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JULES v. STATE

No. 4D13-3121.

162 So.3d 12 (2014)

Harold JULES, Appellant, v. STATE of Florida, Appellee.

District Court of Appeal of Florida, Fourth District.

March 12, 2014.

Attorney(s) appearing for the Case

Harold Jules, Fort Lauderdale, pro se.

No appearance required for appellee.

We reverse the portion of the trial court's order imposing sanctions pursuant to State v. Spencer, 751 So.2d 47 (Fla. 1999). The trial court failed to issue an order to show cause before imposing the sanction. See Epps v. State, 941 So.2d 1206,

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