IN THE CIRCUIT COURT, FOURTH JUDICIAL CIRCUIT IN AND FOR DUVAL COUNTY, FLORIDA

BERNARD ALBERT KRUIDBOS,

: CASE NO. : DIVISION: Plaintiff, : : vs. : : : COMPLAINT FOR DAMAGES : ANGELA B. COREY, in her official capacity as : DEMAND FOR JURY TRIAL STATE ATTORNEY FOR THE FOURTH : JUDICIAL CIRCUIT OF FLORIDA, : : Defendant. : FL Bar No. 273392 : _____________________________________________/

Plaintiff, BERNARD ALBERT KRUIDBOS (hereinafter “KRUIDBOS”), is a natural person and a resident of Nassau County, Florida. At all times material hereto, KRUIDBOS was employed by the Defendant as the Information Technology Director for the State Attorney’s Office in and for the 4th Judicial Circuit of the State of Florida. Defendant, ANGELA B. COREY, is being sued in her official capacity as State Attorney in and for 4th Judicial Circuit of the State of Florida. Defendant maintains offices in Clay, Nassau, and Duval Counties. Defendant’s headquarters are maintained in Duval County, Florida. Plaintiff sues Defendant, incorporates the above allegations, and further alleges:

COUNT I 1. This is an action for damages, exclusive of attorney’s fees and costs, in excess of FIVE MILLION DOLLARS ($5,000,000), caused by the unlawful and intentional conduct of Defendant.

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2.

Florida Statutes 92.57 provides:

92.57 Termination of employment of witness prohibited.—A person who testifies in a judicial proceeding in response to a subpoena may not be dismissed from employment because of the nature of the person’s testimony or because of absences from employment resulting from compliance with the subpoena. In any civil action arising out of a violation of this section, the court may award attorney’s fees and punitive damages to the person unlawfully dismissed, in addition to actual damages suffered by such person. History.—s. 1, ch. 90-185. 3. Contrary to the provisions of Florida Statutes 92.57, KRUIDBOS was terminated by Defendant on Thursday July 11, 2013 in retaliation for having testified on June 6, 2013, pursuant to a subpoena, before the circuit court in and for Seminole County in State v. Zimmerman, Case No. 2012-001083-CFA. The nature of Plaintiff’s testimony related to the suspected violation by the State Attorney’s Office of its reciprocal discovery obligations under the Florida Rules of Criminal Procedure, and under Florida and federal law. A copy of the subpoena is attached hereto as “Exhibit A”. A copy of the letter of termination is attached hereto as “Exhibit B”. 4. The letter of termination dated July 11, 2013, and signed by Cheryl Peek, references Plaintiff’s testimony. 5. The letter of termination pretextually references other alleged misconduct of the Plaintiff. Notwithstanding those allegations of misconduct, but for the nature of Plaintiff’s testimony Plaintiff would still be employed by Defendant. 6. The unlawful conduct of Defendant in terminating Plaintiff was an intentional and knowing violation of the law and of Plaintiff’s rights, and purposefully, maliciously, directly, proximately, and foreseeably resulted in pecuniary damage to Plaintiff. Those damages include, but are not limited to, loss of income, diminishment of Plaintiff’s ability to seek employment elsewhere, damage to Plaintiff’s standing and reputation in the professional community, and emotional distress. 7. Plaintiff has complied with any conditions prerequisite to bringing this action.

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8. Plaintiff is obligated to pay his attorney a reasonable fee for his services rendered in this cause. WHEREFORE Plaintiff demands: A. Compensatory and special damages. B. An award of attorney’s fees. B. Such other relief as the court deems just and proper.

DEMAND FOR JURY TRIAL Plaintiff, in accordance with Rule 1.430, Florida Rules of Civil Procedure, requests Jury Trial of all issues contained herein so triable.

Respectfully Submitted,

BY:_________________________ Wesley F. White, Esquire Attorney for Plaintiff Post Office Box 17015 Fernandina Beach, FL 32035 Tel. 904.335.8335 Email: wfwhite@gmail.com

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EXHIBIT A

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EXHIBIT B

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