Commercial Lien
John Carlin, Joseph Guerra, Ana Guerra.
I, Michael Mincieli, of sound mind and competent to testify, hereby depose and state the following facts based on my firsthand witnessing of the violence perpetrated by Joseph Guerra, Ana Guerra, and the actions of Judge John C. Carlin:
Do you admit or deny that over a period exceeding 10 years, my daughter, Paige Mincieli, has consistently expressed fear and apprehension towards the violent behavior exhibited by her husband, Joseph Guerra? (Check one: [ ] Admit [ ] Deny)
Do you admit or deny that Joseph Guerra's mother has been employed by the Broward States Attorney's Office for nearly three decades, holding significant power and influence within the community? (Check one: [ ] Admit [ ] Deny)
Do you admit or deny that the recurring instances of violence involving Joseph Guerra, a man weighing approximately 350 pounds, targeting my daughter, who weighs only 117 pounds, are substantiated by the existence of seventeen recorded 911 calls? Tragically, despite the occurrence of these incidents, no arrests have been made. (Check one: [ ] Admit [ ] Deny)
Do you admit or deny that as an elderly grandfather at the age of 68, I personally experienced one of Joseph's violent episodes when I intervened to protect the infant, Heaven Grace Guerra? Joseph physically assaulted me, repeatedly striking me in the face, while law enforcement and medical personnel were present. Despite the presence of Ana Guerra, Joseph's mother, no arrest was made. (Check one: [ ] Admit [ ] Deny)
Do you admit or deny that the sense of powerlessness in the face of such abuse is deeply debilitating? (Check one: [ ] Admit [ ] Deny)
Do you admit or deny that following the separation of Joseph and Paige, my daughter and I were granted custody of the minor child for a duration of one year, as substantiated by court records and transcripts? (Check one: [ ] Admit [ ] Deny)
Do you admit or deny that on November 30, 2022, Judge Carlin issued a void order to pick up the minor child, disregarding the unresolved issues of violence surrounding Joseph Guerra and the welfare of the minor child and her mother? It is pertinent to note that Judge Carlin was aware of the thirty-thousand-dollar payment made by Joseph to opposing counsel. Furthermore, the judge made disparaging remarks questioning my daughter's legal profession and expressed a desire to exclude such information from the proceedings. (Check one: [ ] Admit [ ] Deny)
Do you admit or deny that prior to the Emergency Pick Up Order of Minor Child issued by Judge John C. Carlin on December 1, 2022, Heaven Grace Guerra had been in the legal custody of her mother, Paige Mincieli, for at least one year, during which time there were no visitations or contact with her father, Joseph Guerra? The court acknowledged and upheld this custodial arrangement. (Check one: [ ] Admit [ ] Deny)
Do you admit or deny that throughout this period, both my daughter, Paige Mincieli, and I, Michael Mincieli, her biological grandfather, served as the primary caregivers for Heaven Grace Guerra? We resided together, providing unwavering care, support, and a stable environment for the child's upbringing. (Check one: [ ] Admit [ ] Deny)
10 Do you admit or deny that the actions taken by Judge John C. Carlin represent a blatant abuse of power, infringing upon the constitutional rights of citizens as guaranteed by the Due Process Clause? Such a violation is subject to punishment under 18 USC §242. (Check one: [ ] Admit [ ] Deny)
11 Do you admit or deny that it is widely recognized that forcibly separating a child from their primary caregiver can have severe and enduring psychological consequences? The abrupt and unforeseen separation of three-year-old Heaven Grace Guerra from her mother, Paige Mincieli, has caused significant emotional distress, including confusion, anxiety, and feelings of abandonment. (Check one: [ ] Admit [ ] Deny)
12 Do you admit or deny that the negative impact of disrupting a child's life extends beyond immediate emotional distress, eroding their sense of security and stability? This instability can lead to persistent behavioral issues and depression. (Check one: [ ] Admit [ ] Deny
13 Do you admit or deny that it is imperative to consider the specific circumstances surrounding Paige Mincieli, the primary caregiver and mother of Heaven Grace Guerra? Paige Mincieli has initiated counseling as a victim of domestic violence, seeking support to overcome the trauma she has endured. It is important to note that any inappropriate texts sent by Paige Mincieli arise out of the duress caused by being a victim of domestic violence and coercion by Joseph Guerra, and not as a reflection of her character or free will. (Check one: [ ] Admit [ ] Deny)
14 Do you admit or deny that Paige Mincieli's participation in counseling is an indication of her commitment to healing and breaking free from the cycle of abuse? The duress she has experienced as a victim of domestic violence has influenced her actions and communication, highlighting the impact of the perpetrator's coercion rather than any malicious intent on her part. (Check one: [ ] Admit [ ] Deny)
15 Do you admit or deny that, additionally, it is imperative to consider the specific circumstances surrounding Paige Mincieli, the primary caregiver and mother of Heaven Grace Guerra? Paige Mincieli is protected under the Americans with Disabilities Act (ADA) due to her status as a type 1 diabetic for the past [number of years]. This medical condition presents significant challenges to her overall health and well-being. The traumatic experience endured by Heaven Grace Guerra, coupled with the health concerns of her mother, Paige Mincieli, underscore the urgency and gravity of the situation. Immediate legal action must be taken to address the judicial overreach and safeguard the well-being and best interests of the child. (Check one: [ ] Admit [ ] Deny
To be continued
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