I. OVERVIEW

Respondent SHANE CHRISTOPHER BROWN, pro se, pursuant to Florida Family Law Rule of Procedure 12.280 and the Court's Pre-Trial Order dated January 16, 2026, hereby files this Master Exhibit List identifying all exhibits Respondent intends to introduce at the evidentiary hearing scheduled for April 2, 2026 at 1:30 PM.

All exhibits are organized into a two-tier system:

• Primary Exhibits (A–B): Two comprehensive reference documents - a verified case timeline and a visual case presentation - that synthesize and cross-reference all evidence exhibits below.
• Evidence Exhibits (C–J-4): Forty-eight (48) individual exhibits organized into eight (8) chronological groups spanning 2015 through 2026, each containing the source documents, court orders, sworn testimony, attorney correspondence, and physical evidence underlying the case.

Convention: Per Florida family law practice, Respondent's exhibits use letter designations. Petitioner's exhibits use numbers.

II. PRIMARY EXHIBITS

III. EVIDENCE EXHIBITS - TABLE OF CONTENTS

GROUP C - Family Bond & Case Background (Pre-Case)

Establishes father-child bond, judicial background, and the adoption campaign predating the case.

GROUP D - Case Inception & Early Filings (December 2023 – August 2024)

Separation begins. Adoption-for-support quid pro quo documented. Father enters case, files Answer.

GROUP E - Father's Compliance & Procedural Denials (September – December 2024)

Father completes parenting course 36 days early. Attorney claims ignorance. "Not even the father." GAL/psych denied. Attorney leaves firm.

GROUP F - February 2025 Order & Federal Response (January – March 2025)

Contempt filed with wrong email. False finding issued. Father files federal §1983 naming judge as defendant.

GROUP G - Contempt Ruling & Continued Enforcement (April – June 2025)

Father sends good faith letter. Judge REFUSES contempt order. Court finds NO willful noncompliance. Enforcement continues.

GROUP H - Hearings, Evidentiary Record & Attorney Correspondence (July – November 2025)

Judge named federal defendant. "Completely unresponsive" contradicted by 12 documented attempts. 12 of 14 exhibit tabs switched without disclosure. Mother's 6 sworn admissions.

GROUP I - 730-Day Written Acknowledgment & Current Proceedings (December 2025 – Present)

Father's zero-condition email. Kantaras admits 730 days in writing. All court-denied conditions reinstated. Orders set for April 2 hearing.

GROUP J - Reference & Supporting Materials

Federal ruling, supporting motions, Father's proposed resolution.

IV. CRITICAL FINDINGS CROSS-REFERENCE

V. THE CASE IN ONE PAGE

The Children: B.M.B. (age 11) and B.R.B. (age 7).

The Separation: 847+ days without contact - no court order, no best-interest findings, no fitness adjudication.

The Pattern: Father complied with every requirement. Mother conditioned access on stepparent adoption consent (5 times, in writing). Court issued a factually false finding. Court exonerated Father, then continued enforcement. Opposing counsel admitted 730 days in writing.

The Constitutional Triad: Treated as a non-father for contact. Treated as a father for enforcement. Given the due process of neither.

The Ask: Written findings. Immediate contact. The rights that existed before this case was filed.

The Law: Florida § 61.13(2)(c) mandates written best-interest findings on 20 statutory factors before any modification of time-sharing. After 847 days of complete separation, zero of these 20 factors have been addressed in any written order. The statutory obligation is mandatory, not discretionary.

VI. RESERVATION OF RIGHTS

Respondent reserves the right to:

1. Supplement this Exhibit List upon discovery of additional relevant evidence;
2. Introduce any exhibit identified on any other party's exhibit list;
3. Introduce rebuttal exhibits as necessitated by testimony or evidence at the hearing;
4. Object to exhibits offered by any other party on any ground permitted by the Florida Evidence Code;
5. Convert all exhibits currently in screenshot, HEIC, or image-only format to PDF prior to the hearing date.

CERTIFICATION

I HEREBY CERTIFY that a true and correct copy of this Respondent's Master 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,

Filed in compliance with the Pre-Trial Order dated January 16, 2026
Case No. 23-009419-FD-14 | Sixth Judicial Circuit | Pinellas County, Florida
Pre-Trial Memorandum Due: March 19, 2026 at 5:00 PM
Evidentiary Hearing: April 2, 2026 at 1:30 PM | Courtroom 421, 315 Court Street, Clearwater, FL 33756