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3.840, moves this Honorable Court to Issue an Order to Show Cause as to why
Statutes 27.04 and 27.181 an investigative subpoena was personally served upon
Rosita Donaldson directing her to appear at the Office of the State Attorney
Ralph Fernandez, Esq., A.J. Alvarez, Esq., Andrew Shafii, Esq., and Edgar
Guzman, Esq. She was placed under oath by an official court reporter. The
subpoena issued to her conferred upon her use and derivative use immunity by
result of the immunity granted to her by operation of Florida Law, she did not
have a constitutional right against self-incrimination and did not have the
right to refuse to answer questions posed to her by the undersigned Assistant
State Attorney.
Attorney, Rosita Donaldson stated her name, address and date of birth as well
as the names of her husband and children. Additionally, Mrs. Donaldson upon
advised that she would be refusing to answer any questions posed to her. In
refusing to answer, Mrs. Donaldson did not invoke any statutory privilege
B.)
appear and answer why she should not be held in indirect criminal contempt of
subpoena.
I HEREBY CERTIFY that the foregoing MOTION FOR ORDER TO SHOW CAUSE
has been furnished to Ralph Fernandez, Esquire, 109 S. Moody Ave, Tampa, FL
33609, via E-mail RALPH@REFERNANDEZLAW.COM, this __6th___ day of
December, 2017.
Respectfully submitted,
ANDREW H. WARREN
STATE ATTORNEY
/S/SCOTT HARMON
MailProcessingStaff@SAO13th.com
SCOTT HARMON
ASSISTANT STATE ATTORNEY
FLORIDA BAR# 0933775
STATE ATTORNEY'S OFFICE
419 N. PIERCE ST.
TAMPA, FL 33602-4022
(813) 272-5400
SH/als