Pro Se Respondent
Burja v. Brown - Case No. 23-009419-FD-14
Sixth Judicial Circuit | Pinellas County, Florida
Filed: March 19, 2026 - Day 847 of Parent-Child Separation
Section I
Six filing documents prepared for the evidentiary hearing
Exhibit Package & Exhibit List
Official pre-trial notice identifying all 50 exhibits Respondent intends to introduce at the April 2, 2026 evidentiary hearing. Filed pursuant to the Court's Pre-Trial Order (Exhibit I-5).
Respondent's Master Exhibit TOC
Court-ready index of all 50 exhibits organized into 8 chronological groups with key evidentiary findings cross-reference.
Master Exhibit Record
Comprehensive descriptions and significance of each exhibit across 7 chronological phases with 5 critical evidentiary findings.
Verified Case Timeline
Day-by-day chronological record of all material events from November 2023 through March 2026. Ten sections, color-coded by event type.
Visual Case Presentation
29-slide court-ready visual summary covering 847 days, 6 critical findings, constitutional analysis, and 11-item relief request.
Google Drive Folder
All 48 evidence exhibits organized into 8 chronological groups (Groups C through J-4) - court orders, transcripts, correspondence, compliance records, photographs, and text messages.
Section II
Burja v. Brown at a glance
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, zero of 20 factors have been addressed in any written order.
Section III
Material contradictions documented in the record
CF-1
Retainer signed Nov 22 → fake meetup Feb 2024 → Mother claims "couldn't reach him" at hearing → destroyed by months of her own texts.
CF-2
Parenting certificate filed on docket 49 days prior to order stating it "does not appear."
CF-3
Court found no willful noncompliance and no ability to pay - enforcement nonetheless continued.
CF-4
12 of 14 exhibit binder tabs changed between consecutive hearings without disclosure on the record.
CF-5
Six admissions under oath - withholding, negative statements, DV by stepfather, 5 adoption attempts - zero written findings on any.
CF-6
Opposing counsel's own correspondence acknowledges 730 days without meaningful contact - absent any court order.