Case 9:19-cv-80800-XXXX Document 1 Entered on FLSD Docket 06/19/2019 Page 1 of 2

UNITED STATES DISTRICT COURT FOR THE

SOUTHERN DISTRICT OF FLORIDA
WEST PALM BEACH DIVISION

JOHN DOE, CASE NO.: _________________

Plaintiff,

vs.

CITY OF VERO BEACH, a Florida

Municipality,

Defendant.
/

DEFENDANT, CITY OF VERO BEACH’S

NOTICE OF REMOVAL

Pursuant to 28 U.S.C. § 1446(a) and Fed. R. Civ. P. 81(c), the Defendant, City of Vero

Beach, by and through undersigned counsel, files this Notice of Removal, and as grounds

therefore states:

1. Plaintiff’s Complaint filed May 25, 2019, in the Circuit Court of the Nineteenth

Judicial Circuit, Indian River County, contains allegations of violation of civil rights under 42

U.S.C. § 1983 (See Complaint at ¶¶ 1, 5-6, 8, 23.)

2. Original jurisdiction is conferred upon this Court by the fact that Plaintiff’s claims

of violations arise under the laws of the United States.

3. Venue is appropriate in the Southern Division as the actions giving rise to this

cause of action are believed to have occurred in Indian River County, Florida.

4. Copies of all pleadings filed in the State Court are attached hereto as Composite

Exhibit A.

5. A copy of this Notice is being filed in the State Court in which the claim was

originally brought.
Case 9:19-cv-80800-XXXX Document 1 Entered on FLSD Docket 06/19/2019 Page 2 of 2

WHEREFORE, Defendant, City of Vero Beach, having complied with 28 U.S.C. §

1446(a) and Rule 81(c) of the Federal Rules of Civil Procedure, files this Notice of Removal.

I HEREBY CERTIFY that on June 19, 2019, I electronically filed the foregoing with

the clerk of the court by using the CM/ECF system which will send a notice of electronic filing

to Bradford L. Jefferson, Esquire, 130 S. Indian River Drive, Suite 402, Ft. Pierce, FL 34950,

servebradjefferson@yahoo.com.

/s/ Gail C. Bradford

WILLIAM E. LAWTON, ESQ.
Florida Bar No. 163236
GAIL C. BRADFORD, ESQ.
Florida Bar No. 0295980
Dean, Ringers, Morgan & Lawton, P.A.
Post Office Box 2928
Orlando, Florida 32802-2928
Tel: 407-422-4310 Fax: 407-648-0233
wlawton@drml-law.com
gbradford@drml-law.com
Attorneys for Defendant

2
JS44 (Rev. 06/17) FLSD Revised 06/01/2017 CIVIL
Case 9:19-cv-80800-XXXX Document 1-1 COVER
EnteredSHEET
on FLSD Docket 06/19/2019 Page 1 of 1
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose
of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.) NOTICE; Attorneys MUST Indicate All Re-filed Cases Below.

I. (a) PLAINTIFFS JOHN DOE DEFENDANTS CITY OF VERO BEACH, a Florida Municipality

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant Indian River
(EXCEPT IN as. PLAINTIFF CASES) (IN U.S PLAINTIFF CASES ONL Y)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Bradford L. Jefferson, P.A., 130 S. Indian River Drive, Suite 402, Fort Gail C. Bradford, Esq., Dean, Ringers, Morgan & Lawton, P.A., PO
Pierce, FL 34950; 772-468-8887 Box 2928, Orlando, FL 32802; 407-422-4310
(d) Check County Where Action Arose: a Miami- dade □ monroe □ broward □ palm beach □ martin □ st. lucie jzf Indian river □ okeechobee □ highlands

II. BASIS OF JURISDICTION (Place an "X" in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X” in One Box for PlaintiJJ)
(For Diversity Cases Only) and One Box for Defendant)
Q 1 U.S. Government MD3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State □ 1 □ 1 Incorporated or Principal Place □ 4 □4
of Business In This State

□ 2 U.S. Government
Defendant
□4 Diversity
(Indicate Citizenship of Parties in Item III)
Citizen of Another State □ 2 □ 2 Incorporated and Principal Place
of Business In Another State
□ 5 □ 5

Citizen or Subject of a □ 3 □ 3 Foreign Nation □ 6 □ 6

Foreign Country
IV. NATURE OF SUIT (Place an ‘X” in One Box Only) Click here for; Nature ofSuit Code Dcscriplions
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
□ 110 Insurance PERSONAL INJURY PERSONAL INJURY □ 625 Drug Related Seizure □ 422 Appeal 28 USC 158 □ 375 False Claims Act
□ 120 Marine □ 310 Airplane □ 365 Personal Injuiy - of Property 21 USC 881 □ 423 Withdrawal □ 376 Qui Tam (31 USC
□ 130 Miller Act □ 315 Airplane Product Product Liability □ 690 Other 28 USC 157 3729 (a))
□ 140 Negotiable Instrument Liability □ 367 Health Care/ □ 400 State Reapportionment
□ 150 Recovei-y of Overpayment □ 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS
□ 820 Copyrights
□ 410 Antitrust
□ 430 Banks and Banking
& Enforcement of Judgment Slander Personal Injury
□ 151 Medicare Act □ 330 Federal Employers’ Product Liability □ 830 Patent □ 450 Commerce
[—1835 Patent - Abbreviated
□ 52 Recovery of Defaulted Liability O 368 Asbestos Personal ^ New Drug Application
□ 460 Deportation
Student Loans □ 340 Marine Injury Product □ 840 Trademark □ 470 Racketeer Influenced and
(Excl. Veterans) □ 345 Marine Product Liability LABOR SOCIAL SECURITY Corrupt Organizations
□ 53 Recovery of Overpayment
of Veteran’s Benefits
Liability
□ 350 Motor Vehicle
PERSONAL PROPERTY □ 710 Fair Labor Standards
□ 370 Other Fraud Act
□ 861 HIA(1395f0
□ 862 Black Lung (923)
□ 480 Consumer Credit
□ 490 Cable/Sat TV
□ 60 Stockholders’ Suits □ 355 Motor Vehicle □ 371 Truth in Lending □
720 Labor/Mgmt, Relations □ 863 DIWC/DIWW (405(g)) □ 850 Securities/Commodities/
□ 90 Other Contract Product Liability □ 380 Other Personal □
740 Railway Labor Act □ 864 SSID Title XVI Exchange
□ 95 Contract Product Liability
□ 196 Franchise
□ 360 Other Personal
Injury □
Property Damage
385 Property Damage
□ 751 Family and Medical
Leave Act
□ 865 RSI (405(g)) O 890 Other Statutory Actions
□ 891 Agricultural Acts
□ 362 Personal Injiuy - Product Liability □ 790 Other Labor Litigation □ 893 Environmental Matters
Med. Malpractice □ 791 Empl. Ret. Inc. □ 895 Freedom of Information
REALPROPERTY CIVIL RIGHTS PRISONER PETITIONS Security Act FEDERAL TAX SUITS Act
□ 210 Land Condemnation E 440 Other Civil Rights Habeas Corpus: □ 870 Taxes (U.S. Plaintiff □ 896 Arbitration
□ 220 Foreclosure □ 441 Voting □ 463 Alien Detainee or Defendant)
1-1 871 IRS—Third Party 26
□ 899 Administrative Procedure
□ 230 Rent Lease & Ejectment □ 442 Employment □ 510 Motions to Vacate
Sentence ‘-‘use 7609
Act/Review or Appeal of
r—1 443 Housing/ Other: Agency Decision
□ 240 Torts to Land ‘ Accommodations
r-| 950 Constitutionality of State
□ 245 Tort Product Liability □ 445 Amer. w/Disabilities - □ IMMIGRATION Statutes
□ 290 All Other Real Property Employment □ □ 462 Naturalization Application
□ 446 Amer. w/Disabilities - □ 540 Mandamus & Other □ 465 Other Immigration
Other □ Actions
□ 448 Education □ 555 Prison Condition
560 Civil Detainee -
□ Confinement
V. ORIGIN (Place an "X" in One Box Only)
□ I Original 1^2 Removed □ 3 Re-filed □ Reinstated □ i Transferred from
another district
□ 6 Multidistrict
Litigation □ Appeal to □ 8 Multidistrict i— Remanded from
Proceeding from State (Sec VI or District Judge Litigation I— Appellate Court
Court below) Reopened (specify) Transfer
from Magistrate - Direct
File

VI. RELATED/ (See instnictions): a) Re-filed Case □YES gNO b) Related Cases nYES □ NO
RE-FILED CASE(S) JUDGE: DOCKET NUMBER:

Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cUe jm-isdicHomd slaluies unless diversity):
VII. CAUSE OF ACTION 42 U.S. Section 1983; Plaintiff alleges Defendant violated civil rights under 42 U.S. Section 1983
LENGTH OF TRIAL via5 days^timatecHforbothsidesJo^ry ent^^
VIII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION
COMPLAINT:
□ UNDER F.R.C.P. 23
DEMAND $ CHECK YES only if demanded in complaint:

JURY DEMAND: Yes □ No

ABOVE INFORMATION IS TRUE & CORRECT TO THE BEST OF MY KNOWLEDGE
DATE ✓»)SIGN/WURE0FATT0EM.EY0FR
June 19,2019

FOR OFFICE USE ONLY

RECEIPT # AMOUNT IFF JUDGE MAG JUDGE
Filing Case
# 90127048 E-Filed 05/25/2019
9:19-cv-80800-XXXX 10:52:51
Document AM
1-2 Entered on FLSD Docket 06/19/2019 Page 1 of 2

FORM 1.997. CIVIL COVER SHEET

The civil cover sheet and the information contained in it neither replace nor supplement the filing and service of pleadings
or other documents as required by law. This form must be filed by the plaintiff or petitioner for the use of the Clerk of
Court for the purpose of reporting judicial workload data pursuant to section 25.075, Florida Statutes. (See instructions for
completion.)

CASE STYLE
IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT.
IN AND FOR INDIAN RIVER COUNTY, FLORIDA

Case No.:_
20l9CA(l00«(XXXffl
Judge:___

Plaintiff
vs.

Defendant

TYPE OF CASE

□. Non-homestead residential foreclosure

□ Condominium $250,00 or more
n Contracts and indebtedness □. Other real property actions $0 - $50,000
□. Eminent domain □_ Other real property actions $50,001 - $249,999
□. Auto negligence Other real property actions $250,000 or more
□. Negligence - other
□. Professional malpractice
□. Business governance
□ Business torts
□ Malpractice - business

□ Environmental/Toxic tort
□ Malpractice - medical
Third party indemnification
□ Malpractice - other professional
other
□ Construction defect
□ Antitrust/Trade Regulation
□ Mass tort
□ Business Transaction
□ Negligent security
Nursing home negligence a Circuit Civil - Not Applicable

□ Premises liability - commercial

□ Constitutional challenge-statute or
ordinance
□ Premises liability - residential
□ Constitutional challenge-proposed
□ Products liability amendment
□ Real Property/Mortgage foreclosure □ Corporate Trusts
□_ Commercial foreclosure $0 - $50,000 □ Discrimination-employment or other
□ Commercial foreclosure $50,001 - $249,999 □ Insurance claims
□ Commercial foreclosure $250,000 or more □ Intellectual property
□ Homestead residential foreclosure $0 - 50,000 □ Libel/Slander
□ Homestead residential foreclosure $50,001 - □ Shareholder derivative action
$249,999
□ Homestead residential foreclosure $250,000 or
□ Securities litigation

more
□. Trade secrets

Non-homestead residential foreclosure $0 -

□ Trust litigation
$50,000
□ Non-homestead residential foreclosure
$50,001 - $249,999
 Case 9:19-cv-80800-XXXX Document 1-2 Entered on FLSD Docket 06/19/2019 Page 2 of 2

COMPLEX BUSINESS COURT

This action is appropriate for assignment to Complex Business Court as delineated and mandated by the
Administrative Order. Yes n No M

REMEDIES SOUGHT (check all that apply):

M Monetary;
□. Non-monetary declaratory or injunctive relief;
Q Punitive

IV. NUMBER OF CAUSES OF ACTION; ( )

(Specify)

V. IS THIS CASE A CLASS ACTION LAWSUIT?

m Yes
□ No

VI. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED?

^ No
□_ Yes - If “yes” list all related cases by name, case number and court:

VII. IS JURY TRIAL DEMANDED IN COMPLAINT?

M Yes
□ No

I CERTIFY that the information I have provided in this cover sheet is accurate to the best of my knowledge and belief, and
that I have read and will comply with the requirements of Florida Rule of Judicial Administration 2.425.

Signature s/ Bradford L Jefferson FLBarNo.: 197270

Attorney or party (Bar number, if attorney)

Bradford L Jefferson 05/25/2019

(Type or print name) Date
 Case
Filing 9:19-cv-80800-XXXX
# 90127048 Document10:52:51
E-Filed 05/25/2019 1-3 Entered
AM on FLSD Docket 06/19/2019 Page 1 of 1

IN THE CIRCUIT COURT OF THE

NINETEENTH JUDICIAL CIRCUIT, IN
AND FOR INDIAN RIVER COUNTY,
FLORIDA

CASE NO.: 2019CA000436XXXXXX

JOHN DOE,

Plaintiff,
vs.

CITY OF VERO BEACH, a Florida

Municipality,

Defendant.

SUMMONS
THE STATE OF FLORIDA:
To Each Sheriff of the State:

YOU ARE COMMANDED to serve this Summons and a copy of the Complaint on the Defendant,
by serving:

City of Vero Beach, a Florida Municipality

c/o Mayor Val Zudans
1053 20“' Place
Vero Beach, FL 32960

Each Defendant is required to serve written defenses to the complaint or petition on:

BRADFORD L. JEFFERSON, ESQUIRE

130 S. Indian River Drive, Suite 402
Fort Pierce, Florida 34950
Telephone: (772) 468-8887

within 20 days after service of this Summons on that defendant exclusive of the day of service, and to rule
the original of the defenses with the Clerk of this Court either before service on Plaintiffs' attorney or
immediately thereafter. If a Defendant fails to do so, a Default will be entered against that Defendant for
the relief demanded in the Complaint or Petition.

DATED this day of _ 2019.

Jeffrey R Smith

(SEAL)
2019 CA
Case 000436 - DOE, JOHNDocument
9:19-cv-80800-XXXX vs. CITY OF
1-4VERO BEACH,
Entered A FLORIDA
on FLSD Docket MUNICIPA... Page 11 of
06/19/2019 Page of 11

Back I Print

2019 CA 000436 - DOE, JOHN vs. CITY OF VERO BEACH, A FLORIDA MUNICIPALITY

Judge: CROOM, JANET C Case Type OTHER

Case Number: 2019 CA 000436 Uniform Case Number 312019CA000436XXXXXX
Clerk File Date: 5/25/2019 Status Date 5/25/2019
SAO Case Number: Total Fees Due 0.00
Agency: Agency Report # Custody Location:

PARTIES

TYPE :PARTY NAME lATTORNEY

DEFENDANT CITY OF VERO BEACH, A FLORIDA MUNICIPALITY

PLAINTIFF DOE, JOHN JEFFERSON, BRADFORD L (Main Attorney)

LOCATION

No Events on Case

CASE HISTORY

CASE NUMBER iCHARGE DESCRIPTION [CASE STATUS IDISPOSITION OUTSTANDING AMOUNT [NEXT EVENT

No Additional Cases

CASE DOCKETS

JMAGE :DIN ‘ DATE ; ENTRY

11 6/12/2019 SUMMONS ISSUED: CITY OF VERO BEACH

10 “67T272bT9.... “"TUMMONSStATUYCHANyEDTO'®

Request j 6/12/2019 AFFIDAVIT OF SERVICE ( CITY OF VERO BEACH A FLORIDA MUNICIPALLITY) SVD; 5/29/19

Qi PAYMENT $410.00 RECEIPT #2019019012

‘''sUMMONS'STAfusZHA^^^^
5/28/2019 EMAIL SENT TO JEFFERSON, BRADFORD L RE SERVICE OF COURT DOCUMENT - CASE NUMBER 312019CA000436XXXXXX WITH 1 ATTACHMENTS: EFSUMM-5/25/2019
7
“EMAILED SUMMONS CITY OF VERO BEACH" _ _ ............................................................ ....................... .........................................
2 5/28/2019 ’ PLAiNTIFF ATTORNEY: JEFFERSON, 'bRADFoW l aSSIG^^^ ............................ ...... .. '

□ i.. 4 5/25/2019

5 572572079"' CLASS ACTION COMPLAINT FOR VIOLATION OF CONSTITUTIONAL RIGHTS

D2 3 "'''"F/il/Ml"?"' '’civirCOVERTHEET'"''.................. ......

1 5/’2r/2bl9 CASE FILED 05/25/2019 CASE NUMBER 2019 CA 000436

https://court.indian-river.org/BenchmarkWeb/CourtCase.aspx/DetailsPrint/4794467digest-... 6/17/2019
Filing
Case# 90127048 E-Filed 05/25/2019
9:19-cv-80800-XXXX Document10:52:51 AM on FLSD Docket 06/19/2019 Page 1 of 7
1-5 Entered

IN THE CIRCUIT COURT OF THE

NINETEENTFI JUDICIAL CIRCUIT,
IN AND FOR INDIAN RIVER
COUNTY, FLORIDA

CASE NO.: 312019CA000436.

JOHN DOE,

PkintifT
vs.

CITY OF VERO BEACFI, a Florida

Municipality,

Defcndant.
/

CLASS ACTION- COMPLAINT FOR VIOLATION OF CONSTITUTIONAL.

RIOHTS

Plaintiff, JOFIN DOE, on behalf of himself and all others similarly situated, files

class action against the CITY OF VERO BEACH, a Florida Municipality, and says:

1. John Doe #1 is an adequate Class representative because he, like all members of

the proposed class, suffered an invasion of privacy injury redressable by 42 USC

§1983 and caused by the same unlawful/unconstitutional conduct, including

video recording and viewing, committed by the same Defendant at the same

location on approximately the same dates. All class members were recorded on

videotape, without permission, while receiving lawful massage therapy.

2. The members of the class, believed to be in excess of 100 persons, are so

numerous that separate joinder of each member is impracticable. Further, the

Case 9:19-cv-80800-XXXX Document 1-5 Entered on FLSD Docket 06/19/2019 Page 2 of 7

clainis and defenses of the representative party raise the same questions of law

and fact raised and applicable to each class member. The representative party

can fairly and adequately protect and represent the interests of eaeh member of

the class. Further, prosecution via class action reduces the risk of inconsistent

or variant adjudiGations with respect to the individual class members that could

establish incompatible standards of conduct for the party opposing the class and

Finally adiudications in the class which, as a practical matter, would be

dispositive of the interests of other members of the class, who are not parties to

the adjudications, whose interests are hot otherwise protected.

INTRODUCTION

3. The Plaintiff files this action anonymously as .lohn Doe, in an effort to protect

his ongoing rights of privacy, which as alleged below, were violated by the

Defendant. While the Plaintiff will provide all identifying information to the

parties as necessary and as will be protected by Court Orderj the anonymity will

also work to the benefit of the Defendants by mitigating and minimizing the

harmful and damaging potential effects further disclosure would have.

4. This is an action based upon the cohduct of the Defendant, which included

impermissible, non-consensual videotaping of the Plaintiff and other indi viduals

while involved in lawful massages while undressed or semi-undressed.

Case 9:19-cv-80800-XXXX Document 1-5 Entered on FLSD Docket 06/19/2019 Page 3 of 7

5. The Fourth Amendment of the Constitution of the United States of America,

provides for:

The right of the people to be secure in their persons,

houses, papers and effects, against unreasonable searches and
seizures...

6. Defendants violated John Doe’s constitutional rights by surreptitiously

videotaping him while in a state of undress in a licensed massage parlor while

being given a massage by a licensed masseuse without consent or notice.

7. That members of the class were also each videotaped without their knowledge

or consent while receiving lawful massages without notice.

8. This action is brought to hold the Defendant accountable for these violations of

the class members’ constitutiottal rights pursuant to 42 USC 1983 for deprivation

under color of state law of rights, privilege and immunities secured by the

CGnstitution.

THE PARTIES

9. Plaintiff, John Doe, is an individual resident of Martin County, Florida. Other

class members’ residence status will be determined during the course of

discovery.

10. The Veto Beach Police Department is a law enforcement agency of the City of

Vero Beach, Indian River County, Florida.

FACTUAL BACKGROUND

11. In the wake of the worst terror attack in the history of our country. President

George W. Bush signed into law on October 26, 2001, an Act entitled ‘'Uniting
Case 9:19-cv-80800-XXXX Document 1-5 Entered on FLSD Docket 06/19/2019 Page 4 of 7

and Strengthening America By Providing Appropriate Tools Required To

Intercept and Obstruct Terrorism Act of 2001”, This became known as the

Patriot Act. There was substantial debate about the Act, which abrogated the

rights of citizens, including authorization of searches without consent. This was

also called a delayed notice warrant, The laudable purpose of the Act to prevent

further teiTorlst attacks has now been used by the Vero Beach Police Department

to videotape citizens receiving legitimate massages by licensed masseuses in

private rooms! As judge Menz stated, “this is unacceptable”. (Why, if the stated

intent of law enforcement was to protect sex slaves from human trafficking,

wouldn’t law enforcement immediately make arrests, close the spas and end the

alleged criminal enterprise. Gonversely, why would law enforcement allow the

sex slaves to continue to be abused for months.)

12. Sometime in the late fall of 2018, certain members of law enforcement agencies

from Palm Beach, Martin and Indian River counties participated in a “meet and

greet” during which time a discussion involving allegations of prostitution at

spas was brought up. Upon informati on and belief, the subj ect matter of how to

obtain warrants from judges to pursue a course of investigation into these

allegations were also discussed. It is believed that the motivation was far from

that ultimately stated to the press ie: to save the victims of sex slavery, and it

was more likely based upon other considerations.

13 . Each of the law enforcement agencies, and speGifically the Vero Beach Police

Department, utilized the services of a Health Department employee who, Under

Case 9:19-cv-80800-XXXX Document 1-5 Entered on FLSD Docket 06/19/2019 Page 5 of 7

the guise of Health Department authority, actually aeted as an agent of the police,

performing a warrantless search of the spa premises in an effort to determine

whether the spas were engaged in prostitution.

14/rhereafter, each of the identified agencies, including the Town of Jupiter, Palm

Beach County, Martin County, Indian River County and Vero Beach Police

Department, applied for and obtained “sneak and peek” warrants. It should be

noted that each and every warrant contained the same bullet point language.

Various deceptive methods were used to install the video equipment without the

knowledge of others aside from law enforcement. For example, one scenario

involved a fake bomb scare, another involved a power outage, etc.

15, After obtaining the “sneak and peek” warrants, video equipment was installed

throughout the massage parlor, including in actual private rooms where licensed

massages were carried out, Thereafter, the Vero Beach Police Department had

videotape recordings made on a 24/7 basis for a period of approximately 60 days,

16. Multiple members of law enforcement actually viewed the videotapes of all

massages performed at the massage parlors. This, of course, was without the

knowledge and consent of any of the subjects of the video, These videos have

been published and produced publicly ,

17 . John Doe and every member of the class had a reasonable expectation of privacy

while receiving massages from licensed therapists in private rooms.

Case 9:19-cv-80800-XXXX Document 1-5 Entered on FLSD Docket 06/19/2019 Page 6 of 7

18. As Judge Menz stated in her order suppressing the videotape:

The fact that some totally innoeent women and men had their
entire lawful time spent in a massage room fully recorded and
viewed intermittently by a deteetive-monitor is imacceptable...

19. The actions of the Vero Beach Police Department demonstrated a reckless

indifference for the rights of United States citizens.

DAMAGES

20. Plaintiff, John Doe, was actually charged with a crime of solicitation of

prostitution pursuant to Florida Statutes. He pled, and is, not guilty of any such

offense and had to retain counsel.

2,1. Further, John Doe, as well as other class members, were subjected to public

humiliation by ineessantly published photographs and references in the press and

media, both in Florida, the United State and presumably internationally. John

Doe sulTered emotional upset, depression, loss of self esteem and other damages

as a result of this unlawful, unconstitutional conduct by the Defendant.

22. The Defendant’s actions were taken without regard for the risk of public

defamation and hurniliation of members of the class, including John Doe and, in

fact, it is submitted that the Defendants r elished in the aftermath of this operation

and enjoyed the publicity.

23. The actions of the Defendant are in clear violation of the Plaintiff s

consfitutional rights pursuant to the Fourth Amendment.

24. John Doe has retained the undersigned to represent hiin and has agreed to pay

reasonable compensation for his services.

Case 9:19-cv-80800-XXXX Document 1-5 Entered on FLSD Docket 06/19/2019 Page 7 of 7

PR AVER FQR RELIEF

JOHN DOE respectfully requests this Court to certify this class action, order the

Defendant to identify all persons who were suiteptitiGiisly videotaped by the Vero Beach

Police Departinent, enjoin the Defendant froni further disclosure of the surreptitiously

obtained videotape and to award damages, together with costs and attorney’s fees.

Trial by jury is demanded on all issues.

BRADFORD L. JEFFERSON, P.A.

Counsel for Plaintiffs
130 S. Indian River Drive, Suite 402
Fort Pierce, Florida 34950
Telephone; (772) 468-8887

Bradford L. Jefferson
Florida Bar No.: 197270
Email: seivebradiefferson@vahoo.com
 Case 9:19-cv-80800-XXXX Document 1-6 Entered on FLSD Docket 06/19/2019 Page 1 of 3
Indian River Receipt of Transaction
Receipt# 2019019012
Jeffrey R. Smith
Clerk of Court
Indian River. Florida

Received From:
JEFFERSON. BRADFORD L
130 S INDIAN RIVER DRIVE
SUITE 402
Cashier ID: 4308911
On: 5/30/19 9:01 am
Transaction # 921282

CaseNumber 2019 CA 000436

Comments:

Fee Description Fee Prior Paid Waived Due Paid Balance

(CIRCIV) CIRCUIT CIVIL 400.00 0.00 0.00 400.00 400.00 0.00
(CASUMMONS) SUMMONS - CIRCUIT CIVIL 10.00 0.00 0.00 10.00 10.00 0.00

Total: 410.00 0.00 0.00 410.00 410.00 0.00

Grand Total: 410.00 0.00 0.00 410.00 410.00 0.00

PAYMENTS

Payment Type Reference Amount Refund Overage Change Net Amount

OK 410.00 0.00 0.00 0.00 410.00
ePORTAL 90127048

Payments Total: 410.00 0.00 0.00 0.00 410.00

Page 1 of 1
 Case 9:19-cv-80800-XXXX Document 1-6 Entered on FLSD Docket 06/19/2019 Page 2 of 3
Filing # 91007067 E-Filed 06/12/2019 04:33:29 PM

AFFIDAVIT OF SERVICE

State of Florida Gdonty of Indian River Circuit Court

Case^ Number: 312019CA0D0436

Plaintiff:
JOHN DOE, JJR2019005319
VS.
Defendant:
CITY OF VERO BEACH, A FLORIDA MUNICIPALITY,

For;
BRADFORD L, JEFFERSON, P.A.
130 S. Indian River Drive
Suite 402
Fort Pierce, FL 34950

Received by JOSEPH RiGH GPS, INC. on the 29th day of May, 2019 at 10:39 am to be served on CITY OF VERO BEACH, A
FLORIDA MUNICIPALITY C/0 MAYOR VAL ZU,DANS, 1053 2pTH PLACE, VERO BEACH, FL 32960,

I, Beth Kramer, being duly sworn, depose and say that on the:29th day of May, 2019 at 3:49 pm, 1;

GOVERNMENT AGENCY: served by delivering a true copy of the Summons and Glass Action Complaint for Violation of
Constitutional Rights with the date and hour of service endorsed thereon by me, to: TAMMY BURSIGK as CITY CLERKfor CITY OF
VERO BEACH, A FLORIDA MUNICIPALITY C/0 MAYOR VAL ZUDANS, and informed said person of the contents therein, in
compliance with. State Statutes,

Description of Person Served: Age: 50+, Sex: F, Raee/Skin Color: WHITE, Height: 5'5", Weight: 150, Hair: BLONDE. Glasses: N

I certify that lama US citizen over the age of 18, have no interest in the above action, and am a Certified Process Server in good
standing, in the judicial circuit in which the process was served. Under penalty of perjury, I declare that I have read the foregoing and
that the facts stated in it are true. No notary is necessary pursuant to Florida, Statute §92.525.

STATE OF FLORIDA.
COUNTY OF ST, LUCIE Beth Kramer
Subscribed and Sworn to before me on the_ day PS# 09-46
of ___________, _______ by the affiant who is
personally khowh to itie. JOSEPH RICH CPS, INC.
10380 S.W. Village Center Drive,, #414
Port St. Lucie, FL 34987
NOTARY PUBLIC
(772) 340-0011

Our Job Serial Number: JJR-20190.05319

Ref; DOE V, CITY OF VERO

Copyright © 199'2'2019 patabase.Se'rvices, Inb. - Process Server's Toolbox V8.1c

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Case 9:19-cv-80800-XXXX Document 1-6 Entered on FLSD Docket 06/19/2019 Page 3 of 3

Filing # 90127048 E-Filed 05/25/2019 10;52:51 AM

IN Ti-iE emcuiT court of the

NINETEENTH JUDICIAL CIRCUIT, IN
AND FOR INDIAN RIVER COUNTY,
FLORIDA

CASENO.;
JOHN DOE,

Rlaintiff;
vs„

CITY OF VERO BEACH, a Florida

Municipality,

Defendant,

SUMMONS
THE STATE OF FLORIDA:
To Each Sheriff of the State;

YOU ARE COMMANDED to serve this Sumrnons and a copy of the Complaint on the Defendant,
by sei'ving;

City of Vero Beach, a Florida Municipality

c/o Mayor Val Zudans
1053 20"'Place
Vero Beach, FL 32960

Each Defendant is required to serve written defenses to the contpiaintvPr.,petttion..on;.-,

BRADFORD L. JEFFERSON, ESQUIRE |

130 S, Indian River Drive, Suite 402
Fort Pierce, Florida 34950 ,|
Telephone; (772)468-8887

within 20 days after seiwice of this Summons on that defendant excii|sivfe of|:ht,day-;QfserviG6i,,and t0-i'uIe-*
the original of the defenses with the Clerk of this Court either before service on Plaintiffs' attorney or
, iramediately thereafter. If a Defendant fails to do so, a Default will be entered against that Defendant for
the relief demanded in the Complaint or Petition.

DATED this___day of _ ,2019.

Jeffrey R Sniilli

(SEAL)