| Probable cause affidavit: |
SUBMITTED BY: STANTON, JOE 0260 (AR10116798) DID UNLAWFULLY, ACTUALLY AND INTENTIONALLY TOUCH OR STRIKE THE VICTIM, A PARAMEDIC, AGAINST HIS WILL OR INTENTIONALLY CAUSE BODILY HARM TO SAID PERSON, AND IN THE COMMISSION OF THE BATTERY THE DEFENDANT DID USE A DEADLY WEAPON, TO WIT: A 1992 BUICK FOUR DOOR, IN VIOLATION OF FLORIDA STATE STATUTE NUMBER 784.045(1)(A)(2). ON 091210 AT APPROXIMATELY 1017 HOURS, I WAS DISPATCHED TO A MOTOR VEHICLE CRASH WITH UNKNOWN INJURIES AT 3924 SOUTH FLORIDA AVENUE IN INVERNESS. WHILE EN ROUTE I WAS UPDATED WITH INFORMATION FROM DISPATCH ADVISING THAT THE DEFENDANT, IDENTIFIED AS MR SETH MICHAEL GOLEY, HAD LEFT THE SCENE OF THE CRASH AND IN THE PROCESS STRUCK A PARAMEDIC, IDENTIFIED AS THE VICTIM, WITH HIS VEHICLE. THE VEHICLE THEN LEFT THE SCENE TRAVELING SOUTHBOUND ON SOUTH FLORIDA AVENUE. I PROCEEDED PAST THE ORIGINAL CRASH LOCATION SOUTHBOUND ON SOUTH FLORIDA AVENUE AND AS I CAME THROUGH THE TRAFFIC LIGHT IN FLORAL CITY CONTINUING SOUTH, I OBSERVED WHAT APPEARED TO BE A RED PASSENGER VEHICLE APPROXIMATELY A QUARTER MILE AWAY FROM ME. UPON CATCHING UP TO THIS VEHICLE, I VERIFIED THE TAG WITH DISPATCH AS THE PARAMEDIC THAT WAS ON SCENE WAS ABLE TO GIVE US THE TAG OF THE VEHICLE, AT WHICH TIME, DISPATCH ADVISED THAT IT WAS THE SUSPECT VEHICLE. I DID NOT OBSERVE ANY UNUSUAL DRIVING BEHAVIOR AT THAT TIME. I THEN CONDUCTED A HIGH RISK TRAFFIC STOP JUST SOUTH OF EAST STAGECOACH TRAIL ON SOUTH FLORIDA AVENUE, EXITED MY VEHICLE, AND DREW MY DUTY WEAPON AND KEPT IT AT THE LOW READY POSITION NOT POINTING IT AT THE DEFENDANT AND ORDERED THE DEFENDANT OUT OF HIS VEHICLE. ONCE THE DEFENDANT WAS OUT OF HIS VEHICLE, HE WAS TAKEN INTO CUSTODY BY THE BACKUP DEPUTY WHO RESPONDED TO ASSIST ME. AFTER THE DEFENDANT WAS IN CUSTODY, HE WAS SEARCHED AND PLACED IN THE REAR SEAT OF MY PATROL VEHICLE. AT THAT TIME, THE DEFENDANT WAS ASKING WHAT HE WAS STOPPED FOR AND I INFORMED HIM THAT I STOPPED HIM BECAUSE HE WAS INVOLVED IN A CRASH AND THEN LEFT THE SCENE AND IN THE PROCESS HE STRUCK A PARAMEDIC WITH HIS VEHICLE. THE DEFENDANT DENIED ANY KNOWLEDGE OF THE EVENTS THAT I EXPLAINED TO HIM. I DID NOT SMELL ANY ALCOHOL EMITTING FROM THE DEFENDANT, HOWEVER, THERE WAS AN OPEN COORS LIGHT BEER CAN IN THE DEFENDANT'S ARM REST OF HIS VEHICLE. I ASKED THE DEFENDANT IF HE HAD ANY TYPE OF MEDICAL PROBLEMS AND THE DEFENDANT STATED TO ME THAT HE WAS HYPOGLYCEMIC. I ASKED THE DEFENDANT IF HE WAS A DIABETIC AND HE STATED THAT HE DID NOT THINK SO. I ASKED THE DEFENDANT IF A DOCTOR HAD EVER DIAGNOSED HIM WITH DIABETES OR IF HE WAS TAKING ANY MEDICATION FOR DIABETES AND HE STATED NO. SINCE THE ORIGINAL VICTIM WAS ALREADY EN ROUTE TO MY LOCATION TO IDENTIFY THE DEFENDANT, I HAD EMERGENCY MEDICAL SERVICES (EMS) CHECK THE DEFENDANT'S BLOOD SUGAR WHICH WAS 105. ACCORDING TO EMS THIS WAS NOT A HYPOGLYCEMIC READING. I ASKED THE DEFENDANT AGAIN IF HE HAD ANY OTHER MEDICAL PROBLEMS AND HE STATED NO. I ASKED THE DEFENDANT IF HE HAD BEEN TAKING ANY KIND OF DRUGS AND HE STATED NO. I DID NOT QUESTION THE DEFENDANT ANY FURTHER AS TO WHAT HAD HAPPENED BECAUSE I EXPLAINED TO HIM TWICE THE REASON WHY I HAD PULLED HIM OVER AND EACH TIME HE DENIED ANY KNOWLEDGE THAT THE EVENTS HAD TAKEN PLACE. WHILE I HAD THE DEFENDANT DETAINED IN MY VEHICLE, THE PARAMEDIC WHO WAS STRUCK BY THE DEFENDANT'S VEHICLE RESPONDED TO MY LOCATION, AT WHICH TIME, HE IDENTIFIED THE DEFENDANT AS THE PERSON WHO WAS DRIVING THE VEHICLE WHEN THE VEHICLE STRUCK HIM. AT THAT TIME, I WAS ABLE TO SPEAK WITH THE VICTIM WHO EXPLAINED TO ME THAT HE HAD RESPONDED TO THE MOTOR VEHICLE ACCIDENT AS AN EMPLOYEE FOR NATURE COAST EMS. UPON HIS ARRIVAL, HE NOTED THE DEFENDANT'S VEHICLE WITH FRONT END DAMAGE AGAINST A TREE. I ASKED THE VICTIM HOW BIG THE TREE WAS AND HE DESCRIBED IT AS BEING APPROXIMATELY FOUR TO FIVE INCHES IN DIAMETER. THE VICTIM STATED THAT AS HE APPROACHED THE VEHICLE ON THE DRIVER'S SIDE HE NOTICED AN OCCUPANT IDENTIFIED AS THE DEFENDANT WHO WAS NOT AWAKE IN THE DRIVER'S SEAT. THE VICTIM STATED THAT HE SHOOK THE DEFENDANT'S SHOULDER AND THE DEFENDANT OPENED ONE EYE AND WHEN THE DEFENDANT SPOKE THE VICTIM STATED HE COULD SMELL AN ODOR OF ALCOHOL AND NOTICED AN OPEN CONTAINER OF BEER IN THE DEFENDANT'S VEHICLE. THE VICTIM STATED THAT HE TOLD THE DEFENDANT THAT HE HAD BEEN IN A WRECK AND THE DEFENDANT STATED TO THE VICTIM THAT HE DID NOT REMEMBER IT. THE DEFENDANT THEN TRIED TO PUT HIS KEYS IN THE IGNITION, AT WHICH TIME, THE VICTIM, WHO WAS STANDING AT THE OPEN DRIVER DOOR NEXT TO THE DEFENDANT, TRIED TO STOP HIM, BUT THE DEFENDANT WAS ABLE TO START HIS VEHICLE. AT THAT TIME, THE DEFENDANT SLAMMED HIS VEHICLE INTO REVERSE AND BACKED UP STRIKING THE VICTIM WITH THE DRIVER'S DOOR KNOCKING HIM BACK APPROXIMATELY TEN TO FIFTEEN FEET. AT THAT TIME, THE VICTIM REPORTED WHAT HAD HAPPENED OVER HIS RADIO. I DID OBSERVE AN ABRASION ON THE VICTIM'S LEFT LEG WHICH WAS PHOTOGRAPHED. I OBTAINED A WRITTEN STATEMENT FROM THE VICTIM AND I ALSO OBTAINED A STATEMENT FROM THE VICTIM'S COWORKER, THE WITNESS. THE WITNESS STATED THAT HE ALSO HAD RESPONDED TO THE MOTOR VEHICLE CRASH AND WHEN HE AND THE VICTIM ARRIVED ON SCENE HE FOUND A WHITE MALE, IDENTIFIED AS THE DEFENDANT, SITTING IN THE VEHICLE WITH THE DOOR OPEN THAT HAD HIT A LARGE ROCK AND A TREE. THE WITNESS STATED THAT THEY APPROACHED THE VEHICLE TO TALK TO THE DRIVER WHO APPEARED UNCONSCIOUS AND WHEN THE VICTIM SHOOK THE SHOULDER OF THE DEFENDANT, THE DEFENDANT WOKE UP. AT THAT TIME, THE WITNESS AND THE VICTIM STARTED TO ASK QUESTIONS AS TO WHAT HAD HAPPENED AND NOTICED SEVERAL BEER CANS IN THE VEHICLE. THE WITNESS THEN STATED THAT THE DEFENDANT STARTED THE VEHICLE, PUT IT IN REVERSE AND SPUN THE TIRES BACKING UP HITTING THE VICTIM WITH THE OPEN DOOR KNOCKING HIM TO THE GROUND. THE VEHICLE THEN LEFT SOUTHBOUND ON SOUTH FLORIDA AVENUE. BOTH STATEMENTS WILL BE TURNED IN TO RECORDS. THE DEFENDANT WAS INFORMED HE WAS BEING PLACED UNDER ARREST AND CHARGED WITH ONE COUNT OF AGGRAVATED BATTERY WITH A DEADLY WEAPON TO EMS PERSONNEL. WHILE ON SCENE WAITING FOR THE FLORIDA HIGHWAY PATROL (FHP) TO FINISH THEIR CRASH INVESTIGATION, I HAD DISPATCH CONTACT THE REGISTERED OWNER OF THE VEHICLE, THE DEFENDANT'S FATHER, AND MAKE ARRANGEMENTS TO HAVE THE VEHICLE PICKED UP IN LIEU OF HAVING THE VEHICLE TOWED. THE VEHICLE DOORS WERE LOCKED AND THE WINDOWS WERE ROLLED UP PRIOR TO MY DEPARTURE. THE KEYS TO THE VEHICLE WERE TURNED IN TO THE BOOKING DESK AT THE DETENTION FACILITY WITH THE DEFENDANT'S OTHER PROPERTY. THE DEFENDANT WAS LATER TRANSPORTED TO THE CITRUS COUNTY DETENTION FACILITY WHERE HE WAS TURNED OVER TO THEIR STAFF. THE DEFENDANT WAS ISSUED UNIFORM TRAFFIC CITATION, 7471 FRY, FOR OPEN CONTAINER. "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* |
