The Open LetterJustice & accountability
Editorial adaptation
Volusia County · Courts & corrections

Nicole Jackson case: an open letter questions jail records

VolusiaExposed.Com asks whether a disciplinary report—and the timing behind it—impeded a juvenile defendant's access to private legal counsel.

Source letter by VolusiaExposed.ComLetter dated Adapted from a four-page open letter
About this adaptation. This page presents the substance of VolusiaExposed.Com’s letter in an editorial format. Allegations and opinions belong to the publication or to the reports as described in its letter. The supplied letter contains no response from the officials it names.

A September 3, 2026 open letter from VolusiaExposed.Com asks Volusia County Corrections Director Joseph Demore to explain a timing discrepancy in a jail disciplinary report involving Nicole Jackson. The publication questions whether corrections personnel helped interfere with Jackson’s effort to obtain private counsel before a January 2023 plea hearing.

The letter frames that question as part of its broader allegation that Sheriff Mike Chitwood and several justice officials promoted a false attempted-murder narrative against Jackson and Travis O’Brien. Those allegations, along with the letter’s conclusions about coercion, conflicts of interest and misconduct, are the views of VolusiaExposed.Com.

The prosecution, as the letter describes it

VolusiaExposed.Com says that over the preceding five years it published articles arguing that Chitwood, assisted by a judge, a prosecutor and a public defender, knowingly advanced false charges that two children—O’Brien, identified as 12, and Jackson, identified as 14—attempted to murder several Volusia sheriff’s deputies. It points readers to its article about judicial candidate Larry Avallone. [1]

The publication maintains that the children are factually innocent of the attempted murder charges, while acknowledging that they broke into the unoccupied home and caused major damage inside. It disputes Chitwood’s public statement that the children fired numerous rounds from a military-type rifle at deputies. [2]

As evidenced within an earlier article, this publication opined that the responding deputies idiotically engaged in a "friendly fire" incident, something the sheriff is attempting to cover-up within his false accusations against the children.

According to the letter’s reading of Investigator Cordell Lemay’s report, the AK-47 rifle was not fired; instead, the children fired four rounds from a small-caliber handgun and two shotgun rounds. The letter further contends that evidence suggests all six rounds were fired inside the home as part of the damage to its interior. These are the publication’s interpretations of the evidence. [3]

The letter states that O’Brien was ultimately prosecuted as a juvenile, while Jackson was prosecuted as an adult and, as of the letter’s date, was serving a 20-year prison sentence. VolusiaExposed.Com characterizes her plea agreement as judicially coerced.

Questions about the January 27 hearing

VolusiaExposed.Com alleges that a sealed transcript of a January 27, 2023 hearing supports its contention that Circuit Court Judge Elizabeth Blackburn coerced Jackson, then 15, into accepting a plea agreement with prosecutors. The letter says the hearing occurred behind a closed courtroom door, and alleges that Blackburn attempted to conceal her coercive tactics through the courtroom closure and the sealing of the transcript. The letter further documents that the Volusia County Clerk of the Court subsequently released the transcript inadvertently. [4] [5]

The letter identifies the case as State of Florida v. Nicole Jackson, 2021 303222 CFDB, and provides a link to the Clerk's website. [6]

It also says the transcript shows that Blackburn assigned Assistant Public Defender Larry Avallone, described as a former Volusia sheriff’s deputy, to represent Jackson. The publication questions whether Avallone's former employment created a conflict of interest in a prosecution involving alleged attempts to kill Volusia sheriff’s deputies, citing page 15 of the transcript. [7]

The disciplinary reports and access to counsel

Citing what it describes as the recent arrest of Correctional Officer T. Joyal for perjury in her official capacity, the letter questions whether corrections personnel also nefariously helped to impede Jackson’s efforts to secure effective defense counsel. It links to Officer Joyal's arrest report; the letter's reference to this arrest is an allegation of wrongdoing, not a finding of guilt. [8]

According to the letter, prosecutors and others learned in early January 2023 that Jackson was seeking a private attorney to replace Avallone - in order to take her case to trial. VolusiaExposed.Com alleges that people it accuses of coordinating against Jackson listened in on her telephone conversations about finding new counsel. It cites transcript pages 45–47 and says additional evidence exists to support its “phone tap” allegation, without supplying that additional evidence in this letter. [9]

The letter states that on January 14, 2023, Correctional Officer P. Hall #22172 filed in-house disciplinary report #230004787. As recounted in the letter, Hall alleged that Jackson threatened to kill corrections staff and said she would accuse her attorney (Avallone) of looking at her in a sexual way so that she could have him fired. The letter says no formal criminal charges were filed over the alleged threats and describes that absence as suspicious.

Four days later, on January 18, 2023, Correctional Officer T. Joyal #24047 filed a supplemental report with a similar account of the alleged threats and statements, according to the letter. It says Jackson adamantly denied threatening staff when investigative jail personnel questioned her on January 19, 2023. The disciplinary report and supplement are linked together. [10]

The letter says Avallone stated at the January 27 hearing that he knew Jackson’s jail housing status had recently changed. VolusiaExposed.Com raises the possibility that Avallone knew of the officers’ reports concerning alleged accusations of sexual misconduct against him. It argues that such knowledge, if present, may have biased Avallone's representation during the plea and sentencing hearing - thereby resulting in Ms. Jackson being provided ineffective counsel.

The publication goes further, alleging that the disciplinary narrative may have been fabricated in order to place Ms. Jackson into disciplinary segregation, thereby severing her telephone privileges, and her ability to secure private counsel. It speculates that justice officials requested such an illicit action through jail administrators. The letter cites a WESH report about the firing of a Volusia County corrections director and alleged violations of inmate rights as context for its concerns about the agency in early 2023. That citation does not itself establish the letter’s allegations about Jackson. [11]

The time discrepancy at the center of the letter

VolusiaExposed.Com says both Officer Hall and Joyal placed the alleged January 14 disciplinary incident at “approximately 0940 hours.” Yet, according to the letter’s reading of the final page of the disciplinary report, the jail’s Beacon Software Solutions report-generation and tracking system shows Hall requested a tracking number at 0607 hours—more than three and a half hours earlier. [10]

The letter argues that requesting a report number before the alleged event suggests advance knowledge and a fictionalized account. It asks Demore’s office for clarification of the discrepancy and the broader concerns it raises.

A post-conviction motion and a request for answers

The letter states that in February 2025 a private attorney filed a post-conviction challenge arguing that Jackson received ineffective counsel. It alleges that Blackburn promptly ordered the motion sealed and that, like the sealed hearing transcript, it was also inadvertently released by the Clerk. The letter links to a copy of the motion. [12]

As of September 3, 2026, VolusiaExposed.Com asserted that Judge Blackburn had not addressed for more than a year and a half, Ms. Jackson's legal challenge of being provided ineffective counsel. The publication characterizes that delay as a denial of due process, and as furthering of what it alleges were the officials’ original aims.

“We would welcome any clarifications your office can provide.”

— VolusiaExposed.Com, closing request to Director Demore

The letter closes with the legal maxim, “Justice delayed is justice denied.”

The document trail

Source links & references

Below are web addresses used in support of the September 3, 2026 letter to Mr. Demore.

  1. VolusiaExposed.Com article: “Judicial Candidate Larry Avallone Assisted In The Railroading Of A Child”https://volusiaexposed.com/elections/2026/larryavallone52026.html
  2. Sheriff Chitwood’s media statement (YouTube)https://youtu.be/1VMwsKcRRJI?si=uw23E_BjxCFq08kB
  3. Investigator Cordell Lemay’s charging reporthttps://volusiaexposed.com/vcso/2022/nicolejackson92022/chargingreport.pdf
  4. January 27, 2023 hearing transcript — part 1https://volusiaexposed.com/stateattorney/2025/nicolejackson62025/nelsontranscripts1of2.pdf
  5. January 27, 2023 hearing transcript — part 2https://volusiaexposed.com/stateattorney/2025/nicolejackson62025/nelsontranscripts2of2.pdf
  6. Volusia County Clerk of the Court — case 2021 303222 CFDBhttps://www.clerk.org/
  7. Hearing transcript — page 15https://volusiaexposed.com/elections/2026/larryavaollone52026/page15.pdf
  8. Officer T. Joyal arrest reporthttps://volusiaexposed.com/corrections/2026/officertjoyal72026/arrestreport.pdf
  9. Hearing transcript — pages 45–47https://volusiaexposed.com/elections/2026/larryavaollone52026/page4547.pdf
  10. Jail disciplinary report #230004787 and supplementhttps://volusiaexposed.com/corrections/2023/jacksonnelsonhearing1272023a/nicoledrtimedilation.pdf
  11. WESH: “Volusia County Corrections Director Fired. Violation of Inmate Rights Alleged.”https://www.wesh.com/article/mark-flowers-fired-volusia/42420686
  12. Post-conviction motion referenced by the letterhttps://volusiaexposed.com/stateattorney/2025/nicolejackson62025/3850.pdf