IN THE CIRCUIT COURT OF THE FIFTEENTH · Web view2010/02/01 · IN THE CIRCUIT COURT...
Transcript of IN THE CIRCUIT COURT OF THE FIFTEENTH · Web view2010/02/01 · IN THE CIRCUIT COURT...
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUITIN AND FOR PALM BEACH COUNTY, FLORIDA
JUDGE RICHARD L. OFTEDAL
IN THE MATTER OF THE MARRIAGE OF
JEFFREY P. LAWSONHUSBAND,
2005DR001269XXXXNBAND FAMILY DIVISION “FH”
KATHY ANN GARCIA-LAWSONWIFE.
TO THE HONORABLE JUDGE OF SAID CIRCUIT COURT:
MOTION FOR LEAVE TO INTERVENE PURSUANT TO FLORIDA RULE OF CIVIL PROCEDURE 1.1230, and
Request for Hearing
The undersigned Intervenors, jointly and severally, on behalf of
themselves and of all persons who have filed Notices of Intervention, seek leave
to come and appear before this Court, and to have a full-and-open evidentiary
hearing on the constitutional issues which they have raised. Kathy Lawson has
provided Intervenors with the initial (file-marked and mailed December 18,
2009) and later resent copies of this Court’s “Order Setting Trial” (which was
not served on any of the 14 intervenors, neither the two (Bertrand and Caliguiri)
whose interventions were “stricken” on October 28, 2009, nor any of the other
twelve who had intervened as of that date.
Intervenors demand a hearing be set for at least 1-3 hours on
February 17-19, 2010 concerning their multiple Notices of Intervention
in support of Kathy Ann Garcia-Lawson’s complaint to challenge the
constitutionality of Florida’s domestic relations courts: their existence,
Notice of Intervention in Support of Constitutional Questions after Federal Court Dismissal under Younger v. Harris, 401 U.S. 37 (1971)
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procedure, and jurisdiction in light of Judge Kenneth Marra’s dismissal
pursuant to Younger v. Harris, 401 U.S. 37 (1971). The gravamen of
Judge Marra’s Orders in the two cases brought in the United States District
Court for the Southern District of Florida concerning Kathy Ann Garcia-Lawson’s
challenge to the jurisdiction of Florida Courts to hear Jeffrey P. Lawson’s Petition
for Dissolution of Marriage against her is that Florida Courts should have the
first fair shot at addressing these issues.
Kathy Ann Garcia-Lawson’s position is that she (as a Respondent in this
case) has been trying to frame her constitutional challenge to the jurisdiction of
the Florida Domestic Relations Courts, including but not limited to the 15th
Judicial Circuit Court “Family Divison” “FH” for nearly five years now. She
started out with a very modest analysis and proposal which would have
reformed but not abolished the system (see “White Paper” attached as Exhibit
A, completed in or about summer 2006). As Respondent Kathy A. Garcia-
Lawson’s knowledge and awareness of the system has changed over time, all
her efforts have been rebuffed.
It is now Kathy Ann Garcia-Lawson’s position and contention, in this case
and elsewhere, that the entire Florida Family and Domestic Relations Code
needs to be scrapped. The Intervenors, each jointly and severally, acting on his
or her own behalf, come into this Court to support and obtain a ruling on
Respondent’s Constitutional claims, and to ask this Court to declare and
adjudge that the entire Statutory Scheme of the Florida Domestic Relations
courts be declared unconstitutional as to its constitutional presumptions,
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underpinnings and basic premises, and therefore that this Court abolish itself or
in the alternative abjure from further exercise of jurisdiction over any marital
dissolution, property division, or child custody case except to the extent allowed
by the common law pre-existing or external to the Florida Statutory Scheme for
Family organization and creation, whose existence is in and of itself offensive to
the separation of Church and State established by the First Amendment. It is
this constitutional interest in the dissolution, not of marriage but of the family
courts all together, which is the direct and immediate interest of each of the
intervenors. This direct and immediate and personal interest shared by each
intervenor in Kathy Ann Garcia-Lawson’s demand for the abolition (by
declaratory judgment and subsequent injunctions against the further
enforcement) of the Florida Family Code which entitles each and every
intervenor in this case to intervene under (non-Family Code) Florida Rule of Civil
Procedure 1.230.
Further operation of the Florida Family Courts will directly and
immediately infringe upon the rights of each and every one of the intervenors if
Kathy Ann Garcia-Lawson’s petition is not granted. Intervenors specifically
concur with Kathy Ann Garcia-Lawson to the degree that she has realized and
contends in her pleadings that there is (as a practical matter) no honor or
integrity among the practitioners in family law, and, as a theoretical and
constitutional matter, there is no constitutional authority whatsoever for the
existence or exercise of Domestic Relations jurisdiction by any state under the
First, Fifth, Seventh, Ninth, and Fourteenth Amendments. Accordingly, it
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appears to the Respondent and to the undersigned intervenors that the Florida
Family Division/Domestic relation courts should be abolished, razed to the
ground, and power and freedom returned to the people.
On December 16, 2009, Respondent Kathy Ann Garcia-Lawson received
an order including the following specific orders to which all intervenors object as
a facial violation of Kathy Ann Garcia-Lawson’s fundamental rights, and as a
result, to be facially violative of the First, Fifth, Seventh, Ninth, and Fourteenth
Amendments:
Judge Oftedal has ordered that Kathy Ann Garcia-Lawson file with the
Court for purposes of a non-jury trial:
A. An updated financial affidavit.
B. A proposed parenting plan [under] Florida Statutes §61.12(2)(b)
(F.S.)
C. A proposed plan of equitable distribution of the parties’ marital
assets and liabilities.
D. A proposed child support guidelines worksheet.
Intervenors object to each and every one of these orders as follows:
A. This order requiring a financial affidavit is an unconstitutional order
because it is void for vagueness. The order does not define a
financial affidavit nor is there any constitutional authority for this
court to violate the Fourth Amendment by ordering a nonconsensual
search without a warrant supported by affidavit:
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The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.
The allowance, enforcement, or perpetuation of these orders is each one
a constitutional violation which offends and infringes upon the rights of each
and every one of the intervenors, not merely under the maxim that “none can
be free until all are free” but because the perpetuation of the Florida Domestic
Relations law and judicial system is a continuing threat to the life, liberty, and
property interests of each individual intervenor, whether he or she be currently
single, married, divorced, with or without minor children.
An old attachment circulated to newlyweds by the State of Florida
explained, “the State of Florida is interested in your marriage” (see Exhibit B).
For all and precisely the same reasons, the intervenors are interested in
stopping the dissolution of Kathy Ann Garcia-Lawson’s marriage, but
additionally the intervenors are interested in the legal issues which are raised
by Kathy Ann Garcia-Lawson in this case, which have never been raised before
(to the Intervenors’ knowledge) in any other case ever presented to any Florida
Court.
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This is a case of First Impression, requiring that fundamental changes be
instituted affecting the cultural, economic, judicial, legal, political and social
fabric of the State of Florida
On or about October 28, 2009, this Court struck the Notices of
Intervention signed by Robert J. Bertrand and Donna Caliguiri, but all other
Intervenors Notices, including those of the undersigned, aside from Bob
Bertrand, have been ignored. Robert J. Bertrand in particular signs this Demand
for a hearing that his intervention be reinstated (and in particular requests
leave of court to appear by telephone at any hearing).
In the alternative, part A of Judge Oftedal’s order entered December
18, 2009, violates the Fifth Amendment because it is designed to facilitate
a government ordered taking of property without due process of law AND
amounts to an order to Kathy Ann Garcia-Lawson to testify against herself
in a case which is governed by the “quasi-criminal” evidentiary standard
of “clear and convincing evidence” applied in Florida and elsewhere to all
Family or Domestic Relations cases.
In addition, part A of Judge Oftedal’s order violates the 7th
Amendment because Kathy Ann Garcia-Lawson has demanded a trial-by-
jury of all facts so triable at common law under the Seventh Amendment
(as of February 20, 2007) and this court, without justification, has
scheduled this for a non-jury trial and ordered respondent to testify
against her own interests without immunity or voluntary waiver of her
rights.
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B. Part B of Judge Oftedal’s order violates the First, Ninth, and
Fourteenth Amendments because the First Amendment forbids the
establishment of any religion and secures freedom of speech, and
just as the first amendment was incorporated to the States by the
14th, the Ninth Amendment also secured all undelegated powers to
the people, and the right to plan how to “parent” (i.e. educate,
nurture, and rear) one’s children is a fundamental right secured to
the people. A Court-ordered “parenting plan” is a violation of the
First Amendment rights to freedom of speech, freedom of assembly
or association, and freedom of religion and Kathy Ann Garcia-
Lawson objects on grounds of religious freedom, as do all of the
intervenors.
C. All the objections to the financial affidavit listed above apply to this
order for a “proposed plan of equitable distribution.” Kathy Ann
Garcia-Lawson and Jeffrey P. Lawson had only one plan for their
property, which was joint ownership and management together
throughout their lives, and neither party has breached this
agreement, nor properly pled at common law any grounds for
recission or reformation of that agreement.
D. “A proposed child support guidelines worksheet” is objectionable for
all of the same grounds as asserted by the intervenors to parts A, B,
and C of Judge Oftedal’s order, and the Court’s threat of sanctions
for failure to comply with unconstitutional orders is precisely the
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kind of systemic threat to the freedom of all Floridians which causes
the undersigned intervenors here to appear and object.
On or about September 30, October 14, 2009, October 21, 2009, and
February 3, 2010, the following individuals filed Notices of Intervention:
Petitions in Intervention Filed: September 30, 2009
Eladio ArmestoPOB 350002
Miami, Fl. 33135-0002305-530-8787
Robert Bertrand6951 Miami Lakes South
Miami, Fl.786-338-0220
Rebecca Potter1417 Michigan Drive
Lake Worth, Fl. 33461561 876 7148
Salvatore Melita1426 S. Atlantic Drive
Lantana, Fl. 33462561 585-8526
Donna Caliguiri1503 Donald Rd.Jupiter, Fl. 33419
561 745-0442
Intervenor Petitions Filed 10/14/09:
Gustavo Marlelo8230 SW 117 TerraceMiami-Dade, Fl. 33156
Leslie Garcia5047 Magnolia Bay Circle
Palm Beach Gardens, Fl. 33408
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Susan Kiraly Surio White2005 Windwood Lane
Lakeland, Fl. 33813Lorraine Gonzolez
6961 Miami Lakeway S.Miami Lakes, Fl. 33014
Nelly Benjamin2168 N.W. 208th Way
Penbroke Pines, Fl 33029
Michael Benjami101 E. Okeechobee Rd.
Hialeah, Fl. 33010
Merle Long7100 Miami Lakeway S.Miami Lakes, Fl 33014
Jorge Norma14113 SW 31 St.
Miramar, Fl 33027
Ateeq Rehman45 E. 11th St. #11Hialeah, Fl 33010
Roberta Bertrand465 Paradise Isle Blvd #309
Hallandale, Fl 33009
On or about October 21, 2009:
Charles Edward Lincolnc/o Lucas Daniel Smith or Melissa Shepard Gillespie
13206 Glenmoor DriveWest Palm Beach, Florida 33409
Filed February 4, 2010.Kenneth Martinez
930 Parham Ct.Bartow, Fl. 33830
863-333-6764
Jennifer Leslie
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590 Cody Caleb Dr.Winter Haven, Fl 33884
863- 875 3297
Ailleen Rodriquex1100 Lowry Ave. #56
Lakeland, Fl 33801863- 934-9907
Irene Castillo Sato5508 Starling LoopLakeland, Fl. 33810
863- [email protected]
Ventura Smith269 Winter Ridge Blvd.
Winter Haven, Fl. 33881 863-581-0881
Kim M. Umholtz10685 DeMilley Rd.Polk City, Fl 33868
863- 651-3102
Pearl L. Bryan1227 Motorcoach Dr.Polk City, Fl. 33868
863-984-7474
Vera Peskanc/o 8500 Belcher Rd. Apt.
Pinellas Park, Fl. 33781727 289-9831
Adam Family Umholtz10685 Demilly Rd.Polk City, Fl. 33868
863 651 [email protected]
Jacqueline Y. Bain512 High Street
Lake Wales, Fl 33853863 676 4550
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Angela Fitch325 Haynes CirclePolk City, Fl 33868
863- 606 [email protected]
Troy Riner4259 Mahogany Run
Winter Haven, Polk County, Florida 33884863-969-8963
Janice Patterson5210 Paul Meyers. Lane
Plant City, Fl. 33566813 900 -3500
Brandi Denham695 Hawkin Rd.
Bartow, Fl 33830863-205 6829
Alexis Rowjohn695 Hinkin Rd.
Bartow, Fl 33830813 777-3695
Melba DavisP.O. Box 4114 FVS
Winter Haven, Fl 33885863 299-7548
JW Bartkovich1477 Alford Rd.
Haines City, Fl 33844863-439-2505
Mike Putnick4716 Joyce Dr.
Lakeland, Fl. 33805863-221-2061
Wally Benjamin
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2168 NW 208th WayPembroke Pines, Fl 33025
James Harvey2145 West Central Ave.
Winter Haven, Florida 33880863 207-2792
Kenneth White158 East 4th StreetHialeah, Fl 33010
305 888-2328
Rafael E. Gonzalez6961 Miami Lakeway South
Miami, Lakes, Fl 33014305 822-8859
Melissa Shepherd-Gillespie13206 Glenmoor Drive
West Palm Beach, Fl 33409
Sonia Valerio4845 NW 169th Street
Miami, Fl. 33055
The undersigned Intervenors (who constitute only a representative subset
of those listed above) have filed their notices and asserted their rights in this
case to demand an answer to one core question: are the Domestic Relations
Courts of the State of Florida really capable of evaluating the constitutional
violations of fundamental rights to life, liberty and property which these Courts
have perpetuated? They were joined today, February 4, 2010, by the above-
noted additional intervenors who all join in this motion seeking leave of court to
intervene in this cause, with the advice, proviso, and reservation of rights that if
leave to intervene is denied, they will file separate mass tort or class actions
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concerning the constitutional questions herein raised in the regular Civil Circuit
Court for the Fifteenth Judicial Circuit of the State of Florida and/or the United
States District Court for the Southern District of Florida.
The Intervenors move and request that this Court approve and appoint
counsel to serve as their attorney and counselor so that this case may be
certified as a mass constitutional tort or else as a class action under the (non-
Family) Florida Rules of Civil procedure.
As this Court is well aware, KATHY ANN GARCIA-LAWSON sought for
several years now (at least) to obtain answers to her questions concerning the
constitutionality of various provisions of the Florida Dissolution and Domestic
Relations Codes (especially but not limited to Chapters 61 and 741 of the
Florida Statutes). KATHY ANN GARCIA-LAWSON has also challenged the
qualities of substantive and procedural due process protection available in the
Florida Domestic Relations and Dissolution Courts and proceedings, and
asserted that neither the statutes on their face, nor the courts as administrators
of the processes established by statute, can withstand strict constitutional
scrutiny under the First, Fifth, Ninth, and Fourteenth Amendments to the
Constitution.
PRAYER FOR RELIEF
Wherefore, Intervenor joins Respondent Wife and former Federal Plaintiff
Kathy Ann Garcia-Lawson to move, request, and pray that this Court will allow
these pleadings in intervention to allege and frame and then to present
evidence and proof regarding the unconstitutionality of the State Domestic
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Relations Court’s politically and economically motivated collusion to “fix” all
domestic relations cases.
Intervenor further asks this Court to enter a declaratory judgment, and
therein to declare and adjudge this Court’s very existence to be unconstitutional
as a violation of the freedom of expression, association, and religion enshrined
by the First Amendment, the protection for substantive and procedural due
process guaranteed by the Fifth Amendment, and the reservation of all rights to
the people under the Ninth Amendment. Intervenor asks this 15th Judicial
Circuit Court to apply all these Constitutional Rights in the Federal Bill of Rights
to the States by operation of the Fourteenth Amendment, as construed by the
United States Supreme Court in Grosejean and all related cases.
Intervenor further and finally moves and requests that this Court to
Dismiss all cases now pending before it for Want of Constitutionally Valid
Jurisdiction and that the Court admit that the imposition of the State Marital
Licensing and Dissolution regime was a result of political and Public Fraud,
resulting from a conspiracy to impose unconstitutional communistic values and
an authoritarian regime on the American public.
In effect, Intervenor wishes hereby to obtain a final declaratory judgment
that state-licensed marriage is a state-imposed contract of adhesion and that
this Court will find that the Florida state licensing statutes create and constitute
constitutionally impermissible licensing and taxing of a fundamental right and
that this regime further constitutes and creates a constitutionally impermissible
excessive entanglement of state and religious affairs.
Notice of Intervention in Support of Constitutional Questions after Federal Court Dismissal under Younger v. Harris, 401 U.S. 37 (1971)
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Respectfully Submitted,
February 4, 2010
Intervenor’s Name:________________________________________________________
StreetAddress:____________________________________________________________________
City, County, State, Zip:____________________________________________________
Telephone:_________________________________________________________________
Facsimile:__________________________________________________________________
E-mail:______________________________________________________________________
Status: Married_____, Single______, Divorced______ Separated________Minor Children? Yes___________ No___________Current Florida Resident? Yes________ No__________Former Florida Resident? Yes________No____________
Intervenor’s Name:________________________________________________________
StreetAddress:____________________________________________________________________
City, County, State, Zip:____________________________________________________
Telephone:_________________________________________________________________
Facsimile:__________________________________________________________________
E-mail:______________________________________________________________________
Status: Married_____, Single______, Divorced______ Separated________Minor Children? Yes___________ No___________Current Florida Resident? Yes________ No__________Former Florida Resident? Yes________No____________
Intervenor’s Name:________________________________________________________
StreetAddress:____________________________________________________________________
Notice of Intervention in Support of Constitutional Questions after Federal Court Dismissal under Younger v. Harris, 401 U.S. 37 (1971)
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City, County, State, Zip:____________________________________________________
Telephone:_________________________________________________________________
Facsimile:__________________________________________________________________
E-mail:______________________________________________________________________
Status: Married_____, Single______, Divorced______ Separated________Minor Children? Yes___________ No___________Current Florida Resident? Yes________ No__________Former Florida Resident? Yes________No____________
Notice of Intervention in Support of Constitutional Questions after Federal Court Dismissal under Younger v. Harris, 401 U.S. 37 (1971)
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Intervenor’s Name:________________________________________________________
StreetAddress:____________________________________________________________________
City, County, State, Zip:____________________________________________________
Telephone:_________________________________________________________________
Facsimile:__________________________________________________________________
E-mail:______________________________________________________________________
Status: Married_____, Single______, Divorced______ Separated________Minor Children? Yes___________ No___________Current Florida Resident? Yes________ No__________Former Florida Resident? Yes________No____________
Intervenor’s Name:________________________________________________________
StreetAddress:____________________________________________________________________
City, County, State, Zip:____________________________________________________
Telephone:_________________________________________________________________
Facsimile:__________________________________________________________________
E-mail:______________________________________________________________________
Status: Married_____, Single______, Divorced______ Separated________Minor Children? Yes___________ No___________Current Florida Resident? Yes________ No__________Former Florida Resident? Yes________No____________
Notice of Intervention in Support of Constitutional Questions after Federal Court Dismissal under Younger v. Harris, 401 U.S. 37 (1971)
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Intervenor’s Name:________________________________________________________
StreetAddress:____________________________________________________________________
City, County, State, Zip:____________________________________________________
Telephone:_________________________________________________________________
Facsimile:__________________________________________________________________
E-mail:______________________________________________________________________
Status: Married_____, Single______, Divorced______ Separated________Minor Children? Yes___________ No___________Current Florida Resident? Yes________ No__________Former Florida Resident? Yes________No____________
Intervenor’s Name:________________________________________________________
StreetAddress:____________________________________________________________________
City, County, State, Zip:____________________________________________________
Telephone:_________________________________________________________________
Facsimile:__________________________________________________________________
E-mail:______________________________________________________________________
Status: Married_____, Single______, Divorced______ Separated________Minor Children? Yes___________ No___________Current Florida Resident? Yes________ No__________Former Florida Resident? Yes________No____________
Notice of Intervention in Support of Constitutional Questions after Federal Court Dismissal under Younger v. Harris, 401 U.S. 37 (1971)
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Intervenor’s Name:________________________________________________________
StreetAddress:____________________________________________________________________
City, County, State, Zip:____________________________________________________
Telephone:_________________________________________________________________
Facsimile:__________________________________________________________________
E-mail:______________________________________________________________________
Status: Married_____, Single______, Divorced______ Separated________Minor Children? Yes___________ No___________Current Florida Resident? Yes________ No__________Former Florida Resident? Yes________No____________
Intervenor’s Name:________________________________________________________
StreetAddress:____________________________________________________________________
City, County, State, Zip:____________________________________________________
Telephone:_________________________________________________________________
Facsimile:__________________________________________________________________
E-mail:______________________________________________________________________
Status: Married_____, Single______, Divorced______ Separated________Minor Children? Yes___________ No___________Current Florida Resident? Yes________ No__________Former Florida Resident? Yes________No____________
Notice of Intervention in Support of Constitutional Questions after Federal Court Dismissal under Younger v. Harris, 401 U.S. 37 (1971)
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Intervenor’s Name:________________________________________________________
StreetAddress:____________________________________________________________________
City, County, State, Zip:____________________________________________________
Telephone:_________________________________________________________________
Facsimile:__________________________________________________________________
E-mail:______________________________________________________________________
Status: Married_____, Single______, Divorced______ Separated________Minor Children? Yes___________ No___________Current Florida Resident? Yes________ No__________Former Florida Resident? Yes________No____________
Intervenor’s Name:________________________________________________________
StreetAddress:____________________________________________________________________
City, County, State, Zip:____________________________________________________
Telephone:_________________________________________________________________
Facsimile:__________________________________________________________________
E-mail:______________________________________________________________________
Status: Married_____, Single______, Divorced______ Separated________Minor Children? Yes___________ No___________Current Florida Resident? Yes________ No__________Former Florida Resident? Yes________No____________
Notice of Intervention in Support of Constitutional Questions after Federal Court Dismissal under Younger v. Harris, 401 U.S. 37 (1971)
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CERTIFICATE OF FILING AND SERVICE
I, the undersigned Intervenor, do hereby certify that I filed an original signed
copy of the above-and-foregoing Notice of Intervention with the Palm Beach County
Clerk of the Fifteenth Judical Circuit Court and simultaneously served a true and correct
copy of the same on each of the following known parties to the above entitled and
numbered cause as follows:
Clerk of 15th Judicial Circuit Court, Palm Beach CountyPalm Beach County Courthouse
North County Courthouse3188 PGA Boulevard
Palm Beach Gardens, Florida 33401-4599
Mr. Jeffrey P. Lawsonc/o Steve Marchildon
113 Ashley CourtJupiter, Florida 33408
Dr. Kathy Ann Garcia-Lawson2620 Nature’s Way
Palm Beach Gardens, Florida 33410
Respectfully Submitted and signed on September ____, 2009
By Intervenor: Name:_____________________________________________________
Address:______________________________________________________________
City, County, State Zip:_________________________________________________
Telephone:____________________________________________________________
E-mail:________________________________________________________________
Notice of Intervention in Support of Constitutional Questions after Federal Court Dismissal under Younger v. Harris, 401 U.S. 37 (1971)
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Exhibit A:Kathy Ann Garcia-Lawson’s
2006 “White Paper” on Divorce
Notice of Intervention in Support of Constitutional Questions after Federal Court Dismissal under Younger v. Harris, 401 U.S. 37 (1971)
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