Corrine Brown Support Document From Lawyers Association 4-2-18

Case: 17-15470 Date Filed: 04/02/2018 Page: 1 of 22
Docket No. 17-15470
IN THE
UNITED STATES COURT OF APPEALS
ELEVENTH CIRCUIT
UNITED STATES OF AMERICA,
Appellee,
Direct Criminal Appeal
Middle District of Florida
v.
Lower Case No. 3:16-cr-93-TJC-JRK-1
CORRINE BROWN,
Appellant.
BRIEF OF FLORIDA ASSOCIATION OF CRIMINAL DEFENSE

LAWYERS IN SUPPORT OF APPELLANT
MICHAEL UFFERMAN
Michael Ufferman Law Firm, P.A.
2022-1 Raymond Diehl Road
Tallahassee, Florida 32308
(850) 386-2345/fax (850) 224-2340
FL Bar No. 114227
Email: ufferman@uffermanlaw.com
Chair, FACDL Amicus Committee

B. CERTIFICATE OF INTERESTED PERSONS AND CORPORATE

DISCLOSURE STATEMENT
The following certificate of interested persons and corporate disclosure
statement is provided pursuant to Federal Rule of Appellate Procedure 26.1 and
Eleventh Circuit Rules 26.1-1, 26.1-2, 26.1-3, and 28-1(b):
Andrews, Barbara; victim
Andrews, John; victim
Baker, John D. II; victim
Bentley, A. Lee III; Former United States Attorney
Birk, Edward L.; Counsel for Graham Media Group, Florida, Inc.
Bittel, Stephen; victim
Brown, Corrine; Defendant/Appellant
Brown, Shantrel; Movant
CA Florida Holdings, Inc., dba The Florida Times-Union; Movant
C.A.P. Contracting, Inc.; victim
Caldwell, Leslie; Former Assistant Attorney General, United States Department of
Justice
Charter Communications (ticker symbol: CHTR); victim
Chartrand, Gary; victim
ii
Community Leadership PAC, Inc.; victim
Conner, Timothy, J.; Counsel for CA Florida Holdings, Inc. & Multimedia Holdings
Corporation
Coolican, Michael; Assistant United States Attorney
Corrigan, Honorable Timothy J.; United States District Judge
Cox Media Group Jacksonville; Movant
Cronon, John P.; Acting Assistant Attorney General, United States Department of
Justice
CSX Coirporate Citizenship (ticker symbol: CSX); victim
Delaware North Companies, Inc. Buffalo, NY; victim
DeMaggio, Bryan E.; Former Counsel for Ms. Brown
Duva, Andrew Tysen; Assistant United States Attorney
Fingate, Lonya; victim
Flooring with Dimensions, dba S.L. Gresham Co.; victim
Florida East Coast Industries Company, LLC; victim
Fugate, Rachel E.; Counsel for Cox Media Group Jacksonville
Geraghty, Pat; victim
Glober, Bonnie Ames; Assistant United States Attorney
Graham Media Group, Florida, Inc., dba WJXT-TV4 & News4Jax.com; Movant
iii
Greenpoint Holdings, LLC; victim
Greenspoon Marder; victim
Haas, David L.; Former Counsel for Ms. Brown
Hall, Loretta; victim
Handberg, Roger Bernard III; Assistant United States Attorney
Hoppmann, Karin B.; Assistant United States Attorney
Hulser, Raymond N.; Former Chief, Public Integrity Sections, United States
Department of Justice
Kachergus, Matthew R.; Former Counsel for Ms. Brown
Kent, William Mallory; Appellant Counsel for Ms. Brown
Klindt, Honorable James R.; United States Magistrate Judge
Lazzara, Gaspar; victim
Lipsky, Richard; victim
Lopez, Maria Chapa; United States Attorney
Ludwig Family Foundation; victim
Mansfield, Jennifer A.; Counsel for Multimedia Holdings Corporation & CA Florida
Holdings, Inc.
Marta Employees Charity Club; victim
McFarland, Ryan E., Esquire
iv
Mills, Harry; victim
Mills, Rosa; victim
Muldrow, W. Stephen; Former Acting United States Attorney
Multimedia Holdings Corporation, dba WTLV/WJXX First Coast News; Movant
NeJame, Mark E.; Former Counsel for Ms. Brown
Olshan, Eric; Assistant United States Attorney
Orange Park Mitsubishi; victim
Pajcic & Pajcic; victim
Picerne, John G.; victim
Rhodes, David P.; Assistant United States Attorney, Chief, Appellate Division
Robinson, Sue-Ann N.; Counsel for Shantrel Brown
Sheppard, William J.; Former Counsel for Ms. Brown
Simmons, Elias; Co-defendant
Simply Healthcare Plans, Inc.; victim
Simpson, Allison Kirkwood; Counsel for Cox Media Group Jacksonville
Smith, Daniel Austin; Former Counsel for Mr. Elias Simmons
Smith, James Wesley III; Trial Counsel for Ms. Brown
Stafftime, LLC; victim
Stermon, Kent; victim
v
Suarez, Anthony; Counsel for Mr. Elias Simmons
Tirol, AnnaLou; Acting Chief, Public Integrity Section, United States Department of
Justice
USSC, LLC; victim
Walker, Samuel A.; Trial Counsel for Ms. Brown
Ward, Michael; victim
White, Elizabeth Louise; Former Counsel for Ms. Brown
Wiggins, Janet; victim
Wiggins, Sidney; victim
Wilkison, Jesse B.; Former Counsel for Ms. Brown
CORPORATE DISCLOSURE STATEMENT
Amicus curiae Florida Association of Criminal Defense Lawyers (“FACDL”)
is a non-profit entity. FACDL does not have a parent corporation, and no publicly
held corporation owns ten percent or more of the organization.
vi
C. TABLE OF CONTENTS
Page
A. TITLE PAGE.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i
B. CERTIFICATE OF INTERESTED PERSONS AND CORPORATE

DISCLOSURE STATEMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii
C. TABLE OF CONTENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii
D. TABLE OF CITATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . viii
1. Cases. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . viii
2. Other. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . viii
E. CONSENT OF THE PARTIES TO FILE AN AMICUS BRIEF.. . . . . . . . . 1
F. INTEREST OF AMICUS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
G. STATEMENT OF THE ISSUES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
H. SUMMARY OF ARGUMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
I. ARGUMENT AND CITATIONS OF AUTHORITY. . . . . . . . . . . . . . . . . . 5
J. CONCLUSION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
K. CERTIFICATE OF COMPLIANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
L. CERTIFICATE OF SERVICE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
vii
D. TABLE OF CITATIONS
Page
1. Cases
Allen v. State, 21 S.W.2d 527 (Tex. Crim. App. 1929). . . . . . . . . . . . . . . . . . . . . . 7
Commonwealth v. Perez, 569 N.E.2d 836 (Mass. App. Ct. 1991). . . . . . . . . . . . . . 6
Dickson v. Sullivan, 849 F.2d 403 (9th Cir. 1988). . . . . . . . . . . . . . . . . . . . . . . . . . 8
Marino v. Vasquez, 812 F.2d 499 (9th Cir. 1987). . . . . . . . . . . . . . . . . . . . . . . . . . 8
Morgan v. Illinois, 504 U.S. 719, 112 S. Ct. 2222 (1992). . . . . . . . . . . . . . . . . . . . 5
North v. State, 65 So. 2d 77 (Fla. 1952). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
People v. Hamilton, 60 Cal. 2d 105 (Cal. 1963).. . . . . . . . . . . . . . . . . . . . . . . . 9-10
People v. Morse, 388 P.2d 33 (Cal. 1964). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
People v. Tang, 2002 WL 110582 (Cal. Ct. App. Jan. 28, 2012).. . . . . . . . . . . . . 10
People v. Williams, 940 P.2d 710 (Cal. 1997). . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Riggs v. State, 809 N.E.2d 322 (Ind. 2004). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
State v. Rios, 314 S.W.3d 414 (Mo. Ct. App. 2010).. . . . . . . . . . . . . . . . . . . . . . . . 9
Tanner v. United States, 483 U.S. 107, 107 S. Ct. 2739 (1987).. . . . . . . . . . . . . . . 8
United States v. Hernandez-Escarsega, 886 F.2d 1560 (9th Cir. 1989). . . . . . . 7-8
2. Other
11th Cir. R. 26.1-1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii
11th Cir. R. 26.1-2. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii
viii
11th Cir. R. 26.1-3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii
11th Cir. R. 28-1(b). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii
Fed. R. App. P. 26.1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii
Fed. R. App. P. 29(a)(2). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Fed. R. App. P. 32(a)(7)(C). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
Fed. R. Evid. 606(b). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
ix
E. CONSENT OF THE PARTIES TO FILE AN AMICUS BRIEF
Pursuant to Federal Rule of Appellate Procedure 29(a)(2), undersigned counsel
represents that both parties have consented to FACDL filing an amicus brief in this
case.
1
F. INTEREST OF AMICUS1
FACDL is a statewide organization representing over 1,500 members, all of
whom are criminal defense practitioners. FACDL’s unique body of real world
experience and extraordinary depth and breadth of knowledge and training in the field
of criminal law places it in a position to be of assistance to the Court in the
disposition of the case at hand and in the consideration of its impact on cases in the
future.
1
No party’s counsel authored this brief in whole or in part. No party or party’s
counsel contributed money that was intended to fund preparing or submitting this
brief and no persons contributed money that was intended to fund preparing or
submitting this brief.
2
G. STATEMENT OF THE ISSUES
The district court erred by dismissing Juror Number 13.
3
H. SUMMARY OF ARGUMENT
The district court erred by dismissing Juror Number 13. A criminal defendant
has a constitutional right to a trial by an impartial jury, and the removal of a qualified
juror from the jury panel violates this constitutional right. Seeking guidance from
God does not amount to jury misconduct and is not a basis to remove a juror who is
otherwise qualified to serve.
4
I. ARGUMENT AND CITATIONS OF AUTHORITY
The district court erred by dismissing Juror Number 13.
A criminal defendant has the right to have a qualified juror serve on his or her
case. The unwarranted removal of a juror from a case violates this right – especially
when the removal occurs after deliberations have begun. In this case, Juror Number
13 was simply doing what the vast majority of all jurors– and judges – do in every
single case: seeking guidance from God prior to rendering a decision. Thus, as
explained below, FACDL submits that the district court erred by dismissing Juror
Number 13.
The Constitution guarantees a criminal defendant a trial by an impartial jury.
See Morgan v. Illinois, 504 U.S. 719, 727, 112 S. Ct. 2222, 2228 (1992). As one
court has held, “[o]nce deliberations begin, discharge of a juror is warranted only in
the most extreme situations where it can be shown that the removal of the juror is
necessary for the integrity of the process, does not prejudice the deliberations of the
rest of the panel, and does not impair the parties right to a trial by jury.” Riggs v.
State, 809 N.E.2d 322, 327-328 (Ind. 2004) (emphasis added). See also People v.
Williams, 940 P.2d 710, 763 (Cal. 1997) (“Before a trial court may excuse a juror for
inability to perform the juror’s functions, that inability must appear in the record as
a demonstrable reality.”) (internal quotation and citation omitted). Another court has
5
explained that
The discharge of a deliberating juror is a sensitive undertaking and is

fraught with potential for error. It is to be done only in special
circumstances, and with special precautions. . . . The trial court has at
most a limited discretion to determine that the facts show an inability to
perform the functions of a juror, and that inability must appear in the
record as a demonstrable reality.
Commonwealth v. Perez, 569 N.E.2d 836, 837 (Mass. App. Ct. 1991) (internal
quotation and citation omitted).
As stated above, Juror Number 13 was simply doing what the vast majority of
all jurors do in every single case – seeking guidance from God prior to rendering a
decision. The freedom to exercise one’s religion is one of the bedrock principles
upon which this country was founded. The law does not require that jurists leave
their faith at the courthouse doors. Every day in this country, jurors are asked to
render decisions in criminal and civil trials in state and federal courtrooms, and a
substantial portion of those jurors seek guidance from their Creator when making
these tough decisions (just as they do when making every other important decision
in their lives). Removing a juror simply because the juror seeks guidance from God
violates the right of a criminal defendant to have qualified jurors resolve a case
without unwarranted judicial intervention.
Courts in this country have rejected the argument that error has occurred after
it was discovered that jurors in a case sought guidance from God. For example, in
6
Allen v. State, 21 S.W.2d 527, 528-529 (Tex. Crim. App. 1929), the court held that
there was no basis to set aside the verdict simply because the jurors prayed for divine
guidance before discussing the case or taking a vote:
With reference to the allegation as to the prayer, the record shows

that E. B. Gude was elected foreman; that the jury finally voted ten for
the death penalty and two for a penitentiary sentence and the Gude was
one of these two; that immediately after Gude was elected foreman, and
before any discussion of the case by the jury occurred, and long before
any vote was taken, he called for a prayer. Juror O’Brien described the
scene as follows: “You could have heard a pin drop I guess, all was
quiet in a moment or two. Gude took his hands from his eyes and there
were tears in his eyes. That is what occasioned the remark . . . and Mr.
Gude called for the prayer. Mr. Gude, the words he used in calling for
the prayer was, ‘I want us to pray’ . . . The prayer was for divine
guidance.”
This was the only prayer offered. The record not only fails
altogether to sustain the allegations of the motion setting up this matter,
but it was affirmatively shown that nothing of a prejudicial nature
occurred during said prayer. It will be noted that Gude himself called
for it. The prayer does not appear to have been used as a Pharisaical
cloak to cover an argument against appellant.
In the state of this record we are of the opinion that no possible
injury could have happened to appellant from such proceedings.
(Emphasis added).
More recently, a court refused to set aside a verdict based on the allegation that
a juror based her verdict on a “sign from God,” concluding that such a matter is
“intrinsic” rather than “extrinsic”:
After the verdict was returned, Hernandez filed a motion for new
trial based upon the affidavit of Audrey Giles, one of the jurors in the
7
case. In her affidavit, Giles states that on the final morning of the jury’s
deliberations one of the other jurors commented that she hoped a third,
unnamed juror would wear his blue blazer that day. After the jury
reached its verdict, Giles was told the following: (1) that one of the
jurors had prayed to God that another juror, Walter Geudtner, would
change his vote from not-guilty to guilty; (2) that this juror had asked for
and received a sign from God that her prayers had been heard and that
Mr. Geudtner would change his vote; and (3) that the sign would be that
Mr. Geudtner would be wearing his blue blazer to court on a particular
day. Hernandez claims that the introduction of this “sign from God”
into the jury deliberations impermissibly tainted the verdict. He asked
for an evidentiary hearing so that this matter could be explored further,
but the district court denied his request.
“A defendant is entitled to a new trial when the jury obtains or
uses evidence that has not been introduced during trial if there is ‘a
reasonable possibility that the extrinsic material could have affected the
verdict.’” Dickson v. Sullivan, 849 F.2d 403, 405 (9th Cir. 1988)
(quoting Marino v. Vasquez, 812 F.2d 499, 504 (9th Cir. 1987)). Rule
606(b) of the Federal Rules of Evidence, however, prohibits the use of
juror testimony to impeach a verdict when that testimony relates to
intrinsic matters – that is, the internal, mental processes by which the
verdict was reached. See Tanner v. United States, 483 U.S. 107, 116-
127, 107 S. Ct. 2739, 2745-2751 (1987). Whether the juror was literally
inside or outside the jury room when the irregularity occurred has no
bearing on the determination that a particular influence was external or
internal. Id. at 117, 107 S. Ct. at 2746.
In the present case, the district court did not err in refusing to hold
an evidentiary hearing on the sign-from-God matter. All that has been
alleged is that one of the jurors used prayer and a belief in a sign from
God as part of her mental process. Nothing in the declaration indicates
that any of the other jurors were told or became aware that a sign from
God would be manifested in one juror’s wearing a blue blazer while they
were still deliberating. Thus, the affidavit does not establish that the
verdict was improperly influenced by an extrinsic matter. In such
circumstances, an evidentiary hearing was unnecessary.
United States v. Hernandez-Escarsega, 886 F.2d 1560, 1579 (9th Cir. 1989)
(emphasis added) (footnote omitted).

8
Finally, in North v. State, 65 So. 2d 77 (Fla. 1952), the court found no juror
misconduct where a preacher met with the jury at breakfast and prayed, “God, give
these men your divine guidance in their duties.” At the conclusion of the opinion, the
court stated the following:
The oath of every officer of this State, from Governor to

Constable, concludes with the words ‘So help me God.’ The oath of the
juror concludes with the same words. Those who do not believe in the
existence of a Deity may affirm instead of taking the oath. To most of
us, everything around us proclaims and is evidence of the existence of
a Divine Being. After having taken the oath, concluding with the words,
‘So help me God,’ it was natural that the jurors would, of their own free
will and accord, ask a preacher to Grace the table and to read a passage
from the Bible. It was not reversible error for the preacher to respond
and read a Psalm and pray for ‘Divine guidance.’ The scripture reading
and prayer did not constitute harmful or reversible error in this case.
North, 65 So. 2d at 101. As in North, in the instant case, Juror Number 13 was not
guilty of misconduct for seeking “Divine guidance.” See also State v. Rios, 314
S.W.3d 414, 418 (Mo. Ct. App. 2010) (finding no error in a case where a juror
“commented that she was confident that by virtue of her prayers, God was leading her
in the right direction”).
“While it has been said repeatedly . . . that a defendant is not entitled to be tried
by a jury composed of any particular individuals, but only by a jury composed of
qualified and impartial jurors, this does not mean that either side is entitled to have
removed from the panel any qualified and acting juror who, by some act or remark
9
made during the trial, has given the impression that he favors one side or the other.”
People v. Hamilton, 60 Cal. 2d 105, 128 (Cal. 1963), overruled on other grounds in
People v. Morse, 388 P.2d 33 (Cal. 1964). “It is obvious that it would be error to
discharge a juror for such a reason, and that, if the record shows (as it does here), that,
based on the evidence, that juror was inclined toward one side, the error in removing
such a juror would be prejudicial to that side.” Id. “The erroneous removal of a juror
at the behest of the prosecution and over the objections of the defense after the juror
has made a comment that might be viewed as sympathetic to the defense is clearly
prejudicial and requires reversal of the judgment.” People v. Tang, 2002 WL 110582
at *13 (Cal. Ct. App. Jan. 28, 2012) (unreported). In the instant case, Appellant
Brown was prejudiced by the erroneous removal of Juror 13.
Accordingly, for the reasons set forth above, the district court erred by
dismissing Juror Number 13.
10
J. CONCLUSION
The appropriate remedy is reversal of Appellant Brown’s conviction and
sentence and a remand with directions that the district court conduct a new trial.
11
K. CERTIFICATE OF COMPLIANCE
Undersigned counsel hereby certifies pursuant to Federal Rule of Appellate
Procedure 32(a)(7)(C) that this brief complies with the type-volume limitation. The
number of words in this brief is approximately 3,081.
12
L. CERTIFICATE OF SERVICE
I HEREBY CERTIFY a true and correct copy of the foregoing instrument has
been furnished to:
Assistant United States Attorney David P. Rhodes

Chief, Appellate Division
400 North Tampa Street, Suite 3200
Tampa, Florida 33602
William Mallory Kent, Esquire

24 North Market Street, Suite 300
Jacksonville, Florida 32202
by U.S. mail delivery this 2nd day of April, 2018.
Respectfully submitted,
/s/ Michael Ufferman

MICHAEL UFFERMAN
Michael Ufferman Law Firm, P.A.
2022-1 Raymond Diehl Road
Tallahassee, Florida 32308
(850) 386-2345/fax (850) 224-2340
FL Bar No. 114227
Email: ufferman@uffermanlaw.com
Chair, FACDL Amicus Committee
13

Corrine Brown Support Document From Lawyers Association 4-2-18

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Case: 17-15470 Date Filed: 04/02/2018 Page: 1 of 22

Docket No. 17-15470

UNITED STATES COURT OF APPEALS

UNITED STATES OF AMERICA,

BRIEF OF FLORIDA ASSOCIATION OF CRIMINAL DEFENSE

Chair, FACDL Amicus Committee

B. CERTIFICATE OF INTERESTED PERSONS AND CORPORATE

The following certificate of interested persons and corporate disclosure

statement is provided pursuant to Federal Rule of Appellate Procedure 26.1 and

Eleventh Circuit Rules 26.1-1, 26.1-2, 26.1-3, and 28-1(b):

Andrews, Barbara; victim

Andrews, John; victim

Baker, John D. II; victim

Bentley, A. Lee III; Former United States Attorney

Bittel, Stephen; victim

Brown, Corrine; Defendant/Appellant

Brown, Shantrel; Movant

CA Florida Holdings, Inc., dba The Florida Times-Union; Movant

C.A.P. Contracting, Inc.; victim

Caldwell, Leslie; Former Assistant Attorney General, United States Department of

Charter Communications (ticker symbol: CHTR); victim

Chartrand, Gary; victim

Community Leadership PAC, Inc.; victim

Coolican, Michael; Assistant United States Attorney

Corrigan, Honorable Timothy J.; United States District Judge

Cox Media Group Jacksonville; Movant

CSX Coirporate Citizenship (ticker symbol: CSX); victim

Delaware North Companies, Inc. Buffalo, NY; victim

DeMaggio, Bryan E.; Former Counsel for Ms. Brown

Duva, Andrew Tysen; Assistant United States Attorney

Fingate, Lonya; victim

Flooring with Dimensions, dba S.L. Gresham Co.; victim

Florida East Coast Industries Company, LLC; victim

Fugate, Rachel E.; Counsel for Cox Media Group Jacksonville

Geraghty, Pat; victim

Glober, Bonnie Ames; Assistant United States Attorney

Greenpoint Holdings, LLC; victim

Greenspoon Marder; victim

Haas, David L.; Former Counsel for Ms. Brown

Hall, Loretta; victim

Handberg, Roger Bernard III; Assistant United States Attorney

Hoppmann, Karin B.; Assistant United States Attorney

Kachergus, Matthew R.; Former Counsel for Ms. Brown

Kent, William Mallory; Appellant Counsel for Ms. Brown

Klindt, Honorable James R.; United States Magistrate Judge

Lazzara, Gaspar; victim

Lipsky, Richard; victim

Lopez, Maria Chapa; United States Attorney

Ludwig Family Foundation; victim

Marta Employees Charity Club; victim

McFarland, Ryan E., Esquire

Mills, Harry; victim

Mills, Rosa; victim

Muldrow, W. Stephen; Former Acting United States Attorney

Multimedia Holdings Corporation, dba WTLV/WJXX First Coast News; Movant

NeJame, Mark E.; Former Counsel for Ms. Brown

Olshan, Eric; Assistant United States Attorney

Orange Park Mitsubishi; victim

Pajcic & Pajcic; victim

Picerne, John G.; victim

Robinson, Sue-Ann N.; Counsel for Shantrel Brown

Sheppard, William J.; Former Counsel for Ms. Brown

Simmons, Elias; Co-defendant