1. No. 15-500
================================================================
In The
Supreme Court of the United States
------------------------------------------------------------------
PEGGY WILLIS,
Petitioner,
vs.
ANNE MARIE MOBLEY,
Respondent.
------------------------------------------------------------------
On Petition For Writ Of Certiorari
To The District Court Of Appeal
Of The State Of Florida, Fifth District
------------------------------------------------------------------
BRIEF IN OPPOSITION TO PETITIONER’S
PETITION FOR WRIT OF CERTIORARI
-----------------------------------------------------------------
LINDSEY M. SHARP, ESQUIRE
1900 Hickory Street
Suite B
Melbourne, FL 32901
Tel. (321) 951-7600
Fax (321) 951-7601
Pleadings@sharplawpa.com
Jason@sharplawpa.com
Attorney for Respondent
================================================================
COCKLE LEGAL BRIEFS (800) 225-6964
WWW.COCKLELEGALBRIEFS.COM

2. i
QUESTION PRESENTED
Whether the State of Florida’s same-sex marriage
prohibition violated Petitioner’s due process and equal
protection rights under the Fourteenth Amendment
inasmuch as she was unable to avail herself of same
parentage rights afforded to opposite-sex couples.

3. ii
TABLE OF CONTENTS
Page
QUESTION PRESENTED................................... i
TABLE OF AUTHORITIES ................................. iii
PREFACE ............................................................ 1
INTRODUCTION ................................................ 1
STATEMENT OF THE CASE.............................. 2
STATEMENT OF RELEVANT FACTS................ 3
REASONS FOR DENYING THE PETITION
FOR WRIT OF CERTIORARI.......................... 5
I. PETITIONER FAILED TO TIMELY FILE
HER PETITION AND IGNORED THE
JURISDICTION OF LOWER TRIBU-
NALS, NAMELY THE STATE COURT
OF LAST RESORT .................................... 5
II. PETITIONER DID HAVE EQUAL PRO-
TECTION UNDER THE LAW, DESPITE
FLORIDA’S DISCRIMINATORY BAN ON
SAME-SEX MARRIAGE, AS SIMILARLY
SITUATED UNMARRIED OPPOSITE-
SEX COUPLES WERE AFFORDED THE
SAME PROTECTION AND REMEDIES
AT LAW...................................................... 6
III. THE RELIEF PETITIONER SEEKS
WOULD UNJUSTLY PROVIDE RELIEF
TO A LARGE CLASS OF INDIVIDUALS
WHO OTHERWISE ARE NOT ENTI-
TLED TO SAID RELIEF, LEADING TO
AN ABSURD RESULT .............................. 15
CONCLUSION..................................................... 16

4. iii
TABLE OF AUTHORITIES
Page
CASES
Adoption of D.P.P. v. C.P., 158 So.3d 633 (Fla.
5th DCA 2014)...........................................................8
Adoption of X.X.G. and N.R.G., 45 So.3d 79
(Fla. 3d DCA 2010)....................................................8
Beagle v. Beagle, 678 So.2d 1271 (Fla. 1996).............16
D.M.T. v. T.M.H., 129 So.3d 320 (Fla. 2013)........13, 14
Embry v. Ryan, 11 So.3d 408 (Fla. 2d DCA
2009) ..........................................................................9
In Re Adoption of John Doe, 2008 WL 5070056..........9
Loving v. Virginia, 388 U.S. 1 (1967).........................10
Obergefell v. Hodges, 135 S.Ct. 2584, 192
L.Ed. 2d 609 (2015).........................................1, 6, 10
Wakeman v. Dixon, 921 So.2d 669 (Fla. 1st
DCA 2006) ...............................................................10
STATUTES, RULES, AND ORDERS
§ 742.11, Fla. Stat.......................................................11
§ 742.13, Fla. Stat.......................................................11
Art. V, § 3(b), Fla. Const...............................................5
Equal Protection Clause, U.S. Const., 14th
Amendment.................................................2, 7, 9, 12
Sup. Ct. R. 13.1.............................................................5
Rule 91.20, Fla. R. App. P.............................................6

5. 1
PREFACE
In this Brief in Opposition, Petitioner Peggy
Willis will be referred to as “Ms. Willis.” Respondent
Anne Marie Mobley will be referred to as “Anne
Marie.”
------------------------------------------------------------------
INTRODUCTION
Ms. Willis’ Petition joins a growing number of
other such post-Obergefell petitions seeking to find
retroactive protection and remedies previously not
enjoyed by same-sex individuals. To be clear: this is
not a gay rights issue.
This is Not a Gay Rights Issue.
Ms. Willis’ Petition is misguided and is particu-
larly ill-suited for review by this Honorable Court for
numerous reasons. First and foremost, Ms. Willis did
not seek to remedy this cause in a state court of last
resort and has thereby circumvented the Rules in an
attempt to take a second bite of the proverbial apple,
without the foresight or knowledge of how her cause
would have been treated under a discretionary review
in the state court of last resort.
Second, the basis of Ms. Willis’ Petition is dubi-
ous at best, where she attempts to persuade this
Honorable Court that Florida’s now-overturned ban
on same-sex marriage somehow prohibited her from
becoming a legal parent of a child she has no legal
claim to. Rather than legally adopting or donating

6. 2
genetic material during the artificial insemination
process – which are the same remedies an un-
married opposite-sex couple would have had to
undertake in order to stake a legal claim over
the child – she now seeks the assistance of this
Court under the guise of an Equal Protection issue,
when in fact, nothing could be further from the truth.
True, Florida’s former ban on same-sex marriage was
a travesty – a wrong that has since been righted – but
that ban has nothing to do with this cause, nor did it
contribute to Ms. Willis’ conscious choice to not carry
out any of the legal remedies mentioned above which
would have ensured her Equal Protection under the
law.
Ms. Willis’ Petition is really only a ruse designed
to seek review under this Honorable Court’s recent
same-sex marriage decision. Because Ms. Willis has
not met her burden to prove the parties ever actually
intended to marry but were denied the right to do so,
and because Ms. Willis did in fact enjoy Equal Protec-
tion under the law at the time she chose not to
legally adopt or donate genetic material to contribute
to the conception of the child, her Petition is utterly
without merit and should be denied certiorari review.
------------------------------------------------------------------
STATEMENT OF THE CASE
Ms. Willis filed her Verified Petition for Determi-
nation of Parentage and Related Relief on November
14, 2013. Anne Marie filed her Motion to Dismiss the

7. 3
cause on February 5, 2014. On August 5, 2014, a
hearing on the Motion to Dismiss was held before the
Honorable Kelly J. McKibben of Florida’s Eighteenth
Judicial Circuit. Judge McKibben filed her Order
Granting Respondent’s Motion to Dismiss on August
25, 2014.
Ms. Willis timely appealed to Florida’s Fifth
District Court of Appeal and submitted her Initial
Brief on January 12, 2015. Anne Marie filed her
Answer Brief on February 20, 2015 and Ms. Willis’
Reply Brief followed on February 25, 2015. The
District Court issued a per curiam Affirmation with
Judges Sawaya, Lambert, and Edwards concurring
on July 14, 2015. Ms. Willis sought rehearing on July
15, 2015, and the Court denied her motion on August
4, 2015. The appeal to this Honorable Court follows.
------------------------------------------------------------------
STATEMENT OF RELEVANT FACTS
While Anne Marie does not entirely dismiss the
statement of facts presented by Ms. Willis in her
Petition, the overall tone of an equal partnership is
wholly inaccurate. The relationship was one dominat-
ed by a much older Ms. Willis, and this Honorable
Court should be made aware of several facts not
present in the Petition.
The Court should understand the nature of the
relationship between Ms. Willis and Anne Marie. The
relationship began on the Internet as an “online”
relationship. Anne Marie was still a juvenile high

8. 4
school student, while Ms. Willis was several decades
her senior. Anne Marie resided in a small town in
Georgia where homosexuality was not generally
accepted, and acceptance was what she desperately
needed. She found that acceptance in Ms. Willis.
Unfortunately for Anne Marie, the nature of their
relationship began with an older, experienced Ms.
Willis grooming a minor child.
The relationship may have eventually grown into
a loving one, but for Anne Marie, something was
always missing. Anne Marie desperately wanted to
have a child, but Ms. Willis was adamantly against
the idea. It was only after several years of pleading
that Ms. Willis relented and “allowed” Anne Marie to
begin the process of artificial insemination.
It is true that medically controlled assisted
reproductive technology was not successful, and it is
true that the parties ordered donor semen from the
Internet. The donor semen was injected into Anne
Marie’s vagina and onto her cervix. This insemination
was not medically controlled, and not a single egg
was harvested from either party. Of the two parties,
Anne Marie was the only person providing any
biological material, and Anne Marie alone shoul-
dered the burden of carrying the child within her own
body.
When the child was approximately one year old,
the relationship between Peggy and Anne Marie came
to an end and Anne Marie returned home to Georgia

9. 5
where she has a support system of friends and family
to help care for her child.
------------------------------------------------------------------
REASONS FOR DENYING THE
PETITION FOR WRIT OF CERTIORARI
I. PETITIONER FAILED TO TIMELY FILE
HER PETITION AND IGNORED THE JU-
RISDICTION OF LOWER TRIBUNALS,
NAMELY THE STATE COURT OF LAST
RESORT.
Supreme Court Rule 13.1 clearly indicates “a
petition for a writ of certiorari to review a judgment
. . . entered by a state court of last resort . . . is
timely when it is filed with the Clerk of this Court
within 90 days after entry of the judgment.” The Rule
goes on to state a petition for a writ of certiorari
“seeking review of a judgment of a lower state
court that is subject to discretionary review by the
state court of last resort is timely when it is filed
with the Clerk within 90 days after entry of the
order denying discretionary review.” [Emphasis
added].
Ms. Willis’ Petition seeks review of a judgment
from Florida’s Fifth District Court of Appeal, which is
not a state court of last resort. The Florida Supreme
Court is the state court of last resort and under
Art. V, § 3(b), Fla. Const., has jurisdiction to “review
any decision of a district court of appeal that express-
ly declares valid a state statute . . . ” (See Fla. Const.

10. 6
Art. V, § 3(b)(3)), or otherwise provide discretionary
review of judgments of district courts of appeal. Rule
91.20, Fla. R. App. P., provides the mechanism by
which a movant may seek discretionary review by the
Florida Supreme Court.
Here, Ms. Willis circumvented the rules by
untimely filing her Petition (1) seeking review of a
judgment from a court other than a state court of last
resort; (2) seeking review of a judgment from a lower
state court that was subject to discretionary review;
and (3) seeking review from a lower state court that
was subject to discretionary review without the court
of last resort entering an order denying discretionary
review. As such, Ms. Willis’ Petition must be treated
as untimely and denied because this Honorable Court
does not have jurisdiction over untimely-filed peti-
tions.
II. PETITIONER DID HAVE EQUAL PRO-
TECTION UNDER THE LAW, DESPITE
FLORIDA’S DISCRIMINATORY BAN ON
SAME-SEX MARRIAGE, AS SIMILARLY
SITUATED UNMARRIED OPPOSITE-SEX
COUPLES WERE AFFORDED THE SAME
PROTECTION AND REMEDIES AT LAW.
Ms. Willis’ attempt to ride the coattails of
Obergefell is unpersuasive. Same-sex marriage was
not and is not the issue before this Honorable Court,
despite Ms. Willis’ assertion to the contrary. What
this case is really about is the rights – or lack thereof
– of unmarried individuals who have a bond with a

11. 7
child, but who have no biological or legal link to the
child. As this Honorable Court may imagine, this
refers to a large class of individuals.
To further demonstrate Anne Marie’s position
that this cause is not really about same-sex marriage,
Anne Marie would submit that the parties never
intended to marry. Ms. Willis conceded as much in
her own Petition at Page 15, Paragraph 2, when she
stated, “The Petitioner acknowledges that this re-
quest for certiorari requires some speculation beyond
the record . . . since the record does not contain a
definitive finding that the parties would have
married . . . ” [Emphasis added]. This statement ev-
idences the fact that Ms. Willis is now seeking review
of her bad choices – much like one with buyer’s re-
morse – rather than review of a judgment which
infringed upon her constitutional right to Equal Pro-
tection.
Because there is absolutely no evidence the
parties ever intended to marry, Ms. Willis cannot
meet her burden in demonstrating she was denied
Equal Protection under the law just as Ms. Willis
cannot sue NASA for not allowing her to become an
astronaut when she never in fact applied to become
an astronaut. Again, Ms. Willis is second guessing her
prior choices and is seeking that second bite of the
apple through her Petition.
Ms. Willis relies heavily on this Honorable
Court’s holding in Obergefell v. Hodges, 135 S.Ct.
2584, 192 L.Ed. 2d 609 (2015). That landmark case is

12. 8
distinguishable from the instant matter and therefore
not controlling here for numerous reasons. First, as
stated above, that case’s central issue was same-sex
marriage. Such is not the issue here. Second, Ms.
Willis attempts to draw similarities between that
case and the instant matter by focusing on the story
of April DeBoer and Jayne Rowe.
True, their story is an inspiring tale of love,
acceptance, and family, but it is not an illustration of
Ms. Willis’ purported plight. Ms. Willis’ Petition goes
into detail regarding April and Jayne’s adoption of
multiple children and how Michigan law prohibited
both of the women to adopt – only one of the women
were permitted to adopt the children. Same-sex
marriage was germane to their struggle, this Court
accurately reasoned, because Michigan only permit-
ted married couples or single individuals to adopt and
because same-sex couples could not be married in
Michigan.
The instant matter is distinguished because
Florida did not prohibit adoption by same-sex cou-
ples at the time Ms. Willis and Anne Marie were
together. See Adoption of D.P.P. v. C.P., 158 So.3d 633
(Fla. 5th DCA 2014), where Florida’s Fifth District
reversed the trial court’s holding that a final judg-
ment of adoption was void on the basis that the
adoptive mother was in a same-sex relationship with
the biological mother; Adoption of X.X.G. and N.R.G.,
45 So.3d 79 (Fla. 3d DCA 2010), where that Court
held the Florida statute categorically denying homo-
sexuals the right to adopt served no rational purpose

13. 9
and was violative of the Equal Protection Clause of
both the U.S. Constitution and the Florida Consti-
tution; Embry v. Ryan, 11 So.3d 408 (Fla. 2d DCA
2009), where the Court held Full Faith and Credit
had to be extended to an out-of-state adoption judg-
ment and the homosexual adopted mother could
proceed with her petition to determine parentage; In
Re Adoption of John Doe, an unreported case from
Florida’s Sixteenth Judicial Circuit, Monroe County,
Juvenile Division, otherwise cited to by West Law as
2008 WL 5070056, where the circuit court found the
statutory prohibition against same-sex persons seek-
ing to adopt was unconstitutional.
The law in Florida assumes a child born to an
intact marriage – almost blindly, regardless of the
circumstances surrounding conception – is the legal
child of the married partners. In addition to mar-
riage, parentage may be determined in numerous
other ways including the donation of biological mate-
rial during the conception of the child, and legal
adoption. Based on the foregoing authorities, it is
clear Ms. Willis enjoyed the right to legally adopt the
child in question throughout the entire course of the
child’s existence. Ms. Willis simply chose to not
adopt. Ms. Willis also argues she should have paren-
tal rights through a purported (and unsubstantiated)
agreement between her and Anne Marie. But this
argument is moot because the law at the time any
“agreement” was entered into stated such agreements
are unenforceable against the birth mother. This was

14. 10
also true for heterosexual men, which further
demonstrates that Ms. Willis did indeed enjoy Equal
Protection under the law. See Wakeman v. Dixon, 921
So.2d 669 (Fla. 1st DCA 2006), where the male sperm
donor could not enforce a written co-parenting agree-
ment with the biological mother. Here, Ms. Willis’
cause is even feebler than the position in that case
because here Ms. Willis did not have a written
agreement and she did not donate biological material.
It is a travesty that Florida was unwilling for so
many years to adopt same-sex marriage, but the
state’s reluctance certainly did not prejudice Ms.
Willis with regards to her rights – or lack thereof –
over the minor child in question. But even assuming
Florida was somehow “with the times” back when the
child was conceived and/or born, Ms. Willis would not
find relief. In this Honorable Court’s Obergefell
Opinion, the Court relied heavily upon former land-
mark cases such as Loving v. Virginia, 388 U.S. 1, 12
(1967). This Court pointed out that in Loving, at 12,
this Court held, “The freedom to marry, or not to
marry, a person of another race resides with the
individual and cannot be infringed by the State.”
[Emphasis added]. Ms. Willis’ arguments would seek
to abolish Anne Marie’s freedom to not marry Ms.
Willis. In essence, Ms. Willis is arguing this Court
should retroactively imagine she would have been
married to Anne Marie, and then suppose all of the
rights which would have befallen her should that
marriage have taken place and award Ms. Willis with
said rights in the present.

15. 11
But Anne Marie never intended to marry Ms.
Willis, and Ms. Willis’ argument is completely devoid
of any evidence to the contrary. And let us not forget
that Ms. Willis herself, in her appeal to Florida’s
Fifth District Court of Appeal, conceded that § 742.13,
Fla. Stat. was completely devoid of any marriage
requirement, rendering her argument on that point
moot. That statute is further inapplicable here be-
cause the statute clearly only applies to artificial
reproductive technology (“ART”), which is defined by
the statute as “those procreative procedures which
involve the laboratory handling of human eggs or pre-
embryos . . . ” [Emphasis added]. The intent is clearly
to not limit the statutory definition of ART; the legis-
lature was clearly only “limiting” its definition to
procedures which handle the eggs or embryos, not
where the eggs are not harvested and donor semen is
simply injected into the vagina and onto the cervix, as
in the instant case. Here, there was no harvesting or
handling of eggs or embryos, so the statute does not
apply to Ms. Willis’ cause. Further, Ms. Willis’ attack
on § 742.11, Fla. Stat. is baseless because that statute
was clearly established to enable anyone with a legal
or biological connection to a child to seek a determi-
nation of parentage (here, Ms. Willis, again, did not
legally adopt and therefore did not have a legal
connection; nor did she donate genetic material,
rendering this statute inapplicable for the purposes of
her Petition). Therefore Ms. Willis is left with the
remaining remedies for an unmarried person seeking
parental rights and obligations. As discussed above,
we know Ms. Willis did not attempt to adopt the child

16. 12
(not that Anne Marie would have permitted said
adoption). We know the parties never intended to
marry. So that reduces the case to one of biology and
scientific truths.
Ms. Willis attempts to persuade this Honorable
Court to believe Florida law somehow provides more
protection under the law to non-biological heterosex-
ual parents than to same-sex parents, and in doing so
discriminates against homosexuals by not offering
Equal Protection. This argument is preposterous. As
discussed above, Ms. Willis enjoyed the same protec-
tions as a heterosexual, non-biological, non-legal
parent – which is no protection under the law. That
lack of protection is equal for homosexuals and heter-
osexuals.
Let us juxtapose the same fact pattern to an
opposite-sex couple. Man and woman are dating.
Woman orders sperm from the Internet and man
assists her in artificially inseminating herself in the
privacy of their home. Woman becomes pregnant.
After the birth, the couple parts ways. The man in
this model has no legal claim over the child because
he did not (1) marry the mother, (2) adopt the child,
or (3) donate genetic material to aid in the conception
of the child. For Ms. Willis, (1) Anne Marie did not
wish to marry so she lacked standing to raise a claim
under this prong, but she could have sought to (2)
legally adopt the child, or (3) she could have donated
genetic material.

17. 13
Ms. Willis could have donated an egg, as many
women do. That egg could have been inseminated in
a laboratory and inserted into Anne Marie’s womb.
This would have provided Ms. Willis with a biological
– and therefore legal – claim over the child. Ms. Willis
even admits in her Petition that she and Anne Marie
attempted laboratory-assisted insemination and that
“the parties agreed that [Anne Marie] would use her
own ova and that [Anne Marie] would carry the
embryo in her own body.” Ms. Willis’ Petition, Page 9,
Paragraph 1. [Emphasis added]. Ms. Willis chose to
not use her own egg. Ms. Willis chose to not carry the
baby. This demonstrates Ms. Willis’ claim is noth-
ing more than regret over her own choices
which precluded her from having a legal claim
over the child; not the State of Florida. She chose to
not have a biological link to the child. Could this be
because even after several years of Anne Marie
begging permission to become pregnant that Ms.
Willis still did not want a child? Maybe Ms. Willis
only decided she wanted the child when she found out
she had no legal standing to ask for such.
Florida law actually provided protection under
similar circumstances in D.M.T. v. T.M.H., 129 So.3d
320 (Fla. 2013). There, the Florida Supreme Court
held the biological mother – the woman who donated
her egg to her same-sex partner who then carried the
baby to birth – was akin to a man who provides his
sperm. In a heterosexual relationship, the male is
equivalent to an unknown sperm donor, other than
the fact that the male in a heterosexual relationship

18. 14
does not waive his parental rights and responsibili-
ties as a donor would. A male in a heterosexual rela-
tionship (even a one-night stand) transfers his
biological material to the birth mother. D.M.T. held
the same is true for lesbians where one of the in-
volved partners transfers her egg (biological material)
to the birth mother. This provides Equal Protection,
because a male has to also transfer biological materi-
al under this model. This, the Court reasoned, would
provide protection under the law for any individual
donating biological material to create a child. Ms.
Willis chose to not do this, and in doing so, chose to
not shield herself under the laws which she now
seeks to undermine. She did in fact enjoy Equal
Protection under the law but chose to not exercise her
rights. Again, if the heterosexual male in the same
model, who did not donate any genetic material,
whether or not he was the “intended,” “apparent,” or
“psychological” parent, failed to adopt the child
subsequent to birth, he would fail to meet the statu-
tory criteria to qualify as a legal parent – just as
would happen to a homosexual woman. This protec-
tion, or lack thereof, is equal and does not discrimi-
nate.
Because Ms. Willis made a sound choice to not
share a link with the child – biological or legal – she
was not discriminated against. Her own choices bar
her from any relief. Accordingly, as a matter of law,
her Petition must be denied.

19. 15
III. THE RELIEF PETITIONER SEEKS WOULD
UNJUSTLY PROVIDE RELIEF TO A
LARGE CLASS OF INDIVIDUALS WHO
OTHERWISE ARE NOT ENTITLED TO
SAID RELIEF, LEADING TO AN ABSURD
RESULT.
The quintessence of Ms. Willis’ Petition for relief,
simply put, is this: parental rights and responsi-
bilities should be granted to persons who were
(1) never married to the natural mother, (2) share
no biological link to the child, and (3) are not the legal
guardians – by way of adoption or other legal mecha-
nisms. This is a description of Ms. Willis’ argument
in a nutshell.
To grant legal parenting rights to an individual
in such circumstances is to open the door for other
non-parents to stake a claim over the children of
others. For instance, if Ms. Willis is entitled to par-
enting rights, so then are any roommates who lived
with a single mother for an extended period of time
and who developed a bond with that woman’s child.
Such roommates may also love the child as if it were
their own: they may even assist in rearing the child,
but that does not mean they are entitled to any legal
parenting rights over the child, nor does it mean they
may be encumbered with any of the responsibilities
that come with being a legal parent. Let us examine
that possibility: if Ms. Willis is entitled to parenting
rights, then the courts must start entering judgments
enforcing parental responsibilities of women similarly
situated to Ms. Willis, but who do not wish to have

20. 16
parental rights – just as the courts would do to a man
who donated his genetic material but did not wish to
have a relationship with the child. This would also
open the floodgates to cases involving similarly
situated, unmarried, heterosexual couples where only
one party is the biological parent. This would be
violative of sound Florida law. See Beagle v. Beagle,
678 So.2d 1271 (Fla. 1996), where the Florida Su-
preme Court held the courts may not intrude upon a
natural parent’s right to raise their child [except
where the child is in harm’s way] and allowing visita-
tion [to someone similarly situated to Ms. Willis] over
a natural parent’s objection would violate fundamen-
tal parental rights.
Ms. Willis may want to rewrite the laws, and
some may sympathize with her plight. But Anne
Marie is the sole biological and legal parent of the
child in question, and it is her sole decision who she
decides to allow into the child’s life. Ms. Willis’ desire
to rewrite the laws should only affect Ms. Willis – it
should not affect a child which she has no legal right
to affect.
------------------------------------------------------------------
CONCLUSION
Admittedly, the social climate regarding homo-
sexuals – especially as parents – has rightfully
changed in the preceding years. There is no doubt the
coming years will bring even more change and more
rights for same-sex couples. However, none of that is

21. 17
relevant here. Because Ms. Willis and Anne Marie
were engaged in a same-sex relationship, the real
issues are easily veiled. The issue in the instant
matter is not the sexual orientation of any involved
party. The issue is whether a person who has no
biological or legal link to a child may assert parental
rights and responsibilities regarding that child. The
answer – even if it were a heterosexual man seeking
the same resolution – is a resounding “No.”
Although Ms. Willis’ arguments find no support
in our laws, one may certainly sympathize with an
individual in her shoes. She knew and loved a child,
albeit for a very short amount of time. But the child
was not hers. The child was Anne Marie’s. Demand-
ing legal parenting rights over a child that is (1) not
one’s biological child, (2) not one’s legally adopted
child, and (3) where one consciously chose to not
share a biological or an adoptive legal link to the
child, is not in anyone’s best interest other than Ms.
Willis’. Expecting this Honorable Court to rewrite the
laws to safeguard one’s position in light of all of those
choices is wholly fantastical.
Ms. Willis made those choices. She chose to not
share a biological link with the child. She chose to
not legally adopt the child. Anne Marie had no desire
to marry Ms. Willis, so Ms. Willis lacks any standing
to argue for protection under any governing authority
of which marriage is a requirement. Ms. Willis now
has to live with her choices.

22. 18
Because heterosexual couples must also satisfy
the same biology and non-biology related prongs of
parentage discussed herein, Ms. Willis has not suf-
fered an Equal Protection violation. Parents of all
sexual orientations are subject to satisfying the same
prongs in their pursuit to being classified as legal
parents. This Honorable Court should now dismiss
Ms. Willis’ Petition and allow Anne Marie and her
child to pursue their lives together.
Respectfully submitted,
LINDSEY M. SHARP, ESQUIRE
1900 Hickory Street
Suite B
Melbourne, FL 32901
Tel. (321) 951-7600
Fax (321) 951-7601
Pleadings@sharplawpa.com
Jason@sharplawpa.com
Attorney for Respondent