Docs Viewer

Calibri;Calibri; \*Riched20 10.0.22621 **IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT** **IN AND FOR DUVAL COUNTY, FLORIDA** **Case No.: [16-2001-DR-2055-FM]** **Demetrius Thompson,** Petitioner, v. **[ALANA CHERISE WATSON, DEPT OF REVENUE, STATE OF FLORIDA ],** Respondent. --- ### **MOTION TO STAY CONTEMPT PROCEEDINGS AND MODIFY SUPPORT OBLIGATION DUE TO EMANCIPATION, FINANCIAL HARDSHIP, AND DENIAL OF ASSISTANCE** **COMES NOW**, the Petitioner, Demetrius Thompson fully moves this Honorable Court to stay the contempt proceedings scheduled for **June 9, 2025**, and to modify the existing child support obligation. In support thereof, Petitioner states as follows: 1. **Emancipation of Child**: The child for whom support was ordered has reached the age of majority and is no longer a minor. Pursuant to **Florida Statutes 61.14(9)**, the obligation to pay current child support terminates upon the child's emancipation. Arrearages, however, may still be enforced within legal limits. 2. **Financial Hardship**: Petitioner has experienced significant and ongoing financial hardship, including unemployment and reliance on **Temporary Assistance for Needy Families (TANF)**. During periods of employment, the State was already garnishing **$10 biweekly**, reflecting Petitioner's limited ability to contribute. 3. **Arbitrary Increase in Obligation**: Despite Petitioner's clear financial difficulties and prior payments, Hearing Officer **Barrat Garrett** arbitrarily imposed a **$300/month obligation**an amount created without justification and contrary to Petitioner's actual income and documentation. 4. **Audit Results Acknowledging Overstated Arrears**: An audit ordered by Hearing Officer **Leatrice Walton Williams** reduced the arrears from an alleged **$108,000 to $53,000**. Petitioner continues to dispute this revised amount, but this finding confirms major accounting errors in the original enforcement. 5. **Settlement Offer Rejected Without Cause**: Petitioner received a **past-due letter** inviting him to call for help. Upon calling, Petitioner was **denied any assistance**, and his reasonable **settlement offer of 38% of the disputed amount ($15,200) and a $100/month payment plan** was either **ignored or rejected outright**. No payment arrangements were offered despite Petitioner's good faith effort to resolve the matter cooperatively. 6. **Judicial Complaints Filed**: Petitioner has submitted **formal complaints** to the Florida Judicial Qualifications Commission regarding alleged misconduct by Hearing Officers Garrett and Williams. These complaints are attached hereto as **Exhibits A and B**. 7. **Due Process Concerns**: These enforcement actionscombined with the rejection of financial documents, refusal of settlement, and arbitrary increasesdemonstrate a **lack of due process**, in violation of *Turner v. Rogers*, 564 U.S. 431 (2011), which requires an ability-to-pay inquiry prior to any contempt-based punishment. ### **WHEREFORE**, Petitioner respectfully requests that this Honorable Court: A. **Stay the contempt proceedings** scheduled for June 9, 2025; B. **Modify the existing child support obligation** to reflect Petitioner's actual ability to pay and the emancipation of the child; C. **Recognize Petitioner's good faith attempt to resolve the matter**, including the rejected settlement proposal; D. **Consider audit findings** and request recalculation of the arrearages; E. **Grant any further relief** deemed just and proper. --- **Respectfully submitted,** [Demetrius Thompson] [1003 Mayer Dr ] [Jacksonville, Florida ] [904-451-2175 [Kamonraking@gmail.com --- ### **CERTIFICATE OF SERVICE** I HEREBY CERTIFY that a true and correct copy of the foregoing was served upon **[Opposing Party's Name or Attorney]**, at **[Address]**, on this ___ day of __________, 2025. Demetrius Thompson --- **Attachments:** - **Exhibit A:** Judicial Complaint Barrat Garrett - **Exhibit B:** Judicial Complaint Leatrice Walton Williams - **Exhibit C:** Settlement Offer and Past-Due Letter Correspondence - **Exhibit D:** Financial Affidavit and TANF Documentation ---