Case 2:14-cv-00270-PAM-MRM Document 324-1 Filed 02/02/17 Page 1 of 2 PageID 10681
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ALEKSANDAR STEPANOVICH,
MONIKA MOZOLICOVA, and IVANA KAVAJA
Plaintiffs,

CIVIL ACTION
Case No. 2:14-CV-270-PAM-MRM

v.
KYLE BRADSHAW, et al.,
Defendants.

AFFIDAVIT OF STEPHEN P. NORMAN
I, Stephen P. Norman, being of the age of majority and having personal knowledge of the
matters set forth below, do testify under oath that the following statements are true and correct:
1. On February 1, 2017, I received a voicemail from a former Naples Police Officer
claiming to have information about the case.
2. I followed up on the information left in the voicemail and determined that it pertained to
a pattern and practice of illegal activity by the Naples Police Department.
3. As a direct result of the conversation with the witness, I conducted a brief investigation
using information obtained from the witness. That investigation resulted in me finding
two additional witnesses.
4. On February 2, 2017, I received additional information for two different former Naples
Police officers who provided additional information concerning a pattern and practice of
illegal stops and searches by the Naples Police Department Midnight shift of which Kyle
Bradshaw was a member.
5. In support of these claims I received a letter written by Charles Ankenbauer, dated April
15, 2012, approximately one month before the incident.

 Case RM Document 324-1 Filed 02/02/17 Page 2 of 2 PagelD 10682

6. Mr. Ankenbauer agreed to provide an affidavit af?rming that a signed copy of the letter
was hand delivered to Captain Adams of the Naples Police Departement.

7. All of the new information was not known and could not have been discovered through
due diligence.

8. Plaintiffs were diligent about requesting said information, but the information in the sole
possession ofthe City ofNaples, was not disclosed.

9. Additionally, officers and employees for the City of Naples, constantly denied that there
was any knowledge ofa pattern and practice and represented the incident with Kyle
Bradshaw as an isolated incident.

lO. 1 have the names and addresses of the two additional former police officers and will
provide them upon directive from the Court.

1 l. The information provided is true and correct to the best of my knowledge.

Further the affiant sayeth naught.

  

 

?a - 
Stephe?iyonnart 

SUBSCRIBED TO AND SWORN before me, a Notary Public for the State of 
A
Country of 05/4 on this Ca? day of
F?brvara/ ,2017. (?unf?j/




NoteiryPu?bliC Jim/4455M,

KELLY M. HEBBLE
?5 Notary Public - State of Florida

'5 My Comm. Expires Jul 30. 2017
Commission FF 041087