Legal Update: Response to FDLE’s Motion to Dismiss filed in Does #1-5
Yesterday, attorneys for Does #1-5, et al – Valerie Jonas and Todd Scher, filed a Response to the Florida Department of Law Enforcement’s Motion to Dismiss the Third Amended Complaint.
This is the case that has been litigated in the Southern District of Florida since 2018, was dismissed once, appealed, and then remanded by the 11th Circuit Court of Appeals. This is the case we commonly referred to as Ex Post Facto I (to distinguish it between Ex Post Facto II, which was filed in the Northern District of Florida and in which the registrant prevailed), though it has evolved much during the past 7 years.
Jury Trial in this case is presently set for July 13, 2026 in Miami. While it seems like a long time away and unquestionably it’s been a long time coming, there is still much to do and so much that has transpired since this case was filed.
As usual, the attorneys did a fabulous job on behalf of the plaintiffs. This translates to a fabulous job on behalf of the entire population of persons forced to register. Thank you Val and Todd! Thank you also to the Plaintiffs who continue to bravely represent our community. And thanks to all of you who have contributed financially to the fund that sustains this litigation. There will still be plenty needed going forward so if you would like to contribute to help this case, you can do so here.
To read a copy if the Response, click on the link below:
EPF I – Response to MTD TAC
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This says that predators also can report in-state travel online. I was told that it had not changed for predators because EPF-1 did not say ‘sexual predator’ by name, it only used the words ‘sex offender’ and even though it should’ve been inclusive, it was instead applied only to the words used in the complaint.
The state/ government provided no studies or documentation at all to get these laws passed. Instead they just bandied about words like ‘high and frightening’ with absolutely no factual support.