| Probable cause affidavit: |
SUBMITTED BY: ANSTEAD, LAURA 0459 (AR07003887) DID UNLAWFULLY AND KNOWINGLY HAVE IN HER ACTUAL OR CONSTRUCTIVE POSSESSION A CONTROLLED SUBSTANCE TO WIT: XANAX AND VALIUM IN VIOLATION OF FLORIDA STATE STATUTE 893.13 AND DID UNLAWFULLY AND KNOWINGLY HAVE IN HER ACTUAL OR CONSTRUCTIVE POSSESSION OF A DRUG WITHOUT A PRESCRIPTION, TO WIT: SOMA, IN VIOLATION OF FLORIDA STATE STATUTE 499.063(1) AND DID UNLAWFULLY AND KNOWINGLY OBTAIN OR USE, OR ENDEAVOR TO OBTAIN OR USE, THE PROPERTY OF THE KEY TRAINING CENTER TO WIT: PRESCRIPTION DRUGS, SAID PROPERTY BEING OF A VALUE OF LESS THAN $100.00, WITH THE INTENT TO EITHER TEMPORARILY OR PERMANENTLY DEPRIVE THE VICTIM OF A RIGHT TO THE PROPERTY TO HER OWN USE OR THE USE OF ANY PERSON NOT ENTITLED THERETO , IN VIOLATION OF FLORIDA STATE STATUTE, 812.014. ON 071107 AT APPROXIMATELY 0300 HOURS, I WAS DISPATCHED TO 1367 NORTH JAMES PAGE POINT (KEY TRAINING CENTER) IN REFERENCE TO A THEFT OF MEDICATION. UPON ARRIVAL, I MADE CONTACT WITH THE COMPLAINANT, WHO ADVISED THAT SHE AND THE DAY SHIFT AIDE, CONDUCTED A MEDICATION COUNT AT 1400 HOURS ON 071007, AT WHICH TIME, THE VICTIM HAD 45 VALIUM IN STOCK. SHE ADVISED SHE WAS CONTACTED AT APPROXIMATELY 0030 HOURS, BY THE NIGHT NURSE (WITNESS ONE), WHO CONDUCTED A COUNT AT 2345 HOURS, AT WHICH TIME, IT WAS DISCOVERED THAT 30 VALIUM WERE MISSING. A RECOUNT WAS CONDUCTED PRODUCING THE SAME RESULTS, AT WHICH TIME, THE CITRUS COUNTY SHERIFF'S OFFICE WAS CONTACTED IN REFERENCE TO THE MISSING MEDICATION. I THEN SPOKE WITH THE WITNESS ONE, WHO ADVISED THAT SHE AND ONE OF THE DAY SHIFT NURSES (WITNESS TWO), CONDUCTED THE COUNT SEVERAL TIMES AND THAT THERE WERE THIRTY VALIUM MISSING. SHE FURTHER ADVISED SHE SUSPECTED THE SECOND DAY SHIFT NURSES AIDE, THE DEFENDANT, MS RHONDA MORRIS, BECAUSE SHE HAD BEEN VERY ANXIOUS TO LEAVE EARLY AND THEY SUSPECTED SHE WAS UNDER THE INFLUENCE OF SOMETHING BECAUSE SHE WAS VERY GROGGY WHEN SHE LEFT. THE COMPLAINANT STATED SHE SPOKE WITH THE DEFENDANT AT APPROXIMATELY 2150 HOURS, WHEN THE DEFENDANT CALLED HER AND REQUESTED TO GO HOME EARLY. THE COMPLAINANT STATED SHE THOUGHT IT WAS STRANGE BECAUSE THE DEFENDANT HAD NEVER DONE THIS BEFORE. THE COMPLAINANT THEN ADVISED ME THAT THE DEFENDANT HAD BEEN INVOLVED IN A HIT AND RUN EARLIER, AND THAT DEPUTY CULBERTSON HAD ADVISED HER THAT HE SUSPECTED THE DRIVER (DEFENDANT) WAS UNDER THE INFLUENCE OF AN UNKNOWN SUBSTANCE. IT SHOULD BE NOTED, THAT AT APPROXIMATELY 2300 HOURS, THE CITRUS COUNTY SHERIFF'S OFFICE RECEIVED A TELEPHONE CALL IN REFERENCE TO THE HIT AND RUN THAT OCCURRED ON VAN NORTWICK ROAD. DEPUTY CULBERTSON CAUGHT UP WITH THE VEHICLE IN INVERNESS, AT WHICH TIME, HE OBSERVED THE DEFENDANT, MS RHONDA MORRIS AS BEING THE DRIVER, AND SHE ADVISED SHE DID NOT REALIZE SHE HAD HIT THE TRUCK. DEPUTY CULBERTSON SUSPECTED THE DEFENDANT WAS UNDER THE INFLUENCE AND DECIDED TO GIVE HER A RIDE HOME. DEPUTY CULBERTSON ADVISED IT WAS APPROXIMATELY 0000 HOURS, WHEN HE DROPPED HER OFF AT HER RESIDENCE AND SHE WAS VERY UPSET ABOUT HAVING TO LEAVE HER VEHICLE AND NOT BEING ABLE TO DRIVE. WHILE ON SCENE AT THE KEY TRAINING CENTER, I MADE CONTACT WITH DEPUTY CULBERTSON IN REFERENCE TO THIS INCIDENT AND REQUESTED HE AGAIN MAKE CONTACT WITH THE DEFENDANT AND INQUIRE ABOUT THE MISSING MEDICATION. I THEN CONTACTED CORPORAL AMSLER DUE TO DEPUTY CULBERTSON GETTING ANOTHER CALL FOR SERVICE AND REQUESTED CORPORAL AMSLER MAKE CONTACT WITH THE DEFENDANT. I INFORMED CORPORAL AMSLER ABOUT THE INCIDENT AND PROVIDED HIM WITH THE DESCRIPTION OF THE MISSING MEDICATION. APPROXIMATELY TWENTY MINUTES AFTER MAKING CONTACT WITH CORPORAL AMSLER, HE CONTACTED THIS DEPUTY VIA TELEPHONE AND ADVISED THIS DEPUTY THAT UPON MAKING CONTACT WITH THE DEFENDANT, SHE DENIED HAVING ANY KNOWLEDGE OF WHERE THE MEDICATION WAS. CORPORAL AMSLER STATED THAT THE BOYFRIEND OF THE DEFENDANT, (WITNESS THREE) UPON HEARING THE CONVERSATION WENT OUT TO THE GARAGE AND CAME BACK WITH THE STOLEN MEDICATION AND THREE SMALL BAGGIES OF PILLS. WHEN ASKED WHERE HE OBTAINED THE MEDICATION HE ADVISED IT WAS IN THE GARAGE, UNDER THE DEFENDANT'S WORK CLOTHING, WHERE SHE ALWAYS HIDES HER ALCOHOL. I CONFIRMED THAT THE NARCOTICS WERE THE MISSING NARCOTICS FROM THE KEY TRAINING CENTER. CORPORAL AMSLER ADVISED THAT AFTER FINDING THE PILLS, THE DEFENDANT STATED THAT SHE HAD GOTTEN HOME FROM WORK, AT WHICH TIME, SHE FOUND THE PILLS IN HER PURSE AND BELIEVED THAT ANOTHER NURSE PUT THEM THERE TO FRAME HER AND WAS GOING TO TAKE THEM BACK IN THE MORNING. I REQUESTED DEPUTY CULBERTSON TRANSPORT THE DEFENDANT TO THE CITRUS COUNTY DETENTION FACILITY, WHERE I WOULD MAKE CONTACT WITH HER. UPON ARRIVAL, THE DEFENDANT WAS READ MIRANDA VIA CARD TO WHICH SHE ADVISED SHE UNDERSTOOD AND WOULD ANSWER MY QUESTIONS. THE DEFENDANT AGAIN ADVISED THAT UPON HER ARRIVAL HOME, SHE FOUND THE MEDICATION IN HER PURSE AND WAS GOING TO RETURN THE MEDICATION THE FOLLOWING DAY UPON HER RETURN TO WORK. SHE ALSO ADVISED THAT SHE DID NOT WANT HER DAUGHTERS (AGES 13, 13 AND 15) TO FIND THE MEDICATION AND THINK IT WAS CANDY, SO SHE HID IT THE GARAGE. WHEN ASKED ABOUT THE OTHER PILLS, SHE ADVISED THAT HER SISTER WHO HAD TRAVELED FROM GEORGIA A WEEK PRIOR, GAVE HER THE MEDICATION WHEN SHE WAS IN FLORIDA VISITING THE DEFENDANT. IT SHOULD BE NOTED, THAT THERE WERE THREE SEPARATE CELLOPHANE WRAPPERS, ONE CONTAINING THREE HALVES OF XANAX PILLS, THE SECOND BAG CONTAINED THREE WHITE ROUND PILLS WITH THE MARKINGS DAM AND 5513 ON THE OTHER SIDE WHICH WERE CONFIRMED TO BE 350 MILLIGRAMS OF CARIZOPRADOL WHICH IS A NARCOTIC SOMA. THE THIRD CELLOPHANE BAG CONTAINS TWO 26 OF THE SOMA PILLS. THE DEFENDANT ADVISED THAT SHE DID NOT HAVE A PRESCRIPTION FOR ANY OF THESE MEDICATIONS AND IS ALLERGIC TO MOST PAIN MEDICATIONS. WHEN ASKED WHERE SHE OBTAINED THE MEDICATIONS FROM, SHE ADVISED HER SISTER GAVE THEM TO HER, HOWEVER, THE DEFENDANT COULD NOT EXPLAIN WHY THE SISTER WOULD GIVE HER MEDICATION IF THE DEFENDANT IS ALLERGIC TO THE MEDICATION AND CANNOT TAKE THE MEDICATION. CONTACT WAS THEN MADE WITH THE COMPLAINANT VIA THE TELEPHONE, AT WHICH TIME, THE WHEREABOUTS OF THE SECOND AID (WITNESS FOUR) THAT THE DEFENDANT ADVISED WAS TRYING TO FRAME HER (DEFENDANT), WERE CONFIRMED, IN WHICH IT WAS DISCOVERED THAT NO TIME BETWEEN THE TWO DRUG COUNTS WAS IT POSSIBLE FOR ANY OF THE AIDS TO PLACE ANYTHING IN THE DEFENDANT'S PURSE. I ALSO MADE CONTACT VIA TELEPHONE WITH THE DEFENDANTS BOYFRIEND. HE ADVISED AFTER HEARING THE CONVERSATION THE DEPUTIES WERE HAVING WITH THE DEFENDANT, HE KNEW THAT IF SHE HAD THE MEDICATION, IT WOULD BE IN HER HIDING SPOT IN THE GARAGE. HE ADVISED THAT SHE WAS ACTING FUNNY UPON HER ARRIVAL HOME FROM WORK AND HE COULD TELL SHE HAD BEEN DRINKING. I OBTAINED STATEMENTS FROM THE DEFENDANT'S BOYFRIEND AND THE DEFENDANT. THE NARCOTICS WERE PACKAGED AND TURNED OVER TO THE CITRUS COUNTY EVIDENCE LOCKER. THE DEFENDANT WAS CHARGED WITH TWO COUNTS OF POSSESSION OF A CONTROLLED SUBSTANCE, POSSESSION OF A DRUG WITHOUT A PRESCRIPTION AND THEFT. THE DEFENDANT'S BOND WAS SET AT $4,750.00 PER THE BOND SCHEDULE. *NOT-EXEMPT* |
