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Complaint for Declaratory and Injunctive Relief

Complaint for Declaratory and Injunctive Relief

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Published by John Carroll
After 4 years of attempting to get redress for the wrongs committed against me, the Good Old Boys of Walton County are making a new attempt to railroad me with a backwoods trial by ambush. Boys, you're going to push me to far with your white trash garbage one of these days. We can take off the gloves and settle this anytime, anywhere.
After 4 years of attempting to get redress for the wrongs committed against me, the Good Old Boys of Walton County are making a new attempt to railroad me with a backwoods trial by ambush. Boys, you're going to push me to far with your white trash garbage one of these days. We can take off the gloves and settle this anytime, anywhere.

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Published by: John Carroll on Mar 16, 2012
Copyright:Attribution Non-commercial

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I THE CIRCUIT COURT OF THE FIRST JUDICIAL CIRCUITI AD FOR WALTO COUTY, FLORIDACIVIL DIVISIOJOH P. CARROLL,Plaintiff, Case o.: 12CA0211v.WALTO COUTY, FLORIDA,
a politicalsubdivision of the State of Florida,
WALTO COUTY BOARD OF COUTYCOMMISSIOERS
,
WALTO COUTYCOTRACTOR COMPETECY BOARD,JOH DALTO,
Board Chairman,
SUEDELLE WILKERSO,
Board Vice Chairman
ROBERT AGERTO, GARY MITCHEM,ROBERT ADREWS, GARY BILLIGSLEY,MARIA WHITEHURST, JOHY SMITH,RADALL YATES, WALTO COUTYBUILDIG DEPARTMET, BILLY BEARDE,
in his capacity as Building Official,
LEE DEPAUWDefendants. ____________________________________________/VERIFIED PETITIO FOR EXPEDITED DECLARATORY,IJUCTIVE AD OTHER RELIEF
Plaintiff John Carroll (Carroll) sues Defendants Walton County, Florida (WaltonCounty), Walton County Board of County Commissioners (Commissioners), WaltonCounty Contractor Competency Board (Contractor Board), Board Chairman John Dalton(Dalton), Board Vice Chairman Suedelle Wilkerson (Wilkerson), Contractor BoardMembers Robert Agerton (Agerton), Gary Mitchem (Mitchem), Robert Andrews(Andrews), Gary Billingsley (Billingsley), Maria Whitehurst (Whitehurst), Johnny Smith(Smith), Randall Yates (Yates), the Walton County Building Department (Building
 
2Department), Billy Bearden (Bearden) and Lee DePauw (DePauw) in their officialcapacities with the Building Department and alleges:
Jurisdiction
1. This Declaratory Action and Petition for Injunction are brought pursuantto Florida Statutes 86.011(2), 86.021, 86.051, 86.061, 86.071, 86.111; 42 U.S.C. § 1983related to the unconstitutionality of a Walton County Ordinance; Violations of Article I,Section 2 of the Florida Constitution against Carroll by the Building Department andContractor Board; Florida Statute 125.01(1) related to the enactment and enforcement of a Walton County Ordinance which stands inconsistent with general or special law; andFlorida Statutes 455 and 489 related to the violation of fundamental due process againstCarroll by the Defendants, over which this Court has subject-matter jurisdiction.2. Carroll is a Florida resident with his principal residence in Walton County,Florida.3. Walton County is a political subdivision of the State of Florida.4. The Commissioners are elected officials serving the residents of WaltonCounty, FL.5. The Contractor Board was appointed by the Commissioners pursuant toWalton County Ordinance 2003-16 (Exhibit A).6. Dalton is the unelected Chairman of the Contractor Board, appointed bythe Commissioners, and sits in judgment of Carroll in violation of conflict of interests toCarroll, the State of Florida Construction Industry Licensing Board or both.
 
37. Wilkerson, Agerton, Mitchem, Andrews, Billingsley, Whitehurst, JohnnySmith and Yates are unelected members of the Contractor Board, appointed by theCommissioners.8. The Building Department was created by Walton County Ordinance andemploys Bearden and DePauw.9. Venue is proper in Walton County, pursuant to Florida Statute 47.011, because the causes of action pled herein accrued in Walton County.
Summary of Claims
10. Carroll holds a valid Florida Building Contractor’s certificate of registration and license number RB0066902.11. In November 2007, Chambers Street Builders, Inc. entered into a bindingcontract with Freddie and Susan Kaye (Exhibit B). Carroll is the President of ChambersStreet Builders, Inc. (Chambers Street).12. On or about February 2008, the Kayes and Chambers Street’s contractualrelations began to deteriorate. The contractual frictions concerned a lack of finishselections on the part of the Kayes, untimely payments to Chambers Street on the part of the Kayes and concern by the Kayes over Chambers Street’s ability to complete thecontract within its contract period.13. At some point during the contract period, the Kayes began negotiationswith CJB Construction Inc., an unlicensed contractor who was building (2) homesnearby. Finish selections ceased on the part of the Kayes, Chambers Street brought theconstruction as far along as it could without said selections, construction payments to

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John Carroll added this note
The very word secrecy is repugnant in a free and open society; and we are as a people inherently and historically opposed to secret societies, to secret oaths and to secret proceedings. We decided long ago that the dangers of excessive and unwarranted concealment of pertinent facts far outweighed the dangers which are cited to justify it. Is America gone?

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