Case 2:24-cv-14348-XXXX Document 1 Entered on FLSD Docket 10/23/2024 Page 1 of 18

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
FORT PIERCE DIVISION

STATE OF FLORIDA,

Plaintiff,

v. Case No. 2:24-cv-14348

MERRICK GARLAND, in his official

capacity as U.S. Attorney General,

Defendant.
_________________________________/

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF

1. In just a two-month period, Donald J. Trump (President Trump) has

faced two credible attempts to take his life.

2. In one attempt, a gunman fired shots at President Trump’s head, nearly

killing him, and was even able to wound the former President’s ear. The alleged

failures by the Secret Service with respect to that event were so severe that the head of

that agency resigned.

3. In the other attempt, a gunman was able to hide for nearly twelve hours

near the sixth green of Trump International Golf Club in West Palm Beach, Florida.

By the time the Secret Service found the shooter, he had “ma[de] it within several

hundred yards” of President Trump.1

1
Alana Wise, 2 close calls have the Secret Service facing criticism and an uncertain future, NPR (Sept. 19,
2024), https://www.npr.org/2024/09/19/g-s1-23618/secret-service-trump-shooting-gunman-
problems.
Case 2:24-cv-14348-XXXX Document 1 Entered on FLSD Docket 10/23/2024 Page 2 of 18

4. Two days after this second attempt, on September 17, 2024, Governor

Ron DeSantis signed Executive Order Number 24-197. 2 The Executive Order directed

the Florida Department of Law Enforcement (FDLE) and Florida Highway Patrol

(FHP) to work with relevant partners and with the Office of Statewide Prosecution to

ensure appropriate state charges are brought. Cf. Crossley v. California, 168 U.S. 640,

641 (1898) (“[I]t is settled law that the same act may constitute an offense against the

United States and against a state.”).

5. Within days of Governor DeSantis signing the Executive Order,

however, officials at the Federal Bureau of Investigation (FBI), under the supervision

of the Department of Justice (DOJ), indicated that the State of Florida must suspend

its investigation. As the basis for this demand, the federal officials cited 18 U.S.C.

§ 351(f), which purports to temporarily “suspend the exercise of jurisdiction by a State

or local authority” when the federal government asserts jurisdiction over an

assassination attempt of a major presidential candidate.

6. In conversations with federal officials and in subsequent correspondence,

these officials have stated that Florida may not conduct its own investigation, may not

interview witnesses, and may only cooperate with the federal government’s

investigation.

7. Because § 351(f) does not prohibit such conduct, and because it would

violate the Tenth Amendment if it reached so far, Florida sues to vindicate its

2
Available at https://www.flgov.com/wp-content/uploads/2024/09/EO-24-197.pdf.

2
Case 2:24-cv-14348-XXXX Document 1 Entered on FLSD Docket 10/23/2024 Page 3 of 18

sovereign interest to investigate violations of state law, as delay may impact the

outcome of any prosecution.

PARTIES

8. Plaintiff the State of Florida is a sovereign State and has the authority

and responsibility to protect its sovereign interests and the health, safety, and welfare

of its citizens. As the State’s Chief Legal Officer, Attorney General Ashley Moody is

authorized to represent the interests of the State in civil suits. § 16.01(4), (5), Fla. Stat.

9. Defendant Merrick Garland is the U.S. Attorney General and the head

of the Department of Justice (DOJ). The Federal Bureau of Investigation (FBI) is a

component of DOJ and is under Defendant Garland’s supervision and control.

JURISDICTION AND VENUE

10. Florida sues Defendant Garland under 5 U.S.C. § 702, 28 U.S.C. §§ 1361

and 2201–02, the U.S. Constitution, and the Court’s equitable powers.

11. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331,

1346, and 1361, and the U.S. Constitution.

12. Venue is proper in this district and division for two reasons.

13. First, venue is proper under 28 U.S.C. § 1391(e)(1) because Defendant

Garland is a federal officer and Plaintiff the State of Florida is a resident of every

judicial district in its sovereign territory, including this district (and division). See

California v. Azar, 911 F.3d 558, 570 (9th Cir. 2018); Florida v. United States, No. 3:21-

cv-1066, 2022 WL 2431443, at *2 (N.D. Fla. Jan. 18, 2022).

3
Case 2:24-cv-14348-XXXX Document 1 Entered on FLSD Docket 10/23/2024 Page 4 of 18

14. Second, a substantial part of the events or omissions giving rise to the

claims occurred here. See 28 U.S.C. § 1391(b)(2). Virtually all the relevant events

occurred in this district. And one of the most important events occurred in this division

because, as further detailed below, the first time the federal government communicated

to Florida regarding § 351(f) was on a phone call with a Florida law enforcement

officer based in Fort Pierce.

BACKGROUND

Factual Background

15. On September 15, 2024, President Trump played a round of golf at

Trump International Golf Club in West Palm Beach, Florida.

16. During that round, the Secret Service discovered an armed gunman, later

identified as Ryan Wesley Routh, hiding near the sixth green.

17. After Secret Service agents fired at his position, Mr. Routh fled on foot

and later by car. Officers from the Martin County Sheriff’s Office, in coordination with

the Palm Beach County Sheriff’s Office, later located Mr. Routh and took him into

custody.

18. It is reasonably clear from all the facts and circumstances, including a

note authored by Mr. Routh himself, that Mr. Routh intended to assassinate President

Trump.

19. This was the second assassination attempt on President Trump in as

many months. In the first attempt, a gunman was able to shoot President Trump in

the ear and nearly kill him.

4
Case 2:24-cv-14348-XXXX Document 1 Entered on FLSD Docket 10/23/2024 Page 5 of 18

20. During the first attempt, the Secret Service failed to discharge its duties

in a variety of ways,3 including by allowing the gunman access to a rooftop with a clear

line of sight to President Trump. Within days of these failures, the head of the Secret

Service resigned.

21. With respect to the second attempt, similar concerns have been raised,

such as how a gunman managed to get so close to President Trump and hide for twelve

hours undetected.

22. Two days after this second attempt, on September 17, 2024, Governor

Ron DeSantis signed Executive Order Number 24-197. 4 The Executive Order directed

FDLE and FHP to work with relevant partners and with the Office of Statewide

Prosecution to ensure appropriate state charges are brought.

23. Those charges may ultimately include attempted murder, fleeing and

eluding, and charges related to Mr. Routh’s unlawful possession of firearms. See

§ 782.04, Fla. Stat. (murder); id. § 777.04 (liability for attempted crimes); id. § 316.1935

(fleeing and eluding); id. § 790.23 (felon in possession).

24. Additionally, the State may pursue charges against Mr. Routh stemming

from injuries caused by his flight from law enforcement after the assassination attempt.

25. Almost immediately, however, federal officials began taking steps to halt

the State’s investigation.

3
Report of the Independent Review Panel on the July 13, 2024 Assassination Attempt in Butler Pennsylvania,
Independent Review Panel (Oct. 15, 2024), https://www.dhs.gov/sites/default/files/2024-
10/24_1017_opa-Independent-Review-Panel-Final-Report-and-Accompanying-Materials.pdf.
4
Available at https://www.flgov.com/wp-content/uploads/2024/09/EO-24-197.pdf.

5
Case 2:24-cv-14348-XXXX Document 1 Entered on FLSD Docket 10/23/2024 Page 6 of 18

26. Only a few days after Governor DeSantis signed the Executive Order,

FBI Special Agent in Charge Jeffrey Veltri called the FDLE Special Agent in Charge

in Fort Pierce. During that phone call, Mr. Veltri directed FDLE to 18 U.S.C. § 351(f).

27. Mr. Veltri did so even though, at that time, the federal government had

only charged Mr. Routh with firearms related charges and had not charged him for

attempted assassination under § 351.

28. Section 351(f) purports to temporarily “suspend the exercise of

jurisdiction by a State or local authority” where the federal government asserts

“investigative or prosecutive jurisdiction” over violations of § 351, which would

include the attempted assassination of a major presidential candidate.

29. In a subsequent meeting between Florida’s Statewide Prosecutor

Nicholas Cox and U.S. Attorney Markenzy Lapointe of the Southern District of

Florida, the U.S. Attorney again mentioned § 351(f). In this meeting, U.S. Attorney

Lapointe suggested that Florida should not interview witnesses until the federal

investigation was completed.

30. In light of these statements and other attempts to block Florida’s

investigation, on September 23, 2024, Florida Attorney General Ashley Moody wrote

a letter to U.S. Attorney Lapointe and FBI Director Christopher Wray. See Ex. 1. The

letter covered several things.

31. First, the letter noted the lack of public confidence in the federal

investigation—specifically (a) the Secret Service’s repeated failures to adequately

protect President Trump, (b) the federal government’s ongoing prosecution of the

6
Case 2:24-cv-14348-XXXX Document 1 Entered on FLSD Docket 10/23/2024 Page 7 of 18

victim, President Trump, and (c) the fact that Mr. Veltri, who is leading the

investigation, has made statements in the past that some believe demonstrate a bias

against President Trump. The letter further noted that “having Florida conduct its own

investigation . . . would mitigate public concern regarding the credibility and

reliability of these institutions.” Ex. 1 at 3.

32. Second, the letter noted that, as a legal matter, general references to

§ 351(f) in a verbal conversation were likely insufficient to invoke that provision. Ex. 1

at 4.

33. Third, the letter asked for clarification regarding whether § 351(f) was

being formally invoked and, if so, “what you believe this provision prohibits and how

the federal government would enforce it.” Ex. 1 at 4.

34. Notably, when General Moody sent that letter, DOJ had only charged

Mr. Routh with illegal possession of firearms. DOJ had not charged Mr. Routh with

any violation of § 351.

35. After DOJ received General Moody’s letter, DOJ charged Mr. Routh

with a violation of § 351(c), which prohibits the attempted assassination of a major

presidential candidate.

36. On September 30, a week after receiving General Moody’s letter, U.S.

Attorney Lapointe sent a response letter. Ex. 2.

37. U.S. Attorney Lapointe’s letter claimed that “[t]he federal indictment

returned last week—which post-dates your letter—resolves any potential uncertainty

about whether 18 USC 351(f) applies here.” Ex. 2 at 3.

7
Case 2:24-cv-14348-XXXX Document 1 Entered on FLSD Docket 10/23/2024 Page 8 of 18

38. U.S. Attorney Lapointe’s letter did not provide any response to General

Moody’s request for guidance regarding what § 351(f) prohibits or how the federal

government plans to enforce it.

39. Following this unequivocal assertion of § 351(f), the federal government

almost immediately asked the trial court assigned to the criminal case to remove the

case from the trial calendar until further notice. See Unopposed Motion to Designate

Case as Complex Under Speedy Trial Act, United States v. Routh, Doc. 30, 9:24-cr-

80116 (S.D. Fla. Oct. 2, 2024).

Legal Background

18 U.S.C. § 351

40. Section 351 prohibits the killing, kidnapping, attempting killing or

kidnapping, or assaulting of a variety of individuals. 18 U.S.C. § 351(a)–(c), (e).

41. These individuals include members of Congress, certain high-ranking

executive branch officials, justices of the Supreme Court, nominees for certain

positions, and “major Presidential or Vice Presidential candidate[s]” as defined in 18

U.S.C. § 3056(a)(7). See 18 U.S.C. § 351(a).

42. Subsection (f) of § 351 states as follows: “If Federal investigative or

prosecutive jurisdiction is asserted for a violation of this section, such assertion shall

suspend the exercise of jurisdiction by a State or local authority, under any applicable

State or local law, until Federal action is terminated.”

8
Case 2:24-cv-14348-XXXX Document 1 Entered on FLSD Docket 10/23/2024 Page 9 of 18

43. It appears that no court has interpreted this provision. But applying

traditional principles of statutory interpretation, the statute is far narrower than DOJ

asserts.

44. Specifically, all the statute prohibits is the State’s “exercise of jurisdiction”

under “any applicable State or local law, until Federal action is terminated.” 18 U.S.C.

§ 351(f) (emphasis added).

45. That phrase—“exercise of jurisdiction”—does not refer to all

investigatory actions. Rather, it refers to the formal exercise of jurisdiction over a

person or thing—namely, a seizure. That is true for several reasons.

46. First, the phrase “exercise jurisdiction” stands in contrast to the phrase

“assert[] . . . jurisdiction,” which is what DOJ must do to trigger the statute. See Sosa

v. Alvarez-Machain, 542 U.S. 692, 711 n.9 (2004) (“[W]hen the legislature uses certain

language in one part of the statute and different language in another, the court assumes

different meanings were intended.” (quotations omitted)).

47. Given this contrast, exercising jurisdiction involves something more

significant than asserting jurisdiction. For example, if someone “asserts” a right to

vote, that person may take any number of actions short of casting a ballot. If someone

seeks to “exercise” such a right, however, that person may do so only by the formal

act of casting a ballot.

48. Second, and relatedly, the phrase “exercise jurisdiction” is most

frequently used in a manner consistent with Florida’s reading of the statute—

specifically, in reference to taking a person or thing into custody.

9
Case 2:24-cv-14348-XXXX Document 1 Entered on FLSD Docket 10/23/2024 Page 10 of 18

49. “Exercising jurisdiction” arises most often in applying the rule of comity.

Under that rule, when a state government and the federal government both assert

jurisdiction over the same person or thing, “the court which first takes the subject-

matter of the litigation into its control, whether this be person or property, must be

permitted to exhaust its remedy, to attain which it assumed control, before the other

court shall attempt to take it for its purpose.” Ponzi v. Fessenden, 258 U.S. 254, 260–61

(1922).

50. In rule of comity cases, the first sovereign to take custody of the person

or thing—thus triggering the rule of comity—is said to “exercise its jurisdiction over

the” person or thing. Rooney v. Hunter, 64 F. Supp. 165, 168 (D. Kan. 1945); accord

United States ex rel. Helwig v. Klopfinstrin, 137 F. Supp. 214, 215 (W.D. Pa. 1956); In re

James, 18 F. 853, 857 (C.C.W.D. Mo. 1884).

51. Applying this understanding of “exercise jurisdiction,” § 351(f) grants the

federal government a right to custody of Mr. Routh even if the State arrests him first.5

In other words, the purpose of § 351(f) is merely to modify the rule of comity, which

would otherwise compel the federal government to wait for the State to prosecute and

incarcerate Mr. Routh before it could do so.

52. Finally, even if the State’s reading is only one of multiple plausible

readings, the Court should adopt the State’s reading. As explained below, the federal

5
In fact, the State did arrest Mr. Routh first and complied with § 351(f) by acquiescing to the federal
government taking custody of Mr. Routh.

10
Case 2:24-cv-14348-XXXX Document 1 Entered on FLSD Docket 10/23/2024 Page 11 of 18

government’s reading would raise a substantial constitutional question because it

would likely render § 351(f) unconstitutional under the Tenth Amendment.

The Tenth Amendment and the Supremacy Clause

53. The Tenth Amendment to the U.S. Constitution states that “[t]he powers

not delegated to the United States by the Constitution, nor prohibited by it to the

States, are reserved to the States respectively, or to the people.”

54. This Amendment confirms that “[t]he Constitution confers on Congress

not plenary legislative power but only certain enumerated powers,” and thus, “all

other legislative power is reserved for the States.” Murphy v. NCAA, 584 U.S. 453, 477

(2018).

55. As relevant here, the Supreme Court has interpreted the Tenth

Amendment to impose an anti-commandeering rule. Under that rule “‘[t]he Federal

Government’ may not ‘command the States’ officers, or those of their political

subdivisions, to administer or enforce a federal regulatory program.’” Murphy, 584

U.S. at 473 (quoting Printz v. United States, 521 U.S. 898, 935 (1997)).

56. Unconstitutional commandeering can include ordering state officials to

take some action, such as conducting background checks. E.g., Printz, 512 U.S. at 905.

And it can also involve ordering state officials not to do something, such as enacting

particular legislation. E.g., Murphy, 548 U.S. at 474.

57. Commandeering, however, is different from federal preemption.

58. Preemption occurs as a result of the Supremacy Clause of the U.S.

Constitution, which expressly designates federal law as the “supreme law of the land.”

11
Case 2:24-cv-14348-XXXX Document 1 Entered on FLSD Docket 10/23/2024 Page 12 of 18

U.S. Const., art. VI, cl. 2. But “that Clause is not an independent grant of legislative

power to Congress. Instead, it simply provides ‘a rule of decision.’” Murphy, 584 U.S.

at 477 (quoting Armstrong v. Exceptional Child Ctr., Inc., 575 U.S. 320, 324 (2015)).

59. When a federal law preempts a state law, “a state law confers rights or

imposes restrictions that conflict with the federal law; and therefore the federal law

takes precedence and the state law is preempted.” Id. Thus, when federal law preempts

state law, the federal law creates “a federal right to engage in certain conduct subject

only to certain (federal) constraints.” Id. at 479.

60. Importantly, “the Constitution ‘confers upon Congress the power to

regulate individuals, not States.’” Id. at 477 (quoting New York v. United States, 505 U.S.

144, 166 (1992)). As such, to constitute a valid preemption provision, a federal law

“must be best read as one that regulates private actors.” Id. (emphasis added).

61. By contrast, a federal law that “dictates what” state officials “may and

may not do” is not a valid preemption provision and “violates the anticommandeering

rule” of the Tenth Amendment to the U.S. Constitution. Id. at 474.6

6
While Murphy addresses legislative acts, other case law makes clear that the anti-commandeering
rule applies equally when the federal government “harnesses a State’s . . . executive authority.”
Haaland v. Brackeen, 599 U.S. 255, 281 (2023); e.g., Printz, 512 U.S. at 905 (reviewing a provision of
federal law requiring state executive officials to conduct background checks for a federal regulatory
program).

12
Case 2:24-cv-14348-XXXX Document 1 Entered on FLSD Docket 10/23/2024 Page 13 of 18

Injuries to the State of Florida

62. The mere fact that the State may not carry out its right to investigate

violations of its own laws is a sovereign injury sufficient to trigger Article III

jurisdiction. But the State’s concrete injuries go beyond that harm to its sovereignty.

63. According to U.S. Attorney Lapointe’s letter, Florida law enforcement

officials may not conduct any investigative activities of their own until after “the

conclusion of the federal prosecution.” Ex. 2 at 3. This means that, according to the

federal government, the State may not interview witnesses or execute warrants or

subpoenas.

64. That is significant. Evidence disappears, memories fade, and the State

has no way to force the federal government to cooperate in the State’s prosecution. See

United States ex rel. Touhy v. Ragen, 340 U.S. 462, 465 (1951).

65. Every day that Florida is prevented from investigating, the State’s case

becomes harder to prove at trial. By contrast, the federal government suffers no injury

from Florida investigating state law crimes, as the State has no intention of interfering

with or obstructing the federal investigation.

66. To prevent further injury, Florida seeks the following relief.

13
Case 2:24-cv-14348-XXXX Document 1 Entered on FLSD Docket 10/23/2024 Page 14 of 18

CLAIMS

COUNT 1

Declaratory Judgment Act

67. Florida repeats and incorporates by reference ¶¶ 1–66.

68. The Declaratory Judgment Act (DJA) provides that, “[i]n a case of

actual controversy within its jurisdiction, . . . any court of the United States . . .

may declare the rights and other legal relations of any interested party seeking such

declaration, whether or not further relief is or could be sought.” 28 U.S.C. § 2201.

69. The DJA empowers a party faced with a “genuine threat of

enforcement” to bring an action to seek a court’s declaration as to whether an

expected government action is lawful. MedImmune, Inc. v. Genentech, Inc., 549 U.S.

118, 129 (2007).

70. Moreover, courts “normally do not require plaintiffs to ‘bet the

farm . . . by taking the violative action’ before ‘testing the validity of the law.’” Free

Enter. Fund v. Pub. Acct. Oversight Bd., 561 U.S. 477, 490 (2010) (quoting MedImmune,

Inc., 549 U.S. at 129).

71. The federal government has demonstrated a “genuine threat of

enforc[ing]” § 351(f) to bar Florida from investigating the latest assassination attempt

14
Case 2:24-cv-14348-XXXX Document 1 Entered on FLSD Docket 10/23/2024 Page 15 of 18

against President Trump, as well as other state law crimes emanating from Mr.

Routh’s actions. MedImmune, Inc., 549 U.S. at 129.

72. As discussed above, federal officials have stated in writing that § 351(f) is

in effect against the State of Florida and have told state officials that basic investigative

activities, such as interviewing witnesses, are illegal under federal law. Moreover, the

federal government indicated in its letter that it will not allow Florida to access

evidence until after the federal government has concluded its own investigation. See

Ex. 2 at (“[Section 351 (f)] does not preclude state prosecutions permissibly following

the conclusion of the federal prosecution—and in no way prevents the sharing of federal

evidence with state authorities after the federal matter has ended.” (emphasis added)).

73. As explained above, the federal government dramatically overreads

§ 351(f), which merely modifies the traditional rule of comity and allows the federal

government to take custody of Mr. Routh over the State’s objection.

74. A declaratory judgment action is therefore proper to clarify whether the

federal government can lawfully prevent Florida’s investigation of state law violations

under § 351(f) until the conclusion of the federal prosecution. See GTE Directories Publ’g

Corp. v. Trimen Am., Inc., 67 F.3d 1563, 1567 (11th Cir. 2011) (A suit brought under

the Declaratory Judgment Act presents “a substantial controversy, between parties

having adverse legal interests, of sufficient immediacy and reality to warrant the

issuance of a declaratory judgment.” (quoting Maryland Cas. Co. v. Pacific Coal & Oil

Co., 312 U.S. 270, 273 (1941))).

15
Case 2:24-cv-14348-XXXX Document 1 Entered on FLSD Docket 10/23/2024 Page 16 of 18

COUNT 2

Equitable Cause of Action

75. Florida repeats and incorporates by reference ¶¶ 1–66.

76. Under the traditional equitable cause of action, courts may “enjoin

unlawful executive action.” Armstrong, 575 U.S. at 326–27. This cause of action “is the

creation of courts of equity, and reflects a long history of judicial review of illegal

executive action.” Id.

77. For the reasons discussed in Count 1, the federal government’s attempt

to thwart Florida’s investigation vastly overreads § 351(f) and any enforcement of it

would constitute illegal executive action.

COUNT 3

Violation of the Tenth Amendment

78. Florida repeats and incorporates by reference ¶¶ 1–66.

79. To the extent the Court rejects Counts 1 and 2 and adopts DOJ’s broad

reading of § 351(f), that provision violates the Tenth Amendment.

80. It does not create “a federal right to engage in certain conduct subject

only to certain (federal) constraints.” Murphy, 584 U.S. at 479.

81. Rather, it operates directly on the States by leaving state law completely

intact but issuing a command to state officials regarding when they may exercise a

sovereign function—here, enforcing state law.

82. By “dictat[ing] what” state officials “may and may not do,” § 351(f)

“violates the anticommandeering rule” of the Tenth Amendment. Id. at 474.

16
Case 2:24-cv-14348-XXXX Document 1 Entered on FLSD Docket 10/23/2024 Page 17 of 18

83. Put differently, a valid preemption provision is one that “regulates private

actors” because “the Constitution ‘confers upon Congress the power to regulate

individuals, not States.’” Murphy, 584 U.S. at 477 (quoting New York, 505 U.S. at 166).

84. But § 351(f)—at least on DOJ’s reading—does not regulate private

individuals at all—it only tells the States when they may enforce an otherwise valid

law against those private individuals.

85. As the Supreme Court recently held, “[t]he Supremacy Clause gives

priority to the ‘Laws of the United States,’ not the criminal law enforcement priorities

or preferences of federal officers.” Kansas v. Garcia, 589 U.S. 191, 212 (2020).

86. For these reasons, to the extent the Court rejects Counts 1 and 2, § 351(f)

violates the Tenth Amendment.

PRAYER FOR RELIEF

For these reasons, Florida asks the Court to:

a) Declare that Florida may conduct its investigation without violating

§ 351(f).

b) In the alternative, declare § 351(f) unconstitutional as applied to Florida.

c) Enjoin Defendants from enforcing § 351(f) in a manner that would prevent

Florida from conducting its investigation.

d) Award costs and reasonable attorney’s fees.

e) Award such other relief as the Court deems equitable and just.

17
Case 2:24-cv-14348-XXXX Document 1 Entered on FLSD Docket 10/23/2024 Page 18 of 18

Respectfully submitted,

Ashley Moody
ATTORNEY GENERAL

John Guard (FBN 374600)

CHIEF DEPUTY ATTORNEY GENERAL

/s/ James H. Percival

James H. Percival (FBN 1016188)
CHIEF OF STAFF

Henry C. Whitaker (FBN 1031175)

SOLICITOR GENERAL

Christine Pratt (FBN 100351)

COUNSELOR TO THE ATTORNEY GENERAL

Darrick Monson (FBN 1041273)

ASSISTANT SOLICITOR GENERAL

Office of the Attorney General

The Capitol, Pl-01
Tallahassee, Florida 32399-1050
(850) 414-3300
(850) 410-2672 (fax)
james.percival@myfloridalegal.com

Counsel for the State of Florida

18