Welcome to Scribd. Sign in or start your free trial to enjoy unlimited e-books, audiobooks & documents.Find out more
Download
Standard view
Full view
of .
Look up keyword
Like this
1Activity
0 of .
Results for:
No results containing your search query
P. 1
Angela Corey Complaint Answer and Counterclaim Response 2-21-14

Angela Corey Complaint Answer and Counterclaim Response 2-21-14

Ratings: (0)|Views: 4,959|Likes:
District attorney, Angela Corey, responds to the complaint filed by Ben Kruidbos.

Of note in her complaint is Corey stating the information from the cell phone of Trayvon Martin was, according to her, "work product" as opposed to discovery material.

They extracted information from the cell phone belonging to Trayvon Martin, and because of the content they refused to turn it over to the defense team representing George Zimmerman.
District attorney, Angela Corey, responds to the complaint filed by Ben Kruidbos.

Of note in her complaint is Corey stating the information from the cell phone of Trayvon Martin was, according to her, "work product" as opposed to discovery material.

They extracted information from the cell phone belonging to Trayvon Martin, and because of the content they refused to turn it over to the defense team representing George Zimmerman.

More info:

Categories:Types, Legal forms
Published by: The Conservative Treehouse on Feb 21, 2014
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

02/22/2014

pdf

text

original

 
1
IN THE CIRCUIT COURT, FOURTHJUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDACASE NO.: 16-2013-CA-007407DIVISION:BERNARD ALBERT KRUIDBOS,Plaintiff,v.ANGELA B. COREY, in her official capacity asSTATE ATTORNEY FOR THE FOURTHJUDICIAL CIRCUIT OF FLORIDA,Defendant./DEFENDANT ANGELA B. COREY’S, IN HER OFFICIAL CAPACITY AS STATEATTORNEY FOR THE FOURTH JUDICIAL CIRCUIT OF FLORIDA, ANSWER ANDAFFIRMATIVE AND OTHER DEFENSES TO COUNT II IN THE AMENDEDCOMPLAINT AND COUNTERCLAIMS
Pursuant to Fla. R. Civ. P. 1.110(c) and (d), Defendant Angela B. Corey, in her OfficialCapacity as State Attorney for the Fourth Judicial Circuit of Florida (“State Attorney”), answersCount II in the Amended Complaint and asserts affirmative and other defenses thereto and asgrounds states as follows:As to the three paragraphs preceding Count I, State Attorney admits the allegations inthose paragraphs except that she denies any wrongdoing whatsoever and asserts that Plaintiff violated critical job duties, engaged in egregious conduct, and exposed the public to risk of serious harm, leaving State Attorney with no choice but to terminate Plaintiff’s employment.
Count II
1
1
State Attorney filed a motion to dismiss Count I in the Amended Complaint; thus, paragraphs 1-8, which pertain toCount I in the Amended Complaint, need not be answered in this pleading.
Filing # 10369258 Electronically Filed 02/17/2014 08:44:20 PM
 
29. As to paragraph 9 in the Amended Complaint, State Attorney admits that Plaintiff is suing for alleged damages pursuant to the Florida’s public Whistle–blower’s Act (“WBA”)and that this Court has jurisdiction over such claim; however, State Attorney denies that itviolated the WBA and asserts that she acted at all times in accord with Florida law.10. State Attorney denies the allegations in paragraph 10 in the Amended Complaintexcept that she admits Plaintiff was terminated for engaging in egregious misconduct.11. Concerning paragraph 11 in the Amended Complaint, State Attorney denies thefirst sentence, admits that the court has the power to, in certain limited circumstances, sanction parties for discovery violations as alleged in the second sentence (but denies that State Attorneyviolated any discovery obligations and any remaining allegations in the second sentence), anddenies the third sentence in its entirety.12. Concerning paragraph 12 in the Amended Complaint, State Attorney denies thatshe engaged in any action warranting the filing of a complaint with the Florida Commission onHuman Relations (“FCHR”), but nonetheless admits that Plaintiff filed a complaint with theFCHR; she is without knowledge as to when Plaintiff filed the complaint, when such complaintwas received by the FCHR, and whether Exhibit C to the Amended Complaint is a true andaccurate copy of the complaint Plaintiff filed, but she admits that the correct case number was201301613. All other allegations in paragraph 12 are denied.13. Concerning paragraph 13 in the Amended Complaint, State Attorney admits thefirst sentence and further asserts that the FCHR concluded that its investigation did notsubstantiate the allegation that Plaintiff was retaliated against as defined by the WBA. A copy of the Notice of Termination of Investigation is attached hereto as Exhibit A. Concerning thesecond sentence in paragraph 13, State Attorney is without knowledge of Plaintiff’s opinion but
 
3admits that he filed a lawsuit pursuant to the WBA despite the FCHR’s investigation anddecision.14. State Attorney denies the allegations in paragraph 14 in the Amended Complaint.15. State Attorney is without knowledge as to the allegations in paragraph 15 in theAmended Complaint, except that she does admit Plaintiff satisfied his pre-suit obligation relatedto filing a complaint with the FCHR prior to filing the instant lawsuit.16. State Attorney is without knowledge as to the allegations in paragraph 16 in theAmended Complaint.As to the WHEREFORE clause following paragraph 16 in the Amended Complaint, StateAttorney denies that Plaintiff is entitled to any relief whatsoever and asserts that the AmendedComplaint should be dismissed with prejudice and that she should be awarded her attorneysfeesand costs for having to defend against a frivolous claim made in bad faith.
AFFIRMATIVE AND OTHER DEFENSES
A. Plaintiff has failed to state a cause of action because he has not identified a protected disclosure defined by the Act.B. Plaintiff’s termination was predicated upon grounds other than, and would have been taken absent, the employee’s or person’s exercise of rights protected by the WBA.C. Plaintiff has failed to mitigate his damages, if any.D. Plaintiff’s damages may be offset by earnings or benefits he received since histermination of employment.E. The intent of the WBA is not to insulate Plaintiff from being held accountable for his own unlawful and egregious conduct.

You're Reading a Free Preview

Download
scribd
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->