[Hulka]

I am amazed at the childish, nasty, contemptuous opening statement by the states attny (http://www.scribd.com/doc/132906836/BDLR-States-Response-to-Ds-Motion-for-Sanctions-Against-State-Attorneys-Office-for-Discovery-Violations-3-28-13)

“The only thing more inflated than Defense Council's rhetoric is perhaps the alleged hourly fees cited in a second motion for payment of attorney's fees and costs.”

Might as well stick your thumbs in your ears, wave your fingers and bleat “nay-nay-nay.”

Just as mature as that opening remark.

States attny should be fired for that remark. Because the states attny is an officer of the court and this "officer" (supposed adult) shined their back-side to the world by demonstrating a level of contempt that would not be tolerated if Defense Counsel did same, the court should act forcefully.

[PUGACHEV]

I am an attorney who does a significant amount of trial work, and I have been writing briefs and motions for the last thirty years in both state and federal courts. This is one of the most poorly written pleadings I have ever encountered. If I didn't see the author's bar number below his signature, I would have assumed it was written pro se. Either the standards of the Florida bar are so low as to encompass legal writing skill that which a lay person might posses, or the prosecutor here is outstandingly incompetent. I cannot think of a single judge that I appear before who would not admonish the state on the record for filing a thing like this.

Moreover, this sort of pleading makes the judge's job so much harder, because now he or she has to wade through the trash talk in the state's motion to see if there is any reasonable argument in opposition to the defendant's motion. That sort of thing does not usually end well for the respondent.