| Probable cause affidavit: |
SUBMITTED BY: MATOS, THOMAS 0675 (AR11119528) DID UNLAWFULLY THREATEN TO HARM A PUBLIC SERVANT TO WIT: REPEATED THREATS WERE MADE DURING TRANSPORTATION BY THE DEFENDANT TOWARDS LAW ENFORCEMENT OFFICERS, CORRECTIONS OFFICERS AND ANY OTHER PERSONS HE MIGHT COME IN CONTACT WITH UP TO AND INCLUDING DEATH. IN VIOLATION OF FLORIDA'S STATE STATUTE 838.021(1). DID UNLAWFULLY COMMIT BATTERY UPON THE VICTIM BY ACTUALLY AND INTENTIONALLY TOUCHING OR STRIKING SAID PERSON AGAINST SAID PERSON'S WILL, OR BY INTENTIONALLY CAUSING BODILY HARM, TO WIT: CHOKED THE VICTIM WITH BOTH HANDS AROUND THE NECK, IN VIOLATION OF FLORIDA STATE STATUTE 784.03(1)(A)(1). ON 022611 AT APPROXIMATELY 1548 HOURS, I WAS DISPATCHED TO THE PARKING LOT OF AN APARTMENT COMPLEX LOCATED AT 8686 WEST MAYO DRIVE, IN REFERENCE TO A DISTURBANCE THAT WAS IN PROGRESS. UPON ARRIVAL AT APPROXIMATELY 1552 HOURS, IT WAS FOUND THAT BOTH PARTIES HAD LEFT THE PARKING LOT. I WAS INFORMED THROUGH DISPATCH THAT THE VICTIM WOULD BE EN ROUTE BACK TO MY LOCATION SO I WAITED FOR HER IN THE PARKING LOT OF THE APARTMENT COMPLEX. THE VICTIM, MS NICHOLE HAWKS, ARRIVED SOON THEREAFTER IN THE WITNESS, CHAUNDA MORIARITY. THE VICTIM ADVISED ME THAT SHE AND THE DEFENDANT, MR JUSTIN JONES, WERE AT THE APARTMENT COMPLEX TOGETHER. THE VICTIM ADVISED ME THAT THE DEFENDANT HAD BEEN DRINKING AND HAD BECOME BELLIGERENT VERBALLY TOWARDS THE VICTIM. THE DEFENDANT GOT IN THE VICTIM'S FACE AND BACKED HER INTO A CORNER SO THE VICTIM PUSHED PAST THE DEFENDANT TO GET HERSELF TO SAFETY. THE WITNESS TOOK BOTH THE VICTIM AND THE DEFENDANT AWAY FROM THE APARTMENT COMPLEX DUE TO A GATHERING CROWD FROM THE ARGUMENT IN AN UNKNOWN DIRECTION. WHILE TRAVELING SOUTHBOUND ON US 19, THE DEFENDANT BEGAN YELLING AT THE VICTIM FROM THE BACK SEAT. WHILE SITTING AT THE STOP LIGHT IN FRONT OF THE HOME DEPOT AT THE INTERSECTION OF US 19 AND WEST VENABLE STREET, THE DEFENDANT BEGAN CHOKING THE VICTIM UTILIZING BOTH HANDS WRAPPED AROUND THE VICTIM'S NECK. THE WITNESS PULLED THE VEHICLE OVER AND THE VICTIM EXITED THE VEHICLE. THE VICTIM SAW FIT TO RETALIATE AND DEFEND HERSELF AGAINST THE DEFENDANT BY HITTING THE DEFENDANT UNTIL HE LEFT THE VEHICLE. AT THAT TIME, THE WITNESS AND THE VICTIM DROVE AWAY AND RETURNED TO THE INCIDENT ADDRESS WHERE I WAS WAITING. I RECEIVED INFORMATION FROM BOTH THE WITNESS AND OTHER PEOPLE LOCATED IN THE HOME DEPOT PARKING LOT THAT THE DEFENDANT WAS ON FOOT AND WALKING TOWARDS THE REAR OF THE BEALL'S SHOPPING CENTER. I THEN LEFT THE APARTMENT COMPLEX ON MAYO DRIVE IN AN ATTEMPT TO LOCATE THE DEFENDANT. UPON ARRIVAL AT THE BEALL'S SHOPPING CENTER, DEPUTY WEATHERFORD ADVISED VIA THE RADIO THAT HE HAD LOCATED THE SUSPECT ON THE NORTHWEST SIDE OF THE SHOPPING PLAZA. I THEN MADE CONTACT WITH THE DEFENDANT WHO HAD MULTIPLE SCRATCHES ON HIS CHEST AND ON HIS FACE ALL SEEMINGLY SUPERFICIAL. THE DEFENDANT HAD A STRONG ODOR OF AN ALCOHOLIC SUBSTANCE EMANATING FROM HIS PERSON AS WELL AS SLURRED SPEECH AND UNBALANCED MOVEMENT. THE DEFENDANT WAS DESCRIBING THE ALTERCATION BETWEEN THE VICTIM AND HIMSELF. THE DEFENDANT ADVISED ME THAT THE VICTIM WAS THE AGGRESSOR. I OBTAINED A NEW JERSEY DRIVER'S LICENSE FROM THE DEFENDANT IN AN EFFORT TO RUN HIM IN FCIC/NCIC. WHEN THE DEFENDANT ADVISED ME THAT HE DID HAVE A WARRANT OUT OF NEW JERSEY, HOWEVER, IT WAS NON EXTRADITION. I COULD NOT CONFIRM THE WARRANT THROUGH TELETYPE DUE TO "NLETS" BEING DOWN. DUE TO THE INFORMATION RECEIVED FROM THE VICTIM AND THE WITNESS REGARDING THE INCIDENT AND THE SEVERITY OF THE DEFENDANT'S ACTIONS COMPARED TO THE RETALIATION OF THE VICTIM, I PLACED THE DEFENDANT UNDER ARREST FOR SIMPLE BATTERY. THE DEFENDANT WAS HANDCUFFED BEHIND HIS BACK DOUBLE LOCKED, SEARCHED INCIDENT TO ARREST, AND PLACED IN THE BACK SEAT OF MY PATROL VEHICLE. ONCE PLACED IN THE BACK SEAT OF MY PATROL VEHICLE, THE DEFENDANT BECAME EXTREMELY IRATE. STARTING FROM HIS INITIAL ENTRY INTO MY PATROL VEHICLE THROUGH THE ENTIRE TRANSPORTATION PROCESS THREATS WERE BEING MADE BY THE DEFENDANT FOR PHYSICAL VIOLENCE AGAINST LAW ENFORCEMENT OFFICERS, CORRECTIONAL OFFICERS, OTHER INMATES AT THE DETENTION FACILITY, AS WELL AS ANY OTHER PERSONNEL THAT HE COULD GET HIS HANDS ON UP TO AND INCLUDING DEATH. THE DEFENDANT WAS KICKING AGAINST THE BARRIER IN MY PATROL VEHICLE AS WELL AS MADE ATTEMPTS TO KICK AGAINST THE PASSENGER SIDE REAR DOOR. ONCE ARRIVING AT THE DETENTION FACILITY, AN EXTRACTION TEAM WAS IN PLACE BY THE DETENTION FACILITY TO ESCORT THE DEFENDANT FROM MY PATROL VEHICLE INTO THE DETENTION FACILITY. DURING THAT INTERACTION THE DEFENDANT BECAME PHYSICALLY RESISTANT TO THE EFFORTS OF THE CORRECTION OFFICER AS WELL AS BEING VERBALLY BELLIGERENT. THE DEFENDANT WAS CHARGED WITH ONE COUNT OF CORRUPTION BY THREAT AGAINST A PUBLIC SERVANT AND ONE COUNT OF SIMPLE BATTERY AGAINST THE VICTIM WITH HIS BOND SET AT A TOTAL OF $2,500.00 PER THE BOND SCHEDULE. "IF YOU ARE A PERSON WITH A DISABILITY WHO NEEDS ANY ACCOMMODATION IN ORDER TO PARTICIPATE IN THIS PROCEEDING, YOU ARE ENTITLED, AT NO COST TO YOU, TO THE PROVISION OF CERTAIN ASSISTANCE. PLEASE CONTACT THE ADA COORDINATOR AT THE OFFICE OF THE TRIAL COURT ADMINISTRATOR, CITRUS COUNTY COURTHOUSE, 110 NORTH APOPKA AVENUE, INVERNESS, FLORIDA 34450, TELEPHONE (352) 341-6700, AT LEAST 7 DAYS BEFORE YOUR SCHEDULED COURT APPEARANCE, OR IMMEDIATELY UPON RECEIVING THIS NOTIFICATION IF THE TIME BEFORE THE SCHEDULED APPEARANCE IS LESS THAN 7 DAYS; IF YOU ARE HEARING OR VOICE IMPAIRED, CALL 711.” *NOT-EXEMPT* |
