Iwho) quickly developed a reputation for independence and Ioyalty to her constituents,
often fighting powerful, moneyed, and entrenched interests for the sake of what she
believed to be the good of her District and the City.'' (Compl. 11 30). Her opposition,
however, d'came from a somewhat different school of politics than Spence-lones, a
school based on friendship, patronage, and political favors.'' (ld. :1 35).
Full of political intrigue, the Complaint moves from an attempted extradition or
kidnapping in Costa Rica (id. j r 83-88), the 1993 confrontation between the FBl and
Branch Davidians at Waco, Texas (id. I 89-93), a plan to fire the Miami PoliceCommissioner because he had ordered raids on illegal gambling (id. IN 535-540), the
Mayor's alleged misuse of a city-issued gas credit card (id. 1111 51-55), and the failure to
arrest and prosecute the Mayor (at the time, a city commissioner) over an incident
during street protests over Elian Gonzalez which occurred over a decade ago. (Id. 1156).
For purposes of this Order, however, the pedinent allegations are relatively
discreet, involving two criminal prosecutions.
A. Karvm Venturesïcafé Soul ProsecutionAllegations of the Complaint pertaining to the prosecution of Ms. Spence-lonesarising out of the Karym Venturesïcafé Soul matter may be found in paragraphs 238-
325 and 543-592. I have construed the Complaint in the Iight most favorable to the
Plaintift accepting as true all facts that she alleges. See Hishon e. King of Spaulding,
467 U.S. 69, 73 (1984)* see also Wright v. Newsome, 795 F.2d 964, 967 (1 1th Cir.1986).
Case 1:12-cv-24253-DMM Document 100 Entered on FLSD Docket 12/20/2013 Page 3 of 64