EXHIBIT B' Ethics Complaint against Defendant Peterson
Defendant County Atorney Jack N. Peterson's contended that mare research was necessary to determine if ‘OR SE8/675
\was vald, However na 2000 Memo by Joan C. Henry, Pteroon's fice asseried before tho Lay v. Site of lr court that
there was no dedication of Cayo Costa to the publ. Asa resut, the Ly court red against Defendant Sse, Said cout
‘etemined that Defendant County had no powers, rights-of-way, or itrests inthe private easements ‘as @ mater of
‘established real property law. Therefore, Peterson atitarly contadcted his own Office In order to obtain bene for
Defendant County, Stator himself and undermined ongoing judi proceedings in Sate and Federal Cour.
‘n summary, Peterson's claims and defenses were precluded, because the Lay cours judgment had binding fet and
foredosed Peterson's fvolus contentions. Therefore, Peterson harassed and oppressed Pil and undemined the
{uci process wth foreclosed and factually impossible claims,
In February 1999, Peterson's Office wrote to Cayo Costa riparian lot omer T.Pamell that‘Defondent Lee County Atomey's
(fc researched the history ofthe Second Revised Plat ofthe Cayo Costa Subdson and governing cas aw on eczeton
‘and rection in response to coespondence to Delendant Ato. Sid Plt conclusively evidenced thatthe record owners
Published in tho GranforiGrantee Index, incudng Plan, own private easements, beaches, ard thelr abuting petied
‘designated common use areas in the undedicaled Subdivision fe simple Therefore, Peterson concealed the 1989 and 2000
research by tis own Office and oppressed Pint, because he unjusty exercised power never confered upon hm. in
cancusion, Peterson abused his pubic positon to improperly assist taking of property for State park purposes thereby
oprving and injuring Pen. Therefor, Panis ented to compensatory and puntve damages, and expenses.
Peterson contended that Plants lot 15A did not touch the water. Paints Warranty Deed conveyed lot 15A in reference to
‘seid Plt, cling forthe Gu of Mexico. Said Plat of Survey described Paints lot 15A as a riparian lot abutng the natural
‘monument of the Gull. Pubic poicy demands that all land shall have an owner, and all owners of the accretions in
‘controversy were recorded in Defendants’ GrantorGrantee Index. The publc Index evidenced that al acreions onto the
‘Subdislon belonged to A. C. Roesch, who subdivided and conveyed them, and all accretions onto lot 15A belonged to
Pant. n adton, Peterson was notified that unauthorized unconsttutonal daft ‘OR 568/875’ had multiple eros, voted
Defendant's home rule powers law, and was unenforceable. With particularly, Peterson was ordered to cease false claims
‘and slander of tle. However, Peterson defied the order and continued slandering Plaintiff's paramount tl, in summary,
Pein is ented to cancellaton of ‘OR 569/875, ‘OR 2967/1084-00, and ‘Agenda lem Summary 980206.
Plain ticholder was ented tothe statutory presumption that the 1895 Federal Patent and mesne conveyances were val.
‘Therefore, the burden was on Defendant challenger to prove the Patents inva. Defendant Oficial’ averments and calms
(of ‘OR 569/875, lot A, and block 1, such 2s eg. in doc. #5, were in bad fath and impeded justice, Therefore, Plant is
ented to invalidation and nullification of ‘OR S681675, lot A, and block 1, compensatory and punitive damages, and
Injuncive and dectaratry rele.
10EXHIBIT ‘A’: Unconstitutional and unauthorized "OR 569/875
TH
AESOLUTICE PERTAINING TO PURLIC LDS
— LOR NTMI
WHEREAS, there’ appears in the Public Records of ise
County, Florida, im Pint Book 3 et page 25 the Second nevieed
Piet of Cayo Costa Subdivision: and
WHEREAS, there appears upon enid plat certain designated
Jot and Blowk areas etd other undesignated ereee; and
WHEREAS, there appears upon said plat certain un-numbered
and untettored arees lying East of tho Easterly tier of blocks
im s2id ovbdivision and West of the Westerly tier of blocks
tm eald cubdivision: and
‘wrEREAS, tho County claims asid Jenta a8 public Jande
together with all accretions thereto.
NOM, THEREFORE, SE IT RESOLVED BY THE BOND OF COUNTY
CHUA OOIONERS OF LEE COUNTY, FLORIDA does by this Resolution
claim 03) of raid lands and accretions thereto fer the use
and benefit of the public for public purposes.
DONE Jp ADOPTED this /¢™ dey of L cumbee, 1969.