IN THE CIRCUIT COURT, FOURTH JUDICIAL

CIRCUIT, IN AND FOR DUVAL COUNTY,

FLORIDA

CASE NO.: 16-2009-SC-006365

DIVISION: CC-C

ADRIAN LOFTON,

Plaintiff

v.

WASHINGTON MUTUAL,
BANK OF AMERICA,
EVERBANK,
WACHOVIA,
OPTION ONE,

Defendants,

________________________

COMPLAI T

Plaintiff’s complaint seeks damages for Negligence, Conspiracy and Breach of Implied Contract
for surreptiously working with Fidelity National Information Services in violation of the terms
and conditions in the User Access Agreements.

Plaintiff received an e-mail from James Dorrian at Fidelity National Information Services on
August 22, 2007 addressing the ramifications that could result over the sharing of passwords.
Attached to the e-mail were several examples of incidents that occurred when other financial
institutions failed to protect sensitive consumer records. After reading the e-mail, and knowing
that Fidelity National Information Services was facing a multi-million dollar lawsuit for similar
breaches; the Plaintiff called Dorrian on August 22, 2007 and told him that access to millions of
sensitive consumer records and information that should always be guarded and protected was
being mishandled or breached on a daily basis.
Plaintiff reported The Gramm-Leach-Bliley Act violations in accordance to the rules in his
08/02/06 Access Agreement from Ann Thorn of Washington Mutual as well as the User Access
Agreements from the other aforementioned Defendants and Plaintiff objected to and refused to
continue to breach the client’s login credentials.

On August 24, 2007 Lorenzo Roundtree of Fidelity National Information Services assaulted,
then forced the Plaintiff to continue to put millions of consumer records at risk by sharing his
credentials until he was terminated.

After filing suit against Fidelity National Information Services for Wrongful Termination in
violation of the Florida Whistleblower Act, counsel for Fidelity National Information Services
argued that no violation occurred because the aforementioned Defendants secretly gave Fidelity
permission to share these credentials.

Seeing as though (10) ten associates sharing the same credentials would be a monumental
violation of The Gramm-Leach-Bliley Act, the Plaintiff petitioned the courts on numerous
occasions for leave to validate this, but every request was contested and subsequently denied. As
a result of his refusal to violate the client’s user agreements the Plaintiff lost his home,
automobile and livelihood

Plaintiff’s lawsuit against Fidelity National Information Services was dismissed on the grounds
that no violation of federal, state, local or user agreement existed because Defendants gave
Fidelity permission to share user access. As a result of said dismissal, Plaintiff faces a $250,000
to $500,000 dollar judgment for Fidelity’s fees and cost.

It is the Plaintiffs argument that had he known these Defendants had given Fidelity permission
to share these credentials he would have never objected to sharing his credentials and he would
have never instituted suit against Fidelity.

August 5, 2009

Respectfully submitted,

_____________________________

Adrian Lofton, Pro se

Email: loftonadrian@comcast.net
4269 Timuquana Rd
Jacksonville, FL 32210
Phone: 904.384.6646