Filing # 184064663 E-Filed 10/16/2023 03:59:46 PM
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`IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT,
`IN AND FOR ORANGE COUNTY, FLORIDA
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`STATE OF FLORIDA,
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`Plaintiff,
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`vs.
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`JASMYNE R. MAULE,
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`Defendant.
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`CASE NO. 48-2023-CF-2050-EO
`DIVISION 17
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`MOTION TO ENFORCE PRETRIAL DIVERSION
`AGREEMENT AND DISMISS CASE
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`COMES NOW the Defendant, Jasmyne R. Maule, by and through the
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`undersigned attorney, pursuant to Florida Rule of Criminal Procedure 3.190
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`and moves the Court to enforce the Pretrial Diversion contract and dismiss the
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`case.
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`In support of this motion, Ms. Maule would show:
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`BACKGROUND
`In May 2021, law enforcement obtained information Ms. Maule, who
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`was 19 years old, “was possibly engaging in prostitution acts.” (Arr. Aff., p. 2,
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`June 10, 2021, 48-2021-CF-6848-AO.) On June 2, 2021, MBI Agent
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`Blankenship arranged for Ms. Maule to provide a “massage” at a hotel room.
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`Id. Once at the hotel, Agent Blankenship and Ms. Maule discussed services
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`and price and she advised she performs massages for $150 and handjobs for
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`$60. Id. (“Um, the only thing I do is handjobs.”)
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`MOTION TO ENFORCE PRETRIAL DIVERSION
`AGREEMENT AND DISMISS CASE
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`1
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`

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`During the massage, Ms. Maule informed Agent Blanenship:
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`“[S]he had moved to Florida two months earlier” and
`“started doing ‘this’ [] when she moved to Florida
`[after] she met a female who befriended her.”
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`“Two weeks into their friendship, [the friend]
`introduced Jasmyne Maule to a male that turned out
`to be a ‘pimp.’” Who “own[ed] a fur coat but
`otherwise a ‘normal’ guy.”
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`“[T]he male wouldn’t make her have sex with
`anyone, and had her start giving massages to
`clients. He taught her how to do the dates, and after
`a while she became tired of giving money to him. She
`stopped working for the male a week earlier.”
`
`Ms. Maule went on to explain “she had to give all the
`money she made from dates to the male. She started
`living in his house, and she justified giving money to
`the male because he made it appear that it would
`ultimately benefit her.”
`
`“While staying with the male, he told [Ms. Maule] to
`stop paying for her apartment and just live with
`him.” “The other female also had paid the male
`money she made from dates, and she has been with
`the male for three years.”
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`Ms. Maule “eventually realized he was manipulating
`her to give him money [and] write down any money
`he spent on Jasmyne Maule, and would keep track
`of everything she owed him. When she told him she
`didn’t want to pay him anymore, he was ‘cool’ about
`it and let her leave.”
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`MOTION TO ENFORCE PRETRIAL DIVERSION
`AGREEMENT AND DISMISS CASE
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`2
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`“However when she went to retrieve her car from his
`house, she said he was no longer ‘cool’ with her. He
`wouldn’t allow her into his house to charge her
`phone, and made her wait outside for a tow truck for
`her car that wouldn’t start.” Id.
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`On June 9, 2021, Agent Blankenship met Ms. Maule again under the
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`pretense of receiving a massage and handjob and once she was about to start,
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`“assisting MBI agents entered the room” and arrested Ms. Maule. Id.
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`While detaining Ms. Maule, MBI Agents Maestre and Goodling
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`identified themselves as human trafficking investigators and, without
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`mirandizing her, questioned her about her former “pimp.” (MBI Ex. A, p. 137,
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`Feb. 15, 2023.) Ms. Maule revealed the pimp was a male she knew as “king,”
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`whose name was Julian Pinnock (Co-Defendant A who was then 33 years old).
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`Id. at 138. She met Pinnock another female named “Sunshine.” Sunshine is the
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`alias of Faith Buchanan (Co-Defendant B who was then 23 years old). Id. at
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`163.
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`Ms. Maule met Buchanan while working at The Le Palace strip club in
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`Tampa and Pinnock would come by the strip club when Buchanan was working
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`and talk to Ms. Maule. Id. at 138. Ms. Maule told Pinnock and Buchanan she
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`moved to Orlando from Virginia, was struggling financially, and had no clothes
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`or personal belongings. Id.
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`After which, Pinnock began convincing Ms. Maule to work for him
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`because he could help her make money “finessing” dates, she did not have to
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`MOTION TO ENFORCE PRETRIAL DIVERSION
`AGREEMENT AND DISMISS CASE
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`3
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`have sex, and all she would have to do is go on dates as an escort and give
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`massages. Id. He further explained she would work for him, give him all the
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`money she earned from stripping and going on dates, and in return he would
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`manage her money, invest it in the stock market and provide her with anything
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`she needed. Id.
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`Ms. Maule eventually agreed to this arrangement and moved into a
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`house located in Kissimmee where Pinnock and Buchanan lived. Ms. Maule
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`began going on dates in which she would mainly give massages in the nude,
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`and some she would give “hand jobs” and others she would not (engage in any
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`sexual activity). Id. Some dates would be done with Buchanan, where Ms.
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`Maule gave the massage and Buchanan would have sex with the customer. Id.
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`Ms. Maule gave 100% of the money she made from stripping at strip clubs and
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`going on dates to Pinnock. Id. Ultimately, Ms. Maule got tired of giving Pinnock
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`all her money and not knowing where the money was going and told Pinnock
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`she wanted to part ways. Id. at 139.
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`After Ms. Maule corroborated the information she previously told Agent
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`Blankenship, Agent Maestre told Ms. Maule he wanted an official sworn and
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`recorded statement from her, which prompted her to explain she did not feel
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`comfortable doing so and said she needed to call a friend who is an attorney.
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`Id. Agent Maestre then told Ms. Maule she was detained, was not free to call
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`an attorney, informed her she was under arrest for prostitution, and told her
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`MOTION TO ENFORCE PRETRIAL DIVERSION
`AGREEMENT AND DISMISS CASE
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`4
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`he could not speak to her until she obtained legal counsel. Id.
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`Ms. Maule was then arrested for Unlicensed Practice of a Health Care
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`Profession, two counts of Entering a Place of Prostitution, and two counts of
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`Prostitution. (Arr. Aff., p. 1, June 10, 2021, 48-2021-CF-6848-AO.)
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`On August 10, 2021, the State filed an Information formally charging
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`Ms. Maule with two counts of Prostitution and two counts of Entering a Place
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`of Prostitution. The Information stated, “This information encompasses the
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`transaction and all charges listed on complaint number 48-202I-CF-006848-0.
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`The Orange County Sheriff's Office and the Orange County Corrections
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`Department shall substitute the charge(s) indicated on the information for
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`those on the above cited complaint. The bond(s) shall remain the same as that
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`last set on 48-202I-CF-006848-0.” (Inf., p. 3, Aug. 10, 2021, 48-2021-MM-5608-
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`AO.)
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`On November 23, 2021, Ms. Maule executed a Pretrial Diversion
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`Contract that was counter signed by the State Attorney’s Office, which stated
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`“if its terms are met, the initial charge will be dropped and the State of
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`Florida will be barred from prosecution.” (See Pretrial Diversion
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`Contract, Section III, attached as “Exhibit A.”) Ms. Maule’s contract required
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`her to complete the Ninth Judicial Circuit’s State Attorney’s Pretrial Diversion
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`Prostitution Education Course, which is “aimed at educating those
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`arrested for prostitution offenses about human trafficking and
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`MOTION TO ENFORCE PRETRIAL DIVERSION
`AGREEMENT AND DISMISS CASE
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`community resources with the goal of reducing recidivism, decreasing
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`human trafficking, and benefitting the community at large.” (See
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`Pretrial Diversion Prostitution Education Course program overview attached
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`as “Exhibit B.”) Ms. Maule fulfilled her contractual obligations, completed the
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`terms of the Pretrial Diversion Contract, and the State Attorney’s Office filed
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`a Nolle Prosequi on Feb. 2, 2022. (See Nolle Prosequi attached as “Exhibit C.”)
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`However, two years later, the Office of the Statewide Prosecutor filed an
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`Information against Ms. Maule for Racketeering, Conspiracy, Money
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`Laundering, and Unlawful Use of Two-Way Communication Device based on
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`the same conduct and information they obtained when she was originally
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`arrested under case number 48-202I-CF-006848-0 and 48-2021-MM-5608-AO
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`notwithstanding she was 19 years old when the alleged crimes occurred, had
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`complied with her Pretrial Diversion Agreement, completed the Pretrial
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`Diversion Prostitution Education Course, and had not engaged in any
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`subsequent criminal activity.
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`Notably, the Probable Cause Affidavit used to justify filing charges
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`against Ms. Maule repeatedly refers to her as a possible human trafficking
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`victim. (“Jasmyne Maule is possibly a human trafficking victim” MBI
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`Ex. A, p. 92-93 Feb. 15, 2023; “Agent Fredy Maestre has collected several pieces
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`of evidence showing that Julian Pinnock is running a prostitution ring [and]
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`Jasmyne Maule is possibly a human trafficking victim.” Id. at 105-106.
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`MOTION TO ENFORCE PRETRIAL DIVERSION
`AGREEMENT AND DISMISS CASE
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`6
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`“Jasmyne Maule [is] part of Julian Pinnock’s prostitution ring and turn[s] over
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`all proceeds [made] to him.” Id. at 128.)
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`Moreover, the charges upon which she was originally arrested and the
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`subsequent information she provided regarding Pinnock’s human trafficking
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`provides the foundation upon which the entire Racketeering prosecution was
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`built, yet the affidavit wholly omits Ms. Maule was formally prosecuted for
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`predicate offenses 27-28 and 31-32 under Orange County Case Numbers 48-
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`2021-CF-6848-AO / 48-2021-MM-5608-AO and entered into an agreement
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`whereby the State agreed to dismiss the then pending charges and the “State
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`of Florida will be barred from prosecution” if she completed the Pretrial
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`Diversion Prostitution Education Course. Ms. Maule upheld her end of the
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`agreement; the State has not.
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`MEMORANDUM OF LAW
`Contractual Enforcement and Dismissal
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`A.
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`“It is a settled principle of criminal procedure that, if the government
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`fails to honor a plea agreement, the court may either enforce the agreement or
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`allow the defendant to withdraw the plea.” State v. Simons, 22 So. 3d 734 (Fla.
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`1st DCA 2009). “In some situations, it may be proper to allow the defendant to
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`withdraw the plea, but in others the only fair remedy is to enforce the
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`agreement. For example, Florida courts have held that specific performance is
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`a proper remedy if the defendant has partly performed the agreement.” Id.
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`MOTION TO ENFORCE PRETRIAL DIVERSION
`AGREEMENT AND DISMISS CASE
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`Moreover, “the power to enforce an agreement between the prosecution
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`and defense applies not only to plea agreements, but also to settlement of
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`agreements that do not require the defendant to enter a plea. See State v.
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`Davis, 188 So. 2d 24 (Fla. 2d DCA 1966); Butler v. State, 228 So. 2d 421 (Fla.
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`4th DCA 1969). The underlying principle is the same. When the parties agree
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`to settle a case, they should be bound by their agreement. The incentive to
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`settle a case by plea bargaining or by an agreement not requiring a plea would
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`quickly disappear if one party could renege on an agreement without any
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`consequence.” State v. Simons, 22 So. 3d at 737 (Fla. 1st DCA 2009).
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`Simons involved a case where the State Attorney attempted to withdraw
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`from a Pretrial Intervention agreement (which would result in complete
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`dismissal of the charges) after the defendant had partially performed the
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`conditions of the agreement and had not otherwise violated the agreement. The
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`defendant objected to the State’s attempt to back-out of the agreement and
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`moved the Court to enforce the agreement or dismiss the charges.
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`Rather than enforce the agreement, the trial court instead dismissed the
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`case outright because of the State’s conduct in backing out of the agreement
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`after the defendant had partially performed. The appellate court “support[ed]
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`the trial judge's decision to enforce the agreement and dismiss the charges.”
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`State v. Simons, 22 So. 3d at 737 (Fla. 1st DCA 2009). In doing so, the appellate
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`court reasoned that the “defendant had partially complied by making
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`MOTION TO ENFORCE PRETRIAL DIVERSION
`AGREEMENT AND DISMISS CASE
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`8
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`restitution and he was prepared to comply with all of his other obligations [but]
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`was prevented from doing so only because the victim backed out of the
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`agreement without justification.” Id.
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`Important to the prosecutorial posture of this case, it matters not that
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`Ms. Maule entered into a pretrial diversion agreement with the Ninth Judicial
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`Circuit State Attorney and is now being prosecuted by the Office of the
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`Statewide Prosecutor. Because once a defendant performs their “end of the
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`bargain, the State [is] obligated to uphold its end of the agreement” regardless
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`of whether another prosecutorial authority was not part of the agreement or
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`could have also prosecuted the defendant. See Johnson v. State, 238 So. 3d 726,
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`739 (Fla. 2018). Consequently, the Statewide Prosecutor’s subsequent
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`prosecution of Ms. Maule after she completed Pretrial Diversion Program, for
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`the same underlying conduct and information, “violates general contract
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`principles and notions of fundamental fairness.” Id.
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`WHEREFORE, Ms. Maule respectfully moves the Court to enter an
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`order enforcing her Pretrial Diversion Agreement, dismissing the charges filed
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`against her and hold the “State of Florida [is] barred from prosecution” of these
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`crimes pursuant to the Pretrial Diversion Contract she entered into with the
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`State.
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`MOTION TO ENFORCE PRETRIAL DIVERSION
`AGREEMENT AND DISMISS CASE
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`9
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`CERTIFICATE OF SERVICE
`I CERTIFY that the foregoing document has been furnished to ASP
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`Mary
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`Sammon, Off
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`ice
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`of
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`Statewide
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`Prosecutor,
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`mary.sammon@myfloridalegal.com, 135 West Central Boulevard, Suite
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`1000, Orlando, FL 32801 by electronic transmission on October 16, 2023.
`
`/s/ Richard E. Hornsby
`Richard E. Hornsby, Esquire
`Florida Bar Number 474134
`RICHARD E. HORNSBY, P.A.
`1217 E. Robinson Street
`Orlando, Florida 32801-2115
`407-540-1551 | 407-540-1553 (fax)
`richard@hornsby.com
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`MOTION TO ENFORCE PRETRIAL DIVERSION
`AGREEMENT AND DISMISS CASE
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`10
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`12/3/2021 10:36 AM FILED IN OFFICE OF TIFFANY IM. RUSSELL CLERK OF CIRCUIT COURT ORANGE CO FL
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`*.
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`4,
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`STATE OF FLORIDA,
`Plaintiff
`
`VS
`
`JASMYNE RENEE MAULE
`Defendant
`
`IN THE COUNTY COURT OF THE NINTH JUDICIAL CIRCUIT
`IN AND FOR ORANGE COUNTY, FLORIDA
`
`CASE #: 48-2021-MM-005608-0
`DiVision: 62
`
`THIS AGREEMENT is between the above-named Defendant and State Attorney Monique H. Worrell, by and
`through the undersigned Assistant State Attorney. Supervision of contract conditions will be administered by the Orange
`County Corrections Department.
`The Defendant
`is charged with PROSTITUTION/LEWDNESS 1ST VIOL, PROSTITUTION/LEWDNESS 1ST VIOL,
`ENTER/REMAINING IN PLACE FOR PROSTITUTION, AND ENTER/REMAINING IN PLACE FOR PROSTITUTION), in
`violation of Florida Statute 796.07(2)(E)-100, 796.07(2)(E)-100,
`796.07(2)(G)-9, AND 796.07(2)(G)-9, After an
`investigation of the offense and the Defendant's background, it appears that the interests of the State of Florida and that
`of the Defendant will best be served by entering into this agreement.
`
`is agreed that the prosecution in this matter will be deferred for a period not to exceed 18 months, provided the Defendant
`It
`abides by the following conditions:
`
`(A) You must refrain from violation of any federal, state, or local
`law. You will not possess any illegal or controlled
`substance in violation of Florida State Statute.
`If you are arrested or charged with a crime while on the Pretrial
`Diversion Program, you are subject to automati
`revocation whether the crime occurred before or after the signing
`of the contract.
`(B) You must associate only with law-abiding persons.
`(C) You must work regularly at a lawful occupation; or pursue a course of studies as a full-time student, or both and
`support legal dependents to the best of your a ility. Employment must be verified by documentation as directed.
`(D) You must take an active part in counseling anc attend all scheduled appointments. You must participate in and
`be responsible for program costs of any referrals your Officer recommends. Referrals may include, but are not
`limited to participation in drug/alcohol coun eling,
`a mental health evaluation, urine screenings, General
`Equivalency Diploma (GED) and English for Speakers of Other Languages (ESOL).
`(E) You must immediately inform the Pretrial Diversion Program of any anticipated or unanticipated change in your
`residence or your employment.
`is your obligation to notify Pretrial Diversion of any change in your address and
`It
`to comply with residence verification instructionS. Should it be determined that you have moved from your reported
`residence or changed employment, without ndtice to Pretrial Diversion, and are no longer able to be contacted
`through your reported mailing address, you are subject to automatic revocation.
`In addition, you must also notify
`the Clerk of the Court for Orange County (see below for addresses), in writing, of your address change.
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`

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`Page 2
`NAME: JASMYNE RENEE MAULE
`CASE #: 48-2021-MM-005608-0
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`All Notices, Summonses, or other mail will be se t to your current address.
`If you fail to appear in court due to
`paperwork being sent to an old address, a warran may be issued for your arrest, and you may be revoked from the
`Pretrial Diversion Program.
`CLERK OF THE COURT LOCATIONS:
`(407) 836-2000 for all locations
`Orlando cases: 48-YEAR-MM-NUMBER-ending in letter 0
`425 N. Orange Ave., Room 250, Orlando, 32801
`Apopka cases: 48-YEAR-MM-NUMBER-ending in letter A
`1111 N. Rock Springs Rd., Apopka, 32703
`Ocoee cases: 48-YEAR-MM-NUMBER-ending in letter W
`475 W. Story Rd. Ocoee, 34761
`Winter Park cases: 48-YEAR-MM-NUMBER-ending in letter E
`450 N. Lakemont Ave., Winter Park, 32792
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`(F) Report monthly as directed by your officer. Wri ten, verbal, telephonic, and electronic monthly reports may be
`required as well as associated fees, if applicabl. Promptly and truthfully answer all questions directed to you by
`your officer. Regardless of reporting method,
`II responses must be made promptly and truthfully.
`(G) You must pay a non-refundable processing and supervisory fee of $50 for each month of supervision to the Pretrial
`Diversion Program, as REQUIRED BY Florida tatute Section 948.08.
`(H) You must pay a $50.00 non-refundable cost o prosecution fee (per case number) to the State of Florida within
`sixty (60) days as REQUIRED BY Florida Statute Section 938.27.
`(I) You must pay a one-time $20.00 Intake fee as
`irected.
`(J) You must pay a one-time $17.00 Drug Testing ee as directed.
`(K) You will complete Alternative Community Serv4 (ACS) as directed.
`(L) Unless otherwise directed by Pretrial Diversion staff, all contract conditions must be completed and documentation
`provided to your Pretrial Diversion Officer (or designee) no less than thirty days prior to the termination of this
`contract or any extension of the contract period
`(M) You will also submit to random urine screeningS for drugs. Any drug test with a positive result is a violation of this
`contract and may result in additional consequences or revocation of this contract.
`(N) You will pay investigative costs and restitution laoint and several) if applicable, and as directed by your assigned
`officer.
`(0) If there is an accompanying PTD contract for a different case, the contracts should run concurrent with each other.
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`

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`Page 3
`Name: JASMYNE RENEE MAULE
`CASE #: 48-2021-MM-005608-0
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`By signing this contract, you affirm that you have no criminal history (arrests, convictions, or cases in which adjudication
`of guilt has been withheld, whether as a juvenile or adult), or if you have a prior criminal history, you have fully and
`completely disclosed it to Pretrial Diversion.
`it is fou d that you have not been fully candid on this issue, you are subject
`If
`to revocation from the Pretrial Diversion Program.
`
`Pretrial Diversion is a voluntary program. You may wit draw at any time during the contract period by notifying your officer
`and by signing the withdrawal form, after which your case will be returned to the State Attorney's office for prosecution.
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`If you fail to comply with any of the contract conditions, your case may be subject to the following action, depending
`upon the violation:
`
`111
`
`the State Attorney will authorize a modification of the contract
`(A) The Office of
`through the Orange County
`Corrections Department upon case review. The modification may include additional special conditions, an extension
`of the contract length, or other modifications as deemed appropriate.
`(B) Your officer may revoke this Contract and the State Attorney will prosecute you for this offense. Upon being
`informed that a revocation is under consideration, you may request an administrative hearing, which is comprised of
`you, your PTD officer, and one or more representatives from PTD and/or Community Corrections Division. At the
`administrative hearing, any information you present will be considered in reaching a resolution.
`
`This agreement is a deferral of prosecution. Upon completion of contract conditions and once half the supervision term
`has passed, contracts with approved charges,
`in accOrdance with policy, may be terminated early by the Office of the
`If its terms are met, the initial charge will be dropped and the State of Florida will be barred from
`State Attorney.
`its terms are violated, prosecution concerning this charge will proceed.
`If
`prosecution.
`
`IV
`I HEREBY STATE that the above has been read by me or to me. All conditions have been explained to me and I
`understand them and agree that I will comply with theM.
`I also state that I have never before participated in any Pretrial
`Diversion or Pretrial
`Intervention program or
`if you have previously participated in any Pretrial Diversion or Pretrial
`Intervention program that I have fully and completely disclosed it to Pretrial Diversion. Furthermore, I fully understand the
`criminal charge (s) pending against me.
`By signing this Pretrial Diversion Contract, I understand I waive my right to have prosecution commence within the time
`limits required by the statute of limitations and my right to a speedy trial as defined by the Constitutions of the United
`States and Florida, and the Florida Rules of Criminal Rrocedure.
`I further agree that if the offense, with which I am charged involves the use or possession of a weapon or firearm,
`agree to forfeit that weapon to the appropriate authority, as defined by Florida Statute.
`
`I
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`

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`Page 4 •
`NAME: JASMYNE RENEE MAULE
`CASE #: 48-2021-MM-005608-0
`
`Cl/
`I understand that this contract is for a term of
`months.
`I understand the supervisory fee referenced above is $50 per
`th.
`6 / cost of restitution is $
`•
`I understand the amount due for cost of investigation i
`a hours of Alternative Community Service (ACS).
`I also understand that I am required to complete
`Other special conditions, if applicable, and as indicated:
`
`',
`
`1
`
`You will submit to a substance abuse evaluation rlid complete all recommended treatment.
`If treatment is not recommended; you will attend nd complete a Substance Abuse Education/Awareness Class.
`You will complete an Impulse Control/Theft prevehtion class.
`You will attend and complete YADP (Youth Alcohol Drug Program) through MADD, if available.
`You will complete a Batterer's Intervention Prograrn as directed.
`You will possess no firearm or weapon as definedby Chapter 790 of the Florida State Statutes. As a
`condition of
`this contract, you may be required to submit to a search of your person, property, vehicle, and
`place of domain and/or residence search.
`You should have no hostile victim contact, unless Otherwise ordered by the court.
`You should have no victim contact, unless otherwise ordered by the court.
`You will complete an Anger Management Class.
`You will complete in person a minimum eight-hour Anger Management Class in divided sessions.
`You will successfully complete and pay the cost of class/program designed to inform and educate
`regarding the law regulating selling and serving alohol to persons under the age of 21 years.
`You will obtain a mental health evaluation and corhply with all treatment recommendations.
`You will obtain and show proof of STD testing.
`You will complete an STD/HIV (sexually transmitted disease) awareness class.
`You will not retum to the scene and/or vicinity of the arrest or the incident
`You will write and submit a letter of apology to the arresting officer. This letter is subject to the review and
`51-ale allorney 's piedih-/-420 brvastan Coi4,0-5e_
`Other:
`Early termination date if applicable
`
`4 approval of the Qommunity Corrpctions Division.
`AtOrneyi
`
`DEFt
`
`i,‘
`
`•
`
`T (Signature)
`
`This agreement shall be in force once signed by both the defendant and the authorized representative of the Office of the State
`L.., \\—e2:2,--Li,
`
`via,m,e1,00\
`DATE OF BIRTH
`
`DATE SIGNED
`
`Witness to Defendants Signature
`
`H. Worrell, State Attorney, Ninth Judicial Circuit, hereby agrees that, should the defendant fully meet the terms
`litions of this m.reeient, the charge(s) referred to herein shall be dropped (by Nolle Prosequi or No Information
`pon completkon of thb,Program.
`
`-
`
`.ìv
`
`State
`
`t
`DATE
`
`I
`
`40
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`

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`Office of the State Attorney for the Ninth Judicial Circuit
`Pretrial Diversion Prostitution Education Course – Orange County
`
`
`The State Attorney’s Office’s new diversion initiative is aimed at educating those arrested
`
`for prostitution offenses about human trafficking and community resources with the goal of
`reducing recidivism, decreasing human trafficking, and benefitting the community at large. While
`prostitution offenses have always been diversion eligible, the diversion program has only offered
`an HIV/STD awareness course as a prostitution related condition. Orange County’s need for a
`more robust educational course to combat human trafficking is evident from the statistics: In 2019,
`Florida ranked third in the nation for number of calls to the National Human Trafficking Hotline
`and Orlando has been ranked as high as third in the nation per capita for number of calls in recent
`years. In 2019, the State Attorney’s Office received 117 prostitution cases from law enforcement.
`This course was developed in partnership with various community anti-human trafficking
`organizations.
`
`Eligibility:
`• Only sellers of commercial sexual activity—not buyers aka johns—are eligible to
`participate.
`• Criminal history/prior diversion will not exclude participation in this course.
`o If someone is charged with a non-prostitution related offense, e.g. drug related,
`but this person has a recent history of prostitution offenses (selling commercial
`sex), and you think they would benefit from this course, email SCU/HT Unit
`Chief Jenny Rossman jrossman@sao9.org to review for participation.
`• Citizenship is not relevant to course participation.
`Initially this course will only be available live, in-person.
`•
`
`Date/Location
`• Course location is in downtown Orlando (disclosed only to necessary parties/participants
`for safety reasons).
`• The first course will take place on June 18, 2021 from 10 am to 2 pm.
`o Future 2021 courses will be at the same time/place on September 17th and
`December 10th.
`
`
`Logistics:
`• Security: OPD providing
`• Masks will be required at June course, future courses TBD
`• When participants register, pretrial diversion/probation will email SAO9 PTD legal
`assistant Stephanie Derolus sderolus@sao9.org and Jenny Rossman jrossman@sao9.org
`with participant information and if they have any of the below needs:
`o Transportation (United Abolitionists to assist)
`o Childcare (will have additional space for kids)
`o Language other than English (can find volunteer interpreter for course)
`
`
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`
`
`

`

`Agenda:
`• 10:00–10:10 Registration – coffee/donuts provided by United Abolitionists
`
`• 10:10–10:15
`
`Introduction by ASA Jenny Rossman, SCU/HT Unit Chief
`
`• 10:15–10:45 Dr. Phil Toal, Aspire, MA Clinical Psychology/PhD Clinical Sexology
`• The Psychology of Exploitation: Education focusing on
`trauma/substance abuse/mental health/ACES and their
`neurological/physiological effects
`• Overview of Aspire's HT residential program and substance abuse
`program
`
`
`• 10:45–11:15 Attorney Lisa Haba, former Seminole County HT prosecutor
`• Legal Overview: What is HT and who are the victims?
`(Commercial sex/labor/immigration)
`• HT Expungement in Florida/nationally
`
`• 11:15–11:45 Mikala Klein, One More Child Regional Advocate/former MBI VA
` Reporting to Law Enforcement: Debunking the Myth
`•
`
`• 11:45–12:15 Survivor Speaking
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`• 12:15–1:00 Lunch – subs provided by United Abolitionists
`
`
`
`• 1:00–1:30
`
`• 1:30–2:00
`
`• 2:00–2:15
`
`Dionne “Dee” Coleman, Executive Director, Samaritan Village
`• Overview of HT residential treatment programs and resources:
`mental health, job training, tangible needs
`
`Kathryn Ross, Sex Educator, Planned Parenthood
`• STD/birth control education and overview of community health
`organizations
`
`Conclusion
`• Tomas Lares, Founder/President United Abolitionists – backpack
`presentation
`• Announce that MBI Agent/VA on call if anyone wants to meet
`• Participants fill out feedback form and survey predicting whether
`course will change future behavior
`
`
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`

`

`IN THE COUNTY COURT OF THE
`NINTH JUDICIAL CIRCUIT, IN AND FOR
`ORANGE COUNTY, FLORIDA
`
`CASE NO: 48-2021-MM-005608-O
`
`
`
`DIVISION: 62
`
`
`
`
`
`STATE OF FLORIDA
`
`
`
`vs.
`
`JASMYNE RENEE MAULE
`________________________________/
`
`
`
`
`
`THE STATE OF FLORIDA, by the undersigned State Attorney, enters a Nolle Prosequi
`
`NOLLE PROSEQUI
`
`
`in the above-entitled action as to:
`
`ALL COUNTS
`
`MS. MAULE COMPLETED THE STATE ATTORNEY’S OFFICE PROSTITUTION
`
`DIVERSION COURSE
`
`that a copy hereof has been
`
`furnished
`
`to Richard Hornsby,
`
` I
`
` CERTIFY
`
`Richard@Hornsby.com, 1217 E. Robinson Street, Orlando, FL 32801 by e-mail on this 2nd day
`
`of February, 2022.
`
`
`
`
`
`
`
`
`
`MONIQUE H. WORRELL, State Attorney
`Ninth Judicial Circuit of Florida
`
`
`
`By:
`
`
`Jenny R. Rossman
`Assistant State Attorney
`Florida Bar # 84625
`Division62@SAO9.org
`PO Box 1673, 415 N Orange Ave
`Suite 300
`Orlando, FL 32802-1673
`407-836-2189
`
`