back



APPENDIX B - MANDI NEVER HAD AN OPPORTUNITY FOR AN APPEAL

Mandi's Judge Jessica Recksiedler, made numerous reviewable errors which affected the outcome of the trial. They had to affect the outcome of the trial, because the biggest error was not just acquitting Mandi after the prosecution made their presentation. I believe Recksiedler thought the jury would acquit Mandi, and save Recksiedler the political trouble. Many people were then surprised when the jury found Mandi guilty, as I have detailed elsewhere.

The error the lawyers had most confidence in, was Detective Sprague's claim, on the stand, that Mandi refused to give over her cellphone password. In fact this was just a bizarre scheme where the court tried to compel Mandi to unlock her phone after she asked to speak to her attorney, which a higher court found to be ridiculous. But it made the jury think Mandi was hiding something. And it corroborated the story a jailhouse witness told that Mandi received incriminating texts, when everyone in the court but the jury knew the jailhouse witness was a scam. It was not even clear Mandi knew the password, or hadn't forgotten it six months later when they did the bizarre motion to compel, or there was even anything on the phone.

Judge Recksiedler also blocked and allowed a lot of evidence and cross examination based on her own preconceptions of fact, and of what was a fair narrative to present the jury. Judge Recksiedler disallowed evidence such as photographs of marijuana, with a direct role in supporting or discrediting the prosecution and defense narratives.

Judge Recksiedler denied Mandi the full opportunity to confront the witnesses against her, and to bring out facts and photographs and arguments in front of the jury. At the same time, the judge allowed the prosecution anything that fit even the silliest narrative they could come up with.

Rather than allowing the defense to impeach the credibility of the jailhouse witnesses, and compare their credibility to other witnesses, Recksiedler allowed the prosecution to improperly bolster them as the most credible witnesses in the trial, who could get life in prison if they ever told a lie. It is plainly false, and against the spirit of the Florida Supreme Court's latest opinion on jailhouse witnesses.

There was also a motion for a mistrial, and a lot of weird stuff during jury selection, and in the creation of the jury instructions, even in the closing arguments. But I don't believe the appeals court ever knew about any of that, or even looked at Mandi's transcript.

Mandi's appeal was denied without the appeals court ever looking at her case, or even being asked to look at her case or given a chance to look at her case.

--------------------------

Mandi's appeal was first given to Teresa Sutton, in the taxpayer appeals office in Daytona Beach. Teresa writes appeals all day, and actually tries to write a fair appeal. She writes a custom appeal for each case, using the facts and case law specific to each case. It is certainly not the best possible appeal, but is is an actual appeal written by a person who takes appeals seriously. Teresa had to withdraw from the case, based on the importance of the cellphone motion. Teresa would have had to argue it was probably Scott Love's cellphone. But Scott Love was already her client, because Teresa had already written his appeal.

Next, Mandi's appeal was turned over to Lori Loftis in Seminole County, the standard fallback lawyer in case of conflicts. Lori dropped the case, saying she had some conflict.

Next Mandi's appeal was given to "registry attorney" Hubert Kyle Fletcher. Registry attorneys are private attorneys on a list, who represent indigent clients for the state.

When I saw they had assigned Mandi's case to H. Kyle Fletcher, I called him to make sure he was aware of the judicial errors. And to suggest he should get a transcript of jury selection, before Seminole County lost the tapes.

When Fletcher answered the phone he did not know he had been assigned Mandi's case. I told him her name was Mandi Jackson. He said "Hold on, I am looking for the case it is a long list."

I said "There are a lot of Jacksons on the court website, so you should also type m-a-n-d."

Fletcher said "Yeah, and a lot of Washingtons and Williamses and Johnsons. And Garcias and Ramirezes."

Fletcher said "Oh, is this the case where the guy got thrown off a balcony? Her lawyer Carrie Rentz talked to me about this case. Why didn't she take a deal?"

I said nobody got thrown off a balcony, and no witness said anybody got thrown off a balcony. And then Kyle Fletcher remembered even faster than I did, why Mandi didn't take a deal: Because Fletcher's own client, Maletta Young, took a deal to testify lies against Mandi, when Fletcher was Maletta Young's lawyer. That prevented them from offering Mandi a deal, even though Maletta later backed out.

Fletcher asked me "Wait, which jailhouse witnesses testified in this case?"

I assumed Fletcher had a worse conflict than either Sutton or Loftis, having made a deal for his own client who was still in prison, to testify lies against Mandi. I assumed Fletcher would withdraw. Imagine my surprise when, not long after, I saw Fletcher submitted some garbage brief with none of the actual facts or judicial errors of Mandi's trial, just so he could collect his fee.

After looking at Hubert Kyle Fletcher's picture, and hearing his disdain for Washingtons and Johnsons, I had a memory. On June 28, 2017 when I went to the prosecutor's office to get Mandi's discovery, there was an angry loud old white guy there, an attorney. He was bitching to anyone who would listen, how his client was guilty. He was saying how his client was like a stereotypical awful scary black guy, like seven feet tall with gold teeth and an afro or something. And the old white guy was saying how he hoped he could withdraw from the case and get replaced, because he was afraid to sit alone in a room with his client, for fear of getting murdered himself.

H. Kyle Fletcher spent perhaps 15 minutes copy-pasting part of Scott's appeal written by Teresa Sutton, that did not even mention the actual facts or judicial errors in Mandi's case. Mandi's trial was a totally different crime and evidence from Scott's trial. Fletcher submitted a quick brief with statements that were not even true about Mandi's case, and did not even bother to change the name from Scott Love to Mandi Jackson in most places:

H. Kyle Fletcher's so-called brief


I immediately sent a letter saying Fletcher should withdraw this invalid document and withdraw from the case, before the appeals court rejected Mandi's appeal, based on nobody having even tried to write an appeal. Of course Fletcher neither responded nor withdrew, and collected his fee for copy-pasting a few inaccurate pages, and throwing away a girl's life like a gum wrapper.

Fletcher withdraw from case

Fri, May 29, 2020 at 11:55 AM

Kyle Fletcher submitted a brief which was not relevant to Mandi Jackson's case, because it was simply copied from Scott Love's case without even changing the name from Scott Love to Mandi Jackson in most places. It certainly did not include any work to address the actual judicial errors in Mandi's case.

This brief appears to represent less than 10 minutes work in a six-day first degree murder trial.

If Kyle Fletcher does not withdraw this sad brief, and withdraw from the case, I am complaining to The Bar that Kyle Fletcher is not qualifiied to be a registry attorney or any attorney. Kyle Fletcher represented Maletta Young whose interests may, under some arguments and outcomes, be adverse to the interests of this appellant.

Fri, May 29, 2020 at 2:09 PM

I haven't gotten any indication yet that you have used the portal to withdraw this brief and withdraw from this case. So without knowing the rules of your profession, I have to at least offer my opinion that this is not even a valid brief.

Just as an example, on page 3 of your brief you make the following statement:

***************
The first neighbor remembered that he was woken up around 6:30 a.m. by "yelling and banging and moving around in the apartment right above me, including furniture being moved on the balcony." (T100-118).
***************

In fact, this quote comes from day 2, transcript 95, pdf 1-50, of Scott Love's trial the previous year, as attached.

Nowhere in pages 100 to 118 of Mandi Jackson's trial, does anyone mention "banging." So you have signed and submitted a false statement to the Fifth District Court of Appeals. Knowingly, given that you had no basis to assume that quote actually occurred in Mandi's transcript.

Just another grain in the mountain of your violation of the requirements of your profession, you stated on page 23 of your brief:

***************************
There was no evidence presented by the State that contradicts or is inconsistent with Appellants theory of the case that the victim consented to Mr. Love coming into the apartment, the gun belonged to the victim, the victim was the aggressor, and the credit card was found after leaving the apartment. ***************************

For recklessly and intentionally misrepresenting the appellants theory of the case at trial to the panel, you should be disbarred.

When are you going to withdraw your brief and withdraw from this case?


I tried to warn Mandi about this, but she was too retarded. I asked her over and over if she had heard anything about her appeal, or if she knew any justification or reason why this brief wasn't the end of her life. I told her Hubert Kyle Fletcher threw her life away like a gum wrapper. She was too dumb to respond. Or when she did respond, it was just some nonsense about jail commissary and lesbians and shampoo and getting beat up and molested in prison. For months many of my mails and emails were blocked, and I could not get through to Mandi at all.

Mandi spent most of the summer in quarantine, or in confinement for her own protection against getting beat up by other prisoners or guards. And most of my emails to her about court documents, and about her appeal, were blocked for some unknown reason.

Finally in November 2020, more than a year after her trial, she figured out she was supposed to have an appeal or something and hadn't. But the prison library was still closed from the virus. And she couldn't get help from the "law clerk" girls in prison. Because the State of Florida will literally let any dangerous felon out of prison, who finds out the basic facts of Mandi's case, invents the rest, and claims Mandi confessed to it.

So I helped Mandi with some motions to remove Kyle Fletcher from the case, and ask for more time to write an actual brief. But even then they got blocked in the mail. And even when she got them, she was still in confinement, had no idea what she was doing, and had to rely on another girl in another prison to mail her stamps, which she could not get on her own for some reason. Mandi did not even have a tablet to send and receive email.

Motions to remove Hubert Kyle Fletcher, get a transcript of jury selection, and get time to submit a real appeal brief

COMES NOW the undersigned Appellant, Mandi May Jackson, and moves this Court to remove Counsel H. Kyle Fletcher from this case, and as grounds states:

1. The undersigned has a right "to have the Assistance of Counsel" in matters pertaining to judicial errors in the trial by jury in this case, pursuant to the Sixth Amendment to the United States Constitution.

2. While Attorney H. Kyle Fletcher has submitted documents, he has failed to provide relevant or material assistance in this case.

3. H. Kyle Fletcher submitted a brief which appears to have simply been copied from Scott Love's case without even changing the name from Scott Love to Appellant Mandi May Jackson in most places, as seen in attached Exhibit A.

4. H. Kyle Fletcher submitted a brief which was not relevant to Appellant's case; It does not include any work to address the numerous, actual, and specific judicial errors in Appellant's case, such as rulings on motions in limine for specific evidence, and disallowed testimony. The submitted brief appears to represent less than 20 minutes work for a six-day first-degree murder trial.

5. As one of many examples, on page 3 of this brief H. Kyle Fletcher made the following statement:

The first neighbor remembered that he was woken up around 6:30 a.m. by "yelling and banging and moving around in the apartment right above me, including furniture being moved on the balcony." (T100- 118).

In fact, this quote comes from day 2, transcript 95, pdf 1-50, of Scott Love's trial the previous year, as attached in Exhibit B. Nowhere in pages 100 to 118 of Appellant's trial, does anyone mention "banging." So H. Kyle Fletcher signed and submitted a false statement to the Court, and did so knowingly, given that he had no basis to assume that quote actually occurred in Appellant's transcript.

6. As another of many examples, on page 23 of this brief H. Kyle Fletcher states:

There was no evidence presented by the State that contradicts or is inconsistent with Appellants theory of the case that the victim consented to Mr. Love coming into the apartment, the gun belonged to the victim, the victim was the aggressor, and the credit card was found after leaving the apartment.

As seen on page 1458 line 16 of Appellant's trial transcript in attached Exhibit C, Counsel argued "Scott comes in and sees Mandi with Mr. Mulrenin. Scott pulls Mandi from him, puts a gun to her head." H. Kyle Fletcher recklessly and intentionally misrepresented the appellants theory of the case at trial to the panel.

7. H. Kyle Fletcher represented Maletta Young in Seminole County 2018 CF 451B where she made a deal to swear lies against Appellant as show in attached Exhibit D and Exhibit E. H. Kyle Fletcher is still Maletta Young's attorney of record according to the Seminole County online docket as shown in Exhibit F. Maletta Young is a potential witness in this case who was subpoenaed by the defense to testify for the defense at Appellant's trial.

WHEREFORE, the undersigned Appellant Mandi May Jackson respectfully requests the Court remove Counsel H. Kyle Fletcher from this case.

Respectfully submitted,

Mandi May Jackson, G90650


Finally in January of 2021, Mandi mailed the motions to ask the judge to remove Fletcher and give her time to write an actual brief. But she did not notify the other parties with copies of the motions, as required by the rules of procedure. Because it was just too much, being unable to even get stamps except through the mail from another girl in prison. So the judge struck the motions, and gave her 15 days to try again.

Of course a person in confinement in prison cannot accomplish anything in 15 days. I kept trying to ask her about the motions, but they blocked or delayed my emails to her, or blocked or delayed her emails to me, it is impossible to tell. And as hard as I have always tried to get help from Mandi keeping track of which emails we have each sent and not received, by numbering each email or something like that, Mandi is too mentally disorganized for any plan like that. And she just wants to talk about shampoo.

So finally I helped her with some new motions to notify the other parties with, but they got sent back. And by the time I figured that out and sent Mandi what she needed, the court had denied her appeal without even offering an opinion. Presumably because there was never any appeal written for them to even respond to.



So I immediately sent the following emails, and that is what became of Mandi's chance to appeal a conviction based on lies and nonsense.

no appeal

2/23/2021 9:51 AM

Mandi lost her appeal, without anybody ever even writing an appeal for her. There were numerous legitimate errors by the judge which affected the outcome. Not to mention, the failure by the judge to acquit was itself an error, because the case was not proved.

I started telling Mandi almost a year ago, that her lawyer didn't write her an appeal. And if she didn't do something, she would lose her appeal. But between her being retarded and not wanting to talk to me, her being quarantined, her being confined for her own protection from guards and other inmates, and them blocking my electronic and hard mail to her, she was never able to file a simple motion to ask the judge for more time so she could write an actual appeal. And also because she was not able to get help from the "law clerk" girls in prison. Because the State will literally let any dangerous felon out of prison, who finds out some details about Mandi's case, invents the rest, and claims Mandi confessed.

She filed the motion in January, but the judge struck it because it did not notify the other lawyers, which is hard for her to do from confinement. She was unable to ask again because she is retarded, she was in confinement, and they blocked my mail to her. And so before she could correct her request to ask for time to actually write an appeal, they just denied her appeal without even writing an opinion why. Probably because there was nothing for them to even respond to.

This despite the judge made known, clear errors, defined as errors by other courts. And the jury and judge still erred, because the case was not actually proved.

sick sick seminole county

Tue, Feb 23, 2021 at 10:05 AM

Only in sick sick Seminole County does a 21-year-old girl, facing life without parole after every single witness lied, lose her appeal without anyone ever even writing her an appeal:

http://onlinedocketsdca.flcourts.org/DCAResults/LTCases?CaseNumber=3411&CaseYear=2019&Court=5

There were multiple legitimate judicial errors, including denying Mandi's right to present to the jury, allowing and blocking evidence based on the judge's preconception of facts, bolstering witnesses with lies, biasing the jury outside testimony, and using some bizarre compelled cellphone thing. And the failure to acquit was itself an error, based on the case not having been proved. And a very strong argument could have been made for that.

But the judges denied her appeal without even writing an opinion. Probably because there was nothing to respond to. Nobody ever gave the judges any document that contained any true facts about her trial, nobody spent more than 15 minutes.

And most of my efforts to help her were blocked by her being confined for her own protection, being quarantined, by them blocking my hard and electronic mail... And by Mandi being unable to ask the "law clerk" girls in prison for help. Because the State will literally let any dangerous felon out of prison who finds out the basic facts of Mandi's case, invents the rest, and claims she confessed to it.

Sick sick people you all are, totally subhuman. The Florida Bar is a disgrace.

Tue, Feb 23, 2021 at 10:54 AM

H. Kyle Fletcher, you threw away this girl's life like a gum wrapper for a few thousand dollars.



back