Filing # 199618730 E-Filed 05/31/2024 04:17:46 PM

IN THE CIRCUIT COURT, FOURTH

JUDICIAL CIRCUIT, IN AND FOR
DUVAL COUNTY, FLORIDA

CASE NO.: 2023-CF-3145

DIVISION: CR-E
STATE OF FLORIDA,

Plaintiff,

vs.

JEFFREY PAYNE CLAYTON,

Defendant.
_________________________________/

DEFENDANT’S SENTENCING MEMORANDUM

The Defendant, JEFFREY PAYNE CLAYTON, by and through his undersigned

counsel, files this Sentencing Memorandum for the Court’s consideration in imposing a

just and fair sentence at his sentencing hearing scheduled for June 14, 2024 at 1:30 p.m.,

and in support states the following:

A. PROCEDURAL BACKGROUND

Mr. Clayton was arrested by the Duval County School Board Police on March 22,

2023 and subsequently charged by Information with Offenses Against a Student by an

Authority Figure (Counts 1 and 2), Indecent, Lewd, or Lascivious Touching of an

Individual Between 16 and 17 Years of Age (Count 3), and Unlawful Use of a Two-Way

Communications Device (Count 4). This was the first time Mr. Clayton, then 65 years old,

was arrested in his life anywhere at any time. A GPS ankle monitor was installed on Mr.

Clayton at first appearance which he has had on during the entire pendency of his case.

He has not violated a single term or condition of pretrial release.

ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 06/04/2024 01:27:52 PM

 On April 24, 2024, Mr. Clayton entered guilty pleas as charged to this Honorable

Court pursuant to a partially negotiated plea agreement (attached along with the Amened

Information as Composite Exhibit A).

As part of the plea agreement, the Court is permitted to listen to testimony from

the seven other former DA students listed by initials in the plea agreement. It is imperative

to note, however, that Mr. Clayton has not and will not be criminally charged by the State

of Florida with any conduct relating to these individuals, and he maintains his adamant

denial of any criminal actions relating to them. As such, while this Honorable Court of

course can listen to any such testimony, the defense submits the Court should not give

undue weight to any uncharged and unsubstantiated allegations it may be presented with

by the State at sentencing.

B. JEFFREY CLAYTON’S CHILDHOOD & BACKGROUND

Jeffrey Clayton was born in Morristown, Tennessee along with his twin brother,

Barry Clayton. Barry died of muscular dystrophy at the young age of 17. Most of Mr.

Clayton’s childhood was devoted to helping his mother care for Barry with his father being

out of the home often as a pastor at a local church and personnel manager for a private

corporation.

After graduating high school from Mount Pleasant High School at the top of his

class, Mr. Clayton attended Samford College in Birmingham, Alabama. There, he met

and married his then wife at the age of 21 and earned his bachelor’s degree in 1980. He

continued pursuing his passion in the music theatre and vocal arena, and in 1984, earned

his Master of Music degree in Vocal Performance on a scholarship at the prestigious

Indiana University School of Music (“IUSM”). While at IUSM, he interned with the San
Francisco Opera, won various awards, and sang opera as a baritone singer and

performed in music theatre.

After his then wife obtained employment with the school board in Houston, Texas,

Mr. Clayton took a position as chairman of the vocal department at Houston Community

College (Northwest Campus) where he taught for seven years. Following his divorce, Mr.

Clayton met his current wife, Kim Janeen Keepers (f/k/a Kim Janeen Clayton), a music

teacher who auditioned for a show that Mr. Clayton was leading. The couple married in

1989 and had five children together.

The Claytons relocated to Jacksonville, Florida where Mr. Clayton accepted an

offer to become Worship Leader at the New Beginnings Church while simultaneously

pursuing a doctorate degree at Florida State University after applying, auditioning for, and

receiving a fellowship there.

C. CAREER AT DOUGLAS ANDERSON

In August 2000, Mr. Clayton began his career at Douglas Anderson School of the

Arts (“DA”) as a teacher and chair of the voice department. He also accepted an offer to

become the South Jacksonville Contemporary Church’s Worship Leader.

While at DA, Mr. Clayton transformed the school’s voice and choir programs as

evidenced by the achievements and awards he received and the countless students he

helped both there and in higher education or employment settings after graduation. These

achievements and accomplishments include (and some of the below are attached as

Composite Exhibit B):

• Gladys Prior Award Recipient for Career Teaching Excellence (one

of only four award recipients out of all Jacksonville public and private
schools and one of the largest monetary awards for teachers in the
country)(2008);

• Willis H. Page Music Award presented by the Rotary Club of

Jacksonville (2018)(one music specialist is chosen each year from the
Duval County Public School system who through music has inspired
children to improve their minds, gain confidence in their abilities and
potential, and achieve an appreciate for music and education);

• Applause Award for Best Music Director/Conductor of Chorus Line

(2022);

• State American Choral Director’s Association (“ACDA”) appearance

by Chorale Women (November 2004 and 2007);

• Regional ACDA appearance (2010);

• Mr. Clayton was part of several grammy awards and was the only
conductor to have been before a National ACDA Conference as part of a
performance choir from Northeast Florida (Chicago 2011);

• Provided countless pro bono voice training hours for the Florida
Vocal Association;

• Feature choir with Jacksonville Symphony Orchestra multiple times

and conducted performances for State Thespians Conventions multiple
times;

• Musical Director for the Jacksonville Children’s Chorus since August

2002;

• Prepared chorus for the Jacksonville Symphony Orchestra’s

production of Carmen (2004) and La Boheme (2005);

• Guest Conductor for Alabama All-State Choirs (2010), South

Carolina ACDA Convention (2012), Polk County Honor Choir – Boys and
Mixed; and

• Musical Director/Vocal Coach/Conductor of the following

performances while at Douglas Anderson (Rags – 2001, Sideshow – 2002,
Cabaret – 2006, Aida, Kiss Me Kate, and A Chorus Line).
order as Composite Exhibit D (full names and any photographs are redacted for privacy

and confidentiality in most letters).

JEFFREY CLAYTON’S DA PERSONNEL FILE

Aside from the countless former DA students Mr. Clayton taught, coached, and

assisted throughout the years both in and outside of the classroom, Mr. Clayton received

overall excellent and above performance reviews from many different individuals every

single year from as early as 2000 to as recent as his 2021 year-end review. Attached as

Exhibit E is Mr. Clayton’s personnel file received in response to a Public Records

Request. Some of the positive remarks/comments received throughout his career from

various members of DA’s administration are as follows:

• “Master of his subject area.” (2011 review);

• “Mr. Clayton has dramatically increased the number of students accepted into top
vocal performance universities.” (2009 review);

• “Student growth evident in performances.” (2008 review);

• “Mr. Clayton has effectively raised the level of the vocal department as evidenced
by the level of preparation the students receive and the number of vocal performance
scholarships offered. His strengths are his knowledge, experience, and implementation
of teaching strategies in the classroom.” (2007 review);

• “The vocal program continues to grow under Mr. Clayton’s leadership.” (2004
review);

• “The vocal program has grown under Mr. Clayton’s leadership. More student
scholarships have been earned and awarded under his tutelage.” (2003 review);

• “Committed to excellent in student achievement!” (2002 review);

• “As a first-year teacher and department chair at a demanding school, Mr. Clayton
has adjusted well. I look forward to his input in making our vocal program one of the best
nationally. His cooperation and dedication are valued!” (2001 review); and
• “Mr. Clayton made a significant contribution to our department, particularly in the
area of musical productions.” “Jeff demonstrates excellent teaching skills, exceptional
initiative and imagination.” (2000 review).

While Mr. Clayton acknowledges the five “substantiated” (a 2022 incident was

found to have been unsubstantiated after a full and complete investigation) disciplinary

records (other than the instant offense) contained within his DA Personnel File across a

twenty-three year span, it is important to note that not a single instance contains

allegations (let alone substantiated findings) that Mr. Clayton is even alleged to have

committed – let alone committed – actual criminal conduct. Moreover, none of the other

former students referenced in the plea agreement are subjects of any prior disciplinary

complaints (whether substantiated or unsubstantiated). The prior disciplinary instances

involving substantiated findings are as follows:

• In 2006, Mr. Clayton received a complaint for tutoring students for profit on
school grounds (written reprimand given).

• In 2008, Mr. Clayton was reprimanded for offering advice outside of his
teaching duties to a then student who suffered from an eating disorder by offering to
introduce her to his son who at the time also suffered from an eating disorder to help the
student.

• In 2016, records show that the then-student reported to DA personnel that

Mr. Clayton made comments about her “talent and focus”, her “attractiveness”, and that
Mr. Clayton “strokes her on the back at times making her feel awkward”. An investigation
was opened, and Mr. Clayton was disciplined and reprimanded. While certainly beyond
the boundaries of a teacher/student relationship, there were no allegations by this student
that Mr. Clayton attempted to develop any kind of a romantic relationship, touched or
attempted to touch her in a lewd manner, kiss her, or committed any criminal conduct.

• In 2020, Mr. Clayton received a verbal warning for failure to wear a mask
on three occasions during COVID.

• In 2021, it was reported that Mr. Clayton put his arm on the shoulder of a
student, rubbed her back, and told her she was beautiful in 2020. Mr. Clayton was
disciplined for this incident after the findings were substantiated. While certainly beyond
the boundaries of a teacher/student relationship, there were no allegations by this student
Exhibit J. He has also been attending the Faithful and True faith-based counseling

programs, continuing his volunteer and philanthropic work at a retirement home playing

piano and singing, and investing time in his church and related groups.

E. THE NEED TO AVOID UNWARRANTED OR UNJUST SENTENCING

DISPARITIES

Although every case is unique and the Court certainly must consider each case on

its own facts and circumstances, Mr. Clayton would submit that ensuring that defendants

with a lack of any prior criminal history who have been found guilty of objectively more

egregious conduct than Mr. Clayton’s in this case in the vast majority of the below cases

receive fair and sentences commensurate with the conduct to avoid unwarranted or unjust

sentencing outcomes is a matter of utmost importance to this Honorable Court. To that

end, the undersigned’s research revealed the following cases involving Florida teachers

and criminal conduct with students (arrest reports where available and news articles

where arrest reports were not available, pleas, judgment and sentences, and orders of

probation are attached as Composite Exhibit K):

A. Florida Cases Where Former Teachers Had Sexual Intercourse with Student(s)

These cases illustrate sentences for conduct objectively far worse than Mr.

Clayton’s where the former teacher had sexual intercourse with a student or students, but

who received a sentence often less than or close to Mr. Clayton’s sentencing guidelines

(33.6 months prison):

Lavelle Gordon (22-CF-10561)(Broward County)

Former Broward County English and Journalism high school teacher was arrested for
Offenses Against Students by Authority Figure after Gordon had sex with an 11th grade
student and engaged in a romantic relationship with the student over the course of over
8 months.
On May 11, 2023, Gordon received a withhold of adjudication and was sentenced to 5
years probation as originally charged (Offenses Against Students by Authority Figure).
Gordon served no jail time as part of this disposition.

Virginia Hinckley (15-CF-1614)(St. Johns County)

A former St. Augustine High School high school teacher was arrested for Unlawful Sexual
Activity with a Minor after engaging in a romantic relationship with a minor student, having
sex with the student, sending/receiving nude and sexually explicit photos to and from the
minor student, and telling the student not to disclose the relationship to law enforcement.

On June 7, 2017, Hinckley was sentenced to 6 months jail followed by 12 months

community control followed by 5 years sex offender probation.

Jennifer Fichter (14-CF-2790, 2967 and 4183)(Polk and Hillsborough Counties)

Former Polk County high school teacher arrested for 7 counts of Sexual Act by a Person
Over 24 Years Old with a Person 16 or 17 Years Old, and 3 counts in Hillsborough County
for Unlawful Sexual Activity with a Minor for having sex with a total of three different minor
students over a span of several years.

On July 2, 2015, Fichter was adjudicated guilty of all 7 counts in Polk County and
sentenced to 22 months Florida State Prison. The court downward departed from the
mandatory sentencing guidelines and found that the minor student victims were “willing
participants” in Fichter’s criminal behavior.

On April 28, 2017, Fichter was sentenced in Hillsborough County to 36 months Florida
State Prison followed by 1 year sex offender probation and convicted of one count of
Unlawful Sexual Activity with a Minor with the remaining two counts dismissed. The Polk
and Hillsborough sentences were run concurrently.

Daniel Norment (22-CF-3773)(Palm Beach County)

Former Palm Beach County middle school teacher who was arrested for Offenses Against
a Student by Authority Figure and Unlawful Sex Act with a Minor after he coerced a
student to have sex with him in a closet on school property after repeatedly rubbing her
on the back and shoulders and kissing her on the cheek over the course of at least a year.
Norment was also accused of allowing and watching other students change clothing in
the school room closet.

On September 12, 2022, Norment was adjudicated guilty of both counts and sentenced
to 3 years Florida State Prison followed by 4 years probation.
Paige Leduc (23-CF-126)(Okeechobee County)
A former Okeechobee County elementary school teacher was arrested for Sexual Activity
with a Minor (Defendant 24 Years or Older and Victim 16 or 17 Years of Age) for having
sex on multiple occasions with a minor female student, having a romantic relationship
with the student, and sending the student sexually explicit photographs of herself.
On August 3, 2023, Leduc was adjudicated guilty as charged and sentenced to 1 year jail
followed by 5 years probation with sex offender conditions.

Brittany Lopez-Murray (21-CF-17299)(Miami-Dade County)

A Miami-Dade County drama teacher at Hialeah Middle School was arrested for having
sex with a 14-year-old male student on multiple occasions on school property and for
sending sexual text messages with the student.

On December 13, 2023, after pleading guilty to three counts of Lewd/Lascivious Battery,
one count of Lewd/Lascivious Molestation on a Child 12-16 Years of Age, and two counts
of Unlawful Use of a Two-Way Communications Device, Lopez-Murray was sentenced to
two years community control followed by ten years of sex offender probation. She
received no jail time as part of the sentence.

Calvi Heiry (21-CF-017592)(Miami-Dade County)

Heiry was a teacher in Doral, Florida and was arrested for having an inappropriate
relationship with a 15-year-old student and possessing a firearm on school property after
she had sex with the student on multiple occasions and exchanged sexually explicit
videos and photographs with the victim.

Following a plea of guilty to Offenses Against Students by Authority Figures and simple
Battery, Heiry was sentenced on November 15, 2023 to a withhold of adjudication on the
felony charge, convicted of the misdemeanor battery charge, and 10 years of probation.
She received no jail time at sentencing.

B. Florida Cases Where Former Teacher Kissed and/or Inappropriately Touched

Student(s) and/or Engaged in a Romantic Relationship or Similar Conduct but no Sexual
Intercourse with Student

The following cases illustrate sentences for conduct similar to or objectively more

egregious than Mr. Clayton’s where the former teacher kissed and/or inappropriately

touched the student(s) at issue but did not have sexual intercourse with them or engage

in any sexual activity or similar conduct beyond that. The vast majority of every single one
of these former teachers (including cases from the Fourth Judicial Circuit) received

sentences less than Mr. Clayton’s minimum sentencing guidelines of 33.6 months prison:

Joseph Sparks (19-CF-3388)(Okaloosa County)

A former Okaloosa County middle school teacher was arrested for soliciting and/or
engaging in lewd behavior with a student, engaging in a romantic relationship with a
student, and failing to report child abuse after sending hundreds of sexually explicit text
messages to a 13-year-old student (including Sparks’ request to have the minor send him
a photograph of herself in her underwear).

On December 11, 2019, Sparks received a withhold of adjudication for the failure to report
child abuse felony charge and sentenced to 3 years probation. All other counts were
dropped as part of the plea deal and Sparks received no jail time at sentencing.

Jeannette Valle-Tejeda (21-CF-5350)(Miami-Dade County)

A former South Florida high school teacher was arrested for sexually molesting multiple
students over a period of years, including one female minor student as young as 11 years
old.

On September 15, 2022, Valle-Tejeda received a withhold of adjudication to three counts

of Aggravated Child Abuse Involving Great Bodily Harm or Torture and received two years
community control followed by 8 years probation. She served no jail time as part of the
plea deal.

Carlos Aguirre Rendon (22-CF-100232)(Volusia County)

Former Volusia County middle school math teacher who was arrested for Lewd &
Lascivious Conduct and Witness Tampering in a Felony Proceeding for kissing a 15-year-
old student in his classroom, engaging in a romantic relationship with her and meeting
with and touching her outside of the classroom (including at a local park), and attempting
to prevent another student and witnesses from telling law enforcement about it.

Aguirre Rendon pled guilty to reduced charges of Child Abuse and Witness Tampering in
a Felony Proceeding and was sentenced to 5 years probation with sex offender conditions
on March 2, 2023. He served one day in jail.

Brian Kornbluth (17-MM-2016)(Palm Beach County)

Former 4th grade teacher in Boca Raton who was arrested for kissing and hugging two
students (including one as young as 10-years-old student) in his classroom and luring the
other student (the 10-year old’s sister) with gummy bears.
On May 16, 2017, Kornbluth was sentenced to one year of probation after pleading guilty
to a reduced charge of Battery and received a withhold of adjudication. He served no jail
at sentencing.

Andrea Jimenez (18-CF-24825)(Miami Dade County)

A former Doral science teacher was arrested on two counts of lewd and lascivious
behavior after repeatedly luring a 12-year-old minor student into her classroom and
attempting to kiss him and sending multiple sexually explicit text and social media
messages over a period of months and professing her love for the minor student. Jimenez
also bought the minor clothing, shoes, electronics, and books, and warned him not to talk
to girls his own age.

On November 20, 2019, Jimenez received a withhold of adjudication on one count of

Child Abuse and was sentenced to 5 years probation. She received no jail time at
sentencing.

Jason Jamall Camaron Clark (21-CF-1670 – Duval County)

Former Ribault High School math teacher arrested for Offenses Against Students by
Authority Figures and Contributing to the Delinquency of a Minor after Clark, during a
FaceTime conversation with the minor, asked for the minor’s address and, minutes later,
met up with the minor at a local convenience store near her home, entered Clark’s car,
and engaged in or attempted to engage in a sex act with the minor.

On November 17, 2021, Clark pled guilty to Offenses Against Students by Authority
Figures and was sentenced to 4 months Duval County Jail followed by 2 years probation.
After violating probation at least 4 times, some of which included new law violations and
arrests, Clark’s probation was revoked and terminated and sentenced to 6 months Duval
County Jail.

Michele Anne Little (23-CF-4217)(Sarasota County)

Michele Little, a former Sarasota Military Academy High School teacher, was arrested on
April 28, 2023 for engaging in sexual conduct with a minor student on multiple occasions
during school hours on school property and for indecent lewd or lascivious touching of
certain minors of the breasts, genitals, genital area, or buttocks, or the clothing covering
them.

On November 8, 2023, Little pled no contest to a reduced charge of Child Abuse and
received a withhold of adjudication, 45 days of community control followed by 2 years
probation to attend counseling and perform 50 hours of community service. She served
no jail time as a part of this sentence.
James Rankin Johnson (21-CF-001412 – Duval County)
Former New Beginnings Christian Academy teacher James Rankin Johnson was arrested
on February 11, 2021 for Offenses Against Students by Authority Figures and two counts
of Lewd or Lascivious Molestation after touching a minor female student on multiple
occasions in her vagina and other prohibited areas underneath her clothing, and the minor
victim touched Johnson’s penis, and for sending sexually explicit messages to the minor
through multiple social media apps and in written notes over the course of a year.

Johson pled guilty to and was convicted of a count of Offenses Against Students by
Authority Figures and was sentenced on March 14, 2023 to 4 years Florida State Prison
followed by 5 years of sex offender probation. All remaining charges were dropped at
sentencing.

Christine Samantha Dennard (19-CF-012040 – Duval County)

Christine Denard was a former First Coast High School teacher and chorus director who
was arrested on November 22, 2019 for five counts of Unlawful Sexual Activity with a
Minor (then 16) for having sex – both oral and conventional – and digitally penetrating a
minor student on multiple occasions over a 7-month time frame and forming a romantic
relationship with the minor.

On June 7, 2021, following a plea to Unlawful Sexual Activity with Certain Minors,
Dennard was sentenced to 18 months Florida State Prison followed by 5 years of sex
offender probation. The remaining four felony charges were dismissed at sentencing.

Kristopher Paul Beckstrom (18-CF-9706 – Duval County)

Beckstrom was a Former Landon Middle School music teacher who was arrested for
Producing or Promoting a Sexual Performance involving a minor child and Transmission
of Material Harmful to Minors after requesting sexually explicit videos and photographs
from and transmitting sexually explicit pictures and videos to a minor student over the
course of at least two years and pretending to be a 17-year-old boy. Beckstrom also
exchanged sexually explicit images with a second minor female student who made
contact with the first minor student and informed her that Beckstrom was in fact a 42-
year-old middle school teacher at Landon Middle School. He is also alleged to have stolen
a pair of underwear belonging to third minor student from her volleyball bag.

On August 22, 2019, Beckstrom pled guilty to and was convicted of Promoting a Sexual
Performance and two counts of Transmission of Material Harmful to Minors and
sentenced to 3 years Florida State Prison followed by 3 years sex offender probation.

Tylar Reagan (22001327CFMA – St. Johns County)

On December 30, 2021, Reagan, a former weightlifting and track and field coach at
Bartram Trail High School and a volunteer at Pedro Menendez High School, was arrested
for two counts of Engaging in an Act Which Constitutes Sexual Battery Upon or With a
Child (Older than 12 but Younger than 18) after sending two different minor female
students sexually explicit social media messages, including nude images of himself, and
having sexual intercourse and orally and digitally penetrating the student on
approximately 30 different occasions over an almost 4 year term from August 2015 to
May 2019. The second minor student was contacted by Reagan on social media and
Reagan sent her explicit videos and images of himself including videos of him
masturbating. Throughout the course of their relationship spanning at least a year,
Reagan had sex with the minor in a storage shed on school grounds and elsewhere on
at least 6 different occasions.

On August 29, 2023, following a plea of no contest to two counts of Felony Battery,
Reagan was sentenced to 10 years probation with 2 years of community control. He
received no jail time at sentencing.

Kenneth Gordon (23-CF-7104)(Duval County)

Gordon was a biology teacher at the Duval Charter School at Mandarin when he was
arrested on June 27, 2023 for two counts of Lewd or Lascivious Conduct after at least
seven students reported that Gordon had touched, slapped, or “tickled” their buttocks
during class and made comments about how big his penis is on multiple occasions,
whether the female students in the classroom liked a big penis, discussed pornographic
websites with students during class and asked students if they liked it, discussed how he
liked to “lick whip cream off of his wife”.

After pleading guilty to one count of Felony Battery, Gordon was sentenced to 3 years
probation on October 11, 2023. He served no jail time at sentencing.

Daniel Fernandez (21-CF-17174)(Miami-Dade County)

Fernandez, then a 36-year-old middle school teacher at Renaissance Charter Middle
School in Doral, was arrested for sexually assaulting a 14 year old female student against
her will on multiple occasions by kissing her and fondling her over and underneath her
clothing, including on one occasions in a classroom storage closet.

On January 30, 2024, Fernandez was convicted of Engaging in a Sex Act on a Child in a
Custodial Relationship, Lewd/Lascivious Molestation on a Child Between 12-16 Years of
Age, and Lewd/Lascivious Conduct on a Child Less Than 16 Years of Age, was
designated a Sexual Predator, and was sentenced to 5 years Florida State Prison
followed by 10 years of Sex Offender Probation.

Kyle Spitzer (23-CF-651)(St. Johns County)

Spitzer was a middle school Chemistry teacher employed by the St. Johns County School
District when he was arrested on December 15, 2022 for sending photographs of his
penis to a 13 year old female student on multiple occasions through Snapchat and asked
that the student come over to his house to “hang out” and also purchased vape pens for
other students at the school.
Sptizer pled No Contest to three counts of Transmission of Material Harmful to Minors
and was sentenced on October 26, 2023 to 3 years Florida State Prison followed by 2
years probation with sex offender conditions.

Roberto Diaz (23-CF-1524)(Polk County)

Diaz, a then 54-year-old 9th grade Bible Study teacher’s assistant for Poinciana Christian
Preparatory School South, was arrested for touching a minor female student’s breast
area, kissing her, and asked the victim for nude photos.

Following a plea of No Contest to one count of Offenses Against Students by Authority

Figure, Diaz was sentenced to 3 years probation. He served no jail time at sentencing.

F. CONCLUSION

The Defendant respectfully requests this Honorable Court impose a just and fair

punishment of 33.6 months in the Florida State Prison (the term of incarceration

mandated by the mathematic sentencing guideline formula as established by Florida law)

followed by a term of probation to continue mental health counseling and therapy,

maintain full time employment, and continue to abide by the law.

Such a sentence fully considers the facts of this case, Mr. Clayton’s lack of any

prior arrest or criminal history, full and complete compliance without a single alleged

violation of all conditions of pretrial release, and the substantial support and character

attestation from prior DA and non DA students, parents, colleagues and others shown in

the characters letters attached herewith and by way of live testimony presented at

sentencing, while at the same time imposing a harsh punishment for Mr. Clayton’s

crimes.

Dated this 31st day of May, 2024.

 WOOLSEY MORCOM, PLLC

By: /s/ John Rockwell

JOHN ROCKWELL
Florida Bar No. 779911
203 Fort Wade Road, Suite 260
Ponte Vedra, FL 32081
(904) 638-4235 (telephone)
Email: john@woolseymorcom.com
Second: kennedy@woolseymorcom.com
ATTORNEY FOR DEFENDANT

CERTIFICATE OF SERVICE

I hereby certify that on this 31st day of May 2024, I electronically filed the foregoing
with the Clerk of Court by using the Florida E-portal, which will send an electronic service
copy to:

Office of the State Attorney 4th Circuit

Anna Hixon, Esq.
Ed Austin Building
311 West Monroe Street
Jacksonville, Florida 32202
sao4duvalcriminal@coj.net

/s/ John Rockwell

Attorney