mr. Pratt was stopped by Ofc. Sanjay Raja of the West Palm Beach Police
Department. A field contact card was generated which reflects hair facial, full beard
and bald head with upper and lower gold teeth (Ex. 21).
k. On 5/10/09, Mr. Pratt was arrested by Ofc, Christian Tomas of the West Palm Beach
.'

13

Police Department. Ofc. Tomas states in his report, 'I immediately recognized the
individual who I trespass warned a week ago. Mr. Pratt's booking photo and report
from the incident is attached (Ex. 22).
*

On 4/4/14, Camile Hamilton stated that a couple of days after she participated in a

live lineup, (prior to her testimony before the grand jury), she viewed Mr, Pratt's
booking photo online (Ex. 13, p. 127).
XI. Whether Ms. Hamilton was Sexually Assaulted by the Perpetrator, the Type of
Assauit and the Location of the Assault.

a. On 8/18/09, Camile Hamilton stated that the perpetrator 'wanted to rape me' and that

he 'took his penis out.' Detective Toyota asked if the perpetrator removed Camile
Hamilton's clothes, to which she responded in the affirmative. Later in her statement
Camile Hamilton reiterated that the perpetrator 'took out his penis' while in Faith
Bisasor's bedroom. She later indicated that she is not sure if she was raped and that

the perpetrator 'put his penis away' (Ex. 5, pp 112-15).


b. On 8/22/09, Camile Hamilton stated that the perpetrator took out his penis, and told
her to remove her drawers, which made her believe he wanted to rape her. Camile
Hamilton further stated that she was unable to remove her drawers because of the

tape, so the perpetrator removed them. Her panties were removed prior to Faith
Bisasor being taped up. Camile Hamilton stated that the perpetrator told her he was
going to put his penis in her mouth (Ex. 6, pp 14, 18-20).
c.

On 4/4/14, Camile Hamilton stated that she had no memory of telling the police that
the perpetrator removed her parities (Ex. 13,1. 14).

d. On 8/24/09, Camile Hamilton stated that the perpetrator unzipped his pants (Ex. 7,
p.122).
14

<

e.

On 8/2.6/09, Camile Hamilton stated that when the perpetrator asked Faith Bisasor for
money, he was saying 'nasty stuff to Camile Hamilton in front of Faith Bisasor.

Camile Hamilton stated that she told the perpetrator that they were not going to have
sex. At that point, Ms. Hamilton states the perpetrator took out his penis, Ms.
Hamilton reiterated that they would not have sex, to which the perpetrator put his
penis in his pants and taped up Faith Bisasor (Ex. 8, p 186).
f. On 8/31/09, Camile Hamilton stated that after all four victims had been taped up, the
perpetrator took out his penis and put it in her face, stating that he wanted her to suck
his penis and to have sex with him (Ex. 9, p 3).

g. On 9/9/09, Camile Hamilton stated that the perpetrator grabbed her by the hair, took
out his penis, and stated he would rape her and then kill them all. When she said no,
he shot her (Ex.10,p 5).

h. On 1/4/10, Camile Hamilton stated that the perpetrator dragged her into the bedroom,
unzipped his pants and said he would rape her. She told the perpetrator that she was
'on her period/ he put his penis in his pants (Ex. 11, p 249).
i. On 4/4/14, Camile Hamilton stated that at no time did the perpetrator say he wanted
to have sex with her or rape her (Ex. 13, p 78)
XII.

Whether the Perpetrator Took Money During the Incident.

a. On 8/31/09, Camile Hamilton stated that the perpetrator took $20.00 from Nekitta

Hamilton. Later in this statement Camile Hamilton said that Nekitta Hamilton gave
$20.00 to the perpetrator (Ex. 9, pp 2, 11).
b. On 9/9/09, Camile Hamilton stated that Nekitta Hamilton had $20.00 in her hand,
and the perpetrator took it (Ex. 10, p 3).

15

c.

On 1/4/10, Camilc Hamilton stated that she gave $20.00 to Nekitta Hamilton, then
Camile Hamilton took the $20,00 back and handed the money to the perpetrator.
Later Camile Hamilton said that the perpetrator took the $20.00 from Nekitta

Hamilton after Camile Hamilton gave the money to her daughter. Later she stated

that the perpetrator took her daughter's money (Ex. 11, pp 253, 272,287,290).
d. On 4/4/14, Camilc Hamilton stated that the perpetrator took $40.00 from Nekitta

Hamilton during the initial confrontation at the car, and then stated that Nekitta
Hamilton gave her money to the perpetrator (Ex. 13, pp 37,38).
XIII. Whether the Perpetrator Took Money From Ms. Hamilton's Purse.
a.

On 8/22/09, Camile Hamilton stated that Faith Bisasor told the perpetrator that she
had no money at home; it was all in the bank (Ex. 6, p 12).

b. On 8/26/09 Camile Hamilton stated that Faith Bisasor gave money to the perpetrator
after Faith Bisasor was ordered to the ground by the perpetrator (Ex. 8, p 180).

c. On 9/9/09, Camile Hamilton stated that Faith Bisasor handed over money to the

perpetrator, who ordered Faith Bisasor to tape up the other victims (Ex. 10, p 4).
d. On 4/4/14, Camile Hamilton stated that Faith Bisasor emptied her purse onto the bed.
Camile Hamilton stated that Faith Bisasor told the perpetrator that she would take

him to her bank, and that Camilc Hamilton urged the perpetrator to take Faith Bisasor
to the bank (Ex. 13,50,23-25).
e.

On 4/4/14, Camile Hamilton stated that she went into her purse and gave the
perpetrator money (Ex. 13, p 45,1.5).

16

XIV.
a.

Whether the Perpetrator Had the Gun in His Right or Left Hand.

On 8/17/09, Camile Hamilton stated that the perpetrator held the gun in his left hand
(Ex.4,pp 103-04).

b. On 8/18/09, Camile Hamilton stated that the perpetrator held the gun in his right hand
(Ex. 5, pp 112,115).
c. On 8/22/09, Camile Hamilton stated that the peipetrator took the gun out of his
pocket with his right hand (Ex. 6, p 3).
d. On 1/4/10, Camile Hamilton stated that the perpetrator had the gun in his right hand
and his penis in his left hand while he was grabbing her hair. (Ex. 11, p 251).
e.

On 4/4/14, Camile Hamilton stated that the perpetrator held the gun in his right hand
(Ex. 13, pp 10-12).
XV.

a.

How Each Victim Was Tied Up and By Whom

On 8/22/09, Camile Hamilton stated that when the perpetrator asked Faith Bisasor
for her purse, the victims were already taped up. Later in this statement, Camiie
Hamilton asserted that she, Nekitta Hamilton, and Damion Bishop, were already tied
up when the perpetrator demanded money from Faith Bisasor (Ex. 6, pp 9,10,13).

b. On 1/4/10, Camile Hamilton stated that she did not see Faith Bisasor tie up Nekitta
Hamilton and/or Davion Bishop because she was knocked out by the perpetrator and
that when she regained consciousness, the other three were tied up (Ex. 11, p 57, L
16-20).
c. On 8/22/09, Camile Hamilton stated that the perpetrator tied her up at the same time
as Nekjtta Hamilton, then demanded money from Faith Bisasor. Later in the
statement Camile Hamilton asserted that the perpetrator ordered Faith Bisasor to tie

17

up Nekitta Hamilton and Davion Bishop. When the other three were taped up, the
perpetrator taped up Faith Bisasor. Later in the same statement, Camile Hamilton
said that the perpetrator taped up Faith Bisasor and herself, and then had Faith tape
Davion Bishop and Nekitta Hamilton (Ex. 6, pp. 9-12).
d.

On 8/24/09, Camile Hamilton stated that Faith Bisasor was ordered to tape Davion

Bishop and Niketta Hamilton, and then the perpetrator taped up Faith Bisasor.
Camile Hamilton remained untaped. Camile Hamilton staled that her feet were then
taped up by Faith Bisasor (Ex. 7, p 120),
e. On 8/26/09, Camile Hamilton stated that Davion Bishop was taped up first by Faith
/

Bisasor, followed by Nekitta Hamilton and lastly herself (Ex. 10, p 181).
f.

On 8/31/09, Camile Hamilton stated that the perpetrator ordered Faith Bisasor to

tape up Nekitta Hamilton and Davion Bishop first. Davion Bishop was taped up,
then Nekitta Hamilton, and then Camile. The perpetrator taped up Faith Bisasor.
Later in the statement, Camile Hamilton asserts that Faith Bisasor tied up Davion,
then Nekitta Hamilton and then Camile Hamilton, after which Faith taped up Davion

Bishop's and Nekitta Hamilton's feet (Ex. 9, pp 2-3, 8).

g. On 9/9/09; Camile Hamilton stated that Faith Bisasor was ordered to tape everyone
up. Camile Hamilton could not remember if Faith taped up Davion Bishop or
Nekitta Hamilton first (Ex. 10, pp 4-5).

h. On 1/4/10, Camile Hamilton stated that the perpetrator handed Faith Bisasor the tape
/

and ordered her to tape up Nekitta Hamilton, Davion Bishop, and herself. Camile
Hamilton cannot remember if she got hit, but when she regained consciousness she

was taped up, and saw the perpetrator taping Faith Bisasor. Camile Hamilton later
18

-t

asserts that Faith Bisasor taped Nekitta Hamilton first, then Davion Bishop. Camile
Hamilton stated that the perpetrator ordered Faith Bisasor to tape them up. Camile
Hamilton stated that Faith Bisasor taped Nekitta Hamilton, then Davion Bishop (Ex.
11, pp 260-61,264-65,277,282,283,287).
.

1.

On 4/4/14, Camile Hamilton stated that she does not remember when everyone was

taped, only that she was pistol whipped, passed out, and that when she regained
consciousness everyone was taped up, and the perpetrator was just finishing taping
up Faith Bisasor (Ex. 13, p 58,11. 23-25).
XVI.

Origin Of The Tape Used To Tie Up The Victims

a. On 8/18/09, Camile Hamilton stated that the tape came from Faith Bisasor's home
(Ex. 5, p 114).
b. On 8/22/09, Camile Hamilton stated that she did not remember where the tape came
from (Ex. 6, p 157).
c. On 8/26/09, Camile Hamilton stated that she did not know where the perpetrator got
the duct tape. Camile Hamilton did not know if there was duct tape in Vivian
Lassman's car (Ex. 10, p 189).
d. On 8/31/0, Camile Hamilton stated that the duct tape came from the perpetrator's
pocket (Ex. 9, p 2-3,7).
e.

On 9/9/09, Camile Hamilton stated that the perpetrator removed duct tape from his
pocket (Ex. 10, p 4).

f. On 1/4/10, Camile Hamilton stated that she was not sure whether the tape came from
Faith Bisasor's home or from the perpetrator's pocket. She further stated that there
was always gray tape in Faith Bisasor's home. Camiie Hamilton stated that she was

19

not sure if the tape came from the table, the room, or the peq)etrator (Ex. 11, p 254,
273,276,283).

g. On 4/4/14, Camile Hamilton stated, 'I was screaming and yelling and saying don't
tape them up' (Ex. 13, pp 57-58,1.1).
XVII. Color of the Gun

a. On 8/18/09, Camile Hamilton stated that she did not remember what color the gun
was (Ex. 5,p 116).
b. On 8/22/09, Camile Hamilton stated that the gun was black (Ex. 6, p 3).
c.

On 9/9/09, Camile Hamilton stated that she thought the gun was black (Ex. 10, p 11).

d. On 4/4/14, Camile Hamilton stated that she did not remember what color the gun was
(Ex. 13, p 40,11. 18-20).
XVIII. When and How the Perpetrator Dropped the Gun and Camile Hamilton
Took Possession of the Gun
a.

On 8/22/09, Camile Hamilton stated that she got the gun when the perpetrator

dropped it. Later in the statement she asserted that she got the gun while the
perpetrator was taping up Faith Bisasor. Still later Camile Hamilton stated that the
gun dropped while the perpetrator was takin out his penis (Ex. 6, pp 15-16, 18, 19).
b. On 8/24/09, Camile Hamilton stated that the gun dropped when the perpetrator
unzipped his pants (Ex. 7, p 122).
c. On 8/26/09, Camile Hamilton stated that while the perpetrator was taping Faith

Bisasor, the gun dropped. Camilc Hamilton picked up the gun and ran into the other
room (Ex. 10,p 183).

20

d. On 8/31/09, Camile Hamilton stated that the perpetrator dropped the gun when he

was re-taping Faith Bisasor's hands. Camile Hamilton picked up the gun and crawled
into another room with the gun (Ex. 9, p 3).
e. On 9/9/09, Camile Hamilton stated that she crawled and ran into another room with
the gun after the perpetrator dropped it (Ex. 10, p 5).
f. On 1/4/10, Camile Hamilton stated that when the perpetrator was over her, and taping

Faith Bisasor, he dropped the gun. She took it and crawled into the next room (Ex.
11,261,277,287,283).
g

On 4/4/14^ Camile Hamilton stated that the gun fell out of the perpetrator/s pants.

She picked up the gun with both hands, and drug on her knees into the next bedroom
(Ex. 13, pp 60, 65, 69, 70).
XIX.

Location of Camile Hamilton and the Perpetrator


When She Discharged the Gun

a. On 8/22/09, Camile Hamilton stated that she was not in a separate room from the
others, and that she was in the master bedroom when she shot at the perpetrator. Later
in the statement, Camile Hamilton asserted that she may have been in the guest room
when she shot at the perpetrator (Ex. 6, pp 15-19).
b,

On 8/26/09, Camile HamiUon stated that the perpetrator finished taping Faith Bisasor
and then entered the room when she fired two shots. She restated that she was in the

guest room when she fired two shots (Ex. 10, pp 183-184,185).
c.

On 8/22/09, Camile Hamilton stated, 'Did you find, did you find out that I fire a

shot?... Did you check my hand?' (referring to the gun shot residue test) (Ex. 6, p 17).
d. On 8/31/09, Camite Hamilton stated that she fired two shots at the perpetrator from
the guestroom (Ex. 9, p 3).
21

e. On 9/9/09, Camilc Hamilton stated that she thought she fired two shots while in the
guest room (Ex. 10, p 5).

f. On 1/4/10, Camile Hamilton stated that when she reached the other bedroom, the

perpetrator was in front of her, and she fired one shot, then another, and the gun
dropped (Ex. 11, p 261-262, 277,283).

g. On 4/4/14, Camile Hamilton stated that they were in the other bedroom and the
perpetrator was standing by the door when she shot at him (Ex 13, p 74).
XX.

Whether, How, and Where the Perpetrator Dragged


Camile Hamilton

a. On 8/24/09, Camile Hamilton stated that the perpetrator drug her out on her knees
(Ex. 7, p 120).
b.

On 8/26/09, Camile Hamilton stated that after she fired the gun, the perpetrator

grabbed her by her hair and dragged her. She later asserted that the perpetrator

grabbed her with one hand and held the gun in the other (Ex. 10, pp 214, 217).
c. On 8/31/09, Camile Hamilton stated that the perpetrator drug her back inside (Ex. 9, p
3).

d. On 9/9/09, Camile Hamilton stated that the perpetrator grabbed her by her hair and

dragged her back in the room. Camile Hamilton stated that she did not try to grab his
hands as he dmg her by her hair into the room (Ex. 10, pp 7, 10).
e.

On 1/4/10, Camile Hamilton stated that the perpetrator grabbed her in the back of the

head and drug her into the bedroom at the end of the bed. Later she states that the
perpetrator grabbed her by her hair and took her back in the room (Ex. 11, pp
262,277,278,287).

22

f. On 4/4/14, Cainile Hamilton stated that the perpetrator dragged her back to Faith
Bisasor's room after she shot at him. She further stated that the perpetrator grabbed
her by the hair and drug her back into the other room (Ex. 13, p 76-77).

g. On 8/24/09, Camile Hamilton stated that the perpetrator dragged her out of Faith
Bisasor's room and into the guest room (Ex. 7, p 121).
h. On 8/26/09, Camile Hamilton stated that the perpetrator dragged her into the room
where Faith Bisasor, Nekitta Hamilton and Davion Bishop were located (Ex.10, p
185).

XXI. Whether the Perpetrator Demanded or Attempted to Take Jewelry or


Valuables

a. On 8/22/09, Camile Hamilton stated that she had a gold chain, bracelet, and two rings

that night that broke off and fell to the ground. Camile Hamilton did not remember
how this happened. When the Detective refreshed her recollection with a previous
statement, she indicated that she was sure that the peq)etrator pulled off the jewelry
and threw it to the ground (Ex. 6, p 13).
b.

On 8/31/09 Camile Hamilton stated that she took off the bracelet and two rings and

placed them under the bed. She stated that the gold chain fell off (Ex. 9, p. 6).
c. On 4/4/14, Camile Hamilton stated that the perpetrator never asked for jewelry, that

she removed it and placed it under the bed. She stated she did not recall telling law
enforcement that the perpetrator removed her jewelry and threw it on the floor (Ex.
13, pp. 47, 48).

Furthermore, the specific facts of this case create a particularized need for this testimony.
Florida Statutes Section 905.27(l)(c) provides for the disclosure of grand jury testimony in order
to further justice. Human memory is a complex process. Research "has refuted the notion that
23

memory is like a video recording, and that a witness need only replay the tape to remember what

happened." SttUe v. Hsnderson, 208 N.J. 208, 245 (N.J. 2011). Memory is a constructive,
dynamic, and selective process. There are three stages in memory: "acquisition-the perception
of the original event; retention-the period of time that passes between the event and the
eventual recollection of a particular piece of information; and retrieval-the stage during which a

person recalls stored information." Id. (internal citations omitted) (citing to Elizabeth F. Loftus,
Eyewitness Testimony 21 (2d cd. 1996). Human vision does not capture a perfect, error-free
"trace" of a witnessed event. At each stage of the memory process, memory can be distorted,
contaminated, and even falsely imagined.
Trauma effects the accuracy of memory, and Camile Hamilton's head injury renders her

incapable of recalling these horrific events accurately. Camiie Hamilton suffered a gunshot
wound to her head, requiring hospitalization and subsequent operations and treatment. Detective
Toyota stated in his deposition that the reason he immediately took a statement from Camile
Hamilton was because her treating physicians did not expect her to live (Ex. 24, p 11, 11. 5-7).
The other victims in the case were Davion Bishop, a young man with whom Camile Hamilton
was intimately acquainted, Faith Bisasor, a friend, and Nekitta Hamilton, the daughter ofCamile
Hamilton. The events that Camile Hamilton endured were nothing short of traumatizing and life
shattermg.
At times, even Ms. Hamilton has acknowledged her difficulty with remembering these
events. On 8/22/09, Camile Hamilton stated, 'Did you find, did you find out that I fire a
shot?...Did you check my hand?' (referring to the gun shot residue test) (Ex. 6, p 17). On 9/9/09,
Camile Hamilton stated, 'you know, I forgot him 'cause I see people on the road, and I look at
them. I don't know how I'm alive' (Ex. 10, p 9). On 4/4/14, Camile Hamilton stated that she

24

was unable to recall making an earlier statement because 'I was in trauma' (Ex. 13, p 55,1.17).
On 4/4/14, in explaining why there were inconsistencies in her prior statements, Camile
Hamilton indicated, 'well I was in the hospital, and my jaw was wired shut, so they could not
understand what I was saying' (Ex. 13, p 84,11. 6-25). On 4/4/14, in explaining why she had

previously asserted that the perpetrator wore a mask, Camile Hamilton said, 'I was under
anesthesia' (Ex- 13, p 1 10,1. 14). On 4/4/14, Camile Hamilton stated that she has no memory of
being loaded into the ambulance or taken to the hospital. (Ex. 13, p 124,}. 7).
The known inconsistencies between Ms. Hamilton's accounts and the known potential

causes of Ms. Hamilton's faulty memory increase the need for disclosure of all of her statements.

It is particularly problematic in this case that Detective Toyota failed to record or fully
memorialize all of the statements he obtained from Ms. Hamilton. On 4/4/14, Camile Hamilton
stated that there were several times when she would cali Detective Toyota (Ex. 13, p 90,1. 18, pp

95-96). On 4/4/14, Caraile Hamilton stated that there were times when Detective Toyota called
her (Ex. 13, p9. 93-94, II. 22-5). On 4/10/15, Detective Toyota stated that he had a conversation
with Camile Hamilton regarding a live lineup, but that he does not remember where or when this
conversation occurred (Ex. 23, p 134,1. 12). On 4/10/15, Detective Steven Toyota stated that a
conversation with Camile Hamilton occurred after a live lineup was conducted. There is no

recording, notes or mention of this conversation in any discovery provided by the State (Ex. 23,

p 147,1. 19). On 4/10/15, Detective Toyota attributed statements to Camile Hamilton that appear
in no recording, written note, or transcript (Ex. 23, p 161,1. 21, pg. 162, 1. 5). On 4/19/15,
Detective Steven Toyota gave previously unknown infoi-mation regarding a conversation he had
with Camile Hamilton that was not included in his report of the conversation (Ex. 23, p 167,1.4).

Detective Toyota's rough notes reflect that on Oct. 18, 2009, Camile Hamilton and Detective
25

Toyota spent the day together. There is no recording or reference to this in any report (Ex. 15, p
52).

Some of the factors that can affect eyewitness memory are beyond law enforcement
control. These estimator variables relate to the environmental conditions at the time of the crime

and the characteristics of the witness and the perpetrator. However, some factors that affect

eyewitness memory are under the control of law enforcements. These system variables are the
characteristics of the procedures and practices used by Saw enforcement while trying to obtain an
identification. Based on the reported contents of some of the unrecorded conversations with law
enforcement, it is clear that Detective Toyota and Ms. Hamilton discussed many issues that relate
to her memory of the event and perpetrator. Detective Toyota's rough notes reflect that Camile
Hamilton described her dreams to Detective Toyota (Ex. 15, p 40). Detective Toyota's rough

notes reflect that Camile Hamilton picked out a different suspect (Ex. 15, p 47). On 11/6/14,
Detective Toyota stated that Camile Hamilton was shown crime scene photos, but that he is not
sure when she was shown the photos, or which photos she was shown (Ex. 25, p. 39,11. 6-10, pg.
40,11.1-4).
Even Detective Toyota does not recall some of the statements he has obtained from Ms.
*/

Hamilton. On 11/6/14, Detective Toyota stated his rough notes contained a statement from
Camile Hamilton that 'would have been taken from her that is unrecorded and we have never

seen before' (Ex. 25, p. 8,1.22-25, p. 9,1,1). On 11/6/14, Detective Toyota explained an entry in
his rough notes regarding Camile Hamilton, stating, 'I'm assuming I made contact with her but I
don't have any notes of that conversation" (Ex. 25, p 10, 11. 22-24). On 11/6/14, Detective

Toyota was asked; 'And that looks like it would have been another statement between 4 and 5, is
that right?' to which he responded, -Correct' (Ex. 25, p 14,11. 20-22). On 11/6/14, Detective
26

Toyota stated, "Is it possible that I made contact (with Camile Hamilton)? Yes, but I didn't sec
any documented contacts in my notes..." (Ex, 25, P 19, 11. 20-21). On 11/6/14, Detective Toyota
was asked, '.. .and others of your contact (with Camile Hamilton) were not recorded? 'to which
he answered, 'Yes' (Ex. 25, p 21,11. 23-24). On 11/6/14, Detective Toyota had the following

exchange with defense counsel, ". . .do you recail if you had any communications with her
(Camile Hamilton) between statement 5 and 6 that is not recorded?' Ans. "No." Q. "Okay. You
do not recall or you did not?" A: "I do not recall" (Ex. 25, p. 26,11. 14-19). On 1 1/6/14,
Detective Toyota stated that he did not recall whether he had contact with Camile Hamilton
between the statements she gave on Aug. 24 and Aug. 26, 2009. Detective Toyota's report does
not reflect any contact, however, his rough notes and testimony at deposition reflect numerous
contacts omitted in his report(s) (Ex. 25, p 3 8,11. 6-11, Ex. 1, Ex. 15). On 11/6/14, Detective

Toyota stated that prior to recording Camile Hamilton's statement on 8/24/09, he had
conversation with Camile Hamilton, but does not remember what the conversation was about and
took no notes of the conversation. There is no mention of this conversation in Det. Toyota's

report(s) (Ex. 25, pp. 33, 11. 24-25 and p. 34, 11 1-13, Ex. 1),
The defense acknowledges that Grand Jury testimony and evidence is not routinely

provided to the defense, however, the unusually high number of inconsistencies and the
progression of Mrs. Hamilton's testimony mandate that this witness' testimony be provided to
Mr. Pratt in its entirety. The detriment to the State is minimal when compared to Mr, Pratt's

right to confront the witness and to fully investigate the capital accusations against him. The
attached article, 'Secret Grand Jury Testimony From Ethel Rosenberg's Brother Is Released,'
which ran in the New York Times just two weeks ago, is illustrative, to say the least. (Ex. 26).

27

In addition due to the severity and irrevocable nature of the death penalty, the United

States Supreme Court has held that "the Eight Amendment requires a greater degree of accuracy
and fact-finding than would be true in a noncapital case" in all phases of a capital trial. Gilmore
v. Taylor, 508 US 333, 342 (1983). Accord Woodson v. North Carolina, 428 US 280, 305

(1976); Beck, supra, 447 U.S. at 637-638; Johnson v. Mississippi, 486 U.S. 578, 584-90 (1998).
The heightened degree of reliability demanded in capital cases affords additional protections
against inaccurate or unconstitutionally unreliable verdicts about and beyond the basic due
process protections applicable in all criminal cases.
MEMORANDUM OF LAW AND AE. UMENT

Ms. Hamilton's testimony and any physical evidence upon which the grand jury relied in

returning its Indictment against Mr. Pratt should be provided to undersigned counsel for the
following reasons:

(a) To ascertain whether Ms. Hamilton's grand jury testimony agrees with other
testimony and evidence given by the witness during the investigation, depositions,
hearings and/or trial.
(b) In furtherance of justice and due process

(c) To enable meaningful and intelligent enforcement and review of the right to a grand
jury indictment guaranteed by the Fifth, Eighth and Fourteenth Amendments to the United States
Constitution and article I, section 15(a) of the Florida Constitution.

There is no justification for continued secrecy of the grand jury proceeding; any

justification advanced by the State is minimal when weighed against the due process rights of
Mr. Pratt. A defendant charged with a capital crime is entitled to State and Federal constitutional

28

right to disclosure of what transpired during the Grand Jury proceeding under these
.

circumstances.

The disclosure of the above material is essential to ensure compliance with the Federal

guarantee of due process and indictment under the Fifth, Eighth and Fourteenth Amendments to
the United States Constitution and Florida's Constitution and statutes.

Disclosure of the above material is appropriate under Florida Statute 905.27.


Disclosure of the above material is necessary to provide effective assistance of counsel,

obtain meaningful appellate review, and to otherwise fully protect the Accused's constitutional
rights under article I, sections 2, 9, 15(a), 16, 17 and 22 of the Florida Constitution.
The disclosure of the above material is necessary provide effective assistance of counsel,

obtain meaningful appellate review, Due Process of Law and to otherwise fully protect the rights
guaranteed by Amendments V, VI, VIII and XIV to the United States Constitution.
In general, trial courts have the discretion to order the disclosure of grand jury

proceedings. Seefi?Mv^tom, 918 So.2d 405 (Fla. 5th DCA 2006) (not an abuse of discretion
in a non-capital case where defendant found guilty of second degree murder to fail to order
disclosure of grand jury proceedings). The testimony that was presented at the grand jury is
accessible because Florida now requires that "testimony in grand jury proceedings shall be

reported by a court reporter, but shall not be transcribed unless required by order of the court.
Other parts of grand jury proceedings, including deliberations and voting, shall not be reported."
Fla-RJud.Admin. 2.535(h)(6). The testimony and evidence presented during a grand jury

proceeding can be property admitted under section 90.801 (2)(a) as substantive evidence. State v.
Green, 667 So.2d 756, 759 (Fla. 1995); Moore v. Stale. 452 So.2d 559 (Fla. 1984). In that

regard, the State of Florida has unfettered access to grand jury proceedings and is readily able to
29

use grand jury testimony to impeach witnesses whose grand jury testimony differs from that
presented at trial. Rg, Barv^tgte, 938 So. 2d 451 (Fla. 2006) (prosecutor allowed to

impeach witness with testimony and photograph presented during grand jury proceedings). This
gives an unfair advantage to the state.

Mr. Pratt's interests in enforcing the state and federal right to indictment for a

capital crime and to prepare a meaningful defense to imposition of capital punishment otherwise
outweigh the State's interest in concealing what transpired during the grand jury hearing
In Bwtterwwtfi.v. Smith, (110 S.Ct. 1376) Judge Rehnquist delivered the opinion for a

unanimous Court, holding Florida a statute prohibiting a grand jury witness from ever disclosing
his testimony violated the First Amendment insofar as it prohibits a witness from disclosing his
own testimony after grand jury's term has ended. Although the Court was dealing with a very

narrow issue of grand jury witness testimony and the 1st Amendment, Judge Rehnquist's opinion
undermines the State's assertion as to the necessity for secrecy in grand jury proceedings. Judge

Rehnquist cites to Unites Slater v. Prociec & CjwnNfCo., an opinion that had stood for the
State's assertion. (356 U.S 677, 78 S.Ct. 983 (1958)). The Court in that case noted that several
distinct interests are served by safeguarding the confidently of grand jury proceedings,
specifically:
1.

If pre-indictment proceedings were public, many prospective witnesses would be


hesitant to come forward voluntarily, knowing that those against whom they testify
would be. aware of that testimony. Moreover, witnesses would be less likely to testify
*

fully and frankly.


2.

There is the risk that those about to be indicted would flee. or would try to influence
individual grand jurors lo vote against indictment.

30

3, Protection for the person that is accused but exonerated by the grand jury will not be
leld up to public ridicule. Dw&laiOitCo^afrMlfgrmavJ'etroiStoMMll^^
441 US 211, 218-219 (1979).

Florida relies on the interest in preserving grand jury secrecy as outlined by the Qouglas,

Court. But as the Supreme Court held in the BuUerworth case, the Justices did not believe those
interests warrant a permanent ban on the disclosure by a witness of his own testimony once the

grand jury has been discharged. Some of those interests are not served at all by a Florida ban on
disclosure, and those that are served are not sufficient to sustain the statute, Id., at 632.
(emphasis added).

The safeguards that Florida places on the release of grand jury testimony as referred to
above are simply not relevant in Mr. Pratt's case and are distinguished as follows:

1. The secrecy safeguard that would protect testifying witnesses does not apply in this
case as Camile Hamilton has been listed as a state witness since November 13,2011.

Additionally, Mr. Pratt actually had direct face to face contact with her pre indictment
when law enforcement arranged for Ms, Hamilton to confront Mr. Pratt. The issue of

protecting the witness identity does not apply here. Additmall}^ the Defense is not
requesting the identification of the grand jurors.
<

2. Pre-indictment concerns regarding flight do not apply in this case. Mr. Pratt remains
in maximum security at the Broward County Main Jail and has no bond.

3. Finally, concerns for the un-indicted is inapplicable as Mr. Pratt has been indicted in
this case.

Florida courts resist requiring the disclosure of grand jury proceedings unless Defendants

can show a special need for the material. The Defendant respectfully submits that a special need
31

here exists for the testimony of Ms. Camile Hamilton that was presented to the grand jury. In
Miritmv, Siate, the Florida Supreme Court granted Certiorari because there was an apparent
conflict between the decision of the District Court of Appeal and tlie decision of the Supreme

Court in TrafficaMe v. State, 92 So.2d 811 (1957) involving the rights of the defendant in a
criminal case to inspect the grand jury testimony of a state's witness for the purpose of laying the

foundation for impeaching the trial testimony. 113 So.2d 361 (1959). In Minton, the Defense
both filed a written motion and orally moved for an order requiring the State to make available to
the defendant and his attorney all portions of the grand jury report. The motion was sworn to by

counsel for defendant 'upon information, knowledge and belief... .so that I can determine
whether he is testifying to the same thing at this time as he did then" id. at 362. Essentially
defense counsel wanted to see if the witness' Grand Jury- testimony would be consistent with his

trial testimony. Defense counsel did not show a particularized need for the testimony and merely
surmised and speculated that the Grand Jury testimony would conflict with the trial testimony
and the Court properly denied both motions.

In J'fnfncante v-Sleite, the Florida Supreme Court, allowed release of a witness' grand

jury testimony because counsel had been able to demonstrated a particularized need for the
testimony. 92 So.2d 811 (1957). In Tmfficgnte, the Florida Supreme Court held that it was error
for the trial judge to deny a sworn application for subpoena duces tecuin directing the official
court reporter to bring the transcript on one of the. states witness given before the grand jury in
order that it might be utilized in cross-examination of the witness for the purpose of laying the
foundation for impeachment of the witness' direct testimony without first examining same to
determine its 'materiality'.

The appellate court affirmed the trial courts finding holding that no

proper predicate, was made by the defendant sufficient to require a preliminary examination of
32

ff

the Grand Jury testimony of witness Thomas. The Florida Supreme Court reversed the appellate
court's ruling and found that counsel had in fact laid the proper predict and had demonstrated a
particularizes need for the testimony.

Under oath, counsel for Trafljcante stated that an examination of the grand jury

transcripts of a specific witness (Sergeant Dietrich) was warranted as it was material and relevant
to, and in conflict with, Sgt. Dietrich's testimony on direct examination. In order to show the
court this conflict, defense counsel proffered the testimony of the official grand jury court

reporter, who stated that Sergeant Dietrich testified before the grand jury concerning some or all
of the matters and transactions about which he testified at trial. Counsel also demonstrated that

Sergeant Dietrich's testimony was in direct conflict with other testimony. It was crystal clear to
the Florida Supreme Court that something more than mere surmise or speculation that a witness'
testimony at trial is inconsistent his grand jury testimony and that Trafficante has shown the
proper predicate and had demonstrated a particularized need for disclosure.
Mr. Pratt's case is similar to the Trafficante case in that Mr. Pratt has illustrated a

particularized need for disclosure of Ms. Hamilton's grand jury testimony. Mr, Pratt does not

speculate or surmise that Ms. PIamilton has previously given inconsistent statement relating to
material aspects of his case. Mr. Pratt has illustrated in this motion that Ms. Hamilton has given
at least 12 previous sworn statements and in those 12 statements she has given conflicting
responses. It is therefore necessary to disclose her testimony in order for the defense to prepare
for impeachment as well as to insure that justice is served.
Because heightened procedural due process attends imposition of capital punishment,
disclosure of the basis of the prosecution is required to enable meaningfuj appellate review and
effective assistance of counsel. The interests of reliable fact finding and heightened procedure

33

due process that accompany imposition of capital punishment far outweigh any interest in the
continued secrecy of grand jury proceedings in this case,
.

Section 905.27(1), Florida Statute, allows disclosure of grand jury testimony to ascertain
whether it is consistent with testimony in court, to determine whether the witness is guilty of

perjury, and for die purpose of "furthering justice." Justice is furthered by insuring that grand
jury proceedings resulting in the indictment of a person for a capital offensc was properly
conducted in accordance with ethical concerns and the laws of the State of Florida.

The secrecy that once cloaked Florida grand jury proceedings now gives way to scrutiny
when a valid interest is served.

The constitutional rights that are fundamental to the case at bar are as substantial as the
first amendment rights of the witness in Buttemorlh v. Smith. Initially, the defendant's right

against arbitrary application of the death penalty under the Eighth Amendment and Article I,
Section 17 of the Florida Constitution. Further, Mr. Pratt's right not to have Ills life taken

without due process of law under the Fourteenth Amendment as well as article I, section 9 of the
Florida Constitution are surely as compelling as the First Amendment right involved in

Buttsrwgrth. Similarly, the public interest in preventing the execution of those with valid
defenses and those for whom the death penalty is inappropriate is of great importance. \Vhen

weighed against these rights, Florida's interest in grand jury secrecy dissipates entirely.
.

WHEREFORE,, based on the grounds specified in the motion and the accompanying

memorandum of law, the defendant requests that this Court enter an order authorizing the

undersigned attorney to have the grand jury proceedings in this cause transcribed.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been

furnished by e-service to the Office of the State Attorney, ALBERTO RIBAS, Homicide
34

Division at courtdocs@saol7.state.fl.us, Broward County Courthouse, Fort Lauderdale, Florida,


this October 29, 2015.
T
HOWARD FINKELSTEIN

Public Defender, 17th Judicial Circuit


S/ BETSY BENSON
---.

BETSY BENSON
Florida Bar No. 434280
Assistant Public Defender

Attorney for Kevin Pratt


discovery@browarddefender.org
(954)831-8672

35

EXHIBIT INDEX

Exhibit 1: Composite of reports prepared by Detective Toyota pp. 1-18


Exhibit 2: Statement ofCamile Hamilton given August 17, 2009

Exhibit 3: (3rd) Statement ofCamile Hamilton given August 17, 2009


Exhibit 4: (2nd) Statement ofCamile Hamilton given August 17, 2009
Exhibit 5: Statement ofCamile Hamilton given August 18, 2009
Exhibit 6: Statement of Camile Hamilton given August 22, 2009
Exhibit 7: Statement ofCamile Hamilton given August 24, 2009
Exhibit 8: Statement of Camile Hamilton given August 26, 2009
Exhibit 9: Statement ofCamile Hamilton given August 31, 2009
Exhibit 10: Statement ofCamile Hamilton given September 9, 2009
Exhibit 11: Cognitive Interview ofCamile Hamilton given January 4,2010
Exhibit 12: Statement ofCamile Hamilton given September 8, 2011
Exhibit 13: Deposition ofCamile Hamilton taken April 4, 2014
Exhibit 14: Composite by forensic sketch artist John McMahon
Exhibit 15 Rough Notes ofDet. Steven Toyota
Exhibit 16 Florida Identification card issued to Mr. Kevin Pratt on 9/16/09

Exhibit 17 Field Interview Card from stop of Mr. Pratt by Officer. Gomez in Miami Dade on
8/16/09

Exhibit 18 Field Interview Card from stop of Mr. Pratt by Ofc. Sanjay in West Palm on 8/23/09
Exhibit 19 Field Interview Card from stop of Mr. Pratt by Officer. Vertefeuille in West Palm on
9/1/09

Exhibit 20 Field Interview Card from stop of Mr. Pratt by Off. Tomas in West Palm on 5/1/09
Exhibit 21 Field Interview Card from stop of Mr. Pratt by Off. Sanjay in West Palm on 5/4/09
Exhibit 22 P.C./booking photo from arrest of Mr. Pratt by Off. Tomas in West Palm on 5/10/09
Exhibit 23 4/10/15 (continued) deposition of Detective Steven Toyota
Exhibit 24 4/28/14 (continued) deposition of Detective Steven Toyota
Exhibit 25 11/6/14 (continued) deposition of Detective Steven Toyota
Exhibit 26 7/15/15 New York Times "Secret Grand Jury Testimony From Ethel Rosenberg's
Brother is Released

1;

36

BUSINESS INVOLVEMENT:

33a. If you are now an officer, director or otherwise engaged in the management of any
business enterprise, state the name of such enterprise, the nature of the business, the

nature of your duties, and whether you intend to resign such position immediately upon
your appointment or election to judicial office.
am the Co-founder and President of2-4theshow.org, inc., a non profit that provides

surplus and unused tickets to theater and arts presentations to underprivileged youths.
33b. Since being admitted to the Bar, have you ever been engaged in any occupation,
business or profession other than the practice of law? If so, give details, including dates.
I was the co-owner of a dance dub in Orlando from 1990 to 1991. The club was called

Big Bang. From 1992 to 1993 I was the co-owner of a publication called Out Pages. It
was a directory of businesses and services for the gay community.

33c. State whether during the past five years you have received any fees or compensation of

any kind, other than for legal services rendered, from any _ business enterprise,
institution, organization, or association of any kind. If so, identify the source of such
compensation, the nature of the business enterprise, institution, organization or
association involved and the dates such compensation was paid and the amounts.
I have not.

POSSIBLE BIAS OR PREJUDICE:


34.

The Commission is interested in knowing if there are certain types of cases, groups of

entities, or extended relationships or associations which would limit the cases for which
you could sit as the presiding judge. Please list all types or classification^ of cases or
litigants for which you as a general proposition believe it would be difficult for you to sit
as-the presiding judge. Indicate the reason for each situation as to why you believe you
might be in conflict. If you have prior judicial experience, describe the types of cases
from which you have recused yourself.

Nothing would prevent me from following the law.


MISCELLANEOUS:

35a. Have you ever been convicted of a felony or a first degree misdemeanor?
Yes

No

XXX

If "Yes" what charges?


Date of Conviction:

Where convicted?

-K.---.-.-.V.

35b. Have you pled nolo contendere or pled guilty to a crime which is a felony or a first
degree misdemeanor?
Yes

No

XXX

If "Yes" what charges?


Date of Conviction:

Where convicted?

35c. Have you ever had the adjudication of guilt withheld for a crime which is a felony or a
first degree misdemeanor?
Yes

No

XXX

If "Yes" what charges?


9

Rev. 100209-OGC

Date of Conviction:

Where convicted?

36a. Have you ever been sued by a client? If so, give particulars including name of client,
date suit filed, court, case number and disposition.
No.

36b. Has any lawsuit to your knowledge been filed alleging malpractice as a result of action or
inaction on your part?
No.

36c. Have you or your professional liability insurance carrier ever settled a claim against you
for professional malpractice? If so, give particulars, including the amounts involved.
No.

37a. Have you ever filed a personal petition in bankruptcy or has a petition in bankruptcy
been filed against you?
No.

37b. Have you ever owned more than 25% of the issued and outstanding shares or acted as
an officer or director of any corporation by which or against which a petition in

bankruptcy has been filed? If so, give name of corporation, your relationship to it and
date and caption of petition.
No.

38.

Have you ever been a party to a lawsuit either as a plaintiff or as a defendant? If so,
please supply the jurisdiction/county in which the lawsuit was filed, style, case number,
nature of the "lawsuit, whether you were Plaintiff or Defendant and its disposition.

In 1993 I was named in a foreclosure lawsuit (93-020125) as I was the tenant on the

property. In 2005,1 was one of six defendants when our properties were the_subject_of a
lawsuit based on a developer's attempt to keep us from selling (Margolis vs. Day by Day

Realty 04-11130). Both cases were in Broward. I was removed from the foreclosure
39.

judgment and the real estate case was voluntarily dismissed.


Has there ever been a finding of probable cause or other citation issued against you or

are you presently under investigation for a breach of ethics or unprofessional conduct by

any court, administrative agency, bar association, or other professional group. If so, give

the particulars.
No,
40.

To your knowledge within the last ten years, have any of your current or former co-

workers, subordinates, supervisors, customers or clients ever filed a formal complaint or


formal accusation of misconduct against you with any regulatory or investigatory agency,

or with your employer? If so, please state the date(s) of such formal complaint or formal
accusation(s), the'specific formal complaint or formal accusation(s)_mad_^ and the
background and resolution of such action(s). (Any complaint filed with JQC, refer to
32d(v).
No.
41.

Are you currently the subject of an investigation which could result in civil, administrative
10

Rev. 100209-OGC

If

or criminal action against you? If yes, please state the nature of the investigation, the

agency conducting the investigation and the expected completion date of the
investigation.
No.

42.

In the past ten years, have you been subject to or threatened with eviction proceedings?
If yes, please explain.
No.

43a. Have you filed all past tax returns as required by federal, state, local and other
government authorities?
No
D
Yes

If no, please explain.

n-.-.L-.".""-"

43b. Have you ever paid a tax penalty?


No
If yes, please explain what and why.
Yes D

43c. Has a tax lien ever been filed against you? If so, by whom, when, where and why?
No.

HONORS AND PUBLICATIONS:


44.

If you have published any books or articles, list them, giving citations and dates.
No.

45.

List any honors, prizes or awards you have received. Give dates.
No.

46.

List and describe any speeches or lectures you have given.

Adjunct Professor. Shepard Broad Law Center Nova University, Nova High School

"Poverty and the Law Symposium" 2012, panelist with Sr Helen preJean a^Death

Penalty Symposium 2014. I have given numerous lectures to the Public Defender's
Office on client relations, depositions, evidence, legal updates, trial practice and death
penalty cases.

47. Do you have a Martindale-Hubbell rating? Yes D If so, what is it?

No

PROFESSIONAL AND OTHER ACTIVITIES:

48a. List all bar associations and professional societies of which you are a member and give
the titles and dates of any office which you may have held in such groups and
committees to which you belonged.

Broward County Bar Association, B'Nai B'rith, Hispanic Bar, GLLN, TJ Reddick Bar,
Weston Bar, South Broward Bar, Broward County Women's Bar.

48b. List. in a fully Identifiable fashion, al! organizations, other than those identified in

response to question No. 48(a), of which you have been amember_since graduating

from law school, including the titles and dates of any offices which you have hetd in each
such organization.
1]

Rev. 100209-OGC

National Association of Criminal Defense Attorneys

48c. List your hobbies or other vocational interests.

My son, Harbordale School Association, Concerts, Kayaking, our rescue dogs, Cooking.
48d. Do you now or have you ever belonged to any club or organization that in practice or
policy restricts (or restricted during the time of your membership) its membership on the
basis of race, religion, national origin or sex? If so, detail the name and nature of the
club(s) or organizations), relevant policies and practices and whether you intend to

continue as a member if you are selected to ser^/e on the bench.


No.

48e. Describe any pro bono legal work you have done. Give dates.

For eleven years I was both the proi bono Guardlcln and Attomeyfor1^ ^un^' ^h^as

declared incapacitated in 2003. I provide pro bono work for client's families and those in
need in the community. I work with Essie (Big Mama) Reed, Terry Scott and others

helping with those who in need of help with child custody, injunction, child support, and

traffic issues on a pro bono basis. I have worked in expungement workshops in trying to

help people get their records sealed if they have met the requirements of Florida law.

SUPPLEMENTAL INFORMATION:

49a. Have you attended any continuing legal education programs during the past five years?
f so, in what substantive areas?

Death penalty, criminal law, ethics, and other issues.

49b. Have you taught any courses on law or lectured at bar association conferences, law

school forums, or continuing legal education programs? If so, in what substantive areas?
I taught at the School of Law at Nova Southeastern University in the areas of Trial
Advocacy, Psychology and Criminal Process, and Lawyer Skills and Values I worked in
the training division for Mr. Finkelstein. I taught trial advocacy to law_yers for the National
lnstitutute-of Trial Advocacy with Prof.'s Mark Dobson and Micheal Dale.

50.

Describe any additional education or other experience you have which could assist you
in holding judicial office.
Please see attached.

51. Explain the particular potential contribution you believe your selection would bring to this
position.
Please see attached.
52,

If you have previously submitted a questionnaire or application to this or any ther


judicial nominating commission, please give the name of the commission and the
approximate date of submission.

53.

I have applied twice before; when Judge's Cowart and Pollack retired.
Give any other information you feel would be helpful to the Commission in evaluating
your application.
Please See Attached.
12

Rev. 100209-OGC

Question 50 Describe any other experience you have which could assist you in holding this
office.

believe I have life experience which would help me see the difficulties that those who come
before the bench might face. I grew up during a time when being gay meant isolation at best
and criminal charges at worst, When I told my father that I was gay, his response was'Never
tell another person what you have just told me.' He said this to me because he loved me and
wanted to protect me. I spent many years hiding who I was. I was stalked and harassed, my
home was burglarized; but I never called the police for fear of being found out and losing my
job and license to practice law. Homophobia took a real toll on my personal life and my career.
I know what it is like to feel that I won't be heard. I would never do that to someone who came

before me. I will treat everyone with dignity and respect and make sure they know that the law
will be adhered to in my courtroom without regard for their status.
When I was 47 years old I resolved to realize my dream of being a mother. At the time it was
against the law for a gay person to adopt a child in Florida. I explored the option of
international adoption, and decided to adopt internationally, I went to Russia, alone, and met
my amazing son. I stayed there alone for a month and visited him all day, every day. I went to
Court and the Russian government approved my request. I went to the United States embassy
in Moscow with a toddler who did not understand me. t spent a week in Moscow with my bags,

my son, and my documents. We flew for 22 hours to come home to the United States. We
flew in to Houston and navigated through customs with my boy, our luggage and our
documents. When we got home to Fort Lauderdale, my son said his first English word to my
Dad; 'Papa/ In many ways, life began for me at 47. Many who come to court need
encouragement and hope, and to be told that good can come from trying. I think that I can
impart hope based on my experience, and encourage those who have obstacles to never, ever
I

give up.

Question 51. Explain the particular contribution your selection would bring to this position.
I have been practicing law for 30 years, but I have been a part of a family with a reverent
commitment to the law all of my life. My father, Bill Benson, practiced law for more than 53

years, until his 83rd birthday. People still stop me in the courthouse to tell me about his
generosity and dedication to the law, and to his clients. Dad would give generously of his time
to any lawyer that asked for help. I have tried to be that kind of lawyer as well.

have spent 30 years in the courthouse. I believe in the importance of role models. I learned
how to behave in court, and what was expected from attorneys, from my father, but also from

Judges Mowry, Nutarro, Zebedee Wright, and Fleet, to name a few, I think it is crucial that
young lawyers appear before Judges who have a deep respect for the rule of law and show that
the courtroom is a place of reverence. I will show up to court every day, on time, with a calm
and measured demeanor that reveals my family's deep commitment to following the law in
service to others in general, and to Broward in particular.

Q.uestion 53. Give any other information you feel would be helpful to the Commission in
evaluating your application.

believe that an attorney is not given the privilege to practice law, but instead promises a deep
commitment to her clients, and the rule of law. I believe that this extends to the judiciary as
well. As a judge I would be committed to giving my time and attention to those who come

before me. I would be on time, listen carefully and diligently, and rule based on the evidence
before me, in accordance with the law, 1 believe that anything less is an affront to our system
of justice and to the people of Broward County. The Judges that I have been honored to appear
before have patiently and selflessly given their time and attention to all parties. I would strive
to do the same.

53.

Give any other information you feel would be helpful to the Commission in evaluating
your application,
please see attached.

REFERENCES:

List the names, addresses and telephone numbers of ten persons who are in a position
to comment on your qualifications for judicial position and of whom inquiry may be made
by the Commission.

54.

1. Hon. George Moraitis, 2132 East Oakland Park Blvd., Suite 2, Ft. Lauderdale, FL
33306 (954) 563-4163
2. Hon. Ron Rothschild 4501 Van Buren Street, Hollywood, FL 33021(954) 224-6729
th

3. Hon. John J. Murphy, Rm 940b, Broward County Courthouse 201 SE 6In St, FTL
33301 (954) 831-1648

4. Mr. William Teili 1218 S.E. 3rd Avenue, Fort Lauderdale FL 33316 (954) 525-2221
th

5. Hon. Jeffrey Levenson, Rm 6850, Broward County Courthouse, 201 SE 61" St., FTL
33301 (954)831-7817
th

6. Mrs. Essie Reed, Team of Life, 2136 NE 8In St., FTL, FL 33311, (954) 584-1400
th

7. Hon. Lisa Porter, Rm. 4760, Broward County Courthouse, 201 SE 6m St., FTL 33301
(954) 831-0601
8. Mr. David Di Pietro, Esq., David Di Pietro and Associates, Legacy Bank Bldg., 12 SE
th
7In
Street, Suite 606, Ft. Lauderdale, FL 33301 (954) 712-3070
th

9. Hon. Kal Evans, Rm. 331, Broward County Courthosue, 201 SE 6In St., FTL 33301
(954)831-6713
10. Mr. Ben Baldanza, President, Spirit Airlines, Miramar, FL (954)494-2816

Rev. 100209-OGC

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6 M&dicare lax wUhheid

84,991,50

1,232.38

Tallahassee, Florida 32399-0356

Aft4*fr.

iv^ftjc^-m^W.^Mfmf^it

4.

7 ScciaE securiiy tips

j^,0. ConlTis numbar


fi

flw^i!Hrf K^A-*feww-ti--

v/iVf.'y.

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Vnf

10 Dependent csre SeneSts

WvA^vWWwMCv

11 Nunquaiified plans

t.iUrijU^O^.^Wiwrt^.v^*--^

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ww^y*

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^

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Lfe

*MUWA'A'

RsLisTsment

smployee

B
fs

.^S5. is

r
^.ft^fi-

X<^fr^*(^*/.-rfw^w W^J^^W.y^

1ZB

Srd-Psrty
sicis. pay

plan

:ww^

3,000.00

'.-^-f-

13 Statutory

E. Empioyes's first name. mi, and E^^ nama

^^-Artft

12A See instructtons for b3K 12

012032 01/07

-^

DD

14,920.08

LL

^. ^W^K

^^ff^^^W^^^'^w^^'^^-^VS^^wi

14 Other

12C

HELEN E BENSON

?
t

393.26

125

*npDn *rt*^JXWW^'AfrLA^K^Sw^wATWypw^lr

12D
t

A^

-t^

F Em&!oyae's address snd zip cods


^...K-'.-^-^'-ft'

VWCK

15 Siatg Ef^Fioye''s state ID numbsr

c
"C^^Lfr

16 SUsie wages, tips; slc| 17 Slfilfl income iax

18 l.ocai weges, bps.eie

fit Lo^~i

^
m
'^Jt
sy^sa, Jy St."
3-4
20 Lc^ t/ name
>*L

ico y ia?

j
<fl\- VK^-^-X-X

-m'-^-a^-.HAiSAhitteSSW^H-^AS -AA<^u^u---M*^vflA^^Mj^rif^^^uAd^^^_c^^^^:Ai

FORM W-2

WAGE AND TAX


STATEMENT

Copy C - For EMPLOYEE'S RECORDS


n/>227W .'-<....., 03-'0"20i2

^yWS^V: .J^^-_-^J^_^_-^f_s^v_ff

2012

'.^vvoS^f

3s.

^tw

fimww^

A ^AtA^,

I-T-T.

0S No '545.0008

Oepartmant of the Treasury - Intsmai Rsvenue San/ice


This mfcrmation is being furTitshQ^i to thsi iniomai Ryvynue Sar^ice. if ynu ara r'uquired ii; f"Q a la^ retun. B
n&yiiyenco ponai'iy ar otf^er san=t:on may be ImposecS on you H yiis Inconia is La?'abte and yuu <3>! to '-apart rt

V.y, ;? .^ .^

"r^h- K^K X ^.^..tW-St-'WW.:^

.w-

rfWfl^K^

y^ffVfy^ :-h;

-m^tf^-a

^.^s^

fSt*y.VV'^~^J^^^^VWV'-'^*'~JV^V-

AitiWf

A>-rJ^

inlradepBrtn-'ohi number

.-

0000000000

21-60-17-03-000

^ -rf^.

K:<*v:-i

-y

2 PtiQi^sE incoms ttix wft^iaid

Wagoss, Ups, olher con'pensatior

b Emptoyer fttentfttcalion nymtaer


59-6001874

9,931.44

67,334.21

au^v.fr ^ffwfjv^^w^w^-^^w

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V&MSAA-

j c Employers na^e. acirtress, ana ZIP coOe

J 4 Social sscurity lax wiihh&id

Soc'iaS security wages

5,446.28

87.843.23
?

State of Florida

Jeff ANater, Chief Financial Officer

(.
j(

-ff

^ft

'Y^um'MuV-':;--,
WK

:-'va6^--:^rf.W-;-ffi^-il'A-W-'<.:)tf:ide^.A^-;;<'^<J.LW'>^i^?:r^JJSnWft--J*-^]*-tJ^-x^:<^.ft'K-^

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-V

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plan

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sic^ p@y

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RaElrefTient

13 Statutory
smpioyee
n

17,850.00

."!:

yS

j^y

15,606.48

DD
f

WWWS^fS^.f^Sr

jE
f

-I

<bs

Sse inslructiuns for box 1 2

1!a

fVS'S^ft.

.ifr-^W?-J,'-^JMOOtW^4^^'
g

-I

10 Dep&ndenl care benehts

011919 01/07
i/W^fft^:-fZv^^-----.Vff.Mf^>-

.Vf'i^^v

tf-^w

11 Ncmquaftfisd pians

d Coniroi nuTiber
^

^^E

Social securiti/ 'ips

1,273.73

87,843.23

Tallahassee, Florida 32399-0356

^L

8 Medicare tax w'thhstd

MedicsrBwegos and tips

200 E Gaines Street

iSSflK^'B

^.w/-A*vh*W^T

Kflh

"iK'V^y.

I 1I?1~
12c

14 Other

HELEN E BENSON

791.52

125

?6W?KWWrf*W-

^^

W/L

12d

!..-"".

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<

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v^yy yw J--Ji*-fr

rw^

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v>

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-^sv^

/fw t

17 Stata income tax

16 Stale wages, Bps, Me,

^mt^y^"^ li^lH'm)nbor

15'51 ata

20 Loca'fty rsarne

IS. Local wsges, lips, etc, | .t9 Local income Luc

^
t

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/f* -V

FORMW-2

.^^Hf:4f *<*i**-^/u^*

fl.

ff ~9tSSSVVW'SSA^H

WAGE AND TAX


STATEMENT

-!

Jfcnuit

OhtB ^'B

545-0206

Department of ihe Treasury - Internal Revenue Service

Copy B - To Be f'tod With Emptoyss's FEDERAL Tax Return


Tbit. Infr'rmahon I'! Ofcing fnrris'Toa to the Inlsrnal Revenue Service
-1^"

^M^t.Mt^.Sv^^vlv

<*-*

w^JKn

vh^t

^
r

^t<^-A^",?-w

^*^-

0000000000

21-60-17-03-000
V .ftSWSKMWMfr^*:

B-ft^'ft^

2 Fecisrat incoms iax withheld

Wages, tips, other compsnsation

9,931.44

67,334.21

59-6001874

J3

c EmployB?sn.arne, i^rsss, and gJP cods

State of Florida

Jeff Atwater, Chief Financial Officer

KWfrWfl

:tirA -Jkfr:

y??AW?Tt

Social security wages

5,446.28
mw>--"fr

^S^fW^fSKWWss.w-th-aAiiiHmt

-ft

Jft

^"Wft-s

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v

HELEN E 8ENSON

^t'^^'d't^r
^K^WW^.-'-'Awwy

791.52

125

V.

.A.

15,606.48

DD

-1-:

14 0 er
.^

^ft

.I

12b

Third-Purty
glcit pay

empicyos

17,850.00

-;

,fn-m^

VM^,

Retjremenf

13 SLstLjlory

6n''p!oyes's firsl fia)T1&, mi, ynd 1@il na?Tia

?
^
-^

Sse instructions for box 1 2

123

yxw^^AWttr.

,i-

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twr^^iW

I 16 Dependent care bsneiris

rf;<-^ ^WS'WitfWW^-^^

^fxv^s^w^^^f'

'^

1,273.73

7 Saciei secunty tips


v

;..:T.-u*i

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Medicare fax withheid

G
^^AvWy.

-^

.wwv

rfw

1-t Konquaisfisd pfans

^f<m>m^vwv,fKwwfviAF^~r''y^v' A^"MW

Sorisi security tax withhsid

87,843.23

01191-9 0'1/07

s;

Siit-MWiSftA .wv

.n

87,843.23

d Cor'ir^ nu'nbar
^

5 Medicare wages and tips

200 E Gaines Street


Tailahassee, .Florida 32399-0356
.^SW^<UW-^' wwr'w/^w

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^r:

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PayrDl! orgartfzalioh code


ff-J

b ErnpEoyer ktonEification mimbar

j<

^frrfKih

/Mwft,,^

frfl

^ggtojge^ggjiyggjrtj^mber

^KF

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^^fAjwj-K-^.v^jwwyyw

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.^
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fffKWf

I
'ff

f ^mpiay&e's sddress ar^d 21P cede


-^--i~v'^'~iv:VJ'w-WWJ-~J^'Mvfl^:WMlw
t ISSIalo
Empi&yer's 'slatfl iD number
li

WWA'?i?? TfrK-''y'<-*Sfr

..-.fWwmmwKwyy^Wf^.'*

.S'ilU-JWWW^

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I 16 Ststs wages, tips, etc.

vff*'W

jv

v"r ^K<

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18 Local ncome tax

18 Local wages. !?ps, elr

-17 State incams 133;

2..<<-* SA ^
20 Locaht, narne

.h^.

^
-^.-

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Jf-. JlM^.if^wXr.S^'K jS'.'-'^Si; ^M^.^'ri^

-2
FORMw

A^f.

^
^

L.

WAGE AND TAX


STATEMENT

Copy C - For EMPLOYEE'S RECORDS


fW2~/W Rev. Q3/21,'2013

-^
f

^
If

^
sr--/<w-^T

2013

vV: ^K/K

OF/B No 1 S45-OCOS

Departmant of the Treasury - Internal Revenue Service

This information is being furnished to the Internal Revenue Ssrvlce I' you are required to file a tax return, a
negligence penalty or other ganclion may be imposed on you if this income is taxable and you fail to report it.

'^{siilIs5Si5Bi2]E5

ni.mb&r

v.w^f.
yfM'l^f-T^Hf^ff^Wwy^w^wyMWUKWK^W^f^f

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atfi - i^'fffQV- ..^f.V^-.-^vWV^ft-h .t/f^-Sbh';-^ ^^f.t-v.'^V.T-f^vfV^H^'^'f'^WVTy

p^sri Q?^^1zEiiiST"^BeTTMWKMTiw
i 21-60-17-03-000

Jj*.M^.

Vt

in'r^depsrtm&nl num&Br

0000000000

^
W^"'W"L

m^'JK ^n

^ww>.

i'naio

^f

13,230.16

83,595.68

59-6001874
Av^. L"U MW '^' ff- ^A

2 Federai incoms tax wit.hhsid

Wsgss, tips, olhsr ccmpsnsaUon

b mpEuy9f ictaniificaticn nunrtbfir


"0 B cT -w < ^T^-^---?-**!~-:L-^A.

'^r^ff^l^'ff.

^t'.riv.

4 &3C&31 s&cunty ta^: v^iiih^d

3 Social security wages

s n@ffln, sddress, snri -^iP cody

5,728.94

92,402.20

State of Florida

i
y

Jeff Atwater, Chief Financial Officer

S Medicare wages an0 tips

Tallahassee, Florida 32399-0356


-^....KLU-^-^MAM..^^.^^^-^^^^ A-

i; / *l JI<u*;'K-:''-ri. :;^-:^ S^---:-:-A-*^JU^'^'^.-^'

F^^

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f.

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tf

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;c:A:Aa ^^w^

v^W^-

012119 01/07

fl

6,000.00
-V^fM^K^-^-'-:f-^f--

R&^m^nt Tlwd-Pany
s(ck pay
pian

13 Slaftitory
employee

e ^-f i?i j<'i>p ^ firo* m'n^ r i, &fi<J ^3E nsme

-ii-S/A^S.^

I 12<;

140ltiu

^^-.-j'/s-.wsw-wwwwy.

wewn^Hfc^v^fywym^ KB??

1,149.24

^Wmt.^^WW^-Wt

12d

f^fr

'TOHW ?rtt*rt<<ff'K'K

AIC^I

ff

.jwi "rs 'USP in n-nit

Idll.

rft

{.

* ^,.~"-

^ y fv
4
^ ^

'>&.".

J(*n

W(fr

*^.

17 Slats income lay pSLocaf A/agsa.fips, etc. ^ IS Local HLOW tax

16Slalewagas.lips.ete.

i"

>

12e

IS

v X.

!j

wif '*fy

f Fmp'CvQ^ $ i3tl^jf> ^ S^ Z)p U3dlS

*.

17,248.88

OD

HELEN E BENSON

-i-.A-

.^w

12b

.^^"^.iv

125

-BA^. uv

..

12a See inslrucl'ionsfcrbox 12

ww^-t-w-^^w.w

^y<^Wff-^w^~.V.JWyy.^.^tr^.^ '.K^SMiB3!?^WflnW^^^' -^

-AAu

-^t.wx.^w^'^'.^y^^,^^.

10 Oependenl care benefits

It1 NunquaiifiBd plans

AI( fctwx^eWitci.W^'HvVvW.vW^f'w1

A':^ ^fw^^

^fr

I 7 Soddi sscurity tips

Controi "Lmbsr

It

1,339.83

B MeO'scare tax wilhhe'id

92,402.20

200 E Gaines Street

TW-T4:

^p

A*?

)>-^'

-.J

20 Locsitty nams

jt

^
flft

^k

v v tftMC

*<

W-2
FORM

vV V

VWft w

.vW

.A

<CkJ<

-v&

/r

2014

WAGE AND TAX


STATEMENT

J>*<

O^SNf; i&;S.300fi

Department of the Treasury - Internal Revenue Service

Copy B . To Be FHad With Emptoyee's FEDERAL Tax Return

This infomialun <s hnng tuiT'isftsd to the Internal Revenue Sep/fae


Jftr^h

.k^.^r.

;flr

^ft^w^^MV

^v 1^A

'fhw

.a'

Er

.V- '^^V^^P^Y^.^

Intraclepsrtment number

0000000000

; 21-60-17-03-000

IwWw

*aSfi;-^w^WW^ Spti^^'.SKJsfr?S?'^fr'*^-*'^wrS&^fi*^rt*'-6(F^Ai.rt.rfy^W3alffii

b Emptoygr kjentiftcation number


59-6001874

1 Wages, tips, other compen$ation

F&dsrsl income tax wiyiheld

-^..?^?^S^SBAV?S3Sfc^^^.'^^?!!B?^LWff%5? ??w?wq^^.^^fl^^

vn

TSw Ai^^P

fs^/fi-

^3 SociaTse&jintywBgas
s

State of Florida

i-. ,

S:--^bW^^w...:^^

^MfftWfMr

:^WA:-^;-W-^

* 5 M&dicare wages and tips

200 E Gaines Street

^'W^&KU^WBk.-^MWtoftffi.Ayfiik^jWft?*:?^

r7

<-A^wAA|

*^

yVH^r^-^-t-^f^f-^

'.h Wvwv.

f^

."Wft-iJ

6 M&ciicare tax Withh&ict

1,339.83

92,402.20

Taliahassee, Florida 32399-0356

./t

Soda! s&curity tax wilhhsfrf

5,728.94

^v^W^SiSW^V^X^^^.^P^ .-f.Wf.-f-A^^^-- *? ^:: :-.<

Jeff Atwater, Chief Financial Officer

^KKfi^

92,402.20

<

5 I

13,230.16

83,595.68

I c Empioyef's nsms, acdress, and 2lPcoEl8

SKWXCWSKy^

^t'^^W^K-X^S^SKWy^.t^t^fWfWWff^^SS^^-^Wt.

.VWWWW^Wfaf/WMf:

Payroll organization cooe

nj.;io^S8^soaa^9cur:t^ujmber

.E
W : -K^?^b&-rf-AC;^x<>-<-.HfiKWK*-?-

y'''

^^WSS-^^SS^t "K3~E*t^

.T'U^Srt

^
-Wr-.^-h.'^

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10 Doperdenfc care bynefils

Social security Ups

s
^

.^

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v^

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.".f.^t*.?-.-^

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pian

At^

^^V^M'^(^Mwf.WwtrWf^^V^JWr^<^MI^Wf*y:<L

RE>!JrerT->eiC

13 Statutory
si-+ pkiyse

Efnpiuyiiii's f;;9i fctms, :mt, 3;E'!tf !*t5} "sme

Tf.ird-Party
3)0^ pay

SEA

^.---;nk-vyTLI -^*

-sr :-.<-BM^W-,

See inslruciions for box 12

6,000.00

012119 01/07

<

^.

12B

11 No .^uaiiHed plans

d Control numbef

il
ft

~1

.^ y

.1 12B

17,248.88

DD

^
?

.14 Olrer

12c

HELEN E BENSON

125

1,149.24

A'-.MfrW^

-yvW

J_

^^W^.WM.^.

12d
Wf.

.fw wt

12B

<y
^
^

f Employee's address and ZIP code

^-

*-;^ri*Kr3^.Jh

^^^u^v^.

-K

-w-sW?

16 S'^te wag&s, fspa. etc

Empb.'sr's slats ED number

15 State

.i
'WiW/MiV^^Stf.

-3Vi 'sx

^.K.Wf^-.^-:

K:

.w

13 Lacal wages, tips, sic.

17 Sta^i iri&'jfftg Uix

:-AI:-^'^"3K1

-'A.-SE:s&2?&y<-y,3ffrf.;--*.F' * i.
13 Lees' incumg tax

20 Locality nsrne

.i

.f

-^ .V-/*^W.<-M

^.:*AA-i

_),,."..,.._ _

< fr

*^I

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W-2
FORM

w.w ^'^'^-SVFfS^sv.^vfVf: .MV

,?->,.+^-?- WW^-'m.MvW*

VWWMWWW- wf^jSv^WSWWfV

WAGE AND TAX


STATEMENT

Copy C - For EMPLOYEE'S RECORDS


AA427W Rev. 0-'/2;;2014

MtA-

^ ^v-ff^ .yS. .WijW'y^^^pwW .;^.

.fy^f^V^- .VVt'

0MB Kc,1Iy5C-008

Department of the Treasury - internal Revenue Ssrvice

This ^nformstion is being furnished to the intema! Revenue Sen/icG. Ef you are requifed tc flte a tax return, a
negligGnc-e penaEty or other sgnction may be Ernposed on you if this Incofne EK ta.xabls and you faii TO report it

FORM 6

FULL AND PUBLIC


DISCLOSURE OF
FINANCIAL INTEREST
PART A-NET WORTH

Please enter the value of your net worth as of December 31 or a more current date, [Note; Net worth is not calculated
by'subtracting your reported liabilities from your reported assets, so please see the instructions on page 3.]
My net worth as of 12/31, 20U was $509AQO.
PART B - ASSETS

HOUSEHOLD GOODS AND PERSONAL EFFECTS:

Household goods and personal effects may be reported in a lump sum if their aggregate value exceeds$1,000 This
category includes any of the following, if not held for i"vestmentPurPoses'.Jewelry^G^llecti^J3.f,stamPs^gun^rld
numtsmafcitems^rt objects; househofd equipment and: furnishings; clothing; other household items; and vehicles for
personal use.

The aggregate value of my household goods and personal effects (described above) is $ 633,000,
ASSETS INDIVIDUALLY VALUED AT OVER $1,000:
DESCRIPTION OF ASSET (specific description Is required - see instructions p. 3)

VALUE OF ASSET

5,000.

1999 JeepWrangler

-M<A

350,000.
f'/f^M^mw^^^vf?"^

169,000

Deferred Compensation Account

27,000.

Florida Prepaid College Fund (ITF Bond Benson)


fl^wwm^-M

88,000.

Savings

PART C - LIABILITIES
LIABILITIES IN EXCESS OF $1,000 (See instructions on page 4):

NAME AND ADDRESS OF CREDITOR

Third Federal Savings 7007 Broadway Avenue, Cleveland OH 44105

AMOUNT OF LIABILITY
A. .v^ .-AW

-ru.' V^

130,000

.wnw

^UAW.

.-^-.-^-

AMOUNT OF LIABILITY

JOINT AND SEVERAL LIABILITIES NOT REPORTED ABOVE:


NAME AND ADDRESS OF CREDITOR

fl

15

Rev, 062414-OGC

PART D - INCOME

You may EITHER (1) file a complete copy of your latest federal income tax return includtng all W^s, schedlites'and
attack, -OR (2) file a sworn statement identifying each separate source and amount of income which exceeds
$1,000 including secondary sources of income, by completing the remainder of Part D, below
elect to file a copy of my latest federal income tax return and all W2's, schedules, and attachments.

(if you check this box and attach a copy of your latest tax return, you need not complete the remainder of Part D.
PRIMARY SOURCE OF INCOME (See instructions on page 5):

ADDRESS OF SOURCE OF INCOME


NAME OF SOURCE OF INCOME EXCEEDING $1,000

AMOUNT

Am

.fjrw

^riwAW^I

SECONDARY SOURCES OF INCOME [Major customers, clients, etc., of businesses owned by reporting person-see instructions on page 6]
NAME OF

BUSINESS ENTITY

PRINCIPAL BUSINESS
ACTfVn"Y OF SOURCE

ADDRESS

NAME OF MAJOR SOURCES


OF BUSIENSS' INCOME

OF SOURCE

;V-^-J\^^T^VHy//.---AJ/--J^^^

-M<

<m\w.w. fwmv.v,-,

'W-V^VW\W ~^^'

PART E - INTERESTS IN SPECIFIC BUSINESS [Instructions on page 7]


BUSINESS ENTITY #2

BUSINESS ENTITY #1

BUSINESS ENTITY #3

^w

NAME OF BUSINESS ENTTITY 2-4theshow.org

^TMfMW^MV.
.-r'.'TW

ADDRESS OF BUSINESS ENTITY


my house
.vwv,

f"W1f*

.V-

PRINCIPAL BUSINESS ACTIVIPl'

nonprofit

POSITION HELD WITH ENTITY Co-Founder


I OWN MORE THAN A 5%
INTEREST IN THE BUSINESS

no income - non profit 50%

-M^L^rtAAA^

We held kids attend shows

NATURE OF MY

OWNERSHIP INTEREST

^^^%i^^^

sna a

IF ANY OF PARTS A THROUGH E ARE CONTINUED ON A SEPARATE SHEET, PLEASE CHECK HERE
s

OATH

, the person whose name appears at the beginning


of this form, do depose on oath or affirmation and
say that the information disclosed on this form and
any attachments hereto is true, accurate, and

STATE OF FLORIDA
COUNTY OF Broward

Sworn to (or affirmed) and subscribed before me this


of Oct, 2015 by Betsy Benson

complete.

(Signature of Notary Public-State of Florida)


(Print, Type, or Stamp Commissioned Name of Notary Public)
Personally Known
SIGNATURE

Type of Identification Produced Ft PL #8525-385-59-670

16
Rev. 062414-OGC

OR Produced Identification xxx

day

.i

DIANA J. WHITELOCKE, P.A.


2640 HOLLYWOOD BLVD., #201
HOLLYWOOD, FL 33020
(954) 925-9989
April 6, 2015
HELEN E. BENSON

Dear Betsy,
Your 2014 Federal Individual Income Tax return will be electronically filed with the Internal

Revenue Service upon receipt of a signed Form 8879 - IRS e-file Signature Authorization. No
tax is payable with the filing of this return. The refund of $3,761 will be directly deposited into
your checking account.

Under the Affordable Care Act, you and each member of your household had either health
coverage or an exemption for each month during 2014. No individual shared responsibility
payment is due with the filing of this return.
Please be sure to call if you have any questions.
Sincerely,

Diana J. Whitelocke

T-f""".

0MB No. 15ii5.007'i

iRS e-fi!e Signature Authorization

Form8879

.. Do not send to the IRS. This is not a tax return.


.

DepMimen! of t^e TfcT^ury

>

intsjn^l Revsnue Servtce

Submission Identification Number (SID)

Keep this form for your records.

Information about Form 8879 and its instructions is at www.irs.gov/form8879.

^
Social security number

Tsxpgty&f's name

***_**_****

HELEN E. BENSON

Spouse's social security number

SpQuy^'S name

Part

Tax Return {nfonrsation - Tax Year Ending Deeemberjtl, 2014 (Whole Dollars^pnly)
Adfuiied gross incomeTForm 1040. line 38;'Fom:Tf64.0A,iineS2; Form 1040EZ, line 4).
2

83,612.
9, 469.

13,230.

i^jsk.

/.

2
3
4
5

Total tax (Form 1040, line 63; Form 1040A, line 39; Form W40EZ, line 12)
Federal income tax withheld (Form 1040, line 64; Form 1040A, line 40; Form 1040EZ, line 7)..
Refund (Form 1040, line 76a; Form 1040A, line 48a; Form 1040EZ, line 13a; Form 1G40-SS, Part 1, line 13a> ...
Amount you owe (Form 1040, line 78; Form 1040A, line 50; Form 1040EZ, iine 14)..,.,...... ..,".

>

Part H [Taxpayer Declaration and Signature Authorization (Be sure you get and keep a copy of your return)

Under'penalties of perjury, ldBclareMlhavee^affllne^a^y^I7e1^

December 31,2014, and to the tet of my knowledge and belief Jt is true correct
^ome'ta/reum.'i consent to atowr^nterm^ate service pmider, transmittw, or electronic return originator (ERO) to send my return to the IRS and to receive from theiRS(a)m
^o;^^'of^pt.^n..^of.e^^s,on^)..T^a^l^^^^^^^t^^^^
auttor^elea^ Treasu^'and itedesign^Firiancial Agent to initiate an ACH electronic funds witharawal (diTertdeUt;ierrtiy_totnefmanaalmstit^n^ountjncicate^m e tax
OTparationsoitwarefor^yment'ofmyWeral taxes owed on this return and/o^ payment of estimated tax,^ndthe_finanda! Mution So_deb;t theentr^to {^ "ccountjte
S^sTremam In' viforce'and'effect'untiU'notifythe'U.S. Treasury Financial Agent to terminate'the authorization. To revoke (cancel) a payment, I must contact the U.&

^^nnaiicialAgent'atl'is^^T:;^^ cancellation request^ mustberec^noj^tha^bus^sd^pno^^payment^


financial inshtutionslnvolved mthe'processlngof the electronic payment of taxes to receive confidential information necessa^ So answer inq^r^and resoteissues rehtedto the

pament. Tfu-toacknowiedgethat te'perso^al identification number (PIN) below is my signature for my electronic income tax return and, if applicable, my Electronic Funds
Withdrawal Consent.

Taxpayer's PIN; check one box only


to enter or generate my PIN

XJ I authorize Diana J. Whitelqcke_,_P.A.

25495
Enter five digits, but do

ERO finn name

not enter all zeros

as my signature on my tax year 2014 electronically filed income tax return.

Q^^i^^^^^^^ij^u^^^^^^^T^^i^^^^^ji^^^^^^i^rp^'^l<^^box onlyif you are entering your


Your signsture

Date .

----...-

4/06/2015

Spouse's PIN: check one box only


to enter or generate my PIN

Jj I authorize

Enter five digits, but do

ERO Hrm name

not enter all zeros

as my signature on rny tax year 2014 electronically filed income tax return.

D
I] L.wlJi^teL^'y,f.!?^tTJ;^i?;[LaJ'J^i^i^!te^Jt?)?L^or1^i^l^^a^il^An^?pt^^^^^
only if you
own'P^nd'you^ur^s'fned'using'the pradi^ner PIN method T^eERO must comptets
Partare
111enterin9
below. yc"Jr
Spouses stgnature

Daie &-

Practitioner PIN Method Returns Only - continue below


Part Hi

Certification and Authentication

Practitioner PIN Method Only

j^." m-^^^^-^--^

60246011226

ERO's EFIH/PiN. Enter your six-digit EFIN followed by your five-digit sel'-selected PIN.

Do not enter all zeros

;=esas ss, Kss^^sssss&^s-^ss' f[ .he

certify Shal the above


Saxpayeits) !nciicated_above

mdPublication'134^ Handbook for" Aulhonzed IRS e-Ate Providers of Individual Income Tax Returns.
ERO's sajnstw

Da'.e

V"

>-

4/06/2015

ERO Must Retain This Form - See Instructions


Do Not Submit This Form to the IRS Unless Requested To Do So
01

BAA For Paperwork Reduction Act Notice, see your tax return instructions
rDIA 17011

3.;29.'11

i 8879 (201 A)

Form

(99)

internai Revenue Service

DepaiU'nent of Ihc Treasury

1040

U.S. Individual Income Tax Return

0MB No 1545.0074!RS Use Only

, 2014, ending

For the yrai Jan 1 . Dec 3!, 2014, or other tax year b^mning

Your social security nun-sbar

Last n^Ene

Yoy? H??t name ^n! imli^^

Do not wfite or stspK? in this space

See separate instructions.

,20

**.*-**-.*.**.*

HELEN E. BENSON

Spouse's social security number

lat>t name

t 3 join? return, spousfc's first name and ntit^.1

Apartment no

Hofns address (number srtd stre^Q, \t you have a P.O. box, see ;nslruct!ons

- --

ciiy.lowr ' P"sS ofliCe, sia(e,3nd ZIP code " you ha-;e a ioreign address, also comBlcle spaces below (see instructions),

and on line 6c are correct.

Presidential Election Campaign

Check here if you, or your spouse if filing


(OinUy, want $3 to yo to ihi5 fund Checking

FT. LAUDERDALE, FL 33334


Foreion poslai code

Foreign {'K'Eiyin&efetgiWc&oNy

FoTeiyn c&rntfy ^amc

Make sure the SSN(s) above

a box below will not change your tax or


reEunci

Single

Filing Status
Check only

Married filing jolntiy (even i? only one had income)

Married filing separately. Enter spouse's SSN above & full


name here..

one box.

6a

Exemptions

b
c

Q Qualifying widow(e7)~with dependent child

instructions,) if the qualifying p&rsan is a child


but not your dependent, enter this child's
1

name here .

B-

Xj Yourself. If someone can claim you as a dependent, do not check box 6a., ........
(2) Depencfenl's
social securiiy

(4)</

(3)De)K!n<tert's
relalJonship

number

t7

with you

ir,, fur
<]i|,ili{,-;iK)

to you

LillltJ'td
c
(^&ti iPSl?S)

t^U^tft-dtVQrcp

SON

or sepftr^tion
(see Jn&trs)t>
DdfMsndents

f more than four

dependents, see
instructions and
check her&..

>.

Income

Attach Form(s)
W-2 here. Also
attach Forms
W-2G and 1099-R
if tax was withheld.

f you did not


get a W-2,

see instructions.

^.tnAn,

Add numbers

on lines

r^"^w

d Total number of exemptionsjslajmed


7 Wages, salaries, tips, etc. Attach Form(s) W-2..

above

<

b Tax-exempt interest. Do not include on line 8a ......,.,.... |_8b


9 a Ordinary dividends. Attach Schedule B if required.
b Qualified dividends .................... .....,,.....-...... |__^b

83,596.

7
8a

8 a Taxable interest. Attach Schedule B if required.

16,

9a

f,

10

10 Taxable refunds, credits, or offsets of state and local income taxes. >...
11 Alimony received
12 Business income or (loss), Attach Schedule C or C-EZ,..
13 Capital gain or (loss), Att Sch D if read. If not reqd, ck here
14 Other gains or (losses). Attach Form 4797..

11

<F

12
i>-

13
14

1C

15 a IRA disii'ibutions.
16 a Pensions and annuities .

?.

15b

b Taxable amount
b Taxable amount

15a
16a

16b
17
18

17 Rental real estate, royalties, partnerships, S corporations, trusts, etc. Attach Schedule E
18 Farm income or (loss). Attach Schedule F
19 Unemployment compensation.
20 a Socia! secuntv benefits
21

19

_J b Taxable amount

20a

Gross

Combine the amounts in the far right column for lines 7 Itu'ougM 2!. This is your total mcome
23
23 Educator expenses
24 Certain business expenses of rescrwsSs, performing artists, and 'ee-basis
24
government officials. Attach Form ?10G or 2106-EZ

Income

25 Health savings account deduction. Attach Form 8889..

25

26 Moving expenses. Attach Form 3903,


27 Deductible part of seif-emp'oyment tax. Attach Scheduie SE ......
28 Self-employed SEP, SIMPLE, and qualified plans..
29 Se'f-employed health insuiance deduction
30 Penalty on early withdrawal of savings.

26

31 a Alimony paid b Recipient's SSN


32

.J^.-.'

f-

21
22

'<.:.

;;

27

unt^ T .UJUJti^JWJCOCO^J^^^--"

8lL612..1

:;:.

28
29

.;-;

30

:-.

-r

31 a

>

:-:

IRA deduction

33 Student ioan interest deduction.


34
ui'iion and fees. Attach Form 8917
35 Domestic production actwties deductior. Attach Form
36

20 b

Other income

22

Adjusted

on .6e not
entered aboue

W^SWM-W^

ww

did not

live with you

f7n

***_**_****

%Iroad

thit<! ur<!fyr

Last name

(1) First name

Bas&S checked
on 6^iEt9ri6h . .
^o of chUdren
on 6c who

Spouse,

Dependents:

["[Spouse

Xi You

}(j Head: of household (with quaiiSying^persony (See

8903

32
33
34
35

Add lines 23 throjqh 35

37 Subtract line 36 from line 22. This is your adjusted gross income

BAA For DTsdosure, Privacy Act.andlPaperwork Reduction Act Notice, see separate instructions.

>.

D1A01I2L

36

0.

37

83,612.

12'^9;

F' .^

i"T

040 (2014)

Form 1040(2014)

.^^ * - A-Ttr "*.*.*.*

HELEN E. BENSON
38

Tax and

Credits

a Blind.-l_

Total boxes

,.|JSpouse was born before January 2, 1950. U Blind. J checked

If:

b if your spouse itemizes on a separate return or you were a dual'status alien, check here
40 Itemized deductions (from Schedule A) or your standard deduction (see left margin)

Standard
Deduction
for

>

39 a

39 b

R
42 Exemptions. If line 38 is $152,525 or less, multiple $3,950 by the number on line 6d. Otherwise, see instrs .
43 Taxable income. Subtract line 42 from line 41.

39b or who can


be claimed as a

dependent, see

If line 42 is more 'nan line 41, enter -0-. ...


44 Tax (see instrs). Check if any from:

a DFOrm(s) 8814

45 Alternative minimum tax (see instructions). Attach Form 6251


46 Excess advance premium tax credit repayment. Attach Form 8962

Single or
Married filing

47 Add lines 44, 45 and 46

52

Head of

54 Other crs from Form:

49

n 380C b D8801

51
52

550,

53

54
h-

<

60 a
60 b

61
62
I*-

<..?

66 a Earned income credit (E1C),

66a

Payments
^youh^a 1_65 20i4 estlmated tax Payments and amou"t aPP'ied frOT 20'3 returil

<1

66 b

67 Additional child tax credit. Attach Schedule 8812 .......,,

67

68

68

American opportunity credit from Form 8863, line 8..

69 Net premium (ax credit. Attach Form 8962


70 Amount paid with request for extension to file

69
70

71 Excess social security and tier 1 R;=(TA tax withheld

71

-^-^,

Is Attach Foirn^.136

"a

Reserved c

Reserved d

72
73

>

74 Add Ins W, 65, 65a, & 67 73 These are w total pmts


75 "i !ine 74 is more than lire 63 subtract Ine 6"' froTi line 74 This is 'he amount you overpaid

Refund

9,469.

63

13,230.

&4
65

: a D'

9,469.

59

< 1;

64 Federal income tax withheld from Forms W-2 and 1099

72 Credit for federal tax on !


73 Credits from Form
2^39 b

1,150.

56
58

8919., .. ...

63 Add !ines 56-62. This is yow total tax..

jfr"

55
57

Self-employment tax. Attach Schedule SE

b Nontaxable combat pay election...

10,619.

KW"

62 Taxes from: a Q Form: 8359 bQ Form 8960 c Q InsSrs; enter code(s)

Schedule EIC,

0.

600.

59 Additional tax on IRAs, other qualified retirement plans, etc. Attach Form 5329 if required . ",
60 a Household employment taxes from Schedule H
b First-time homebuyer credit repayment. Attach Form 5405 if required ...
61 Health care: individual responsibility (see instrucfons) Full-year coverage

child, atfach

10,619.

50

.<

58 Unrepo'ted social security and Medicare lax from Form: a |_14137

qualifying

44
45
46
.^"

56 Subtract line 55 from line 47. If line 55 is more than line 47, enter -0-..
57

64,822.,

47

55 Add lines 48 through 54. These are your total credits.

Other
Taxes

7,900,

43

iff^fwwmwmxrf?frrr"\

Child tax credit. Attach Schedule 8812, if required


53 Residential energy credits Attach Form 5695

household,
$9,100

42

48

50 Education credits from Form 8863, line 19..


51 Retirement savings contributions credit. Attach Form 8880..

widow(er),
$1 2,400

72,722,

:WWK

>.

Foreign tax credis. Attach Form 1116 if required


49 Credit (or child and dependent care expenses. Attach Form 2441

joint;;? or
Qualifying

48

separately
$6', 200
Married filing

10,890.

40
41

b I I Form 4972..

instructions.
All others;

83,612.

Subtract line 40 from line 38 .

8 People who
check any box
on line 39a or

Page 2

38

Amount fromiine 37 (adjusted gross income).


39 a Check
You were born before January 2,1950,

.*

74

13,230.

75

3.761.

76a Amount of line 75 you want refunded to you. If Form 8888 isattached, check here . *' [J]j 76 a

Direct deposit7

See instructions

>

b Rouung number

fr-

d Account number,

0531002 77 ] - c Type: JXJ Checking Q Savings


t>-

77

:-:.

78 Amount you owe. Subtract Hne 74 from line 63. For details on how to pay, see inslructians,,.

X| Yes. Complete below.


@

Do you want to allow another person to discuss this return with the IRS (see instructions)?.
Designee's
name

78

79

79 Estimated Sax penaIljLJSeej^tructJQnsL

Third Party
Designee

J!.

.;-;

77 _ Amount of line ?5 you want applied tn yoUF2B15;ed.im3te(l tax- __

Amount
You Owe

Phone >

Diana J. Whitelocke

nc.

Persons! [denti'ica^on

954-925-9989

nu-naer (PIN)

DNo
'--"-' ' ' . -'-"-^

Uncef penaUies of pe(;ufy> I declarG that i h^ve exarn:^ d Ihis fe[urn arid ac<;9mpany<ng schisdules <3nd staterTients, ano to iriO bc'sl o? rny i<,ncv.':edge ancj
be!ie?, ihey are tfue. correcl. snd ccrnplele. Deciaration oi yrepai'e? (oihef U";<;?^ ^stpayeO 'as bgs^ on a!i li'iiormation o? which p'epaier has sny knowledgs

Here

Date

Your signalure

^\

Joint return /
See insiruc'.ions

^ Spouse's SfgnaS-jre I? 3 j&int return, both must 13?.

Keep a copy
for your lecords

r',

L>aie

55928

>

^QQOFHJ^nuuau

Sign

'^fM

3 761.

Ji

Your occupation

Dayhm& phone nijmhf.'r

ATTORNEY

954-831-8413
f the IPS^senl you sn !den;K-,' '"-'ro

SpQUSS'S OCCUp^tOH

?">

cstion PIN, enler


it hgje (see .)isl's)

^v^^v^^vwrfv

Pnn[.'TyFe prt;py'erls na'ne

Paid

Preparer
Use Only
FOIAO'IEL

^1-^-L
12
^L9/14

FEf*yyTe:'s SKjnaiure

Diana J. Whitelocke
F irm's Fame
Fi'Tn's. address

ST

Diana J. Whitelocke, P.A.

&-

2640 Hollywood Blvd., #201


Hollywood, FL 33020

Dale

Cri&c"

^ei'r<-irip!oyf:c

Firm's EiN >


PK.'

PTIN

P00997553
65-0355928
925-9989
Form 1040 (2014)

(954)

2014
>-

Dcpari.'nenl of the^Jfc^wy

(99)

K'itc-rnai Revenue Se'iy^OK

0MB Nc 1545.0074

temized Deductions

SCHEDULE A
(Form 1040)

Information about Schedule A and its separate instructions is atwwiv./rs.gok//sc?iecfutea.

Attachment

Attach to Form 1040.

Sequence No

Na^w(s) shown on i~'o('m 'S 040

Yrour social security runnh&r

HELEN E. BENSQN
Caution. Do not include expenses reimbursed or paid by others
Medical

***_**-****

and
Dental

Expenses

Statement 2

Medical and dentai expenses (see instructions)

2,675.

83,612.

Enter amount from Form 1040, line 38....

3 iVlulnply ime 2 by 10% (.10$. But if either you w your spouse was born before

8,361.

January 2, '950, multiply line 2 by 7.5% (.075) instead


Subtract, line 3 from line 1. If line 3 is more than line 1 , enter -0-.
5 State and local (check only one box):

4
Taxes You
Paid

>

a Q Income taxes, or

b iXJGeneral sales taxes


6

Real estate taxes (see instructions)

Personal property taxes

,,Se.e..St.9 tenant..3

898.

2,670.

0.

3 568.

.I

8 Other faxes. List type and amount

07

t*w*(

8
<*ff

Add

.nMi

; .?.

through 8.
10 Home mtg interest and points reported to you on Fol'n
9

interest
You Paid

fv^f.

WA.

-. I . . L

ines c;
^^

See St 4 10

098

i^27.0_

Wv

11 Home mortgage interest not reported to you on Form 1098. Ispid to the person
from whom you bought the home, see instructions and show that person's name
i-

identifying number, and address


Note.

Your mortgage

-U-<ir. -hC* ATO^- --

.^mwSi

"-*-

.wu
1

interest
deduction may

v<-^

be limited (see
nstructions).

<M& *w^-

-)W*A ^^M- \-ff^

v<

^wh

^ouc **^

InK

/A^f/

n
fcnAI^

fvwji

*mA

r<N>

Aunt

12
13

12 Points not reported to you on Form 1098. See instrs for sod rules.
13 Mortgage insurance premiums (see instructions)
14 Investment interest. Attach Form 4952 if required.

14

(See mstrs.)
15

Gifts to
Charity
If you made a
gift and got a
benefit for it,
see instructions.

Add lines 10 through 14 .

16 Gtfts by ca 5h-or''checkHTyou"i"natte' a ny gift of $250 or


more, see

instrs ,.................. ,see .st.atement. .5

16

17 Otberthan by cash or check. If any gift of_$250_o[

19

982.

20

0.

ti

more, see instructions. You must attach Form 8283 if

/
/
>

17

over $500.... .

18

18 Carryover from prior year. ......,,..

Casuafty'irTd
Job Expenses

4,27 CL

982.

19 Add lines 16 through 18


Theft Losses

15
rf

20 Casualty or theft loss(es). Attach Form 4684. (See instructions.)


21 Unreimbursed employee expenses job travel, union dues,

and Certain

|ob education, etc'. Attach Form 2106 or 2106-EZ if

Miscellaneous
Deductions

required. (See instructions.)

.f.

]>
JVVJtti

.ft^^v

Form. 2106_ lTaxayer)_ __________ 3 ,_4_42,


22 Tax preparation fees
23 Olher expenses - investment, safe deposit box, etc. List

21

3,442.

22

300.

tfr-

lype and amount

J-H^

A^*u

^__-

.w^^

TW^ -^MV T*# vw -^v

23
vwft

flF'TV

24 Add lines 21 through 23


25 Enter amount from Form 104Q, line 38.
26

UtRcT-

*^

aw

V1M*

*wtf

A--^

^XIV

3,742.

24

L25_

--^

83,612.

Multiply line 25 by 2% (.02).

1,6"? 2.

26

27

27 Subtract line 26 from hne 24. If line 26 is more than line 24, enter -0>28 Oiher - from list in instructions. Lisi type and arnouni

Miscellaneous
Deductions
Total
Itemized
Deductions

I 28

LJJ-CL
0.

29 Is Form 10'W, hne 38, over $152,525?

j^j N^L ^^rq^^^n,^ ^^'!^^' t'Klt*a!?i^^r'l!'ocuintFsor^]t?!^,r l^el1^clumr

29

[~| Yes. Your (leduchon may bejimited. See the iteffiizec Deductions Worksheet

1^890,

V^-MV>.WXW,

jin the instructions to iigu'e the arnouii' So enter.

30

you elect to Uem^e dedudicns even though they are less Sha" your standard

>

deds.ciion, check here

BAA For Paperwork Reduction Act Notice, see Form 1040 instructions.

^-

U'AOiU i

-\

I2'?a"u

D
Scheduie A (Form 1040) 2014

SCHEDULE B
Department of the Tr&ss.ury
Internal Revenije S^fv%<;?

0MB No 1545.0074

interest and Ordinary Dividends

(Form 1040A or 1040)

Attach to Form 1040A or 1040.

(99)

Attachment
Seciuence No 08

Information about Schedule B and its instructions is at www.irs.gov/scheduleti.

^-

Your social security number

Narn&Cs) shown o': ?eh;/ri

*.*.*.-**_^***

HELEN E. BENSON
Part)
Interest

List name of payer. If any interes'i is ftom a sejler-tinanced mprtgage ana the buyer used

(See

Bank of America

Amount

She property as a personal residence, see Die instructions and list iBs interest iirsl Also,
show thai buyer's social security number and address .-

instruciions for
Form 1040A, or

+0^< -^T

Form 1040,
me 8a.)

fHAK

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/ft^*

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Note. If you

iece:ved-s Fonn
1099.IMT, Form
1099.0!Q, or
sub&tilnte stslemsnl
from a broHsrags
firm. Sisl the fi'm's
name as ihfi p^yc-r
and enter thskilaE

16.
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jmv. WTC~ *WT^

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Add the amounts on. line 1.

Excludable interest on series EE and I U.S. savings bonds issued after 1989. Attach

Form 8815.
4

Part II

Subtract line 3 from line 2. Enter the result here and m Rirm lfi40A,,or Form 1040,: line 8a

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vmKK ^vfM

Ordinary

jwnfr

Dividencis
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instructions for
Form 1040A, or
Form 1040

16.

4
Amount

Note. If line 4 is over $1,500, you must complete Part III,


5 List name of payer >
.1*M*

16.

:< H H;

Wff

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JIJJJ

www ^nv^

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Note. If yqi! received


a Form ''099-OIV 01

A-rtw

J^WA

.-^__u

vmf wwn

./v-^

^wv

w - A-

subs(il=j;e stgiemQn!

from a fcrokerage

A-

firm, 3:si the firm's


pame as th& payer

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and enter t^e

Oidi^sry dividends

^Nh^

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HXf^r

Wflvf

.?-".

w^w

Uws*

shown on iha! iwn\,

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.. up

^ff

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wva

^rtna'

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Add She amounts on ime 5. Enter fce total here and on wm WOA, or ForrR i04p, line Sa

>

^VAV^ft

Part ill

Foreign

Accounts

and Trusts
(See
instructions)

0.

Note. If line 6 is over $1,500, youmust complete Part 111.


You must compiete this part if you (a) had over $"i,500 of taxabts interest or ordinaty_divtdends, (b) had
a foreign account; or (c) received a distribution from, or were a grantor of, or a transferor to. a foreign trust
----

Yes

No

7 a AS any time during 2014, did you have a financial interest in or signature authonty over a financia
account (such as a bank account, securities account, or brokerage account) located in a foreign country?
See instriictions

f 'Yes,' are you required to file FinCEN Form 114, Fteport of Foreign Bank and Financial Accounts JFBAR), io
report thai Itnanciai inteFest o! s>gnafure authority? See FmCEN Form 114 and its instrucSions for filnKj
requirements and exceplions to ihose requirefnenis

b If you are required to file FinCEN Form 114, enter the name of the ioreign country where the financial
account is located

s-

8 During 2014, did you leceiye a disinbujion fro'i, or were yDu the grantor of, or transferor to, a foreign trusi? If
"Ves, you may have to file Form 3520 See insiructiohs

BAA For Papemork Reduction Act Notice, see your tax return instructions.

FDIA0401

ymm

Schedule B (.Fow 1Q40A or 1040) 2014

Form

0MB No. 1545.0074

Child and Dependent Care Expenses

2441

>.

Depaflmenl of lh^ Treasyfy


nlernai Revenue ^fi^'Ki*

2014

Attach to Form 1040, Form 1040A, or Form 1040NR.

AHachment

(99)

>

Information about Form 2441 and its separate instructions is at www.trs.gov/fonn2441

Sequence No.

21

four social s&cithty numbo

f4ame(s) shown on feturn

HELEN EBENSON
Persons or Organizations
Part I

***_**

Who Provided UwCiTe

* * fc *

You must complete this part.

(If you have more than Iwo care providers, see she instructions.)
vwvwvw - -^M^-

(c) Identifying no.


(SSN or EIN)

(b) Address

(a) Care provider's name

(no., street, apt no,, cily, slate, and ZIP code)

(d) Amount paid


(see instructions)

7,405.

45-4213648

Did you receive

dependent care benefits?

No

>

Yes

^-

Complete only Part II below.


Complete Part III on page 2 next.

Caution, if the care was provided ,n your home.j/ou may cm employment taxes. If you do, you cannot fiie Form 1040A. For detaiis,
see the instructions for Form 1040, line 60a, or Form 1040NR, line Sfe.
Part.H
2

CredrtJw'Chlld and Dependent Care Exggnses


^/.WJk^JLIk^.-^m

|nfoTmatK3naboutyourquaiHyingperson<s,),tfyou have more than two qLialifying persons,_see the instructiwis;


(b) Qualifying person's social
security numbef

(a) Qualifying person's name

**_****

* -k *

BENSON

BOND

3 Add the amounts in column (c) of !.ne 2. Do not enter more than $3,000 for one qualifying person or $6,000

5
6

Enter your earned income. See instructions

If marned filing jointly, enter your spouse's earned income (if you or your spouse was a student

or was disabled, see the instructions); all others, enter the amount from line 4 ,.

Enter the smallest of line 3, 4, or 5.,

nier the amount from Form 1040, line 38; Form 1040A, line 22; or Form
1040NR, line 37..

83,596.
3, 000.

Enter on line 8 the decimal amount shown below that applies to the amount on line 7
I! line 7 is:
But not
Over

over

$0 15,000
15,000 - 17,000
17,000 - 19,000
19,000 2'i ,000
21,000 - 23,000
23,QOO - 25,000
25,000 - 27,000
27,000 - 29,000

10

3,000,
83,596,

83,612.

.r.

If line 7 is:

LJJ35;

for two or more persons. If you completed Part III, enter the amount ?rom line 31.....

you incurred and paid


n 2014 for the person
listed in column (a)

Last

First
^

c) Qualified expenses

Decimal
amount is
.35

Over

But not

Decimal

over

amount is

.u.l,-L . . JL JL+

$29,000 - 31,000

.27

.34

31,000 - 33,000

,26

,33

.25

.30

33,000 - 35,000
35,000 37,000
37,000 39,000
39,000 - 41,000

29

41.000 -43,000

21

28

43,000 - No limit

20

.32
.31

.24

Fax liability limit. Enter the amount from the Credit Limit Worksheet

22

10

here and on Form 1040, Sme 49; Form 1C40A, line 31; or Form 104pNR, line_47_

BAA For Paperwork Reduction Act Notice, see your tax return instructions.

Ft;';A3212i. 0;; 1.1;"!

600.

11 Credit (or child and dependent care expenses. Enter the smaller of line 9 or I me 10

.20

.23

Multiply line 6 by the decimal amount on line 8. 'f you paid 2013 expenses in 2014, see the instructions ,
in the .nstrucdons

10,619.
:_"J
n

600.
Form 2441 (20'i4;

fli

Empioyee Business Expenses

2106

Form

Deparirnsnt c>f the Tiea^siify


'nlemal Revene Servicy

(99 /'

fr.

2014

Attach to Form 1040 or Form 1040NR.

AUiX'ht^efif
Seqw^e^ ^o

Information about Form 2106 and its separate instructions is available at ivww.irs.goy/form2t06.

Your name

HELEN E. BENSON

Part i

OM3 No 1545.0074

Occypalion irs whic^ you mcufred expenses

Social ^ecuHty number

ATTORNEY

***

**_****

Employee Business Expenses and Reimbursements


Column A

Step 1 Enter Your Expenses

Parking fees, lolis, and transportation, including train, bus, etc., that did not
involve overnight travel or commuting to and from work..,. .

.\

Travel expense whiie away from home overnight, including lodging, airplane,

2
3

cai rental, etc. Do not include meals and entertainment

Meals and
Enterta'nrnent

2 369.

See instruciions.).

Column B

Other Than Meais


and Entertainment

1 Vehicle expense from line 22 or iine 29. (Rural mail carriers:


2

129

Business expenses not included on lines 1 through 3. Dp nat include meals


See St.stgffient. .6.
and entertainment

1,042.

^.

Meals and entertainment expenses (see insiructions) ......

Total expenses. In Column A, add lines 1 through 4 and enter the result.

5
6

in Column B, enter the amount from line 5 .,.

61.

1
^

61.

3,411,

Note. If you were not reimbursed for any expenses in Step 1, skip line 7 and enter ihe amount from line 6 on line 8.

Step 2 Enter Reimbursements Received From Your Employer for Expenses Listed in Step 1
w

-^

Entsr reimbursennis.r^eived from.your employer that were not (epfflted to

yoy:!n box ! of Form W2,Jnclude any reimbursements reported under code 'L'
in Box 12ofyoufF6rmW-2 (see itistnjctions)..

Step 3 Figure Expenses To Deduct on Schedule A (Form 1040 or Form 1040NR)


.Jt--"-"-"--J^J^

8 Subtract line 7 from line 6. If zero or less, enter -0-. However, if line 7 is greater
than line 6 in Column A, r-eport the excess as income on Form 1040, line 7 (or
on Form 1040NR, line 8)

3,411.

61.

3,411.

31.

Noie. ft both columns oj line 8 are zero, you cannot deduct employee

business expenses. Stop here and attach Form 2106 to your return.
^t

n Column A, enter the aiwunt from line 8. In Column B, multiply Sins 8 by 50%

^ lOUi'S of
(.50). (Employees subject to Department of Transpprtation (DO
iefVfce limrts: Muitiply meal expenses inc'urred whiie away from home on
business by 80% (,8Q) instead of 50%. For details, see inslrucliQns.),.

10 Add ',he amounis on line 9 of both columns and enter the total here. Also, enter the total on Schedule A

(Form 1040), line 21 (or on Schedule A (Form 1040NR), tne 7), (Armed .Forces reservists; qualiiied
performing arlssts, fee-basis state or locai government officials, and individuals with disabilities: See (he
inslTuctions for special rules on where to enter the iota!.).

10

3,442.
Form 2106 (2014

BAA For Paperwork Reduction Act Notice, see your tax return instructions.

FOiA2?i21

>

C9''03''!^

.^

Form 2106(2014)

Part It
Vehicle Expenses
Section A - Genera! information o/ou must complete this section if
you are claiming vehicle expenses.)

(b) Vehicle 2

(a) Vehicle 1

11/05/05

Enter the date the vehicle was placed in service

12

Toia! miles the vehicle was driven during 2014

12

13,000 miles

13

Business miles included on iine 12,.


Percent of business use. Divide line 13 by line 12.....

13

4,2i0i_miles

14

15 Average daily roundtnp commuting distance..,


16 Commuting miles included on line 12 ..

15

32.54 %
9 miles

16

2,025 miles

17

6,745 miles

14

Page 2

HELEN E.BENSON

17 Other miles. Add lines 13 and 16 and subtract the total


from line 12..

Was your vehicle available for personal use during off-duty hours?
19 Do you (or your spouse) have another vehicle available for personal use?..
20 Do you have evidence to support your deduction?.
18

miles
miles
%
miles
miles
miles
x
x
x
x

fl

* K

23 Gasoline, oil, repairs, vehicle

No

2;3,69.

f,

24 a

b Inclusion amount (see instructions) ..

No

Yes

(b) Vehicle 2

MYehide

r- T T

23

insurance, etc.....
24 a Vehicle rentals ....

No

Yes

22

22 Multiply line 13 by 56 * (,5G). Enter the result here and on line


vwr

No

Yes

n*Ui1

f 'Yes,' is the evidence written?.......


Section 8
Standard Mileage Rate (See th& instfuctions for Part ll to find out whether to comptetia this secnon or Section C.)

Yes

iritoftl*^

21

ictlorlS.~;AC1Eua!^SXenses

WW

1
.>

24 b
r

24 c

c Subtract line 24b from line 24a ....

Jli

t
t

25 Value of emp)oy<ir'grovidGd vehicle

(appiies only if 100'%. o[annuaj iease

yalue was incluyecl on Form W-2


- see instructions)................

25

.> .>

26 Add lines 23, 24c, and 25 .

26

.>

rf

/
/

27 Multiply line 26 by the percentage

.>

.>

27

on line 14

.>
/

28

28 Depreciation (see instructions)..

.>

.>

ti
/

29

Add lines 27 and 28. Enter total

29

here and on line 1 ,,..

.>

Section D - Depreciation Of Vehicles (Use this section onty if you owned thtrvehicle and are compledng Section C for ite_vehi^[i_.)
(b) Vehicle 2

(a) Vehicle 1

30

31
32

Enter cost or other basis

(see instructions).

30

Enter section 179 deduction


(see instructions).,.,

31

'T ffv -r

rf

w-

Muiiipiy line 30 by line 14 (see

instructions if you claimed Ihe


section 179 deduction)

32

.>
ft

33

Enter depreciation me'ihod and


percentage (see instruciions)

<

I I

33
^^
-i

34 Multiply line 32 by the percentage


on line 33 (see iristruclions).,

34

35 Add lines 31 and 34, ..........

35

^
'.y^
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^

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;-.

36

Enier the applicable limit explained in


the line 36 instructions, .

36

.?':
/.

:--.

on line 14.

37

:--;

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..;

-:--;

.:'-

yKf

:-:---:

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.--..

^
:-..

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V-

"f*

.;;.'

; ---'-.
:;--

':-.

..?

.:.--

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;-.

'^- --..
:-:' :.--:

-::

. -:--.

:--;
-:: -.--

:-:.

;:-

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,,--.
.---..
-:-:

--

:-.

.-:
';--

:-.

-;

:-.

..";.

^ ^-

;:-.

38

-:;
;-..

;:-.-;--

;.

::-.

:;-',;;

.:;--

;--

:---.

line 37. If you skipped lines 36 and 37,

..-..^

L.L'

:^

'.'-.' .J~~~~
.--..

Enter the smaller of line 35 or


enter this amount on hne 28 above

.,;.
:.;

^:
-r. .'y-~l

enter the amount 'rom line 35, Also

';.

;--

.-:. -;

38

,;..

,.;.

-':
^;

v
:-:

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;,;;

:-

37 fv'ultipiy line 36 by the percentage

:-.

;;-.;,' .;J,\

.-: .:-

:-:'
---..:-.

-:'

.-.--:-.

FOIA2712L 09;03;14

Form 2106 (2014)

<ft

Federal Statements

2014

Page 1
**..*,MKMX
h
K

HELEN E. BENSON

Statement 1
Form 1040

Wage Schedule
Medi-

Federal

__Tax&a

r - Employer

State of Florida

_Wages__
T*l* liKmK^

Grand Total

83JiliL
83,596.

HZH

FICA

care

13,230.
13,230.

5,729.
5,729.

1,. 340,
1,340,

State

W/H
0.

Local
W/H
0.

Statement 2

Schedule A, Line 1
Medical and Dentai Expenses

Prescription Medicines and Drugs...,.,...-..,,.,........,...,........,........, ._.,^.. _ $

2,675.
Total

2,675.

Total

$
$

2,670.

Statement 3

Schedule A, Line 6

Real Estate Taxes


Home

.:

<

<

2^670^

Statement 4

Schedule A, Line 10

Home IViortgage Interest Reported on Form 1098


Third Federal

.V

h ^

4,270.

LT y

Total $

4,27(L

Statement 5

Schedule A, Line 16

Contributions by Cash or Check


Various
Total

982.
982.

Statement 6 - ATTORNEY

Form 2106, Page 1, Line 4


Other Business Expenses
99.
901.
42.

Drop Box.
Dues
Website..
Total

1,042.

Page 1

Vehicle/Unreimbursed Expenses

2014

HELEN E. BENSON
a

Vehicle Expenses - Form 2106


ATTORNEY

Jeep

1. Date placed in service


2. Total mileage
3. Business mileage

4. Business use percentage (divide line 3 by line 2)

11/05/05
13,000
4,230
0.3254

Standard Mileage Rate:

5. Multiply line 3 by 56 cents (.56)


Depr. portion of mileage_(22 cents per mile)
Oper. exp. portion of mileage (34 cents per mile)

2,369.
931.

1,438.

Actual Expenses:
6. Gasoline, lube and oil
1. Repairs
8, Tires
9. Insurance
10. Miscellaneous

li. Auto license (except personal property taxes)


12. Value of employer-provided vehicle

13. Vehicle rent or lease (less inclusion)


14. Add lines 6 through 13

0.

15. Nttltiply line 14 by line 4

16. Depreciation and section 179 deduction


17. Ada lines 15 and 16

Total Vehicle Expenses:


18. Enter line 5 or line 17

0.

Std Mileage
2,369.

A;

&/&>>'& U<'&' ss.S'^'''^ '':.'.; n'iL'p;"

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+ ^^t .w^

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9? W~i.20

Tallahassee, Florida 32399-0356


^i-<^--^^?v-^--^-^

<)

feti S & V/E^S ;i!'ilJ t:?S

200 E Gaines Street

.i7r

//'

-W^v ^wy

JeffAtwater, Chief Financiai Officer

Jfrh-^K-.-Nrt.-W

^s

)5i3t~)~^l socis:l;>y \3y-'vvfti'iv-f-i<i

O? 402,20

Stale of Florida

^w^^

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3 z.M 16

3 Sc-cht secuiiiy tosg&s

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i'

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241 St!

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14 0^h

HELEN E BENSON

I-

1,149.24

125

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20 Lo^yi iy ii^rrt^

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2014

WAGE AND TAX


STATEMENT

FORM

^ S.i'

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Depa;t;"tt,>nl ot U';e Trcssuiy - !'ntc:-.n'iai Ro'/^rmft >Ssrvi<'.e

Copy 8 . T<, Be ^M W.ln D, ployee's FEDEML T.B Rturn


11 r If

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5./2o.91

? '102 20

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State of Florida

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W-2

FORM

WAGE AND TAX

STATEMENT
Copy C -For EMPLOYEE'S RECORDS
AA4 ? 7'/ Rrw 01 '2' /?C 1.1

Dt^p^rtniti
This ;nforrn^i;ort

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CERTIFICATE

have read the foregoing questions carefully and have answered them truthfully, fully
and completely. I hereby waive notice by and authorize The Florida Bar or any of its
committees, educational and other institutions, the Judicial Qualifications Commission,
the Florida Board of Bar Examiners or any judicial or professional disciplinary or

supen/isory body or commission, any references furnished by me, employers, business


and professional associates, all governmental agencies and instrumentalities and all
consumer and credit reporting agencies to release to the respective Judicial Nominating
Commission and Office of the Governor any information, files, records or credit reports

requested by the commission in connection with any consideration of me as possible


nominee for appointment to judicial office. Information relating to any Florida Bar

disciplinary proceedings is to be made available in accordance with Rule 3-7.1(1), Rules


Regulating The Florida Bar. I recognize and agree that, pursuant to the Florida
Constitution and the Uniform Rules of this commission, the contents of this

questionnaire and other information received from or concerning me, and all interviews
and proceedings of the commission, except for deliberations by the commission, sha
be open to the public.

Further, I stipulate I have read, and understand the requirements of the Florida Code of
Judicial Conduct.
Dated this

day of

J^ / <? 6A<^

,20_^

^?

'Bs-rsy 'ff^^^^^

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y

Printed Name
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Signature
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(Pursuant to Section 119.071(4)(d)(1), F.S.^. , The home addresses and telephone


numbers of justices of the Supreme Court, district court of appeal judges, circuit court

judges, and county court judges; the home addresses, telephone numbers, and places ^
of employment of'the spouses and children of justices and judges, and the names and
locations of schoois and day care facilities attended by the children of justices and

judges are exempt from the provisions of subsection (1), dealing with public records.
13
Rev. 100209-OGC

JUDICIAL APPLICATION DATA RECORD


^.-/.-.VT

The judiciai application shall include a separate page asking appliGants to identify their
race, ethnicity and gender. Completion of this page shall be optional, and tHe page shall
include an explanation that the information is requested for data GolleGtion purposes
in the judiciary. The chair of the
in order to assess and promote diversity
Commission shal! forward ail such completed pages, along with the names of the
nominees to the JNC Coordinator in the Governor's Office (pursuant to JNC Uniform
Ruie of Procedure).

vdW^^*h"

(Please Type or Print)


Date:

November 9, 2015

JNC Submitting To:

ReQgje_Zach a ri ah, Chair, Gree n b u rg Tra u rig, P .A.

Betsv Benson
Name (please print):
Asst. Public Defender, Capital Crimes Division
Current Occupation:
Attorney No.: 434280
Telephone Number:
Female
D Male
Gender (check one):
White, non Hispanic
Ethnic Origin (check one):
Hispanic
D Black
Vf^^,

D
D

American Indian/Alaskan Native


Asian/Pacific Islander

County of Residence: B reward

22
Rev. 100209-OGC

-"-^~^^*""--*""-'

FLORIDA DEPARTMENT OF LA W ENFORCEMENT


DISCLOSURE PURSUANT TO THE
FAIR CREDIT REPORTING ACT (FCRA)

The Florida Department of Law Enforcement (FDLE) may obtain one or mor^consumer

reports, including but not limited to credit reports about^ you for_emPlloymen^uJ'pos^
as'defned-bythe Fair Credit Reporting Act, including for determinations related to Initia

employment,' reassignment, promotion, or other employment-related actions.

CONSUMER'S AUTHORIZATION FOR FDLE


TO OBTAIN CONSUMER REPORT(S)

have read and understand the above Disclosure. I authorize the Florida Department of

Law "Enforcement (FDLE) to obtain one or more consumer reports on me, for
employment purposes, as described in the above Disclosure.
Printed Name of

Betg^Benson

Applicant:

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Signature of Applicant:

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Date:

10/30/2015

23

Rev. 100209-OGC

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