Amended Initial Brief
- Sire Business Review
- Jan 21
- 14 min read
Case 25006414MM10A / 4D2025-3665 Document FBMN41 Filed 01/21//26 Page 1 of 10
January 21, 2026
Via E-Filing and Email
Fourth District Court of Appeal
Courthouse in West Palm Beach
110 S Tamarind Ave, West Palm Beach, FL 33401
January 21, 2026
Via Email
Supreme Court of the United States
1 First Street, NE
Washington, DC 20543
January 21, 2026
Via Email
Seventeenth Judicial Circuit
201 SE 6th Street Florida, FL 33301
Re: Josue Moran v. State of Florida
Dear Whom It May Concern,
[Concision]: Warden Moran changes the plea from “judicial immunity” to “educational immunity, " suggesting he is not only immune to civil lawsuits but also criminal prosecution.
[Concision]: Warden Moran unhides the “necessity defense,” and removes the self-defense plea.
[Concision]: Warden Moran reveals the 1st amendment plea as a closing argument.
Dear Whom It May Concern:
This letter is in response to Judge John. D Fry’s guilty verdict. It is my understanding that I wish to appeal and start the process of submitting briefs that explain why judgement was wrong to the higher courts.
I started off strong on the first witness named Juan Rodriguez with setting up a moral counter argument. However, when I asked the witness if I ever disclosed to them that I was “the founder at Sire University,” I failed to include “Founding Warden” in that question. This mistake significantly weakened my credibility as someone who is the founder and “serving” – and I didn’t even ask him much of anything else. Another weak area is when I declined to question Morgan Durinick. I had mistaken her to be Michelle (an associate from Bank of America) where I had questions prepared for more moral arguments. This confusion impeded court findings that might have favored the defendant. It is my belief that the Judge is negligible for not clarifying this issue; when Morgan stepped down from the stand. I did not really care at the time because even if Morgan said there was excessive force involved by the arresting officer; suing the state of Florida would amount to nothing when compared to sanctioning/sue Bank of America since they have more money.
I had numerous statements prepared for my defense. The Judge asked me not to refer to my notes. I was only able to say out loud the “no food” argument and that was a moral argument. Thinking back obviously that was weak. There was an error when I said no to Judge Fry when asked if I had anything else to say; I interpreted the judge to mean if I had anything else “not written” to say.
Having analyzed the court proceedings and legal precedent… I will be taking extra steps to ensure the legal question is answered in full: “I could not hear a Trespass warning.”
I had 11 not guilty reasons prepared, one was hidden:
• presidential immunity; 1st amendment; police defiance; humanity; absolution; demonic possession; impregnated status; empathy quality; true character; educational immunity; good life; necessity-defense.
For convenience, Sire University has the reasons that would have significantly altered the legal verdict highlighted in bold (4/12) and apologize for doing whatever we wanted/acting cocky in a judge trial that clearly had no jury.
Case 25006414MM10A / 4D2025-3665 Document FBMN41 Filed 01/21//26 Page 2 of 10
The Latest Family Feud:
My mother got into an argument with my father this morning. The morning started with me writing this letter in my room. I overheard mother tell me not to leave the strawberries in the case half bitten and throw them in the trash. I let mother know that the trash was full because I was concentrating on writing. Mother then asserts quietly that she took out the trash. Then she talks about how I have no value for the food to which I ignore.
Mother fights with my father about him bringing his entire family over the weekends and not picking up their trash. She is hurt because my father doesn’t do anything to mitigate mother’s suffering. Her volume increases. Father lets her know you're gonna go to work like that now? Mother says “you don’t got a job - how about you do it.” “You do it,” father says. Mother goes ballistic. I remain safe in my room under cover of visual privacy with my door being closed. Though it can easily be broken down. Father doesn’t raise his voice much here. It seems like he knows when mother wins. For once mother gets to bully father.
Mother: “You think you're the king of this house.”
Father: “I don’t think of the king of this house, this house belongs to all of us.”
Mother: “You allow strangers (one stranger, one my cousin that idk) in that guest house while my mother and his (schizophrenic) son aren’t allowed to come here. My own mother can’t even be brought into this house from Cuba due to no space.”
Father: “Yeah he was –”
This conversation just escalated from here on out. To the point where mother threatens to call the police and have the people back there and people being invited on weekends out of the property. Father had enough of my mother’s bullying and he raises his voice but his stance is short lived as mother matches; if not goes over him. The thing about what makes this argument special are a couple of things:
Mother has a brother in the United States who helped our family 20 years ago.
Brother has been brought into conflict with father after learning of my father’s abuse to my mother
Brother lives in a home rental - didn’t buy a house
Brother has a schizophrenic son
Brother is handicapped at hands due to labor
Brother has yet to receive his disability pension
Mother threatens to call the police to remove father’s family members.
This is significant because my father relies on income made from the two people housed in the guest house, earns $2,000 a month… plus a retirement pension: $900.
It’s his family.
He has no one else to talk to.
I don’t know but I’m glad I didn’t leave my room. The conversation got pretty heated. My nephews are running around preparing for school. My sister tries to say something but just takes the kids to the car and bolts to work and school.
Father: “Stop threatening to call the police and do it already. You’ll see what I’ll do.”
Mother: “We’ll see how we go down” (she said “touch” in spanish, I don’t remember)
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The Devil Made Me Do It Defense
The title is The Devil Made Me Do It Defense. We saw this defense play out in the courts by Arne
Johnson… The judge rejected Mr. Johnson’s sense of not being guilty over demonic possession.
He was ultimately convicted of 1st degree manslaughter for killing his landlord, Alan Bono. He
served 5 years of a 10-20 sentence and was released early for good behavior.
Now that we got that out of the way, we must first come to the agreement that we as humans
have interior actions that come from within and exterior actions that come from outside our
control. If I pick up my phone - that is considered an interior action of which I am 100%
responsible for. If I am running and my phone pierces through the cotton and falls - that is
considered an exterior action of which I am 0% responsible for. Now that we have identified
what interior and exterior actions are, it is now time to add attributions. Bank of America closed
my bank account. Why was there? Because they closed my account. Because “the devil” made
I do it. For those who think I should have been stronger than the devil: I want you to think
about Billy the kid. Billy was walking one day on the sidewalk when a gust of wind pushed him
and a car hit him. Was Billy stronger than the Devil? Billy was a good kid, wasn’t he? Mr.
Johnson got his high school diploma in prison. I attribute Mr. Johnson to Billy. If only he knew
how to attribute things that make sense to all of us… I attribute the gust of wind Billy endured as
a natural evil force that invoked unnatural evil, resulting in an exterior action to which Billy was
not responsible for. It was a determined action against libertarianism; the freedom to choose
otherwise was taken from Billy through temporary demonic possession. I know it sounds insane
but I was there because if I hadn’t been I would have been dead. I would never have gotten my
account reopened and been able to transfer the $1,000 dollars to another bank and order food.
This argument is then re-titled by me from The Devil Made Me Do It Defense to The God
Made Me Do It Defense.
I re-titled this argument again to The Devil and God Made Me Do It.
The reason for the title change is because the Devil does not have the power to control me acting
alone. Only God does. So how could the Devil have controlled me? Because God allowed the
Devil to. When God created this world - it was perfect. There's a fire in somebody's house, you
say? You bring people buckets of water to take out the fire… If there was no fire, then there
could never be character. With this in mind, God created a perfect world. But- it was not the
perfect kind[s] of worlds. There is famine, natural disasters, and the invention of wars that could
be described as the Devil’s work.
God gave us free will but he also gave the Devil free will as well. When Adam gave Eve the
Apple, the Devil told Eve to eat it for no fault of her own. Thinking about this in my situation – it
could only be described as the work of God and the Devil. My bank account is reopened as I’m
writing due to trespassing at Bank of America. If I didn’t Trespass I would have had to wait 30
days for the check to be mailed but because God intervened - he gave me permission..
Looking back at how perfectly everything was choreographed; the bad parts, where the act of Trespass was done, are the work of the Devil; just as President Trump has said that “the good parts are my doing in this country” and “the bad parts are Biden’s
country” when asked by a reporter.
Case 25006414MM10A / 4D2025-3665 Document FBMN41 Filed 01/21//26 Page 4 of 10
[Concision]: Warden Moran, essentially, goes ballistic with the questions when compared to the 1st trial. Warden Moran gave Juan the opportunity to side with him, asking “would you just change the outcome if you were a superior” but he chose to be mad at police for taking long and my little questions were only targeted at an anarchist society.
[Concision]: These questions frame Warden Moran to be a public servant.
[Concision]: These questions frame Warden Moran to have had permission to Trespass. And thus, “not being able to hear a warning.”
[Concision]: Warden Moran drops a boom of a defense by introducing the Educational Immunity plea.
Witness Questions: JUAN RODRIGUEZ
Did I ever tell you or the police that I was the Founding Warden at Sire University?
What is Bank of America’s role in society?
Did I engage in dialogue with you and other staff about your immediate safety? For example, asking you if you have eaten?
When I asked you if you have eaten anything, you responded no, correct?
When did the branch close on that Saturday? (2:30pm)
When did the police arrive? (5pm-6pm)
I saw that you were next to Michelle when I asked for a brownie, correct?
I told her that I would give her $5 dollars for one of four muffins she had. She asked me to prove it. Then she asserted that she didn’t want to take my money, correct?
You mentioned about considering ordering pizza, correct?
Would you give me a slice for $5 dollars?
Can you say how many public servants were at the private Bank of America branch at the time of the police arrival?
Did you know public servants have permission to Trespass if harm is imminent?
Can you point to public servants in this court room who have absolute judicial immunity from only civil lawsuits?
Did you ever say you were mad or upset? Were you mad with the company or the police?
Did you feel we weren’t important enough when the police took hours to arrive?
Did you know that Wardens of prisons receive qualified judicial immunity?
Can you point to the public servants in this courtroom who have educational immunity from both civil and criminal prosecutions? (Relevant because if he knew who I was, Bank of America would have no chance against me in court.)
No further questions, your honor.
Case 25006414MM10A / 4D2025-3665 Document FBMN41 Filed 01/21//26 Page 5 of 10
[Concision]: Warden Moran has entered a “I’m not playing anymore” mode line of questioning. A stark contrast from the 1st trial where Warden Moran just asked Cory if he used excessive force, and that was it.
Witness Questions: Cory Moore
How are you?
Did I ever tell you that I was the Founding Warden at Sire University prior to this day?
Do you recall answering “no” to my question of whether or not you used excessive force in our first trial?
Are you afraid of me, Officer Moore? (Relevant because if found to use excessive, I can punish him.)
I’ll tell you why you should be. Are you aware of the allegations I have raised against the State of Florida?
These allegations include:
Failure to Comply with University Staff Directives – Responsible
Disorderly Conduct – Responsible
Harmful Behavior (Verbal or Written Communication) – Responsible
Retaliation – Responsible
Battery on University Staff Directives – Responsible
Terrorism (Deadly threat) – Responsible
There is a clear preponderance of evidence to suggest that you were in violation of Sire University policy. Sanctions have been assigned to assist what the State of Florida was set to do in serving and protecting the American people.
Pass the “Take Care of the American Bill Act”.
This bill proposes that the federally funded Bank of America be held accountable when suspending/expelling/ and or closing accounts with balances in them. Granting Americans immediate withdrawals.
Fire the arresting officer, Cory Moore.
Approve the 1 billion deposited funds into my Bank of America Account.
I’ll tell you what: If you confess to using excessive force at the time of arrest, I won’t recommend your termination.
Further questions if he answers no:
Did you verbalize asking me to enter the car?
Did you put your hands on me?
Did you tighten those hands on my frail starving arms?
No Further questions, your honor.
Case 25006414MM10A / 4D2025-3665 Document FBMN41 Filed 01/21//26 Page 6 of 10
[Concision]: Warden Moran questions Morgan. Something he did not do during the first trial due heavily relying on his “moral arguements/reasons”... Something he could not do since there were no civil judges present.
[Concision]: Warden Moran executes his line questioning precisely to target the legal present: Was there excessive force involved by the arresting officer.
Witness Questions: Morgan Durinick
I would like to take this time to ask you some questions on the day of my arrest. Were you 100% of the time close to my arresting officer, Cory Moore?
The manager did not issue a Trespass warning when the male officer and you entered the financial center, correct?
Do you recall me asking to be arrested?
Do you recall Cory declining my offer stating “I can’t because there isn’t a victim yet?”
Do you recall Cory asking me to talk outside?
Do you recall when I told him "I'm not moving?”
Do you recall Cory saying “if you don’t move, I will help you move?”
If hadn’t moved and he put his hands on me, would you have tried to protect me?
Did Cory push you as you both attempted to cuff my hands?
Did you try to arrest me to protect me from Cory?
Did you see Cory’s hands on me?
Did you have vision or partial vision of him tightening those hands on my frail starving arms, causing bodily harm, as he dragged me to the car?
No further questions, your honor.
Case 25006414MM10A / 4D2025-3665 Document FBMN41 Filed 01/21//26 Page 7 of 10
[Concision]: Warden Moran demonstrates his “pardoning” power. Something he did not do in the 1st trial.
Luigi Mangione Defense
This argument is titled the Luigi Mangione Defense. This argument is designed to play as a
measure of demonstration to the powers vested in me an educational Founding Warden at Sire University..
A message I sent to Luigi Mangione’s attorneys: Karen Friedman Agnifilo, Marc Antony Agnifilo,
Dominic A. Gentile, Jacob Kaplan, Alexandra S. Messiter, Avraham Chaim Moskowitz, Thomas
John Wright, Jun Xiang
My name is Josue Moran and I’m the Founding Warden at Sire University. It has been
brought to my attention that your defendant is facing serious criminal charges at the state and
federal level. President Trump, unfortunately, can only pardon federal charges and not the state
murder charge due to it occurring in the state. The judiciary is bound by the law, which prohibits
the court from intervening in the matter. I would like to demonstrate what the power of education
can do in these situations. With receiving President Trump’s blessing and with me being a
recognized educational cause very soon… (Was arrested for trespass at Bank of America and
now they’re gonna pay for that.) I can mirror the New York State’s governor, Kathy Hochul,
ability to pardon.
I must warn you that my ability to mirror the governor’s clemency powers may not be as
effective nor serve a guarantee for your client. But I do definitely believe it helps when and if it
comes down to the Judge’s decision on life imprisonment or the death penalty.
Case 25006414MM10A / 4D2025-3665 Document FBMN41 Filed 01/21//26 Page 8 of 10
The necessity defense that Florida recognizes in limited cases can justify otherwise criminal acts (including some trespasses) if:
The act was done to prevent a greater, imminent harm.
There was no reasonable legal alternative.
The harm avoided was greater than the crime committed.
The defendant didn't create the situation themselves.
I.
The first clause is supported because I was severely starving.
II.
The second clause is supported because I was starving and unable to access alternatives due to low brain power.
III.
I retrieved my $1,200 dollars in exchange for a night in jail for a bond set at $500.
IIII.
Bank of America closed my account. A decision I could not control as banks can close accounts at any time for any reason.
Case 25006414MM10A / 4D2025-3665 Document FBMN41 Filed 01/21//26 Page 9 of 10
[Concision]: Warden Moran ends with recommending the judiciary grant him educational immunity. Something he did not do in the 1st trial.
[Concision]: Overall, it seems as though Warden Moran is no longer playing around with the witnesses power and the Judge’s power, and is actively making reasonable efforts to be found not guilty. Kind of like if a divine being gave them a chance to do good on their own part… Thinking "oh I know them…” I know they wouldn’t do that… And enter a guilty verdict. But Judge Fry did… And so Warden Moran retaliates with the full arguments addressing the legal question: “Could Warden Moran hear a Trespass warning?”
Educational Immunity
I recommend the Judiciary before me to consider granting me educational immunity from both civil and criminal prosecution(s). This makes it difficult for any party to bully me, my educational institution, and finally at least making one educational cause achieve total independence.
Case 25006414MM10A / 4D2025-3665 Document FBMN41 Filed 01/21//26 Page 10 of 10
Closing Argument
I may hold the originating court in contempt and be remanded in any department of corrections facility until their authority on the guilty verdict is changed or removed/lifted/relieved of duties.
Such methods I may impose:
Revisiting Bank of America and demanding they Trespass me.
Issue a command to law enforcement: “I command you to arrest me.”
The need for this command is dependent on whether the manager wants to verbalise a Trespass warning.
If the arresting officer fails to comply with my command or rejoice in a society where the good of things are done for eachother… I may issue this command: “I’m gonna kill the United States President if you don’t arrest me”.
I didn’t Trespass somebody’s house. We're talking about the 1st amendment rights of the Constitution. I walked into a bank that closed my account – held my food, and as a result demanded reparations for the damage caused in a peaceful non-violent movement. So, I am asking that you please speed up this appeal process so I can figure out what my next steps are. I come from many family hardships as you may or may not know and live in a rural area. And do not want to see either of them: a. die; b. kill each other; c. starve to death before they die.
Respectfully submitted,
Hon. Josue Moran
Founding Warden
Sire University, Inc.
Fort Lauderdale, Fl, 33312
cc: All white house correspondence (by email)
All Harvard Office of Admission
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