Respondent Shane Christopher Brown, pro se, files this Master Exhibit Record in support of Respondent's Pre-Trial Memorandum. This document serves as the unified evidence bank for the case, organizing all documentary evidence into a single indexed filing. All motions and memoranda cite to this Notice by exhibit reference number.
Filed pursuant to Florida Rule of Civil Procedure 1.080 and Florida Family Law Rule of Procedure 12.080. All exhibits are offered to establish the factual foundation for pending motions and to preserve a clean, organized record for the state court's review.
Total Exhibits: 50 (2 Primary Exhibits A-B + 48 Evidence Exhibits C through J-4)
Case Presentation: Exhibit B - 25-slide visual case presentation (PDF file), filed as a companion exhibit to this Notice.
Before any exhibit number, any legal citation, or any procedural argument, this filing exists because of two children:
| B.M.B. | B.R.B. | |
|---|---|---|
| Date of Birth | March 4, 2015 (Santa Monica, CA) | December 4, 2018 (Tampa, FL) |
| Current Age | 11 years old | 7 years old |
| Age at Separation | 8 years old | 4 years old |
| Days Without Father | 847 (as of this filing) | 847 (as of this filing) |
| Percentage of Life | ~21.0% of his entire life | ~31.8% of his entire life |
| Birthdays Missed | 9th, 10th, 11th (March 4, 2026 - 13 days ago) | 5th, 6th, 7th |
| Christmases Missed | 2023, 2024, 2025 | 2023, 2024, 2025 |
| Father's Days Missed | 2024, 2025 | 2024, 2025 |
Total separation: 847 days = 20,328 hours = 2 years, 3 months, 24 days
Zero written court orders suspending contact.
Zero written best-interest findings under § 61.13(2)(c).
Zero written findings of parental unfitness.
Zero written paternity adjudication (despite oral acknowledgment August 9, 2024).
Zero phone calls, video calls, visits, letters, or birthday cards permitted.
| Exhibit | Document | Date | Significance | Referenced In |
|---|---|---|---|---|
| C | Father's Day Book - Children's Own Words - authored by B.M.B., expressing the children's relationship with Father | Various | Direct evidence of parent-child bond from the child's own perspective. | F2, F5, F8 |
| C-1 | UCCJEA Affidavit - Sworn Under Perjury Warning - children's DOBs, residence history; identifies Shane as biological father; BOTH Igor AND Kelly signed under explicit perjury warning (§ 92.525) | 5/16/2024 | Establishes Father's residential history and active parental presence Dec 2018–Mar 2019. Any false statement constitutes perjury. | F2, F5, F8 |
| C-2 | 5th Joint Petition for Adoption by Stepparent - filed by Igor Radwanski and Kelly Burja; prepared by K. Dean Kantaras, P.A.; claims father "has not participated meaningfully"; case number and division LEFT BLANK; swears Shane's consent "is attached hereto as Exhibit E" - provably false (Shane never signed any consent) | 5/16/2024 | CF-4. 5th adoption attempt while Father actively litigating. False representation of Father's participation. False claim of attached consent. Same counsel represents Mother in paternity AND stepfather in adoption. | F2, F5, F6, F8 |
| C-3 | Paternity Acknowledgment Motion | Various | Companion to Exhibit C-2. Documents paternity acknowledgment proceedings. | F2, F5 |
| C-4 | Judge Pollack Biography - "Captain Child Support" / DOR Career - Inn of Court biography: exclusive career in Title IV-D child support enforcement; "thousands of cases on behalf of the interests" of DOR; no custody, visitation, or parent-child relationship experience documented | Various/2018 | Career-long structural focus on financial enforcement. Structural appearance of partiality per Caperton when balancing enforcement vs. parental liberty. | F7, F8 |
| C-5 | Google Search Screenshot - "Captain Child Support" article confirmation from independent online source (inns.innsofcourt.org) | Various | Third-party corroboration of the "Captain Child Support" designation. | F7, F8 |
| Exhibit | Document | Date | Day # | Significance | Referenced In |
|---|---|---|---|---|---|
| D | Stepfather Text Messages - "4th time" adoption reference + threatening tone - Igor Radwanski's own texts. Quote: "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." | Various | Various | CF-1 (supporting). Stepfather's own words confirm at least 4 prior adoption attempts, all refused by Father. | F2, F5, F6 |
| D-1 | Adoption-for-Support Quid Pro Quo Letter - sent ONE DAY after 5th adoption petition (Exhibit C-2). Contains: "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.." Also: "Upon your consent... we would be willing to waive past child support obligation." | 5/17/2024 | 176 | CF-4. Attorney-authored coercion of parental rights. Offering to waive financial obligations in exchange for constitutional parental termination. Violates § 63.062 (consent cannot be coerced or purchased), FL Bar Rule 4-4.4. | F2, F5, F6, F8 |
| D-2 | Good Faith Letter (Companion Exhibit to Mother's Motion to Compel) - 7-day compliance demand; uses CORRECT email (sb@vizionprotocol.io) | 7/23/2024 | 243 | Part of discovery chain. Notable: correct email here, wrong email on later filings. | F6 |
| D-3 | Mother's Motion to Compel (Filing #203762488) - anchors timeline: Dec 13, 2023 demand → Apr 9, 2024 deadline → Jul 23, 2024 good faith letter → Jul 31, 2024 motion filed | 7/31/2024 | 251 | Original motion that initiated the discovery/contempt chain. | F6 |
| D-4 | Father's Answer to Petition - filed at August 9, 2024 hearing; Court directed opposing counsel to file it; they did not file it | 8/9/2024 | 260 | Father's formal entry into the case. Opposing counsel's failure to file court-directed document is itself a record integrity issue. | F2, F3, F4, F5, F6, F8 |
| Exhibit | Document | Date | Day # | Significance | Referenced In |
|---|---|---|---|---|---|
| E | Certificate of Parenting Course Completion - Certificate ID: sb1jxxg3nb; completed 36 days BEFORE the October 15, 2024 court deadline | 9/9/2024 | 291 | CF-1. Course completed early. Certificate's existence directly contradicts the Feb 3, 2025 false finding. | F3, F5, F8 |
| E-1 | Kantaras Letters (Jul 23 + Oct 1, 2024) - July 23: 7-day ultimatum for financial compliance (signed by Anita Abraham). October 1: signed by K. Dean Kantaras personally (initialed KDK/kk by Kristopher Kaylor); explicitly acknowledges Father's refusal to consent to adoption; states: "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." Uses wrong email. | 7/23/2024 + 10/1/2024 | 243 + 313 | CF-1 (supporting). 14-month coercive correspondence pattern. Zero mention of reunification in any letter. Adoption ultimatum conditioned on surrendering parental rights. | F2, F5, F6, F8 |
| E-2 | Federal ECF 1-1 - Kantaras Oct 1, 2024 Letter (ECF Pages 33–34) - Fee-gating + adoption pressure letter as it appears in the federal filing record | 10/1/2024 | 313 | Federal court's own copy of the adoption-GAL quid pro quo letter. Cross-references Exhibit E-1 (verified original). | F2, F6, F8 |
| E-3 | Hearing Transcript - Judicial Statements - Nov 22, 2024: "It doesn't even matter, you're not even the father." Nov 24, 2025: reunification characterized as "only a band aid." Father directed to leave chambers. Neither statement reduced to writing. | 11/22/2024 + 11/24/2025 | 365 + 732 | Constitutional Triad - Father denied parental status while held to parental obligations. "Band aid" statement reflects prejudgment of reunification value. | F2, F4, F5, F7, F8 |
| E-4 | Motion to Correct Procedural Record - parenting certificate attached as exhibit; documents "not even the father" statement; documents Shane directed to leave chambers; placed certificate ON DOCKET December 16, 2024 | 12/16/2024 | 389 | CF-2. Certificate was on docket 49 days before Exhibit F-1 falsely stated otherwise. Mother's own exhibit list (Exhibit H-6, Tab 8) confirms this filing existed. | F2, F3, F4, F8 |
| E-5 | Fuchslocher Paralegal Email - "I apologize for our overdue Order... Kris Kaylor is no longer with the firm." Confirms proposed-order drafting practice by opposing counsel. | 12/27/2024 | 400 | Confirms attorney turnover. Confirms firm drafted proposed orders for judicial signature. | F4, F6 |
| E-6 | Conformed Order - GAL and Psych Eval DENIED | 12/31/2024 | 404 | Court denied the same conditions Petitioner's counsel reinstated via Exhibit I-1 letter one year later without new evidence or court authority. | F2, F6 |
| Exhibit | Document | Date | Day # | Significance | Referenced In |
|---|---|---|---|---|---|
| F | Mother's Motion for Contempt and Sanctions (Filing #215532998) - claims "willful" non-compliance; Certificate of Service uses WRONG email (sb@vizionprotoc.io - missing 'l'); filed 6 days before the False Finding Order | 1/28/2025 | 432 | June 2, 2025 Order later found NO credible evidence of willful noncompliance. Service may be defective. | F3, F6 |
| F-1 | February 3, 2025 Order (THE FALSE FINDING) - states parenting certificate "does not appear from the docket"; imputes income at $61,440/yr without § 61.30(2)(b) findings; denies Father's Emergency Motion for Time-Sharing; imposes fee-conditioned contact chain | 2/3/2025 | 438 | CF-1. Binary factual error - certificate filed 49 days earlier (Exhibit E-4). Income imputation without required findings. Triggered entire downstream enforcement chain. | F2, F3, F7, F8 |
| F-2 | Federal § 1983 Complaint - Brown v. FL Dep't of Revenue, No. 8:25-cv-00621 (M.D. Fla.) - Judge Pollack named defendant; due process + equal protection + parental rights claims; defended by FL Attorney General | 3/14/2025 | 477 | Judge simultaneously adjudicating this state case while defending himself in federal § 1983 litigation by the same party. Canon 3E. | F7, F8 |
| F-3 | Federal Exhibit List Phase 1 (ECF 1-1, 259 pages) - Full Phase 1 federal exhibit index | 3/14/2025 | 477 | Federal exhibit structure documentation. | F8 |
| F-4 | Federal ECF 1-1 - Phase 1 Exhibit Screenshots (P1-A through P1-G) - iPhone screenshots of federal complaint Phase 1 exhibit index pages from PACER Document 1-1 (259 pages) | 3/14/2025 | 477 | Visual documentation of Phase 1 federal exhibit structure. Cross-references Exhibit F-3 (full ECF 1-1 PDF). | F8 |
| F-5 | Federal ECF 1-1 - Complaint Narrative Pages (Pages 36–50+) - Sequential screenshots of the federal complaint narrative from ECF Document 1-1 | 3/14/2025 | 477 | Full complaint narrative as filed. 12 sequential page screenshots documenting Father's federal due process, equal protection, and parental rights claims. | F7, F8 |
| G | KDK Good Faith Letter (Apr 2, 2025) | 4/2/2025 | 496 | Good faith correspondence from opposing counsel. | F6 |
| G-1 | Proposed Contempt Order - REFUSED BY JUDGE - Court response: "After review, not signed. Court will be entering its own order." Submitted by Matthew J. Loscher (Kantaras firm) | 5/29/2025 | 553 | CF-3 (supporting). Even the Court found Petitioner's proposed contempt order could not be signed. | F2, F3 |
| G-2 | Order Granting-In-Part Motion for Enforcement - "no credible competent substantial evidence" of willful noncompliance; no ability to pay; contempt DENIED; sanctions DENIED; fees DENIED | 6/2/2025 | 557 | CF-2. Court's own finding vindicates Father. Enforcement continues without new findings. Irreconcilable with Feb 3 income imputation. | F2, F3, F5, F7, F8 |
| G-3 | "Wife's" Motion to Appoint Guardian Ad Litem (Filing #224658090) - falsely designates Petitioner as "Wife" (never married); proposes Mr. Melendez ($275/hr) as counsel's chosen GAL; REFILED 194 days after Court denied GAL; Certificate of Service uses WRONG email (sb@vizionprotoc.io - missing 'l') | 6/4/2025 | 559 | False designation in sworn, notarized filing. Refiling previously denied relief without new evidence. Possible defective service under Fla. R. Jud. Admin. 2.516. | F2, F4, F6, F8 |
| G-4 | Notice of Federal Litigation Filed in State Court - cross-notice; sworn declaration of pending federal action | 6/10/2025 | 567 | Establishes that this Court has been formally notified of the pending federal action against Judge Pollack. | F7, F8 |
| Exhibit | Document | Date | Day # | Significance | Referenced In |
|---|---|---|---|---|---|
| H | Federal ECF Doc 46 - confirms Judge Pollack as defendant in federal case | 2025 | - | Federal docket confirmation. | F7 |
| H-1 | Notice of Hearing - 5 Coordination Attempts documented in footnote (Aug 26, 27, 28, Sep 2, Sep 5, 2025); contains incarceration/jail threat language | 9/10/2025 | 657 | DIRECTLY CONTRADICTS Exhibit H-3. Father was NOT "completely unresponsive" - he made 5 documented outreach attempts in the same period. | F4, F6, F8 |
| H-2 | Federal Stay Order - case stayed but NOT dismissed; all claims preserved; judge remains active defendant | 9/19/2025 | 666 | Federal claims remain live. Stay may be lifted based on continued state court violations. | F7, F8 |
| H-3 | Harrer Email - "Completely Unresponsive" - Danielle Harrer (Kantaras firm) emails judicial coordinator claiming Respondent was "completely unresponsive" | 10/2/2025 | 679 | CF-4 (supporting). DIRECTLY CONTRADICTED by 5 documented coordination attempts in Exhibit H-1. FL Bar Rule 4-3.3(a)(1) (candor to tribunal). | F4, F6, F8 |
| H-4 | "Wife's" Exhibit List - 14 Tabs - presented at October 16, 2025 hearing (Hearing #1); title uses false "Wife" designation (parties never married); includes retainer agreement (Tab 13) and invoices (Tab 14) | 10/16/2025 | 693 | CF-3 (baseline exhibit). Original binder. Financial docs in Tabs 13-14 were removed from the Exhibit H-6 binder. | F2, F4, F6, F8 |
| H-5 | Burja Notice of Hearing (GAL) - documents 7 coordination attempts by Father with opposing counsel | 10/24/2025 | 701 | Further evidence Father was responsive and cooperative. | F4, F6, F8 |
| H-6 | "Mother's" Exhibit List - 14 Tabs (12 of 14 DIFFERENT from Exhibit H-4) - presented at November 24, 2025 hearing (Hearing #2); title changed from "Wife's" to "Mother's"; Tab 8 changed to include Father's own Motion to Correct (Exhibit E-4) without notice | 11/24/2025 | 732 | CF-3. 12 tabs materially changed without disclosure or meet-and-confer. Judge acknowledged different binders on the record. | F2, F3, F4, F5, F6, F8 |
| H-7 | Hearing Transcript - Court's on-record acknowledgment of different binders between Oct 16 and Nov 24 hearings | 11/24/2025 | 732 | Judge was AWARE of binder discrepancy and took NO corrective action. | F4 |
| Exhibit | Document | Date | Day # | Significance | Referenced In |
|---|---|---|---|---|---|
| I | Father's Dec 17, 2025 Good Faith Email - Christmas Contact Request - 4 specific requests (phone/video, Christmas overnights, 50/50 schedule, coordination call), zero conditions; documents all three prior conditions removed (GAL denied, psych eval denied, drug testing withdrawn); voluntary drug test offer; full financial cooperation offer; Dec 19 response deadline set | 12/17/2025 | 755 | Establishes Father's documented good faith the day before KDK's 730-day letter (Exhibit I-1). Contrast between Father's cooperative posture and opposing counsel's conditional demands is dispositive. | F2, F5, F8 |
| I-1 | Kantaras Letter - 730-Day Written Admission - signed by K. Dean Kantaras personally; admits "lack of meaningful communication in the past 730 days"; conditions access on psych eval + drug screen "approved by us"; cc: Kelly Burja. No mention of reunification. | 12/18/2025 | 756 | CF-5. Binding party admission. Opposing counsel's own written acknowledgment of 730+ day deprivation (actual count: 756 days). Conditions fundamental rights on finances. | F2, F3, F5, F6, F8 |
| I-2 | Kantaras Dec 18, 2025 Response - 730-Day Written Acknowledgment + 3 Unauthorized Conditions - KDK's response to Father's Dec 17 good faith email (Exhibit I). Admits "lack of meaningful communication in the past 730 days." Reinstates psych eval + drug screen + GAL-style conditions - all previously court-denied (Exhibit E-6). Screenshots of full letter. | 12/18/2025 | 756 | Companion to Exhibit I-1 (the letter PDF). Exhibit I-2 provides the screenshot evidence of the full letter in context. Proves voluntary cessation was tactical - every demand abandoned in Oct 2025 reinstated 76 days later. | F2, F3, F5, F6, F8 |
| I-3 | Order Setting Continued In-Person Evidentiary Hearing - references 2+ year case duration; sets Jan 16, 2026 hearing | 1/14/2026 | 783 | Court's own acknowledgment of case duration. | F2, F4 |
| I-4 | Shane's Email to Court - 11 Substantive Issues - received by Court Jan 16, 2026 at 12:21 PM; only 1 of 11 issues addressed (continuance); 10 remain unaddressed and preserved for appeal | ~1/10/2026 | ~779 | 10 of 11 issues preserved for appellate review. Court initially stated Shane "did not appear" - then "discovered" the email. | F2, F8 |
| I-5 | Order Granting Motion for Continuance + Setting Pre-Trial Conference - March 19, 2026 deadline; April 2, 2026 hearing at 1:30 PM; only 1 of 11 issues addressed; sanctions warning; AI note-takers prohibited | 1/16/2026 | 785 | Governs all deadlines. 10 of 11 issues remain unaddressed. | All Filings |
| Exhibit | Document | Date | Significance | Referenced In |
|---|---|---|---|---|
| J-1 | Motion for Clarification (condensed) | Various | Condensed motion for clarification of record. | F4 |
| J-2 | Father's Official Exhibit List | Various | Father's formal exhibit list filed with the Court. | F2, F4 |
| J-3 | Father's Proposed Parenting Plan - graduated contact restoration plan filed by Father | 2025 | Father's affirmative proposal for reunification. Demonstrates good faith and willingness to work within the system. | F2, F5 |
| J-4 | Federal ECF 1-1 - Phase 2 Exhibit Screenshots (F2-A through F2-F) - Phase 2 exhibit index pages from federal complaint | 3/14/2025 | Visual documentation of Phase 2 federal exhibit structure. | F8 |
| J-5 | Certificate of Service Template | Various | Template for service documentation. | - |
| Exhibit | Document | Date | Significance | Referenced In |
|---|---|---|---|---|
| Exhibits A–T | 20 Text Message Exhibits - complete documented contact record between Father and Mother/Stepfather. Documents: Father's repeated contact attempts; offers of financial support ("take my money"); co-parenting proposals; stepfather's threatening communications; evidence of domestic violence by stepfather | 2022–2024 | 20 documented contact attempts. Directly contradicts narrative of abandonment. Contains evidence of DV by stepfather. | F2, F5, F8 |
| Exhibit | Document | Significance | Referenced In |
|---|---|---|---|
| Exhibit B | 25-Slide Visual Case Presentation - EXHIBIT-B-CASE-PRESENTATION.html (265 KB, self-contained). Covers: 847-day timeline, 6 critical evidentiary findings, Constitutional Triad, SB 1128 comparison, 11-item relief request, full exhibit cross-references. Labeled "EXHIBIT B" on all 25 slides. | Visual summary of the entire case for judicial and appellate review. Every data point sourced from Exhibits C through J-4. Zero words of content are unsupported by the documentary record. | F1 (this filing) |
Day Zero: November 23, 2023 - last contact with B.M.B. (age 8) and B.R.B. (age 4).
| Date | Event | Source | Exhibit |
|---|---|---|---|
| Mar 4, 2015 | B.M.B. born, Santa Monica, CA | [SWORN] UCCJEA | Exhibit C-1 |
| Dec 4, 2018 | B.R.B. born, Tampa, FL | [SWORN] UCCJEA | Exhibit C-1 |
| Dec 2018 – Mar 2019 | Father lived with Mother and both children at 700 Dockview Way, Apt 1321, Tampa FL | [SWORN] UCCJEA | Exhibit C-1 |
| Mar 20, 2021 | Mother marries Igor Radwanski in St. Petersburg, FL | [SWORN] Adoption Petition | Exhibit C-2 |
| 2021–2023 | Four adoption attempts by stepfather - all refused by Father | [SWORN] Mother's admission + [EVIDENCE] Exhibit D texts ("4th time") | Exhibit D |
| Date | Day # | Event | Source | Exhibit | CF |
|---|---|---|---|---|---|
| Nov 23, 2023 | 0 | LAST CONTACT. Father's final contact with B.M.B. (8) and B.R.B. (4). Total separation begins. No court order. | [EVIDENCE] All docs | Multiple | All |
| Dec 15, 2023 | 22 | Petition for Paternity filed by Mother. Request-Demand for Mandatory Disclosure filed. | [FILED] | Exhibit H-4, Exhibit H-6 | - |
| Date | Day # | Event | Source | Exhibit | CF |
|---|---|---|---|---|---|
| May 16, 2024 | 175 | 5th Adoption Petition filed by stepfather + Mother. Same attorney. Case # LEFT BLANK. Claims Father "has not participated meaningfully." False claim of attached consent (Exhibit E). | [FILED] | Exhibit C-2, Exhibit C-1 | CF-4 |
| May 17, 2024 | 176 | Quid pro quo letter: "Consent to adoption... we waive child support." ONE DAY after petition. | [ATTORNEY] | Exhibit D-1 | CF-4 |
| Jul 23, 2024 | 243 | 7-day financial ultimatum letter (Anita Abraham). Zero mention of children's wellbeing. | [ATTORNEY] | Exhibit E-1 | CF-5 |
| Jul 31, 2024 | 251 | Mother's Motion to Compel filed. | [FILED] | Exhibit D-3 | - |
| Aug 9, 2024 | 260 | Father orally acknowledges paternity. Files Answer. Court directs opposing counsel to file it - they do not. | [FILED] | Exhibit D-4, Exhibit E-4 | - |
| Aug 23, 2024 | 274 | Father files Motion for Extension; provides proof of health/dental insurance for children. | [FILED] | Exhibit E-4 | - |
| Sep 9, 2024 | 291 | Parenting course COMPLETED - 36 days BEFORE court deadline. Certificate ID: sb1jxxg3nb. | [EVIDENCE] | Exhibit E | CF-1 |
| Oct 1, 2024 | 313 | Certificate provided to opposing counsel (Kris Kaylor) per judge's instruction. | [EVIDENCE] | Exhibit E-4 | CF-1 |
| Oct 1, 2024 | 313 | Kantaras "or-else" letter - adoption refusal linked to GAL/psych eval conditions. Wrong email used. | [ATTORNEY] | Exhibit E-1 | CF-5 |
| Oct 15, 2024 | 327 | Court deadline for parenting course - already completed 36 days earlier. | [COURT ORDER] | - | CF-1 |
| Nov 22, 2024 | 365 | "It doesn't even matter, you're not even the father." Kris Kaylor admits unaware of certificate. GAL + psych eval DENIED. Father directed to leave chambers. | [EVIDENCE] | Exhibit E-3, Exhibit E-4 | CF-1 |
| Dec 16, 2024 | 389 | Certificate placed ON DOCKET via Motion to Correct Procedural Record. Mother's own exhibit list (Exhibit H-6 Tab 8) confirms. | [FILED] | Exhibit E-4 | CF-1 |
| Dec 27, 2024 | 400 | Fuchslocher email: "overdue Order... Kris Kaylor is no longer with the firm." | [EMAIL] | Exhibit E-5 | CF-1 |
| Dec 31, 2024 | 404 | GAL and Psych Eval formally DENIED by written order. | [COURT ORDER] | Exhibit E-6 | - |
| Date | Day # | Event | Source | Exhibit | CF |
|---|---|---|---|---|---|
| Jan 28, 2025 | 432 | Mother files Motion for Contempt - wrong email in COS. 6 days before False Finding. | [FILED] | Exhibit F | CF-2 |
| Jan 31, 2025 | 435 | Father files Emergency Motion for Time-Sharing - STILL PENDING 13+ months. | [FILED] | Docket | - |
| Feb 3, 2025 | 438 | February 3, 2025 Order - Record Discrepancy. Certificate "does not appear from the docket" - 49 days after Exhibit E-4 placed it there. Income imputed $61,440/yr without § 61.30(2)(b) findings. Emergency time-sharing DENIED. Contact conditioned on financial compliance. | [COURT ORDER] | Exhibit F-1 | CF-1 |
| Mar 14, 2025 | 477 | Federal § 1983 complaint filed. Judge Pollack named defendant. Defended by FL Attorney General. | [FILED] | Exhibit F-2 | - |
| May 27, 2025 | 551 | Bodily attachment order - no notice to Father, no hearing, no ability-to-pay finding. | [COURT ORDER] | Docket | CF-2 |
| May 29, 2025 | 553 | Court REFUSES to sign proposed contempt order. "After review, not signed." | [EVIDENCE] | Exhibit G-1 | CF-2 |
| Jun 2, 2025 | 557 | EXONERATION: NO willful misconduct, NO ability to pay. Contempt DENIED. Sanctions DENIED. Fees DENIED. | [COURT ORDER] | Exhibit G-2 | CF-2 |
| Jun 4, 2025 | 559 | "Wife's" GAL Motion refiled - 194 days after denial. Wrong email. False "Wife" designation. | [FILED] | Exhibit G-3 | CF-3 |
| Sep 10, 2025 | 657 | Notice of Hearing filed - 5 coordination attempts documented in footnote. | [FILED] | Exhibit H-1 | CF-3 |
| Sep 19, 2025 | 666 | Federal case STAYED - remains LIVE. Judge Pollack remains defendant. | [COURT ORDER] | Exhibit H-2 | - |
| Oct 2, 2025 | 679 | "Completely unresponsive" - Harrer email to court. Directly contradicted by Exhibit H-1. | [EMAIL] | Exhibit H-3 | CF-3 |
| Oct 16, 2025 | 693 | Hearing #1 - "Wife's" exhibit list (Exhibit H-4). 14 tabs. Father testified 2 hours. Cross cut off at 4:30 PM (11 min remaining). | [EVIDENCE] | Exhibit H-4 | CF-3 |
| Nov 24, 2025 | 732 | Hearing #2 - DIFFERENT exhibit list (Exhibit H-6). 12 of 14 tabs changed. Judge acknowledged different binders on record. Mother's 6 sworn admissions. "Band aid" statement. Cross began 3:19 PM, cut off 3:30 PM. 11 minutes remaining. | [EVIDENCE] [SWORN] | Exhibit H-6, Exhibit E-3 | #3, #4 |
| Dec 18, 2025 | 756 | 730-day written admission. Kantaras letter. Access conditioned on psych eval + drug screen "approved by us." Zero mention of reunification. | [ATTORNEY] | Exhibit I-1 | CF-5 |
| Date | Day # | Event | Source | Exhibit | CF |
|---|---|---|---|---|---|
| ~Jan 10, 2026 | ~779 | Father sends 11-issue email to Court. Only 1 addressed (continuance). 10 preserved. | [EMAIL] | Exhibit I-4 | - |
| Jan 16, 2026 | 785 | Continuance to April 2. 10 of 11 issues unaddressed. | [COURT ORDER] | Exhibit I-5 | - |
| Mar 4, 2026 | 832 | B.M.B.'s 11th birthday - 3rd consecutive without Father. | - | - | - |
| Mar 19, 2026 | 847 | THIS FILING. 847 days. 20,328 hours. | - | - | All |
| Mar 19, 2026 | 847 | Pre-Trial Memorandum deadline. 5:00 PM. | Exhibit I-5 | - | - |
| Apr 2, 2026 | 861 | Evidentiary Hearing. 1:30 PM. Courtroom 421, 315 Court St, Clearwater FL 33756. Day 861 = 20,664 hours. | Exhibit I-5 | - | - |
Each finding is a binary, verifiable fact - not an opinion, not an interpretation. Each can be confirmed from the Court's own records.
| Element | Fact |
|---|---|
| What happened | Nov. 22, 2023: retainer signed by Mother (reflected in Mother's own exhibit). Nov. 23: final visit between Father and children. Nov.–Feb.: Mother communicated with Father via text throughout. Feb. 2024: Mother arranged a meeting - children were never there - process server delivered papers. |
| Binary proof | At Nov. 2024 cross-examination, Mother claimed she "couldn't reach him" - directly contradicted by months of her own text messages entered into the record. |
| Core Exhibits | Exhibit C-1 (UCCJEA - retainer date), Exhibit H-4 (Mother's exhibit list showing retainer, Tab 13), Exhibit D (text messages) |
| Consequence | The case was built on a fabricated narrative of unreachability - disproven by the opposing party's own communications. |
| Legal authority | FL Bar Rule 4-3.3(a)(1) - candor toward the tribunal; Fla. Stat. § 57.105 - sanctions for unsupported claims |
| Element | Fact |
|---|---|
| What happened | Feb 3, 2025 Order (Exhibit F-1) states parenting course certificate "does not appear from the docket" |
| Why it's false | Certificate was filed on docket December 16, 2024 via Exhibit E-4 - 49 days before the order |
| Binary proof | Mother's own Nov 24, 2025 exhibit list (Exhibit H-6, Tab 8) includes Father's Motion to Correct (Exhibit E-4) - confirming the certificate was known to exist |
| Core Exhibits | Exhibit E (certificate), Exhibit F-1 (false order), Exhibit E-4 (motion to correct) |
| Consequence | Emergency time-sharing DENIED. Income imputed at $61,440/yr. Contact conditioned on financial compliance. All flowing from a verifiably false premise. |
| Legal authority | Fla. R. Civ. P. 1.540(b)(3) - relief from judgment based on fraud, misrepresentation, or misconduct |
| Element | Fact |
|---|---|
| What happened | Court found NO willful misconduct, NO ability to pay on June 2, 2025 (Exhibit G-2) |
| Why it matters | Enforcement posture continues unchanged despite the Court's own exoneration. Proposed contempt order REFUSED by judge on May 29 (Exhibit G-1). |
| Core Exhibits | Exhibit G-2 (exoneration order), Exhibit G-1 (refused proposed order), Exhibit F-1 (income imputation) |
| Legal authority | Turner v. Rogers, 564 U.S. 431 (2011); Bearden v. Georgia, 461 U.S. 660 (1983) |
| Element | Fact |
|---|---|
| What happened | 12 of 14 tabs changed between hearings without disclosure. "Completely unresponsive" claimed while 5 coordination attempts were documented. |
| Binary proof | Exhibit H-4 vs. Exhibit H-6 - side-by-side comparison shows 12 different tabs. Exhibit H-3 vs. Exhibit H-1 - "unresponsive" claim vs. 5 documented attempts. |
| Core Exhibits | Exhibit H-4, Exhibit H-6 (two exhibit lists), Exhibit H-3 (Harrer email), Exhibit H-1 (coordination attempts) |
| Legal authority | FL Bar Rules 4-3.3(a)(1), 4-3.4(a)(b), 4-8.4(c)(d); Fla. Stat. § 117.05 |
| Element | Fact |
|---|---|
| What happened | Under oath at the November 24, 2025 hearing, Mother admitted: withholding children from Father; making negative statements about Father to the children; physical abuse of children by Stepfather; five stepparent adoption attempts; claim of "never received" financial support contradicted by texts read into the record. |
| Binary proof | Six sworn admissions on the record. None have been addressed in any written finding or order. FL § 61.13(2)(c)(13) requires written findings on negative statements. FL § 61.13(2)(c)(14) requires findings on domestic violence. |
| Core Exhibits | Exhibit E-3 (Nov 22, 2024 transcript - "not even the father"), Exhibit H-7 (Nov 24, 2025 transcript - six sworn admissions) |
| Legal authority | Fla. Stat. § 61.13(2)(c)(13) & (14); Keitel v. Keitel, 716 So. 2d 842 (Fla. 4th DCA 1998) |
| Element | Fact |
|---|---|
| What happened | Opposing counsel's own letter admits "730 days" without "meaningful communication" - with NO court order, NO best-interest findings, NO fitness adjudication |
| Binary proof | Exhibit I-1 - K. Dean Kantaras's own signature. Actual count at writing: 756 days (understated by 26). |
| Core Exhibits | Exhibit I-1 (admission letter), Exhibit I (Father's zero-condition email), Exhibit I-2 (three unauthorized conditions reinstated) |
| Legal authority | 14th Amendment due process; Troxel v. Granville, 530 U.S. 57 (2000); Fla. Stat. § 61.13(2)(c) |
The following filings contain the WRONG email address (sb@vizionprotoc.io - missing the letter 'l') in the Certificate of Service:
| Filing | Date | Correct Email | Implication |
|---|---|---|---|
| Exhibit G-3 - GAL Motion | 6/4/2025 | sb@vizionprotocol.io | Service may be defective under Fla. R. Jud. Admin. 2.516 |
| Exhibit F - Motion for Contempt | 1/28/2025 | sb@vizionprotocol.io | Service may be defective - this filing preceded the False Finding Order by 6 days |
| Exhibit E-1 - Oct 1, 2024 Letter | 10/1/2024 | sb@vizionprotocol.io | Wrong email used in attorney correspondence |
If any enforcement action relies on service through these filings, service of process may be defective.
At the November 24, 2025 hearing (Day 732), Petitioner Kelly Burja admitted under oath (Exhibit H-6; Exhibit E-3):
1. Withholding: She withheld the children from Father for 730+ days - with no court order directing her to do so [§ 61.13(2)(c)(1), (3)]
2. Refusal to co-parent: She did not engage in co-parenting and refused to communicate with Father [§ 61.13(2)(c)(1)]
3. Negative statements: She made negative statements about Father to the children - directly implicating § 61.13(2)(c)(1) (facilitation of parent-child relationship) [§ 61.13(2)(c)(14)]
4. Domestic violence: She was physically abused by stepfather Igor Radwanski on multiple occasions - the man currently residing with and raising the children. Implicates § 61.13(2)(c)(13) (evidence of domestic violence) and § 39.201 (mandatory reporting). This Court has a mandatory reporting obligation under § 39.201 that has not been fulfilled in the 129 days since this admission was made on the record. [§ 61.13(2)(c)(13); § 39.201]
5. Adoption pattern: The stepfather pursued five adoption attempts to legally eliminate Father - all while Father was fighting in court. Implicates § 63.062 (consent cannot be coerced) [§ 63.062; § 61.13(2)(c)(14)]
6. Financial contradiction: Father DID provide financial support - directly contradicting her earlier sworn financial affidavit and testimony that she "never" received support. Texts read into the record at the same hearing proved otherwise. [§ 61.30(2)(b)]
None of these six admissions have been addressed in any written finding or order.
Florida Statute § 61.13(2)(c) mandates written findings on 20 best-interest factors before any modification of time-sharing. After 847 days, zero factors have been addressed in any written order.
| Factor | Description | Evidence in Record | Exhibit | Written Finding |
|---|---|---|---|---|
| (1) | Capacity to facilitate parent-child relationship | Mother admitted: refused to co-parent, made negative statements | H-6, E-3 | NONE |
| (3) | Continuity, stability, permanence | 847 days zero contact with no written plan | Timeline | NONE |
| (8) | Anticipated division of parental responsibilities | Never addressed in any order | - | NONE |
| (10) | Geographic viability of parenting plan | Father and children in same metro area; no geographic barrier | C-1 | NONE |
| (13) | Evidence of domestic violence, child abuse | Mother's sworn admission: DV by stepfather currently raising children | H-6, E-3 | NONE |
| (14) | Evidence of parental alienation | 4 letters over 19 months, zero reunification mentions; negative statements | D-1, E-1, I-1 | NONE |
| (19) | Child's preference if sufficiently mature | B.M.B. age 11; Father's Day Book expressing bond | C | NONE |
Result: Zero of 20 mandatory factors addressed. The statutory obligation is not discretionary - it is mandatory before any deviation from equal time-sharing.
This Court has simultaneously occupied three irreconcilable positions:
No constitutional classification theory permits this contradictory posture. Written findings must clarify which status applies and the legal basis for the current regime.
Florida Senate Bill 1128 (effective July 1, 2026; committee vote 11-0) was passed to prevent cases exactly like this one:
| This Case (847 Days) | SB 1128 Requirement |
|---|---|
| No parenting hearing for 847 days | Hearing within 30 days of initial pleading |
| No temporary parenting plan | Parenting plan within 60 days |
| Emergency motion pending 13+ months | Enforcement hearing within 5 business days |
| Mediation used as blocking mechanism | Mediation requires both parties' consent |
| Default rule gives Mother sole custody by silence | Default rule REPEALED - § 742.031(2) eliminated |
| No public accountability | OSCA reports compliance data to Legislature annually |
SB 1128 does not apply retroactively. But the rights it codifies - frequent and continuing contact, equal timesharing presumption, written findings, no unilateral mediation gates - existed in § 61.13 and the Constitution before this case was filed. SB 1128 is the Legislature's acknowledgment that those rights were being violated in cases like this one.
847 days. The Legislature gave courts 60. The gap is 787 days. That gap has two names: B.M.B. and B.R.B..
| Case | Citation | Establishes |
|---|---|---|
| Santosky v. Kramer | 455 U.S. 745 (1982) | Fundamental liberty interest; clear and convincing evidence required; parental rights don't evaporate absent model parenting |
| Troxel v. Granville | 530 U.S. 57 (2000) | Parental liberty among oldest fundamental interests; presumption of parental fitness |
| Stanley v. Illinois | 405 U.S. 645 (1972) | Unwed father's constitutional rights; cannot presume unfitness because parents were unmarried |
| Caban v. Mohammed | 441 U.S. 380 (1979) | Gender-based parental rights distinctions require heightened scrutiny; father's right to object to adoption |
| Turner v. Rogers | 564 U.S. 431 (2011) | Ability-to-pay required before civil contempt for non-payment |
| Bearden v. Georgia | 461 U.S. 660 (1983) | Cannot incarcerate for inability to pay without willfulness finding |
| M.L.B. v. S.L.J. | 519 U.S. 102 (1996) | Parental rights proceedings cannot be conditioned on ability to pay |
| Mathews v. Eldridge | 424 U.S. 319 (1976) | Procedural due process three-factor balancing test |
| Kennedy v. Mendoza-Martinez | 372 U.S. 144 (1963) | Civil sanctions that become punitive require criminal due process protections |
| Caperton v. A.T. Massey Coal Co. | 556 U.S. 868 (2009) | Due process requires not only impartiality but appearance of impartiality |
| Liteky v. United States | 510 U.S. 540 (1994) | Extrajudicial source doctrine for judicial bias |
| Pierce v. Society of Sisters | 268 U.S. 510 (1925) | Parents' liberty to direct upbringing of children |
| Statute | Requirement |
|---|---|
| § 61.13(2)(a) | Written order required to modify time-sharing |
| § 61.13(2)(c) | 20 mandatory best-interest factors for time-sharing determinations |
| § 61.13(2)(c)(1) | Each parent's capacity to facilitate parent-child relationship |
| § 61.13(2)(c)(2) | Each parent's capacity to provide consistent routine |
| § 61.13(2)(c)(13) | Evidence of domestic violence, abuse, neglect |
| § 61.30(2)(b) | Written findings required before imputing income |
| § 63.062 | Biological father's consent to adoption cannot be coerced or purchased |
| § 63.087 | Stepparent adoption procedure |
| § 39.201 | Mandatory reporting of child abuse or neglect |
| § 38.10 | Grounds for disqualification of judge |
| § 57.105 | Sanctions for frivolous claims or defenses |
| § 117.05 | False acknowledgments in notarized documents |
| § 92.525 | Perjury - false statements under oath |
| Rule | Purpose |
|---|---|
| Rule 1.080 | Filing and service of pleadings |
| Rule 1.520 | Mandatory written findings of fact and conclusions of law |
| Rule 1.540(b) | Relief from judgment - fraud, misrepresentation, or misconduct |
| Rule 12.080 | Family law written findings requirement |
| Rule 12.510 | Family law findings |
| Rule | Obligation |
|---|---|
| 4-3.3(a)(1) | Candor toward the tribunal - no false statements of fact |
| 4-3.4(a)(b)(c) | Fairness to opposing party - no altering/concealing evidence |
| 4-4.1 | Truthfulness in statements to others |
| 4-4.4 | Respect for rights of third persons |
| 4-8.4(c)(d) | Misconduct - dishonesty, fraud; conduct prejudicial to justice |
| 4-1.7 | Conflict of interest - concurrent representation |
Requires disqualification where impartiality might reasonably be questioned, including financial interest, personal bias, or when the judge is a party to the proceeding.
42 U.S.C. § 1983 - Civil rights action against persons acting under color of state law.
Respondent reserves the right to supplement this record as additional evidence becomes available, including but not limited to transcripts of the October 16, 2025 and November 24, 2025 hearings, federal court orders, and any newly discovered evidence of attorney or judicial misconduct.
This Notice does not constitute a waiver of any right, claim, or defense - including but not limited to all constitutional claims and all claims pending in Brown v. Florida Dep't of Revenue, No. 8:25-cv-00621 (M.D. Fla.).
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via the Florida Courts E-Filing Portal and/or electronic mail to:
K. Dean Kantaras, P.A.
attorneys@kantaraslaw.com
danielle@kantaraslaw.com
gabrielle@kantaraslaw.com
on this 19th day of March, 2026.
_________________________________
SHANE CHRISTOPHER BROWN
Respondent, Pro Se
sb@vizionprotocol.io
| Tab | October 16, 2025 (Exhibit H-4) "WIFE'S" | November 24, 2025 (Exhibit H-6) "MOTHER'S" | Status |
|---|---|---|---|
| 1 | Petition for Paternity 12/15/2023 | Petition for Paternity 12/15/2023 | SAME |
| 2 | Kelly Burja Financial Affidavit 3/31/2025 | Request-Demand + Financial Affidavit | DIFFERENT |
| 3 | Request-Demand for Compliance | Summons: Personal Service 12/15/2023 | DIFFERENT |
| 4 | Certificate of Nonappearance 05/20/2024 | Certificate of Nonappearance 05/20/2024 | SAME |
| 5 | Motion to Compel (Amended) 09/10/2024 | Mother's Motion to Compel 07/31/2024 | DIFFERENT - different date |
| 6 | Order Granting Amended Motion 01/14/2025 | Motion for Extension of Time 08/23/2024 | DIFFERENT - Father's motion as Petitioner's exhibit |
| 7 | Mother's Motion for Contempt 01/28/2025 | Mother's Amended Motion to Compel 9/10/2024 | DIFFERENT |
| 8 | Order Granting in Part 06/02/2025 | Father's Motion to Correct Record 12/16/2024 | DIFFERENT - Father's filing presented as Petitioner's exhibit |
| 9 | Order Handling Emergency Motion 02/03/2025 | Order Granting Amended Motion 01/14/2025 | DIFFERENT |
| 10 | Certificate of Nonappearance 07/10/2025 | Mother's Motion for Contempt 01/28/2025 | DIFFERENT |
| 11 | Motion for Contempt + to Strike 08/20/2025 | Emergency Motion Handling Order 02/03/2025 | DIFFERENT |
| 12 | Order Setting Hearing 10/10/2025 | Order Granting-in-part Motion 06/02/2025 | DIFFERENT |
| 13 | Retainer Agreement (redacted) | Certificate of Nonappearance 07/10/2025 | DIFFERENT - financial docs REMOVED |
| 14 | Invoices (redacted) | Motion for Contempt and to Strike 08/20/2025 | DIFFERENT - financial docs REMOVED |
Result: 12 of 14 tabs contain materially different documents. Tabs 13 and 14 - financial documents (retainer agreement and invoices) - were removed entirely from the second binder without disclosure or meet-and-confer. No explanation has been provided. No sanctions have been imposed.