**BEFORE THE DESIGNATED HEARING OFFICER**

Jun 18, 2026

**BEFORE THE DESIGNATED HEARING OFFICER**

**CITY OF TAMPA, FLORIDA**

**IN RE: THE TRESPASS APPEAL OF:**

**BRYAN WILKINS,**

(Issued as "Unidentified Subject")

**Appellant,**

**v.**

**CITY OF TAMPA,**

**Appellee.**

**TPD Case No.: 26-113074**

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**SUPPLEMENTAL MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR REHEARING HIGHLIGHTING PERJURY OF THE CITY'S SOLE WITNESS**

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### **INTRODUCTION**

This supplemental memorandum is submitted to bring to the Hearing Officer's attention newly analyzed, material evidence of perjury by the City's sole witness, Corporal Jessica Hollis, which came to light during her testimony at the May 27, 2026, hearing. Corporal Hollis made multiple, irreconcilable, and contradictory statements under oath regarding the two central justifications for the trespass warning: (1) that employees verbally expressed fear, and (2) that Appellant entered a properly marked restricted area. These falsehoods are not minor discrepancies; they are material misrepresentations that undermine the entire factual and legal basis for the trespass warning and fatally compromise the integrity of the City's case. A decision predicated on perjury cannot stand.

### **FIRST INSTANCE OF PERJURY: CONTRADICTORY TESTIMONY REGARDING WHETHER EMPLOYEES VERBALLY EXPRESSED FEAR**

The City’s primary justification for the trespass was that Appellant’s presence made employees “afraid.” Corporal Hollis offered two diametrically opposed statements under oath regarding whether this fear was ever verbally communicated to her.

1. **First Statement: NO ONE Verbally Expressed Fear.**

Under questioning by Attorney Brandon, Corporal Hollis unequivocally denied that any employee had verbally communicated fear to her while Appellant was present in the building.

> **Attorney Brandon:** "No one verbally said that to you, no?"

> **Corporal Hollis:** **"No one verbally said that to you, no. Okay."**

> *(See Hearing Transcript, approx. 31:24)*

2. **Contradictory Statement: YES, Someone Verbally Expressed Fear.**

Later, under direct questioning by Appellant Bryan Wilkins about the exact same issue, Corporal Hollis completely reversed her sworn testimony, now claiming she was, in fact, verbally told that employees were scared.

> **Bryan Wilkins:** "...Did anybody in the building come and tell you that they were scared while we were there, yeah? ... Did anybody say this on your body cam is what I'm getting."

> **Corporal Hollis:** "...It's just yes or no."

> **Bryan Wilkins:** "Yes."

> **Corporal Hollis:** **"Yes."**

> *(See Hearing Transcript, approx. 01:11:43 - 01:12:26)*

These two statements are mutually exclusive and irreconcilable. Both cannot be true. Corporal Hollis either lied to Attorney Brandon or she lied to Mr. Wilkins. In either case, she committed perjury on a material fact.

### **SECOND INSTANCE OF PERJURY: CONTRADICTORY TESTIMONY REGARDING SIGNAGE**

The secondary justification—that Appellant caused a disturbance in a restricted area—was also based on false testimony regarding the placement of a sign.

1. **Initial Testimony: A Properly Posted Restricted Area.**

Corporal Hollis initially testified that Appellant had entered a restricted area that was marked by a sign, implying a knowing violation. *(See Hearing Transcript, approx. 24:03-24:10)*

2. **Later Admission: The Sign Was Moved AFTER Appellant Left.**

Upon further cross-examination, Corporal Hollis admitted the truth: the security guard, Lawrence Craft, moved the sign from the side to the center of the doorway *after* Appellant had already left the area. This was done specifically to create the false appearance that Appellant had disregarded a clear warning. This means **there was no properly posted restriction when Appellant was present in the area.** Her initial testimony was a deliberate misrepresentation of the facts on the ground.

### **LEGAL AUTHORITY ON PERJURY BY CONTRADICTION**

The law is clear that proving two contradictory statements were made under oath is sufficient to prove perjury, as both statements cannot logically be true.

* ***People v. Ricker*, 262 N.E.2d 456 (Ill. 1970):** The court held, **"By definition contradictory statements cannot both be true... Thus, proof that a person has made contradictory statements proves of itself, without aid of any presumption, that the person has made a false statement."**

* ***Papas v. People*, 55 P.2d 1330 (Colo. 1936):** Lying under oath about a prior inconsistent statement, a fact material to the witness's credibility, constitutes perjury.

* ***People v. Brilliant*, 58 Cal. 214 (1881):** A false denial of having made prior statements can constitute perjury if the witness must have known they had, in fact, made them.

### **MATERIALITY OF THE FALSE TESTIMONY**

Corporal Hollis’s false testimony was not incidental; it was central to the City's entire case. The "fear" of employees was the primary justification for the trespass. Corporal Hollis admitted this herself:

> **"Because the people who work in that building were afraid of you."** *(See Hearing Transcript, approx. 52:36)*

The materiality is undeniable. If her first statement (that no one verbally expressed fear) is true, then the entire "fear" justification was a post-hoc fabrication. If her second statement (that someone did verbally express fear) is true, then her first sworn statement was a deliberate lie. Either way, she committed perjury on the most critical fact at issue, rendering her entire testimony unreliable and the City’s justification baseless.

### **CONSEQUENCES OF PERJURED TESTIMONY**

Under Florida law and the Due Process Clause, a decision based on perjured testimony cannot stand. It is a fundamental fraud upon the tribunal. The trespass warning issued to Appellant was predicated on two pillars, both of which have now crumbled under the weight of Corporal Hollis’s false testimony: (1) the fabricated "fear" justification and (2) the nonexistent "restricted area" violation. The City has failed to present any competent, credible evidence to support its action.

### **CONCLUSION**

The sworn testimony of Corporal Jessica Hollis is riddled with material falsehoods and irreconcilable contradictions. She has demonstrably committed perjury, and the decision to sustain the trespass warning is therefore based on a foundation of lies. The integrity of this process demands that a decision tainted by such clear perjury be vacated.

WHEREFORE, Appellant respectfully requests that the Hearing Officer **vacate** the decision of May 27, 2026, based on this newly discovered evidence of perjury and **rescind** the trespass warning. Alternatively, Appellant requests a new hearing where Corporal Hollis may be properly impeached with her contradictory, perjurious statements.

Dated: May 28, 2026

Respectfully submitted,

_________________________

**Bryan Wilkins, Pro Se**

CHUCK BRONSON MEDIA