BREAKING: State Files Reply Defending Protective Order in Bubba Bozo Trio Case
Hearing on motion set Monday at 11:30 a.m.
Prosecutors on Friday filed a detailed reply defending their request for a protective order aimed at limiting the scope of a proposed deposition of Chief Assistant State Attorney Joe Mansfield in the criminal cases against the Bubba Bozo Trio — former Key West City Attorney Ron Ramsingh, his brother, former Chief Building Officer Raj Ramsingh and former Code Enforcement Director Jim Young.
Although the joint investigation between Federal authorities and the Monroe County State Attorney’s Office is on going — the trio currently face 27 felony charges together. All have pleaded not guilty. Suspects are considered innocent until proven guilty by a jury of their peers.
The filing, submitted Feb. 20 in Monroe County Circuit Court, responds to the defense’s opposition to the state’s motion for a protective order and argues that much of the testimony sought by defense attorneys would intrude into protected prosecutorial work product and privileged deliberations.
The hearing on the motion is scheduled for Monday, Feb. 23, at 10:30 a.m. before Judge Mark Jones.
In the reply — obtained and reviewed by Above the Fold — the State Attorney’s Office, led by State Attorney Dennis Ward and signed by Assistant State Attorney Colleen Dunne, acknowledges that Mansfield had a conversation with Ron Ramsingh on Aug. 22, 2024, regarding subpoenas issued to various City of Key West commissioners and officials. The filing also confirms that Ramsingh sent a follow-up letter to Mansfield on Aug. 28, 2024.
The state wrote that it is not seeking to prevent questioning about the Aug. 22 conversation or the subsequent letter.
However, prosecutors argue that inquiry into the “purpose, intent, and/or reason” behind the issuance of State Attorney’s Office subpoenas and preservation letters would constitute protected work product. The reply states that the defense has not demonstrated that such internal prosecutorial reasoning is discoverable or materially necessary to prepare a defense, including in the context of the pending charge of tampering with physical evidence.
The filing further addresses additional subject areas the defense has indicated it may explore in a deposition, including Mansfield’s attendance at a public City Commission meeting, communications with prior defense counsel and investigations into other individuals’ compliance with the subpoenas. The state contends those topics also fall under work-product and related privileges and that a “mere assertion” of relevance is insufficient to compel testimony.
Prosecutors also responded to references in the defense’s filings to “selective enforcement” and “disparate treatment.” The reply states that even if the defense intends to pursue a selective prosecution claim, established case law requires a threshold showing of discriminatory effect and intent before discovery into prosecutorial decision-making is permitted.
The state emphasizes that it is not seeking to block all inquiry into Mansfield’s interactions with Ramsingh, but argues that attorney-client privilege, work-product privilege, investigative privilege and prosecutorial deliberative privilege protect broader questioning into internal prosecutorial decisions.
Monday’s hearing is expected to focus on whether the court will grant the protective order and restrict the scope of any deposition of Mansfield.
This is an evolving story. Watch this space.