| Date | Event | Source | Exhibit |
|---|---|---|---|
| Mar. 4, 2015 | BMB born in Santa Monica, California | Birth Certificate | TBD |
| Dec. 4, 2018 | BRB born in Tampa, Florida | Birth Certificate | TBD |
| Date | Event | Source | Exhibit |
|---|---|---|---|
| Nov. 22, 2023 | MOTHER SIGNS ATTORNEY RETAINER with K. Dean Kantaras, P.A. -- Day −1. Discovered from Mother’s own exhibit binder (Wife’s Exhibit List, Tabs 13/14). Premeditation: hired attorney the day BEFORE allowing Father’s final visit with children. | Wife’s Exhibit List Binder, Tabs 13/14 | Exhibit H-4 |
| Nov. 23, 2023 | LAST CONTACT -- THANKSGIVING DAY -- DAY ZERO OF SEPARATION. Father’s children (BMB, age 8; BRB, age 4) are brought by Mother to Father’s family’s home -- a paternal family Thanksgiving gathering. Mother texts Father: “The boys will be happy to see you.” Father attends. Contact occurs at Father’s family’s home in a safe, family environment. No threats. No safety incident. No court order. No restraining order. No documented concern of any kind. Mother had already retained K. Dean Kantaras, P.A. the prior day. This is the last time Father sees or speaks to his children. No reason was ever given for the total separation that immediately followed. | Exhibit J-2 (p.1) | Multiple |
| Nov. 24, 2023+ | TOTAL SEPARATION BEGINS -- ZERO CONTACT FROM THIS DATE FORWARD. The day after a safe, voluntary Thanksgiving family visit, all contact between Father and his children is severed. No court order authorized separation. No safety finding was made. No restraining order was in place. No allegation of abuse, neglect, or threat had been adjudicated. Father was given no explanation. Zero contact, zero visitation, zero communication -- sustained without judicial authorization for 845+ days as of the March 19, 2026 PTM filing. Acknowledged in writing by opposing counsel: KDK Dec. 18, 2025 letter states “730 days” without contact -- a binding party admission under Fla. Evid. Rule 90.803(18). | Kantaras Dec. 18 Letter | Exhibit I-1 |
| Nov. 29, 2023 | Mother texts: “What makes you think you deserve spending time with BRB” -- falsely denying Father access. Father responds via text documenting his desire for contact and challenging the narrative. | Exhibit J-2 (p.1) | Exhibit J-2 |
| Nov. 30, 2023 | Mother texts: “You’re the one creating a false narrative to make yourself look better” and “Your false promises and inability to be a responsible parent is what was hurting BRB. He couldn’t be happier with how well he’s cared for, no thanks to your parental support which has been nonexistent for the past 5 years.”
Father responds: “We both know that’s not true” and “I’m kindly asking for time, any time, to spend with BRB on his birthday … plz don’t take that away from us.” Father also states: “I love Igor and cherish my boys and just want to be there for them plz” and “I appreciate y’all very much … I won’t let them down.” |
Exhibit J-2 (p.2) | Exhibit J-2 |
| Dec. 2, 2023 Sat, 8:30 AM |
FATHER REQUESTS BRB’S BIRTHDAY CONTACT -- LIMITED CALL ALLOWED. Father texts: “Good morning! May I ask if there are any plans or if I can call and say hi to BRB today or tomorrow plz?” and “If y’all having a party, can I say hi before plz? Or plz let me know if I can show up Monday morning to see BRB as well plz?”
Kelly responds: “Good morning. Call anytime.” A brief phone call was allowed. Father: “Thank you so much! Is now ok or maybe in 10/15? That means so much!” “Thank you so much :) … breaks my heart hearing BRB say that multiple times so I know this is affecting him so plz help.” Note: Despite allowing a brief call, in-person visitation and birthday present drop-off were denied. Kelly’s Nov. 24, 2025 sworn testimony claims she could never reach Father -- contradicted by her own “Call anytime” response on this date. |
Exhibit J-2 (p.3) | Exhibit J-2 |
| Dec. 4, 2023 9:55 PM |
BRB’S 5th BIRTHDAY -- PRESENT DROPPED AT DOOR, NO CONTACT. Father texts at 9:55 PM: “Just left the present in front of the door :( Please record him and let him know this was from me.” “It’s an electric bike for both BRB and BMB … charged up full and ready to go.” “Daddy loves you so much BRB…”
Mother does not respond. Father is not permitted to see or speak to BRB on his birthday. |
Exhibit J-2 (p.4) | Exhibit J-2 |
| Dec. 6-7, 2023 | FOLLOW-UP TEXTS UNANSWERED -- 2+ DAYS OF SILENCE. Dec. 6 (5:13 PM): Father texts: “If I don’t hear from you soon I’m going to start thinking something is wrong, you need to at least answer me and let me know everything is ok at least plz…” “May I ask an update on the boys and May I call them soon plz?” “Did BRB like the bike!?” Dec. 7 (9:34 AM): “?? Plz answer ??” -- no response from Mother. | Exhibit J-2 (p.4) | Exhibit J-2 |
| Dec. 15, 2023 | Petition for Paternity, Parenting Plan, and Child Support filed by Mother (e-filed 02:57:38 PM, Filing #88140825) | Filed -- Court Docket | Exhibit H-4, Exhibit H-6 |
| Dec. 15, 2023 | Request-Demand for Compliance with Mandatory Disclosure filed -- compliance required by April 8, 2024 | Filed -- Court Docket | Exhibit H-4, Exhibit H-6 |
| Dec. 25, 2023 Christmas Day |
CHRISTMAS DAY -- ZERO CONTACT WITH BOTH SONS. Father texts at 12:54 PM: “Can I say hi to my kids on Christmas? Or are you that evil?” At 3:58 PM: “Please? Why are you doing this to their mindset and their memories? What type of mother and human being does that? Where is your soul?” “You’re personally doing so much damage to them and only out of spite and no common sense.” “There’s no other words to describe you.”
Father itemizes: “- won’t let me speak or see BRB on his bday? - won’t let me see, speak or even say hi on Christmas?” Mother does not respond. No contact with BMB or BRB on Christmas Day 2023. |
Exhibit J-2 (p.5) | Exhibit J-2 |
| Date | Event | Source | Exhibit |
|---|---|---|---|
| Late Jan. / Early Feb. 2024 | THE SETUP BEGINS -- FINANCIAL REVERSAL + MEETING BAIT. Father sends texts offering financial help for the children. Mother responds: “i didnt realize all your lengthy texts were about child support.” Hours later, Mother denies wanting the funds and refuses the offer entirely.
Shortly after the financial reversal, Mother pivots: she begins setting up a meeting, telling Father he will be able to see the children. Father -- acting in good faith -- agrees. This is the beginning of a documented pattern: financial bait, reversal, then physical bait using children as leverage to coordinate Father’s location. The full setup sequence: Late Jan. text exchange → Feb. 13-14 “Looking forward to Tuesday” re-engagement → Feb. 23 Catapult -- papers served at 4:10 PM. |
Text Messages | -- |
| Feb. 13-14, 2024 Day 82-83 -- Step 2 |
SETUP STEP 2 -- “LOOKING FORWARD TO TUESDAY” + PAYMENT SENT BUT NOT RECEIVED. Feb. 13: Father texts Mother: “Looking forward to Tuesday!” Mother responds: “They can play at Catapult with you like I suggested in my last text…” -- confirming the location (Catapult) and the promise of seeing the children.
Mother also sends Zelle payment information (kelly.burja@gmail.com). Father responds: “Thanks so much! Plz send CashApp since I don’t have Zelle at the moment.” Feb. 14: Child support payment SENT by Father but not received / not acknowledged. Note: Mother’s own text confirming the Catapult visit directly contradicts her Nov. 24, 2025 sworn claim that Father was disengaged or unable to be reached. She was confirming a visit with Father one week out. |
Exhibit J-2 (p.6) | Exhibit J-2 |
| Feb. 23, 2024 4:10 PM |
SETUP STEP 3 -- SERVICE CONFIRMED -- MOTHER’S TEXT PINS FATHER’S LOCATION AT EXACT MOMENT OF SERVICE (Exhibit J-2, p.7). Mother confirms meeting: “Next Friday 2/23/24 Time: 12:00 Catapult, 40767 US Hwy 19 N, Tarpon Springs 34689.” Father responds: “Can’t wait to see the boys! I’ll be there!” Mother responds: “Yep we’ll be there.”
At 4:10 PM, Mother texts Father: “We’re here where are you?” -- the exact moment the process server arrived and served Father. The court citation (Personal Service on Individual, Case 23-009419-FD, Shane Brown, Respondent/Father, Sixth Judicial Circuit, Pinellas County) is visible in the Father’s own exhibit alongside these texts. Exhibit J-2 annotation: “MOTHER REQUESTS MY LOCATION AT 4:10 PM ON FEBRUARY 23rd, 2024 -- EXACT TIME PAPERS WERE SERVED.” Proves visitation was a setup for Title IV-D enforcement, violating due process. Mother coordinated Father’s physical location with process service. Federal exhibit P2-B compiles the process server records (Robert L. Jones Inc., Server ID AB24493, 4:10 PM) alongside these deceptive text messages. This directly ties the service ambush to a deliberate, pre-planned scheme coordinated on the eve of Mother signing the retainer (Nov. 22, 2023). |
Exhibit J-2 (p.7) | Exhibit J-2 |
| Mar. 4, 2024 | BMB’S 9th BIRTHDAY -- FATHER BLOCKED FROM ALL CONTACT. BMB turns 9 years old (born Mar. 4, 2015). Father is not permitted to speak to or see BMB on his birthday. Exhibit J-2 (Father’s Exhibit List, p.8) documents: “MOTHER DID NOT ALLOW TO SPEAK TO BMB ON HIS 9th BIRTHDAY.” Father has now been denied contact with his son on two consecutive birthdays (BRB’s Dec. 4, 2023 and BMB’s Mar. 4, 2024). This adds to the documented pattern of Mother withholding child access -- which she later admits under oath at the Nov. 24, 2025 hearing. | Exhibit J-2 (p.8) | Exhibit J-2 |
| Apr. 8, 2024 | Original discovery compliance deadline passes (from Dec. 15, 2023 Demand) | Jan. 14, 2025 Order | -- |
| May 16, 2024 | ADOPTION ATTEMPT: Joint Petition for Adoption by Stepparent filed (Igor Radwanski and Kelly Burja), prepared by K. Dean Kantaras, P.A., under Fla. Stat. §63.087. Case number and division left blank on petition. | Filed -- Petition | Exhibit C-2 |
| May 16, 2024 | UCCJEA Affidavit filed by Igor Radwanski -- sworn residence history. Identifies Shane Brown as biological father. | Sworn Affidavit | Exhibit C-1 |
| May 17, 2024 | ADOPTION QUID PRO QUO LETTER. Kantaras firm letter explicitly ties child support compliance to adoption consent: “If you are not going to consent to the adoption, then we are going to collect child support.”
Full verbatim offer (KDK letterhead, verified original): “Kelly Burja is willing to put this whole litigation to rest, as long as you consent to the adoption of BMB and BRB. Upon your consent… we would be willing to waive past child support obligation. Once we receive from you all necessary, the basis for trying to collect past child support will be waived, and the paternity action will cease.” Translation: Consent to permanently losing your children = we drop the money case. Refuse = financial enforcement continues indefinitely. Financial enforcement used as leverage to coerce Father into relinquishing fundamental parental rights under Fla. Stat. §63.062 -- which requires consent of a living, known biological father. Father said no. Every time. All five attempts. And so the enforcement continued. |
Attorney Correspondence (Verified Original) | Exhibit D-1 |
| May 20, 2024 | Certificate of Nonappearance | Filed -- Court Docket | Exhibit H-4, Exhibit H-6 |
| Jun. 3, 2024 | Judicial Coordinator (Section 14, Tara) emails Danielle Harrer: “Judge Pollack said that a 15 or 30-minute CMC can be set regarding this matter.” Shane Brown CC’d directly at sb@vizionprotocol.io. Shane is in active communication with the court and counsel 10 weeks before the Aug. 9 hearing -- directly contradicts any claim he was disengaged. | Email Chain (Exhibit C, Exhibit C-3) | Exhibit C-3 |
| Jun. 7, 2024 | Danielle Harrer sends Notice of CMC Via Zoom to Section 14. Shane Brown CC’d (sb@vizionprotocol.io). | Email Chain (Exhibit C, Exhibit C-3) | Exhibit C-3 |
| Jun. 10, 2024 | Danielle Harrer sends Amended Notice of CMC Via Zoom to Section 14. Shane Brown CC’d (sb@vizionprotocol.io). Confirms Shane was receiving all scheduling communications. | Email Chain (Exhibit C, Exhibit C-3) | Exhibit C-3 |
| Jul. 23, 2024 | Kantaras letter (signed by Anita Abraham) -- 7-day ultimatum for financial compliance. Financial demands only; zero mention of reunification. Note: The Court’s own Jan. 14, 2025 Order characterizes this letter as a “good faith” communication -- i.e., the court treated the adoption-demand-as-litigation-weapon as good-faith outreach. | Attorney Correspondence; Jan. 14, 2025 Order (Finding #2) | Exhibit D-2 |
| Jul. 31, 2024 | Mother’s Motion to Compel filed (Filing #203762488) | Filed -- Court Docket | -- |
| Aug. 9, 2024 9:05 AM |
HEARING + PRE-HEARING EMAIL: At 9:05 AM, Shane emails Danielle Harrer, Section14@jud6.org, Kelly.Burja@gmail.com, and Dean Kantaras (kdk@kantaraslaw.com): “I will be attending the upcoming hearing and will be submitting this today as my official answer to the petition.” Attachment: Case23-009419-fd.pdf (5 MB) -- the full Answer to Petition. Father then orally acknowledges paternity at the hearing. Court sets aside prior default judgment. Court instructs Father (pro se) to submit documents to opposing counsel to “perfect the record” -- directing Shane to channel all documentary submissions through K. Dean Kantaras, P.A. This instruction is why Father subsequently sent all compliance documentation directly to opposing counsel via email. Source: Exhibit E-4, Motion to Correct Procedural Record; Exhibit C (Exhibit C-3). | Motion to Correct; Email (Exhibit C, Exhibit C-3) | Exhibit E-4; Exhibit C-3 |
| Aug. 13, 2024 4:35:47 PM |
FATHER EMAILS KDK -- GOOD FAITH COLLABORATION. At 4:35:47 PM, Shane emails Madison Fischer (madison@kantaraslaw.com), CC: Dean Kantaras (kdk@kantaraslaw.com) and Anita Abraham (anita@kantaraslaw.com). States he just received Clerk of Record Access credentials, is finalizing disclosures and getting parenting course done, and is “more than happy to help/send here and discuss in good faith with your team your requests, as well as doing anything and everything the honorable Judge Pollack has requested.” References BMB and BRB by name. Active, cooperative, documented communication 4 days after the hearing. | Email Chain (Exhibit C-1, Exhibit C-3) | Exhibit C-3 |
| Aug. 17, 2024 | Court order (deadline #1 for compliance) | Referenced in Feb. 3 Order | Exhibit F-1 |
| Aug. 23, 2024 4:25 PM |
FATHER FILES MOTION FOR EXTENSION + PROVIDES INSURANCE DOCUMENTATION. At 4:25 PM, Shane emails Madison Fischer, CC: Dean Kantaras, Anita Abraham, Kelly.Burja@gmail.com. 5 attachments (4 MB). States: “Please review our Motion for an Extension of Time submitted today and filed at the courthouse, also includes basic information but will provide entire insurance documents to provide to Kelly/court/etc. Health + Dental Insurance goes into effect for both boys September 1 and Full Dental begins October 1st.”
Insurance plan: myBlue Connected Care Silver 2332C. Monthly premium: $45.70 (subsidized). Enrolled members: BRB Brown and BMB Brown (both children). Primary applicant: Shane Brown. Deductible: $0 individual / family. Out-of-pocket max: $1,300 individual / $2,600 family. |
Email + Insurance Docs (Exhibit C-1/C-2, Exhibit C-3) | Exhibit C-3 |
| ~Aug.-Sep. 2024 | Kris Kaylor retained by Kantaras firm to handle case (~3 months total) | Email (Gabrielle) | Exhibit D-1 |
| Sep. 3, 2024 | Court order (deadline #2 for compliance) | Referenced in Feb. 3 Order | Exhibit F-1 |
| Sep. 9, 2024 | PARENTING COURSE COMPLETED -- Certificate of completion issued (Certificate ID: sb1jxxg3nb). Completed 36 days before the court’s October 15 deadline. Certificate URL: courtparentingclass.com/certificates/sb1jxxg3nb. Certificate emailed as PDF attachment to opposing counsel (KDK) on October 1, 2024 per the Court’s Aug. 9, 2024 instruction to “perfect the record” via opposing counsel -- confirmed by Father’s Exhibit List, Tab 4 (federal filing P4-B): “submitted certificate to opposing counsel by 10/1/24.” The Kantaras firm had the certificate in hand on Oct. 1, 2024 -- 74 days before the Dec. 16 docket filing and 52 days before the Nov. 22 hearing at which counsel claimed ignorance. | Certificate (Verified Original) | Exhibit E |
| Sep. 10, 2024 | Mother’s Amended Motion to Compel filed | Filed -- Court Docket | Exhibit H-4, Exhibit H-6 |
| Oct. 1, 2024 8:45 AM |
HARRER EMAILS SHANE -- ADDS PSYCH EVAL TO UPCOMING HEARING (8:45 AM). Danielle Harrer (danielle@kantaraslaw.com) emails Shane Brown (sb@vizionprotocol.io) at 8:45 AM -- 3 hours and 21 minutes before Shane’s 12:06 PM response. Subject: “RE: Burja v. Brown/Hearing dates.” States: “I am following up on the below scheduling request sent last Friday. We will also be including the Motion for Psychological Evaluation in this hearing. Please advise as soon as possible what date will work.”
Significance: KDK unilaterally adds the Motion for Psychological Evaluation to the upcoming hearing before Shane sends his good-faith email that same morning. Shane’s 12:06 PM response directly denies the GAL/psych eval request -- which KDK had already scheduled that morning. The psych eval was a demand, not a procedural necessity. |
Email (Exhibit C-3) | Exhibit C-3 |
| Oct. 1, 2024 12:06 PM |
FATHER SENDS 5-PAGE FORMAL EMAIL (P2-E3) -- Subject: “Re: Burja v. Brown/Hearing dates”. Sent at 12:06 PM to: Danielle Harrer, Kelly.Burja@gmail.com (Mother directly), and Dean Kantaras (KDK). States 313 days without meaningful contact with BMB and BRB.
3 attachments (4 MB total): (1) “Shane Brown -- PARENTING COURSE CERT.pdf”; (2) original-FE646901-EF39-48C4-9DD9-3876A28A75C7.jpeg; (3) processed-92DF2C99-3874-4172-A50E-4A024FB53FFD.jpeg. The parenting course certificate was physically delivered to the Kantaras firm as a PDF email attachment on this date, in direct compliance with the Court’s August 9, 2024 instruction to “perfect the record.” KDK’s own Oct. 1 response confirms: “Those go to our office.” The firm had the certificate 7 weeks and 3 days before the November 22 hearing at which Kris Kaylor claimed to be “unaware” of its existence. Parenting course verification link provided: courtparentingclass.com/certificates/sb1jxxg3nb. Google Drive evidence link provided in email: videos, photos, and pictures of missed birthdays, Christmas, and 313 days since last contact with boys. Father also proposes 60/40 time-sharing (60% Mother / 40% Father) and states he underwent a forensic audit of his finances to provide to the court. Cites Florida Rule 12.363 -- GAL evaluations must be grounded in good faith. Eight sections: (1) Obstruction of Parenting Time; (2) False Statements; (3) Unfounded and Delaying Motions; (4) Financial Transparency; (5) New Parenting Plan -- 60/40; (6) Pattern of Unethical Conduct; (7) Evidence of Good Faith Relationship (Google Drive -- missed birthdays, Christmas, 313 days); (8) Request for Immediate Judicial Intervention. Explicitly rejects GAL and psychological evaluation citing due process and parental alienation. “Shows ongoing parental alienation and that Plaintiff is being treated as a financial obligation rather than a parent.” |
-- | -- |
| Oct. 1, 2024 | Mother replies via text: “Do not contact me about the case.” -- strategic obstruction, refusal to engage on parenting time | -- | -- |
| Oct. 1, 2024 | KDK RESPONSE LETTER (P2-E2 / Exhibit E-1) -- EXPLICIT ADOPTION-GAL NEXUS. K. Dean Kantaras, Esq., BCS responds same day to Father’s email. Sent to sb@vizionprotoco.io (WRONG EMAIL -- missing “l” in “protocol” -- preserved service error). Letter states: “I was forwarded your message you sent to Ms. Burja this afternoon.”
KDK makes three written false allegations: Father (1) placed children’s safety at risk by his lifestyle and behavior; (2) only provides financial assistance when it works for him; (3) has consistently verbally abused Ms. Burja. Zero evidentiary basis provided for any of the three. THE EXPLICIT QUID PRO QUO (verbatim): “Based on your recent communications, it is apparent that you are not in agreement with consenting to a step-parent adoption. If you truly believe that you are capable of being the good father that you say you are, the psychological evaluation and the appointed GAL will show that.” Translation: Refuse adoption → face GAL + psych eval. This is the adoption-demand-as-litigation-weapon in writing, by a Board Certified Specialist in Family Law, sent the same day Father submitted his parenting course certificate. Zero mention of reunification. CC: Kelly Burja. |
KDK Letter (Verified Original) | Exhibit E-1 |
| Oct. 15, 2024 | Court-ordered deadline for parenting course completion -- course was completed 36 days before this date | Court Order | -- |
| Nov. 22, 2024 | HEARING -- DAY 366 -- 364 DAYS WITHOUT COMMUNICATION. Judge Pollack states: “It doesn’t even matter, you’re not even the father.” Judge states Father “did not comply” with parenting course. Mother’s attorney (Kris Kaylor, ~3 months on case) admits he was unaware of the certificate -- despite the Kantaras firm having received the certificate as a PDF email attachment 52 days earlier (Oct. 1, 2024), submitted by Father in direct compliance with the Court’s Aug. 9 instruction to “perfect the record.” KDK received it, failed to enter it into the record, and then their own attorney claimed ignorance at hearing. Father directed to leave chambers. Court denies motions for GAL and psychological evaluation.
Exhibit J-2 (Father’s Exhibit List, p.8) documents in large text: “AS OF TODAY, NOVEMBER 22 -- 364 DAYS WITHOUT COMMUNICATION.” Father has gone 364 consecutive days without any contact with his sons -- one day short of a full year -- as of this hearing date. This figure is Father’s own contemporaneous exhibit presented to the court. |
Motion to Correct; Email to Court; Exhibit J-2 (p.8) | Exhibit E-4, Exhibit I-4, Exhibit J-2 |
| Nov. 28-29, 2024 Thanksgiving |
THANKSGIVING DAY -- NO CONTACT + FOURTH ADOPTION ATTEMPT + FINANCIAL EXTORTION. Father is denied contact with both sons on Thanksgiving Day 2024. Exhibit J-2 (p.9): “NOVEMBER 2024 THANKSGIVING DAY -- DID NOT SPEAK TO CHILDREN.”
Stepfather Igor texts Father requesting adoption consent and threatening financial exposure via mandatory disclosure demands: “No problem, wanted to give you a chance to do something honorable for your children for once. Looking forward to your mandatory disclosures and financial affidavit.” Father replies: “Threats are unnecessary my friend.” Igor responds: “That behavior still shows abusive, threatening and intimidating threats with your condescending response and adoption request for the 4th time … noted.” Exhibit J-2 annotation: “STEPFATHER ADOPTION REQUEST + FINANCIAL EXTORTION RELATED TO CHILDREN.” Stepfather’s own message confirms this is the 4th adoption demand. Financial disclosures are weaponized as leverage -- same pattern as the May 17, 2024 letter. |
iMessage Screenshot; Exhibit J-2 (p.9) | Exhibit D; Exhibit J-2 |
| Dec. 4, 2024 Wed, 7:50 AM |
BARRON’S BIRTHDAY -- MOTHER EXPLICITLY CONDITIONS CHILD CONTACT ON STEPPARENT ADOPTION SIGNATURE. [CF-4] Father texts at 7:50 AM: “Happy Birthday BRB!!!!!! Your Daddy loves and misses you so much!!! I hope you have the best day ever.” and “Good Morning, I would love to set up a time to get on a call, birthday and/or let me know if there is any free time to say hi, drop off presents, have them mailed/dropped off at your place and or anyway to let him know his Daddy loves & misses him on his birthday!”
Mother’s response (verbatim): “I sent you the reunification information over a year ago, and you chose not to act on it. You’ve also taken money from the boys in the process. When someone who has been there for him every day since he was 9 months old, showing up without fail, asks you for a step-parent adoption, you don’t acknowledge his support or efforts. Instead, you threaten and mock him. I’m not going to facilitate…” Mother then states: “There’s a difference between extortion and whether or not I speak to my son on his birthday.” Then: “Shane, no one is extorting you, but you were already given the opportunity to sign the stepparent adoption and prefer to be their legal parent, that’s your decision. We’ll proceed with the paternity suit, and you’ll have the accountability that come with it.” Father responds: “Answer to the Petition. Being The ‘Father’ was already ‘agreed to’ on Aug 8th … which was submitted, sent and filed to the court, you and your legal team.” Exhibit J-2 annotation: “MOTHER DID NOT ALLOW TO SPEAK TO BARRON ON HIS 5th BIRTHDAY.” (Note: per UCCJEA Affidavit Exhibit C-1, BRB was born Dec. 4, 2018, making this his 6th birthday; Father’s exhibit labels it “5th.”) This text exchange is direct, written evidence of conditioning parental contact on stepparent adoption consent -- on the child’s own birthday. No court order permits this. Fla. Stat. §63.062 requires Father’s consent for adoption. Father has denied consent all five times. |
iMessage Screenshot; Exhibit J-2 (p.10) | Exhibit J-2 |
| Late Nov./Dec. 2024 | Kris Kaylor leaves the Kantaras firm | Email (Gabrielle) | Exhibit D-1 |
| Dec. 16, 2024 | Father files Motion to Correct Procedural Record -- parenting course certificate attached as exhibit, now on court docket. Confirmed by Mother’s own Exhibit List, Tab 8. | Filed -- Court Docket | Exhibit E-4 |
| Dec. 27, 2024 | Gabrielle Fuchslocher (Kantaras paralegal) email: “I apologize for our overdue Order... Kris Kaylor is no longer with the firm.” | Email (Verified Original) | Exhibit E-5 |
| Dec. 31, 2024 | CONFORMED ORDER -- GAL AND PSYCHOLOGICAL EVALUATION DENIED. Court enters conformed order. Both the Guardian ad Litem appointment AND the psychological evaluation are DENIED. These were the primary conditions demanded by opposing counsel in every correspondence letter (Jul. 23, Oct. 1, 2024; Dec. 18, 2025). Court’s rejection renders those demands moot. | Conformed Order (Verified Original) | Exhibit E-6 |
| Date | Event | Source | Exhibit |
|---|---|---|---|
| Jan. 10, 2025 9:15 AM |
HEARING via Zoom (9:15 AM) on Mother’s Amended Motion to Compel. Court reporter: Cathleen Tveteen. Mother present with Rachel Reyes-Silva, Esq. (Kantaras firm). Father did not appear. Court sounded the halls in Pinellas County courthouse. | Court Order | -- |
| Jan. 13, 2025 | FATHER FILES MOTION TO ACKNOWLEDGE COMPLIANCE (P4-A). Father proactively files a motion documenting his compliance with prior court orders one day before the Jan. 14 Order is entered. The court ignores this filing entirely -- the Jan. 14 Order does not acknowledge it, reference it, or address Father’s documented compliance posture. This filing, combined with the Dec. 16, 2024 certificate on the docket and the Oct. 1, 2024 email to opposing counsel, means Father’s compliance was documented in three separate places before the Feb. 3, 2025 false finding. | -- | -- |
| Jan. 14, 2025 5:03:26 PM |
ORDER GRANTING MOTHER’S AMENDED MOTION TO COMPEL. Signed: Circuit Judge Frederick L. Pollack at 5:03:26 PM (electronic docketing timestamp). Five factual findings, all financial: (1) Dec. 15, 2023 demand for financial information; (2) KDK’s Jul. 23, 2024 letter -- characterized by the court as a “good faith” communication; (3) Sep. 3, 2024 court order; (4) Sep. 10, 2024 Amended Motion to Compel; (5) §61.30(2)(b) income imputation language. Full discovery compliance ordered by Jan. 24, 2025. Attorney fees awarded to Mother. Income imputation threatened. Entire 3-page order is financial -- zero mention of parenting time, visitation, or children’s wellbeing.
Conformed copies sent electronically via JAWS to: Shane Brown (Pro Se) and K. Dean Kantaras, Esq., BCS. Confirms Shane received electronic service and that Dean Kantaras himself (not Kris Kaylor, who had left the firm in Dec. 2024) was the attorney of record at time of service. |
Court Order | -- |
| Jan. 24, 2025 | Discovery compliance deadline per Jan. 14 Order (10 business days) | Court Order | -- |
| Jan. 28, 2025 | Mother files Motion for Contempt and Sanctions (Filing #215532998) -- claims willful non-compliance “despite having the ability to do so” | Filed -- Court Docket | P4-B |
| Jan. 28, 2025 | Court orders Father to pay for mediation while continuing Title IV-D enforcement -- fee-gated visitation. Note: Phase 4 Exhibit List (P4-B) identifies “Jan. 28, 2025 -- Emergency Motion for Time-Sharing & Court Denial” as a single exhibit group. P4-B may encompass Father’s Jan. 28 motion + the Feb. 3 Court Denial as one paired exhibit (see also Jan. 31 entry). | P4-B | -- |
| Jan. 29, 2025 | Federal documents confirming Trump Administration’s Title IV-D funding freeze due to systemic bias -- federal recognition of enforcement abuses | -- | -- |
| Jan. 31, 2025 | Father files Emergency Motion for Enforcement of Time-Sharing and Make-Up Relief. Cites §61.13, Schutz v. Schutz, Rules 12.110 and 12.615. Requests immediate unsupervised visitation + daily communication. Notes 15+ months of alienation.
⚠️ As of the March 19, 2026 PTM filing -- over 13 months after this motion was filed -- it has NEVER been set for an enforcement hearing. Mother’s financial contempt motion (filed same period) was heard promptly. Father’s emergency motion for contact with his children sat on the docket for 13+ months without a hearing date. That asymmetry -- financial enforcement heard immediately, parent-child contact motion ignored for 13 months -- is the two-track system in documented form. (Phase 4 Exhibit P4-B is labeled “Jan. 28, 2025 -- Emergency Motion for Time-Sharing & Court Denial” -- date may be approximate, or P4-B bundles Jan. 28 + Jan. 31 activity + Feb. 3 denial as one exhibit group.) |
Filed (Referenced in Feb. 3 Order); P4-B | -- |
| Date | Event | Source | Exhibit |
|---|---|---|---|
| Feb. 3, 2025 | THE FALSE FINDING ORDER. Judge Pollack denies emergency motion. States parenting course “does not appear from the docket” -- FACTUALLY FALSE: certificate filed December 16, 2024 (49 days earlier), confirmed by Mother’s own Exhibit List, Tab 8. The certificate was also emailed directly to opposing counsel on Oct. 1, 2024 per the Court’s own Aug. 9 instruction to “perfect the record” -- KDK received it and failed to enter it. The false finding is therefore the direct result of opposing counsel’s failure to perform a court-directed duty. Orders mediation before any time-sharing relief. Imputes income at $61,440/year. Creates fee-gating chain: financial compliance → mediation → hearing → time-sharing. | Court Order (3 pages, Verified Original) | Exhibit F-1; P4-C |
| Feb. 13, 2025 | Hearing notice, motion, and court order -- child support enforcement prioritized while parenting rights ignored; evidence of judicial bias | -- | -- |
| Date | Event | Source | Exhibit |
|---|---|---|---|
| Mar. 14, 2025 | FEDERAL §1983 LAWSUIT FILED -- Brown v. Florida Dept. of Revenue, Case No. 8:25-cv-00621, U.S. District Court, Middle District of Florida, Tampa Division. Judge Pollack named as defendant (defended by Florida Attorney General). Claims: 42 U.S.C. §1983 -- due process, equal protection, parental rights violations. | Filed (CourtListener Verified) | Exhibit F-2 |
| Date | Event | Source | Exhibit |
|---|---|---|---|
| May 27, 2025 Bodily Attachment |
BODILY ATTACHMENT ORDER -- ARREST AUTHORIZED -- DAY 551. A bodily attachment order is entered authorizing Father’s arrest for civil contempt in a child support matter. No notice to Father. No hearing. No ability-to-pay finding before the order was entered.
Father could have been arrested -- for failing to pay money that the court imputed to him based on a false finding (Feb. 3, 2025 Order) -- without ever having been given the constitutional opportunity to demonstrate inability to pay. Turner v. Rogers, 564 U.S. 431 (2011) requires an ability-to-pay determination before civil contempt jailing. Bearden v. Georgia, 461 U.S. 660 (1983) prohibits jailing for failure to pay without first determining willfulness. Six days later (June 2), the Court’s own order found: “No credible evidence of willful noncompliance” and “No evidence of ability to pay.” The arrest order was constitutionally defective. The enforcement that gave rise to it violated Father’s due process rights. The arrest order was entered and the exoneration followed six days later -- with no reconciliation of those two outcomes in any written order. |
Court Order (Bodily Attachment) | -- |
| May 27, 2025 | HEARING on Mother’s Motion for Contempt and Sanctions. Father did not appear. Mother present with Matthew J. Loscher, Esq. (Kantaras firm). | June 2 Order | -- |
| May 29, 2025 | Opposing counsel submits Proposed Order on contempt -- JUDGE REFUSES TO SIGN IT. Court response: “After review, not signed. Court will be entering its own order.” | Verified Original | Exhibit G-1 |
| Jun. 2, 2025 | ORDER GRANTING-IN-PART MOTION FOR ENFORCEMENT. Discovery enforcement only. Contempt, sanctions, and attorney fees ALL DENIED. “No credible evidence of willful noncompliance” found by court. “No evidence of ability to pay” found. Discovery compliance deadline: June 16, 2025. | Court Order (3 pages, Verified Original) | Exhibit G-2 |
| Jun. 4, 2025 | “Wife’s” Motion to Appoint GAL filed (Filing #224658090). Identifies Petitioner as “Wife” -- parties were never married. Mother is married to Igor Radwanski. False designation in a sworn court filing. | Filed -- Court Docket | Exhibit G-3 |
| Jun. 16, 2025 | Discovery compliance deadline from June 2 Order | Court Order | -- |
| Jun. 23, 2025 | Judge Pollack first seeks extension in federal case -- Florida Attorney General’s office defending him | Federal Docket | -- |
| Aug. 13, 2025 | ECF DOC 46 -- JUDGE POLLACK FILES UNOPPOSED MTD EXTENSION IN HIS OWN FEDERAL CASE. Judge Pollack personally files a motion for extension to respond to Shane Brown’s §1983 complaint -- while simultaneously presiding over Shane Brown’s state family court case. This is documented proof that Judge Pollack is an active named federal defendant during the period he is ruling on matters adverse to Father. He has never disclosed this conflict. See Caperton v. Massey, 556 U.S. 868 (2009). | ECF Doc 46, 8:25-cv-00621 (CourtListener Verified) | Exhibit H |
| Date | Event | Source | Exhibit |
|---|---|---|---|
| Aug. 20, 2025 | MOTHER FILES MOTION FOR CONTEMPT AND MOTION TO STRIKE PLEADINGS. Both motions filed on the same date. The contempt motion triggers the judicial coordinator’s Sept. 5 scheduling email. The Motion to Strike Pleadings targets Father’s filings. Both motions are set for the December 23, 2025 evidentiary hearing. Note: This filing comes after the court already found “no credible evidence of willful noncompliance” and “no evidence of ability to pay” in the June 2, 2025 Order (Exhibit G-2) -- Mother files a second contempt motion on the same factual record. | Filed -- Court Docket | -- |
| Date | Event | Source | Exhibit |
|---|---|---|---|
| Sep. 5, 2025 11:53 AM |
JUDICIAL COORDINATOR SCHEDULES DEC 23 HEARING -- SHANE CC’D DIRECTLY. Tara (Section 14, Family Law, Sixth Judicial Circuit) emails Danielle Harrer (danielle@kantaraslaw.com) with CC to Shane Brown (sb@vizionprotocol.io) at 11:53 AM.
Hearing scheduled: Wednesday, December 23, 2025 at 9:00 a.m. EDT, 1 hour allotted. In-person evidentiary hearing at Pinellas County Courthouse, 315 Court Street, 4th Floor, Chambers/Room 421, Clearwater, FL 33756. Hearing is on: Petitioner’s Motion for Contempt and Motion to Strike Pleadings (both filed 8/20/25). Harrer instructed to prepare notice of hearing and serve all parties including Department of Revenue. Shane was CC’d directly by the court -- directly contradicting KDK’s Oct. 2 claim that he is “completely unresponsive.” |
Court Email (Verified Original); Exhibit H-3 | Exhibit H-3 |
| Sep. 10, 2025 | Notice of Hearing filed (Filing #231256081) -- footnote documents 5 coordination attempts by Father | Filed -- Court Docket | -- |
| Sep. 19, 2025 | FEDERAL CASE STAYED -- TRIGGERS VOLUNTARY CESSATION PATTERN. Federal case Brown v. Florida Dept. of Revenue, 8:25-cv-00621, is stayed by the Middle District of Florida. Case remains live on the docket. The stay does not dismiss the case; it preserves all claims.
Within 13 days of this stay, two major reversals occur in state court: (1) Oct. 2 -- KDK voluntarily withdraws the Motion to Appoint GAL via a non-attorney staff email to the judicial coordinator; (2) Oct. 3 -- the court withdraws the fee-gating requirement imposed by the Feb. 3, 2025 Order. Father’s federal brief argues both constitute voluntary cessation that does not moot the case. See City of Mesquite v. Aladdin’s Castle, 455 U.S. 283, 289 (1982). |
Federal Court Order (Exhibit H-2) | Exhibit H-2 |
| Oct. 2, 2025 9:46 AM |
HARRER EMAIL TO JUDICIAL COORDINATOR (Exhibit H-3) -- GAL ABANDONED + “UNRESPONSIVE” CLAIM. Danielle Harrer (Office Coordinator, K. Dean Kantaras, P.A.) replies to Tara (judicial coordinator) at 9:46 AM. CC: Shane Brown (sb@vizionprotocol.io).
Verbatim: “We have hearings currently scheduled on 10/16 at 10:30am as well as 12/23 at 9am in the above case. We will no longer be pursuing the Motion to Appoint GAL that is set on 10/16 and the attorney would like to move the 12/23 hearing sooner in its place. We would normally obtain permission from the other side for something like this, but Mr. Brown (pro se) is completely unresponsive. I was asked to reach out to you to check if this switch would be agreeable with the Court.” THREE BOMBSHELL FACTS IN ONE EMAIL: (1) KDK voluntarily abandons the Motion to Appoint GAL (Oct. 16 slot) -- the same GAL demand used in every adoption-demand letter (Jul. 23, Oct. 1, 2024; Dec. 18, 2024) as a condition of reunification. After the Dec. 31, 2024 conformed order denied GAL and the Sep. 19, 2025 federal stay, KDK drops it entirely -- no proper motion to withdraw filed, dismissed by non-attorney staff email. (2) “Completely unresponsive” claim is false on its face -- Shane is CC’d on this very email. The Sept. 10 Notice of Hearing documents 5 coordination attempts by Father. KDK tells the court coordinator Shane is unresponsive while simultaneously copying him on the message. (3) Ex parte-style communication -- non-attorney staff contacts judicial coordinator directly, seeks to reschedule hearing without proper inter-party consent, justifies bypass by misrepresenting Father’s responsiveness. Withdrawal comes 13 days after federal stay (Sep. 19) -- pattern of voluntary cessation of contested motions after federal scrutiny. |
Email (Verified Original); Exhibit H-3 | Exhibit H-3 |
| Oct. 3, 2025 | STATE COURT WITHDRAWS FEE-GATING REQUIREMENT -- VOLUNTARY CESSATION (DAY 2 OF 2-DAY PATTERN). One day after KDK abandons the GAL motion (Oct. 2), the state court withdraws the fee-gating requirement first imposed by the Feb. 3, 2025 Order -- which required Father to pay for mediation as a precondition to any time-sharing relief. This is the second major reversal in 24 hours, occurring 14 days after the federal stay (Sep. 19, 2025).
Federal Mootness Argument (from Father’s brief, Section D -- Mootness/Voluntary Cessation): “The October 3, 2025 withdrawal of the court’s fee-gating requirement -- instituted after this lawsuit -- does not moot the case. Under settled law, ‘the voluntary cessation of allegedly wrongful conduct does not moot a case’ unless it is absolutely clear the behavior will not recur. See City of Mesquite v. Aladdin’s Castle, 455 U.S. 283, 289 (1982). Here, the DOR and state court have made no binding, long-term change beyond this single case; they could simply reinstate the fee gate absent a court order.” “More fundamentally, the very act of rescinding the fee requirement underscores the Due Process risk identified in Mathews v. Eldridge -- the fact that the court voluntarily removed the policy after Plaintiff’s complaint highlights that without ‘verify-before-seeking,’ the prior policy posed a high risk of erroneous deprivation.” Mathews v. Eldridge Three-Prong Framework (applied in federal brief): (i) Private interest: parent-child bond is “fundamental” and deeply personal; (ii) Risk of erroneous deprivation: “high -- indeed, proven -- when contempt or visitation denial proceed without first adjudicating ability-to-pay or less-restrictive alternatives”; (iii) Government interest: can be satisfied through “routine non-custodial means (wage garnishment, license suspension, etc.) without the drastic step of incarcerating or financially blocking a parent absent findings.” THE PATTERN: Mar. 14, 2025 → federal lawsuit filed → Jun. 4, 2025 → new GAL motion filed → Aug. 13, 2025 → Judge Pollack files MTD extension in his own federal case → Sep. 19, 2025 → federal stay → Oct. 2, 2025 → GAL withdrawn via non-attorney staff email to Judicial Coordinator → Oct. 3, 2025 → fee-gate withdrawn. Every contested order challenged in the federal case was voluntarily rescinded within 14 days of the federal stay -- then reinstated 76 days later (Dec. 18, 2025 letter). |
City of Mesquite, 455 U.S. 283; Mathews v. Eldridge | Exhibit H-2 |
| Oct. 6, 2025 | Responses in opposition filed in federal case -- FL Attorney General defending Judge Pollack | CourtListener | -- |
| Oct. 16, 2025 | FIRST HEARING -- “Wife’s Exhibit List” presented (14 tabs). Includes Retainer Agreement and Invoices. | Verified Original | Exhibit H-4 |
| Date | Event | Source | Exhibit |
|---|---|---|---|
| Nov. 24, 2025 | SECOND HEARING -- DAY 732 -- “Mother’s Exhibit List” presented (different 14 tabs -- 12 of 14 tabs CHANGED from Oct. 16 list). Court reporter: Alessandra Da Pra. Judge acknowledges different binders on the record.
Father cross-examines Mother using her own exhibit tab. Mother’s six sworn admissions (on the record): (1) withholding children from Father; (2) making negative statements about Father to children; (3) physical abuse by Stepfather Igor (multiple times); (4) five adoption attempts; (5) claims she “never” received financial support -- contradicted by texts read into the record at the same hearing; (6) concedes Father is the father. Mother also claims: “we were having a hard time getting ahold of him” -- directly contradicted by months of her own text messages where she communicated with, responded to, and arranged meetings with Father. Zero written findings were entered on any of the six admissions. Judge states reunification is “only a band aid.” In a case where 100% of court action was directed at financial enforcement and 0% at reunification, calling reunification “a band aid” is the judicial system confirming its own priorities on the record. Not entered in any written order. Cross-examination of Father begins at 3:19 PM and is cut off at 3:30 PM -- 11 minutes in -- with 11 minutes still remaining. Both parties agreed on the record that one more hour was needed. No additional hearing was set that day. The next continuation was coordinated to January 16, 2026. ⚠️ THE “EXCUSE ME” EXCHANGE -- ON THE RECORD: At the close of proceedings, Judge Pollack asks Mother directly: “Is [Father] the father of the children?” Mother: “Yes.” Father: “Did it really just take two years to get that on the record?” Judge Pollack: “Excuse me.” “Not even the father” was said on Day 365 (Nov. 22, 2024). “Yes” was confirmed on Day 732. Neither statement appears in any written order. Father’s question placed the gap between those two statements permanently on the transcript. A judge with a clean answer gives that answer. “Excuse me” -- said with a court reporter present, in response to an accurate statement about the Court’s own record -- is not a denial. |
Sworn Testimony; Email to Court; Exhibit H-6 | Exhibit H-6, Exhibit H-7 |
| Dec. 1, 2025 | Deadline: Financial Affidavit + Mandatory Disclosures due (per Jan. 14, 2026 Order). Father testified he had Financial Affidavit ready but not filed. | Court Order; Testimony | -- |
| Dec. 8, 2025 | ORDER DUE -- NOT ENTERED -- “UNDER ADVISEMENT.” Judge Pollack’s own Practice Preferences, Section E require a proposed order to be submitted within 14 days of the conclusion of a hearing. November 24 + 14 days = December 8, 2025. No order is entered.
Father emails section14@jud6.org asking for the status of the order. JA Tara Martin responds: “The matter is UNDER ADVISEMENT.” Father emails again. JA: “UNDER ADVISEMENT.” Father emails again. JA responds a third time: “UNDER ADVISEMENT.” The Judge’s own Judicial Assistant had to remind him twice to enter his own order -- on a case involving two children who had not seen their father in over two years. The order did not arrive until January 14, 2026 -- 51 days after the November 24 hearing and 37 days past the Judge’s own 14-day rule. While the order was under advisement, Father sent his good-faith Dec. 17 email requesting Christmas contact. KDK responded Dec. 18 with the 5th adoption demand. |
Court Email (section14@jud6.org); Practice Preferences §E | -- |
| Dec. 17, 2025 Wed, 11:04 AM |
FATHER’S GOOD FAITH EMAIL TO KDK -- REQUESTING IMMEDIATE PARENT-CHILD CONTACT + INTERIM TIME SHARING. Subject: “RE: Request for Immediate Parent Child Contact and Interim Time Sharing (Children’s Best Interests).” Sent from sb@vizionprotocol.io to mackenzie@kantarasfirm.com (CC: matthew@kantarasfirm.com, gabriellab@kantarasfirm.com, attorneys@kantaraslaw.com) at 11:04 AM.
Father opens: “I am writing in good faith and through counsel, as requested, regarding parent child contact and interim time sharing pending the next hearing by the trial judge.” Father states the current factual record verbatim: “After more than 730 days, I am now officially recognized as the children’s biological father. During this period, I have had no contact or communication with the children. There are currently no criminal matters, no pending GAL or psychological evaluations, no supervised-visitation orders, and no court orders prohibiting parent child contact.” Father documents attempted contact: “I have attempted on multiple occasions over the past 6-9 months to communicate directly with the mother regarding the children, particularly around birthdays, holidays, and general co-parenting matters, but appear to be blocked from doing so.” Father’s four specific requests: (1) Immediate phone or video contact with the children, to begin as soon as possible; (2) In-person parenting time over the Christmas holiday, including meaningful time to exchange gifts and reconnect (including overnights); (3) A discussion to establish an interim 50/50 time sharing schedule, or at minimum a graduated schedule that promptly restores consistent parent child contact pending the next hearing; (4) A brief call between counsel (or with the parties present) to coordinate logistics. Father documents that all three of Mother’s prior conditions have been removed: “Mediation has already occurred, and the three conditions previously raised by the mother, (1) supervised visitation, (2) appointment of a GAL and/or psychological evaluations, and (3) drug testing, are no longer being pursued. These items were either denied by the Court (without prejudice) and later withdrawn, or expressly removed from consideration and are not presently supported by any findings or pending motions on the record. As such, there are currently no restrictions, safety findings, or unresolved conditions that would warrant continued withholding of all parent child contact.” Father offers voluntarily: “Although no such requirement is currently pending or ordered, I am willing to voluntarily complete and pay for a drug test as a good faith measure, solely to demonstrate cooperation and to address any residual concerns from prior motions, not as a condition, demand, or prerequisite imposed by either party.” Father offers full financial cooperation: “I am fully willing to provide all requested financial information to assist with child support calculations prior to the next hearing.” Father sets deadline: “Please let me know by Friday, December 19, whether we can coordinate immediate contact and holiday parenting time.” KDK responds the very next day (Dec. 18) -- not with a parenting plan, not with a phone call -- but with the 5th adoption attempt, reinstating psych eval, drug screen, and GAL-style conditions. The contrast between Dec. 17 (cooperative, documented, good faith) and Dec. 18 (adoption demand) is the mootness argument made visible in real time. |
Email (Verified Original -- sb@vizionprotocol.io to KDK, 12/17/2025) | Exhibit I-1 |
| Dec. 18, 2025 | FIFTH ADOPTION ATTEMPT -- “730-DAY” LETTER -- RESPONSE TO FATHER’S DEC. 17 GOOD FAITH EMAIL -- VOLUNTARY CESSATION PROVEN CORRECT. One day after Father sent a cooperative, documented request for immediate parent-child contact (Dec. 17), KDK responds not with a parenting plan but with this letter. Kantaras letter admits “lack of meaningful communication in the past 730 days.” Reinstates demands for psych eval + drug screening + GAL-style conditions. Language: “If you are serious/sincere…” Conditional demands not grounded in any court order. References their own Oct. 1, 2024 letter from 14 months prior -- proving continuous 14-month demand cycle with zero reunification effort. Actual separation: 756 days (understated by 26 days).
THIS LETTER PROVES THE MOOTNESS ARGUMENT WAS CORRECT. On Oct. 2, 2025 KDK told the Judicial Coordinator they would “no longer be pursuing” the GAL motion. On Oct. 3, 2025 the fee-gating requirement was withdrawn. Father’s federal brief argued these were voluntary cessation acts that would not remain permanent -- citing City of Mesquite v. Aladdin’s Castle, 455 U.S. 283, 289 (1982): “the behavior could simply recur.” 76 days after voluntarily dropping all contested demands, this letter: (1) reinstates GAL-type conditions (“If you are serious/sincere” conditional framework); (2) reinstates psychological evaluation demand; (3) reinstates drug screening demand; (4) makes the fifth adoption attempt. Every demand that was “voluntarily” abandoned in October 2025 is back in writing by December 18, 2025. The recurrence occurred in exactly 76 days -- the fastest possible confirmation that the voluntary cessation was tactical, not genuine. The chain is now complete and documented: federal lawsuit (Mar. 14, 2025) → federal stay (Sep. 19) → Oct. 2 GAL withdrawn via non-attorney email to JA/Danielle → Oct. 3 fee-gate withdrawn → Dec. 18 ALL demands reinstated. The federal brief’s City of Mesquite argument is vindicated by the opposing counsel’s own subsequent conduct. |
Attorney Correspondence (Verified Original); Federal Brief Section D | Exhibit I-1 |
| Date | Event | Source | Exhibit |
|---|---|---|---|
| Jan. 14, 2026 Day 783 -- 51 days late |
ORDER FINALLY ENTERED -- 51 DAYS AFTER NOV. 24 HEARING -- 37 DAYS PAST JUDGE’S OWN 14-DAY RULE. Order arrives less than 48 hours before the January 16 hearing it sets. JA Tara Martin had to remind Judge Pollack twice to enter his own order (December 2025 emails to section14@jud6.org). The delay was caused entirely by the Court.
What the January 14 Order does NOT contain -- despite 51 days to write it: (1) No written paternity adjudication -- despite Mother’s oral “Yes” on Nov. 24 and “not even the father” on Day 365; (2) No written findings on Mother’s six sworn admissions (withholding children, negative statements, physical abuse, five adoption attempts, false financial claim); (3) No finding on the domestic violence admission; (4) No reconciliation of June 2 exoneration with continued enforcement posture; (5) No written order on which exhibit set was admitted (Oct. 16 vs. Nov. 24 binders); (6) No written best-interest findings; (7) No explanation for the 51-day delay; (8) No acknowledgment that the delay violated Practice Preferences Section E. The order the Judge took 51 days to write addresses the November 24 hearing in one paragraph -- then sets the next hearing. |
Court Order (Verified PDF) | Exhibit I-3 |
| Jan. 16, 2026 12:21 PM -- 69 min before hearing |
FATHER’S 12-ISSUE EMAIL TO THE COURT -- 69 MINUTES BEFORE THE HEARING. Father received the January 14 Order less than 48 hours before the hearing it set -- a delay caused entirely by the Court’s own 37-day violation of its own 14-day rule. At 12:21 PM, Father sends a multi-page email to section14@jud6.org, copied to opposing counsel. 12 documented, sourced issues:
(1) No written paternity adjudication -- oral “Yes” Nov. 24 and “not even the father” Nov. 22, 2024 both unwritten; (2) Two contradictory oral statements on the most foundational question in the case -- zero written orders on either; (3) Zero §61.13 best-interest findings in 800+ days -- the 20 mandatory factors have never been addressed in any written order; (4) Civil-to-coercive enforcement without written ability-to-pay findings (income imputed $61,440 -- no willfulness finding -- arrest order entered without hearing); (5) Mother’s six sworn admissions on Nov. 24 -- zero written findings on any of them; (6) Exhibit binder switch acknowledged on the record -- no written order resolving which exhibits were admitted; (7) Exhibit D-1 adoption demand letter (May 17, 2024) -- extra-judicial conditions conditioning parental rights on financial compliance, no court authorization; (8) June 2 exoneration (“no willful noncompliance,” “no ability to pay”) vs. continued enforcement -- never reconciled in any written order; (9) Dec. 18, 2025 Kantaras letter reinstated court-denied conditions (psych eval, GAL) -- Dec. 31, 2024 Order Exhibit E-6 had already denied them -- no new court order authorizing reinstatement; (10) No written order identifying which exhibit set is in evidence; (11) 48-hour notice problem -- caused by Court’s own 37-day delay violating Practice Preferences §E; (12) GAL motion withdrawn by non-attorney staff email (Oct. 2) -- no formal motion to withdraw -- Dec. 18 letter then privately reinstated the same GAL conditions. Father requested a continuance and certified transcripts of all four hearing dates. The email that the Judge later characterized as “umbrage” produced more procedural progress than four prior hearing sessions combined. |
Email to section14@jud6.org (Verified Original) | Exhibit I-4 |
| Jan. 16, 2026 1:30 PM -- Day 785 |
HEARING -- FATHER DOES NOT APPEAR -- CONTINUANCE GRANTED -- JUDGE CALLS EMAIL “UMBRAGE.” Father’s basis for non-appearance: 48-hour notice, caused by Court’s own 37-day delay. JA Tara Martin is absent for the afternoon session. Judge Pollack reads the section14@jud6.org email inbox himself. He finds Father’s 12:21 PM email. Petitioner is present with counsel. Deputies sound the halls. Father is not there.
Jan. 16 Order verbatim (Finding #4): “The multi-page e-mail takes umbrage with the timeliness of the rendition of the written order from the November hearing continuing the matter to today and requests a continuance of same.” Result: Continuance GRANTED over Petitioner’s objection. First Pre-Trial Conference in the entire history of this case -- Day 786. April 2, 2026 Evidentiary Hearing set. Pre-Trial Memorandum due March 19, 2026 at 5:00 PM. AI note-taking prohibited. Eight sanction categories listed for noncompliance. 10 of Father’s 12 issues: no written order of any kind entered. 1 of 12: continuance GRANTED. 1 of 12: pending. The email the Judge called “umbrage” produced the first Pre-Trial Conference in 785 days. Zero contact continued -- Day 785. |
Court Order (Verified PDF) | Exhibit I-5 |
| Mar. 4, 2026 | BMB’s 11th birthday -- spent without his Father (3rd consecutive birthday in separation) | Calculated | -- |
| Mar. 19, 2026 | DEADLINE: Pre-Trial Memorandum due at 5:00 PM -- Day 847 of separation | Court Order | -- |
| Apr. 2, 2026 | HEARING: Pre-Trial Conference / Evidentiary Hearing at 1:30 PM EDT -- Day 861 of separation | Court Order | -- |
All day counts calculated from November 23, 2023 (Day Zero -- last contact between Father and children).
| As of Date | Day Count | Context |
|---|---|---|
| Nov. 22, 2023 | Day −1 | Mother signs attorney retainer -- PREMEDITATION |
| Nov. 23, 2023 | Day 0 | Last contact -- “The boys will be happy to see you” |
| Dec. 4, 2023 | 11 | BRB’s 5th birthday -- present left at door; no contact. Mother goes silent Dec. 4-24. |
| Dec. 25, 2023 | 32 | Christmas Day -- no contact with BMB or BRB |
| Feb. 3, 2024 | 72 | Fake meeting -- Father arrives, children/Mother not present. Actual service: Feb. 23, 2024 at Catapult, 4:10 PM (Exhibit J-2 p.7) |
| Feb. 23, 2024 | 92 | Mother texts to confirm Father’s location at 4:10 PM -- exact moment of service. Catapult, Tarpon Springs. (Exhibit J-2 p.7) |
| Mar. 4, 2024 | 102 | BMB’s 9th birthday -- Father blocked from speaking to BMB (Exhibit J-2 p.8) |
| Oct. 1, 2024 | 313 | Father’s 5-page email (12:06 PM) states “313 days”; attaches parenting cert PDF; proposes 60/40 plan; KDK responds same day with explicit adoption-GAL quid pro quo |
| Nov. 22, 2024 | 365 | “Not even the father” hearing + cross-exam admissions. Exhibit J-2: “364 DAYS WITHOUT COMMUNICATION” (Father’s own exhibit) |
| Nov. 28-29, 2024 | 371-372 | Thanksgiving -- no contact + 4th adoption attempt; Igor names it “4th time” (Exhibit J-2 p.9) |
| Dec. 4, 2024 | 377 | BRB’s birthday -- Mother conditions contact on stepparent adoption signature in writing (Exhibit J-2 p.10). “No one is extorting you, but you were already given the opportunity to sign the stepparent adoption.” |
| Feb. 3, 2025 | 438 | False finding order |
| Mar. 14, 2025 | 477 | Federal complaint filed (259-page exhibit packet) |
| Jun. 2, 2025 | 557 | No-willful-contempt order |
| May 27, 2025 | 551 | Bodily attachment order -- arrest authorized. No notice, no hearing, no ability-to-pay finding. June 2 (6 days later): court finds no willfulness, no ability to pay. Constitutionally defective order never reconciled in writing. |
| Nov. 24, 2025 | 732 | "Did it really just take two years to get that on the record?" -- Judge: "Excuse me." Cross cut at 3:30 PM. 6 sworn admissions. "Band aid." No written findings on any of it. |
| Dec. 8, 2025 | 746 | Order DUE per Practice Preferences §E (14 days) -- not entered. "Under advisement." JA reminded Judge twice. Order not entered until Jan. 14 -- 51 days late. |
| Dec. 17, 2025 | 755 | Father’s good faith email to KDK: no criminal matters, no GAL, no psych eval, no court orders blocking contact. 4 requests: phone contact, Christmas overnights, 50/50 plan, coordination call. KDK responds next day with 5th adoption demand. |
| Dec. 18, 2025 | 756 | KDK letter says “730” -- understated by ~26 days. 5th adoption demand. All conditions reinstated 24 hours after Father’s good faith email. |
| Jan. 14, 2026 | 783 | Order entered 51 days late -- 37 days past Judge’s own 14-day rule. No paternity adjudication. No findings on 6 sworn admissions. Arrives <48 hrs before Jan. 16 hearing. |
| Jan. 16, 2026 -- 12:21 PM | 785 | Father’s 12-issue email to Court -- 69 min before hearing. Judge reads it himself (JA absent). Continuance GRANTED. Judge calls it “umbrage.” First Pre-Trial Conference in case history. |
| Mar. 4, 2026 | 832 | BMB’s 11th birthday (3rd consecutive without Father) |
| Mar. 18, 2026 | 846 | Today |
| Mar. 19, 2026 | 847 | Pre-Trial Memorandum deadline |
| Apr. 2, 2026 | 861 | Evidentiary Hearing date |
| # | Finding | Summary | Exhibit |
|---|---|---|---|
| 1 | “The Setup” -- Service Ambush | Nov. 22, 2023: retainer signed (from Mother’s own exhibit). Nov. 23: final visit. Nov.-Feb.: Mother communicated with Father via text. Feb. 2024: Mother arranges fake meeting -- children never there -- process server ambush. Nov. 2024 cross-exam: Mother claims “couldn’t reach him” -- destroyed by months of her own text messages. | Exhibit C-1, Exhibit H-4 |
| 2 | False Finding -- Parenting Course Certificate | Certificate on court docket since Dec. 16, 2024 (confirmed by Mother’s own Exhibit List, Tab 8). Feb. 3, 2025 Order states it “does not appear from the docket” -- issued 49 days after the certificate was filed. Binary factual error in a court order. | Exhibit F-1, Exhibit E-4 |
| 3 | June 2 Order Contradicts Enforcement | Court found no credible evidence of willful noncompliance and no evidence of ability to pay. Denied contempt, sanctions, and fees. Judge refused to sign opposing counsel’s proposed contempt order. Yet enforcement posture continued. | Exhibit G-2, Exhibit G-1 |
| 4 | Exhibit Manipulation -- 12 of 14 Tabs Changed | Oct. 16, 2025: “Wife’s Exhibit List” (14 tabs). Nov. 24, 2025: “Mother’s Exhibit List” (14 tabs) -- 12 of 14 tabs different. Judge acknowledged different binders on the record. | Exhibit H-4, Exhibit H-6 |
| 5 | Mother’s Sworn Admissions | Under oath, Mother admitted: withholding children from Father, negative statements about Father to children, physical abuse by Stepfather, five adoption attempts. Claim of “never” receiving financial support contradicted by texts read into the record. | Exhibit E-3, Exhibit H-7 |
| 6 | 730-Day Written Admission | Opposing counsel’s own letter (Dec. 18, 2025) admits “lack of meaningful communication in the past 730 days” -- 730 days of separation acknowledged by the party seeking to maintain it, with no court order, no best-interest findings, and no fitness adjudication supporting it. | Exhibit I-1 |
Mother admitted under oath (Nov. 24, 2025) that Stepfather has attempted adoption five times. Stepfather’s own text message references “4th time.”
| Date | From | Content | Adoption Reference? | Reunification Mention? |
|---|---|---|---|---|
| May 17, 2024 | K. Dean Kantaras, P.A. | EXPLICIT QUID PRO QUO: “If you are not going to consent to the adoption, then we are going to collect child support.” Ties parental rights directly to financial capitulation. [CF-4] | Yes (3rd attempt) | NO |
| Jul. 23, 2024 | Anita Abraham (Kantaras firm) | 7-day ultimatum for financial compliance. Financial demands only. | No | NO |
| Oct. 1, 2024 | K. Dean Kantaras | GAL + psych eval + financials “or else” no withdrawal of motions. References adoption. | Yes (3rd) | NO |
| Dec. 18, 2025 | K. Dean Kantaras | “730 days” admission. Conditional demands for psych eval + drug screening. “If you are serious/sincere...” References Oct. 1, 2024 letter from 14 months prior. | Yes (5th) | NO |
Pattern: Four letters over 19 months (May 2024 - December 2025). All contain financial or compliance demands. Three reference adoption -- the first explicitly conditioning parental rights on adoption consent ([CF-4]). None mention reunification, time-sharing, the children’s wellbeing, or any path to restoring the parent-child relationship. The December 2025 letter references the October 2024 letter, proving a continuous 19-month demand cycle with zero reunification effort. The court independently denied the GAL and psychological evaluation (Dec. 31, 2024, Exhibit E-6) -- rendering the central demands of all four letters moot.