OFFICE OF THE ATTORNEY GENERAL
STATE OF XXX
XXX §
Complainant, §
§
v. § Case No.
§
XX §
Defendant. §
COMPLAINT
To Ms. Katherine Fernandez Rundle,
State Attorney for the XXXX
NOW COMES XXX, Complainant, and files this Complaint against XXX, Defendant, and for cause would show you as follows:
1. Complainant and Defendant are currently embroiled in a landlord-tenant lawsuit at the
County Court, in and for XXX County, before Judge [Name]. The case number
for the above lawsuit is XXX.
2. On [Date], Defendant committed perjury during proceedings in the above-referenced
matter.
3. 2021 Florida Statutes § 837.02 provides as follows: “Except as provided in subsection
(2), whoever makes a false statement, which he or she does not believe to be true, under
oath in an official proceeding in regard to any material matter, commits a felony of the
third degree, punishable as provided in s. 775.082, s. 775.083, or s. 775.084.”
4. Defendant made false statements which he did not believe to be true. He was speaking
under oath before the County Court, in and for Miami-Dade County. A court hearing is
an official proceedings.
5. “As this court observed in Gordon v. State, 104 So. 2d 524 (Fla. 1958), the essential
elements of the crime of perjury are the (1) willful, (2) giving of false testimony, (3) on a
material point, (4) in a judicial proceeding, (5) by a person to whom a lawful oath has
been administered. Nowhere in this definition is motive a required element.”
6. Defendant willfully gave false testimony while testifying under oath before the County
Court, in and for Miami-Dade County. There is no doubt that Defendant is liable for
perjury.
7. Complainant has sufficient evidence to present a prima facie case against Defendant and
is ready to liaise with your office to avail it to you.
REASONS WHEREFORE, PREMISES CONSIDERED, Complainant respectfully requests you
to prosecute Malik Sardar Khan to the fullest extent allowed by law.
Dated this ____ day of XXX.
Respectfully Submitted,
___________________________________
XXX,
Complainant.
VERIFICATION
I, XXX, being duly sworn depose and say that I have read the foregoing
Complaint and know the contents thereof. That the same is true of my own knowledge except as
to those matters and things stated upon information and belief, and as to those things, I believe
them to be true.
_________________________________
(Sign in the presence of a Notary Public)
Sworn to and subscribed before me this ___ day of XXX.
______________________________
Notary Public
________________________________________
(Printed name of Notary Public)
My Commission Expires: ____________________
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