The things I must do!

 

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR          PINELLAS COUNTY , FLORIDA

 

RICHARD W. ROMINE JR.                                                             CASE NO. 2D16-3729

                        VS.                                                                             REF. # 15-11601-CF-K

STATE OF FLORIDA

FRANK QUESADA

 

MOTION FOR POSTCONVICTION RELIEF

FLORIDA RULE OF CRIMINAL PROCEDURE 3.850

Comes now before the court: Richard W. Romine Jr., Sui Juris, In Propia Persona, In special appearance, In good faith, request this court to enter its order for Postconviction Relief, and does collaterally attack the conviction, judgements, and sentencing  in the above listed case and seeks relief in pursuant to Fla. R. Crim. P.  3.850. LET FACTS BE KNOWN. Grounds for this petition are.

1.     Ineffective assistance of trial counsel ( Ben Deburg, Michael O’Hare, Adam Teichler )

2.     The failure of the state to disclose material exculpatory and/or impeaching evidence ( Brady violations)         

3.     Newly discovered evidence of altering, omitting, erasing, to cover up judicial and prosecutorial misconduct, Legal Appellate Documents, in violation of Fla. Stat. 918.13 Tampering with or Fabricating physical evidence. causing irreparable harm to Richard Romine.

4.     The knowing presentation of false testimony and/or evidence by the prosecution. (Giglio violations)

5.     Prejudicial Error in accordance to Statute 941.051, Obstruction of Justice, Judge sitting on bench, in acts of bad behavior, gave orders which are void, unconstitutional, against the law, and against all weight of evidence. Due Process of law violations, Constitutional rights violations by several judges.

6.     Jury and witness tampering by prosecutor and/or Judge at trial directly or indirectly

                                                                              CASE NO. 2D16-3729

 

As to count 1; Ineffective Assistance of Counsel:  Ben Deburg, did-in-fact Fail to file viable pretrial motions, failed to investigate exculpatory evidence or favorable witnesses. Failed to assert affirmative defense.   Ineffective Assistance of Counsel: Michael O’Hare, did-in-fact fail to file viable pretrial motions, did fail to investigate exculpatory evidence or favorable witnesses, failed to assert affirmative defense, quit 2 days before discovery appointments with victims after being paid a large sum of money equals fraud. Ineffective Assistance of Counsel: Adam Teichler, did-in-fact fail to file viable motions, to disqualify a judge knowingly that judge is in bad behavior, allowing a wrong and not making it right, violation of several of the Defendants Civil and Constitutional rights, fail to safeguard the rights and freedoms of defendant making him now a victim of fraud and wrong doing by judicial actors.

As to count 2;  The failure of the state to disclose material exculpatory and/or impeaching evidence (Brady violations): ASA Brain Gnage failed to disclose any affidavit/complaint(s) by Samantha Romine The alleged victim and first count of the charges of; “AGGRAVATED STALKING” which would have impeached the victim/witness. According to investigator ROSS, D.P. (0148) report date 10-16-2015, states Samantha Romine’s testimony to police was submitted as an attachment to the original report. Where is this report? 

As to count 3;  Newly discovered evidence; judicial actors did-in-fact commit the act of; in violation of Fla. Stat. 918.13 Tampering with or Fabricating physical evidence, altering, omitting, erasing, to cover up judicial and prosecutorial misconduct, Legal Appellate Documents, causing irreparable harm to Richard Romine. Newly discovered evidence shows that the Defendant’s Appellate Transcripts were in-fact intentionally altered, omitted, and mutilated by Co-conspirators Judge Frank Quesada and Teresa Russell.

As to count 4; The knowing presentation of false testimony and/or evidence by the prosecution. (Giglio violations) ASA Brian Gnage did present false testimony and witnesses at trial.

As to count 5; Prejudicial Error; Obstruction of justice; Judge Frank Quesada participated in and/or knowingly, willfully and maliciously disregarded egregious civil and constitutional rights violations, denied defendant equal protections under the law, A prejudicial error, in accordance to statute 924.051, occurred in the trial court and did harmfully affect the judgement and or sentence and legal arguments and objections were timely preserved and raised to the evidence. Lack of jurisdiction of the trial court. U.S. and Florida Constitutions and other civil rights violated Before, during, and after the trial. Judge acting in bad behavior, violating Judges Oath of Office. The verdict was against the law and weight of evidence, but this didn’t stop Frank Quesada from a continuance of behavior in violation of his Oath of Office and sworn to uphold the Constitutions of Both Florida and U.S.

As to count 6; Jury and/or witness tampering by prosecutor and/or Judge at trial directly or indirectly. An inference of evidence would infer, that by the Jury’s actions towards the defendant, and the 2 letters they wrote to Richard Romine before the reading of the verdict, stating; Letter 1. “ Are we the jury allowed to issue a statement to be read at the conclusion of

                                                                                                            CASE NO. 2D16-3729

 

the reading of the verdicts? Nature of comment is regarding the defendant’s love for his daughters.   Letter 2.  “To the defendant, Richard Romine, we the jury have heard today unfortunate family dynamics and series of events, but one thing that was made clear is the love you have for your daughters.  We wish you the best in repairing your family dynamics and hope you can be an active participant in the future of your daughters lives.”  and after the weight of evidence by contrary testimony of both “State alleged” “Victims” Melinda Romine and Samantha Romine, the jury did not believe the text messages in question were in fact malicious, which the State had to prove Beyond A Reasonable Doubt and were obviously in fear of retaliations by both Judge and Prosecutors. Judge stated to Jury members that the trial has been scheduled for 4 days and could last up to 14 hours each day, as was the case of the first and only day of the schedule 4 day trial, after a jury member claimed to have a un-supervised puppy at his home and needed to attend to the animal as soon as possible.

 

Wherefore Richard Romine, petitioner, request this court to grant its order of Postconviction Relief. As relief the petitioner Richard Request this Court to rule directly on the legal issue(s) raised in this petition and to rule on the weight of evidence of the PREJUDICIAL ERROR in this case and reverse any and all convictions brought against Richard Romine and release him from his illegal, Unconstitutional chains placed there by these bad actors.

           

 

                        Unnotorized Oath ( ss. 92.525)

I hereby swear that I have read the foregoing petition and that the facts alleged in it are true to the best of my knowledge and beliefs.

 

                                                                                       Submitted: 11-2-2020

                                                                                    :Richard-Wayne :Romine Jr.  

                                                                                    Without prejudice (UCC 1-207.4, 1-308)