EMERGENCY MOTION TO RECONSIDER - With a judge other than corrupt Holly N Derenthal of Osceola County Kissimmee Courthouse

 Please not I have redacted some personal info from the below motion for privacy reasons.

 

 

EMERGENCY MOTION TO RECONSIDER

Please note I am turning my statements in my motions over to the media and social media and all of my statements in my motions are being made VERY public.

 

Because of judge Holly Derenthal’s clear bias and close relationship with the other sides corrupt attorneys Jennifer Jane Watson and Sara Vance that are VERY well connected within not only the courthouse daily but ALL government agencies and employees around the system and courthouse and because of the illegal hearings and illegal orders Judge Holly Marie Newman Derenthal has made in this case while being bias and violating me and my children’s constitutional rights I am requesting a different judge set an emergency hearing to reconsider all of judge Holly Darenthal’s orders immediately before I am forced to send this in for an Emergency appeal to a higher appellate court. 

 

Because of this and what is below and the fact the children I will prove below have been put in a very serious dangerous situation by judge Derenthal I am requesting a pickup order and immediate full temporary custody of the children and power to put them back into their safe school where they have a full time armed policeman, cameras, double security doors and a full time on premise consoler involved with the children where they were going with their older sister I have full custody of before judge Derenthal illegally and unethically removed them and put them in serious danger out of hatred towards me trying to hurt me and get back at me for all my complaints to JQC, the governor and countless others and the she has violated Section 61.13(3), Florida Statutes along with countless others including several constitutional amendments.

 

Section 61.13(3), Florida Statutes

(3) For purposes of establishing or modifying parental responsibility and creating, developing,

approving, or modifying a parenting plan, including a time-sharing schedule, which governs each

parent’s relationship with his or her minor child and the relationship between each parent with

regard to his or her minor child, the best interest of the child shall be the primary consideration.

A determination of parental responsibility, a parenting plan, or a time-sharing schedule may not

be modified without a showing of a substantial, material, and unanticipated change in

circumstances and a determination that the modification is in the best interests of the child.

Determination of the best interests of the child shall be made by evaluating all of the factors

affecting the welfare and interests of the particular minor child and the circumstances of that

family, including, but not limited to:

(a) The demonstrated capacity and disposition of each parent to facilitate and encourage a

close and continuing parent-child relationship, to honor the time-sharing schedule, and

to be reasonable when changes are required.

(b) The anticipated division of parental responsibilities after the litigation, including the

extent to which parental responsibilities will be delegated to third parties.

(c) The demonstrated capacity and disposition of each parent to determine, consider, and

act upon the needs of the child as opposed to the needs or desires of the parent.

(d) The length of time the child has lived in a stable, satisfactory environment and the

desirability of maintaining continuity.

(e) The geographic viability of the parenting plan, with special attention paid to the needs

of school-age children and the amount of time to be spent traveling to effectuate the

parenting plan. This factor does not create a presumption for or against relocation of

either parent with a child.

(f) The moral fitness of the parents.

(g) The mental and physical health of the parents.

(h) The home, school, and community record of the child.

(i) The reasonable preference of the child, if the court deems the child to be of sufficient

intelligence, understanding, and experience to express a preference.

(j) The demonstrated knowledge, capacity, and disposition of each parent to be informed of

the circumstances of the minor child, including, but not limited to, the child’s friends,

teachers, medical care providers, daily activities, and favorite things.

(k) The demonstrated capacity and disposition of each parent to provide a consistent

routine for the child, such as discipline, and daily schedules for homework, meals, and

bedtime.

(l) The demonstrated capacity of each parent to communicate with and keep the other

parent informed of issues and activities regarding the minor child, and the willingness

of each parent to adopt a unified front on all major issues when dealing with the child.

 

 

 

As stated in Florida Statute § 61.534, for the court to issue an order granting a parent or petitioner the ability to secure emergency custody of a child, the court must first determine that the child is likely to suffer physical harm or be removed from the state.

 

Florida Emergency Motions for Custody

 

Florida Statute §61.517 gives the courts temporary emergency jurisdiction of a child present in the state if the child:

 

    Has been abandoned

    Is subjected to or threatened with abuse or mistreatment

    A parent of the child or sibling has been threatened with abuse or mistreatment (domestic violence)

 

A judge can issue an emergency custody order in Florida to protect the child. There are two ways that you can obtain an emergency child custody order.

 

If I have to go to appellate court the following will apply:

 

Rule 9.310 of the Florida Rules of Appellate Procedure, which governs expedited appeals. This rule allows parties to request an expedited appeal for certain types of cases, such as child custody matters, injunctions, and other urgent matters.

 

 

This matter involves my 4 year old daughter and 5 year old son that are in great serious immediate danger around their drug addicted adult movie star prostitute from a whore house in Thailand where I met her mother that was physically and sexual abusing them along with her porn fans and prostitution clients also putting the children in danger and beating them as well. Their mother had me falsely arrested on 3 counts of domestic violence in case number 2022 MM 000984 after I caught her lying, cheating and stealing money and sending it to her boyfriends in Thailand. She had me falsely arrested in an attempt to steal the 100k behind our paid off exclusively in her name Florida titled mobile home after I had a realtor come out and tell us it was worth 100k because of inflation. She was impeached as a witness at the criminal jury trial for compulsively lying to the jury and even admitting to committing perjury to get her injunction against me that has kept me and my full custody daughter out of our home for over a year now. It had also removed my two younger children for several months till I could prove my innocence and all the lies from not only my wife but countless FEMALES ALL collecting government checks on her side painting her as a victim of domestic violence. Help now shelter, DCF, corrupt Injunction for protection Help Now tax payer funded attorneys Jennifer Jane Watson and Sara Vance that have a long history of being corrupt that I currently have personal lawsuits against and countless other FEMALES around my fake domestic violence adult movie star prostitute illegal immigrant wife from a whore house in Thailand where I met her.

 

There is also immediate danger of the children being seriously harmed yet again in the crackhouse across the street with local drug traffickers and drug addicts Michelle Gilliam and Tony Mcnamee that have a huge criminal record for not only drugs but child neglect. There records span from not only Osceola county but to Illinois and other states where them and my wife traffic drugs back and forth and possibly with the children. Michelle Gilliam is my wife’s best friend my wife calls mom and she leaves the children unattended with Michelle and or Tony alone. Our son was seriously injured in their home already once when my wife left him alone with Tony while Tony was smoking drugs around the children and our son later lost two teeth and has a permanent scare inside and outside his lip from it. See Exhibit A, and B several countless times I have videos of I am now making public I have uncovered physical abuse, sexual abuse and Neglect and the children have told me they have slept in bed with mommies porn fans and prostitution client “boyfriends” AND they have had injuries and been unbathed and in dirty clothes with rashes on their private areas and underweight malnourished.

See exhibits C, D, E, F, G after I had not seen the children for months because of the mother having me falsely arrested and then committing perjury to get her injunction that she admitted to the jury that she committed perjury to get and see what I uncovered in the photos in the exhibits with the child consoler present with me at the Kissimmee police station of video with no edits live. Note I have videos and testimony of what the children told their counselors that day had been going on which she had to report to DCF and that was a year ago and of course DCF covered it up. Im will be putting those videos up very soon also.

 

Micheal Gilliams police report with a heart breaking story about drugs and children can be found in Exhibits E where she was arrested for possession of cocaine, possession of marijuana, possession of paraphernalia AND CHILD NEGLECT. Please note not only DCF left my children with her in her home for 3 days instructed by my wife even though I objected to it they lied and said they background check her also but as well my wife leaves the kids with her alone in her crack house constantly.

 

 

When the children’s mother had me falsely arrested for Domestic violence she was also baker acted for attempted suicide and has made threats to murder the children and herself see Exhibit F please note you can see DCF lied and said they background checked Michelle Gilliam when in fact perjury committing liar CPI Jessica Scott left my kids in Michelle Gilliams local crack house with those crackheads Tony and Michelle.

 

The children’s mother has no family or friends in this country to assist with the children other than her porn fans and prostitution clients and crackhead Michelle Gilliam as she testified to at the 07/13/2023 hearing.

 

The children’s mother has no driver’s license or car and has been caught countless times transporting the children in ubers and letting druggies and prostitution clients transport the children without car seats.

 

The mother was twerking naked making porn videos with the children and has caused the children serious mental health damage as well as threatened the children to not speak to officials about it.

 

My wife physically abuses the children and myself and I would have to restrain her and my daughter testified to this in open court in front of a jury at the criminal trial see Exhibit G

 

I am seriously worried about my children to the point I have not slept much since Thursday 8-24-2023 and been crying while posting online exposing the corruption that has put my children in serious danger from the corrupt system of compulsive lying ALL FEMALES around my wife and her team of liars collecting tax payer funded checks in countless agencies. Here is a youtube channel where I am placing publicly solid evidence and testimony from several witnesses including myself, the children, consolers, police, neighbors and MANY more! I have hundreds of videos I have not even put up yet but please look at what is there so far that Proves the coverups of abuse done by the 14 FEMALES in the courtroom against me in the last hearing including judge Holly Derenthal https://www.youtube.com/@Victimofthesystemofwomen/videos Note that I was the ONLY male involved in this case in the courtroom other than the bailiff and their were 14 females in the courtroom from multiple agencies. I say not a coincidence to say the least.

 

This case is an injunction case that was granted temporally by the honorable MALE judge Michael Snure that knew the family cases and situation very well including the divorce Case Number: 2022 DR 002336 DC and all the misconduct and cover ups by countless FEMALES in state and government agencies including DCF that has libeled , slandered me and filled reports with lies about me that all the bogus false reported DCF cases have been unfounded and closed against me. Also a CPI investigator named Jessica Scott of Kissimmee DCF that signed a sworn affidavit and committed perjury making up false statements about me filled with lies and libel and her and countless other females around my fake domestic violence wife have colluded with each other libeling and slandering me and making up lies not only in DCF reports but all over the place including court files and much more. Furthermore Jessica’s false statements full of libel and lies about me caused judge Madrigal to set me and my lawyer a motion to show case denying a motion we filed over a year ago for emergency child custody because he at first believed her lies but at the hearing when we proved they were lies he not only dismissed the contempt but undenied our motion and set it to hearing and apologized saying he should have known better and that he found DCF to be a widely uncredable and unorganized organization. Judge Holly Derenthal knew all this but proceeded to not only libel and slander me reading the statement of lies and libel in the courtroom and the motion to show cause but when I asked why she didnt read the outcome of the hearing for the motion to show cause that proved DCF lied judge Holly did what she always does and kept shutting me up and silencing the truth. Its VERY clear her bias and the fact she can only silence truth and facts when she is told she is wrong and has no consideration for truth or justice and at Both hearings I have had in front of judge Holly Derenthal have been a complete joke and a total violation of me and my children’s rights I will get into more detail below.

 

1.     Judge Holly Marie Newman Derenthal has denied at least 4 motions to recuse in this case and 3 motions to recuse in my divorce and custody case and I started to file motions to recuse only 5 days into her taking the case after the previous judge Michael Snure that I was very happy with that recused himself due to the other sides lawyers intimidating him in a very shady tactic at and emergency hearing to remove my wifes custody in my divorce case where I was going to win that hearing.

 

The WOMEN around my wife have painted me and accused me of being a women beating sex trafficker because my wife was a prostitute in a whore house in Thailand where I met her and she does adult movies. Both allegations have been laughed out of several courtrooms but they still uses this to gain more FEMALES on their side against me.

 

Holly Derenthal has clearly violated me and my children right to the 5th amendment, 6th amendment,  14th amendment and others, and has a clear bias as well as close relationship with apposing counsel which also raises concerns about impartiality, fairness, and due process in the legal proceedings. I am seeking to file a federal lawsuit against her for this and more.

 

In Florida, as in many jurisdictions, there are rules and ethical standards that judges are expected to uphold to ensure the integrity of the judicial process. Judge Holly Marie Newman Derenthal relationship with opposing counsel is so close that affects their ability to remain impartial, it violates ethical rules and constitutional principles as well.

1.     Florida Code of Judicial Conduct: The Florida Code of Judicial Conduct provides guidance for judges' behavior and conduct. Rule 2.11 of the Code specifically addresses the issue of "Disqualification," which includes instances where a judge's impartiality might reasonably be questioned. If a judge's relationship with opposing counsel is so close that it creates an appearance of bias or impartiality, it could be a violation of this rule.

2.     Due Process: The Due Process Clause of the U.S. Constitution requires that individuals are provided a fair and impartial hearing before a neutral decision-maker. If a judge's close relationship with opposing counsel compromises this impartiality, it could potentially violate a party's right to due process.

3.     Fair Trial Rights: The Sixth Amendment to the U.S. Constitution guarantees the right to a fair trial. If a judge's relationship with opposing counsel affects the fairness of the trial or the perception of a fair trial, it could potentially infringe upon this constitutional right.

4.     State Laws: Many Florida specific laws and regulations address conflicts of interest and potential bias among judges. These laws govern judicial conduct and conflicts of interest in Florida. One of many is Section 38.10, Fla. Stat.

 

5.     Case Law: Previous legal cases and court decisions might offer guidance on situations involving judicial bias, conflicts of interest, and relationships between judges and opposing counsel. There is a clear history not only with the judges bias but her judges assistant and been many instantsis of me accuse them both of bias.

 

 

Holly Derenthal bias is violating several constitutional amendments that protect the rights of parties in legal proceedings. It's important to note that the specific circumstances of the bias and its impact on the proceedings would determine which constitutional amendments are implicated. Here are a few amendments that are relevant:

1.     Sixth Amendment: Right to a Fair Trial: The Sixth Amendment guarantees the right to a fair trial, which includes the right to an impartial judge. A biased judge who favors one party over another could violate this amendment by depriving a party of a fair and impartial trial.

2.     Fourteenth Amendment: Due Process Clause: The Due Process Clause of the Fourteenth Amendment prohibits states from depriving any person of life, liberty, or property without due process of law. A biased judge who demonstrates favoritism or prejudice against a party might violate their right to a fair and unbiased legal process.

3.     Fifth Amendment: Due Process and Equal Protection: While the Fifth Amendment's Due Process Clause is similar to the Fourteenth Amendment's, it also encompasses protections at the federal level. Additionally, the Fifth Amendment's Equal Protection Clause prohibits discrimination in legal proceedings. A biased judge's actions could potentially deny equal protection to one of the parties.

4.     First Amendment: Freedom of Speech and Petition: The First Amendment protects individuals' rights to freedom of speech and to petition the government for redress of grievances. If a biased judge censors or discriminates against a party based on their speech or viewpoints, it could implicate First Amendment rights.

5.     Fourth Amendment: Right to Be Free from Unreasonable Searches and Seizures: While not directly related to judicial bias, a biased judge might affect the outcome of search and seizure cases if their bias impacts their decision-making.

 

I don’t even know where to start about all the clear bias illegal orders and things Holly Derenthal did to me and my children at the last hearing and all the cover ups of the mother abuse and lie lie lie lie lie lie lie lie lie lie lie that EVERY single FEMALE around my wife has done and continues to do and judge Derenthal had the audacity to try and cover the wifes abuse up and call me a liar and try and claim I mad up is sickening and ALL of it needs to be reconsidered, undone, overturned most importantly removing my children and placing them in a serious danger with the mother AND Derenthal’s order for CTP to turn over the video tapes of the forensic child interviews made on

7/17/2023

ORDER ON MOTIONS TO COMPEL CHILD PROTECTION TEAM RECORDS (FILED 7/6/23 AND 7/7/23) 

That CPT violated and to this day and has not turned over the video tapes and instead had a CTP member what I believe is commit perjury and lied under oath claiming the children didn’t make the statements that I have on video now on youtube of detective Suzanne Ellis Clouchete that was inside the child forensic interviews and stated the children did disclose that stuff which is also detailed in my original petition:

“Here is a video of Detective Suzanne Ellis Clouchete talking about what they uncovered in the CTP interviews done on all 3 children last week on 06-28-2023 right after they were completed where she states at 1:54 of the video “he said mom did shake her butt when she was naked and said she was making a video” also at 18:51 of the video I said “he is terrified of mom and mom has told him he is going to be in big trouble” and the detective said : “ well when they asked him are you afraid of anybody he said he is afraid of mom and they said why and he said well like monster or scary movies or monster nightmares that’s what he said like a monster or a nightmare”:

https://www.youtube.com/watch?v=JbCK73fCph0

 

 

Also in her order original order from that first hearing she also demanded a member that was involved with the DCF investigation by present at the final hearing and NOBODY from DCF was present even after I subpoenaed them all because they are scared to come into the courtroom knowing already sent them a intent to sue letter and I am going to embarrass them for all their lies, libel. Slander and perjury. On top of not having the video tapes ordered from CTP to prove my case and DCF not there and countless other reason including not being able to have any of my countless witnesses heard including the child consoler and her 4 reports going back over a year and not being given enough time to properly have subpoenas served ten days with the Sherriff and many more reasons detailed in 2 motions for a continuance that judge Derenthal disregarded there is good reason to reconsidered everything she has illegally done and overturn it all with a different judge. If not I will be forced to file an emergency appeal on the denial of this motion and her final order and many others. Lastly something I just thought of is my wife’s corrupt well connect lawyers Jennifer Jane Watson and Sara Vance that work in that courthouse almost everyday for ALL the victims of domestic violence that come to helpnow have been committing what I believe to be exparte with judge assistant and many others possibly even the judge or should I say more than likely, anyways they had already drafted up a pickup order for the children and other orders to hand to the judge at the end of the hearing that she signed which shows some serious shady stuff going on here as how would they known judge Derenthal was going to outrageously do what she did and remove the children from there safe school and and safe home here with us and give her full temporary custody to a drug addicted prostitute illegal immigrant with no car or license and on and on and on at a hearing that was for an injunction against the mother from the children. Really some dirty corrupt stuff going on behind the curtains that I am going to publicly expose.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

WHEREFORE, the Petitioner prays that this honorable court order as follows:

 

A.     The court when determining weather or not to deny this motion will take into consideration that I am prose and to please if going to deny it only deny it in part that is legally allowed and accept other parts of it and set it to hearing.

B.     The court to appoint a separate judge to oversee and hear this motion and preside at its hearing.

C.     Issue a pickup order and have the children returned immediately to the father and his family and return to their proper safe school they were going to with their sister as that would have been the best thing for the children and still is.

D.     If legally possible any injunction relief against Holly Derenthal but I dont think this is even possible other than through federal court which I plan to file soon.

E.     Hold in contempt anyone and everyone that has covered the abuse from the mother and tried to paint me as a liar or libel me!

F.     Remove Holly Derenthal from my cases if legally possible.

G.     At the hearing when the abuse is proved order a permanent injunction on behalf of the children to the mother.

H.    And any other relief that this court finds appropriate.

 

 

Exhibit A

Description: L:\don phone 5-26-2023\kids\20230228_110123.jpg

Exhibit BDescription: L:\don phone 5-26-2023\kids\20230225_102625.jpg

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Exhibit C

Description: L:\don phone 5-26-2023\kids\20221016_095151.jpg

Exhibit D

Description: L:\don phone 5-26-2023\kids\20220930_172224.jpg

Exhibit EDescription: L:\don phone 5-26-2023\kids\20221001_104438.jpg

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Exhibit F

 

Description: L:\don phone 5-26-2023\kids\20221014_170459.jpg

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Exhibit G

Description: L:\don phone 5-26-2023\kids\20221014_170451.jpg

 

Exhibits E

Description: C:\Users\i7 4ghz\Downloads\michelle gilliam arrest.png

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Exhibit F

Description: C:\Users\i7 4ghz\Downloads\fhjngjgm.png

 

Exhibit G

IN THE COUNTY COURT OF THE NINTH

                                   JUDICIAL CIRCUIT IN AND FOR

           2                       OSCEOLA COUNTY, FLORIDA

 

           3                       CASE NO.: 22-MM-000984

 

           4

 

           5   STATE OF FLORIDA

 

           6             Plaintiff,

 

           7   v.

 

           8   DONALD C. SEOANE,

 

           9            Defendant.

 

          10   * * * * * * * * * * * * * * * * * * * * * * * * * *

 

          11       STENOGRAPHICALLY TRANSCRIBED VIA AUDIO RECORDING

 

          12

               TRIAL BEFORE:     THE HONORABLE HAL C. EPPERSON

          13

               DATE TAKEN:       October 3, 2022

          14

               PLACE:            2 Courthouse Square

          15                     Kissimmee, Florida  34721

 

          16   TRANSCRIBED BY:   FILIZ SERDIO

                                 Court Reporter

          17                     Notary Public, State of Florida

 

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                                                                           2

 

 

 

           1   A P P E A R A N C E S:

 

           2   JODI LILLENAS, ASSISTANT STATE ATTORNEY

               OF:  Osceola County State Attorney's Office

           3        2 Courthouse Square

                    Suite 3500

           4        Kissimmee, Florida  34741

 

           5             APPEARING ON BEHALF OF THE PLAINTIFF

 

           6

               MICHAEL D. MORRISON, ESQUIRE

           7   OF:  Law Office of Michael Morrison, LLC

                    P.O. Box 772607

           8        Orlando, Florida  32877

 

           9             APPEARING ON BEHALF OF THE DEFENDANT

 

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                                                                           3

 

 

 

           1                       C O N T E N T S

 

           2   Proceedings................................................4

 

           3   TESTIMONY OF NANTITA SEOANE

 

           4        Direct Examination by Ms. Lillenas....................4

                    Cross-Examination by Mr. Morrison....................21

           5        Redirect Examination by Ms. Lillenas.................36

 

           6   TESTIMONY OF S SEOANE

 

           7        Direct Examination by Mr. Morrison...................39

                    Cross-Examination by Ms. Lillenas....................44

           8        Redirect Examination by Mr. Morrison.................45

 

           9

 

          10   CERTIFICATE OF TRANSCRIPTION..............................48

 

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          13             THE COURT:  Mr. Morrison, you can call your

 

          14        first witness.

 

          15             MR. MORRISON:  S Seoane, Your Honor.

 

          16             THE COURT:  All right.  S****, if you could

 

          17        come have a seat.

 

          18             Ms. S, again, if you can speak right into

 

          19        the microphone.

 

          20             Mr. Morrison, you can inquire.

 

          21                      DIRECT EXAMINATION

 

          22   BY MR. MORRISON:

 

          23        Q    Hi.  Can you tell us your name?

 

          24        A    S****.

 

          25        Q    Can you tell us your last name?

 

 

 

 

                                                                          40

 

 

 

           1        A    Seoane.

 

           2        Q    Now, I know we just had a conversation with

 

           3   you, and I want to talk to you a little bit about what

 

           4   we talked about.

 

           5        A    Okay.

 

           6        Q    Do you know what a lie is?

 

           7        A    Yes.

 

           8        Q    Can you give me an example of one?

 

           9        A    If I -- if I told you my hair was blue but it

 

          10   was actually red, that would be the lie.

 

          11        Q    Okay.  And what would be the truth if I asked

 

          12   you what your hair color is?

 

          13        A    If my hair was black and it was actually

 

          14   black, then I'm telling the truth.

 

          15        Q    Do you understand the importance of telling

 

          16   the truth here today?

 

          17        A    Yes.

 

          18        Q    And do you promise us that you're gonna tell

 

          19   us the truth?

 

          20        A    Yes.

 

          21        Q    Okay.  I want to talk to you about your

 

          22   family.

 

          23             How many people are in your family right now?

 

          24        A    Three right now, but if the kids come over

 

          25   sometimes it's five.

 

 

 

 

                                                                          41

 

 

 

           1        Q    And who are the kids?

 

           2        A    Anna and Junior.

 

           3        Q    Are those your brother and sister?

 

           4        A    Yes.

 

           5        Q    Now, how long have you known Nantita Seoane?

 

           6        A    Every since I was two.

 

           7        Q    Now, prior to all of this happening, did you

 

           8   believe that she was your biological mother?

 

           9        A    Yes.

 

          10        Q    Have you ever known -- or have you ever seen

 

          11   her try to hurt herself?

 

          12        A    Yes.

 

          13        Q    Can you describe to me what that looks like?

 

          14        A    She would pull her hair and she would punch

 

          15   herself.

 

          16        Q    Did she ever try to reach for any knives?

 

          17        A    Yes.

 

          18        Q    And then what would bring about these

 

          19   episodes?

 

          20        A    Usually arguing.

 

          21        Q    Arguing with who?

 

          22        A    My dad.

 

          23        Q    And do you see your dad in the courtroom

 

          24   today?

 

          25        A    What?

 

 

 

 

                                                                          42

 

 

 

           1        Q    Do you see your dad in the courtroom?

 

           2        A    Yes.

 

           3        Q    Okay.  Now, you mentioned hair pulling,

 

           4   hitting herself, and these fights with your father.

 

           5             Did you ever see your father put his hands on

 

           6   your mother?

 

           7        A    To stop her from hurting herself.

 

           8        Q    Can you tell us exactly what he would do?

 

           9        A    He would try to calm her down so she wouldn't

 

          10   hurt herself.

 

          11        Q    And how would he do that?

 

          12        A    Just, like, calm her down like this.

 

          13        Q    Would he hold on to her?

 

          14        A    Yeah.  She -- he would try to hug her to calm

 

          15   her down and stuff.

 

          16        Q    And what did Nantita Seoane do when your

 

          17   father would try to calm her down?

 

          18        A    She would calm down a little.

 

          19        Q    Then would she lose control again?

 

          20        A    The argument would probably end.

 

          21        Q    Okay.  Can you tell me how many times -- let's

 

          22   say, how many times a week would you see her going

 

          23   through these episodes?

 

          24             MS. LILLENAS:  Objection, Your Honor;

 

          25        speculation.

 

 

 

 

                                                                          43

 

 

 

           1             THE COURT:  Overruled on those grounds.

 

           2   BY MR. MORRISON:

 

           3        Q    You can answer.

 

           4        A    Many times.

 

           5        Q    Was it, like, once a week, once a month?

 

           6        A    Probably a couple times a week.

 

           7        Q    Were they scary?

 

           8        A    Yes.

 

           9        Q    Were you afraid that you would be hurt?

 

          10        A    Yeah.  If she would get mad at me.

 

          11        Q    Now, I want to bring you back to April 27th

 

          12   through the 29th.  And I know it sounds like a random

 

          13   date, but that was when your father was arrested.

 

          14             Do you remember those dates?

 

          15        A    Yes.

 

          16        Q    Now, do you remember your parents, were they

 

          17   arguing?

 

          18        A    They were arguing in the bedroom.

 

          19        Q    Do you remember what they were arguing about?

 

          20        A    No.

 

          21        Q    Did you ever see your father hit your mother?

 

          22        A    No.

 

          23        Q    And I know I called her your mother, I guess,

 

          24   your stepmother.

 

          25        A    No.

 

 

 

 

                                                                          44

 

 

 

           1        Q    Have you ever seen your father hit your

 

           2   mother?

 

           3             MS. LILLENAS:  Objection, Your Honor; asked

 

           4        and answered.

 

           5        A    No.

 

           6             THE COURT:  I'll allow it.

 

           7   BY MR. MORRISON:

 

           8        Q    And aside from your father putting his hands

 

           9   on your stepmother to calm her down, have you ever seen

 

          10   him put her hands on her?

 

          11        A    Say again.

 

          12        Q    Aside from when you told us that your

 

          13   stepfather -- or your father would put his hands on your

 

          14   stepmother to calm her down, aside from that, did you

 

          15   ever see him put her hands on her?

 

          16        A    No.

 

          17             MR. MORRISON:  Okay.  I have no further

 

          18        questions, judge.

 

          19             THE COURT:  State, questions?

 

          20             MS. LILLENAS:  Thank you, Your Honor.

 

          21                      CROSS-EXAMINATION

 

          22   BY MS. LILLENAS:

 

          23        Q    Is it okay if I call you S****?

 

          24        A    Yes.

 

          25        Q    S****, you said a moment ago that you were in

 

 

 

 

                                                                          45

 

 

 

           1   the other room on that day; is that correct?

 

           2        A    Yes.

 

           3        Q    So you weren't in the room with your parents?

 

           4        A    No.

 

           5        Q    So you did not see what happened that day?

 

           6        A    No.  But I was listening.

 

           7        Q    But you didn't see what happened?

 

           8        A    No.

 

           9        Q    And did you see what happened the night

 

          10   before?  Were you in the room with them the whole time?

 

          11        A    No.

 

          12        Q    Did you go next door to talk to the neighbor?

 

          13        A    Yes.

 

          14        Q    And did you have any the neighbor call 911?

 

          15        A    Yes, 'cause she forced me to.

 

          16        Q    So she asked you to go next door, but you did

 

          17   go next door and call -- or have the neighbor call 911?

 

          18        A    Yeah.

 

          19        Q    Okay.  But you did not see what happened?

 

          20        A    No.

 

          21        Q    You just heard arguing?

 

          22        A    Yes.

 

          23             MS. LILLENAS:  Okay.  No further questions,

 

          24        Your Honor.

 

          25             THE COURT:  Any redirect?

 

 

 

 

                                                                          46

 

 

 

           1             MR. MORRISON:  Yes, judge.

 

           2                     REDIRECT EXAMINATION

 

           3   BY MR. MORRISON:

 

           4        Q    Now, you said that she forced you.

 

           5             Who's "she?"

 

           6        A    My stepmom.

 

           7        Q    And how did he force you?

 

           8        A    She was telling me --

 

           9             MS. LILLENAS:  Objection, Your Honor; hearsay.

 

          10             THE COURT:  Overruled; not to prove the truth

 

          11        of the matter asserted.

 

          12        A    She was telling me to go over there, because I

 

          13   was really scared of her because she would beat me up.

 

          14             MS. LILLENAS:  Objection, Your Honor.

 

          15             May we approach?

 

          16             THE COURT:  For what purpose?

 

          17             MS. LILLENAS:  To discuss some matters about

 

          18        what --

 

          19             THE COURT:  All right.  Both counsel approach.

 

          20             (Bench conference.)

 

          21             MR. MORRISON:  May I continue, judge?

 

          22             THE COURT:  You may.

 

          23             MR. MORRISON:  Actually, judge, I think we're

 

          24        finished, judge.

 

          25             THE COURT:  Okay.  Any questions -- actually,

 

 

 

 

                                                                          47

 

 

 

           1        that's direct, cross, and redirect.

 

           2             S****, thank you.  You can return to the

 

           3        hallway.  Thank you.

 

           4             (Transcription of audio concluded.)

 

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           1                 CERTIFICATE OF TRANSCRIPTION

 

           2

 

           3   STATE OF FLORIDA:

 

           4   COUNTY OF POLK:

 

           5

 

           6             I, FILIZ SERDIO, Court Reporter, certify that I

 

           7   was authorized to and did transcribe the audio that was

 

           8   provided to me, and that the foregoing transcript, pages 4

 

           9   through 47, inclusive, are a true and complete record of

 

          10   said audio, to the best of my ability.

 

          11             I further certify that I am not a relative,

 

          12   employee, attorney, or counsel of any of the parties, nor am

 

          13   I a relative or employee of any of the parties' attorneys or

 

          14   counsel connected with the action, nor am I financially

 

          15   interested in the action.

 

          16

 

          17        DATED this 20th day of October 2022.

 

          18

 

          19

 

          20

 

          21

                                   _________________________

          22                       FILIZ SERDIO

                                   Court Reporter

          23

 

 

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