Motion to Intervene in Criminal Case in Florida

IN THE COUNTY COURT OF THE SEVENTH JUDICIAL CIRCUIT,
IN AND FOR ST. JOHNS COUNTY, FLORIDA

CITY OF ST. AUGUSTINE,

vs. Case No.: 07000010MOMA
DIVISION: 65

MERRILL ROLAND,
Defendant.
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WRITER’S MOTION TO INTERVENE, WITH
INCORPORATED MEMORANDUM OF LAW

COME NOW, the private citizen and writer, Dwight E. Hines, hereinafter referred to as “Intervenor Hines”, who has a direct and immediate interest in subordinate issues in the instant case, issues that will be effected by the Judgments of the Court, to NOTICE filings with the Court for a limited appearance before the Court, pursuant to Article I, s. 24, Article V, s. 2, Florida State Constitution; Chapter 119, Fla. Stat. (Florida Open Records Act); Rule 2.420, Fla.R.Jud.Admin.; Florida Common Law (Barron v. Florida Freedom Newspapers, Inc., 531 So.2d 113 (Fla. 1988)); the First, Sixth, and Fourteenth Amendments to the United States Constitution; and Chapter 69.081(6), Fla. Stat. (2007), to move the Court, to Order Invervenor Hines to intervene in this case.

Because the City of St. Augustine departments and agencies are inextricably intertwined in their computer information systems, and other services, with the St. Augustine Police Department, Intervenor Hines will move the Court, to Order that all City of St. Augustine departments and agencies comply completely and accurately with Rule 1B-26.003, F.A.C.

The Sworn Affidavit of Writer Dwight Hines’ Limited Interest in “The City of St. Augustine v. Merrill Roland” and the Sworn Affidavit of Dwight Hines on St. Augustine Police Department’s Failures to Comply with Rule 1B-26.003, F.A.C.; Chapter 119, Fla.Stat. (2007), and Chapter 943.081, Fla. Stat. (2007), are attached and provide factual, verifiable information for this Writer’s Motion to Intervene.