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Causes of Action - Kruidbos - 92_57 - Complaint - Final (1)

Causes of Action - Kruidbos - 92_57 - Complaint - Final (1)

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Former IT Director Ben Kruidbos files suit against 4th Circuit District Attorney Angela Corey for wrongful termination. Complaint was filed today 8/1/13 in Duval County under Case Number: 16-2013-CA-007407-XXXX-MA
Former IT Director Ben Kruidbos files suit against 4th Circuit District Attorney Angela Corey for wrongful termination. Complaint was filed today 8/1/13 in Duval County under Case Number: 16-2013-CA-007407-XXXX-MA

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Categories:Types, Business/Law
Published by: The Conservative Treehouse on Aug 01, 2013
Copyright:Attribution Non-commercial

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08/08/2013

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 LAW OFFICE OF WESLEY F. WHITE1
IN THE CIRCUIT COURT, FOURTHJUDICIAL CIRCUIT IN AND FOR DUVAL
 
COUNTY, FLORIDA
BERNARD ALBERT KRUIDBOS,
 
:
CASE NO.
:
DIVISION:
 Plaintiff, ::vs. :::
COMPLAINT
 
FOR DAMAGES
 :ANGELA B. COREY, in her official capacity as :
DEMAND FOR JURY TRIAL
STATE ATTORNEY FOR THE FOURTH :JUDICIAL CIRCUIT OF FLORIDA, ::Defendant. :
FL Bar No. 273392
 : _____________________________________________/Plaintiff, BERNARD ALBERT
KRUIDBOS (hereinafter “KRUIDBOS”)
, is a natural person and a resident of Nassau County, Florida. At all times material hereto, KRUIDBOS was
employed by the Defendant as the Information Technology Director for the State Attorney’s
Office in and for the 4
th
Judicial Circuit of the State of Florida.Defendant, ANGELA B. COREY, is being sued in her official capacity as State Attorneyin and for 4
th
Judicial Circuit of the State of Florida. Defendant maintains offices in Clay, Nassau, and Duval Counties
. Defendant’s headquarters are maintained in Duval County
, Florida.Plaintiff sues Defendant, incorporates the above allegations, and further alleges:
COUNT I
1.
This is an action for damages, exclusive of attorney’s fees and costs, in excess of 
FIVE MILLION DOLLARS ($5,000,000), caused by the unlawful and intentional conduct of Defendant.
 
 LAW OFFICE OF WESLEY F. WHITE2
2. Florida Statutes 92.57 provides:
92.57 Termination of employment of witness prohibited.
 — 
A person who testifiesin a judicial proceeding in response to a subpoena may not be dismissed from
employment because of the nature of the person’s testimony or because of absences
from employment resulting from compliance with the subpoena. In any civil action
arising out of a violation of this section, the court may award attorney’s fees and
punitive damages to the person unlawfully dismissed, in addition to actual damagessuffered by such person.History.
 — 
s. 1, ch. 90-185.
3. Contrary to the provisions of Florida Statutes 92.57, KRUIDBOS was terminated by Defendant on Thursday July 11, 2013 in retaliation for having testified on June 6, 2013, pursuant to a subpoena, before the circuit court in and for Seminole County in
State v. Zimmerman
, Case No. 2012-001083-CFA
. The nature of Plaintiff’s testimony related to the
suspected violation
 by the State Attorney’s Office of its reciprocal discovery obligations under 
the Florida Rules of Criminal Procedure, and under Florida and federal law. A copy of the
subpoena is attached hereto as “Exhibit A”. A copy of the letter of termination is attached heretoas “Exhibit B”.
 4. The letter of termination dated July 11, 2013, and signed by Cheryl Peek,references Plaint
iff’s testimony.
 5. The letter of termination pretextually references other alleged misconduct of thePlaintiff. Notwithstanding those allegations of misconduct, but for the nature of 
Plaintiff’s
 testimony Plaintiff would still be employed by Defendant.6. The unlawful conduct of Defendant in terminating Plaintiff was an intentional andknowing violation of the law
and of Plaintiff’s rights
, and purposefully, maliciously, directly, proximately, and foreseeably resulted in pecuniary damage to Plaintiff. Those damages include,
 but are not limited to, loss of income, diminishment of Plaintiff’s ability to seek employmentelsewhere, damage to Plaintiff’s standing and reputation in the professional community, and
emotional distress.7. Plaintiff has complied with any conditions prerequisite to bringing this action.
 
 LAW OFFICE OF WESLEY F. WHITE3
8. Plaintiff is obligated to pay his attorney a reasonable fee for his services renderedin this cause.WHEREFORE Plaintiff demands:A.
 
Compensatory and special damages.B.
 
An award of attorney’s
fees.B. Such other relief as the court deems just and proper.
DEMAND FOR JURY TRIAL
 Plaintiff, in accordance with Rule 1.430, Florida Rules of Civil Procedure, requests JuryTrial of all issues contained herein so triable.Respectfully Submitted,BY:_________________________ Wesley F. White, EsquireAttorney for Plaintiff Post Office Box 17015Fernandina Beach, FL 32035Tel. 904.335.8335Email: wfwhite@gmail.com

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