By Pamela Jean Curry, Copyright 2022 All Rights Reserved
I’m not a Legal Writer, however I’m a writer. I wrote, and delivered by hand, legal briefs under unbelievable pressure. My family had cherry bombs with other types of violence at my home. Disturbingly crippled cats were abandoned near my home. The denials of how technology was being used I thought was life threatening then.
Now, I see it along with despicable forms of warfare and SILENT weapons of war, as a way to kill without consequence. To keep my sanity in a household that always had small businesses, I organized my lawsuit to store it electronically. It was not published by the courts.
I was the first woman to bring a Title VII based on dataveillance in retaliation. I was the first person to attempt to get electronic discovery based on those allegations and in 1989, electronic records disappeared as soon as they were made. It wasn’t too long after the Lakeland Police Department made an electronic record that they lost the records of who it was sold to. I happened to find one copy that was in the hands of the NEW YORK TIME’S in house Attorney. She had passed it on to the IRS, with some defamatory remarks. I used it to identify to persons in government that her information was created to diminish my lawsuit and defame me, and was fake.
Bear witness and fight for your rights, those two things I’ve done my entire life I wouldn’t want to be in the shoes of most of the women who are held up as successful today. The silence they’ve kept to gain success in male dominated professions has accelerated the decay of rights, particularly in the legal field.
Pamela Jean Curry, copyright 2002, all rights reserved
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1991 AUTHENTICATION INDEX – PRO SE
While being a “lady in waiting” at the 11th Circuit court where I took my case on appeal
by myself, I prepared to get what I was asking for a trial by jury with retroactive application of
the 1991 Civil Rights Restoration Bill, which allowed a trial by jury in my type of case.
Preparing to go to trial alone, without money for subpeonas, I devised a series of forms with
cross references to ever part of the record, defendant’s admissions and answers to legal
discovery, and/or certified/sealed documents and affidavits from records custodians
that would authenticate documents by themselves, without a witness, and that
would allow it to be introduced as evidence/proof of facts.
I also prepared profers in case that did not work!
This was also cross referenced with a second method of authenticating documents, by symbols
such as hearts, diamonds, clubs, stars and so forth that did not import well from the WordStar
program to the WordPerfect program to the html here, but the original scheme code is below.
This page had several BLACK SMILEY FACES!
GREEN BINDER: PART I POLK COUNTY SHERIFF’S DEPARTMEMT
HOMICIDE INVESTIGATION CURRY’S STATEMENT
PART II RECEIPT AND RETURN OF CURRY’S HOMICIDE FILM
PART I
Marked for Request for Admissions F.R.C.P., Rule
Identification as: 36 Admitted by defendant as a “Genuine”
copy, and/or Self-Authenticating, Rules
of Evidence, Rule 901 & 902 or as Indicated.
111 Death Investigation of Rubio, German 13 Apr. 86
Hand stamped a True Copy and signed. 2 Pages
Curry’s Testimony on the Scene, Page 1
Curry’s Testimony on the Scene, Page 2
111 (1)
1) Affidavit of Records Supervisor as to the
signature above and that the records are true and
correct copies. Affidavit 1 the General Record.
Affidavit 2, Curry Testimony on two pages
Affidavit 3, noting record of reports of Criminal Mischief at the house
I was living at during the course of Civil Discovery, very unusual report!
111 (2) 2) Certificate of Sheriff, State of Florida,
Polk County, Capacity of Record Custodian as to
three specific Affidavits
111 (3) 3) Certificate of Judge as to the Capacity of
the Sheriff, specifically identifying the attestations
in the Certificate of Sheriff attached.
111 (3A) 3A) Department of State facsimile signature of
Lawrence W. Crow, Jr. as Sheriff, “Seal”
111 (4) 4) Clerk of Courts, 10th Circuit attesting to the
Capacity of the Judge whose certificate is appended to
the Affidavits, Honorable Judge Curry
111 (4A) 4A) Signature of Judge Curry on the Order Following
First Appearance Hearing, Gerardo Reyes Jr.
111 (4B) 4B) Department of State “Sealed form” attesting
to the “Bud” Dixon’s capacity as Clerk with
the attestation of Judge attached.
Federal Rules of Evidence, Rule 902 (4), (2) or (8)
111A State of Florida v. Gerardo Reyes, Case No. CF86-1951 (Fla.
10th Cir. Ct., May 8, 1986). No Bill under Seal of Clerk of
10th Circuit Court. 902 (1)
Two pages of testimony from a “witness” the alleged assaillant’s brother
who testified about what he saw. His testimony contradicts the no-bill.
Page 1
Page 7
Page 8
UNMARKED Brochure: Your rights as a victim or witness: Prepared by the
Florida Sheriff’s Association.
NEWSPAPER ARTICLES PUBLISHED WITH MY TESTIMONY AT THE SCENE:
Newspaper Article by Kurth Gustafson, her former co-worker published in The Ledger, April 1986
with testimony of a “freelance” photographer and what she witnessed at the homicide scene
in Discovery The Ledger admitted that this photographer was the Plaintiff, Pamela Curry and
that she was known to the Reporter. He was a former co-worker.
I asked not to be identified in both articles because in part the alleged assailant was still “at large”.
Newspaper Article by Michael Crook published in The Tampa Tribune, April 1986
with testimony of a “freelance” photographer about a beating she witnessed
at that same homicide scene, at a music concert in central Florida.
GREEN BINDER: PART II RECEIPT AND RETURN OF CURRY’S HOMICIDE FILM
198 Envelope returning Curry’s Homicide Film from the Polk County
Sheriff’s Department, Detective Wood Postmarked May 15, 1986.
198 (1) ‡ Affidavit of Robert E. Wood (1992)
198 (2) Statement by Bartow Superintendent of Postal Workers Certifying
the meter number is that used by the Polk County Sheriff’s
Department. Postmarked and executed Mar. 22, 1991. Second
unsworn declaration under penalty of perjury by the same
Superintendent 28 U.S.C. § 1746.
Envelope postmarked 1986 from Wood to Curry Returning Film from Homicide
‡ Metered postage number with date noticed to Defendant June 1,
1992 at page 7, (possible use under F.R.E. 803 (24)). Noticing a
postmark of the date the first attestation was executed.
GTE Phone Calls recorded to the Polk County Sheriff’s
Department in MAY 1986. † Testimony of Pamela Curry
as a predicate to admission of phone bill and/or the
later testimony of Patricia Curry.
109 Sheriff’s Department Letter, Sept. 4, 1987
from Robert E. Wood, Corporal to Pamela Jean Curry
109 (1) ‡ Affidavit of Robert E. Wood (1992)
109 (2) Affidavit of Polk County Sheriff’s Department
Executive Secretary who signed the letter dated Sept.
4, 1987. ‡ Noticed to the Defendant on June 1, 1992
at page 9 (“To prove the truth of the matter”). ‡ July 30,
1990 at page 8 Lynn Radford’s address noticed to Defendant.
109 (3) Fifteen pages from the Personnel File of Lynn O’Neal
Radford, identifying her positions as Secretary and Executive
Secretary, respective to her signing of the Letter of
Sept. 4, 1987 and Affidavit of August 1, 1991.
109 (4) Affidavit of Polk County Sheriff’s Department Mike Powell (1
of 3) attesting to employment of Detective Wood & absence of letter.
Affidavit topped by Certificates of Sheriff,Judge and Clerk of Courts.
109 (5) The Ledger, March 3, 1988 1B “Polk County Sheriff’s
corporal suspended after his arrest” concerning Detective Wood.
109 (6) Relative Destruction Request Filed, Under Seal, 902 (1), State
of Florida Archives destruction requests from Polk County Sheriff’s.
Pamela Curry v. The Ledger Publishing Corporation
QUICK REFERENCE – AUTHENTICATION KEY
FOR AN ENTIRE SET OF PAGES LIKE THIS ONE,
ON DIFFERENT SUBJECTS REQUIRING PROOF OF FACTS!
HEART Authenticated by Defendant’s Answer from 1 of Plaintiff’s
4 Requests for Admissions under the Federal Rules of Civil
Procedure, Rule 36. Specifically identified.
DIAMOND Authenticated by Defendant’s Answer to 1 of Plaintiff’s 2
Interrogatories, Federal Rules of Civil Procedure, Rule 33 (b)(c)
CLUB Authenticated by Defendant’s Document Production, 1 of 3 of
Plaintiff’s requests, Federal Rules of Civil Procedure, Rule 34
SPADE Authenticated by Defendant’s Correspondence through Counsel
with Plaintiff during the civil proceedings.
All of above are Admissible in Federal Rules of Evidence, Rule
801 (d) (2) Admission by party-opponent, specifically identified.
WHITE SMILEY FACE Self-Authenticating alone, without additional Certification.
BLACK SMILEY FACE Self-Authenticating Federal Rule of Civil Procedure, Rule 44
or Federal Rules of Evidence, Rule 902 with Certification
† Testimony of Pamela Curry as witness may be needed
‡ Curry served required written “Notice” on the Defendant
POINTING FINGER Deposition Testimony designated by lines that are relative to
Authenticity of an exhibit or part of an exhibit. Admissible
under Federal Rules of Civil Procedure, Rule 32 (a) (2), Rule 32
(a) (3), (D) or (E) where notice was served. Federal Rules of
Evidence: Rule 804 or 804 (b) (5) notice was served; Rule 803
or 803 (24) where notice was served and/or Rule 801 (d) (1) or
(2); Rule 1007 Testimony or written admission of party or 1004;
Statements may also be admissible under Rule 104 (a) or (b).
Deposition or Affidavit of Law Enforcement Personnel (above)—————–
| Green2/Polk County Sheriff’s Department, Information about the former Sheriff Dan Daniels who maintained an intense rivalry with the press, was sued in 1986 by both The Ledger and The Tampa Tribune, and who left office after a grand jury investigation and started his own local newspaper. | Green/Polk County Sheriff’s Department Documents about this Artist as Witness at a Homicide April, 1986 subsequent to this event the newspaper gave this information to thie police with the intent of providing misleading and false information. |
MOTIVES FOR RETALIATION AGAINST
ME BY THE LEDGER
In 1985 I had grounds to file a complaint with the EEOC for reverse discrimination
and harassment against The Ledger.
1990 Affidavit by the Administrator at the Polk County Commissioners Office about the placement
of the then “former” Sheriff’s newspaper stand “The Eagle” next to The Ledger and The Tampa Tribune
and accross from the Polk County Courthouse.
An excerpt from the December 1985 Ledger with a protester in front of The Ledger, A New York Times
Newspaper protesting recent articles about the Sheriff. The Ledger was writing articles accusing the Sheriff
of being associated with the Klan and writing about alleged sexual harassment within his department.
UNDER CONSTRUCTION