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Author Topic: Haleigh Marie Cummings #37 5/24/10 - 7/15/10  (Read 314121 times)
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Jerseygirl345
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« Reply #960 on: June 29, 2010, 08:03:36 PM »

Example of motion..

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
FOR HILLSBOROUGH COUNTY, FLORIDA
CRIMINAL JUSTICE DIVISION
STATE OF FLORIDA
v.
[Defendant]
CASE NUMBER: [CASE #]
DIVISION: [DIVISION]
DEFENDANT’S / STATE’S MOTION FOR CONTINUANCE
The Defendant / State moves for a continuance pursuant to Florida Rule of Criminal
Procedure 3.190(g), and states the following reason(s) as good cause for the request to continue:
[ ] Defense / State not sufficiently prepared for trial.
[ ] Illness of a witness or other party.
[ ] Illness of an attorney for the party.
[ ] Unavailability of a witness or attorney.
[ ] Untimely disclosure of a witness or other discovery information.
[ ] Defense / State inability to depose a witness or victim prior to trial.
[ ] Defendant’s competency to proceed at issue.
[ ] Appointment of regional / conflict counsel upon the public defender’s withdrawal.
[ ] Appointment of public defender upon private counsel’s withdrawal.
[ ] _________________________________________________________
If Defendant is moving for a continuance, counsel has consulted with the Defendant who
has no objection and understands that speedy trial is waived if this motion is granted.
I CERTIFY this motion is made in good faith and that a copy of the motion has been
furnished to [ASA], Assistant State Attorney, Office of the State Attorney, [State Attorney’s
address] or [Defense Counsel], Law Office of [Defense Counsel], [Defense Counsel’s address]
on the _____ day of August, 2008.
___________________________________________
ATTORNEY NAME, Florida Bar # [BAR #]
Law Office of [Defense Counsel] / State Attorney’s Office
[Address]
[City], Florida [ZIP CODE]
(813) [telephone number] (telephone); (813) [facsimile number] (fax)
------------
ORDER DENYING / GRANTING MOTION FOR CONTINUANCE
Having heard and considered the Defendant’s / State’s Motion for Continuance, it is
ORDERED that the Motion for Continuance is
[ ] DENIED.
[ ] GRANTED. The non-moving party [ ] objects [ ] does not object.
DONE AND ORDERED in Tampa, Hillsborough County, Florida on this ______ day of
August, 2008.
___________________________________
Copies furnished to: [JUDGE], CIRCUIT COURT JUDGE
[Defense Counsel], Law Office of [Defense Counsel] AND [ASA], Office of the State Attorney

http://www.fljud13.org/pdfs/ContinuanceFormMotionandOrder.pdf
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Heart
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« Reply #961 on: June 29, 2010, 08:44:47 PM »


Lillymae said,
in June 29th, 2010 at 7:42 pm

CUMMINGS, RONALD LEMYLES
Case Status: TRIAL

UCN: 542010CF000145XXAXMX
06/28/2010 43 MOTION TO CONTINUE

UCN: 542010CF000144XXAXMX
06/28/2010 45 MOTION FOR CONTINUANCE

UCN: 542010CF000146XXAXMX
06/28/2010 45 MOTION FOR CONTINUANCE

UCN: 542010CF000253XXAXMX
06/28/2010 45 MOTION FOR CONTINUANCE

UCN: 542010CF000254XXAXMX
06/28/2010 45 MOTION FOR CONTINUANCE
http://www.putnam-fl.com/clk_apps/crim_dkts/frame.php
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« Reply #962 on: June 29, 2010, 09:23:25 PM »

Example of motion..

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
FOR HILLSBOROUGH COUNTY, FLORIDA
CRIMINAL JUSTICE DIVISION
STATE OF FLORIDA
v.
[Defendant]
CASE NUMBER: [CASE #]
DIVISION: [DIVISION]
DEFENDANT’S / STATE’S MOTION FOR CONTINUANCE
The Defendant / State moves for a continuance pursuant to Florida Rule of Criminal
Procedure 3.190(g), and states the following reason(s) as good cause for the request to continue:
[ ] Defense / State not sufficiently prepared for trial.
[ ] Illness of a witness or other party.
[ ] Illness of an attorney for the party.
[ ] Unavailability of a witness or attorney.
[ ] Untimely disclosure of a witness or other discovery information.
[ ] Defense / State inability to depose a witness or victim prior to trial.
[ ] Defendant’s competency to proceed at issue.
[ ] Appointment of regional / conflict counsel upon the public defender’s withdrawal.
[ ] Appointment of public defender upon private counsel’s withdrawal.
[ ] _________________________________________________________
If Defendant is moving for a continuance, counsel has consulted with the Defendant who
has no objection and understands that speedy trial is waived if this motion is granted.
I CERTIFY this motion is made in good faith and that a copy of the motion has been
furnished to [ASA], Assistant State Attorney, Office of the State Attorney, [State Attorney’s
address] or [Defense Counsel], Law Office of [Defense Counsel], [Defense Counsel’s address]
on the _____ day of August, 2008.
___________________________________________
ATTORNEY NAME, Florida Bar # [BAR #]
Law Office of [Defense Counsel] / State Attorney’s Office
[Address]
[City], Florida [ZIP CODE]
(813) [telephone number] (telephone); (813) [facsimile number] (fax)
------------
ORDER DENYING / GRANTING MOTION FOR CONTINUANCE
Having heard and considered the Defendant’s / State’s Motion for Continuance, it is
ORDERED that the Motion for Continuance is
[ ] DENIED.
[ ] GRANTED. The non-moving party [ ] objects [ ] does not object.
DONE AND ORDERED in Tampa, Hillsborough County, Florida on this ______ day of
August, 2008.
___________________________________
Copies furnished to: [JUDGE], CIRCUIT COURT JUDGE
[Defense Counsel], Law Office of [Defense Counsel] AND [ASA], Office of the State Attorney

http://www.fljud13.org/pdfs/ContinuanceFormMotionandOrder.pdf

I wonder what the reason is for the continuance request JG?   
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Jerseygirl345
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« Reply #963 on: June 29, 2010, 11:12:23 PM »

Snipped from Heart

 I wonder what the reason is for the continuance request JG?

1.Maybe Ron is going to make a better plea deal 
2.GGRanny might be in Las Vegas on that date
 
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GramaMonkey
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« Reply #964 on: June 30, 2010, 09:00:01 AM »

Snipped from Heart

 I wonder what the reason is for the continuance request JG?

1.Maybe Ron is going to make a better plea deal 
2.GGRanny might be in Las Vegas on that date
 


   They need more time to find a way to get Ronnie off!!!!!!
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Heart
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« Reply #965 on: June 30, 2010, 09:48:33 PM »

JAMES  MICHAEL  HOBERG
SATSUMA,  FL
Booking Date & Time: 6/29/2010 1:05:00 AM  - Booking#: 10-02757
Release Date & Time:
DOB: 7/22/1967 -  RACE: W  -  SEX: M
Charges       Misd/Felony   Degree   Bond   Bond Posted
800.04-5b   LEWD LASCV BEHAVIOR MOLEST VIC LESS 12YOA OFFENDER 18 YOA OR OLDER   F   L    $50,004.00    
                $50,004.00    
http://public.pcso.us/jail/bookingDetails.aspx?SYSID=761604&IMG=37588

_______________________________________________________________

541989DR005765CAXXXX   1989-07-18   DOM (Divorce)
Plaintiffs   HOBERG ANNIECE M
Defendants   HOBERG JAMES M

__________________________________________________________________

541996DR007272FDXXXX   1996-03-05   DOM (Divorce)
Plaintiffs   CUMMINGS ANNIECE M
Defendants   CUMMINGS JOHN T
http://public.pcso.us/jail/adb.asp?IMG=39881
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Heart
Brandi
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« Reply #966 on: June 30, 2010, 10:26:52 PM »

Probably close to O/T ... but Lindsy changed her photo here: http://www.myspace.com/lindsy_croslin



We need our emoticons back. Wink
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Jerseygirl345
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« Reply #967 on: June 30, 2010, 10:48:08 PM »

JAMES  MICHAEL  HOBERG
SATSUMA,  FL
Booking Date & Time: 6/29/2010 1:05:00 AM  - Booking#: 10-02757
Release Date & Time:
DOB: 7/22/1967 -  RACE: W  -  SEX: M
Charges       Misd/Felony   Degree   Bond   Bond Posted
800.04-5b   LEWD LASCV BEHAVIOR MOLEST VIC LESS 12YOA OFFENDER 18 YOA OR OLDER   F   L    $50,004.00    
                $50,004.00    
http://public.pcso.us/jail/bookingDetails.aspx?SYSID=761604&IMG=37588

_______________________________________________________________

541989DR005765CAXXXX   1989-07-18   DOM (Divorce)
Plaintiffs   HOBERG ANNIECE M
Defendants   HOBERG JAMES M

__________________________________________________________________

541996DR007272FDXXXX   1996-03-05   DOM (Divorce)
Plaintiffs   CUMMINGS ANNIECE M
Defendants   CUMMINGS JOHN T
http://public.pcso.us/jail/adb.asp?IMG=39881


He has a long rap sheet..

Drugs, Burglary,Domestic Violence,Fellon Battery
http://www.putnam-fl.com/clk_apps/crim_dkts/frame.php

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Heart
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« Reply #968 on: June 30, 2010, 10:59:00 PM »

Probably close to O/T ... but Lindsy changed her photo here: http://www.myspace.com/lindsy_croslin



We need our emoticons back. Wink

 RadioNewz

 
No Haleigh newz this week, but Lindsy Croslin made some big newz with her new MySpace pic.. ... http://bit.ly/ahqFhk

http://forums.radionewz.net/index.php?topic=142.msg8384#msg8384
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Heart
Brandi
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« Reply #969 on: June 30, 2010, 11:48:28 PM »

Probably close to O/T ... but Lindsy changed her photo here: http://www.myspace.com/lindsy_croslin



We need our emoticons back. Wink

 RadioNewz

 
No Haleigh newz this week, but Lindsy Croslin made some big newz with her new MySpace pic.. ... http://bit.ly/ahqFhk

http://forums.radionewz.net/index.php?topic=142.msg8384#msg8384

huh?
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ospainter
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« Reply #970 on: July 01, 2010, 02:04:19 PM »

http://www.firstcoastnews.com/news/local/news-article.aspx?storyid=158126&catid=3

Attorney: Tommy Croslin Being Mistreated in Putnam Jail

PUTNAM COUNTY, Fla. -- The attorney for Hank "Tommy" Croslin Jr. has filed a motion saying his client is being mistreated in jail.

Attorney James Werter said Croslin, who is being held on drug charges but is a notable figure in the search for Haleigh Cummings, was taken out of protective custody last week and that his situation deteriorated.

In a motion for Order to Show Cause and Order of Prohibition Request for Expedited Hearing filed with the State Attorney's office and delivered to the Putnam County Sheriff's Office, Werter said Croslin's new accommodation in the Putnam County Correctional Facility has "inadequate ventilation" and "defective plumbing."

Werter's motion also stated that Croslin was forcibly removed from his cell and denied access to his attorney by detectives who harassed and threatened Croslin.

READ THE COMPLETE MOTION

According to the motion, the detectives said they would charge Croslin with felony murder in the Haleigh Cummings case if he didn't talk, and said they would spread rumors about him to the general population at the jail.

Werter called those "obvious violations" of Croslin's civil rights, and called for the detectives to be held in contempt.

He also wanted the court to establish that detectives could not have contact with Croslin unless it was previously established in writing with Werter.

(snipped)

OS
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It's their lie they can tell it anyway they want.
Who, What, Where, When, How and Why
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« Reply #971 on: July 01, 2010, 02:06:20 PM »

Croslin Files Motion Alleging Harassment

Attorney Wants To Move Croslin To St. Johns County

POSTED: 12:53 pm EDT July 1, 2010
UPDATED: 1:23 pm EDT July 1, 2010


PALATKA, Fla. --
An attorney for Hank Croslin Jr. has filed a motion in court on Monday claiming he's been harassed and threatened by authorities.


Croslin is the brother of Misty Croslin, who was babysitting Haleigh Cummings when she disappeared more than one year ago. Both are jailed facing drug charges.

The motion stated he was recently moved from the St. Johns County Jail to the Putnam County Jail, where Croslin was placed in the general population section in a cell with bad plumbing and ventilation.

The motion also claimed detectives from the Putnam County Sheriff's Office have visited Croslin to harass and threaten him. The alleged threats included telling Croslin that detectives would give other prisoners false information about him that could lead to "physical harm."

Read Motion  http://www.wesh.com/download/2010/0701/24110635.pdf

The motion also stated detectives said Croslin would be charged with the slaying of Haleigh if he doesn't talk. The motion also stated a Sheriff's Office captain berated Croslin and accused him of murder in front of other people.

Croslin's attorney said his client's civil rights were violated and stated he wants to move his client back to jail in St. Johns County.

A judge will hear the motion on July 16

http://www.wesh.com/news/24110371/detail.html
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« Reply #972 on: July 01, 2010, 02:23:57 PM »

Tommy Croslin was denied a lawyer in jail interrogation, lawyer says

Posted: July 1, 2010 - 12:36pm

By Kate Howard

An attorney for Hank "Tommy" Croslin Jr. has asked a judge to prohibit any investigators from interviewing him without notifying his attorney.

In court documents filed today, attorney James Werter said that Croslin, who was transferred to the Putnam County jail last week, was interrogated for two hours by Putnam County investigators and denied an attorney.

He was told "that he did not need an attorney and that the attorney of record and his private investigator were 'rat-ing' him out," according to the motion.

Croslin is the brother of Misty Croslin, who was watching 5-year-old Haleigh Cummings before her disappearance in February 2009 in Satsuma. Both Croslins and Haleigh's father, Ronald Cummings, are in jail awaiting sentencing on prescription drug charges.

Werter declined commenting beyond the court filings.

The court documents said that officers berated Croslin Jr., accused him of murdering Haleigh and threatened to spread false information to other prisoners to cause him physical harm.

The motion also asks a judge for an order that the investigators appear in court to say why they shouldn't be held in contempt for civil rights violations.

Maj. Gary Bowling with the Putnam County Sheriff's Office said he couldn't comment on the issue because of that request, but he said the department will speak with the court if asked to do so.

He was being held in jail in St. Johns County until last week to keep him away from a co-defendant, Putnam County officials said at the time. He pleaded no contest on June 3 to trafficking hydrocodone and no longer needed to be held separately, according to the Sheriff's Office.

He was being held in protective custody but is now in general population in Putnam County, according to the court documents.

A hearing is scheduled for July 16.

http://jacksonville.com/news/crime/2010-07-01/story/tommy-croslin-was-denied-lawyer-jail-interrogation-lawyer-says
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« Reply #973 on: July 01, 2010, 02:26:44 PM »

Attorney: Tommy Croslin Being Mistreated in Putnam Jail
   

PUTNAM COUNTY, Fla. -- The attorney for Hank "Tommy" Croslin Jr. has filed a motion saying his client is being mistreated in jail.

Attorney James Werter said Croslin, who is being held on drug charges but is a notable figure in the search for Haleigh Cummings, was taken out of protective custody last week and that his situation deteriorated.

In a motion for Order to Show Cause and Order of Prohibition Request for Expedited Hearing filed with the State Attorney's office and delivered to the Putnam County Sheriff's Office, Werter said Croslin's new accommodation in the Putnam County Correctional Facility has "inadequate ventilation" and "defective plumbing."

Werter's motion also stated that Croslin was forcibly removed from his cell and denied access to his attorney by detectives who harassed and threatened Croslin.

READ THE COMPLETE MOTION

According to the motion, the detectives said they would charge Croslin with felony murder in the Haleigh Cummings case if he didn't talk, and said they would spread rumors about him to the general population at the jail.

Werter called those "obvious violations" of Croslin's civil rights, and called for the detectives to be held in contempt.

He also wanted the court to establish that detectives could not have contact with Croslin unless it was previously established in writing with Werter.

In court in early June, pretrial hearing, Croslin pleaded no contest to one count of possession, a third degree felony, and to one count of trafficking in hydrocodone, a first degree felony.

His next court date is July 6. His sentencing date has not been set.

http://www.firstcoastnews.com/news/topstories/news-article.aspx?storyid=158126&catid=3
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« Reply #974 on: July 01, 2010, 05:26:14 PM »

Croslin's Attorney: Stop Strong-Arming

Motion Orders Investigators To Stop Talking To Hank Croslin Jr. Without Permission


POSTED: Thursday, July 1, 2010
UPDATED: 4:33 pm EDT July 1, 2010

PUTNAM COUNTY, Fla. -- Whether it's strong-arm tactics or leaning on a suspect, whatever you call it, Hank Croslin Jr. said it's happening to him and he wants it to stop.

Croslin's defense attorney, James Werner, filed a motion this week ordering investigators to stop talking to his client without his permission.

Croslin said that investigators have been threatening him so he would cooperate in the Haleigh Cummings investigation. According to the motion, there were threats that Croslin did not need an attorney and that his attorney was ratting him out and was going to testify against him in court.

"I don't know what they were thinking when they did this," Werner said.

Document: Motion Filed In State Vs. Hank Croslin Jr. Drug Case

Croslin said that an investigator threatened to charge him with Haleigh's murder if he did not speak with him, according to the motion, and that the investigators would give false information to the other prisoners to cause Croslin physical harm.

Hank Croslin Jr. Pleads No Contest
Hank Croslin Jr. pleads no contest to two charges of drug possession.
Werner said the pressure to solve the Haleigh case may be forcing investigators to take unethical tactics.

"You can put blames there, but professional law enforcement is professional law enforcement," Werner said. "I'm former law enforcement, and I believe in a certain amount of professionalism."

The Putnam County Sheriff's Office responded to the allegations Thursday, saying while there was no official internal investigation, they did look into the matter.

"I'm not calling it frivolous. I'm just saying we are not going to respond to it at this point," Chief Rick Ryan said.

Ryan did not address the specific allegations but said his investigators did not do anything improper.

"Croslin is in jail on drug charges facing sentencing," Ryan said. "Our folks talked to him about another pending investigation, totally separate. Again, we're just not going to respond to the allegations."

Croslin's sister is Misty Cummings, 5-year-old Haleigh's former stepmother, who investigators said was the last person to see the Satsuma girl the night she vanished from her home in February 2009.

Croslin, Cummings and Haleigh's father, Ronald Cummings, are all in jail on drug charges.

http://www.news4jax.com/news/24112773/detail.html
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« Reply #975 on: July 01, 2010, 06:46:39 PM »

Haleigh Cummings Update: Is Tommy Croslin Being Mistreated in Jail?

The question here is, is any of this true? Has Tommy really been harassed and threatened as he claims he was. If he was these detectives have some answering to do.

I have been hearing what everyone is saying. You want to know what this has to do with finding Haleigh. I say it does in a certain way but then again it depends on who you think is guilty. If Tommy knows anything about Haleigh’s disappearance I am assuming that the detectives are trying to make him talk. Now if Tommy knows nothing then none of this has anything to do with finding Haleigh, but at least it will either take more drug sellers off the streets.

more...

http://www.bloggernews.net/124829
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« Reply #976 on: July 01, 2010, 08:16:14 PM »

Macy said,
in July 1st, 2010 at 6:43 pm

Cricket as for WBG, I don’t know what the $0 in the bond amount means, but he is in jail and someone posted bond 6/4/10 on two of his charges. This is from the Putnam inmate search.

893.13-6a MARIJUANA-POSSESS POSSESS MARIJUANA OVER 20 GRAMS F T $1,004.00 6/4/2010 4:01:00 PM

893.135-1c1 DRUGS-TRAFFIC 4 GRAMS LESS 30 KG OTHER CNTRL SUBST F F $0.00

893.13-1a1 SYNTH NARCOTIC-POSSESS WIT SELL MFG
OR DELIVER SCHEDULE I OR II F S $2,504.00 6/4/2010 4:00:48 PM

__________________________________________________________________
Cricket responded,
in July 1st, 2010 at 6:45 pm

Macy,
The reason I asked is because I just read that LE beat the hell out of him and put him in jail no bond.

http://www.bloggernews.net/124829#comment-1688646

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Jerseygirl345
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« Reply #977 on: July 01, 2010, 08:30:50 PM »

An attorney for Hank Croslin Jr. has filed a motion in court on Monday claiming he's been harassed and threatened by authorities. In 3 parts being posted.




http://www.wesh.com/news/24110371/detail.html
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Jerseygirl345
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« Reply #978 on: July 01, 2010, 08:31:58 PM »

part2..



http://www.wesh.com/news/24110371/detail.html
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Jerseygirl345
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« Reply #979 on: July 01, 2010, 08:32:56 PM »

part3 of motion..



http://www.wesh.com/news/24110371/detail.html
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