DEMAND FOR JURY TRIAL

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PLAINTIFFS’ ORIGINAL COMPLAINT; AND DEMAND FOR JURY TRIAL – 1
Gloria Dublin
Insert Gloria’s Address
City, ST ZIP Code
Phone
Email
Lorraine Dublin
Insert Lorraine’s Address
City, ST ZIP Code
Phone
Email
Cynthia Clayton
Insert Cynthia’s Address
City, ST ZIP Code
Phone
Email
Plaintiffs in pro per

IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE MIDDLE DISTRICT OF FLORIDA

GLORIA DUBLIN; LORRAINE DUBLIN;
AND CYNTHIA CLAYTON,
Plaintiffs,

vs.
KEVIN EDMONDS, IN HIS CAPACITY AS
CHIEF ADMINISTRATIVE OFFICER OF
THE CITY OF ORLANDO; RISK
MANAGEMENT DIVISION CODE
ENFORCEMENT; AND ORLANDO POLICE
DEPARTMENT,
Defendants.

Case No.: Number

PLAINTIFFS’ ORIGINAL COMPLAINT;
AND DEMAND FOR JURY TRIAL

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PLAINTIFFS’ ORIGINAL COMPLAINT; AND DEMAND FOR JURY TRIAL – 2
NOW COME Gloria Dublin, Lorraine Dublin, and Cynthia Clayton, Plaintiffs, and file
this Verified Complaint against Kevin Edmonds in his capacity as Chief Administrative Officer
of the City of Orlando, Risk Management Division Code Enforcement, and the Orlando Police
Department, Defendants, and for cause would show this Honorable Court as follows:

A. PARTIES
1. Plaintiff Gloria Dublin is a non-state female adult citizen of sound mind and a
paramount security interest holder to the subject property and collateral, both registered and
unregistered belonging to the legal name cestui que trust Gloria Dublin.
2. Plaintiff Lorraine Dublin is a non-state female adult citizen of sound mind and a
paramount security interest holder to the subject property and collateral, both registered and
unregistered belonging to the legal name cestui que trust Lorraine Dublin.
3. Plaintiff Cynthia Clayton is a non-state female adult citizen of sound mind and a
paramount security interest holder to the subject property and collateral, both registered and
unregistered belonging to the legal name cestui que trust Cynthia Clayton.
4. Defendant Kevin Edmonds is being sued in his individual and official capacity as
the Chief Administrative Officer of the City of Orlando.
5. Defendant Risk Management Division Code Enforcement is
6. Defendant Orlando Police Department is a nationally recognized law enforcement
agency that is tasked with ensuring the safety of residents, visitors and businesses in the city of
Orlando.

B. JURISDICTIONAL STATEMENT

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PLAINTIFFS’ ORIGINAL COMPLAINT; AND DEMAND FOR JURY TRIAL – 3
7. This Court has subject matter jurisdiction under 28 U.S. Code § 1331 (federal
question), and 28 U.S. Code § 1343 (civil rights).
8. Venue is proper in this Court in accordance with 28 U.S. Code § 1391(b) which
states that: “A civil action may be brought in – (2) a judicial district in which a substantial part of
the events or omissions giving rise to the claim occurred.” The events and causes of action
described herein took place in the city of Orlando, which is in the Middle District of Florida.

C. FACTUAL STATEMENT
9. On 02/03/2020, Code Enforcement Officer Livingston came to Eric Dublin’ non-
commercial land and said that he received a complaint that there was no electricity and no water
on the land.
10. Plaintiffs tried to explain to Officer Livingston that according to Orlando Code of
Ordinances § 64.1, the city only had control over city-owned leased property and that he had no
authority to be there or condemn Eric’s non-commercial property according to Fla. Stat. §
166.021.
11. On 02/11/2020, Code Enforcement continued to violate Plaintiffs’ constitutional
rights by domestic terrorism contrary to 18 U.S. Code § 2331(5), and the right to privacy under
Florida Constitution Article 1, § 12.
12. Every natural man and woman has the right to be left alone and free from
governmental intrusion into a person’s private life. On Plaintiffs’ non-commercial land, they
have the right to live and be free with no water and utilities if they want to.
13. Code Enforcement brought in two supervisors, Wharton and Crespo, alongside 10
Orlando Police Department officers who went on to force out Plaintiffs off their non-commercial

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PLAINTIFFS’ ORIGINAL COMPLAINT; AND DEMAND FOR JURY TRIAL – 4
land without a warrant to do so according to Fla. Stat. § 933.02.
14. Plaintiffs tried to inform the officers that they did not have permission to enter the
land and that it was a civil matter between the owners of the land who did not, and do not
conduct commercial business on the land. The officers threatened Plaintiffs with arrest.
15. Plaintiffs called and spoke to Kory Keets.
16. Plaintiffs have done their best to determine the names of everyone who was
present at the scene. If Plaintiffs determine the names of more persons, they shall seek leave to
amend this Complaint to include them.
17. Code Enforcement agents/employees who were present at the scene include
Director Michael Rhodes, Supervisor George Wharton, Supervisor Hery Crespo, Aplhonzo
Livingston, Kory Keets, Michele Bachman, and Glenn Bynes Jr.
18. Orlando Police Department agents/employees who were present at the scene
include Supervisor Erine Plaza, No. 33777; Officer Buffkin, No. 12417; Officer Paymayesh, No.
15173; Officer Fisher, No. 33964; Officer Macdougall, No. 31554; Officer Vadi, No. 34551;
Officer Hurt, No. 19153; Officer Austin, No. 31303; Officer Salazar, No. 34713; and Officer
Rine, No. 15633.

D. CAUSES OF ACTION
Violation of Fla. Stat. § 162.12
19. Plaintiffs hereby incorporate by reference the facts set out in ¶ 1-18 of this
Complaint as though set out in full herein.
20. Fla. Stat. § 162.12 provides in relevant part as follows: “(1) All notices required
by this part must be provided to the alleged violator by: (a) Certified mail, and at the option of

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PLAINTIFFS’ ORIGINAL COMPLAINT; AND DEMAND FOR JURY TRIAL – 5
the local government return receipt requested, to the address listed in the tax collector’s office for
tax notices or to the address listed in the county property appraiser’s database. The local
government may also provide an additional notice to any other address it may find for the
property owner. For property owned by a corporation, notices may be provided by certified mail
to the registered agent of the corporation. If any notice sent by certified mail is not signed as
received within 30 days after the postmarked date of mailing, notice may be provided by posting
as described in subparagraphs (2)(b)1. and 2.; (b) Hand delivery by the sheriff or other law
enforcement officer, code inspector, or other person designated by the local governing body;
(c) Leaving the notice at the violator’s usual place of residence with any person residing
therein who is above 15 years of age and informing such person of the contents of the notice.”
21. Florida Statutes require due process and Notice and Opportunity, amongst other
mandatory prerequisites to actions by Code Enforcement and the Orlando Police Department.
These Statutes were not complied with, especially the requirement for a notice.
22. Plaintiffs never received a notice by certified mail, or via hand delivery by the
Sheriff or by any of the other means available under the above cited statute. This violates their
rights to notice and opportunity.
23. Defendants are liable for violation of Fla. Stat. § 162.12 and ought to pay
damages to Plaintiffs.
Violation of 42 U.S. Code § 1983
24. Plaintiffs hereby incorporate by reference the facts and cause of action set out in ¶
1-23 of this Complaint as though set out in full herein.
25. 42 U.S. Code § 1983 states in pertinent part as follows: “Every natural man and
woman who, under color of any statute, ordinance, regulation, custom, or usage, of any State or

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PLAINTIFFS’ ORIGINAL COMPLAINT; AND DEMAND FOR JURY TRIAL – 6
Territory or the District of Columbia, subjects, or causes to be subjected, any natural man or
woman of the United States or other natural man or woman within the jurisdiction thereof to the
deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be
liable to the party injured in an action at law, suit in equity, or other proper proceeding for
redress.”
26. Agents and/or employees of Defendants deprived Plaintiffs of their rights under
color of authority, with respect to an act, which was a violation of the Bill of Attainder Clause at
Article One, Section Ten of the Constitution for The United States of America, having failed to
obtain a court order or any judicial due process prior to the raid incident described above.
27. Agents and/or employees of Defendants deprived Plaintiffs of their rights under
color of authority, with respect to an act, which was a violation of the Ex Post Facto Clause, at
Article One, Section Ten of the Constitution for The United States of America, having imposed
requirements upon a house that was built before the current zoning and building codes were
enacted into law.
28. Agents and/or employees of Defendants deprived Plaintiffs of their rights under
color of authority, with respect to an act, which was a violation of the Due Process Clause and
the Equal Protection Clause that is stated in the Fourteenth Amendment to the Constitution for
The United States of America, having failed to obtain a court order or any judicial due process or
any notice and opportunity for any redress prior to the raid incident described above.
29. Defendants are liable for violation of 42 U.S. Code § 1983 and ought to pay
damages to Plaintiffs.

Violation of 42 U.S. Code § 1985(3)

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PLAINTIFFS’ ORIGINAL COMPLAINT; AND DEMAND FOR JURY TRIAL – 7
30. Plaintiffs hereby incorporate by reference the facts and causes of action set out in
¶ 1-29 of this Complaint as though set out in full herein.
31. 42 U.S. Code § 1985(3) provides as follows: “If two or more persons in any State
or Territory conspire or go in disguise on the highway or on the premises of another, for the
purpose of depriving, either directly or indirectly, any person or class of persons of the equal
protection of the laws, or of equal privileges and immunities under the laws; or for the purpose of
preventing or hindering the constituted authorities of any State or Territory from giving or
securing to all persons within such State or Territory the equal protection of the laws; or if two or
more persons conspire to prevent by force, intimidation, or threat, any citizen who is lawfully
entitled to vote, from giving his support or advocacy in a legal manner, toward or in favor of the
election of any lawfully qualified person as an elector for President or Vice President, or as a
Member of Congress of the United States; or to injure any citizen in person or property on
account of such support or advocacy; in any case of conspiracy set forth in this section, if one or
more persons engaged therein do, or cause to be done, any act in furtherance of the object of
such conspiracy, whereby another is injured in his person or property, or deprived of having and
exercising any right or privilege of a citizen of the United States, the party so injured or deprived
may have an action for the recovery of damages occasioned by such injury or deprivation,
against any one or more of the conspirators.”
32. Agents and/or employees of Defendants committed acts of conspiracy against
Plaintiffs’ rights by depriving them of their rights to equal protection of the laws and the
privileges and immunities under the laws, with respect to an act, which was a violation of the
Due Process Clause in the Fourteenth Amendment, a violation of the Fourth Amendment and a
violation of the Equal Protection Clause of the Fourteenth Amendment.

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PLAINTIFFS’ ORIGINAL COMPLAINT; AND DEMAND FOR JURY TRIAL – 8
33. Defendants are liable for violation of 42 U.S. Code 1985(3) and ought to pay
damages to Plaintiffs.

Violation of 42 U.S. Code § 1986
34. Plaintiffs hereby incorporate by reference the facts and causes of action set out in
¶ 1-33 of this Complaint as though set out in full herein.
35. 42 U.S. Code § 1986 provides as follows: “Every person who, having knowledge
that any of the wrongs conspired to be done, and mentioned in section 1985 of this title, are
about to be committed, and having power to prevent or aid in preventing the commission of the
same, neglects or refuses so to do, if such wrongful act be committed, shall be liable to the party
injured, or his legal representatives, for all damages caused by such wrongful act, which such
person by reasonable diligence could have prevented; and such damages may be recovered in an
action on the case; and any number of persons guilty of such wrongful neglect or refusal may be
joined as defendants in the action; and if the death of any party be caused by any such wrongful
act and neglect, the legal representatives of the deceased shall have such action therefor, and may
recover not exceeding $5,000 damages therein, for the benefit of the widow of the deceased, if
there be one, and if there be no widow, then for the benefit of the next of kin of the deceased.”
36. Agents and/or employees of Defendants failed to prevent the violation of our
rights under established standards of decency and of the lawful duty of law enforcement officials
based upon numerous US Supreme Court Decisions and allowed others in their large group of
tortfeasors to commit acts against our rights by depriving us of our rights as described in Title
42, US Code, Section 1985 to equal protection of the laws and the privileges and immunities
under the laws, with respect to an act, which was a violation of the Due Process Clause in the

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PLAINTIFFS’ ORIGINAL COMPLAINT; AND DEMAND FOR JURY TRIAL – 9
Fourteenth, a violation of the Fourth Amendment and a violation of the Equal Protection Clause
of the Fourteenth Amendment.
37. Defendants are liable for violation of 42 U.S. Code § 1986 and ought to pay
damages to Plaintiffs.

E. PRAYER FOR RELIEF
REASONS WHEREFORE, PREMISES CONSIDERED, Plaintiffs respectfully request
this Honorable Court to grant them the following reliefs:
a. GRANT judgment in Plaintiff’s favor;
b. AWARD Plaintiffs damages in the sum of $5,000,000;
c. AWARD Plaintiffs punitive damages;
d. AWARD Plaintiffs costs of this suit and attorney fees as allowed by law;
e. AWARD Plaintiffs pre- and post-judgment interests;
f. AWARD Plaintiffs such equitable relief as this Court deems necessary under the
circumstances; and
g. AWARD Plaintiffs such further relief as this Court deems proper.

Dated this ____ day of August, 2022.

Respectfully Submitted,

___________________________________
Gloria Dublin

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PLAINTIFFS’ ORIGINAL COMPLAINT; AND DEMAND FOR JURY TRIAL – 10

___________________________________
Lorraine Dublin

___________________________________
Cynthia Clayton

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PLAINTIFFS’ ORIGINAL COMPLAINT; AND DEMAND FOR JURY TRIAL – 11

VERIFICATION

We, being duly sworn depose and say that we have read the foregoing Complaint and know the
contents thereof. That the same is true of our own knowledge except as to those matters and
things stated upon information and belief, and as to those things, we believe them to be true.

___________________________________
Gloria Dublin

___________________________________
Lorraine Dublin

___________________________________
Cynthia Clayton

Sworn to and subscribed before me this ____ day of August, 2022.

___________________________________
Notary Public
(Printed Name of Notary Public)
My Commission Expires: ____________________

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