This is also an official 119 Request for Public Documents; including the document previously produced and the following:

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1 From: To: Subject: Date: Heekin, Jack Gorman, Amanda FW: State v. Trussell, Case No CF -- Terry Trussell 119 request Thursday, January 14, :54:41 AM Amanda, We have received this new 119 request. Would you please confirm receipt with the requestor, and begin coordinating the pull of all responsive docs? I will alert Susan Smith in our office to assist you with identifying responsive documents. Thanks, Jack Sent: Wednesday, January 13, :38 AM To: Heekin, Jack <Jack.Heekin@eog.myflorida.com> Cc: attorney@ingergarcia.com Subject: Re: State v. Trussell, Case No CF -- Terry Trussell 119 request This is also an official 119 Request for Public Documents; including the document previously produced and the following: time frame: 8/1/14 to date Definition: Documents includes - All s includes s and attachments and/or correspondence mailed or hand delivered: All documents or s which mention the name "Terry Trussell" or "Terry G; Trussell" All documents or s which mention Florida Stat All documents or s between the Governor's office and FDLE in relation to Terry Trussell All documents or s with Jeffrey Siegmeister or or his office or staff and the Governor's office in relation to Terry Trussell and/or the previously provided Executive orders All documents or s with Judge Hankinson's office or Willy Megg's Office in relation to TerryTrussell

2 I will accept the 119 requested documents in electronic format originally - then send a courier to pick up. I will stop in today to pick up the originals that are ready and you can me when others are ready Inger M. Garcia, Esq. for Florida Pot Law Firm, P.A. Garcia Legal Group, P.A. From: Heekin, Jack <Jack.Heekin@eog.myflorida.com> Sent: Wednesday, January 13, :17 AM To: Inger Garcia Subject: RE: State v. Trussell, Case No CF -- Subpoena for Deposition Duces Tecum The records you requested are compiled, and the affidavit I sent for your review has been executed certifying the authenticity of the records in our possession. I will leave the materials at our front desk in Suite 209 of the Capitol with Tyler Jefferson please call , if you have difficulty finding the office. I will be in meetings today from 10 a.m. to 12:30 p.m., and again from 2 p.m. to 3:30 p.m., but would be happy to speak with you when you retrieve the materials if I am available. Sent: Tuesday, January 12, :33 PM To: Heekin, Jack <Jack.Heekin@eog.myflorida.com> Subject: RE: State v. Trussell, Case No CF -- Subpoena for Deposition Duces Tecum Please consider this a 119 request and provide the certified copies of what you already gave me with a 119 records custodian affidavit

3 I can pick it up tommorrow since I am in town. Can you speak to me tomorrow for a few minutes when I come to your office? My cell phone Inger Garcia,Esq. Garcia Legal Group Florida Pot Law Firm 4839 Volunteer Road #514 Davie, Fl Attorney@ingergarcia.com Attorney@floridapotlawfirm.com On Tue, Jan 12, 2016 at 5:57 AM -0800, "Heekin, Jack" <Jack.Heekin@eog.myflorida.com> wrote: The draft affidavit is attached to this is this sufficient, or do you have a proposed alternative form of affidavit? The physical copies of our case files for EO and EO , along with the affidavit by Susan Smith as records custodian for those materials, may be picked up in the Florida Capitol building. The address is 400 South Monroe, Suite 209, Tallahassee, FL Suite 209 is the office of the Governor s general counsel, located on the second floor of the Capitol. The requested materials will be held at our front desk in Suite 209. Do you have a better idea of when you will come to pick up these materials? I will do my best to make myself available when you plan to retrieve the documents. The main phone number is (850) , if you have difficulty finding the office. Sent: Tuesday, January 12, :26 AM To: Heekin, Jack <Jack.Heekin@eog.myflorida.com>; attorney@ingergarcia.com Subject: Re: State v. Trussell, Case No CF -- Subpoena for Deposition Duces Tecum

4 Please send affidavit - where can I pick up originals tomorrow? address thanks. Inger M. Garcia, Esq. for Florida Pot Law Firm, P.A. Garcia Legal Group, P.A. From: Heekin, Jack <Jack.Heekin@eog.myflorida.com> Sent: Monday, January 11, :45 PM To: Inger Garcia; attorney@ingergarcia.com Subject: FW: State v. Trussell, Case No CF -- Subpoena for Deposition Duces Tecum I have drafted the attached affidavit to be executed by Susan Smith, Criminal Justice Liaison for our office, to authenticate the records in our possession relating to the executive assignment of Willie Meggs by EO (and extended by EO ), in lieu of requiring her live testimony at a deposition. Please advise whether this draft affidavit is sufficient for your purposes, or if there is an alternative form of affidavit you would prefer us to execute. Thank you, From: Heekin, Jack Sent: Monday, January 11, :44 PM To: 'Inger Garcia' <attorney@floridapotlawfirm.com>; attorney@ingergarcia.com Subject: RE: State v. Trussell, Case No CF -- Subpoena for Deposition Duces Tecum Attached are the documents responsive to your subpoena. The attached file is a scanned copy of all physical materials in the possession of our office relating to EO and EO , as well as the communications received and sent by our criminal justice liaison that relate to the executive assignment in question. The materials are compiled in the chronological order in which they were received or generated.

5 As a point of clarification, the true records custodian for all Executive Orders is the Florida Department of State. Copies of the executed EOs are kept in this office, but the originals are filed with the Dept. of State. Likewise, the true records custodian for the Order Approving Extended Assignment (which authorized the extension of the original executive assignment under EO by EO ) would be the clerk of the Florida Supreme Court. If you have a form of affidavit you would prefer that we use to certify the copied materials being provided by our office, please provide it to me at your earliest convenience and I will see that it is executed and returned to you. If you do not have a prepared form of affidavit for this purpose, please let me know so that I can prepare such a document for our criminal justice liaison to sign. Sincerely, Sent: Friday, January 08, :15 PM To: Heekin, Jack <Jack.Heekin@eog.myflorida.com>; attorney@ingergarcia.com Subject: Re: State v. Trussell, Case No CF -- Subpoena for Deposition Duces Tecum Per our conversation - please make sure I have the information on Monday afternoon via and I will stop by on Tuesday to pick up the original certified copies. I will determine how to narrow the 2014 and 2015 requests and back. Inger M. Garcia, Esq. for Florida Pot Law Firm, P.A. Garcia Legal Group, P.A. From: Heekin, Jack <Jack.Heekin@eog.myflorida.com> Sent: Friday, January 8, :09 PM To: Inger Garcia; attorney@ingergarcia.com Subject: RE: State v. Trussell, Case No CF -- Subpoena for Deposition Duces Tecum

6 Thank you for your response. However, please see my continued concerns below. Even if the request is narrowed to records from , it will still take a substantial amount of time to compile materials responsive to your subpoena. In 2014, 218 Executive Assignments were made by EO; in 2015, 256 Executive Assignments were made by EO. To find records responsive to your subpoena, our custodian would need to go through each EO file by hand. Additionally, the records for 2014 will need to be obtained from archives, and we would not be able to retrieve those records prior to the subpoena date. Given the breadth of the request and the amount of work necessary to fulfill this portion of the subpoena, unless it can be narrowed to a more specific request (such as for particular cases or Executive Orders that you are aware of), we will need to move for a protective order on this matter. Regarding the remainder of your request, copies of all Executive Orders issued by Governor Scott are available online at Our office can provide you with all materials in our possession related to Executive Order and Executive Order , including the request for the original executive assignment, the request for an extension of the executive assignment, the application by this office to the Florida Supreme Court for the extension, the Supreme Court order approving the extension, and any related written communications. I have forwarded your request to our Office of Open Government, which handles all public records requests, to begin compiling the requested information. Executive Orders - Florida Governor Rick Scott Executive Office of Governor Rick Scott 400 S Monroe St Tallahassee, FL (850) Click Here to Governor Scott Click Here to Lt. Governor Lopez... This office does not have records relating to the request or decision to appoint Judge Hankinson to the underlying case. Such orders are rendered by the Florida Supreme Court. This office does not have a summary of the procedure used to make executive assignments by executive order or extensions of such assignments. The assignment and extension of an assignment

7 of a state attorney to another circuit is governed by Section 27.14(1), Florida Statutes. Please respond how you wish to proceed on the matters addressed above. Thank you, Sent: Friday, January 08, :24 PM To: Heekin, Jack <Jack.Heekin@eog.myflorida.com>; attorney@ingergarcia.com Cc: Inger Garcia <attorney@floridapotlawfirm.com> Subject: Re: State v. Trussell, Case No CF -- Subpoena for Deposition Duces Tecum Please See Below in highlight. Inger M. Garcia, Esq. for Florida Pot Law Firm, P.A. Garcia Legal Group, P.A. From: Heekin, Jack <Jack.Heekin@eog.myflorida.com> Sent: Thursday, January 7, :51 PM To: attorney@ingergarcia.com Subject: FW: State v. Trussell, Case No CF -- Subpoena for Deposition Duces Tecum I have not yet heard back from you following our telephone conversation a few days ago. As I mentioned, your request in the subpoena for deposition duces tecum for any Executive Orders during Gov. Scott s terms in office, where he extended a State Attorney s temporary assignment after the original assignment was permitted to expire is very broad, and the process of compiling that information is unduly burdensome because it requires going through each EO and application by hand. In our conversation, you indicated you were willing to narrow the scope of your request. Please advise whether you will narrow your request, and what the narrower request will be. If you are unwilling to narrow the scope of your request, our office will likely file a motion for a protective order in this matter.

8 Additionally, we have offered to provide you with copies of the requested materials and an affidavit from our records custodian certifying their authenticity in lieu of requiring live testimony of the records custodian. Please advise whether this would be acceptable for you, to avoid the expense of holding a deposition. Thank you for clarifying these matters. Please call me if you have any questions my direct line is (850) Sincerely, From: Heekin, Jack Sent: Tuesday, January 05, :40 PM To: 'attorney@ingergarcia.com' <attorney@ingergarcia.com> Subject: State v. Trussell, Case No CF -- Subpoena for Deposition Duces Tecum Thank you for speaking with me this afternoon. We accepted service of your subpoena for deposition duces tecum in the above-referenced case. Your request to provide any Executive Orders during Gov. Scott s terms in office, where he extended a State Attorney s temporary assignment after the original assignment was permitted to expire is very broad and would require substantial effort to compile in the short time frame before the scheduled deposition. Would you please pare down your request to a more reasonable time frame or a more specific search criteria? I am willing to limit it to 2014, 2015 and How much time do you need for this? WHAT I NEED IMMEDIATELY IS: If you will please make sure I have all Executive Orders in relation to this case, along with the applications and applications and documents in relation to any extension, Supreme Court filings, and any communications in relation to the initial application and any extensions (including s, filings or any requests or comments in writing.) I believe there are three or four orders - Two appointing Meggs as the State Attorney and Two appointing Judge Hankinson. Also a summary of the procedure used to issue Executive orders and for Extensions, as well well as citations to any relevant laws. Additionally, would you be willing to accept certified copies of the materials requested in your subpoena, rather than require a live witness to authenticate the materials? - Yes if I have everything in relation to this case by Monday - I will extend time for others and I will accept certified copies with a record's custodian affidavit - via and I will pickup the originals in person on the 12 or 13th in Tally. With this agreement - I will not expect anyone in person. If you

9 ned me call my cell: Thank you for your response to these concerns. John P. Heekin Assistant General Counsel Executive Office of Governor Rick Scott The Capitol, Suite 209 Tallahassee, Florida Phone: (850) Fax: (850)