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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 A WRITTEN OPINION

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]. He also asks this Court to author a written opinion (perhaps, as an alternative to certification). 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 a PCA without opinion

Problem:	The Supreme Court cannot review such decisions

Request:	The Court writes an opinion for the greater good

9.030(a)(2) | Fla R. App. P. | Discretionary Jurisdiction

“The discretionary jurisdiction of the supreme court may be sought to review:...”

9.330 | Fla R. App. P. | Written Opinion

“...A motion for written opinion shall set forth the reasons that the party believes that a written opinion would provide:

a legitimate basis for supreme court review; [or]

an explanation for an apparent deviation from prior precedent; ...”

9.330 | Fla R. App. P. | Committee Notes

“...Subdivision (a)(2)(D)(iii) is intended to address situations in which a specific district court of appeal has exclusive subject matter jurisdiction over a type of case...”

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 the importance of a written opinion.

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.

Written Opinion

This Court may issue a written opinion to permit Appellant to invoke the discretionary jurisdiction of Florida’s Supreme Court (pursuant to Rule 9.030(a)(2) Fla. R. App. P.).

[argV01]

“[quoteV01]”

[argV02]

CONCLUSION

WHEREFORE, based upon the foregoing, Appellant respectfully asks this Honorable Court for to issue a written opinion 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/IssueOpinion.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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