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Federal Lawsuit Against Florida Government Officials For Ilegal Violations Of Civil Rights

Federal Lawsuit Against Florida Government Officials For Ilegal Violations Of Civil Rights

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Published by tallahasseeobserver
Tallahassee Citizens Rob And Stephanie Brayshaw's Federal Lawsuit For Ilegal Access Of Their Personal Driving Information For Harassment and Stalking By Florida Authorities.
Tallahassee Citizens Rob And Stephanie Brayshaw's Federal Lawsuit For Ilegal Access Of Their Personal Driving Information For Harassment and Stalking By Florida Authorities.

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Published by: tallahasseeobserver on Jul 09, 2014
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08/12/2014

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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION ROBERT A. BRAYSHAW and STEPHANIE BRAYSHAW, CASE NO. Plaintiff, v. LARRY CAMPBELL in his official capacity as SHERIFF LEON COUNTY, FLORIDA, LARRY R. ASHLEY in his official capacity As SHERIFF OKALOOSA COUNTY, FLORIDA, CITY OF TALLAHASSEE, FLORIDA, ELLAINA PINKERTON, individually DAVID PAUL EMMONS, individually RYAN CHRISTOPHER PENDER, individually RYAN N. DUNPHY, individually, and JAMIE K. KNOX, individually, Defendant.  ___________________________________/
 
COMPLAINT
 Plaintiff, ROBERT BRAYSHAW and STEPHANIE BRAYSHAW, hereby sues Defendants, LARRY CAMPBELL, in his official capacity as SHERIFF LEON COUNTY, FLORIDA, LARRY R. ASHLEY in his official capacity as SHERIFF OKALOOSA COUNTY, FLORIDA, CITY OF TALLAHASSEE, FLORIDA, ELLAINA PINKERTON, individually, DAVID PAUL EMMONS, individually, RYAN
Case 4:14-cv-00361-RH-CAS Document 1 Filed 07/08/14 Page 1 of 16
 
CHRISTOPHER PENDER, individually, RYAN N. DUNPHY, individually, and JAMIE K. KNOX, individually, and alleges:
JURISDICTION
1. This is an action for injunctive relief and money damages under 42 U.S.C. §§1983 and
1988, the Driver’s Privacy Protection Act o
f 1994, 18 U.S.C. §§2721 et seq.
(“DPPA”),
 the Fourth Amendment, the Fourteenth Amendment, and other protections afforded by the United States Bill of Rights and the laws of the State of Florida to recover damages
for Defendants’ disregard and invasion of Plaintiff’s constitutionally protected
right to privacy. Jurisdiction of this Court is invoked pursuant 28 U.S.C. §1331 (federal question jurisdiction) and 28 U.S.C. §1343 (civil rights claim jurisdiction). 2. The amount in controversy exceeds Seventy Five Thousand Dollars ($75,000.00), including interests and costs. 3. All conditions precedent to the maintenance of this action have been  performed or have been waived.
THE PARTIES
 4. At all times pertinent hereto, Plaintiff, ROBERT BRAYSHAW, has been a resident of Leon County, Florida
.
 5. At all times pertinent hereto, Plaintiff, STEPHANIE BRAYSHAW, has  been a resident of Leon County, Florida
.
 
Case 4:14-cv-00361-RH-CAS Document 1 Filed 07/08/14 Page 2 of 16
 
 6. Defendant LARRY CAMPBELL, in his official capacity as SHERIFF, of
LEON COUNTY, FLORIDA (“SHERIFF”) was at all times pertinent to th
is action the top constitutional law enforcement officer of Leon County, Florida and was the employer of Defendant PINKERTON and EMMONS.
1
 7. Defendant, LARRY R. ASHLEY in his official capacity as SHERIFF OKALOOSA COUNTY
, FLORIDA (“SHERIFF”) was at all ti
mes pertinent to this action the top constitutional law enforcement officer of Okaloosa County, Florida and was the employer of Defendant KNOX. 8. Defendant CITY OF TALLAHASSEE, FLORIDA, is a municipality duly organized and existing under the laws of the State of Florida. 9. At all times pertinent hereto, Defendant ELLAINA PINKERTON, was a resident of the State of Florida and was employed by Defendant LARRY CAMPBELL as Sheriff of LEON COUNTY. She is sued in her individual capacity. 10. At all times pertinent hereto, Defendant DAVID PAUL EMMONS, was a resident of the State of Florida and was employed by Defendant LARRY CAMPBELL as Sheriff of LEON COUNTY. He is sued in his individual capacity.
1
 Defendant Campbell is referred to collectively with Defendants City of Tallahassee and Ashley as the
Entities Defendants.
 All other Defendants are referred to collectively as the
Individual Defendants.
 
Case 4:14-cv-00361-RH-CAS Document 1 Filed 07/08/14 Page 3 of 16

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