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STATE OF FLORIDA

[dca] DISTRICT COURT OF APPEALS

[plfName]	)
Appellate	)
)	Case No.: [caseNo]
v.	)	LT No. (FCHR): [caseNoF]
)	LT No. (DOAH): [daseNoD]
[defName]	)
Appellee	)

APPELLANT’S MOTION FOR CERTIFICATION

Appellant, [plfName], on this [d] day of [MMM] [YYYY], respectfully moves this Honorable Court to certify - for Supreme Court consideration - the decision it rendered on [MMMrndr] [Drndr], [YYYYrndr]. Appellant proffers the following in good faith, and only on the grounds permitted by Rule 9.330 Fla. R. App. P..

Key Points:

Grounds	Direct Conflict with authoritative law

No Argument	This motion does not re-argue the merits

Precedence	Florida DCAs have granted similar motions

Table of Contents:

Context	2nd Page
Motion	3rd Page
Certificates	5th Page
Exhibits	7th Page

Background:	The Court entered an appellate decision

Problem:	The decision conflicted with authoritative precedent

Request:	A certification that the decision conflicted with precedent

9.330 | Fla R. App. P. | Certification

“...A motion for certification shall set forth the case(s) that expressly and directly conflicts with the order or decision...”

Stetson Law Review | Motion Practice in Florida Appellate Courts

“[Rule 9.330] does not require the moving party to state the ground for certification with particularity... but it is advisable to present a complete statement of the reasons for [the request]”

Precedence

Case No. 1D10-3881	- Florida 1DCA (6/24/11)

Case No. 4D06-2992	- Florida 4DCA (10/24/07)

Case No. 5D09-0088	- Florida 5DCA (12/13/10)

Florida Appellate courts have granted similar motions

Abbreviations

DCA	District Court of Appeal
LT	Lower Tribunal

MOTION

Preface

Appellant will not re-argue his points on appeal. Nor will he present any argument that was not previously proffered. Rather, Appellant's motion merely points out that this Court’s decision conflicts with authoritative precedence.

Brief Recitation of Points & Authorities

On [MMMinit] [Dinit], [YYYYinit], Appellant filed his briefs.

Therein, he cited the binding precedent of a controlling case (see ¶[##] of [brief]). That case is titled [caseCitation]. As detailed in the pleading, Appellant’s case was identical to [caseCitShrt] in all material respects (ie, [issOnApp]).

Nevertheless, on [MMMrndr] [Drndr], [YYYYrndr], this Court entered a final decision (“The Decision”); ruling against Appellant.

Certification | Direct Conflict

Based on the facts, Appellant concludes that The Decision directly conflicts with [caseCitShrt].

He believes that this Court should express this in a certification to the Florida Supreme Court (pursuant to Rule 9.330(C) Fla. R. App. P.).

[argIII01]

“[quoteIII01]”

[argIII02]

[argIII03]

As such, this Court should grant certification.

CONCLUSION

WHEREFORE, based upon the foregoing, Appellant respectfully asks this Honorable Court for an order granting certification pursuant to Rule 9.330(a) Fla. R. App. P..

Dated this [d] day of [MMM] [YYYY].

Respectfully submitted,

/s/ [plfName]

[plfName], Plaintiff

[plfAddy]

P: [plfPhn]

E: [plfEml]

W: TextBookDiscrimination.com

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CERTIFICATE OF COMPLIANCE

I certify that the size and style of type used in this document is Times New Roman 14-point Font (caption) and Courier New 12-point Font (contents); thus complying with the font requirements of Rule 9.210(a)(2) Fla. R. App. P.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this [D] day of [MMM] [YYYY], I electronically filed the foregoing with the Clerk of Courts by using its online filing page. I also emailed it to the attached service list.

/s/ [plfName]

Endnotes:

How-To Guide: (interactive)

TextBookDiscrimination.com/Guides/Motions/Certification-CDC.html

SERVICE LIST

[defAtt], Esquire ([barNum]) E: [defEml] P: [defPhn] (appellee’s counsel)
[clrkNm], Agency Clerk [clrkEml]@fchr.myflorida.com Florida Commission on Human Relations Room 110 4075 Esplanade Way Tallahassee, Florida 32399-7020 (agency)

EXHIBIT A

[dsrptnA]

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