IN THE SUPREME COURT OF FLORIDA

CASE NO. SC 13-484

Lower tribunal No(s): 4D11-4722,DCVE 11-6269(59)

Nasra M. Arafat (pervious m.n. Ibrahim) Vs. Mohamed Jhalil

Appellant / Petitioner, Appellee / Respondent ,

Petitioner's Brief On Jurisdection With Appendixes

ON Discretionary ReviewFROM

The Fourth District Court OfAppeal

Petitioner / Pro Se

Nasra M. ArafatP.O.BOX 772177

Coral Springs Florida 33077

TABLE OF CONTENTSNAME PAGETABLE OF CITATION

TABLE OF CITATION

JURISDICTION STATEMNT AND STATEMENT OF THE CASE 'l

STATEMENT OF THE FACTS 2

SUMMARY OF ARGUMENT 11

ARGUMENT: 13

I- Trial court abused its discretion on the matter of law with identicaljustifiable facts for reasonable legal justice against imminent harm.

2- Appellate court erred to reverse trail court ruling when absence ofalternative record was due to trail court disrupted the due process andrequirements of law by preventing a witness to testify; which canestablish relevant record in the case.

3- lower courts on contrary to law provisions and power of justice towardsdomestic violence matter a against single divorce woman's safetybecause of absence of trail transcripts she can't afford.

CONCLUSION 13

CERTIFICATE OF SERVICE 14

CERTIFICATE OF COMPLIANCE 14

TABLE OF CITATIONSTATUTES: PAGE NO.

Florida Rules Of Civil Procedures:

Fla. Civ. R. P. 1.380 (b)(1) 91

Federal Rules Of Civil Procedures:

FRCP 26 (a)(1) 8

Florida State Statutes:

Fla. Civ. R. P. 1.380 (b)(1) 9

Fla. Stat. § 741.30 11

Fla. Stat. § 784.046 11

Fla. Stat. § 741. 046 11

Fla. Stat. § 784. 046 (7) 11

Fla. Stat. 741. 046(c) 12

Fla. Stat. 741.30 (b)&(7) 12

Fla. Stat. § 741.30 (1983) 12

Fla. Stat.§741.30 (9)(a), Fla. Stat (Spp. 1984) 12

Florida Appellate Rules Of Civil Procedures:

Fla. App. R. Civ. P. 9.120 (d) 1

Fla. App. R. Civ. P. rule 9.120(a) 1

Fla. App. R. Civ. P. 9.030(a)(2)(A) and (a)(2)(B)(I)&(ii) 1

Fla App. R. Civ. P. 9.210(a)(2) 14

Cases oflaw:

Henderson V Henderson, App. Dist. 905 So 2 nd 901 (2005) 10

11

Monacelli V Gonzalez App. 4 th Dist. 883 So. 2 nd 361 (2004) 10

office ofstate attorney V Parrotino, 628 So. 2d 1097, 1099 12(Fla. 1993). ;

Others:

AnnotatedReference Fla. Stat. Ann. 32A, (appeal and errors )

111

Jurisdiction Statement And Statement Of The Case

This petitioner's brief on jurisdiction filed under Fla. App. R. Civ. P. 9.120 (d).

The matter filed for DISCRETIONARY PROCEEDINGS TO REVIEW

DECISIONS OF DISTRICT COURTS OF APPEAL Fla. App. R. Civ. P. rule

9.120(a) and Fla. App. R. Civ. P. 9.030(a)(2)(A) and (a)(2)(B)(i)&(ii).

This brief to review appellant / petitioner, petition for injunction for

protection against repeat violence filed by petitioner / pro se Nasra M. Arafat's

(name changed on Oct. 08,2008 from Ibarhim to Last name Arafat). The petition

was denied by Trial Circuit Court Broward County 17* Circuit final order dated

Oct. 31,2011.Therefore appeal filed in 4th district which affirmed trial court ruling.

The injection was filed against respondent's Mohamed Jahlil who

repeatedly harassed, abuse petitioner in the past three years till his recent threat to

kill petitioner. Petitioner has no any relationship with him or she ever talk to him

as he working as custodial in the Islamic Center Community at Sunrise Florida

33551which petitioner attending since 1996 before divorce and after divorce

occurred on Oct. 22,1997.

Respondent's threat to kill and to cause bodily harm repeatedly considered

crimes under state law while his acts showed enough violation of the law. His

threat has no logical reason other than his pervious communication reflected his

attemptation and intention to cause harm after petitioner ignored him especially

petitioner has no any relationship with him nor ever talk to him. Trial court ruling

was affirmed by 4* district court of appeal in serious matter which eliminated each

citizen's right to live harassment, threat free within secure safe life within stable

environment. Denial such right protected by law give respondent full

encouragement to go fare beyond the law which caused definite harm especially

against helpless single divorce woman which can't be restore without justice.

Therefore denial petitioner's right for injunction against repeat violence beside

other trial court errors under Fla. Civ. R. P. under subpoena rules which it has a

great effect on the proper administration of justice.

STATEMENT OF THE FACTS

Respondent's threat to kill occurred on Nov. 28,2011 after pervious continues

harassment and following petitioner. Also civil complaints and another pervious

restraining order was filed since he started on 2009/ 2010. Pervious restraining

order was denied by trial court domestic violence division on May 19,2011 case #

DVCE 10-78116 (59) AND the 2"d current injunction was dismissed on Oct.

28,2011 then denied as final order on Oct. 31,2011 case # DVCE 11-6269 (59)

which affirmed by 4* district court case # 4D11-4722which our matter for

jurisdictional review. This matter included record for errors / fraud by the clerk

and was corrected / amended by petitioner's for related cases and other documents

as asserted by petitioner in trail court record. The record indicated civil cases

2

filed against same respondent and the major conclusion is relief by seeking

restraining order. The recent petition for injunction was the only answer which

could assist to prevent the circumstances petitioner live with now; after his

repeatedly harassment following petitioner with assorted languages and his

physical acts throwing object then his recent serious compose threat on Nov. 2011

to kill petitioner continued after nothing stop him.

This honorable court entered an order dated June 14,2013 which granted

petitioner's motion filed on June 12,2013 for leave to file pass Due Pleadings

Because Of Excusable Neglect. Such motion with essential record can be use

while it has pleading related to civil compliant has connection with same

respondent / Mohamed Jahlil on same matter. These assorted cases generated from

one divorce case as petitioner's ex-husband promised intentional harm against

former wife using his and his friends financial and position power in Islamic

Community. This court granted time extension till July 15,2013 to file this brief by

order dated June 14,2013 exhibit Al with another order exhibit A2 asserted that:

[petitioner's newly acquired counsel to file a notice of appearance]; but petitioner

pro-se and wasn't able to secure counsel to any of her cases at any court level.

This Honorable Court Notice To Invoke Discretionary Jurisdiction on fourth

district court of appeal decision dated Jan. 09,2013 exhibit A3 which affirmed

trail court final order which denied petitioner's petition for injunction against

3

repeat violence as well as rehearing. The 4* district court of appeal decision based

on petitioner's response and motion to compel with appellate court 4* district

order which requesting transcripts within 10 days from the order dated Dec.

05,2012 exhibit A 4. While appellant / petitioner can't afford it nor trial court

provided CD recorder which available to similar cases on same matter of law.

Furthermore the 4* district officially was acknowledge by petitioner as

asserted in appellate court legal signed form, [ Docketing Statement ] that there is

no transcripts and reason why there is no transcripts which exist as a part of the

record filed in the beginning of the appeal. Also explained again in petitioner's

motion to compel with the order to provide the transcript. In addition petitioner

asserted the legal points in her motion for re-consideration / rehearing why and

how trial court prevented petitioner's to exercise her right to present witness to

testify which it could establish record and supportive evidences under alternative

theory as appellate court final decision appointed. The fourth district court still

denied rehearing by decision dated Feb. 19,2013 exhibit A5 .

Therefore petitioner moved to this Honorable court to review the lower

courts decisions on petitioner's petition for injunction against repeat violence

which was filed on Sep. 23,2011in trial court after respondent's recent attack and

threat to kill petitioner if he see her again on Nov. 28,201lease # DVCE 11-6269

(59). Petitioner amended the petition for injunction on Sep. 28,2011 to vacate the

4

clerk input by interfering to fill the paper work and related cases form 12.900(h) as

petitioner discovered later when she become acknowledge about the procedure.

The clerk asked petitioner to sign only the last page then petitioner discovered

improper handling as petitioner advised the clerk when she assumed it is a part of

procedures. Therefore petitioner amended her papers work on her won including

the related cases form 12.900(h) on Sep. 30,2011 see attached exhibit A 6-9 .

Petitioner filed official pleadings to inform the court. After different reschedule

hearings and filing notice of witness's list and witness was served with Subpoena

Duces Tecum exhibit A 10-A11. The case set for final hearing and the witness

failed to come due to excusable reason.

The court entered an order to dismiss petitioner's petition for injunction on

Oct. 28, 2011 exhibit A 12 which inappealable. Petitioner filed Supplemental

affidavit in support of petition for repeat violence on Oct. 30,2011and trial court

entered the final order without a hearing on Oct. 31,2011 exhibit A 13 . Petitioner

filed motion for rehearing exhibit A 14 one page after trial court ignored the legal

opportunity to witness to testify after he failed to attended the final hearing based

on excusable reason. Trial court denied rehearing by order dated Nov. 16,2011

exhibit A15. Therefore appeal was filed in 4* district court case # 4D11-4722.

Also a new civil compliant filed against 2"d individual from same group

case # 11-28202 (25) on the same matter with connection to same defendant /

5

Mohamed Jahlil which still pending. Their retaliation come after petitioner's

divorce on Oct. 22,1997 with plan and conspiracy with her ex-husband to repeat

same thing again to get petitioner off the center she attending since 1996 and

falsely build improper record to swipe her marital assets. The pervious civil

compliant against same respondent / Mohamed Jahlil and his employer filed on

2010 case # 10-48103(25) and an order entered against him to stay way and no

contact with the petitioner while trial court dismissed 2"d part against his employer

by order dated Jan 28,2011 exhibit A 16 . Petitioner filed motion asking to identify

the address where respondent should stay way to avoid repeating their false

pervious information to police on 2009 after the center moved to the newly 11.5

acres on 2008 as they informed police that petitioner belong to old site which was

sold and become a church. Therefore 2nd order entered on Feb. 01,2011 which

identified the address where he should stay away and 2"d part against the full time

private school which petitioner has no business with remain the same exhibitA17.

It was and still ex-husband's plan and conspiracy to get petitioner off every

thing using his financial power and his business partner in community by

providing false information which 1" occurred after divorce and order approving

settlement issued on 1998 and no problem since till 2009 and after the center

moved on 2008. Petitioner filed 1" pleading on 2009 to enforce the pervious

settlement entered by same judge on 1998 and court issued new order dated

6

August 25,2009 exhibit A 18-19 to reserve petitioner's right to stay attending her

community after divorce as she was volunteering before divorce then working

once a week in community after divorce exhibit A 20 . Petitioner stayed with her

primary full time job with Broward County Public School to avoid them also to

disapprove any false allegation they can create when there is no contact through

the major activities in the center. The newly discovery evidences confirmed that

the administration of the full time Islamic school located in same center has tie and

connection to my unlawful termination from my job with public schools after they

become fully affiliated with my employer public schools board while law suit

pending in U.S court of appeal 11 th Cir. Petitioner can't afford lawyer who asked

$15,000 up front and obligated to file due pleading in her discrimination case on

July 14,2013 with addition to her follow up with medical services and other need.

Their harassments and repeatedly violence acts continued with engorgement

after the pervious injunction filed against same respondent / Mohamed Jahlil on

Dec. 22,2010case # DVCE 10-7816 (59)and was also denied on May 19,2011

after unnecessary delay by order exhibit A21 while the case filed on 2010.

Because of petitioner's circumstances which she provided to this honorable court

as filed on June 12,2013. There is a technical barrier to provide further essential

record which reflecting what petitioner went through to protect her right and

defend her self while intentional harm continued. Therefore legislation confirmed

7

protection under the law without a lawyer. Single divorce woman's right which

protected by law in serious matter was fully ignored and petitioner no longer feel

safe, secure nor having normal life; since these individual's actions which has

sever financial, social, emotional impact and interruption to her living stability

which can't be store without the power of justice under the law. There was no

response form this honorable court on petitioner's motion to use the original

record which has all details with exhibits to all other related cases with lower

courts orders against same respondent / Mohamed Jahlil.

These individual's action and conspiracy with petitioner's ex-husband

against single divorce woman certainly intentional harm which already done by

destroying any repair she made caused by her ex-husband since divorce on 1997.

Their harm including newly discoveries evidences for a hidden unknown record

made falsely by the Islamic Center within a deal and conspiracy with petitioner's

ex-husband to swipe her assets, keep her dependant and replacement petitioner by

his wife in community leaving petitioner homeless after 20 years of marriage.

Petitioner has a legal right to use her marital assets as recorded legally as a joint

community property estate protected by law but yet no relief. Therefore petitioner

requested any record based on their false statement and information under Fla. R.

Civ. P. and Federal Rules Civil Procedures FRCP 26 (a)(1) BUT they failed to

provide what required by law which confirmed their lie under oath after they

8

reported in their motion to dismiss as 1" response / appearance ever. They stated

that my husband has restraining order against me and I will be arrested even if I go

to worship God while I'm never talk to this person who is the respondent or

acknowledge about restraining order. These information also given to police in

order to trespassed me out to harm my reputation, keep me dependant and control

my life. Therefore motion for civil contempt filed under Fla. Civ. R. P. 1.380

(b)(1), case # 11-28202(25) still pending

Appellate court affirmed trail court ruling while petitioner continued

suffering continues abuse and unnecessary obligations to come repeatedly to court

to defend her self, belongs and to keep my clean record as respondent focused to

impact my teacher certification and my recent Master Degree. Trial court also

denied temporary injection which not required appearance nor trial. District court

asked appellant to comply with court order to provide transcripts record for trail

court hearing while appellant can't afford court reporter. Also trial court didn't

provided a CD recorder which available to similar cases on same matter of law.

In addition petitioner indicated officially in fourth district court of appeal

form named [ Docketing Statement ] that: there is no transcripts and reason why.

Such questionnaire form must answer and signed by appellant and exist in the

record and done in beginning of the case. Also district court of appeal used

inapplicable law case and confusing reason to affirmed denial of injunction

9

matter. Trial court denied legal opportunity to witness to testify which eliminated a

key factor for legal process could establish alternative record in absence of

transcript while neither necessary in such matter, see Annotated Reference Fla.

Stat. Ann. 32A, (appeal and errors j stated that "Appellate court will reverse,

even in absence of transcript where error of law is apparent on face ofjudgment",

Henderson V Henderson, App. Dist. 905 So 2 ad 901 (2005) and Monacelli K

Gonzaleg App. 4 th Dist. 883 So. 2 nd 361 (2004). Petitioner become very

concern after threat to kill become a real by one way or another while her car

vandalized he at same Islamic Center.

The newly discover evidences indicated that respondents has connection

with my employer Broward County Public Schools who unlawfully terminated

petitioner's employment on April 28,2010.Termination come after the Islamic

Center become affiliated with my employer after most of week end school become

full time private school beside the Mosque opened on 11.5 acres on 2008 which

operated by petitioner's ex-husband friends. Petitioner lost her job based on false

negative evaluations occurred after individual's acts. Petitioner choose to work

away with public school since 2000/2001 as her full time primary job to avoid

them. Petitioner got her Science Teacher Certification in Chemistry and General

Science and her Master Degree In Education, Management and Administration to

be independent and for better life for herself and for other by implementing two

10

projects based research for Special Need Students and Science Education

Standards see the circumstances attached to motion to file pass due brief while

there is pending case in federal court. They never left petitioner alone but

continued to follow her and provided false information about her to authorities.

Their action impacted petitioner's life, her reputation also at other communities

while divorced woman's position not favorable and she is the only one to be blame

even if divorce not her fault which caused life changes injuries.

Summary ofArgument

Petitioner become very concern as a single divorced women because of such

violence behaviors which in need for immediate justice. Court abuse desecration

to protect petitioner's legal right for protection under the provisions of law

according to Fla. Stat. § 741. 046, Fla. Stat. § 741.30 and § 784.046. Petitioner

will not be able to survive when she has no clue how to deal with such behaviors

and the motive behind these individuals repeatedly acts. Respondent targeted

petitioner while she doesn't know him or never ever talk to him. Respondent's

cause of action was against petitioner's well-being and severely invaded her

personal life and her right for normal living stability. Lower courts decisions was

against the provisions of Fla. Stat. § 784. 046 (7) for protection against repeat

violence. Denial petition for injection 1" time encouraged him later to continued

stalking and threaten to kill petitioner if he see her again. Trail court ruling was on

11

contrary to Fla. Stat. 741. 046(c), Fla. Stat. 741.30 (b)&(7) which to secure fast

legal proceeding to assist domestic violence victims while respondent was already

in contempt of active pervious court orders asking him to stay away and 1998

order not to involve in petitioner's personal life during the divorce.

Trial court domestic violence division excessively abuse petitioner's right

for protection from imminent harm and preventing such circumstances from

getting worse after petitioner moved on with her life after nasty divorce. The law

indicated clearly by the legislature according to district court of appeal 20 Fla. L.

weekly D2019 in section analysis domestic violence legislation as stated that: In

1983, the legislature substantially revised section Fla. Stat. § 741.30 (1983), by

creating a simplified, expedited procedure for obtaining from a circuit court an

injunction for protection against violence...such an injunction could now be

obtained directly, quickly, without an lawyer's help " office of state attornev V

Parrotino, 628 So. 2d 1097, 1099 (Fla. 1993). The legislature also provided that

the court issuing the injunction was required to enforce compliance through

contempt proceedings §741.30 (9)(a), Fla. Stat (Spp. 1984).

Petitioner never talk to respondent nor she has any relationship with him or

with any body else at any community what's ever. Respondent has no right by law

what's ever to follow and threat petitioner by any way. Respondent should be

responsible for his involvement in petitioner's ex-husband's plan or with his

12

pharmaceutical business friend's conspiracy to control and harm petitioner's by

misusing their financial and position power in Islamic Center. Their act not only to

torture petitioner from her community but also follow petitioner any where she go

for intentional harm or go back to live in Egypt as her ex- husband's repeatedly

promises and wishes. Petitioner's ex-husband's action since divorce confirmed his

words to cause harm using these individuals who now operating the entire center.

Argument

I- Trial court abused its discretion on the matter of law with identicaljustifiable facts for reasonable legal justice against imminent harm.

2- Appellate court erred to reverse trail court ruling when absence ofalternative record was due to trail court disrupted the due process andrequirements of law by preventing a witness to testify; which canestablish relevant record in the case.

3- lower courts on contrary to law provisions and power of justice towardsdomestic violence matter a against single divorce woman's safetybecause of absence of trail transcripts she can't afford.

Conclusion

Petitioner has constitutional legal right to attend her Mosque, or any place

feeling safe without any harm nor any concern to be harmed directly or indirectly.

There is no substitution for the justice system power to maintain safe and secure

environment by superseding any conspiracy to harm petitioner's right to attend her

community, work and to live normal better life she deserve which protected by

law. Lower courts did departure without application of law to secure free harm and

13

safe secure environment in advance civilization societies who condemned any sort

of violence. Petitioner as a divorce single mother has a legal right to be protected

against abuse, curtly acts, tortures and threat to kill which can't be eliminated, or

over come with without justice. There is no reason ever can be supportive to deny

safety, security and the right of other people to live normal better life.

Therefore petitioner respectfully requesting relief from lower courts decisions on

petitioner petition for injunction against domestic repeat violence against

defendant / Mohamed Jahlil to stop any further negative phenomena and imminent

harm after petitioner's life paralyzed.

CERTIFICATE OF SERVICE

I CERTIFY that a true copy from this brief on jurisdiction send Florida supreme

court by priority mail on July 07"' /2013 and to respondent at 5455 NW 108th

Ave. Sunrise Blv 33351, Hon / Marilyn Beuttenmuller 1525 Palm Beach Leak Blv.

West palm FL,33401&Honorable /Michael Kaplan Broward County Circuit Court.

CERTIFICATION OF COMPLIANCE

I HEREBY CERTIFY that this brief was prepared using Times New

Roman 14 font in compliance with the font requirements set forth in Florida Rule

ofAppellate Procedure 9.210(a)(2).

Petitioner, pro se / Nasra M. ArafatP.O.BOX 772177

Coral Springs FL, 33077

14

IN THE SUPREME COURT OF FLORIDA

CASE NO. SC13-484Nasra M. Arafat (pervious m.n. Ibrahim) Vs. Mohamed Jhalil

INDEX TO APPENDIXCONTENT: PAGE

1-superme court order for time extension on 06/14/13 3

2-superme court order notice for newly acquired counsel to file 3a notice of appearance on 06/14/13[ but still not exist]

3- appellate court 4th diStriCt Order to affirm on 01/09/13 3

4-appellate court 4* district order seeking transcript on 12/05/12 4

5-appellate court 4th district Order denied rehearing on 02/19/13 4

6-petitioner's completed form for related cases filed in trial court on 09/30/11 5

7-petitioner's certified form for Subpoena Duces Tecum 10/21/11 5

8- petitioner's notice of witness's list on 10/21/11 5

9-trial court DCVE order to dismiss petition for injunction on 10/28/11 5

10-trial court DCVE order to dismiss petition for injunction on 10/28/11 5

11-trial court DCVE final order denied petition for injunction on 10/31/11 5

12-petitioner motion for rehearing filed in trial court on 11/03/11 5

13-trial court final order denied petitioner motion for rehearing on 11/16/11 5

14-trial court order on civil compliant against same respondent on 01/28/11 6

15-trial court 2"d order on civil compliant against same respondent on 02/01/11 6

16-trial court order to enforce pervious 1998 order on 08/25/09 7

17-petition prove indicated her work with community since Sep. 2000 7

18-trial court DCVE order denied pervious petition for injunction on 05/19/11 7

CERTIFICATE OF SERVICE

I CERTIFY that correct and a true copy from this appendixes for brief is being

served on July 07*, 2013 to defendant / Mohamed Jhalil individually by US mail

at 5455 NW 108* Ave. Sunrise Blv 33351 and 4* district court ofappeal west

palm Beach FL, 33401 and Honorable Judge / Michael Kaplan Broward County.

CERTIFICATION OF COMPLIANCE

I HEREBY CERTIFY that the appendices was prepared using Times New

Roman 14 font in compliance with the font requirements set forth in Florida Rule

ofAppellate Procedure 9.210(a)(2).

Petitioner, pro se/ Nasra M. ArafatP.O.BOX 772177

Coral Springs FL, 33077

2

Supreme Court of floríbaFRIDAY, JUNE 14, 2013

CASE No.: SC13-484Lower Tribunal No(s).: 4D11-4722,

11-6269 DCVE

NASRA M. ARAFAT vs. MOHAMED JHALIL

Petitioner(s) Respondent(s)

Petitioner's motion for extension of time is granted and petitioner is allowedto and including July 15, 2013, in which to serve the brief on jurisdiction withappendix. NO FURTHER EXTENSIONS OF TIME WILL BE GRANTED TOPETITIONER FOR THE FILING OF THE JURISDICTIONAL BRIEF. All othertimes will be extended accordingly.

A True CopyTest:

1omas D. HallClerk, Supreme Court

abServed:

NASRA M. ARAFATMOHAMED JHALIL

Supreme Court of florthaFRIDAY, JUNE 14, 2013

CASE No.: SC13-484Lower Tribunal No(s).: 4D11-4722,

11-6269 DCVE

NASRA M. ARAFAT vs. MOHAMED JHALIL

Petitioner(s) Respondent(s)

Petitioner's motion for extension of time is granted and petitioner is allowedto and including July 15, 2013, in which for petitioner's newly acquired counsel tofile a notice of appearance with this Court.

A True CopyTest:

omas D. HallClerk, Supreme Court

abServed:

NASRA M. ARAFATMOHAMED JHALIL

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDAFOURTH DISTRICT

January Term 2013

NASRA M. ARAFAT,Appellant,

v.

MOHAMan JHALIL,Appellee.

No. 4D11-4722

[January 9, 2013]

PER CUMAM.

Aff1rmed. See Applegate v. Bamett Bank of Tallahassee, 377 So. 2d1150, 1152 (Fla. 1979) ("Without a record of the trial proceedings the

th t e ou slve the underlying factual issues so

evidence or by an alternative theory.").judgment is not supported by the

MAY, C.J., GROSS and GERBER, JJ., concur.

BroAp alCou ty M ha t Cou or theudSeventeenth Judicial Circuit,DCVE. , ge; L.T. Case No. 11-6269

Nasra M. Arafat, Coral Springs, pro se.

Mohamed Jhalil, Sunrise, pro se.

Notfinal angl disposn

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDAFOURTH DISTRICT, 1525 PALM BEACH LAKES BLVD., WEST PALM BEACH, FL 33401

December 5, 2012

CASE NO.: 4D11-4722L.T. No. : 11-6269 DCVE

NASRA M. ARAFAT v. MOHAMED JHALIL

Appellant / Petitioner(s), Appellee / Respondent(s).

BY ORDER OF THE COURT:

ORDERED that, within ten (10) days from the date of this order, Appellant

shall supply a transcript of the hearing held on October 28, 2011, or shall notify thisCourt that no such transcript exists. Fla. R. App. P. 9.200(f)(2).

I HEREBY CERTIFY that the foregoing is a true copy of the original court order.

Served:

Howard Forman, Clerk Nasra M. Arafat Mohamed JhalilKhurrum Wahid

kb

Rll BEUTTENMULLER, clerkFourth District Court of Appeal

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDAFOURTH DISTRICT, 1525 PALM BEACH LAKES BLVD., WEST PALM BEACH, FL 33401

February 19, 2013

CASE NO.: 4D11-4722L.T. No. : 11-6269 DCVE

NASRA M. ARAFAT v. MOHAMED JHALil

Appellant / Petitioner(s), Appellee / Respondent(s).

BY ORDER OF THE COURT:

ORDERED that appellant's motion filed January 22, 2013, for rehearing and for

reconsideration is hereby denied.

I HEREBY CERTIFY that the foregoing is a true copy of the original court order.

Served:

Howard Forman, Clerk Nasra M. Arafat Mohamed JhalilKhurrum Wahid Hon. Michael G. Kaplan

et

Fausth District Court of Appeal

IN THE CIRCUlf COURT OF THE 17th JUDICIAL CIRCU cnIN AND FOR aroward COUNTY, FLORIDA

Case No.: DVCE 11-6289

Division: SeNasra l¥l. Arafat (p.m.n. Ibrahlm) r

Petitioner,and

Mohamed Jhalif

Respondent.

NOTICE OF REIATED CASES

1. Petitioner submits this Notice of Related Cases as required by Florida Rule of JudicialAdministration 2.545(d). A related case may be an open or closed civil, criminal, guardianship,domestic violence, juvenile delinquency, juvenile dependency, or domestic relations case. A caseis "related" to this family law case if it involves any of the same parties, children, or issues and itis pending at the time the party files a family case; if it affects the court's jurisdiction to proceed;if an order in the related case may conflict with an order on the same issues in the new case; orif an order in the new case may conflict with an order in the earlier litigation.

There are no related cases.

._ The following are the related cases (add additional pages if necessary):

Related Case No. 1Case Name(s): pennon foringunctionforsespainst repeatemos

Petitioner Narsia M. Andat

Respondent Mohamed.lhamCase No.: DVCE 10-7818 Division: s9

Type of ing: [ V aR that apply)Dissolution of Marriage PaternityCustody AdoptionChild Support Modification/Enforcement/Contempt ProceedingsJuvenile Dependency Juvenile Delinquencyermination of Parental Rights CriminalDomestic/Sexual/Dating/Repeat Other {specifylViolence injunctionsMental Health

Fiorida Family law Rules of Procedure Form12.900(h), Notice of Related (01/09)

State where case was decided or is pending: Florida her: {specifyl

Name of Court where case was decided or is pending (for example, Fifth Ørcuit Court, MarlonCounty, Florido): "8'circuit court aRMeni Can, Rose

Title of last Court Order/Judgment (if any): casaror assnisselorminlunsonw sepeatsDate of Court Order/Judgment (if any): May 19,2011 (the evidencee preeenied insullicient)

Relationshi of cases (V all that apply):pending case involves same parties, children, or issues;may affect court's jurisdiction;order in related case may conflict with an order in this case;order in this case may conflict with previous order in related case.

Statement as to the relationship of the cases: ces casewnuspie counie included injunsonwhimie granied asidng sospondent to siey away and no coniect wiin peillioner

Related Case No. 2Case Namels): compeent and injunson W mispie counie and defendente

Petitioner: Neste MJndetRespondent: Mohamed JheHi

Case No.: 1o48103 Division: 25

Type of Proceeding: [ V all that apply}Dissolution of Marriage PaternityCustody AdoptionChild Support Modification/Enforcement/Contempt ProceedingsJuvenile Dependency Juvenile Delinquency

nation of Parental Rights CriminalDomestic/Sexual/Dating/Repeat Other {specify)°°'"P'''"*"" °°°""'8Violence injunctionsMental Health

State where case was decided or is pending: f:lorida her: {specify}Name of Court where case was decided or is pending (for example, Fifth Grcuit Court, MorlonCounty, Florido): 17th circuit court , Broward County, Rodde

Title of last Court Order/Judgment (if any): seiender noceswordeDate of Court Order/Judgment (if any): Jan.28,2011

Relation of cases (V all that apply):pending case involves same parties, children, or issues;may affect court's jurisdiction;order in related case may conflict with an order in this case;order in this case may conflict with previous order in related case.

Florida Family Law Rules ofProcedure Form 12.900(h),.Notice of Related (01/09)

Statement as to the relationship of the cases: respondente same acuan commuled in both cases butcase #2 has more dNrerent counle whBe cent be proceed in DVCE but it essendas to be ceneider

Related Case No. 3Case Name(s): appas scircuit court order the deniet part w pannoner convilentæd irilunction formunips counie ad dwendenis

Petitioner: Nasta M. Armist (pervious married name Ibrahlm)

Respondent: Mohamed JhaiR and STEMS / IFSF

Case No.: 4D11-1154 Division: 4th Diebict Court or Appeal/ West Palm Beach

Type of Proceeding: [ V a8 that apply]Dissolution of MarriageCustodyChild SupportJuvenile Dependency

of Parental RightsDomestic/Sexual/Dating/Repeat

lence injunctionsMental Health

State where case was decided or is pending:

PaternityAdoptionModification/Enforcement/Contempt ProceedingsJuvenile Delinquency

inalOther {specifyl

Florida er:{specifyName of Court where case was decided or is pending (for example, Fifth Orcuit Court, MorlonCounty, Florido): *h'***°°"d''p'''^°""Title of last Court Order/Judgment (if any): pendingDate of Court Order/Judgment (if any):

Relationsh ofcases [V all that apply]:pending case involves same parties, children, or issues;may affect court's jurisdiction;order in related case may conflict with an order in this case;order in this case may conflict with previous order in-related case.

Statement as to the relationship of the cases: emsame or couw or adion done by respondentin bolhihie case and related case whee au counis indicated violence and acts to harm.

2. V one only]I do not request coordination of litigation in any of the cases listed above.I do request coordination of the following cases:

3. V all that apply]Assignment to one judge

_ Coordination of existing cases

Florida Family Law Rules of Pmcedure Form 12.900(h), Notice ofRelated (01/09)

will conserve judicial resources and promote an efficient determination of these cases

because: '""'""*"'Y°*****8°"**'''***'"*"Y©°"*°'**"d°"*'**''***di'******'**'°'***°*°°

4. The Petitioner acknowledges a continuing duty to inform the court of any cases in thfs or anyother state that could affect the current proceeding.

Dated: sep.30,2011 N

Petitioner's SignaturePrinted Name: Nasra M. AtafatAddress: P.o.aoxminCity, State, Zip: Coral Springs FL, 330H

Telephone Number:Fax Number:

CERTIFICATE OF SERVICE

I GRTIFY that I delivered a copy of this Notice of Related Cases to the ®'°**d CouSheriff' partment or a certified process server for service on the Respondent, and [V one onlyma and delivered a copy to@name/ Honorable Judge i Petter Weistein , who is the authat judge assigned to new case},@chiefjudge or family law administrative judge,{namel 'W^ , a party to the related case {name}

N/A , a party to the related case on {date} mep. 2,211

Petitioner/Attorneyfor Petitioner

IF A NONLAWYER HELPED YOU Fili OUT THIS FORM, HE/SHE MUST Fili IN THE BtANKS BEi.OW: {fill inall blanks]|, {full legal name and trade name ofnoniawyer} Nasra u. Arafat ,a noniawyer, located at {street} P.O.BOX H21n , {city} Cong Springs ,{state} FL , {phone} N!A , helped {name} Sei ,who is the Petitioner, fill out this form.

Florida Family Law Rules of Procedure Form 12.900(h), Notice of Related (01/09)

IN THE CIRCUIT COURT OF THE SEVENTEENTHJUDICAL CIRCUIT IN AND FOR BROWARDCOUNTY, FLORIDA

NASRA M. ARAFAT (PERVIOUSMARRIED IBRAHIM Case No: 11- 6269 (59)Plaintiff, DVCE Un

Judge / 1 I plaVs.

Mohamed Jhalil FDefendant.

SUBPOENA DUCES TECUM ,

THE §ÇfATE OF FLORIDA TO THE FOLLOWINO NAMED WITNESS: HifiezFütganHakeem (youth and full time school teacher Imam)office of IFSF at 5455 NW 108* Ave Sunrise FL, 33351YOU ARE COMMANDED TO APPEAR BEFORE JUDGE / Michael Kaplan.ROOM NQ: 870 AT THE BROWARD COUNTY COURT HOUSE LOCATED AT 201 SE6* ST. FT LAUDERDALE, FLORIDA, ON Oct. 28 , 2011 at 9: 30 am to TESTIFY INTHIS ACTION.IF YOU FAIL TO APPEAR, YOU MAY BE IN CONTEMPT OF COURT. YOU ARESUBPOENAED TO APPEAR BY THE PLAINTIFF, AND UNLESS EXCUSED FROM THISSUBPOENA BY SAID PLAINTFF, HIS/HER ATTORNEY, OR THE COURT, YOU SHALLRESPOND TO THIS SUBPOENA AS DIRECTED.

Witness in the my hand and seal of this court on Oct. ,2011

CLERK OF THE COURT

A TRUE COPYHOWARD C. FORMAN BY

CLERK OF CIRCUlT COURT AS DEPUTY CLERK

PLAINTIFF/ Nasra M. Arafat NT 22 2gypP.O.BOX 772177Coral Springs F1, 33077

In accordance with the Americans with disabilities, Act of 1990 (ADA). Disabled person who,because of their disabilities, need special accommodation to participate in this proceeding shouldcontact the ADA coonlinator not later than five business days prior to the proceeding at theindicated address telephone, VOICE / TDD (954) 831-6364

IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICAL CIRCUIT IN AND FORBROWARD COUNTY, FLORIDA

Nasra M. Arafat (servious marriedgame Ibrahim) Case No: DVCE 11-6269 (59)Petitioner Judge / Michael Kaplan

Vs. A TRut. wi ,

Mohamed Jhalil HOWARD C. FORMANRespondent CLERK OF CIRCUIT COURT

OCT 2 1 28t1Notice OfPetitioner's Witness's List

Petitioner as a pro-Se filling this wittiness list as following names will be a possiblewittiness in above style case:

1- HifiezFurqan Hakeem (teacher and youth Imam full time school)

I certify that a true copy from this witness's list send on Oct. 21,2011 by fax & mail to

defendant's lawyer/ Khurrum Wahid defendant's lawyer at 6221 W. Atlantic Blv., Margate FL,

33063.

Pro-Se /petitioner o 2Name Nasra M. Arafat

P.Q.BOX 772177Coral Springs FL. 33077

I, full legal name Nasra M. Arafat none lawyer at P.O. Box 772177 Coral Springs FL,33077 ,

helped her self who is the petitioner to prepare & file all her legal documents.

IN THE CIRCUlf COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT,IN AND FOR BROWARD COUNTY, FLORIDA

Case No.:

Petitioner,and

Respondent.

ORDER OF DISMISSAL OF TEMPORARY INJUN FORPROTECTION AGAINST ( )DOMESTIC VIOLENCE EAT VIDIANCE

( ) DATING VIOIÆNCE ( ) SEXUAL

THIS CAUSE came before the Court on {date} 7 , uponPetitioner's action for an injunction for protection against dorÅestic violence, repeat, dating, orsexual violence, and it appearing to the Court as follows:[Ian that apply]__. failed to appear at the hearing scheduled in this cause..__ ' appeared at the hearing but desires to voluntarily dismiss this action.

The evidence presented is insufficient under Florida law (section 741.30 or 784.046,Florida Statutes) to allow the Court to issue an injunction for protection against domestic,repeat, dating, or sexual violence.

Accontingly, the case is di i ithout prejudice.

ORDERED on f .

CIRCUIT JUDGECOPIES JUDGE MICHAEL G KAPLANSheriffof (* ntyPetitioner__byU.S. Mail_£1Íy delivery in open courtRespondent __by U.S. Mail __ hand delivery in open court__ State Attorney's Office

Other:

I CERTIFY the foregoing is a true copy ofthe original as it appears on file in the officeofthe Clerk ofthe Circuit Court of County, Florida, and that I have furnishedcopies ofthis order as ind .

CLERK OF THE CIRCUIT COURT

(SEAL) .-.. .By: aprrtNA HARRÍNGTON

n 1 7th Deputy Clerk

. IN THE 08tCUff COURT OF Seen EENMJUDOS CNtCUrr IN AND FOR BRO VARDCOUNTY, FLQWBDA

A/45r 19. An424 h 4 junsers w.1611 nirn,

&m~ a ) cAssno:Ô\ME / 62(<r (!9)4wn )v 4ta, )

SÝ<rNd

naaga

At'fW)A u, afyn r we -rgt

and be ne olhensise advised in 8 e Pjpmises, ahe upon,

5 ed -u

R 4

IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICAL CIRCUIT IN ANDFOR BROWARD COUNTY, FLORIDA

Nasra M. Arpfat.(aervious married name IbrahimlPetitionervs.Mohamed JhalilDefendant

Case No: DCVE 11-6269Division: 59

A TRUE C0FHOWARDC. FORMA

CLERK OF CRCUff 00

Motion for rehearina on petitioner's supplemental affidavit in sanoort for petition foriniunction for orotection against repeat violence

On October 31,2011 Honorable judge entered an order which denied petitioner'ssupplemental affidavit in support ofpetition for injunction for protection for repeat violencewithout a hearing based on dismissal ofpervious supplemental petition on hearing 10/28/2011 .

What happened: 1- on last hearing on Oct. 28,2011 the Honorablejudge dismiss petitioner'spervious supplemental affidavit in support for same matter as the order indicated because ofinsufficient evidences. During the hearing Honorable judge indicated that the witness did calledthe judge's office with excuse for not presented that he was traveling. In addition petitionercalled the sheriffoffice civil division who informed that the subpoena not served till noon Oct.27,2011. Therefore in order to provide sufficient evidences as the court indicated petitioner willcontinuo to enforce such subpoena and will hold the witness in the contempt ofthe court if failedagain to testify in this case as continuance.

2- Petitioner did add more facts and clarification for another recent incident which neverreported in the record when respondent did use cane stick as object in his hand to deliver anotherreflection meaning in his mind for c_an ( which he _can continuo assaulted & threaten me and nobody can stop him) when he started to flip it upside down when he stand in women's prayer areawhile his present was unnecessary, unusual and suspicious position as explained in petitioner'ssupplemental affidavit petition for injunction filed on Oct. 31,2011.

Therefore it is essential that petitioner's motion to be respectfully grant for a hearing to addressthe supplemental petition content dated 10/31/2011 and to give a chance for witness to testify.

Certification ofservice

I certify that a true copy from this Motion for rehearing send by fax and certified US mail torespondent's lawyer / Khurrum Wahid at 6221 W. Atlantic Blv., Margate FL, 33063 and by faxand proper mailing with prove ofservice to defendant's Mohamed Jhalil and the witnessHafizFurqan Hekeem work place at 5455 NW 108* Ave Sunrise FL, 33351on Nov. 03,2011.

Nasra . Arafat/ pro-seP.O.BOX 772177

IN THE CIRCUlT COURT OF THE 17TH JUDICIAL CIRCUlT,IN AND FOR BROWARD COUNTY, FLORIDA

NASRA ARAFAT,CASE NO 11-006269

Petitioner, DIVISION: 59vs. JUDGE: M. KAPLAN

MOHAMED JHALIL,

Respondent.

ORDER DENYING PETITIONER'S MOTION FOR RE-HEARING

THIS CAUSE came before this Court upon Petitioner's Motion filed on

11-03-11 and this Court having reviewed same, it is accordingly,

ORDERED AND ADJUDGED that the above-styled Motion is hereby

DENIED.

DONE AND ORDERED at Fort Lauderdale, Broward County, Florida, thisday of , 2011. MICHAEL G KAPLAN

NOV 1 6 2011

MICHAEL G. KAPLAN A TRUE COPYCircuit Court Judge

cc: NASRA ARAFAT, PETITIONER, PRO SEMOHAMED JHALlL, RESPONDENTKHURRUM WAHID, ATTORNEY FOR THE RESPONDENT

IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT,IN AN FOR BROWARD COUNTY, FLORIDA

NASRA M. ARAFAT,

Plaintiff.vs.

SALH TWIFIEK ELEMENTARYAND MIDDLE SCHOOI1IFSF, andMOHAMED JHALIL,

Defendants.

CASE NO.: 1048103 (25)

gee91" A*ø * p .--

FINAL ORDER

The Defendant, SALAH TWIFIEK ELEMENTARY AND MIDDLE

SCHOOI/IFSF is hereby dismissed with prejudice as no cause ofaction exists.

As to Defendant, MOHAMED JHALIL, he shall refrain from having any contact

with the Plaintiff, NASRA ARAFAT. He shall refrain from approaching, speaking to or about

Plaintiff.

The Court further dismisses the damage claim.

Defendant, MOHAMED JHALIL, shall abide by this Order and failure to comply

may result in further sanctions.

DON ..AND ORDERED in Chambers, at Fort Lauderdale, Broward County, Florida,

, 2011.

IS LLIPJUDGI

Copies furnished to: 17tisTATEOF ORIDANasra M. Arafat, pro se to JUDIC UNTYMohamed Jhalil H CERTIFY9e with n er foregològNa true

Salah Twißek Elementary and Middle S .n ,,fee*øj,°

S and of date

puty Clerk

KATRINQA SPFN

N TIN CNNNNT COURT OF THE EEVENTEENTH.MMMCIAL CMCUrT, N AND FOR SMONMIOCOUNTY, FLORBA

CAsE NO.: fÔ�540'Å$

)Plaintiff,

)vs. ) ORDER

Defendant.}

THIS CAUSE was considered by the Court on the following Motion{øf 9tm©stA274:>sc

HEARINesse4eelew

THE COURT having considered the grounds for the Motion, taken4eelignenyrheard argument and considered the

applicable law, it is FOUND.

ORDERED AND ADJUDGED as follows

f�254/ S d $41 W

DONE AND ORDERED

CA S p65RCUt JUDGE

Copies furnished in open Court FEB 0 1 20 1

A TRUE COPY.c,,.<a.=n

U7

IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUITIN AND FOR BROWARD COUNTY, FLORIDA

ALAZHAR AMERICAN : CASE NO.98-6789(03)SCHOOL OF ISLAMICSTUDIES,

Plaintiff(s) : JUDGE: PATTI ENGLANDERHENNING

vL

NASRA ARAFAT,

Defendant(s)

ORDER

THIS CAUSE came before the Court August 25, 2009, to adopt and extend

the Order Approving Settlement of December 3, 1998 in the above-styled case.

The Defendant, NASRA ARAFAT, appeared, and there was no showing of

Plaintiffs. The Defendant provided testimony that the school had moved to

5457 NW 108* Avenue, Sunrise, Florida 33351, and that there is an issue as to

whether the Court's previous Order still must be followed. The Court finds it

appropriate to extend its Order to the new address. Accordingly, the December 3,

1998 settlement shall be effective at the above location.

DONE AND ORDERED, in Chambers, on this 25* day of August, 2009, in

Fort Lauderdale, Broward County, Florida.

PATTI LANDER HENNINGCIRCUlf DGE

Copies furnished to: A TRU6 COPY

CASE NO. 98-6789 (03)

Islamic Foundation ofSouth Florida5457 NW 108'' AvenueSunrise, FL 33351

Nasra ArafatP.O. Box 772177Coral Springs, FL 33077

Ord986789

** If you are a person with a dhahaky who needs as secomunedation la order toparticipate in this proceeding,you are entitled, at no eest to yea, to the provision ofcertainassistance. Please contact the Court Adamialstrator's ADA Coordinator at 954-831-7721withia (2) working days of your sweelpt of this motice. If you are hearing hapaired or voicelampaired, esìI 954-831-7017 or esR the Merida Relay Service @ 1-800-995-8771(TTY) or 1-800-995-8770 (Voice).

SCHOOL OF ISLAMIC STUDIES OF BROWARDa 4505 N.W.103rd Avenue, Sunrise,FL 33351 Phone: (954)1414130;Fax: (954) 74147M

BOARD OF TRUSTEESKliuman Adam!!asth.un AlbassentMohmtuned Illy.ts. Ph.DMohantmed IqbalMohammed JJ\edflhas MianoorAzahar Pirzada

To Whom it May Concem:

$"n"2fsÛ ° lt is my pleasure to write to you on behalf of NasraWuwm Quadn. ? E Ibrahim. MrS. Ibrahim is employed in Our SChool sinCe±aQ8'.f'; ° September 2000. She teaches islamic eciucation to

our 8°'graders, in our weekend school.

DiarctomorSISB MrS. Ibrahim eXhibitS remarkable Strength Ofzuk¼=^usha o character and integrity. She is very decticated and

punctual teacher. Her constant regard for others haspecy made her a reSpected te8Cher by all Who knoW her.

m=o=dn

Sincerely

PrincipalrNWUREA SISBNelofur Pir2nda. C P A.

REGib TH AR

Påsha Oureshi

OtN ECTON OF Em.caro.v

1N THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUrr, .IN AND FOR BROWARD COUNTY, FLORIDA

CaseNo.: p

Petitioner

and

Respondent

ORDER OF DISMISSAL OF TEMPORARY FORPROTECTION AGAINST ( ) DOMESTIC VIOLENCE ( REPEAT VIOLENCE

( )DATINGVIOLENCE ( )SEXUALVIOLENCE

THIS CAUSB came before the Court on {date} $ / ¶ ll , uponPetitioner's action for an injunction for protection against domestic repeat, dating, orsexual violence, and it appearing to the Court as follows:[ /all that apply]

._ Petitioner failed to appear at the hearing scheduled in this cause.___ etitioner appeared at the hearing but desires to voluntarily dismiss this action.

The evrdence presented is insufficient under Florida law (section 741.30 or 784.046Florida Statutes) to allow the Court to issue an injunction for protection against domestic,repeat, dating, or sexual violence.

Accordingly, the case is diamiaaad without prejudice. MICHAEL C. KAPLAN

ORDERED on f 9 1AY 1 9 2011

A RUE COPY

CIRCUIT RJDGE

COPIBS TO:

Sheriffof Soul County

Petitioner by U.S. Mail by hand delivery in open courtRespondent by U.S. Mail by hand delivery in open court-... State Attorney's Office._._ Other.

I CERTIFY the foregoing is a true copy of the original as it appears on file in the officelerk of the Circuit Court of /k2d County, Florida, and that I have fhrnished

order as indicated above.

CLERK CIRCUIT COURT