As you can appreciate, this is a very serious charge that carries with it a minimum/mandatory prison sentence of three years. That being said, you should strongly consider hiring an attorney sooner than later.
By filing a Motion to Dismiss, you are not questioning the facts of the case and must admit that what the State is accusing you of is true. In a Motion to Dismiss, you're basically saying "yes, the facts are what they are, but they don't violate the law." That's the last thing you want...
You're typically better off staying in traffic court unless the case needs to be set for jury trial, in which case your attorney would need to transfer it out to the complex on 49th Street. You should consult an attorney before your pretrial next week to avoid the risk of your case being transferred out.
As Ms. Sticco stated, he most likely has zero bond on the violation of probation, which means once his new charge is resolved, he will be transported to Collier to address the violation. There are many possible sentences - the best being the State drops the new charge and he gets put back on probation for the Collier case. The worst case scenario would be consecutive prison sentences, depending on what he is on probation for.
You may want to contact the attorney who represented her and ask that a Motion for Early Termination of Probation be set or retain an attorney to do that specifically. You could also call the judge's assistant yourself to ask for a hearing. There is not a certain time frame in which judges sign those orders, however close to two months seems long.
You're right to be concerned about prison. Possession with Intent to Distribute is a serious charge and because he has a prior Burglary, he will most likely score mandatory prison if the new charges are filed (the prior Burglary adds 14 points to his score sheet and the Possession with Intent is 28 points - 44 points equals a prison sentence). Regarding a defense, this is a constructive possession case as opposed to an actual possession case, which is very helpful. His best defense is that he...
He may want to consider reporting it to law enforcement as harassing phone calls.
Florida State Statute 365.16 describes obscene or harassing telephone calls as:
Making a call without conversation or disclosure of identity and with the intent to harass, annoy, abuse or threaten. Making a call with conversation and with the intent solely to harass or threaten. Making a call during which any obscene conversation or suggestions are made with the intention of offending, harassing,...