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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	6th Page
Exhibits	8th Page

Background:	The Court entered an appellate decision

Problem:	The underlying issue will have a wide-ranging effect

Alternative A:	The Court certifies questions of great public importance

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 the underlying issue is of great public importance.

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 Per Curiam Affirmation without opinion (hereinafter “The Decision”); ruling against Appellant.

Pertinent Facts Regarding ‘Great Public Importance’

[dataParagraph01]

[dataParagraph02]

Certification | Great Public Importance

Based on the facts (see ¶5-6 supra), the issue that Appellate presented has far-reaching consequences.

In 1986, Florida’s Second DCA certified its decision to the Supreme Court; noting the likelihood that the issue would arise in “other similar circumstances in the future” (see Hillsborough Avia. Auth. v Hillsborough Cty GEA, 482 So. 2d 505). Thereafter, the Supreme Court accepted jurisdiction and quashed the conflicting portions.

More recently, in Gibbs v State, 676 So. 2d 1001, 1006 (Fla. 4th DCA 1996), the Fourth DCA certified a question of great public import because the issue affected numerous prosecutions across the state (also see Cf. Young v State, 678 So. 2d 427, 429 (Fla. 4th DCA 1996)).

[argIV01]

[argIV02]

So, based on The Decision’s wide-ranging effects, Appellant asks this Court to certify to the Florida Supreme Court the following questions of great public importance:

“1. [questIV01]?”

“2. [questIV02]?”

“3. [questIV03]?”

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

Get Booked Up on Justice!

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-GPI.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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