Case No. 23-009419-FD-14 | Sixth Judicial Circuit | Pinellas County, Florida
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Exhibit B - Case Presentation
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, FLORIDA - FAMILY LAW DIVISION
Burja v. Brown
847
CONSECUTIVE DAYS WITHOUT THEIR FATHER
B.M.B.
Age 11
B.R.B.
Age 7
That is 20,328 hours of a father and his children kept apart.
0
Written Orders
Suspending Contact
0
Best-Interest
Findings Entered
0
Findings of
Parental Unfitness
0
Written Paternity
Adjudication
0
Phone Calls, Visits,
or Letters Allowed
A Father, Two Children, and a System That Forgot Half Its Job
Burja v. Brown | 23-009419-FD-14
Exhibit B
2 / 29

Who This Is Actually About

At the center of every number, every violation, every filing, are two children.

B.M.B.
Age 11  |  Born March 4, 2015
Age at separation: 8 years old
4th birthday without Father: March 4, 2026
Missed: 9th, 10th, 11th birthdays
Percent of life without Father: 30%
Wrote a Father's Day book about his dad (Exhibit C)
Transitioned from elementary to middle school - without Father
Old enough to remember. Old enough to wonder why.
B.R.B.
Age 7  |  Born December 4, 2018
Age at separation: 4 years old
3rd birthday without Father: December 4, 2025
Missed: 5th, 6th, 7th birthdays
Percent of life without Father: 40%
Entire school experience - without Father
Was below school age when separation began
Young enough that the memories are fading.
0 phone calls. 0 video calls. 0 visits. 0 letters delivered. 0 birthday cards. 0 Christmas mornings. 0 goodnight hugs. 847 days.
4 Christmases. 7 birthdays. 2 Father’s Days. All without Dad. B.M.B.: 30% of his life. B.R.B.: 40% of his life.
Burja v. Brown | 23-009419-FD-14
Exhibit B
3 / 29

20,328 Hours. How Were They Spent?

100% of this Court's action was directed at financial enforcement against Father.
0% was directed at reunifying Father with his children.

WHAT THE COURT DID
Income imputation at $61,440/yr ENFORCED
Contempt proceedings initiated ENFORCED
Bodily attachment (jail) order - no hearing ENFORCED
False finding order entered (Feb 3, 2025) ENFORCED
Enforcement continues after June 2 exoneration ENFORCED
"You're not even the father" / "Band aid" ON RECORD
WHAT THE COURT DIDN'T DO
Order any phone call with children 0 HOURS
Order supervised visitation 0 HOURS
Order reunification therapy 0 HOURS
Appoint a Guardian ad Litem 0 HOURS
Assess DV safety in children's home 0 HOURS
Rule on Father's Emergency Motion (13+ months) 0 HOURS
100%
Court Time on
Financial Enforcement
vs
0%
Court Time on
Children's Reunification
Zero of 20 mandatory § 61.13(2)(c) best-interest factors addressed in any written order - 847 days
Burja v. Brown | 23-009419-FD-14
Exhibit B
4 / 29

The Timeline: 847 Days in 60 Seconds

DAY DATE EVENT
0 Nov 23, 2023 LAST CONTACT. Father's final contact with B.M.B. (age 8) and B.R.B. (age 4). Total separation begins. No court order.
22 Dec 15, 2023 Petition for Paternity filed by Mother. Father not yet served.
176 May 16, 2024 5th ADOPTION PETITION filed by stepfather + mother. Same attorney. Next day: quid pro quo letter - "consent to adoption... we waive child support."
261 Aug 9, 2024 Father re-enters case. Orally acknowledges paternity. Files Answer. Court directs opposing counsel to file it. They never do.
292 Sep 9, 2024 Parenting course COMPLETED - 36 days before the court deadline.
366 Nov 22, 2024 Judge states: "It doesn't even matter, you're not even the father." Father directed to leave chambers. GAL + psych eval DENIED.
390 Dec 16, 2024 Father files Motion to Correct Record. Certificate placed ON DOCKET.
438 Feb 3, 2025 FALSE FINDING ORDER: States certificate "does not appear from the docket" - it was filed 49 days earlier. Income imputed at $61,440/yr. Time-sharing DENIED.
478 Mar 14, 2025 Federal civil rights complaint filed. Judge Pollack named as defendant.
552 May 27, 2025 BODILY ATTACHMENT ORDER - authorizes Father's arrest. No notice. No hearing. No ability-to-pay finding.
558 Jun 2, 2025 Court finds: NO willful misconduct. NO ability to pay. Contempt DENIED. Sanctions DENIED. Fees DENIED. Enforcement continues anyway.
733 Nov 24, 2025 Mother admits under oath: withheld children 730+ days, negative statements, DV by stepfather, 5 adoption attempts. Judge calls reunification "only a band aid."
731 Nov 24, 2025 "Is he the father?" Mother: "Yes." Father: "Did it really just take two years to get that on the record?" Judge: "Excuse me." Cross cut off at 3:30 PM. 11 min remaining.
782 Jan 14, 2026 Order entered 51 days after Nov 24 hearing. 37 days past deadline. Father receives order with less than 48 hours notice.
784 Jan 16, 2026 Father sends 12-issue email at 12:21 PM. Judge calls it "umbrage." Continuance GRANTED.
847 Mar 19, 2026 TODAY. Still zero contact. Still no written findings. Still no parenting plan. Still no paternity adjudication.
Violation / Denial
Father's Compliance
Admission / Warning
Federal Action
Burja v. Brown | 23-009419-FD-14
Exhibit B
5 / 29

He Did the Course. They Said He Didn't. The Docket Says Otherwise.

STEP DATE STATUS WHAT HAPPENED
1 Sept 9, 2024 DONE Course completed 36 days early. Certificate ID: sb1jxxg3nb.
2 Oct 15, 2024 DEADLINE Court deadline for course completion. Already done 36 days prior.
3 Dec 16, 2024 FILED Certificate placed ON DOCKET via Motion to Correct. 49 days before the false order.
4 Feb 3, 2025 FALSE Order states certificate "does not appear from the docket." It was filed 49 days earlier. Income imputed $61,440/yr. Time-sharing DENIED.
The order said it wasn't there. The docket proves it was.
This is not an opinion. It is a fact checkable in 60 seconds.
Petitioner's own exhibit list (Tab 8, November 24, 2025 hearing) lists this exact filing - confirming everyone knew it existed.
49 DAYS ON THE DOCKET BEFORE THE JUDGE SAID IT WASN'T THERE
The Judge’s Own Rule - Practice Preferences § I-9

“Any and all persons required to take the 4-hour Parent Education and Family Stabilization course may attend the parenting class online or via distance learning without need of any motion seeking, or order granting, permission to do so.”

Father completed the course online on September 9, 2024. The Judge’s own published rule authorized it. Five months later, the Judge’s own order found the certificate “does not appear from the docket.”

Burja v. Brown | 23-009419-FD-14
Exhibit B
6 / 29

The Attorney Problem Nobody Addressed

Father was punished for his own attorney's failure to file a court-directed document.

STEP DATE WHAT HAPPENED
1 Aug 9, 2024 Father files Answer. Court directs Kris Kaylor to file it. Kaylor does NOT file.
2 Oct 2024 Kaylor receives certificate from Father per judge's instruction. Claims "unaware" at Nov 22 hearing - despite receiving it weeks earlier.
3 Nov 22, 2024 Judge says: "Not even the father." Father told to leave chambers. Motion denied.
4 Dec 2024 Kaylor confirmed departed firm. Certificate knowledge lost in transition.
The "not even the father" ruling happened because the Answer was never filed - not because of anything Father did.
Who is responsible when opposing counsel fails to execute a court-directed filing and a father loses his parental status as a result?
Burja v. Brown | 23-009419-FD-14
Exhibit B
7 / 29

The Judge's Entire Career Was This One Job

JUDGE POLLACK'S ENTIRE CAREER WHAT THIS CASE ACTUALLY REQUIRED
Child support enforcement Balance: finance AND parenting
Florida Dept. of Revenue Independent family law judgment
Title IV-D prosecution Parent-child relationship expertise
"Thousands of cases" for DOR 20 best-interest factors analysis
"Captain Child Support" award Restoring a father to his children
Career interest: collecting money Named defendant in Father's federal lawsuit
No custody/visitation experience documented Defended by FL Attorney General
"It doesn't even matter, you're not even the father."
- November 22, 2024
"Only a band aid."
- November 24, 2025
Neither statement was ever put in writing. Neither can be appealed. Neither had to be explained.
Burja v. Brown | 23-009419-FD-14
Exhibit B
8 / 29

Five Times They Tried to Legally Erase a Father

ATTEMPT DATE WHAT HAPPENED FATHER'S RESPONSE
1 ~2021 Stepfather petitions to adopt children REFUSED
2 ~2022 Stepfather petitions again REFUSED
3 ~2023 Stepfather petitions again REFUSED
4 ~2023 "Fourth time" per stepfather's own texts (Exhibit D) REFUSED
5 May 16, 2024 Same attorney as this case. Day 176 of separation. Filed formally. (Exhibit C-2) REFUSED
MAY 17, 2024 - ONE DAY AFTER PETITION #5:
"Kelly Burja is willing to put this whole litigation to rest, as long as you consent to the adoption of B.M.B. and B.R.B....
we would be willing to waive past child support obligation."
- K. Dean Kantaras, P.A., on firm letterhead (Exhibit D-1) - now permanently in the court record
This is not a custody dispute. This is a 5-year coordinated effort to legally replace one father with another.
Burja v. Brown | 23-009419-FD-14
Exhibit B
9 / 29

18 Months of Letters. Not One Mentioned the Children's Wellbeing.

DATE / EXHIBIT DEMAND SUBTEXT REUNIFICATION?
May 17, 2024
(Exhibit D-1)
"Consent to adoption or we keep the children" Quid pro quo: waive support for adoption consent 0
Jul 23, 2024
(Exhibit E-1)
"7-day ultimatum: pay up" Financial compliance or no response to contact requests 0
Oct 1, 2024
(Exhibit E-1)
"Don't oppose adoption AND pay up or no GAL" GAL conditioned on surrendering adoption opposition 0
Dec 18, 2025
(Exhibit I-1)
"Submit to psych eval + drug test from facility WE approve" 730-day written admission + new fee-conditioned reunification requirements 0
4
Letters
18
Months
$0
Reunification Offers
0
Mentions of Children's
Best Interest
Burja v. Brown | 23-009419-FD-14
Exhibit B
10 / 29

Fee-Conditioned Reunification: Treated Like a Criminal in Family Court

Father asked for ONE thing for 847 days: to see or speak to his children. Instead, he was given a chain of conditions - none court-ordered, none proven necessary, all imposed by opposing counsel.

THE FEE-CONDITIONED CONTACT CHAIN - EVERY STEP BLOCKS CONTACT
🔒
PAY
Financial compliance demanded
No ability-to-pay finding. Court later found NO ability to pay.
🔒
MEDIATION
Mandatory prerequisite
SB 1128 requires consent of BOTH parties. Father's consent not obtained.
🔒
PSYCH EVAL
From facility "approved by us"
Not court-ordered. Attorney demand. Court DENIED psych eval Nov 22, 2024.
🔒
DRUG SCREEN
From facility "approved by us"
No allegation of drug use. No court order. Attorney demand only.
🔒
HEARING
Only after all conditions met
Emergency Motion pending 13+ months. 10 of 11 issues unaddressed.
👥
CONTACT
See your children
847 days. Still locked. None of the "gates" were court-ordered.

WHAT FATHER WAS TREATED AS

X Jail threatened (bodily attachment)
X Income imputed without hearing
X Psych eval demanded (no basis)
X Drug screen demanded (no allegation)
X GAL demanded as bargaining chip
X Adoption consent demanded as price of access
X Treated as criminal. In family court.

WHAT FATHER ACTUALLY ASKED FOR

To see his children
To speak to his children by phone
Time-sharing - the statutory default
That's it. For 847 days. That's all.

Father never asked for a GAL.
Father never asked for a psych eval.
Father never asked for anything FROM Mother.
Every demand came from opposing counsel - not from the court, not from law.
0 allegations proven in 847 days. No finding of unfitness. No finding of danger. No finding of neglect. No finding of abuse. The ONLY focus for 847 days was finances - and the Court's own June 2, 2025 order found no ability to pay.
Burja v. Brown | 23-009419-FD-14
Exhibit B
11 / 29

The Court Said Two Opposite Things. Only One Helped Father.

February 3, 2025
The False Finding Order
"Certificate does not appear from docket."
Income imputed: $61,440/year.
Emergency time-sharing: DENIED.
Fee-conditioned contact chain: IMPOSED.
▼ DROVE ALL ENFORCEMENT FOR 847 DAYS
VS
June 2, 2025
The Exoneration Order
"No credible evidence of willful noncompliance."
"No ability to pay."
Contempt: DENIED.
Sanctions: DENIED. Attorney's fees: DENIED.
▼ CHANGED NOTHING
SAME COURT • SAME CASE • SAME FATHER
Both cannot be right. Neither has been explained in writing.
The February 3 ruling has driven 847 days of enforcement. The June 2 ruling changed nothing.
May 29, 2025 - Court refused to sign Petitioner's own proposed contempt order (Exhibit G-1). Three days later: exoneration. The enforcement posture never changed.
Burja v. Brown | 23-009419-FD-14
Exhibit B
12 / 29

The Record of a Father Who Never Stopped Trying

13
Actions Taken
0
Rewarded
COMPLIANCE & COURT PARTICIPATION
Parenting course completed September 9, 2024 - 36 days early (Exhibit E)
Health and dental insurance obtained for children September 1, 2024 (Exhibit D-4)
Financial support offered - "take my money" - never denied the obligation
Appeared at every hearing he had notice for
UCCJEA Affidavit filed - residential history established (Exhibit C-1)
June 2, 2025 - Court found zero evidence of willful noncompliance (Exhibit G-2)
ADVOCACY FOR HIS CHILDREN
20 documented contact attempts to reach B.M.B. and B.R.B. (Exhibits A-T)
Emergency Motion for Enforcement filed January 31, 2025
Motion to Correct Procedural Record filed - placed certificate on docket (Exhibit E-4)
Proposed Parenting Plan filed - graduated reunification (Exhibit J-3)
Father's Day book - B.M.B.'s own words about his Dad (Exhibit C)
Warned Mother by text about consequences of counsel's approach
Federal civil rights complaint filed to preserve constitutional claims
THE RECORD SPEAKS
This is not the record of an absent father.
This is the record of a father who completed everything asked of him while being told he was "not even the father" and to leave the chambers.
Burja v. Brown | 23-009419-FD-14
Exhibit B
13 / 29

They Asked for Arrest. The Court Said No. Enforcement Continued Anyway.

1
JAN 28, 2025
Mother files contempt motion (6 days before False Order)
2
FEB 3, 2025
False Finding Order
Time-sharing DENIED. Income imputed.
3
MAY 27, 2025
BODILY ATTACHMENT
Arrest authorized. NO notice. NO hearing. NO ability-to-pay finding.
4
MAY 29, 2025
Court REFUSES to sign proposed contempt order
"After review, not signed." (Exhibit G-1)
5
JUN 2, 2025
EXONERATED
NO willful misconduct. NO ability to pay. ALL relief DENIED.
THE CONSEQUENCE
Father could have been arrested and jailed.
Six days after the arrest authorization, the Court found he had no ability to pay and no willful misconduct. The arrest authorization was never publicly withdrawn. The enforcement posture never changed.
Burja v. Brown | 23-009419-FD-14
Exhibit B
14 / 29

Florida SB 1128 vs. This Case

SB 1128 (effective July 1, 2026) was written to prevent exactly what happened here. Passed 11-0. Amends FL 61.13 and 742.031.

30
SB 1128 Limit
vs
847
This Case
169x
LONGER
SB 1128
Temporary parenting plan within 30 days
vs
THIS CASE
No parenting plan in 847 days
SB 1128
Enforcement hearing within 5 business days
vs
THIS CASE
Motion pending 13+ months
SB 1128
Cannot deny time-sharing as financial enforcement
vs
THIS CASE
Fee-conditioned contact chain conditioned contact on money
SB 1128
DV is a specific enumerated factor
vs
THIS CASE
DV admitted - never addressed in writing
SB 1128
Written findings to deviate from 50/50
vs
THIS CASE
Zero written findings. 100% to Mother.
SB 1128
Both parents presumed fit absent findings
vs
THIS CASE
Father treated as non-parent with no findings
Burja v. Brown | 23-009419-FD-14
Exhibit B
15 / 29

What the Law Requires vs. What Exists

Every item below is required by Florida Statute or the U.S. Constitution. None exist in this case.

14
of 14
MANDATORY REQUIREMENTS
MISSING - ALL OF THEM
FL § 61.13(2)(c): Written best-interest findings on all 20 mandatory factors required before any modification of time-sharing - NONE PROVIDED
CONSTITUTIONAL & STATUTORY
X Written order suspending time-sharing (FL 61.13(2)(a)) NONE
X Written best-interest findings - 20 factors (FL 61.13(2)(c)) NONE
X Written paternity adjudication NONE
X Finding of parental unfitness NONE
X Ability-to-pay finding before imputation (FL 61.30(2)(b)) NONE
X Notice/hearing before bodily attachment order NONE
X Temporary parenting plan NONE
PROCEDURAL & PROTECTIVE
X Written findings on Mother's 6 sworn admissions NONE
X Ruling on Emergency Time-Sharing Motion (13+ months) NONE
X GAL appointed to assess children NONE
X Safety assessment (DV in home) NONE
X Reunification therapy ordered NONE
X Written reconciliation of June 2 exoneration NONE
X Phone call, video visit, or letter to children NONE
Burja v. Brown | 23-009419-FD-14
Exhibit B
16 / 29

The Constitutional Triad: One Father, Three Statuses

The same court treats the same man three different ways - simultaneously - with no written explanation.

NOT THE FATHER
(for time-sharing)
X Zero contact 847 days
X "Not even the father"
X "Only a band aid"
X Emergency motion denied
X No paternity adjudication
IS THE FATHER
(for financial enforcement)
$ Income: $61,440/yr
$ Contempt proceedings
$ Bodily attachment order
$ Fee-conditioned contact chain imposed
$ Financial compliance demanded
NO DUE PROCESS
(for either status)
? No written findings
? No ability-to-pay finding
? No hearing on enforcement
? No notice before arrest
? Exonerated - still enforced
PICK ONE.
Florida law does not allow all three simultaneously. The Constitution does not allow all three simultaneously.
Burja v. Brown | 23-009419-FD-14
Exhibit B
17 / 29

Father Filed. Court Ignored. Mother's Attorneys Recycled.

FATHER FILED
JAN 31, 2025
Emergency Motion for Time-Sharing
DEC 16, 2024
Motion to Correct Record
SEP 10, 2025
Notice of Hearing (5 attempts documented)
AUG 9, 2024
Answer / Paternity acknowledgment
PROPOSED
Parenting Plan (Exhibit J-3)
COURT RESULT
PENDING 13+ MONTHS
No hearing. No ruling.
IGNORED
Feb 3 order contradicts docket
CONTRADICTED BY DOCKET
"Unresponsive" - 12 attempts
NEVER FILED
Counsel disobeyed court directive
NO RULING
10 of 11 issues unaddressed
MOTHER'S BINDER
OCT 16 - "WIFE" BINDER
14 tabs. Mother called "Wife" (never married).
NOV 24 - SECOND BINDER
12 of 14 tabs CHANGED.
No notice. No motion.
WHAT CHANGED
+ Father's filings inserted
- Financial docs removed
~ Title changed from "Wife"
ACKNOWLEDGED
Judge acknowledged discrepancy on record (Exhibit H-7). No consequence.
Burja v. Brown | 23-009419-FD-14
Exhibit B
18 / 29

Violations Scorecard

Every violation is supported by documentary evidence in the Master Exhibit Record.

35+
COMBINED VIOLATIONS
across all proceedings
U.S. SUPREME COURT 12
Pierce v. Society of Sisters (1925)
Santosky v. Kramer (1982)
Troxel v. Granville (2000)
Stanley v. Illinois (1972)
Caban v. Mohammed (1979)
Turner v. Rogers (2011)
Bearden v. Georgia (1983)
M.L.B. v. S.L.J. (1996)
Mathews v. Eldridge (1976)
Caperton v. Massey (2009)
Liteky v. United States (1994)
Kennedy v. Mendoza-Martinez (1963)
FLORIDA STATUTES 14+
FL 61.13(2)(a) - written order
FL 61.13(2)(c) - 20 factors
FL 61.13(2)(c)(1) - parent-child
FL 61.13(2)(c)(2) - routine
FL 61.13(2)(c)(13) - DV
FL 61.30(2)(b) - imputation
FL 63.062 - adoption consent
FL 63.087 - stepparent adoption
FL 39.201 - mandatory DV report
FL 38.10 - disqualification
FL 57.105 - sanctions
FL 117.05 - false notarization
Rule 1.520 - written findings
Rule 1.540(b) - false finding
BAR RULES + CANON 3E 9+
4-3.3(a)(1) - candor
4-3.4(a) - obstructing evidence
4-3.4(b) - falsifying evidence
4-3.4(c) - disobeying tribunal
4-4.1 - truthfulness
4-4.4 - third persons
4-8.4(c) - dishonesty
4-8.4(d) - prejudice to justice
4-1.7 - conflict of interest

+ Canon 3E
Judicial Code of Conduct

SIX CRITICAL EVIDENTIARY FINDINGS - QUICK REFERENCE

Every Claim. Every Proof. Verifiable in 60 Seconds.

# CF-# The Proof Verifiable In
1 CF-1 - THE SETUP Retainer signed Nov 22, 2023 → fake meetup Feb 2024 → Mother claims "couldn't reach him" at hearing → destroyed by months of her own texts. (Exhibits C-1, H-4)
2 CF-2 - THE FALSE FINDING "Certificate does not appear from the docket." - Feb 3, 2025 Order. Certificate was on docket 49 days earlier. (Exhibits E, F-1, E-4)
3 CF-3 - THE SELF-CONTRADICTION Feb 3: income imputed, time-sharing denied. June 2: no ability to pay, fully exonerated - enforcement continued regardless. (Exhibits G-2, G-1)
4 CF-4 - EXHIBIT MODIFICATION 12 of 14 tabs changed between consecutive hearings without disclosure. Judge acknowledged different binders on the record. (Exhibits H-4, H-6)
5 CF-5 - MOTHER’S SWORN ADMISSIONS Six admissions under oath: withholding children, negative statements, DV by stepfather, five adoption attempts, false "never received" support claim. Zero written findings on any. (Exhibits E-3, H-7)
6 CF-6 - THE 730-DAY WRITTEN ADMISSION Opposing counsel's own signed letter admits "lack of meaningful communication in the past 730 days" - no court order, no best-interest findings, no fitness adjudication. (Exhibit I-1)

14 OF 14 MANDATORY REQUIREMENTS

Every Requirement. Every One Absent. 847 Days.

# Requirement Status
1 Written order suspending time-sharing NONE - 847 days
2 Written best-interest findings - 20 factors NONE - 847 days
3 Written paternity adjudication NONE - 847 days
4 Finding of parental unfitness NONE - ever
5 Ability-to-pay finding before imputation NONE - contradicted June 2
6 Notice and hearing before arrest order NONE - May 27, 2025
7 Temporary parenting plan NONE - 847 days
8 Written findings on Mother’s 6 sworn admissions NONE - 129 days
9 Ruling on Emergency Time-Sharing Motion NONE - 432 days pending
10 GAL appointed NONE - denied Dec 31, 2024
11 Safety assessment - DV in home NONE - admitted under oath
12 Reunification therapy NONE - called “only a band aid”
13 Written reconciliation of June 2 exoneration NONE - 304 days
14 Any contact - phone, video, letter, visit NONE - 847 days

14 mandatory legal requirements. 14 absent. 847 days. 5 hearing sessions. Zero written parenting findings from any of them. The question is not whether these requirements exist - they are in § 61.13, in the Florida Constitution, and in 12 controlling U.S. Supreme Court decisions. The question is why not one of them has been satisfied.

Burja v. Brown | 23-009419-FD-14
Exhibit B
19 / 29

One Question. Write the Answer Down.

If this Court cannot explain, in writing, the legal basis for denying a father all contact with his children for 847 days - against whom no finding of unfitness has ever been made, who completed every court-ordered task, who was exonerated by this Court's own June 2, 2025 order, and who only ever asked for one thing: to see his children - then the denial has no legal basis.

And contact must be restored.
B.M.B.
11 years old. 30% of his life.
B.R.B.
7 years old. 40% of his life.
No phone calls. No video calls. No in-person visits.
No letters. No gifts delivered. No reunification therapy.
No GAL appointed. No graduated contact plan.
No written explanation from any court, at any time, for any reason.
THE QUESTION NO ONE HAS ANSWERED
If this Court has a reason for keeping these children from their father for 847 days -
write it down.

If it does not - let them see their dad.
Every day is irreversible.
Florida § 61.13(2)(c) requires written findings on 20 mandatory best-interest factors before any deviation from equal time-sharing. Zero have been addressed in 847 days.
Burja v. Brown | 23-009419-FD-14
Exhibit B
20 / 29

847 Days Came Down to 69 Minutes

847
Days of Zero Contact
69
Minutes Notice Given
(Father's 12:21 PM Email)
0
Issues Addressed in Written Order
Issue Raised in Email Hearing History Written Order Status
Written paternity adjudication Discussed orally - never written NONE
"Not the father" vs. confirmed as father Both stated on record NONE
Zero § 61.13 best-interest findings 800+ days - no written finding NONE
Civil-to-coercive enforcement Arrest order - no ability-to-pay finding NONE
Mother's 6 sworn admissions On record - Nov 24, 2025 NONE
Exhibit binder switch Court acknowledged on record NONE
Exhibit D-1 adoption letter - extra-judicial Not grounded in written order NONE
June 2 exoneration vs. enforcement Order denied contempt - posture unchanged NONE
Dec 18 letter reinstates denied relief Conditions denied Dec 31, 2024 NONE
Which exhibit set was admitted Court acknowledged binders differ NONE
48-hour notice - order 37 days late Judge's own 14-day rule violated GRANTED
GAL motion - withdrawn - no clarification Prior denial never lifted in writing NONE

Additional Issues Documented

# Issue Detail Category Status
7 "Wife" Designation Notarized filings identify Petitioner as "wife" - parties were never married - no written order or on-record clarification "Wife" Designation NONE
12 Transcript Request Certified transcripts requested for Aug 2024, Nov 22 2024, Oct 16 2025, and Nov 24 2025 hearings - Father offered to pay Transcript Request PENDING

The Score

Category Count
Issues with zero written order - ever 10 of 12
Issues where Court took action 1 of 12 - continuance granted
Issues still fully unresolved entering April 2 10 of 12
Minutes Father had to document all of them 69

10 of 12 issues Father raised in 69 minutes
have never been addressed in any written order
in 847 days of proceedings.

The one issue the Court did address -
it agreed Father was right.
That is what ‘GRANTED’ means.

This email exists in the Judicial Automated Workflow System. It was read by the Court the same day. It was treated as a formal motion. It was granted. It is now part of the official record of this case - and it documents, in Father’s own words sent before the hearing, every constitutional and procedural failure this presentation has shown slide by slide.


THE CONFIRMATION PATTERN

If Father Was Wrong If Father Was Right
Court denies continuance Court grants continuance
Court notes claims unsupported Court confirms facts in signed order
Record shows Father as obstructive Record shows Father as accurate
April 2 proceeds without acknowledgment April 2 proceeds with Father’s email in the record
The Court granted the continuance. Father was right. The orders say so.

This is the same pattern that runs through this case. Father documents something. The record confirms it. Nothing changes. The February 3 order said the certificate wasn’t there - the docket confirmed it was. The June 2 order found no ability to pay - the enforcement posture confirmed it continued anyway. Father’s email said 48 hours was insufficient - the Court confirmed it and granted the continuance. In every instance: Father was right. In every instance: nothing changed.

Pre-hearing email - Shane Brown, Respondent Pro Se - January 16, 2026 ~12:21 PM
Judicial Automated Workflow System (JAWS) - Case No. 23-009419-FD-14
Jan 16, 2026 Order - “Order Granting Motion for Continuance” - Electronically Conformed, Frederick Pollack
FL § 61.13(2)(a), (c) | Mathews v. Eldridge, 424 U.S. 319 (1976) | Troxel v. Granville, 530 U.S. 57 (2000)
Burja v. Brown | 23-009419-FD-14
Exhibit B
21 / 29

What Father Walks Into - April 2, 2026

RESPONDENT - SHANE BROWN
X Pro Se - No Attorney
X No Certified Transcripts
X No Written Paternity Order
X AI Tools Prohibited by Order
X Cross-Examination Pending - Will be on the stand
X 847 Days Without Seeing His Children
X Zero Written Best-Interest Findings
X Order Entered 48 Hours Before Last Hearing
X Financial Affidavit Required
X No Court Reporter (His Expense)
PETITIONER - KELLY BURJA
Full Legal Representation - K. Dean Kantaras P.A.
Court Reporter Present - Paid by Petitioner
Present at January 16 Hearing
Exhibit Binder Prepared by Counsel
Objected to Father's Continuance Request
All Prior Motions Filed Through Counsel
Dec 18, 2025 Letter Sent by Counsel
Oct 1, 2024 Letter Sent by Counsel
5 Adoption Attempts Through Counsel
No Cross-Examination Pending

THE CLOCK - EVERYTHING THAT MUST FIT IN 1 HOUR

⏱ 1 HOUR TOTAL
(per Jan 16, 2026 Order - no extensions)
COMPLETE THE EVIDENTIARY HEARING
- Opposing counsel finishes cross-examination of Father
- Father's redirect examination (if time permits)
- Closing arguments - both sides
PRE-TRIAL CONFERENCE
- Proposed parenting plan - both parties
- Time-sharing schedule - both parties
- Child support calculation - both parties
- Financial affidavits - both parties
- Witness lists - both parties
- Exhibit lists - both parties
- Trial date setting
ALL OF THIS - 1 HOUR - NO EXTENSIONS

THE SANCTIONS THREAT

The January 16 Order lists sanctions for non-compliance with Pre-Trial Memorandum requirements:
Possible Sanction Who It Affects Impact
Striking of pleadings Father - pro se, no attorney to catch procedural gaps Case dismissed without hearing
Automatic imputation of income Father - already imputed at $61,440/yr without findings Financial obligation set without evidence
Barring of evidence on particular matters Father - pro se, 50 exhibits, no counsel to preserve objections Core evidentiary record excluded
Negative inference Father - against any finding he cannot support in 1 hour Court assumes worst
Imposition of fines Father - no income finding, no ability-to-pay finding Financial punishment without means assessment
Any other sanctions deemed appropriate Open-ended - no written standard Unlimited discretion
Father is the only pro se party. Every sanction listed falls asymmetrically on the party without legal representation - the same party who has been separated from his children for 847 days without a single written finding.

WHAT HAS NEVER BEEN RESOLVED - ENTERING APRIL 2

Unresolved Issue Days Pending
Written paternity adjudication 847 days
Written best-interest findings - any of 20 factors 847 days
Written order suspending time-sharing 847 days
Father's Emergency Motion for Time-Sharing (filed Jan 31, 2025) 432 days
Reconciliation of June 2, 2025 exoneration with enforcement posture 304 days
Written findings on Mother's 6 sworn admissions 129 days
Written order on exhibit discrepancy - 12 of 14 tabs changed 129 days
Written order on "Wife" designation in notarized filings 304 days
Any written response to extra-judicial enforcement letters 529 days
Bodily attachment order - publicly withdrawn? 310 days
Any phone call, video call, or letter between Father and children 847 days

WHAT APRIL 2 IS - AND WHAT IT IS NOT

What April 2 Is NOT What April 2 IS
Not a fresh start The 5th hour of a hearing that began October 16, 2025
Not an equal footing Father under cross before he can speak
Not unlimited time 1 hour - confirmed, no extensions
Not a full trial A continuation of two motions + a Pre-Trial Conference
Not a clean record 847 days of unwritten findings, unreconciled contradictions
Not optional Non-appearance = pleadings struck, default possible

APRIL 2, 2026 - 1:30 PM
847 days.
1 hour.
Already under cross.
No transcripts.
No written findings.
No contact with his children.
315 Court Street, Clearwater, Florida
B.M.B.
Age 11
B.R.B.
Age 7
They have not seen their father in 847 days.
No written order has ever explained why.
April 2 is the first hearing where it must.
Jan 14, 2026 Order - Electronically Conformed, Frederick Pollack
Jan 16, 2026 Order - Electronically Conformed, Frederick Pollack
Full case record - Exhibits C through J-4 (48 evidence exhibits)
FL § 61.13(2)(a), (c) | FL Rule 12.200 | FL Rule 1.520
Turner v. Rogers, 564 U.S. 431 (2011) | Troxel v. Granville, 530 U.S. 57 (2000)
Mathews v. Eldridge, 424 U.S. 319 (1976) | Bearden v. Georgia, 461 U.S. 660 (1983)
Case No. 23-009419-FD-14 | Sixth Judicial Circuit | Pinellas County, Florida | Section 14
Burja v. Brown | 23-009419-FD-14
Exhibit B
22 / 29

This Is Not a Family Law Case.

This Is a Financial Extraction Operation That Used Two Children as Leverage.

A Normal Family Law Case
This Case - 847 Days
Paternity adjudicated in writing
No written paternity order - 847 days
Best-interest findings in every order
Zero best-interest findings - ever
Time-sharing set by written order
Zero written time-sharing order
Financial + parenting addressed equally
Finance enforced fully; parenting zero
Enforcement grounded in written findings
Arrest order with no ability-to-pay finding
Counsel correspondence stays within orders
Oct 1 + Dec 18 letters impose denied conditions
Adoption not linked to support waiver
Exhibit D-1: adoption offered for support waiver
Children's interests primary
Children used as leverage - 5 adoption attempts
12
SCOTUS Cases
Implicated
14+
FL Statutes
Violated
9
Bar Rules
Violated
14/14
Mandatory Req.
Absent
33+
Combined
Violations
0
Best-Interest
Findings - Ever

PART B - COLOR OF LAW

The Legal Framework for What Happened Here

WHAT "COLOR OF LAW" MEANS
"Color of law" means using the authority and appearance of legal process to do something the law does not actually permit. A court order based on a false finding is not law - it is the appearance of law used to produce an unlawful result.
Color of Law Element What Happened in This Case
1. False Finding used as legal authority Feb 3 order says certificate "does not appear" - docket proves it was filed 49 days earlier. The false finding drove every enforcement action for 847 days.
2. Process used to punish, not regulate Kennedy v. Mendoza-Martinez: 7-factor test. Separation + arrest threat + income extraction = punishment.
3. Fundamental right conditioned on payment M.L.B. v. S.L.J.: contact with children cannot be conditioned on ability to pay. Fee-conditioned contact chain imposed nonetheless.
4. Enforcement without required findings Turner v. Rogers: incarceration risk requires ability-to-pay finding. Arrest order entered. Finding came 6 days later: no ability to pay. Order never withdrawn.
5. Judge with disqualifying interest presides Caperton: objective probability of bias. Judge is named federal defendant in Father's §1983 case. Still presiding.
6. Private counsel acts as enforcement arm Letters from K. Dean Kantaras, P.A. impose conditions not grounded in any court order - using firm letterhead to create legal-appearing obligations with no legal basis.
7. Concurrent representation - undisclosed conflict Same firm represents Mother (financial extraction) AND stepfather (parental termination) simultaneously - against same father.

PART C - THE PATTERN ON LETTERHEAD

Defined. Documented. In the Court Record.

Note: The following analysis describes a pattern of conduct for the Court's consideration of the fee-conditioned contact chain, the adoption letters, and the enforcement posture as a unified course of conduct - not as a criminal charge.
Element What the Record Shows
1. The asset being extracted Financial compliance - money, disclosure, adoption consent
2. The leverage used Access to B.M.B. and B.R.B. - Father's children
3. The threat "Consent to adoption or this litigation continues." (Exhibit D-1, May 17, 2024)
4. The condition "Agree not to oppose adoption AND submit financials - or no GAL." (Exhibit E-1, Oct 1, 2024)
5. The escalation "Submit to psych eval + drug screen from facility approved by US." (Exhibit I-1, Dec 18, 2025)
6. The mechanism Court process - contempt, arrest, imputed income - used as enforcement tool
7. The result Father complied with every court order. Was exonerated. Lost his children anyway.
8. On letterhead Exhibit D-1: signed by Florida Bar member. On firm letterhead. In court record permanently.

Exhibit E-1 - K. DEAN KANTARAS, ESQ. - OCTOBER 1, 2024
"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: Prove you deserve your children - through a process we control, with an evaluator we select, at your expense - or you will not see them.
Exhibit I-1 - MATTHEW J. LOESCHER, K. DEAN KANTARAS, P.A. - DECEMBER 18, 2025
"Due the lack of meaningful communication with the minor children in the past 730 days... please agree to the previous requests for a psychological evaluation, and obtaining drug screening and testing from a legitimate drug screening facility approved by us."
Translation: This Court's December 31, 2024 order had already denied the GAL and psychological evaluation. This letter reinstates those denied conditions - privately, without court authority - one year later.
Exhibit D - IGOR RADWANSKI - TEXT MESSAGE - DURING 4TH ADOPTION ATTEMPT
"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"
(emoji removed from original)
Translation: Consent to adoption - the "honorable" thing - and provide your financials.

B.M.B. and B.R.B. were not a family law dispute.
They were leverage.

Every enforcement action traces to money.
Every contact denial traces to non-compliance with financial demands.
Every letter conditions children on financial submission.
Every hearing focused on finances - not the children.

847 days. Two boys. Zero written findings explaining any of it.
The question this Court must answer on April 2, 2026 is not whether Father owes money. He has never disputed that obligation. The question is whether a father's right to his children can be used as the collection mechanism - whether B.M.B. and B.R.B. can be held as financial collateral for 847 days - without a single written finding, a single best-interest analysis, or a single written order that any court, any appellate panel, or any constitutional review could sustain.
If the answer is yes - write it down.
If the answer is no - let them see their dad.
Burja v. Brown | 23-009419-FD-14
Exhibit B
23 / 29

Florida Looked at Cases Like This One and Said: Never Again.

THE LEGISLATURE’S VERDICT

847 Days. 20,328 Hours.
The Legislature Gave Courts 60 Days.
The Judge Said “5th Hour.”
The Law Says “30 Days.”
This Case Is Why SB 1128 Exists.

PART A - THE JUDGE’S OWN WORDS vs. THE LAW

“5th Hour” - Said on Day 787 of a 30-Day Case

JUDGE POLLACK
November 24, 2025
Day 732 of this case
“We’re in the 5th hour of a case that’s been going on for years.”
[Said while cutting off cross-examination with 11 minutes remaining]
Practice Preferences § I-11: Temporary relief hearings typically 1 hour.
Day 732.
“5th hour.”
Zero written findings.
Zero contact.
Zero parenting plan.
SB 1128 / § 61.13
Florida Legislature
Effective July 1, 2026
“Absent good cause, the court must hold a hearing within 30 DAYS after the initial pleading is filed.”
“The court must establish a temporary parenting plan within 30 DAYS after the hearing.”
Total outer limit: 60 DAYS.
Written order required.
Both parents’ consent required for mediation.
Priority on court calendar.
▲ WHAT HAPPENED
▲ WHAT THE LAW NOW REQUIRES

The “5th hour” was said on Day 732. By April 2, 2026 it will be Day 861 - Hour 20,664. Under SB 1128, this entire case should have had a temporary parenting plan by Day 60 - Hour 1,440. The “5th hour” represents 0.025% of the total hours of separation - 5 hours out of 20,328. The other 20,323 hours passed without a single written parenting finding. The judge described the symptom of the violation as its justification.


PART E - THE DEFAULT RULE

§ 742.031(2): The Statute SB 1128 Just Repealed

§ 742.031(2)
CURRENT LAW
(Governed this case for 847 days)
“If the final judgment of paternity does not establish a parenting plan or time-sharing schedule - the MOTHER is presumed to have SOLE PARENTAL RESPONSIBILITY and ALL TIME-SHARING.

= No written order required to deny Father contact. Silence does it automatically.

THIS IS WHY 847 DAYS OF ZERO CONTACT REQUIRED NO WRITTEN FINDING. PRACTICE PREFERENCES CONTAIN NO OVERRIDE.
SB 1128
EFFECTIVE JULY 1, 2026
 
The default rule that vests all parental responsibility and all time-sharing in the mother when a paternity judgment is silent on parenting is REPEALED ENTIRELY.

= Silence can no longer automatically deny a father all contact.

THE LEGISLATURE SAID: THIS WAS WRONG.

For 847 days, Father had zero contact with his children and zero written order explaining why. That was legally sustainable under current law because § 742.031(2) automatically vests all time-sharing in the mother when a paternity judgment is silent on parenting. The court never had to write down a reason. The statute provided the result by default. SB 1128 repeals that default. The Florida Legislature has determined that a father cannot lose all contact with his children by statutory silence alone. A court must now affirmatively address parenting - in writing - within 60 days. This case is 847 days of what SB 1128 was passed to prevent.


PART F - THE TWO TRACKS

The Financial Track and the Parenting Track

FINANCIAL ENFORCEMENT TRACK
FAST. PRIORITIZED. FULLY OPERATIONAL. 847 DAYS OF SERVICE. NO MEDIATION GATE PER § I-6.
Contempt filed → heard promptly
Income imputed → $61,440/yr - no hearing required
Financial Affidavit demanded → deadlines enforced
Mediation fee → $120 required and enforced
Bodily attachment → authorized without notice or hearing
Mandatory Disclosure → repeated deadlines set and enforced
Sanctions threatened → all fall on Father
PARENTING / CONTACT TRACK
BLOCKED. MEDIATION GATE (§ I-6). NO PRIORITY. 847 DAYS. NOTHING.
Temporary parenting plan → never established
Best-interest findings → never written
Contact hearing → never prioritized
Equal timesharing presumption → never applied
Make-up time → never ordered
Fitness determination → never made
Domestic violence admission → never addressed in writing
SB 1128 PARENTING TRACK - WHAT THE LAW NOW REQUIRES
PRIORITY. MANDATORY. TIMED. REPORTED PUBLICLY TO LEGISLATURE.
Day 0: Initial pleading filed + proposed parenting plan
Day 10: Other parent files proposed plan
Day 30: Hearing on disputed portions - MANDATORY
Day 60: Temporary parenting plan ESTABLISHED - MANDATORY
Day 65: Enforcement motion filed → hearing within 5 business days
Day 70: Written order issued within 5 days of hearing
Year 1+: OSCA reports compliance data publicly to Legislature

PART J - OPPOSING COUNSEL'S OWN VIOLATIONS

"The Judge's Rules Were Violated - In His Own Courtroom - By the Party Who Benefited From Delay."

VIOLATION 1
Exhibit Binder Requirements - Section G
The Rule

Joint Hearing Binders required. Meet-and-confer at least 2 business days before hearing. Exhibits organized in 3 sections. 4 copies minimum.

What Happened

12 of 14 tabs changed between October 16 and November 24 sessions - without disclosure, without meet-and-confer, without Section I/II/III organization.

Result

Judge acknowledged discrepancy on record. Zero written findings entered.

VIOLATED
VIOLATION 2
Ex Parte Communication - Section A-2 / Canon 3
The Rule

All communications with judicial office must comply with Canon 3. All parties must be copied on any email to the judicial office.

What Happened

October 2, 2025 email from opposing counsel to Court coordinator claimed Father was "completely unresponsive." Father had 12 documented coordination attempts during same period.

The Question

Was Father copied on the October 2 email? If not - direct violation of Section A-2 and Canon 3.

VIOLATED
VIOLATION 3
Unsolicited Communications - Section A-3
The Rule

Parties may only contact the judicial office in accordance with these procedures.

What Happened

December 18, 2025 letter from K. Dean Kantaras, P.A. reinstated court-denied conditions privately after December 31, 2024 Order. Not a court filing - attorney correspondence imposing conditions outside court authority.

Impact

Conditions the Court had already denied were reimposed via private letter.

VIOLATED
VIOLATION 4
Wrong Email Address for Service
The Rule

Practice Preferences require designated email addresses for e-service.

What Happened

Multiple filings served to sb@vizionprotoc.io - missing the letter 'l' - instead of sb@vizionprotocol.io.

Impact

Every filing served to wrong address raises question about proper service under Fla. R. Jud. Admin. 2.516.

VIOLATED

These are not Father's accusations. These are the Judge's own Practice Preferences - published January 8, 2025 - violated by the party who benefited from 847 days of delay, in the Judge's own courtroom, under his own rules. The exhibit binder requirement exists to prevent exactly what happened. The ex parte rule exists to prevent exactly what was sent. The mediation consent requirement SB 1128 now mandates exists because of exactly how mediation was used here.


PART I - THE CLOSING STATEMENT

What the Legislature Said. What This Court Must Now Decide.

The Florida Legislature looked at cases like this one.

They saw fathers separated from children for years without written findings.

They saw mediation used as a blocking mechanism by the party who benefited from delay.

They saw a default rule that let courts stay silent on parenting while enforcing finances with precision.

They saw the “5th hour” problem - not the 5 hearing hours, but the 20,000 hours before them that produced nothing for the children.

And they passed SB 1128.

They said: parenting hearings within 30 days. Parenting plans within 60 days. Enforcement hearings within 5 business days. Mediation only with both parties’ consent. The default rule that made 847 days of silence legally sustainable - repealed. And starting in 2027 - every court in Florida reports compliance publicly to the Legislature every year.


SB 1128 does not apply to this case retroactively.

But the rights it now codifies with deadlines and consequences - frequent and continuing contact, equal timesharing presumption, written findings, no unilateral mediation gates - were not created by SB 1128. They existed in § 61.13 and in the Constitution before this case was filed.

SB 1128 is the Legislature’s written acknowledgment that those rights were being violated in cases exactly like this one - and that the system needed enforceable, public, timed mandates to protect them.


April 2, 2026 is Day 861.
Hour 20,664.
Under SB 1128 - a temporary parenting plan should have existed since Hour 1,440.
Under the Constitution - it should have existed since Day 1.
The question for this Court is not whether the Legislature was right.
The question is whether this Court will give those rights effect before the Legislature’s deadline - or after.
847 Days. 20,328 Hours.
SB 1128 Allows 1,440 Hours.
The Gap Is 18,888 Hours.
That Gap Has Two Names:
B.M.B. And B.R.B.
Burja v. Brown | 23-009419-FD-14
Exhibit B
24 / 29

Relief Requested

Father Respectfully Requests This Court Enter the Following Orders on April 2, 2026

11 RELIEF ITEMS
1
Written Paternity Adjudication
Oral acknowledgment August 9, 2024 - never reduced to written order. Pending 847 days. FL § 742.031.
2
Written Best-Interest Findings - All 20 Factors
FL § 61.13(3) requires written findings on all 20 statutory factors before ordering unequal time-sharing. Zero of 20 addressed in 847 days - specifically § 61.13(2)(c)(1) facilitation, (3) continuity, (13) DV, (14) alienation, (19) child preference.
3
Temporary Parenting Plan with Time-Sharing Schedule
FL § 61.13(2)(a) - mandatory. None established in 847 days. Father’s proposed plan (Exhibit J-3) is on file.
4
Immediate Interim Contact Pending Final Resolution
B.M.B. is 11. B.R.B. is 7. No court order has ever suspended contact. No finding of unfitness exists. Troxel v. Granville, 530 U.S. 57 (2000).
5
Make-Up Time-Sharing for Days Improperly Denied
847 days of contact denied without written findings. SB 1128 § 61.13 mandates make-up time when timesharing is wrongfully withheld.
6
Vacation of Bodily Attachment Order
Entered May 27, 2025 without notice or hearing. June 2 exoneration found no willful misconduct and no ability to pay. Turner v. Rogers, 564 U.S. 431 (2011) - ability-to-pay hearing required.
7
Hearing and Ruling on Emergency Motion for Time-Sharing
Filed January 31, 2025. Pending 13+ months. No hearing scheduled. No ruling entered. No response.
8
Written Findings on Mother’s November 24, 2025 Admissions
Six sworn admissions on the record, including acknowledgment of domestic violence. 129+ days without written findings. FL § 61.13(2)(c)(13).
9
Order Addressing Exhibit Binder Discrepancy
12 of 14 tabs changed between hearing sessions without notice or motion. Acknowledged on record (Exhibit H-7). No written order followed. FL Bar Rule 4-3.4(a).
10
Correction of “Wife” Designation
Notarized filings identify Petitioner as “wife.” The parties were never married. This is a paternity case under § 742.
11
Certified Transcripts for All Hearing Dates
Requested for 4 hearings. Father offered to pay. Currently pending. Fla. R. App. P. 9.200(b).

Every item on this list corresponds to a documented gap in the record - supported by Exhibits 1 through 40 and the Court’s own orders. None of these requests require new evidence. They require this Court to address what is already in the record but has never been reduced to a written finding.

11 requests. 847 days of documented basis.
Every one is already in the record.
Not one has been addressed in a written order.
Burja v. Brown | 23-009419-FD-14
Exhibit B
25 / 29

"Did It Really Just Take Two Years to Get That on the Record?"

"Excuse me." - November 24, 2025. Day 732. With a Court Reporter Present.

THE EXCHANGE
JUDGE POLLACK
"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."
November 24, 2025 - Day 732 - End of Two-Hour Hearing - Court Reporter: Alessandra Da Pra
Cross-examination began
3:19 PM
Cut off at
3:30 PM
11 minutes remaining
Written order entered
Jan 14, 2026
51 days later
THE BRACKET
EARLY IN CASE - On Record
"It doesn't even matter, you're not even the father."
X Never put in writing
X Used to minimize Father's claims for 732 days
731
DAYS
DAY 732 - On Record - Court Reporter
Judge asks: "Is he the father?" Mother: "Yes."
Father: "Did it really just take two years?"
Judge: "Excuse me."
X Still no written adjudication
X Still zero contact
THE 51-DAY ORDER TIMELINE
NOV 24
Hearing Ends
14 DAYS
(his rule)
DEC 8
Order Due
37 DAYS LATE
JAN 14
Order Entered
51 days
48hrs
JAN 16
Hearing
48hrs notice
EMAIL vs. “UMBRAGE”
What Father's Email Raised
1. Written paternity adjudication
2. "Not the father" vs. confirmed as father
3. Zero § 61.13 best-interest findings
4. Civil-to-coercive enforcement
5. Mother's 6 sworn admissions
6. Exhibit binder switch
7. Exhibit D-1 adoption letter - extra-judicial
8. June 2 exoneration vs. enforcement
9. Dec 18 letter reinstates denied relief
10. Which exhibit set was admitted
11. 48-hour notice - order 37 days late
12. GAL motion - withdrawn - no clarification
What the Jan 16 Order Called It
"Takes umbrage with the timeliness"
12 substantive issues reduced to one word:
UMBRAGE
Then: continuance GRANTED.
Pre-Trial Conference SET.
First in case history. Day 787.
THE PATTERN
# Father Said / Did Was Characterized As Record Confirmed
1 Parenting course completed "Does not appear from docket" Docket proves it
2 No ability to pay Arrest authorized June 2: Father correct
3 Exhibit binders different Acknowledged - no order 12/14 tabs changed
4 "Did it really just take two years?" "Excuse me" Mother confirmed yes - 732 days
5 12-issue email, 48hrs notice "Umbrage" Continuance GRANTED, Pre-Trial set
6 Complied with every order Non-compliance basis for separation June 2 exoneration
THE RECORD SPEAKS
Every time Father accurately described the record, the characterization dismissed it. Every time, the record confirmed he was right. "Not even the father" - confirmed as father on Day 732. "Excuse me" - in response to a question the transcript now answers permanently. "Umbrage" - the email that produced the first Pre-Trial Conference in 787 days. April 2 is the hearing where the record speaks for itself. It has been speaking for 847 days. This presentation is what it says.
Case No. 23-009419-FD-14  |  Sixth Judicial Circuit  |  Pinellas County, Florida
Exhibit B  •  Slide 26 of 29
Supplemental Financial Record - March 20, 2026  |  For Pre-Trial Hearing April 2, 2026

Where the Money Went
$72,231 Billed  -  $0 Produced for the Children  -  $0 Father’s Total Spent on Attorney

$53,781 Confirmed Paid
to Kantaras P.A.
$72,231 Total Projected
Through Trial
$0 Attorney Fees
Father’s Entire Case
Days Enforced as Financial Obligor
848
Support. Contempt. Bodily Attachment. Arrest threat.
Days Recognized in Writing as Their Father
0
No written order. No parental rights. No contact. No findings.
Enforced as a Father. Never Written as One.  •  848 Days  •  Case No. 23-009419-FD-14
Court’s Finding - June 2, 2025 (Exhibit G-2):
“The Petitioner presented no credible competent substantial evidence… as to her having incurred any attorneys’ fees and costs… nor as to her need for assistance with such fees and/or the Respondent’s ability to pay such fees.”
✓ Fee award DENIED. ✓ Contempt DENIED.
Retroactive Child Support:
Father agreed to retroactive child support obligation. Specific amount: Agreed - TBD. No dollar amount contested here. Support payments: current and ongoing. Retroactive total to be determined through proper proceeding.
What Father Has Spent - 848 Days - Complete Record
Attorney fees - entire case (pro se throughout) $0.00
Parenting course completed 36 days early (Exh. E) $25.00
GAL retainer paid $0.00
Psych evaluation paid $0.00
Attorney fees paid to opposing counsel $0.00
Father’s Total Attorney Fees - 848 Days $0.00
Lifetime Maximum Demand Through B.R.B.’s 18th Birthday
$584,770
Source: PTM §C, Mother’s Child Support Worksheet, Exhibits E-1, E-6, G-2, I-1
Who Received the Benefit - 848 Days
Kantaras P.A. - confirmed billed $53,781
DOR / Title IV-D - federal matching (~66% rate) Triggered
B.M.B. & B.R.B. - direct financial benefit $0
Father - 20,352 hours with his sons 0 hours
Pattern of Conduct - On the Record
Motions filed against Father / motions won 100+ / 0
Times Father denied child support - 848 days 0
Adoption consent demanded as condition of contact (5 attempts) Documented
Federal § 1983 filed - Brown v. FL Dep’t of Revenue, No. 8:25-cv-00621 Active
Enforced as Father (support, contempt, arrest)  •  Denied as Father (contact, paternity writing, findings)
Color of Law - 42 U.S.C. § 1983 - Federal Case Active
Case No. 23-009419-FD-14  |  Sixth Judicial Circuit  |  Pinellas County, Florida
Exhibit B  •  Slide 27 of 29
System Divergence Analysis - March 20, 2026  |  848 Days  |  For Pre-Trial April 2, 2026

Two Systems. One Case. Opposite Results.
Every enforcement objective was met. Every child welfare objective was not addressed.

Title IV-D / DOR Financial Enforcement
100%
All Financial Objectives - Served
Income imputed at $61,440/yr - no verified earnings Entered
Child support obligation established without contested hearing Established
2 bodily attachments / contempts issued over 848 days - both ultimately denied (Exh. H, G-2) Issued, Then Denied
Motion for Contempt and Sanctions filed (Jan 2025) Filed & Pursued
Discovery compliance order entered (Exh. H) Entered
Enforcement continued after June 2 exoneration Continued
Federal matching funds triggered (~66% reimbursement rate) Triggered
STATE FINANCIAL OBJECTIVE: ACHIEVED
Federal matching funds received. DOR performance metrics met.
vs.
FL § 61.13(2)(c) - Children’s Best-Interest Standard
0%
Children’s Statutory Rights - Not Addressed
Written § 61.13(2)(c) best-interest findings (0 of 20 factors) 0 Written
Written order suspending or limiting contact Never Written
Written paternity adjudication (oral twice - still unwritten) Still Unwritten
Contact hours produced for B.M.B. and B.R.B. - 848 days (861 at April 2 hearing) Zero Hours
Phone calls or video calls permitted to Father Zero Calls
Reunification efforts documented by court Zero Attempts
Written fitness finding against Father Zero Findings
CHILDREN’S STATUTORY RIGHTS: NOT ADDRESSED
B.M.B. + B.R.B. contact hours: zero. Best-interest findings: zero.
Florida SB 1128 (committee vote 11–0, effective July 1, 2026) was passed to prevent courts from allowing financial enforcement without corresponding time-sharing action. As of March 20, Father has waited 848 days. By April 2 hearing: 861 days. SB 1128’s outer limit for a temporary parenting plan: 30 days. The gap at hearing: 831 days. That gap has two names: B.M.B. and B.R.B.
169x
Longer Than
SB 1128’s 30-Day Limit
Case No. 23-009419-FD-14  |  Sixth Judicial Circuit  |  Pinellas County, Florida
Exhibit B  •  Slide 28 of 29
Complete Record - Every Zero - 848 Days as of March 20, 2026

What Never Happened
Every zero in this record is sourced. Not one was contested. Not one was explained in writing.

Contact - What Never Occurred
0 Contact hours permitted in 848 days as of March 20, 2026
0 Phone calls permitted to Father - entire case
0 Video calls permitted - entire case
0 Overnight visits given to Father under any order
0 Birthday calls answered (3 birthdays - 14+ attempts - 0 responses)
0 Holidays with Father - 6 Christmases, 7 birthdays elapsed
0 Seconds the one documented phone call attempt was answered
0 Responses to 14+ documented contact attempts by Father
Legal Process - What Was Never Done
Conduct & Fitness - What Was Never Found
0 Fitness findings against Father - entire record
0 Domestic violence findings or credible allegations
0 Threatening messages from Father - ever - in any communication
0 Times Father denied paying child support when able
0 Drug or substance abuse findings (test required with no evidentiary basis)
0 Cases won by opposing counsel on merits - 100+ motions filed
0 Proven willful noncompliance (exonerated June 2, 2025 - Exhibit G-2)
0 Direct benefit to B.M.B. or B.R.B. from $53,781 in attorney fees paid
24 Zero Items
In This Slide
“Not one was contested. Not one was explained in writing. Not one produced contact between B.M.B., B.R.B., and their father.”
848 Days -
March 20, 2026
Case No. 23-009419-FD-14  |  Sixth Judicial Circuit  |  Pinellas County, Florida
Exhibit B  •  Slide 29 of 29
Exhibit B - Case Presentation - Final Slide - March 20, 2026

One Father. Two Sons.
861 Days.

848 Days as of March 20, 2026  •  861 Days at April 2 Hearing  •  20,352 Hours of Separation  •  0 Times Father Denied Child Support

B.M.B., age 11  •  B.R.B., age 7  •  April 2, 2026  •  Courtroom 421

The Contact Record  -  Every Attempt  -  Documented & Timestamped  -  Father’s Words to Kelly Burja  -  One Side of the Conversation
Feb 23, 2024  •  11:22 AM

“May I ask if we are still set for today at 4pm? So excited if so!”

Kelly: “Yep we’ll be there” → Papers served. Boys not present.
Mar 4, 2024  •  6:17 AM

“Good morning! May I ask to speak with B.M.B. when he wakes up...”

Response: NONE
Mar 4, 2024  •  2:42 PM

“Can I please say hi to B.M.B. on his birthday!”

Response: NONE
Mar 4, 2024  •  4:48 PM

Phone call placed - 0 seconds - not answered.

Response: NOT ANSWERED
Mar 4, 2024  •  6:23 PM

“Plz let me say hi to B.M.B.!”

Response: NONE
Mar 4, 2024  •  Bedtime

“May I please say hi before bed plz”

Response: NONE
Dec 4, 2024  •  6:27 AM

“DADDY LOVES AND MISSES YOU SO MUCH!! Daddy adores, misses and loves you and your brother more than the world itself.”

Response: NONE
Dec 4, 2024  •  2:59 PM

“May I please say hi and wish B.R.B. a Happy Birthday please!!”

Response: NONE
Mar 4, 2025  •  Morning

“HAPPY BIRTHDAY B.M.B.!! I’m free for a call and available ANYTIME!!!”

Response: NONE
May 1, 2025  •  7:53 PM

“I just want to say hi, speak and co-parent… Their Dad will never give up on them, no matter what.”

Response: NONE
May 11, 2025  •  11:45 AM

“Happy Mothers Day Kelly. Please tell the boys how much I love and miss them. Hope you have a wonderful day.”

Response: NONE
Dec 4, 2025  •  6:27 AM

“HAPPY BIRTHDAY B.R.B.!! Daddy loves and misses you and your brother so much. You mean everything to me.”

Response: NONE
Dec 4, 2025  •  Afternoon

“May I please say hi and wish B.R.B. a Happy Birthday please!!”

Response: NONE
Mar 4, 2026  •  Morning  •  Day 848

“HAPPY BIRTHDAY B.M.B.!! Daddy loves you more than anything in this world. I will never stop trying.”

Response: NONE
Feb 2024 → Mar 2026  •  Summary
17+ messages sent
0 seconds answered
0 responses received
Every message was polite. Every message asked permission.
“May I please say hi before bed plz”  -  Father to Kelly, March 4, 2024, bedtime  -  Response: none. 17+ Attempts  •  0 Responses  •  0 Threatening Words  •  848 Days
What It Cost to Keep Him From Them
Billed to Kantaras P.A. $53,781
Total projected through trial $72,231
Motions filed against Father 100+
Contempts proven 0
Fee awards obtained 0
Contact hours produced for children 0
$72,231 billed - 0 motions won
0 contempts proven - 0 contact hours
Case unresolved - still billing
What It Cost Him to Keep Trying
Attorney fees - entire case $0.00
Parenting course (completed 36 days early) $25.00
Times denied paying child support 0
Hours without his children - 848 days 20,352
Court requirements complied with 100%
Days without a single written order naming him Father - as of March 20, 2026 848
$25 total - 0 denials - 100% compliance
Still asking for his sons
One pro se father. Fighting alone. For two boys.
What He Is Asking For - April 2
To speak to
B.M.B. (age 11)
and
B.R.B. (age 7)
No attorneys needed.
No conditions.
No dollar amount.
$0 cost to anyone.
April 2, 2026
The Day the Clock Can Stop
Exhibit B - 29 Slides - Burja v. Brown - Case No. 23-009419-FD-14
Every number in this presentation is sourced from court orders, attorney correspondence, or the opposing party’s own filings.
“If this Court cannot explain in writing the legal basis for denying a father all contact with his children for 861 days - against whom no finding of unfitness was ever made - then the denial has no legal basis.”