april_taylor020810-10am.htm

A Personal Collection of Found Materials

Abraham Shakespeare MURDERED - Plant City, Florida (Hillsborough Co.) April 2009
Abraham Shakespeare (42) won $31 million dollars in the Florida Lottery in 2006. He took a lump sum payout of approximately $17 million. He remained a frugal person as he had before his lottery windfall, but after numerous failed real estate transactions, loans, and friendships Abraham has suddenly gone missing. He was last seen in the Lakeland area in April 2009. Dorice Emma Donegan Moore (AKA Dee Dee Moore) stated in the media that she bought out Abraham's debts to enable him to move away to escape paying child support arrears for a second child that was born after the lottery windfall. Law Enforcement believes there may be more to this story. Abraham Shakespeare's body was found on January 28, 2010 buried beneath a cement slab on the rear property of Shar Krasniqi located at 5802 S.R.60 East, Plant City, Florida 33567. Shar Krasniqi was the boyfriend of Dorice Emma Donegan Moore (AKA Dee Dee Moore). On February 2, 2010 Dee Dee Moore was arrested, first charged with Accessory after the fact and later with First Degree Murder of Abraham Shakespeare.

Contact Hillsborough County Sheriff's Office (http://www.hcso.tampa.fl.us)

April Renee Taylor Interview 02/08/2010 10:00am
Data From Public Records, the Media, and Found Materials
http://www.acandyrose.com/april_taylor020810-10am.htm

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April Renee Taylor Interview 02/08/2010 10:00am
Transcribed to text by www.acandyrose.com from .pdf file Binder #5 Public Discovery 09/16/2010

Abraham Shakespeare Case
02/08/2010 - Transcript of Sworn Statement
by April R. Taylor
09/16/2010 DISCOVERY BINDER #5 PAGES 2-31

1 IN THE OFFICE OF THE STATE ATTORNEY
2 IN AND FOR HILLSBOROUGH COUNTY, STATE OF FLORIDA
3
4 ----------------------------X
5 IN RE: SOA INVESTIGATION
6 ----------------------------X
7
8
9
10 SWORN STATEMENT OF: April R. Taylor
11 TAKEN: Pursuant to Notice
12 TIME: Beginning at 10:00 a.m. Concluded at 11:04 a.m.
13 DATE: Monday, February 8, 2010
14 PLACE: Law Office of James H. Buzbee
15 802 W. Marin Luther King, Jr.
Boulevard - Suite D
16 Plant City, Florida 33563
17 BEFORE: RALPH D. MILLS, CVR, CP
Notary Public
18 State of Florida at Large
19
20
21
22
23
24
25

PAGE 2 (1960)

1 APPEARANCES:
2 On behalf of the State:
3 HON. JAY PRUNER
Assistant State Attorney
4 419 N. Pierce St., Third Floor
Tampa, Florida 33602
5 (813) 272-5400
6
7 ALSO PRESENT:
8 MR. TERRY DELISLE, SAO INVESTIGATOR
9
10
11
12
13
14
15 CONTENTS PAGE
17
18 Examination by Mr. Pruner 4
19 Examination by Mr. Delisle 46
20 Further Examination by Mr. Pruner 48
21 Further Examination by Mr. Delisle 55
22 Further Examination by Mr. Pruner 55
23 Certificate of Oath 59
24 Certificate of Reporter 60
25

PAGE 3 (1961)

1 EXHIBITS
2 EXHIBIT NO.: AT PAGE
3 For The State:
4 Exhibit A (Uncontested Divorce Documents 7
5 Exhibit B (Quitclaim Deed 2009022815) 20
6 Exhibit C (Quitclaim Deed 200905571) 27
7 Exhibit D (Quitclaim Deed 200922816) 31
8 Exhibit E (Assignment of Mortage 20090587860) 38
9 Exhibit F (Assignment of Mortage 2009058784) 38
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

PAGE 4 (1962)

1 APRIL R. TAYLOR,
2 was called as a witness, and being duly sworn by the
3 Notary, was examined and testified as follows:
4 DIRECT EXAMINATION
5 BY MR. PRUNER:
6 Q Please state your name.
7 A April Renee Taylor.
8 Q And your occupation?
9 A Legal assistant and the office manager
10 for James Buzbee.
11 Q And the physical location of Mr. Buzbee's
12 office?
13 A 802 West Martin Luther King, Jr.
14 Boulevard, Suite D, Plant City, Florida 33563
15 Q About how long have you been working for
16 Mr. Buzbee?
17 A I have been here since January the 28th
18 of -- it's seven years, seven years.
19 Q And before that were you also employed in
20 the legal field?
21 A Oh, yes. In LaBelle, Florida I worked
22 for Owen Luckey.
23 Q Okay. We're here to take a sworn
24 statement from you in an ongoing investigation that
25 involves the death of a person by the name of Abraham

PAGE 5 (1963)

1 Shakespeare and some dealings by --
2 (Brief pause in the proceedings.)
3 BY MR. PRUNER (resuming):
4 Q We're here to take a sworn statement from
5 you in an ongoing investigation into the death of
6 Abraham Shakespeare and some dealings conducted by a
7 person by the name of Deedee Moore and Howard Stitzel
8 and others. Did you know a person by the name of
9 Howard Stitzel back in February of 2009?
10 A Yes.
11 Q Can you tell me approximately how long
12 you had known him?
13 A I've know him since I came to work for
14 Mr. Buzbee. Actually, when Mr.Buzbee is out of state,
15 I actually used Howard to go over my documents, sign,
16 so we had a close interactions all the time with Howard.
17 Q So you were familiar with him by name and
18 by sight and by working with him?
19 A Oh,absolutely.
20 Q And did you know Deloris, or her name is
21 not Deloris but Deedee Moore?
22 A Yes.
23 Q And how was it that you first came into
24 contact with her?
25 A Not personally, it was only on a business

PAGE 6 (1964)

1 basis. And the first time I actually met her was
2 February 11th.
3 Q Of 2009?
4 A 2009, yes.
5 Q Okay. Let's talk about that date of
6 February 11th of 2009. Did you see Mr. Stitzel on that
7 day?
8 A Yes.
9 Q When and where and tell us about the
10 circumstances.
11 A We start work at 8:30. When I got here
12 him and Deedee was in the parking lot in a black
13 Mercedes. And as soon as I got out of the truck, of
14 course, he got out to meet me, and that's when he
15 explained that he needed my help to prepare a bunch of
16 documents.
17 Q Okay. Was he the driver of that vehicle?
18 A NO, Deedee was.
19 Q Okay. I'm sorry. And so he approached
20 you outside the office or inside?
21 A At first it was outside because I was
22 walking up and he was just explaining why he was
23 waiting for me out there.
24 Q Okay. And did that, the fact that he
25 showed up early that morning to make that kind of

PAGE 7 (1965)

1 request, was that alarming to you or unusual?
2 A No, not for-- no, because we work
3 closely with Howard.
4 Q Okay. So did Mr. Stitzel come into the
5 office?
6 A Yes.
7 Q And did he request that you perform any
8 type of legal work for him?
9 A Yes.
10 Q Tell us, tell me about that.
11 A Okay. We done Deedee or Dorice Moore's
12 divorce. We did every document start to finish, an
13 uncontested divorce, and then we prepared two deeds, an
14 Assignment of Mortage and a Promissory Note.
15 Q Okay. Let's I guess talk first about the
16 uncontested divorce.
17 A Okay.
18 Q I have a stack of documents here that you
19 just presented to me a few minutes ago before we
20 started and we'll attach these as Exhibit A to the
21 sworn statement.
22 (The document referred to was
23 marked as State's Exhibit A for
24 identification.)
25 BY MR.PRUNER (resuming):

PAGE 8 (1966)

1 Q Does this stack of documents comprise all
2 those documents that you prepared for Mr. Stitzel at
3 his direction in Dorice D. Moore's uncontested divorce?
4 A Yes.
5 Q Okay. Was there anything unusual about
6 either the documents as Mr. Stitzel had instructed you
7 to prepare them or about the contents?
8 A Actually it was a pretty standard
9 uncontested divorce. There was a few issues that I,
10 that we did change up and I can show you really quick.
11 Q Okay.
12 A All of these are very standard documents
13 except the only thing that we modified was this Joint
14 Stipulation for Waiver of Mandatory Disclosure. In an
15 uncontested divorce we can waive everything that's
16 mandatory disclosure except for a Financial Affidavit.
17 And I told Howard that, and he said, "NO,
18 waive it." And I said, "Well, I don't know the
19 language to waive it because it's not something we can
20 do." And then this right here, he read that off to me.
21 And this is what we changed because he didn't want to
22 do the Financial Affidavit. And I started questioning
23 because I'm like --
24 Q Okay, hold on one second. I'm sorry.
25 A Oh.

PAGE 9 (1967)

1 Q And when you say "this right here" you're
2 referring to enumerated paragraph number one on a
3 document entitled Joint Stipulation for Waiver of
4 Mandatory Disclosure?
5 A Yes.
6 Q And that language in paragraph number one
7 reads, "Any and all Financial Affidavits required
8 pursuant to Florida Statutes 61.et.sequeter and the
9 Florida Family Law Rules of Civil Procedure"?
10 A Yes.
11 Q Okay. And you're indicating that is out
12 of the normal practice for preparing an uncontested
13 divorce and its documents?
14 A Yes.
15 Q And educate me. Financial Affidavits
16 would include what?
17 A All your assets and liabilities.
18 Q And is your understanding that in this
19 type of uncontested divorce both parties to the
20 uncontested divorce would have to make such formal
21 complete financial disclosure?
22 A Yes, they do.
23 Q Okay. Had you ever prepared any such a
24 waiver of Financial Affidavits and disclosure in any,
25 in your many years of being a legal secretary or legal

PAGE 10 (1968)

1 assistant?
2 A The waiver, yes. Actually waiving the
3 Financial Affidavit, no, that was something that we
4 don't, it's not allowed. You have to file it.
5 Q Okay. And I interrupted you. You were
6 going on with your explanation of this document and
7 that morning. Tell me about any other unusual
8 procedures or contents of these documents.
9 A Whenever -- because we first started with
10 the divorce, so, but I started, but he'd also just
11 mentioned this other stuff so I knew that there was
12 property involved, so I questioned him and the fact of
13 why we were waiving the financial.
14 Q Howard Stitzel?
15 A Yes, Howard Stitzel. And he just told me
16 that it was his law license and to not -- because I was
17 worried about Mr. Buzbee, even though Mr. Buzbee,
18 because he had no knowledge of this.
19 Mr. Buzbee was not in the office. He
20 wasn't scheduled to be in yet. And I actually had
21 already told Howard that but Howard said, "It's okay, I
22 just need you."
23 Because when you're starting to waive
24 something I knew was wrong, I was like, I was worried
25 about Mr. Buzbee. And he said no, this is his law

PAGE 11 (1969)

1 license, it was going to be his bar number on the
2 bottom of each paper.
3 Q Meaning Mr. Stitzel's?
4 A Yes.
5 Q Okay. Was Ms. Moore in the office at the
6 time of the creation of, drafting and creation of these
7 divorce documents?
8 A No, she was not. She stayed in the
9 parking lot, and that was what was really weird. He
10 kept, every time I had a question as far as what the
11 child's Social Security number was or the child, where
12 the child was born, because that's some of the things
13 that I need in these documents, he wouldn't know it so
14 he would have to run out and ask her.
15 And at one point, and how I know it was
16 actually Deedee in the vehicle was Howard was taking a
17 really long time out there. So I went out to the car
18 and I had asked her some questions that I needed for,
19 you know, to finish the paperwork. I just figured it
20 was faster and get'er done.
21 Q Did either Howard Stitzel or Deedee Moore
22 ever give you an explanation of why she just didn't
23 come inside?
24 A No, and I didn't ask. I just figured it
25 was not his law office so he didn't want to take it

PAGE 12 (1970)

1 over like it was.
2 Q Is that -- had you seen her before that
3 day?
4 A No. No, I have not.
5 Q Have you seen her since that day either
6 in person or on any media reports or anything?
7 A No, I've not seen her in person. No.
8 No.
9 Q Did she -- did you address her as Deedee
10 or Ms. Moore when you went out there?
11 A Yes. Yes, I did. Because I assumed it
12 was her being the fact that that's whose paperwork and
13 she had the answers that I needed.
14 Q Okay. Have you seen her on the
15 television news in the last several weeks?
16 A Yeah, the internet.
17 Q And from seeing the published photos of
18 Ms. Moore on the Internet or published news accounts,
19 are you certain then that the person who was sitting in
20 the Mercedes outside of Mr. Buzbee's practice or office
21 on February 11th of 2009 was, in fact, Dorice Deedee
22 Moore?
23 A Yes.
24 Q Okay.
25 A She was a lot cleaner and, I mean, she

PAGE 13 (1971)

1 was a very well-kept person back then. I mean her --
2 she doesn't look quite as kept now but --
3 Q So when you confronted Mr. or asked
4 Mr. Stitzel about the waiving of the Financial
5 Affidavits, he responded in words or substance that it
6 was his law license and his bar number and not 7 Mr. Buzbee's?
8 A Uh-huh.
9 Q Is that correct?
10 A Yes, sir.
11 Q What did you take that to mean or how --
12 A I didn't take it any way. I just took it
13 that I knew it was wrong so I questioned it and he just
14 assured me, because Mr. Buzbee didn't know what we were
15 doing and I didn't have time to clear it through him.
16 I mean, is it customary that we would, I
17 would help Howard or any other attorney in the past?
18 Absolutely.
19 Q Sure.
20 A They were friends. It's very common.
21 I'm a paralegal. I can actually do this back and forth
22 all day long with no attorney here and just have them
23 proof it.
24 Q All right.
25 A It just, it started getting -- and to

PAGE 14 (1972)

1 give the whole picture of the day Howard come in in
2 shorts, a buttoned-up Hawaiian shirt, and it was --and
3 the reason I know, explicitly remember, because it was
4 really big on him.
5 And there was rumors flying about Howard
6 about drugs and stuff. So, of course, being me
7 thinking I'm on a friend level with him, we actually
8 talked about it, about drug use, and he brought to
9 light all of his weightloss and everything. So --
10 Q Did he acknowledged having a drug problem
11 at that time?
12 A No, what -- we didn't talk explicity. I
13 never said, "Do you," what it was was there was some
14 characteristics that day. Like he had some sores on,
15 I'm no, I'm not, I don't know everything about drugs
16 but I'm not ignorant either, he had some sores on his
17 arms. He would sit there while we were doing this and
18 as he would get really nervous and go (indicating).
19 Q You're showing me he would pick at his
20 forearm?
21 A Yes, he would. Yeah, like, there was
22 like a little sore there. There was like two or three
23 actually. And he drank, I'll never forget it, he drank
24 two Cokes and ate two bags of chips while he was here
25 while I did this paperwork. I mean, he was like really

PAGE 15 (1973)

1 hungry and thirsty, and I was like wow.
2 Q Was there any other unusual provision in
3 these divorce documents that you prepared for
4 Mr. Stitzel on that day?
5 A when we prepared them he asked me to
6 prepare, he asked me to look up with the judge what was
7 the next uncontested dissolution date. I did and I
8 prepared -- there was, you have to have 20 days from
9 the day you file it to the day you can have a final
10 hearing, so the next available date I could get it on
11 was March 11th.
12 That was 30 days from the day I was
13 preparing it. And that was, and I explained to Howard
14 that's if the husband had to sign these and it has to
15 be filed 20 days before. So I gave him a ten-day
16 leeway to get all that done before this hearing.
17 And I also brought up the fact that they
18 have to have a parenting class. I said, "That's a
19 really short notice to get a parenting class done."
20 But I know Judge Sexton, she wouldn't agree to this
21 divorce without it, so I went ahead and done the Notice
22 of Hearing.
23 He said, "Well, if I can't get it done I
24 won't file it." And when I looked it up after the fact
25 he didn't file this. He actually had a different date

PAGE 16 (1974)

1 so --
2 Q Okay. As far as the Notice of Hearing?
3 A Yes.
4 Q Okay. Did Mr. Stitzel sign any of these
5 divorce documents in your presence?
6 A No.
7 Q Did Dorice Deedee Moore sign any of these
8 divorce documents in your presence?
9 A No, because I would not notarize so he
10 didn't bring her in.
11 Q All right. And do you have any personal
12 knowledge as to whether you or the Law Office of Jim
13 Buzbee received any compensation for preparing these
14 divorce documents?
15 A No, we did not.
16 Q Okay. And as far as you knew, in
17 February 11th of 2009 was Mr. Stitzel or Ms. Moore a
18 client in any fashion of the Law Offices of James
19 Buzbee?
20 A No.
21 Q He was not?
22 A No.
23 Q And she was not?
24 A No, neither one has ever been a client.
25 Q Okay. You've also indicated that on that

PAGE 17 (1975)

1 date you prepared, at Mr. Stitzel's request and
2 direction, a number of documents, Quitclaim Deeds, an
3 Assignment of Mortages, is that correct?
4 A Yes, and a Promissory Note.
5 Q Okay.
6 A I was fixing to say something about, oh,
7 if you, and to back this up, if you need the proof of
8 the day that this, how I know the exact day all this
9 stuff was done is our computer date stamps something
10 when it's done. The software we use, it's called Pro
11 Doc.
12 Q Sure.
13 A So that's how I know exactly what date
14 all this was done.
15 Q All of these documents that we're talking
16 about?
17 A Yes. Now, the deeds and stuff, no,
18 because we don't do them in the software. I actually
19 do my own deeds outside the software. And the thing is
20 on that, the computer crashed so I don't have the exact
21 date stamped on these. That's why I printed off the
22 executed copies because, now, I've got the computer
23 still here. So I don't know if you all, that's very
24 evident if you all need it but --
25 Q That's all right. But is it correct

PAGE 18 (1976)

1 that all these Quitclaim Deeds that you've presented to
2 me this morning and the Assignments of Mortage were
3 all done on the same date?
4 A Yes, they were. Because after this it
5 was over, and I told Mr. Buzbee about him being in here
6 and me doing this, we were -- I was very well-advised
7 to never do it again.
8 Q I see. Let me show you what you've given
9 me a few minutes ago, a document entitled Quitclaim
10 Deed which is stamped by the Clerk of Court's Office as
11 instrument number 2009022815.
12 A Yes.
13 Q Okay. Did you prepare this document?
14 A Yes, I did.
15 Q At Mr. Stitzel's request and direction?
16 A Yes, I did.
17 Q And tell me about it. Anything unusual
18 about the preperation of that document?
19 A Actually, yes, there was two things.
20 Instead of us re-typing the full legal, he had the
21 legal on another piece of paper and said, "Just put it
22 as attached, an attached legal." We did that.
23 The second thing was is he, whenever I
24 originally had went into the Quitclaim, it had January
25 on it and I changed it to February. He says, "No, no,

PAGE 19 (1977)

ACR NOTE: 2009022815 = 1418 W Lake Parker Drive, Lakeland, FL 33805
http://www.acandyrose.com/deutsche-shakespeare.htm

1 leave it to January." So I went back and put it back
2 to January. I knew immediately that was wrong and I
3 would never --
4 Q And why is that wrong?
5 A Because I knew it wasn't -- there was no
6 way the deed could be executed on a January date when
7 it was already February 11th.
8 Q Okay. But at Mr. Stitzel's insistence
9 you did put the date of January 11, 2009.
10 A No, I did not. I did not put the 11th.
11 That was wrote in by the notary or someone.
12 Q I see.
13 A I put January, 2009.
14 Q I see. Is there anything else? Is
15 there, is it unusual for the legal discription of the
16 property to which the Quitclaim Deed applies to be on a
17 separate piece of paper other than the body of the
18 actual Quitclaim Deed?
19 A No, that's actually -- I've seen it done
20 multiple times. That I really didn't question as
21 wrong.
22 Q Okay. Did you have any personal
23 knowledge of any of the information set forth in this
24 document?
25 A No. All I knew it was, I had to

PAGE 20 (1978)

1 specifically ask where the property lied because that's
2 where you have to put this, and that's the only way I
3 knew it was even property in Polk County.
4 Q Okay. Had you ever had any contact with
5 Abraham Shakespeare about this document?
6 A No, I had not.
7 Q And for the record this Quitclaim Deed,
8 the instrument number that I've referred to a minute
9 ago, will be attached to the sworn statement as Exhibit
10 B.
11 (The document referred to was
12 marked as State's Exhibit B for
13 identification.)
14 BY MR.PRUNER (resuming):
15 Q Was this document signed by anybody in
16 your presence?
17 A NO, it was an unexcuted document when it
18 left here.
19 Q Did you have anything to do with the
20 filing of this document?
21 A No, I did not.
22 Q Or the recording?
23 A No, I did not.
24 Q Okay.
25 A It was, the only thing I can say is they

PAGE 21 (1979)

1 was here at 8:30. It took us approximately a couple of
2 hours to finish all the paperwork, and it's recorded at
3 3:15 on the same day that I prepared it.
4 Q And you know that by looking at the
5 stamped information up in the upper right-hand corner
6 stamped by Richard M Weiss, Clerk of Court in Polk
7 County?
8 A Yes, sir.
9 Q Okay. There is a notary page, the second
10 page of this cumulative document, Leah King, what looks
11 to be Leah D. King. Does Ms. King, did Ms. King work
12 for the Law Office of Jim Buzbee at that time?
13 A NO, I'm not aware of who she is.
14 Q. Okay. So did you prepare that notary
15 page, page 2?
16 A I am not completely sure because this is
17 a generic --
18 Q Okay.
19 Q --notary. If you'll notice, this notary
20 doesn't specify what it's notarizing, which is very odd.
21 to me whenever I looked at this recorded document
22 because immediately I started looking at different
23 little points.
24 And it, well, it does say, in fact, deed
25 first thing, so, yes, actually then this one is

PAGE 22 (1980)

1 probably a good valid notary.
2 Q Okay.
3 A Except for the date.
4 Q Anything else about this document that
5 you found interesting or unusual?
6 A No, it was pretty standard. When he come
7 in it was simple. He just said, "Attach this one." We
8 used his home address at the time because he did not
9 have an office. That's when he told me that him and,
10 which I had already kind of knew that he wasn't with
11 Byrd & Stitzel anymore simply because I was at the gym
12 a couple of, you know, in January.
13 I seen the signs come down that night and
14 I was like, I kind of thought that was, I'm like, oh,
15 there's something going on over there.
16 So when he come in that day and, like I
17 said, we talked about all of it and he told me that, he
18 told, he flat out told me that when he finished these
19 documents this was the start of his new law office.
20 And one of the papers that you won't find
21 here that, because it's not recorded and, like I said,
22 the computer crashed, is a Promissory Note. I did a
23 Promissory Note for him from, it was the Abraham
24 Shakespeare something, it wasn't him personally.
25 Q LLC?

PAGE 23 (1981)

1 A Yeah. It was a business. It was for
2 $30,000.
3 Q And tell me what that document set out.
4 A It was just a Promissory Note.
5 Q From whom to whom?
6 A From Abraham Shakespeare to or from, I'm
7 sorry, it would be from Howard, D. Howard Stitzel to
8 Abraham Shakespeare, LL whatever, I don't remember.
9 Q LLC?
10 A Yeah, it was a business.
11 Q Indicating an indebredness from
12 Mr. Stitzel to the Abraham Shakespeare entity?
13 A Yes.
14 Q Okay. And you did type that out?
15 A Yes.
16 Q Was that executed in your presence?
17 A No.
18 Q Did you ever see a recorded copy of that
19 or --
20 A No.
21 Q -- have you ever seen that document
22 again?
23 A No.
24 Q Okay. Any further conversation that he
25 had about this would be the start of his new practice?

PAGE 24 (1982)

1 Did he explain what that meant?
2 A Well, the whole context of the story was
3 we was talking about his drug use. And I had told him,
4 I said, "Howard, why don't you go take a drug test.
5 Don't open it." Because, you know, he was still kind
6 of insisting that he wasn't.
7 Not insisting. He didn't specifically
8 say, "April, I don't do drugs, " but you can tell he was
9 still reluctant to admit anything.
10 So I kind of just told him, because he
11 was talking about all the buzz and all the different
12 attorneys that was letting him down, and, you know,
13 that he appreciated me doing this for him and I didn't
14 turn my back on him, dah, dah, dah.
15 And I said, "Well, why don't you go take
16 a drug test, don't open it, and go to the bar
17 association meeting and put it on the table and let
18 them open it." I said, "It will stop all this." And
19 he was like, "I'm not doing that. No, there's no way."
20 I said, "Well, Howard, you got to admit
21 they're," I said, "You've lost a lot of weight." And
22 he's like, "Well, I've been trying to lose weight."
23 And he says, "I look good, don't I?" And I'm like,
24 he stood up and he turned around for me. And I'm like
25 "Well, you do look good but, you know, there's a lot

PAGE 25 (1983)

1 surrounding the reason why you're losing the weight."
2 And you know, just, we were just talking
3 as friends. We had talked before just, you know, we
4 had a lot of dealings with each other over seven
5 years --
6 Q Sure.
7 A -- over different legal stuff. So, I
8 mean, did he ever tell me his personal family life?
9 No, but --
10 Q Did he tell you anything on that date or
11 in any other conversation about his relationship with
12 Deedee Moore, his business or legal relationship with
13 Deedee Moore or personal relationship?
14 A No. It was just that this, the only
15 thing, like I said, the only thing was that when he
16 finished all this for Deedee, because that's who
17 brought him here, whenever we finished this this was --
18 he just kept assuring me that this was the start of
19 his, that he was going to get back on his feet and he
20 was going to show everybody.
21 Because like I told Howard, I respected
22 Howard as an attorney. Howard was a very smart
23 attorney when he was in his day before he got messed
24 up. I mean, if I didn't know how to do something or
25 wording I could call Howard, if he was in the office he

PAGE 26 (1984)

1 could tell you wording off the top of his head. I
2 mean, he was good in his day.
3 Q Did he tell you anything about the
4 $30,000 that he was to receive that was evidenced by
5 this Promissory Note?
6 A No, he just said that was what, how he
7 was going to restart his law firm.
8 Q With the funds that were documented by
9 that Promissory Note?
10 A Yes. And it wasn't recorded so I don't
11 know if they didn't follow through with it or what.
12 But he just said that when he finished this stuff that
13 he was going to be back on his feet.
14 Q All right. Anything else about this
15 Quitclaim Deed or the conversation pertaining to it
16 with Mr. Stitzel that we haven't talked about?
17 A. No, unless you want to talk about after
18 fact things.
19 Q Well, go ahead.
20 A Not at the time we recorded it, like I
21 said, it was an unexecuted document. Now, if you go
22 back and you look, that's why I wanted to print this.
23 Okay. When Howard left here that day I noticed --
24 Q Okay. Excuse me for interrupting again.
25 A Okay.

PAGE 27 (1985)

1 Q When you say "this" you're referring to a
2 copy of a Quitclaim Deed which we'll identify and
3 attach to this sworn statement as Exhibit C.
4 (The document referred to was
5 marked as State's Exhibit C for
6 identification.)
7 BY MR. PRUNER (resuming):
8 Q That is in the form that the Law Offices
9 of Jim Buzbee uses and that you prepared, is that
10 correct?
11 A No.
12 Q No?
13 A Exhibit C is a Quitclaim Deed prepared by
14 the Law Offices of Byrd & Stitzel.
15 Q Okay, I see. Okay. And, go ahead and
16 explain.
17 A After he left here and I knew -- I didn't
18 know who Abraham Shakespeare was, of course, I didn't
19 know until I seen it on the or read it on the newspaper
20 that, or on the Internet, that he was even a lottery
21 winner.
22 But after he left, "he" meaning Howard
23 left this office, I called over because the assistants
24 in every law office, we all talk. I mean, we know
25 what's going on. I mean, it's just part of it. So I

PAGE 28 (1986)

1 called over there and I talked to Lori --
2 Q Excuse me, Let me turn this off. Well,
3 let me take this, excuse me.
4 (Phone call interruption.)
5 BY MR. PRUNER (resuming.):
6 Q You were going to explain or were in the
7 process of explaining Exhibit C, the Quitclaim Deed,
8 and make observations by comparison with Exhibit B.
9 Please, continue.
10 A Okay. As I said, when I left here it was
11 an unexecuted document. But with everything going on
12 and knowing the way he was when he was here and the
13 drug speculation, the first thing I did, of course, was
14 call Lori Collins at Stitzel & Barnhill at the time,
15 now it's Stitzel & Barnhill or, I mean, Byrd 7
16 Barnhill.
17 And she had told me that the last day he
18 worked over there was January the 18th. And that's
19 what led me to speculate that he back-dated this to
20 January the 11th, which is exactly 30 days before I
21 did. It throws it back to the time he was actually
22 there in a law firm verus nowhere.
23 And I just explained the way he was, and
24 she just told me, yeah, that's why he was kicked out of
25 there, not showing to court and stuff like this. So,

PAGE 29 (1987)

1 and, but if you look, his signature here to there,
2 they're different. they're nowhere near the same.
3 Q Who? What signature of whom?
4 A Abraham Shakespeare. The characteristics
5 are nowhere near the same. The slants are different,
6 they're --
7 Q and this Quitclaim Deed, Exhibit C,
8 prepared the 9th day of January 2009 is the document
9 that you're using to compare Mr. Shakespeare's
10 signature, is that right?
11 A Uh-huh. Yes, sir.
12 Q And who is the lady that you spoke with
13 at --
14 A Lori Collins, she's the notary on that
15 Quitclaim Deed.
16 Q Exhibit C, the Quitclaim Deed?
17 A Yes, sir.
18 Q Okay.
19 A And, of course, their assistants are no
20 longer there. They let both, they let all of their
21 assistants go at Barnhill because of it being, it got
22 really slow for all law firms so, unfortunately, they
23 lost --
24 Q So Ms. Collins --
25 A Both of these, both of these witnesses on

PAGE 30 (1988)

1 the deed, Exhibit C, were actually the legal assistants
2 at that office.
3 Q Oh, so Lori Collins is not there any
4 longer?
5 A No. Unfortunately, she lost her job.
6 Q Have you heard through the grape vine if
7 she's employed?
8 A Actually she called me after she got laid
9 pff and gave me her cell number so if I ever heard of
10 another, you know, attorney. And I -- it's somewhere
11 in my office. I --
12 Q Okay. Maybe we'll talk about that after.
13 A I didn't think I should call her now. I
14 don't want to mess any waters up anywhere.
15 Q No, I appreciate that. Let me go back to
16 Exhibit B, this Quitclaim Deed. Did either -- well,
17 you've indicated earlier that nobody attached any
18 signatures to that document?
19 A No, sir, no document.
20 Q Do you know of an indiviual by the name
21 of Doug Hancock who appears to be one of the witnesses?
22 A No, sir. It looks kind of bogus to me.
23 And the reason I say, if you look at his signature on
24 the same day he executed the two deeds that left our
25 office, they're not the same.

PAGE 31 (1989)

Abraham Shakespeare Case
02/08/2010 - Transcript of Sworn Statement
by April R. Taylor
09/16/2010 DISCOVERY BINDER #5 PAGES 32-61

1 Q What's not the same, ma'am?
2 A The way that he -- it looks like somebody
3 tried to forge a name or tried to come up with a name
4 because there's no, the consistency is not there. Look
5 at the point in the R, there's no point. You know, it
6 looks like they tried to come up with a name.
7 Q Oh, I see. Okay. Anything else about
8 Exhibit B or C that you think is significant or odd?
9 A No, sir. No, sir.
10 Q Okay. And again, the Law offices of Jim
11 Buzbee or you individually did not, were not,
12 compensated for the preperation of Exhibit C, is that
13 correct?
14 A No, we were not.
15 Q Okay. Let me show you a document that
16 will be attched to this statement as Exhibit D, a
17 Quitclaim Deed on the upper right-hand corner bearing
18 instrument number 1009011816.
19 (The document referred to was
20 marked as State's Exhibit D for
21 identification.)
22 BY MR. PRUNER (resuming.):
23 Q Did you prepare this document at
24 Mr. Stitzel's request and direction on the 11th of
25 February 2009?

PAGE 32 (1990)

1 A Yes.
2 Q Okay. Is there anything about this that
3 you'd like to comment on or any information?
4 A The only thing, as I said, that he had me
5 do on both these deeds is the date.
6 Q And the document indicates the blank day
7 of January as you prepared it, correct?
8 A Correct. But it was done February the
9 11th.
10 Q And about that you have no uncertainty?
11 A No, there is no uncertainty. I know it
12 was done that day.
13 Q Okay. Did you have any personal
14 knowledge about any of the information contained in the
15 document?
16 A. NO. No, sir, there again, because most
17 of the stuff we do is Hillsborough County so I had to
18 verify, again, verify which county. That's how I know
19 it was Polk County at the time because that's not most
20 of our divorces that we're doing these deeds in. And
21 see, if you'll notice, they're Quitclaim Deeds, not
22 Warranty Deeds.
23 And they're Quitclaim Deeds because most
24 of the time in a divorce we're doing it by Quitclaim
25 Deed and I know a lot more about a Quitclaim than a

PAGE 33 (1991)

1 Warranty. A Quitclaim is really not near as good as a
2 Warranty Deed. And they should have been a Warranty
3 when you're transferring outside of people that's not
4 kin like that, but --
5 Q And educate me why. Why is it better to
6 use a Warranty rather than a Quitclaim Deed?
7 A I don't know all the legal things of how
8 you would say it, but I just know that Mr. Buzbee has
9 always taught me in a divorce when we're just taking
10 one person's interest, like both people have an
11 interst in this property and you're only taking one
12 person off so, therefore, it's still within the same,
13 like, start.
14 So kind of you can do the Quitclaim
15 verus if you're having parties over here that has it
16 and you're transferring it way over here to. So, no,
17 there's no reason, there's no connection, it's just a
18 flat out transfer, it would be a Warranty Deed.
19 Q I see. Okay. And again --
20 A And he didn't ask me to do a Warranty or
21 a Quitclaim, he wanted deeds so naturally I'm going to
22 do a Quitclaim Deed because I have them stored in my
23 computer because of divorces. Whereas, Warranty Deeds
24 the language is a little different, so I didn't want to
25 go through because I'm no really good at the words

PAGE 34 (1992)

1 that's in Warranty Deeds and to which ones have to be
2 changed every time you do a new deed, whereas, a
3 Quitclaim Deed I can pull one up and I know exactly
4 throughout all this what I have to change.
5 Q I gothcha. And again, this document, this
6 Quitclaim Deed, Exhibit D, was not signed in your
7 presence by any of the individuals, Mr. Shakespeare or
8 the witnesses?
9 A No, it was not.
10 Q And the notary, Leah D. King, was not
11 present and did not execute the notary in your
12 presence, is that correct?
13 A No, she did not.
14 Q Okay. Anything about this Quitclaim Deed
15 that we haven't spoken about that's interesting or
16 siginificant in your mind?
17 A Basically you're looking at the same
18 things. I mean, it's all after the fact. After, you
19 know, things you immediately start looking at the
20 signatures. And even this signature to the one that is
21 the same one that I prepared, executed on the same day
22 are different.
23 Q Okay. Did you know anything about
24 Shakespeare & Associates, LLC or American Medical
25 Professionals, LLC?

PAGE 35 (1993)

1 A No. No, he had to give me all of that
2 because I didn't know. Like I said, I knew, I can
3 remember because, unfortunately, Shakespeare is a name
4 you don't forget.
5 Q Right.
6 A So when he was in here I knew the names.
7 And that's just like, when we go to the next document,
8 the Assignment, I can tell you from my, I mean, my
9 memory I know for a fact that this is the particular
10 document that we done because of the name. The name is
11 one that it's just it sticks out there.
12 Q Okay. As to Exhibit D, did you learn
13 from Mr. Stitzel, or any other person that day, of
14 Ms. Moore's, Deedee Moore's relationship with American
15 Medical Professionals?
16 A Just what he was telling us while he was
17 here.
18 Q what did he say about that relationship?
19 A Just that this, it was all in the same,
20 Deedee Moore owned American Medical Professionals and that was
21 part of the reason we were doing these documents.
22 And because I had done this also, and he
23 had briefly told me before we started doing the
24 documents in the divorce that's how I knew he had to
25 have a financial in that, in that divorce because I

PAGE 36 (1994)

1 knew she had property.
2 Q Okay.
3 A And that's why I questioned, you know,
4 you got to have that financial because the husband's
5 entitled to half of anything she owns. I mean --
6 Q So you're indicating that these deeds
7 indicate that Ms. Moore had property interests that
8 were not, that should have been reported in a Financial
9 Affidavit attached to these divorce documents?
10 A Correct. And that's why he was trying to
11 hurry the divorce because to get it filed before she
12 gained the interest in it. But for some reason they
13 felt it very -- a need to record these on the same day
14 they prepared them. They didn't --
15 Q Is that unusual?
16 A Well, yeah. I mean, knowing what he was
17 trying to do over here I would have thought why are you
18 recording this deed so fast when if you're trying to
19 hide it from your husband to not split it up. That's
20 what I thought it was in the beginning. That's why I
21 was trying to tell Howard you can't do this what you're
22 doing without that.
23 Then that's why I was like -- but he
24 back-dated it. So I was like, "You've gotta tell,
25 you've gotta do that Financial Affidavit, " that it

PAGE 37 (1995)

1 didn't make sense. But there again, I knew it wasn't
2 Mr. Buzbee or me and I was never going to execute these
3 documents.
4 Q So was it your thought that what didn't
5 make sense was that he was back-dating these Quitclaim
6 Deeds which was inconsistent with what you thought was
7 his motive concerning the divorce documents --
8 A Yes.
9 Q -- which was to hide assests?
10 A Yes.
11 Q Okay.
12 A Yeah. It didn't make sense he was trying
13 to do two things. It was like he was trying to do two
14 things. But you can't put the cart before the horse if
15 your goal here is that.
16 Q Did Mr. stitzel on that date or Ms. Moore
17 ever indicate to you why Mr., why Shakespeare &
18 Associates was transferring the properties and the
19 mortage, the Assignments of Mortage to American
20 Medical Professionals?
21 A No, he never said and I didn't, honestly
22 question. I was because of my background in legal,
23 I've done divorce for ten years --
24 Q Yes.
25 A -- I was so focued on the divorce and

PAGE 38 (1996)

1 what was wrong there that, honestly, this is just other
2 stuff to me.
3 Q Okay. Did he ever speak about an Assets
4 Purchase Agreement that Deedee Moore or American
5 Medical Professionals had executed to Abraham
6 Shakespeare?
7 A No.
8 Q Or Shakespeare & Associates?
9 A No.
10 Q Or Shakespeare, Abraham Shakespeare, LLC?
11 These are all different entities.
12 A Yeah. See, no, he -- I didn't know, like
13 I said. Any of the business things that you see on
14 here is what he had me do. And if you'll notice on
15 these Assignments of Mortage, which will now be I
16 guess E and F or E --
17 Q Okay. Let's look, let's move on to that.
18 We'll designate as Exhibit E for this sworn statement
19 Assignment of Mortage which is indentified as
20 instrument number 2009058786 -- is that my hand shaking
21 so much -- as stamped by the Clerk of Court in Polk
22 County, and Exhibit F, an Assignment of Mortage,
23 instrument number, as indicated in the upper right-hand
24 corner, 2009058784
25 (The documents referred to were

PAGE 39 (1997)

1 marked as State's Exhibits E and F
2 for identification.)
3 BY MR. PRUNER (resuming):
4 Q Okay. You prepared at Mr. Stitzel's
5 request and direction both of these two Assignments of
6 Mortage, is that correct?
7 A Yes.
8 Q And neither of these documents were
9 executed in your presence, is that correct?
10 A No, sir, they were not.
11 Q Okay. Tell me about these documents. Is
12 anything unusual or --
13 A The only thing I can tell you that is way
14 off was is he had me take off a notary. He had me take
15 it off. That's why you see half this page is blank
16 right here and this is moved down.
17 Q On Exhibit F?
18 A Yes. Because I was trying to even up the
19 page because he had me take the notary off, and you
20 don't do that.
21 Q Take a portion of the documents where the
22 notary would notarize the signatures?
23 A Yes.
24 Q He did not -- or you did that at his
25 direction on both Exhibits E and F?

PAGE 40 (1998)

1 A Yes.
2 Q Okay.
3 A E and F was, yes, they were done exactly
4 the same. All I, when I run it, all I did was just do
5 it the first time and then I just changed the name in
6 the OR book and page.
7 Q Now, on Exhibit F there is attached to
8 this document a notary page, is that correct?
9 A Yes, there is. But that was not on here
10 when it left here.
11 Q Okay. So you prepared --
12 A And this should not be. When you're
13 doing these legal documents you should not have a
14 notary on a full page by itself when you've got this
15 much space. It should be -- there was one here but I
16 took it off.
17 Q Did you ask Mr. Stitzel about why he
18 wanted that off?
19 A Yes.
20 Q What did he say?
21 A Yeah, because I was, I knew 100 percent
22 that was wrong.
23 Q Okay.
24 A And there again, he just said, "Just
25 do --" he said, " Just do it. I'm going to take care of

PAGES 41 (1999)

1 all this." "Okay, you take care of it." But I knew
2 that was wrong.
3 Q And when you say it's wrong, is it just
4 wrong as a matter of form or is there some, some
5 additional --
6 A You have to have a notary on an
7 Assignment because that person is assigning, you're
8 assigning a debt or an asset or whatever you're
9 assigning whether it be, this happens to be a mortage,
10 but you're giving something away.
11 Q And if the notary portion of the document
12 is on the same page as the actual assignment language,
13 is that done so that there is no doubt that the notary
14 is --
15 A Yes, that that notary actually, actually
16 notarized this document.
17 Q This document?
18 A Right. Now, this notary that's attached,
19 she doesn't even acknowledge what she notarized. So
20 really this notary could have been taken off of any
21 document and placed onto there.
22 Q And you're referring to the notary page,
23 the second page on Exhibit F, correct?
24 A Yes, I am.
25 Q And there is no description for, in the

PAGE 42 (2000)

1 language, "I hereby certify," what document the
2 signature is placed on that she's notarized, is that--
3 A Right.
4 Q Okay. And does that --
5 A And there again, this has a notary date
6 of January the 16th. That notary date is on nothing
7 else anywhere. I mean, that date -- because look. Oh,
8 he put the 16th in there.
9 Q Okay.
10 A And the one thing that I have to question
11 on this doucment, like I said, when it left here it was
12 blank, is this address. I'm not sure where that
13 address is.
14 Q You mean the "607 South Alexander Street,
15 Suite 205 South" up in the upper left-hand corner of
16 Exhibit F?
17 A Yes, sir.
18 Q Okay.
19 A Because when we prepared all the
20 documents Howard game me his home address, and I'm not
21 sure if, I cannot remember if he put, had me put that
22 on there that day or if he took that document from here
23 and changed it hisself.
24 Q Okay. Is there any different font or
25 anything that you could tell?

PAGE 43 (2001)

1 A No, it doesn't look like a different
2 font. The notary is definitely.
3 Q Sure.
4 A The notary is not the same color, not the
5 same nothing. I mean, that notary was definitely
6 attached from another document but --
7 Q Okay. Pertaining to Exhibit F, the
8 individuals, it's hard to, well --
9 A That's Howard Stitzel.
10 Q Howard Stitzel indicates he's witnessing
11 the Assignment of Mortage?
12 A Yes.
13 Q And a person whose name is --
14 A That's the notary, Linda Kick --
15 Q Kickliter?
16 A Yes.
17 Q Is it unusual for a notary to also be a
18 witness to the, this document?
19 A Not on some documents. On some documents
20 we can. I'm a notary in this office, and because we
21 only have two girls in this office and Mr. Buzbee,
22 there is times when on certain documents I have to do
23 both, but on certain documents you can't.
24 Q Okay.
25 A Like a Will you can't because you have to

PAGE 44 (2002)

1 self-proof it with two additional witnesses and a
2 notary.
3 Q did you know Ms. Kickliter?
4 A No.
5 Q Okay. On Exhibit E, also witnessed by
6 both Ms. Kickliter and Mr. Stitzel, all of these --
7 A And I did not print the notary page, I'm
8 sorry. I just ran out of time on printing.
9 Q Oh, you mean this morning?
10 A Yes. See, because it's one of two pages.
11 There is a notary page attached to this in the Official
12 Record.
13 Q Okay. You printed these off the Polk
14 County Clerk of Court website?
15 A Yes, I did.
16 Q Okay.
17 A Because like I said, these documents, all
18 of the real estate documents that you see, the deed,
19 the Promissory Note, which I did not find recorded
20 which I know I did that day and these Assignments was
21 on the computer, my computer that crashed. Now, we
22 saved the hard drive. I don't know.
23 Q Okay.
24 A I mean, if date is that important it's
25 there.

PAGE 45 (2003)

1 Q Okay. And both yours, as you've
2 indicated before, you're certain that these documents
3 were prepared by you at Mr. Stitzel's instruction and
4 direction on February 11th, 2009?
5 A Yes. And I do know because it was only
6 one day. Now, he has called several times since and he
7 asked me, you know, to get coverage, ask Mr. Buzbee to
8 cover a case, you know, cover a hearing or ask me what
9 a judge's number is because he hasn't had a secretary.
10 So there has been multiple times since
11 these documents he's called and asked me, you know, a
12 judge's number --
13 Q Sure.
14 A -- or a court reporter's number or
15 something like that.
16 Q Again, these documents E and F, the
17 Assignments of Mortage, were you either individually
18 or was Jim Buzbee's law firm compensated for your
19 preparation of these documents for Mr. Stitzel?
20 A No.
21 Q Okay. And when they, these documents E
22 and F left your office, none of the signatures were on
23 the front pages of these Assignments, is that right?
24 A No, they were not.
25 MR. PRUNER: Okay, Mr. Delisle, any

PAGE 46 (2004)

1 questions?
2 EXAMINATION
3 BY MR. DELISLE:
4 Q Do you know if he uses anybody else to do
5 what you did for him, any other attorney --
6 A No.
7 Q -- or legal assistants or anything in
8 town?
9 A No. I think he used, he uses me because
10 him and Mr. Buzbee were really good friends prior to
11 this and he knows that I don't question it. And
12 there's been multiple times in the past he can call me
13 and I can do a document.
14 Not saying nobody else in town can
15 because they can. Any legal assistant that's done
16 anything for any amount of time can do it. But he just
17 knows that, he knew that I would do it and not, I mean,
18 question it.
19 Like I say, we were kind of not friends
20 to go out and ever have a drink or anything like that,
21 but, I mean, we were friends enough to where he knew
22 when he called me that I could do this. And he knew
23 Mr. Buzbee's office had the ability and the paper and,
24 you know, everything that it could be done.
25 Q On previous occasions when you've done

PAGE 47 (2005)

1 something for him, were those also at no charge?
2 A Yes, we've never charged.
3 Q So the no charge is just a common
4 exchange between attorneys and friends or whatever?
5 A Right. Because like I say, with
6 Mr. Buzbee if he was out of state on vacation we would
7 have Howard sign like a Notice of Appearance. If we
8 had a case and I just needed to get it on another
9 docket and the judge needed a Notice of Appearance
10 Howard would sign it for us, you know.
11 Q Okay.
12 A It's just we've used other attorneys, you
13 know, also to sign.
14 Q Okay. So it wasn't unusual not to
15 charge?
16 A Oh yeah. No, we never.
17 Q I mean, what I'm trying to get at is he
18 didn't say, "Hey, you know, I don't want to pay for
19 this one, " or whatever, "Let's do this one under the
20 table"?
21 A Yeah, no, there wasn't no trying to hide.
22 Q Okay.
23 A And he knew -- as a matter of fact, he
24 didn't have any money that day. And I can prove I
25 didn't get any compensation because he had to borrow

PAGE 48 (2006)

1 five dollars for gas, which I don't know why because
2 Deedee was out there.
3 At some, at some point, and also because
4 he was here for a couple of hours, Deedee was here when
5 we were doing all the divorce stuff because he had to
6 go out there several times. I even had to go out there
7 and ask a question or two and I just bent down in the
8 door and asked.
9 And I noticed at the time, because I told
10 Mr. Buzbee, of course, when Mr. Buzbee come in, I, Of
11 course, told him what I done. I mean, this is his
12 office, I have to tell him. So I told him, and I even
13 made mention that he was in the car because, with the
14 girl, with the, she was very well-kept, very pretty, I
15 mean, nice.
16 Her hair was, you know, bushy blonde. It
17 was kind of, to me it's an '80's look, not current but,
18 you know, the bushy blonde hair, but very nice clothes
19 black Mercedes, you know, she spoke very well.
20 She, you know, she didn't speak like she
21 didn't know, I mean, she spoke, she carried herself
22 very well, she spoke with authority and like she knew
23 what she was doing.
24 FURTHER EXAMINATION
25 BY MR. PRUNER:

PAGE 49 (2007)

1 Q These two Assignments of Mortage, did
2 Mr. Stitzel indicate to you why Abraham Shakespeare was
3 assigning these mortages to American Medical
4 Professionals?
5 A No.
6 Q Okay.
7 A No. And if you'll notice on all of the
8 newer Assignments that was done by, I'm not, if it's
9 Howard I really don't think so, because all the new
10 Assignments it was basically my assignment because I
11 did this first one, I did it and but she added stuff
12 right here.
13 Q Who did?
14 A Deedee. And she always has it returned
15 to Deedee Moore so that tells me one thing. When you
16 take a document to the clerk's Office for recording,
17 they return it to whoever prepared it unless whoever
18 there drops it off says, "I want it returned to me," so
19 she had to drop these off at the Clerk's Office.
20 That's why it's returned. You see this return?
21 Q Uh-huh.
22 A That's the Clerk's return thing.
23 Q The handwritten "R" next to the name
24 Deedee Moore, Post office Box 433?
25 A Yes. It is customary when an attorney

PAGE 50 (2008)

1 prepares something it always goes back to the attorney
2 because we have to make copies for our files and then
3 we mail the orginial deeds and such back to the client.
4 But we have to have that to finish up our files.
5 Q Now, you indicated that insofar as the
6 divorce documents there were times that day when you
7 went out and spoke with Deedee Moore to obtain
8 information from her, is that correct?
9 A Yes.
10 Q Do you remember what type of information
11 you were getting from her?
12 A Howard come in, he had the date of
13 marriage. I'm just trying to go over in my head that
14 day. And I don't know, I'm -- I've got one of these
15 minds where I remember stuff. It's crazy. I swim in
16 divorces all night long.
17 When he come in he had the standard stuff
18 which every attorney -- and it just, it was kind of a
19 joke to me at the time because what he got is very
20 common of the information Mr. Buzbee gets in a call, in
21 a meeting, and then the client always has to come back
22 to my office because there's always the pieces that
23 they never get. That's why it was a joke to me at the
24 time and I was thinking typical attorney.
25 But, like he didn't get, like, where the

PAGE 51 (2009)

1 child was born. You have to have the county and state
2 in which the child was born. You have to have the
3 child's Social Security, which he didn't have. And
4 that was one of the pieces he went back to the car to
5 get he didn't get. So you'll notice on the child's
6 Social Security number is says "To be produced."
7 It was on -- he had where, I don't think
8 he got where they -- okay. You have to also put the
9 county where they separated, like if it was in the --
10 you have to put, because our county is a big county and
11 it's split by 301, we have to put, if they were
12 separated in the East Division of a county you have to
13 put that it was in the East Division so this judge can
14 handle it. So I had to go ask that, little things like
15 that.
16 Q Okay. Did you have to ask Ms. Moore any
17 questions to complete the documents entitled like
18 Quitclaim Deeds or Assignments of Mortage?
19 A No. She left at some point and was in a
20 car because he had to call her for his, "his" meaning
21 the husband's, address.
22 Q Okay. Did you have any other type of
23 conversation at all that day with Ms. Moore other than
24 what we've talked about?
25 A No. No.

PAGE 52 (2010)

1 MR. PRUNER: Mr. Delisle, I think I
2 interrupted you.
3 MR. DELISLE: No.
4 BY MR. PRUNER (resuming):
5 Q Have you spoken with Mr. Stitzel since
6 February 11th about these several documents that you
7 prepared for him on February 11th?
8 A No.
9 Q How about Deedee Moore, have you ever
10 have a conversation with Deedee Moore since that day?
11 A No. I've never personally had one
12 outside of Howard with her, never.
13 Q Did you ever have any conversation with
14 Abraham Shakespeare about any of these transactions?
15 A No.
16 Q Have you ever met him?
17 A No.
18 Q Have you ever had a conversation at all
19 with him?
20 A No.
21 Q Okay.
22 A The only conversation I've ever had even
23 about him was simply when I called Lori Collins about
24 the documents to, because of Howard, the way things
25 were that day, and that we had done documents for him

PAGE 53 (2011)

1 for Abraham and Deedee. That was it.
2 Q On any other date do you recall ever
3 preparing any type of document for Mr. Stitzel
4 pertaining to American Medical Professionals, LLC that
5 you can recall?
6 A I don't believe so, but we'd have to look
7 back at my computer.
8 Q I see. On any other date did you ever
9 have any conversations with Mr. Stitzel about Deedee
10 Moore?
11 A No. The only other conversations I've
12 had period is -- and her name is one of those weird
13 names and she actually turns out she went to school
14 with my sister-in-law. Well, when she got the big
15 house in Lakeland, she actually called my cousin
16 because they all went to school together, and it was we
17 were all sitting around kind of joking is what it was
18 because she called and wanted everybody's phone numbers
19 and addresses because she wanted to do a reunion party
20 at her house since she got the big house.
21 And I remember my cousin was like, "She's
22 crazy if she thinks," because I guess in school she
23 wasn't that popular. She's like, "I am not giving all
24 these addresses out to that crazy woman." And then
25 months later it was like, whoa, when we heard her name

PAGE 54 (2012)

1 again on the radio.
2 Q Sure. On any conversation did
3 Mr. Stitzel ever describe his relationship with
4 Mr. Shakespeare or anything else about Mr. Shakespeare?
5 A No, never.
6 Q Okay.
7 A I didn't know he had represented Abraham
8 before. I knew, like I said, I knew he was doing work
9 with Deedee, that's why I didn't see no conflict. If,
10 because had I known he had done work for Abraham
11 before, well, we know we can't do paperwork, it's a
12 conflict unless you get a conflict letter.
13 Q I gotcha. Conflict of interest?
14 A Yeah.
15 Q Okay. Does the name Judith Haggins mean
16 anything to you?
17 A Haggins?
18 Q H-a-g-g-i-n-s?
19 A No.
20 Q Okay.
21 A Regans is one of the assignments I done.
22 Q Right.
23 A And that name is just one of those really
24 weird names that you won't forget.
25 Q Did you know Johnnie L. or Joyce V.

PAGE 55 (2013)

1 Regans?
2 A No, because -- well, the reason why,
3 after it was over Mr. Buzbee said that name sounded
4 really familiar to him and he thought we had done some
5 work for Regans. So we had to search out files to make
6 sure that I didn't create a conflict in our office.
7 Q Okay. And I'm looking at the other
8 Assignment, did you know Deborah J. or Ronald J.
9 Knight?
10 A No.
11 MR. PRUNER: Mr. Delisle, anything else?
12 MR. DELISLE: Yeah, just one thing.
13 FURTHER EXAMINATION
14 BY MR. DELISLE:
15 Q Prior to doing these documents for
16 Howard, had you ever prepared document for him before?
17 A Yes.
18 Q Had he ever asked you to alter those
19 documents in the way that you were altering these?
20 A No.
21 FURTHER EXAMINATION
22 BY MR. PRUNER:
23 Q And again --
24 A If I -- the stuff that we had done before
25 it was all just very simple, it was never to this

PAGE 56 (2014)

1 degree. The only reason it was to this degree was
2 because he did not have a law office. And I knew the
3 situation and he -- I feel sorry for the man.
4 Like I said, I respected him as an
5 attorney as far as when he was on his game he was on
6 his game. He's a very smart man. Wording, like
7 Mr. Buzbee is good at grammar things. If you ever have
8 a grammar question Mr. Buzbee's the man. Like it I had
9 a question and Mr. Buzbee was in court about something
10 that was a legal wording, I'd call Howard. Howard was
11 good at it.
12 I mean, and I just respected Howard and
13 that. So when he come to me needing all this work and
14 he was telling me that this is his, this is his, to get
15 back on his feet and he was going to get his law office
16 back and he was going to show Johnnie Byrd. And this
17 is just a personal thing of how I feel about Johnnie
18 Byrd is I just felt like Johnnie took advantage of
19 Howard and took business from Howard.
20 I felt that that was Howard's law office.
21 It was Howard's law office before. I'm sorry, but I
22 just, you know, so that's why when Howard come to me I
23 did it, you know.
24 Q Okay. I don't know if I asked you this
25 about these two Assignments of Mortage, but were you

PAGE 57 (2015)

1 individually compensated or was the Law Office of Jim
2 Buzbee compensated for the preparation of these?
3 A No, nothing.
4 Q Okay.
5 A We gave, actually gave him five dollars
6 and Mr. Buzbee had to give me the five dollars back.
7 Q Do you know how Howard Stitzel left that
8 day?
9 A No, I don't know how he left. But I do
10 know he came, he came back later or either I seen him
11 later that day or something because he was in his
12 Camry, his gold Camry that he drove. He come back in
13 that, which he came back several times after this just,
14 just talking.
15 I mean, he stopped in several times. He
16 felt bad. After this happened there was a tift or
17 whatever and between him and Mr. Buzbee, and that's
18 when we were told to absolutely do no more work for
19 him.
20 But he had called several time for like
21 numbers and stuff and I just told him. So he come back
22 to talk to Mr. Buzbee because he realized that there
23 was something that he needed to talk to him about. It
24 was a personal --
25 Q Sure.

PAGE 58 (2016)

1 A -- tift.
2 Q Kind of an ending question, is there
3 anything you've stated today that you'd like to
4 clarify, add to, correct, delete, modify, or whatever
5 adjective you want?
6 A No. I just want to make it clear that,
7 yes --
8 Q Yes.
9 A -- the documents were done on February
10 11th but they were all unexecuted when they left here.
11 MR. PRUNER: Okay. Thanks for your
12 cooperation today. I appreciate it.
13 THE WITNESS: Thank you.
14 (The sworn statement was concluded at
15 11:04 a.m.)
16
17
18
19
20
21
22
23
24
25

PAGE 59 (2017)

1 CERTIFICATE OF OATH
2 STATE OF FLORIDA
3 COUNTY OF HILLSBOROUGH
4 I, the undersigned authority, certify that APRIL
5 R. TAYLOR personally appeared before me on February 8,
6 2010, and was duly sworn.
7 WITNESS my hand and officiail seal this 22nd day
8 of February, 2010.
9 _________________________
10 RALPH D. MILLS, CVR, CP
11 Notary Public, State of Florida
12 Commission No. DD659841
13 Expires: May 2, 2011
14
15
16
17
18
19
20
21
22
23
24
25

PAGE 60 (2018)

1 CERTIFICATE OF REPORTER
2 STATE OF FLORIDA
3 COUNTY OF HILLSBOROUGH
4 I, RALPH D. MILLS, CVR, CP, certify that
5 I was authorized to and did report the foregoing sworn
6 statement of APRIL R. TAYLOR, and that the transcipt
7 is a true and complete record of my stenomask notes
8 thereof.
9 I further certify that I am not a
10 relative, employee, attorney, or counsel of any of the
11 parties, nor am I a relative or employee of any of the
12 parties' attorney or counsel connected with the action,
13 nor am I financially interested in the action.
14 DATED this 22nd day of February, 2010.
15 ____________________
16 RALPH D. MILLS, CVR, CP
17
18
19
20
21
22
23
24
25

PAGE 61 (2019)

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