Notice of Filing — No. 1:22-cr-00032 (Dkt. 53, N.D. Fla.)

Summary

A Notice of Filing, Document 53 filed October 17, 2023 in the Northern District of Florida, Gainesville Division (Case 1:22-cr-00032-AW-MAL), United States v. Joseph Harding. Through counsel, the defendant submits a letter from Caleb R. Leibee, D.O. in connection with his Sentencing Hearing on October 19, 2023. In the letter, an emergency medicine physician at Sarasota Memorial Health and assistant professor at Florida State University describes a long friendship from their shared upbringing, praising the defendant's loyalty, service and resolve, and his care for his family and for people struggling in his community. He writes that he had hoped to speak at sentencing but is out of town.

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      Case 1:22-cr-00032-AW-MAL Document 53 Filed 10/17/23 Page 1 of 4




                 UNITED STATES DISTRICT COURT
             FOR THE NORTHERN DISTRICT OF FLORIDA
                      GAINESVILLE DIVISION

UNITED STATES OF AMERICA

v.                                         CASE NO.: 1:22CR32-AW/MAL

JOSEPH HARDING
_____________________________/

                             NOTICE OF FILING

      Defendant Joseph Harding, through counsel and in connection with his

Sentencing Hearing on October 19, 2023, respectfully submits the attached letter

from Caleb R. Leibee, D.O.




Dated: October 17, 2023                    Respectfully submitted,

                                           /s/ John F. Lauro
                                           John F. Lauro, Esq.
                                           Florida Bar No. 794074
                                           jlauro@laurosinger.com
                                           Filzah I. Pavalon, Esq.
                                           Florida Bar No. 1033403
                                           fpavalon@laurosinger.com
                                           LAURO & SINGER
                                           400 N. Tampa St., 15th Floor
                                           Tampa, FL 33602
                                           813.222.8990

                                                 - and -




                                       1
      Case 1:22-cr-00032-AW-MAL Document 53 Filed 10/17/23 Page 2 of 4




                                               Ron Kozlowski
                                               Florida Bar No. 69432
                                               ron@toklegal.com
                                               Peg O’Connor
                                               peg@toklegal.com
                                               Florida Bar No. 170471
                                               TURNER O’CONNOR KOZLOWSKI, P.L.
                                               102 NW 2nd Ave.
                                               Gainesville, Fl 32601
                                               352.372.4263

                                               Counsel for Defendant
                                               Joseph Harding

                          CERTIFICATE OF SERVICE

      I HEREBY CERTIFY on October 17, 2023, I electronically filed the

foregoing document with the Clerk of the Court using CM/ECF system, which will

serve a notice of electronic filing to all counsel of record.

                                         /s/ Filzah I. Pavalon
                                         Filzah I. Pavalon, Esq.




                                           2
       Case 1:22-cr-00032-AW-MAL Document 53 Filed 10/17/23 Page 3 of 4




To whom it may concern:
In my journey from farm boy to Ivy League Hospital physician, I have encountered countless
individuals, from homeless patients to world leaders, who have influenced and inspired my
journey, but perhaps none more so than Joe. To me, Joe has embodied, loyalty, service and
resolve*.
Joe and I shared a unique upbringing in large traditional fundamentally religious homes with
powerful leaders as fathers and strict unwavering rules surrounding every aspect of our lives.
The obstacles this environment levied against our dreams and ambition seemed quite
formidable. But I watched him navigate these with respect, and honor toward his family. And I
attempted to do the same. We shared similarly lofty goals in youth, quite different specialties
yet both equally altruistic in nature. Both of us have realized some of these original goals - Yet
the greatest accomplishment that we both share as we were able to achieve these while
preserving and honoring our most important relationships.
I remember at medical school graduation discussing with Joe our skyrocketing careers. We are
both so energetic. I was moving to Johns Hopkins in Baltimore. And Joe had an opportunity to
become an incredibly successful construction developer in Miami. But he described to me that
he was moving back home to the tiny town of Williston to be around the people that mattered
most - family and friends to give back and mentor and create opportunities there.
I was not even a bit surprised. It resonated so well. It was Joe all the way. And shortly there after
I began to feel the same draw to get back to home base and serve with those who matter most.
Once again influenced by Joe.
Joe shows up. There is no one I’ve ever met that will drop everything. Do anything. You can just
expect he will be there. And over and over during my hardest days in medical school and
residency, Joe would call me at night on my way home from the hospital to help me unload the
difficult things I was seeing. One particular difficult rotation ICU as an intern, he randomly
bought tickets and just flew up to Baltimore to spend the weekend with me and help get my
mind off of some of the work. When my brother died, he planned a trip to the wilderness of
Florida to get my mind off of it picking me up at the airport driving me out there and just quietly
spending time in the woods.

Whenever I or anyone moves he’s there with his truck. Sleeves rolled up carrying furniture. You
don’t even have to ask. You know he will always be there. During hurricane Irma last fall - I was
in the hospital the entire time. But constantly heard from Joe as he checked in on me. And then
went to Home Depot, buying tons of tools, generators, loading up and coming down to our area
on the west coast of Florida cutting down trees on the side of the road, stopping at strangers
homes, and working tirelessly through terrible conditions. I remember on a hunting trip with him,
driving down an old wilderness road and suddenly pulling over to go fix a different political
candidate’s broken sign saying, “this is so far out no one else will come fix it - I would want it
fixed if it was me”.

Joe serves. He shows up.
I aspire to be this kind of friend and man for the community.
       Case 1:22-cr-00032-AW-MAL Document 53 Filed 10/17/23 Page 4 of 4




The other aspect of Joes character that has deeply impacted me is his resolve. He is a man of
belief. He gave up a career, high-paying job, mortgage does home, farm, much of his earthly
good because he believed in family, his state, county, and the way of life of his community and
wanted to stand up and protect it. I remember being shocked at the risks. He was taken
financially and the opportunities that he gave up to do this. The moves that he had to make. And
the countless long hours he had to work on the side to come up with extra paying things that he
could do when he couldn’t hold down a full-time job while volunteering his time to serve as a
state representative.
But he was so excited about it, because he got to speak and support and protect the things that
he believes in. Even though this meant, sometimes relying on others to do parts of business and
his life that he himself would always have done with such integrity and meticulous care.
I remember him turning over aspects of his farm to others. Aspects of his farm that he had
meticulously, mowed and manicured and tended now I had to be hired out to High school age
boys who at times wrecked his equipment and buildings. Yet he showed them trust and favor,
paid them well, so that he could sacrifice his time to higher causes.

And Joe believes in people. There are countless young men in Marion county, who he has given
jobs, opportunity, at their darkest moments. Sometimes I remember being shocked at the
characters that he would hire. But these were often people from connections in the past that
we’re going through difficult times that he would give opportunities to when they couldn’t find
anything else they could combo Joe’s lawn for pay or paint a barn for pay.

Through these and countless experiences with Joe, I have been inspired to be a better doctor,
and a better man. I know that anyone who knows Joe Harding has become better. I believe that
Joe is one of the most vital men with the character and ability to impact his community, county,
and even state. I know that he will continue to affect us all in a positive way in whatever
occupation and role he occupies.

I had hoped to speak at sentencing. But because of schedule conflicts I unfortunately am out of
town. I hope, Your Honor, this letter helps you understand what type of person Joe is.

Respectfully,

Caleb R Leibee DO
Emergency Medicine Physician, Sarasota Memorial Health
Assistant Professor of Clinical Medicine, Florida State University


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