KELLY R. BURJA,
Petitioner/Mother,
v.
SHANE CHRISTOPHER BROWN,
Respondent/Father (Pro Se).
___________________________________________/
Case No.: 23-009419-FD-14
The Honorable Frederick L. Pollack,
Presiding
Respondent’s Notice of Filing
Exhibit Package and Exhibit List
Case No. 23-009419-FD-14 •
Filed: March 19, 2026 •
Pre-Trial Filing
I. Notice
Respondent SHANE CHRISTOPHER BROWN, pro se, pursuant to Florida Rule of Civil Procedure 1.080, Florida Family Law Rule of Procedure 12.280, and the Court’s Pre-Trial Order dated January 16, 2026 (Exhibit I-5), hereby gives notice of filing this Exhibit Package and Exhibit List in connection with the Evidentiary Hearing scheduled for April 2, 2026 at 1:30 p.m., Courtroom 421, 315 Court Street, Clearwater, Florida 33756.
This Notice identifies all exhibits Respondent intends to introduce or rely upon at the April 2, 2026 hearing. It is filed as a pre-trial exhibit disclosure pursuant to the Court’s Pre-Trial Order (Exhibit I-5, ¶ 7(F)), and to establish a single, organized evidentiary reference on the Court’s docket.
Incorporation by Reference. All motions, memoranda,
and other documents subsequently filed by Respondent in connection with the April 2,
2026 hearing may incorporate this Notice by reference, identifying exhibits by
their designated letter, in lieu of re-attaching individual exhibits to each
filing. The phrase “as identified in Respondent’s Notice of Filing
Exhibit Package filed March 19, 2026” shall constitute sufficient
identification of any exhibit listed herein.
II. Description of Exhibit Package
The exhibit package is organized into a two-tier system:
Primary Exhibits (A–B). Two comprehensive reference
documents, a verified case timeline (Exhibit A) and a visual case presentation
(Exhibit B), each of which synthesizes and cross-references the underlying
evidence exhibits listed in Section IV below.
Evidence Exhibits (C–J-4). Forty-eight (48) individual
exhibits organized into eight (8) chronological groups spanning the period 2015 through
2026, consisting of court orders, conformed orders, sworn filings, attorney
correspondence, hearing transcripts, compliance certificates, photographs, and text
message records.
Exhibit Convention. Per Florida family law practice,
Respondent’s exhibits use letter designations. Petitioner’s exhibits use
numbers.
Digital Location. The complete exhibit package is organized
and accessible at the Google Drive location below, maintained by Respondent and
available for inspection by all parties and the Court:
https://drive.google.com/drive/u/0/folders/1UHkqxMRkLdySVU-qT18YRNhokJhiEg8C
(Organized by exhibit folder, A through J-4; each folder contains the documents identified in Section IV below.)
Exhibit A (Verified Case Timeline) and Exhibit B (Visual Case Presentation) are each
filed simultaneously herewith as companion exhibits to this Notice.
III. Primary Exhibits
Respondent files the following two primary exhibits as comprehensive
reference documents for the April 2, 2026 evidentiary hearing:
Exhibit A - Verified Case Timeline
Format:
PDF (approximately 15 pages).
Description:
Chronological record of all material events from
2015 through April 2026. Ten sections: Family Background; 2023 Case Inception;
2024 Compliance and Hearings; 2025 Court Orders and Federal Action; 2026 Current
Proceedings; Day Count Verification Table (28 key dates); Six Evidentiary Findings;
Five Stepparent Adoption Proceedings; Correspondence Record. Every entry is
sourced from court orders, filed documents, sworn testimony, or verified primary
evidence.
Exhibit B - Visual Case Presentation
Format:
PDF (25 slides).
Description:
Court-ready visual summary of the case. Covers the
chronology of proceedings, the evidentiary record, applicable Florida statutes,
constitutional framework, and Respondent’s requested relief. Every data point
is sourced from the evidence exhibits identified in Section IV below.
IV. Evidence Exhibits - Complete List
The following forty-eight (48) exhibits are organized in eight (8) chronological
groups. Each exhibit is identified by its letter designation, descriptive title, date,
and format.
Group C - Family Background and Pre-Case Records
Records from the period prior to the commencement of
this action, including family background documents, sworn affidavits, and records of
stepparent adoption proceedings.
Exhibit C:
Father’s Day Book - B.M.B.’s Own Words (Pre-Separation)
[PDF]
Exhibit C-1:
UCCJEA Affidavit - Sworn Under Perjury Warning (May 16, 2024)
[PDF + 6 docs]
Exhibit C-2:
5th Joint Petition for Adoption by Stepparent (May 16, 2024)
[PDF]
Exhibit C-3:
Paternity Acknowledgment Motion (2025)
[PDF]
Exhibit C-4:
Judge Pollack Biography - Stann Givens American Family Law Inn of Court (2018)
[DOCX / PNG]
Exhibit C-5:
Online Publication Screenshot - Inn of Court Reference
[PNG]
Group D - Case Inception and Early Filings
(December 2023 – August 2024)
Filings, correspondence, and text message records from
the initial period of the action through Respondent’s entry into the case.
Exhibit D:
Stepfather Text Messages (December 2023)
[JPG]
Exhibit D-1:
Attorney Correspondence - May 17, 2024 Letter from K. Dean Kantaras, P.A.
[PDF]
Exhibit D-2:
Good Faith Letter - Response to Motion to Compel (July 23, 2024)
[PDF]
Exhibit D-3:
Petitioner’s Motion to Compel (July 31, 2024)
[PDF]
Exhibit D-4:
Respondent’s Answer to Petition (August 9, 2024)
[PDF]
Group E - Compliance Records and Court Orders
(September – December 2024)
Compliance certificates, attorney correspondence,
motions, and court orders from September through December 2024.
Exhibit E:
Certificate of Parenting Course Completion - Certificate ID: sb1jxxg3nb
(September 9, 2024) [JPG]
Exhibit E-1:
Attorney Correspondence - October 1, 2024 Letter from K. Dean Kantaras, P.A.
[PDF]
Exhibit E-2:
Federal Court Filing (ECF) - Kantaras October 1 Letter, Pages 33–34
(October 1, 2024) [PNG]
Exhibit E-3:
Hearing Transcript - November 22, 2024
[Transcript - pending certified copy from Milestone Reporting]
Exhibit E-4:
Motion to Correct Procedural Record - Parenting Certificate
(Filed on Docket December 16, 2024) [10 PNGs]
Exhibit E-5:
Paralegal Email from K. Dean Kantaras, P.A. (December 27, 2024)
[JPG]
Exhibit E-6:
Conformed Order - Guardian Ad Litem and Psychological Evaluation
(December 31, 2024) [PDF (Conformed)]
Group F - Court Orders and Federal Filing
(January – March 2025)
Court orders, motions, and federal court filings from
January through March 2025.
Exhibit F:
Petitioner’s Motion for Contempt and Sanctions (January 28, 2025)
[PDF]
Exhibit F-1:
Order Handling Emergency Motion - February 3, 2025
[PDF]
Exhibit F-2:
Federal Civil Rights Complaint - Case No. 8:25-cv-00621 (M.D. Fla.)
(March 14, 2025) [5 PNGs]
Exhibit F-3:
Federal Exhibit List - ECF Doc. 1-1 (259 pages) (March 14, 2025)
[PDF]
Exhibit F-4:
Federal Phase 1 Exhibit Screenshots (March 14, 2025)
[PNG]
Exhibit F-5:
Federal Complaint Narrative (Pages 36–50+) (March 14, 2025)
[12 PNGs]
Group G - Correspondence and Court Orders
(April – June 2025)
Correspondence, proposed orders, conformed orders, and
court filings from April through June 2025.
Exhibit G:
Good Faith Letter - Pre-Mediation Correspondence from K. Dean Kantaras, P.A.
(April 2, 2025) [PDF]
Exhibit G-1:
Proposed Order for Contempt - Returned Unsigned by Court
(May 29, 2025) [PDF]
Exhibit G-2:
Conformed Order Granting-in-Part Motion for Enforcement
(June 2, 2025) [PDF (Conformed)]
Exhibit G-3:
Motion to Appoint Guardian Ad Litem - Second Filing
(June 4, 2025) [PDF]
Exhibit G-4:
Judicial Notice - Notice of Pending Federal Litigation Filed in State Court
(June 10, 2025) [2 PDFs]
Group H - Hearing Records, Exhibit Binders, and
Correspondence (July – November 2025)
Federal court filings, notices of hearing,
Petitioner’s exhibit binder submitted at the October 16, 2025 hearing
(designated “Wife’s” Exhibit List on its face), Petitioner’s
exhibit binder submitted at the November 24, 2025 hearing (designated
“Mother’s” Exhibit List on its face), related correspondence, and the
November 24, 2025 hearing transcript.
Exhibit H:
Federal Court Docket Entry (ECF Doc. 46) - Confirmation of Named Defendant
(August 2025) [PDF]
Exhibit H-1:
Notice of Hearing (September 10, 2025)
[PDF]
Exhibit H-2:
Federal Court Order - Order Staying Case (September 19, 2025)
[PDF]
Exhibit H-3:
Email Correspondence - K. Dean Kantaras, P.A. to Judicial Coordinator
(October 2, 2025) [PNG / JPG]
Exhibit H-4:
Petitioner’s “Wife’s” Exhibit List - October 16, 2025
Hearing (14 Tabs) [PNG]
Exhibit H-5:
Notice of Hearing (October 24, 2025)
[PDF]
Exhibit H-6:
Petitioner’s “Mother’s” Exhibit List -
November 24, 2025 Hearing (14 Tabs) [PNG]
Exhibit H-7:
Hearing Transcript - November 24, 2025
[Transcript - pending certified copy from Milestone Reporting]
Group I - Correspondence and Orders
(December 2025 – January 2026)
Correspondence between the parties and court orders
setting the pre-trial schedule and April 2, 2026 hearing.
Exhibit I:
Respondent’s Email to Opposing Counsel (December 17, 2025)
[PNG]
Exhibit I-1:
Correspondence from K. Dean Kantaras, P.A. (December 18, 2025)
[PDF / PNG]
Exhibit I-2:
Correspondence Screenshots - December 18, 2025 Response with
Access Conditions [PNG]
Exhibit I-3:
Conformed Order Setting Continued Evidentiary Hearing (January 14, 2026)
[PDF (Conformed)]
Exhibit I-4:
Respondent’s Email to Court (January 16, 2026)
[JPG]
Exhibit I-5:
Conformed Pre-Trial Order - Setting March 19 Deadline and April 2 Hearing
(January 16, 2026) [PDF (Conformed)]
Group J - Reference and Supporting Materials
Federal court orders, supporting motions, and
Respondent’s proposed parenting plan.
Exhibit J:
Federal Court Order - Ruling on Motion to Dismiss
[PDF]
Exhibit J-1:
Motion for Clarification (Condensed)
[PDF]
Exhibit J-2:
Respondent’s Official Exhibit List - Visual Timeline and
Text Message Record [PDF]
Exhibit J-3:
Respondent’s Proposed Parenting Plan - Graduated Contact Restoration
[PDF]
Exhibit J-4:
Federal Phase 2 Exhibit Screenshots (March 14, 2025)
[PNG]
V. Exhibit Count Summary
The exhibit package contains a total of fifty (50)
exhibits, comprising two (2) primary exhibits and forty-eight (48) evidence
exhibits, organized as follows:
- Primary Exhibits (A–B): 2 exhibits
- Group C - Family Background & Pre-Case Records:
6 exhibits (C through C-5)
- Group D - Case Inception (Dec 2023 – Aug 2024):
5 exhibits (D through D-4)
- Group E - Compliance Records (Sep – Dec 2024):
7 exhibits (E through E-6)
- Group F - Court Orders & Federal Filing (Jan – Mar 2025):
6 exhibits (F through F-5)
- Group G - Correspondence & Orders (Apr – Jun 2025):
5 exhibits (G through G-4)
- Group H - Hearing Records (Jul – Nov 2025):
8 exhibits (H through H-7)
- Group I - Correspondence & Orders (Dec 2025 – Jan 2026):
6 exhibits (I through I-5)
- Group J - Reference & Supporting Materials:
5 exhibits (J through J-4)
- Total: 50 exhibits (Exhibits A through J-4)
VI. Reservation of Rights
Respondent reserves the right to:
- Supplement this Exhibit List upon discovery of additional relevant evidence
prior to the April 2, 2026 hearing;
- Introduce any exhibit identified on any other party’s exhibit list;
- Introduce rebuttal exhibits as necessitated by testimony or evidence presented
at the hearing;
- Object to exhibits offered by any other party on any ground permitted by the
Florida Evidence Code, Chapter 90, Florida Statutes;
- Convert exhibits currently in screenshot, HEIC, or image format to PDF prior
to the hearing date; and
- Supplement Exhibits E-3 (Hearing Transcript - November 22, 2024) and
H-7 (Hearing Transcript - November 24, 2025) with certified transcripts
upon receipt from Milestone Reporting.
Certificate of Service
I HEREBY CERTIFY that a true and correct copy of the foregoing
Respondent’s Notice of Filing Exhibit Package and Exhibit List has been
furnished to all parties and counsel of record via the Florida Courts E-Filing
Portal and/or electronic mail to:
- K. Dean Kantaras, P.A.
- attorneys@kantaraslaw.com
- danielle@kantaraslaw.com
- gabrielle@kantaraslaw.com
on this 19th day of March, 2026.
Respectfully submitted,
SHANE CHRISTOPHER BROWN
Respondent, Pro Se
Telephone: (727) 939-7992
Email: sb@vizionprotocol.io