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Record on Appeal IN THE DISTRICT COURT OF APPEAL OF FLORIDA FIRST DISTRICT CASE NO: 2015 CA 1423: 2015 CA 2682 DCA NO: 1D18-3141 RICHARD CORCORAN, SPEAKER OF THE FLORIDA HOUSE OF REPRESENTATIVES; JOE NEGRON, PRESIDENT OF THE FLORIDA SENATE, APPELLANT, V. FILED FTP ON: FLORIDA WILDLIFE FEDERATION, INC, ET AL, FLORIDA DEFENDERS OF THE ENVIRONMENT, INC, ET AL, APPELLEE, RECORD ON APPEAL FROM THE CIRCUIT COURT OF LEON COUNTY, FLORIDA RECEIVED, 11/21/20189:00AM,Kristina Samuels,FirstDistrict CourtofAppeal HONORABLE CHARLES DODSON ANDY BARDOS, ESQ ALISA COE, ESQ JAMES T. MOORE, JR, ESQ BRADLEY MARSHALL, ESQ ASHLEY HOFFMAN LUKIS, ESQ 111 S. MARTIN LUTHER KING JR BLVD P. O. BOX 11189 TALLAHASSEE, FL 32301 TALLAHASSEE, FL 32302 DAVID G. GUEST, ESQ GEORGE N. MEROS, JR, ESQ 525 WEST 8TH AVE 315 S. CALHOUNST, SUITE 600 TALLAHASSEE, FL 32303 TALLAHASSEE, FL 32301 JOSPEH W. LITTLE, ESQ 3731 NW 13TH PLACE GAINESVILLE, FL 32605 ATTORNEY FOR APPELLANT ATTORNEY FOR APPELLEE RICHARD CORCORAN, SPEAKER OF THE FLORIDA HOUSE OF REPRESENTATIVES vs. FLORIDA WILDLIFE FEDERATION, INC LT. CASE NO: 2015 CA 002682 HT. CASE NO: 1D18-3141 DECEMBER 11, 2015 NOTICE OF SEVING AMENDED COMPLAINT 7658 - 7659 JANUARY 20, 2016 NOTICE OF RELATED CASE SUPPLEMENT TO CIVIL COVER 7660 - 7662 SHEET MAY 01, 2018 NOTICE OF APPEARANCE FILED 7663 - 7666 JUNE 13, 2018 FDE PLAINTIFFS' MOTION FOR JUDICIAL NOTICE 7667 - 7697 JULY 17, 2018 FDE PLAINTIFFS' RESPONSE TO LEGISLATURE’S AMENDED 7698 - 7700 MOTION FOR REHEARING NOVEMBER 20, 2018 CERTIFICATE 7701 RICHARD CORCORAN, SPEAKER OF THE FLORIDA HOUSE OF REPRESENTATIVES vs. FLORIDA WILDLIFE FEDERATION, INC LT. CASE NO: 2015 CA 002682 HT. CASE NO: 1D18-3141 Filing# 35437477 E-Filed 12/11/2015 11 :33:51 AM THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT OF FLORIDA IN AND FOR LEON COUNTY FLORIDA ~'LORI.DA DEFENDERS OF THE ENVIRONMENT, INC., STEPHEN J. ROBITAILLE, JOSEPll W. LITTLE, JAMES P. CLUGSTON, LOLA HASKINS, S'IEPHEN M. HOLLAND, and \V. THOMAS HAWKlNS, Plaintiffs Case No. 2015 CA 2682 v. KEN DETZNER, in his official capacity as Secretary of State of Florida and Head of the Florida Department of State, ADAM H. PUTNAM, in his official capacity as Florida Commissioner of Agriculture and Head of the Department of Agriculture and Consumer Services, NICK WILEY, in his official capacity as Executive Director of the Florida Fish and Wildlife Conservation Commission, and JONATHAN P. STEVERSON, in his official capacity as SecretaQ· ofHorida Department of Environmental Protection and Head of the .Florida Department of Environmental Protection, Detc~ndants. NOTICE 01" SERVING FIRST AMENDED COMPLAINT Notice is given that the First Amended complaint has been served on the following: John W. Costigan, Assistant (Deputy) General Counsel, Office of General Counsd, Florida Department of Agriculture and Consumer Services; Harold "Bud" G. Vielhauer, General CounseL Florida Fish and Wildlife Conservation Commission; Robert A. Williams, Chief Deputy General Counsel, Department of Environmental Protection; and David A. Fugett, Assistant General Counsel, Florida Department of State representing the named defendants in this -J - 7658 RICHARD CORCORAN, SPEAKER OF THE FLORIDA HOUSE OF REPRESENTATIVES vs. FLORIDA WILDLIFE FEDERATION, INC LT. CASE NO: 2015 CA 002682 HT. CASE NO: 1D18-3141 action. Plaintiffs' Notice of Constitutional Question has also been served upon the named persons. CER1'lFICATE OF SERVICE l certify thar a copy of this notice with copy of the amended complaint was served upon Da_0d,I::\1.g~:tt(a)dos.rnyiJ.9dda.cont, John.Oy;Ugan(ci>Fn~~;l1.FmmFlorid~1.co111, Robcn.A.\:ViUiarns{ri)dcp._il;.ill&JL_us_, and bJ.1d.vielhauer(q;JJ1yfwc.corn on this 11th day of December 2015 on the same:~'.}✓...•= I Ll-~~------ c~(;leph W. Little ··-·- r.Lwyer for Plaintiffs Fla. Bar No. 196749 3731 NW 13th Place Gainesville, Fl. 32605 352-372-5955 littlegnv(i~gmail.com -2- 7659 RICHARD CORCORAN, SPEAKER OF THE FLORIDA HOUSE OF REPRESENTATIVES vs. FLORIDA WILDLIFE FEDERATION, INC LT. CASE NO: 2015 CA 002682 HT. CASE NO: 1D18-3141 Filing# 36774499 E-Filed 01/20/2016 02: 15:47 PM IN THE CIRCUIT COURT OF THE SECOND JUDICIAL ClRCUIT IN AND FOR LEON COUNTY, FLORIDA FLORIDA DEFENDERS OF THE ENVlRONMENT, INC, STEPHEN J. ROBITAILLE, JOSEPHW. LITTLE, JAMES P. CLUGSTON, LOLA HASKINS, STEPHEN M. HOLLAND, and W. THOMAS HAWKINS, Plaintiffs, v. CASE NO.: 2015 CA 2682 KEN DETZNER, in his official capacity as Secretary ofState ofFlorida and Head of the Florida Department of State, ADAM H. PUTNAM, in his official capacity as Florida Commissioner of Agriculture and Head of the Department ofAgriculture and Consumer Services, NICK WILEY, in his official capacity as Executive Director of the Florida Fish and Wildlife Conservation Commission, and JONATHAN P. STEVERSON, in his official capacity as Secretary of Florida Department of Environmental Protection and Head of the Florida Department of Environmental Protection, Defendants. _______________ __;/ NOTICE OF RELATED CASE SUPPLEMENT TO CIVIL COVERSHEET In accordance with Florida Rules of Civil Procedure 1.100(c )(2), Defendant, JONATHAN P. STEVERSON, by and through his undersigned counsel, respectfully notices this Court of the supplemental information regarding Plaintiff's notice ofrelated case Florida Wildlife Federation v. Gardner. Counsel submits the following supplemental fofonnation. Case No.: 2015 CA 001423 Court: Second Judicial Circuit in and for Leon County, Florida Presiding Judge; Honorable George S. Reynolds, HI 1 \ Last Action: Hearing on Defendants' Motion to Dismiss December 3, 2015 - Granted in Part 7660 RICHARD CORCORAN, SPEAKER OF THE FLORIDA HOUSE OF REPRESENTATIVES vs. FLORIDA WILDLIFE FEDERATION, INC LT. CASE NO: 2015 CA 002682 HT. CASE NO: 1D18-3141 The case of Florida Wildlife Federation V; Gardner, nearly identical in nature and intent as this more recently filed action dealing with the Florida Legislature's 2015 appropriations of funds, Chapter 2015-232, Laws of Florida, from Land Acquisition Tmst Fund to various governmental bodies to fulfill the intent of Article X, of the Florida Constitution, more commonly referred to as Amendment l. Notably, both cases seek the clarification of rights through Actions for Dedaratory Jud1:,1111ent and seek injunctions against further expenditure of unspent funds appropriated through Chapter 2015-212, Lrnvs of Florida. In fact, Plaintiffs in this case contest seventy-two (72) of the seventy-five (75) appropriations contested by Florida Wildlife Federation, adding only thirty (30) additional line items to their cause as being a!legedl y unconstitutional appropriations of fonds designated for the land Acquisition Trust Fund Amendment 1. Respectfully submitted this 691h day ofJanuary 2016. STATE OF FLORIDA DEPARTMENT OF Et-.1VIRONMENTAL PROTECTION _,/'" .,-;::;if J --=:::~ /;z;;¼✓ -:,..:'=✓~fl4:-/~==,'--·· _____ Tom B. Ad.fros III Assistant General Counsel FBN: 115317 3900 Commoirwealth Boulevard, MS 35 Tallahassee, Florida 32399-3000 Telephone; (850) 245-2294 Facsimile: (850) 245-2298 Primary: Thomas.Adamsfri;dep.state. fl.us Secondary: Loi:::an. Whiddon(Zi>dep.state.fl.1Jii 2 7661 RICHARD CORCORAN, SPEAKER OF THE FLORIDA HOUSE OF REPRESENTATIVES vs. FLORIDA WILDLIFE FEDERATION, INC LT. CASE NO: 2015 CA 002682 HT. CASE NO: 1D18-3141 CERTIFICATE O _F SERVICE I HEREBY CERTIFY that true and correct copy of the foregoing has been furnished electronically through the Florida Courts E-filing Portal to Joseph W. Little, Attorney for the Plaintiffs, P .0. Box 11 GainesviUe, Florida 32611, at [email protected], David A. Fugett, Florida Department of State, R.A. Building, Suite 100, 500 South Bronough Street, Tallahassee, Florida 32399, at david.fogett(i1)dos.mytlorida.com, Harold Vielhauer, Florida Fish and Wildlife Conservation Commission, 620 South Monroe Street, Tallahassee, Florida 32399, at BucLVielhauer(d;myfwc.com, Steven HaU and .John Costigan, Florida Department of Agriculture and Consumer Services, The Mayo Building, 407 South Calhoun Street, Suite 520, Tallahassee, Florida 32399, at Steven.Hall(iufreshFromFlorida.com and Jolm.Costigarn?i~FreshFromFlorida.com on this 20th day ofJanuary 2016. STATE OF FLORIDA DEPARTMENT OF ENVIRONMENTAL//27 PROTECTJON ',#""~~= ~:::~ ,....,./-/;. L,/U''' f/~/ Tom B. Adams rn Assistant General Counsel 3 7662 RICHARD CORCORAN, SPEAKER OF THE FLORIDA HOUSE OF REPRESENTATIVES vs. FLORIDA WILDLIFE FEDERATION, INC LT. CASE NO: 2015 CA 002682 HT. CASE NO: 1D18-3141 Filing# 71534304 E-Filed 05/01/2018 06: 10:29 PM IN THE CIRCUIT COURT FOR THE SECOND JUDICIAL CIRCUIT IN AND FOR LEON COUNTY, FLORIDA CIVIL CIRCUIT DIVISION FLORIDA WILDLIFE FEDERATION, INC., et al., Plaintiffs, Case No. 2015-CA-001423 v. JOE NEGRON, as President of the Florida Senate, et al., Defendants. ----------------I FLORIDA DEFENDERS OF THE ENVIRONMENT, INC., et al., Plaintiffs, Case No. 2015-CA-002682 v. KEN DETZNER, in his official capacity as Florida Secretary of State, et al., Defendants. ----------------I NOTICE OF APPEARANCE James Timothy Moore, Jr. ofGrayRobinson, P.A., hereby files this Notice of Appearance as co-counsel for Defendants, the President of the Florida Senate, the Speaker of the Florida House of Representatives, and the Florida Legislature, and requests to be furnished with copies of all future orders, pleadings, and other documents to be filed or served in this matter at: Primary Email: [email protected] Secondary Email: [email protected] [email protected] \271018\1 - # 951255 vi 1 7663 RICHARD CORCORAN, SPEAKER OF THE FLORIDA HOUSE OF REPRESENTATIVES vs. FLORIDA WILDLIFE FEDERATION, INC LT. CASE NO: 2015 CA 002682 HT. CASE NO: 1D18-3141 DATED THIS 1st day of May, 2018. Respectfully submitted, Isl James Timothy Moore. Jr. James Timothy Moore, Jr. (FBN 70023) GRAYROBINSON, P.A. Post Office Box 11189 Tallahassee, Florida 32302 Telephone: 850-577-9090 Facsimile: 850-577-3311 Email: [email protected] Attorneys for Defendants, the Florida Legislature, Senate President Joe Negron, and Speaker Richard Corcoran \271018\1 - # 951255 vi 2 7664 RICHARD CORCORAN, SPEAKER OF THE FLORIDA HOUSE OF REPRESENTATIVES vs. FLORIDA WILDLIFE FEDERATION, INC LT.
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