Complaint Filed 8-10-2016 PDF

Filing # 45025402 E-Filed 08/10/2016 12:32:17 AM
IN THE CIRCUIT COURT OF THE

11TH JUDICIAL CIRCUIT IN AND
FOR MIAMI-DADE COUNTY,
FLORIDA
GENERAL CIVIL DIVISION
CASE NO.
JASON BLOCH,
Plaintiff,
vs.
MARCIA DEL REY; STAND UP TO VIOLENCE,
an Electioneering Communications Organization;
JORGE ALBERTO BALLESTE, Chairperson of
Stand Up to Violence; CHRISTINA WHITE, solely
in her official capacity as Miami-Dade County
Supervisor of Elections; and KEN DETZNER,
solely in his official capacity as Florida
Secretary of State,
Defendants.
____________________________ /
COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
Plaintiff JASON BLOCH sues Defendants MARCIA DEL REY, STAND UP
TO VIOLENCE, an Electioneering Communications Organization, JORGE
ALBERTO BALLESTE, CHRISTINA WHITE, solely in her official capacity as
Miami-Dade County Supervisor of Elections, and KEN DETZNER, solely in his
official capacity as Florida Secretary of State, for declaratory and injunctive relief.
PARTIES, VENUE AND JURISDICTION
1.
This is a complaint for declaratory and injunctive relief.
Jason Bloch v. Marcia Del Rey, et al.

Complaint
2.
Plaintiff JASON BLOCH (Bloch) is a candidate for the position of
Circuit Judge, 11th Judicial Circuit of Florida, Group 9, for Miami-Dade County,
Florida.
3.
Defendant MARCIA DEL REY (Del Rey) is a candidate for the
position of Circuit Judge, 11th Judicial Circuit of Florida, Group 9, for Miami-Dade
County, Florida.
4.
STANDUP TO VIOLENCE is an Electioneering Communications
Organization (ECO) organized under the laws of Florida.

5.
JORGE ALBERTO BALLESTE is the Chairperson of Stand Up to
Violence.
6.
Defendant CHRISTINA WHITE (Supervisor of Elections) is the
Supervisor of Elections of Miami-Dade County, Florida, and is responsible for

certain aspects of qualifying candidates in Miami-Dade County and for conducting
elections in Miami-Dade County, and is sued solely in her official capacity.
7.
Defendant KEN DETZNER (Secretary of State) is the Secretary of
State of Florida, and is responsible for qualifying candidates for Circuit Court
Judge, and is sued solely in his official capacity.
FACTUAL ALLEGATIONS
8.
Section 8, Article II of the Florida Constitution requires a candidate
for office to file a full and public disclosure of financial interests at the time of
2

Complaint
qualifying for office. The Constitution reflects the clear and mandatory public
policy directive of openness with respect to a candidates finances. Section 105.031,
Florida Statutes (2015), further explicates the Constitutional requirement of filing a
full and public disclosure of financial interests. This constitutional provision is
mandatory on all candidates for public office.
9.
The need for transparency is no less, and perhaps more important for
judicial candidates, given their unique powers and role in government. Judges are
routinely, and properly, held to higher standards.
10.
At the time she purportedly qualified for judicial office on May 3,
2016, Defendant Marcia Del Rey refused and failed to accurately provide the
mandatory full and public disclosure required by the Florida Constitution, pursuant
to Article II, Section 8(a) of the Florida Constitution. A copy of her May 3, 2016
Full and Public Disclosure of Financial Interests (Form 6) for 2015 as filed with the
Division of Elections, Florida Secretary of State is attached hereto as Exhibit A.
11.
The Form 6 filed by Defendant Del Rey is materially deficient in
several constitutional aspects. First, although every judicial candidate seeking

office on the August 30, 2016 election ballot is required to disclose income for the
year 2015, Defendant Del Rey refused to do so. Form 6 plainly instructs the
candidate to Identify each separate source and amount of income which exceeded
$1,000 during the year [2015] Or attach a complete copy of your 2015 federal
3

Complaint
income tax return Ignoring the mandatory constitutional directive, yet swearing
that the information disclosed on this form and any attachments hereto is true,
accurate, and complete[,] Defendant Del Rey based her information on old,
outdated income figures, stating on Page 2 of her Form 6 that the income was only
based on 2014 return. This reporting of income for a period one year earlier than
that required by law is a fundamental deficiency that is a material violation of the
mandatory Constitutional requirement that is not only inaccurate and incomplete,
but affirmatively misled Florida citizens.
12.
Second, compliance with the constitutional financial disclosure
requirement obligates a candidate to disclose each source of the candidates

income, including the address of that source. Del Rey failed and refused to so
comply. As to the second highest source of her 2014 income ($51,000), she states
only that it comes from Puerto Rico (Puerto Rico Income), as if Puerto Rico is
or could be a source of that income. If the funds are from a sovereign entity of
Puerto Rico, she is required to identify the entity with particularity, including the
address of source of income ... If the income arises from business interests in the
geographic area known as Puerto Rico, she is required to identify that source.
Moreover, she failed to provide the address for this hidden Puerto Rico source,
listing nothing but the City of Caguas, Puerto Rico, a municipality of approximately
150,000 residents. This non-disclosure disregards the requirement to provide the
4

Complaint
source of the income. That affirmative and material omission is improper,

constituting a further breach of the Constitutional mandate.
13.
As a result of Defendant Del Reys failure to comply with the full and
public financial disclosure requirement, she is not constitutionally qualified to seek

public office as defined by Florida law. The multiple failures in this case are
material and not de minimis. As illustrated in the following paragraphs, the
omissions and deficiencies go to the heart of this candidates constitutional
qualifications, and to the public policy underlying that requirement.
14.
Defendant Del Reys campaign materials assert she is an advocate for
families and children, purportedly someone who helps victims of domestic violence
and sexual abuse. Yet, her materially deficient financial disclosure forms do not
disclose the nature and extent of her compensation and profit from hotel and
accommodation businesses that purportedly serve as the host venue for a myriad of
highly questionable activities. This fact may be a purposeful reason for her refusal
to provide the full financial disclosures required by the Florida Constitution.
15.
Defendant Del Rey disclosed in her Form 6 Financial Disclosure
(previously identified as Exhibit A) that she is a 33% owner of Tropic Gardens

Investments, Inc., a business entity that operates as Executive Fantasy Motels, with
locations near the airport and in Hialeah, including the Miami Executive Hotel and
El Presidente. Exhibit B is a compilation of information pertaining to Executive
5

Complaint
Fantasy Motels describing the nature of the motel activity and their corporate
ownership, including Marcia Del Reys ownership of the groups Puerto Rico
entity, Executive Fantasy Hotel of Puerto Rico, Inc., a business entity not disclosed
on her Form 6. Representative samples of the numerous public records, including
arrest affidavits and criminal charges filed by the Miami-Dade State Attorney,
assert that these locations have been host to various criminal activities, including
prostitution, illegal drugs, armed sexual battery, and human trafficking (attached as
Exhibit C).
16.
Defendant Del Reys financial disclosure information, by not
complying with Florida law concerning the sources of her income, materially
misleads the Florida public, including with respect to the undisclosed Puerto Rico
income, and whether that income is derived from ventures similar to the Miami
holdings. Regardless of the nature of the income, Floridas Constitution mandates
that candidates provide specificity in income disclosures, and not merely a
generalized geographic location of business activity, such as Puerto Rico income,
or Florida income, or United States income.
17.
Defendant Del Reys material misstatements and omissions are part
and parcel of a purposeful effort to mislead the public as to matters required to be

disclosed. Included within her pattern of misrepresentations are Defendant Del
Reys political advertisements wherein she claims to be a former Assistant State
6

Complaint
Attorney for the Domestic Violence Unit of the Eleventh Judicial Circuit of
Florida. (Attached as Exhibit D). This is an outright fabrication, as Defendant Del
Rey was never an Assistant State Attorney with the Miami-Dade State Attorneys
Office or any other prosecution office.
18.
Documents (attached as Exhibit E) establish Defendant Del Rey was
never an Assistant State Attorney, either in the Domestic Violence Unit or in any
other unit. To the contrary, she was never employed with the State Attorneys Office
while she was a member of The Florida Bar, since her admission to the practice of
law in Florida occurred on November 1, 2005 (Exhibit E, page 1). Her only status
with the State Attorneys Office was as a Legal Trainee, a fact she omitted in her
effort to mislead the public and misrepresent her credentials (Exhibit E, pages 5,
7, 12-13). While she was offered the opportunity to become an Assistant State
Attorney, according to records of the State Attorneys Office, and briefly was a
trainee in that office, she instead abandoned the position after five weeks, even
before becoming a member of The Florida Bar, a prerequisite to ever becoming an
Assistant State Attorney. Her after-the-fact effort to cover her tracks by purporting
to resign from the State Attorneys Officeafter she had already been terminated
only proves her calculated effort to mislead the voters.
19.
Defendant Marcia Del Rey has even repeatedly misstated the title of
the judicial position for which she is running, stating she is a candidate for District
7

Complaint
11, Group 9, instead of for the 11th Judicial Circuit, Group 9. This further confuses
the electorate as to the office she is seeking, and against whom she is running. The
misleading political advertisements are attached as Exhibit F.
20.
Because Defendant Del Rey is not properly qualified as a candidate for
Miami-Dade Circuit Court Judge due to her material failures to comply with the
requirements of the Florida Constitution to provide full and public financial
disclosure, she is not entitled to be placed on the ballot or to seek election to the
position of Circuit Judge, 11th Judicial Circuit of Florida, Group 9, for Miami-Dade
County, Florida.
21.
This complaint is submitted in advance of the August 30, 2016,
election, and is based upon factual information demonstrating her lack of

constitutional qualifications for office.
22.
In addition, Defendant Del Rey has been the beneficiary of many
thousands of dollars in advertising by an Electioneering Communications

Organization (ECO) known as Stand Up to Violence, whose chairperson is Jorge
Alberto Balleste. In violation of Florida Law, the ECO has engaged in express
advocacy, including in the attached advertisement compilation, Exhibit G hereto,
which, in part, urges voters to vote for Number 81 on your ballot or #81 This
is in violation of the prohibition on express advocacy by an ECO, and therefore
constitutes an undisclosed campaign contribution to Defendant Del Rey in excess
8

Complaint
of the legal limit. Since Defendant Marcia Del Rey is obviously coordinating with
the ECOs activities and has accepted the excessive contribution, she is equally
liable for its statutory misconduct as is the ECO and its chairperson, Jorge Alberto
Balleste. Attached as Exhibit H is the Statement of Organization of Political
Committee for Stand Up to Violence.
23.
Perhaps even more indicative of Defendant Del Reys total disregard
for the financial requirements of office and campaign law is the fact that the Stand
Up ECO is funded almost entirely by Julio Del Rey, Defendant Del Reys father,
with contributions of $185,000. See Exhibit I.
24.
Further, Defendant Del Rey is engaged in a secretive financial scheme
that masks her apparent undisclosed income and her campaign for judicial office in
violation of Floridas financial disclosure requirements. Specifically, during the
course of her judicial campaign, Defendant Del Reys law firm has placed numerous
high-profile billboard and bus bench advertisements within Miami-Dade County,
utilizing the same photograph that appears on her judicial campaign advertisements.
But the payment for those purported law firm advertisements is not through the law
firm, but in part through undisclosed Puerto Rico companies that are involved in
the questionable business activities she thus far has failed to divulge. The sources
of these purported advertisement payments do not appear in her financial
disclosures, even though she is receiving the benefits of this undisclosed or
9

Complaint
disguised income. Nor do they appear as companies in which she has identified a
legal, financial, or beneficial interest. And because the duration of these purported
law firm advertisements is consistent with the judicial campaign period, it appears
the payments constitute undisclosed judicial campaign contributions and benefits.
The law firm advertisement documents and payments are attached as Exhibit J.
They reflect payments made for law firm advertisements by Julio Del Rey,
Defendant Del Reys father, and an undisclosed Puerto Rico corporation in which
Defendant Del Rey has a financial interest.
25.
This entire matter is appropriate to be advanced on the calendar for
expedited relief, in view of the occurrence of the August 30, 2016 election.
COUNT I DECLARATORY RELIEF AS TO MARCIA DEL REY
26.
Plaintiff repeats and re-alleges Paragraphs 1 through 25, all of which
are incorporated herein by reference.

27.
The Plaintiff is in doubt as to his right, title, status, or interest as to his
candidacy vis--vis Defendant Del Rey, due to her failure to satisfy the mandatory
constitutional requirements for full and public financial disclosure.
28.
This is a material and legitimate concern that requires a judicial
declaration.
10

Complaint
29.
Plaintiff is entitled to a judicial declaration as to his rights, title, status,
or interest, declaring that Defendant Del Rey is not constitutionally qualified to be

a candidate for the office she is seeking.
COUNT II INJUNCTIVE RELIEF AS TO DEFENDANT DEL REY
30.

31.
Plaintiff is entitled to the entry of a temporary and permanent
injunction to have the Defendant Del Rey immediately removed from the ballot as
a candidate for circuit judge due to her failure to comply with the mandatory
constitutional requirement for full and public financial disclosure, and to have all
appropriate actions taken to effectuate said injunction.
32.
injunction requiring the Secretary of State to determine that Defendant Del Rey is
not qualified to be a candidate for the position of Circuit Court Judge and to revoke
her official certification as a qualified candidate.
33.
Plaintiff is entitled to immediate entry of a temporary and permanent
injunction directing the Supervisor of Elections to notify voters that Defendant Del
Rey is not a qualified candidate, by any practicable means, and further directing the
Supervisor of Elections not to count any votes cast for candidate Del Rey.
11

Complaint
34.
Plaintiff does not have an adequate remedy at law for the actions of all
Defendants set forth herein, and will suffer irreparable harm if an injunction is not
entered against Defendants, as aforesaid. It is in the public interest for an injunction
to be granted. Plaintiff is likely to be successful on the merits of this matter.
COUNT III
INJUNCTIVE RELIEF AS TO DEFENDANTS DEL REY, STAND UP TO
VIOLENCE (ECO), AND JORGE ALBERTO BALLESTE
35.

36.
The activities of the ECO, by engaging in express advocacy, are
contrary to law and cannot be permitted to continue.

37.
injunction prohibiting Stand Up to Violence, and its chairperson, Jorge Alberto

Balleste, from continuing to expend funds by engaging in express advocacy, and
prohibiting Defendant Del Rey from accepting the benefits of the express advocacy.
38.
Plaintiff does not have an adequate remedy at law for these actions of
the Defendants, and will suffer irreparable harm if an injunction is not entered
against Defendants, as aforesaid. It is in the public interest for an injunction to be
granted. Plaintiff is likely to be successful on the merits of this matter.
For these reasons, Plaintiff asks this Court grant the following relief:
12

Complaint
a.
Set a Status Conference and an Emergency Hearing at which a
Temporary, Preliminary, and/or Permanent Injunction may be granted; and

b.
Enter an Order for expedited discovery.
c.
Enter a Declaratory decree that Defendant Del Rey is not qualified to
be a candidate for Circuit Court Judge.

d.
Enter an Injunction, both temporary and permanent, against Defendants
Del Rey, Supervisor of Elections, and Secretary of State, granting the relief
requested.
e.
Enter an injunction, both temporary and permanent, against Defendants
Del Rey, Stand Up to Violence, and Jorge Alberto Balleste, enjoining them from
engaging in express advocacy or from accepting the benefits thereof.
f.
Such other and further relief as this Court deems just and proper.
DATED this 9th day of August 2016.

Respectfully submitted,
GREENSPOON MARDER, PA
Attorneys for Plaintiff
200 East Broward Blvd, Suite 1800
Fort Lauderdale, FL 33309
Tel: (954) 491-1120
By:
S/ Joseph S. Geller
JOSEPH S. GELLER
Florida Bar No. 292771
LAW OFFICE OF
BENEDICT P. KUEHNE, P.A.
13

Complaint
100 SE 2 Street, Suite 3550

Miami, FL 33131-2154
305.789.5989
305.789.5987 Fax
efiling@kuehnelaw.com
ben.kuehne@kuehnelaw.com
By:
14
S/ Benedict P. Kuehne
BENEDICT P. KUEHNE
MICHAEL T. DAVIS
Exhibit A, page 1
Exhibit A, page 2
Executive Tropic Garden - Miami Adult Hotel
ROOMS
THEMED SUITES
HOT EVENTS
RATES
Page 1 of 3
HOTELS
LOCATION
PRIVACY
CONTACT
EXECUTIVE TROPIC GARDEN HOTEL

A lavish indulgence
Hotel Description
Elegantly decorated with deluxe
suite options set this romantic
hotel apart from the rest. Want
a room with a winding grand
staircase leading to your master
suite? Tropic Garden offers one.
Even the Love Suite is a couples
delight with a clean classic
Exhibit B, page 1
http://www.executivefantasyhotels.com/portfolio/executive-tropic-garden-hotel/
8/8/2016
Page 2 of 3
design. Upgrade to an Executive

Suite and you get the works: a
romantic heart-shaped jacuzzi
anda fantasy shower where
frosted glass lets you be a
voyeur.
Located just minutes east of SW
8th Street and the Palmetto
Expressway.
Heart-shaped Jacuzzis
Fantasy (clear glass)
Showers
Disco Balls
Patented Love Chairs
Mirrored Rooms
Full Bar: Champaign, Beer,
Wine and Spirits
Free Wifi
CD Stereos
Flat Panel TVs
iPod Docking Stations
VIEW ROOMS
Other Hotels
Exhibit B, page 2
8/8/2016
EXECUTIVE
AIRPORT HOTEL
HOTEL PRESIDENTE
Page 3 of 3
LA FUENTE MOTEL
8TH ST
EXECUTIVE GRAND
EMPEROR HOTEL
All rooms feature

The legacy of our
private garage
When you check in
Experience the
signature property
entry, emphasizing
to our budget hotel
highest level in
lies in our
discretion at all
you will noticewe
modern luxury
acclaimed themed
times. Three tiers
paidclose attention
with our stylish
rooms. The Cave
of rooms feature
to fine details that
mood lighting in
Suite, The Jungle
modern designs
make it...
our multi-level
Suite and...
with...
Continue Reading
rooms that make

Continue Reading
any...
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WEATHER
FORECAST
77
F
OUR
LOCATIONS
HOTEL
INFORMATION
Contact Us

info@executivefantasyhotels.com
+

Light Rain
2016 Executive Fantasy Hotels. All rights reserved.
website by Design House
Exhibit B, page 3
8/8/2016
Exhibit B, page 4
Exhibit B, page 5
Exhibit B, page 6
Exhibit B, page 7
Exhibit B, page 8
Exhibit B, page 9
Exhibit B, page 10
Exhibit B, page 11
Exhibit B, page 12
Exhibit B, page 13
Exhibit B, page 14
Exhibit B, page 15
DBPR - TROPIC GARDEN INVESTMENTS INC; Doing Business As: EXECUTIVE T... Page 1 of 2
6:41:11 PM 8/8/2016
Licensee Details
Licensee Information
Name:
TROPIC GARDEN INVESTMENTS INC (Primary Name)

EXECUTIVE TROPIC GARDENS (DBA Name)
Main Address:
6925 SW 8TH STREET

MIAMI Florida 33144
County:
DADE
License Mailing:
LicenseLocation:
6925 SW 8TH STREET

MIAMI FL 33144
County:
DADE
License Information
License Type:
Retail Beverage
Rank:
4COP
License Number:
BEV2300826
Status:
Current,Active
Licensure Date:
09/19/2007
Expires:
03/31/2017
Special Qualifications
Qualification Effective
Invoice Sent
08/29/2007
Dual Beverage and

Tobacco License
08/16/2007
Hotel/Motel - COP &

Package
08/16/2007
Alternate Names
View Related License Information

View License Complaint
2601 Blair Stone Road, Tallahassee FL 32399 :: Email: Customer Contact Center :: Customer Contact Center: 850.487.1395
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Under Florida law, email addresses are public records. If you do not want your email address released in response to a public-records
request, do not send electronic mail to this entity. Instead, contact the office by phone or by traditional mail. If you have any
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Detail by Entity Name
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Florida Profit Corporation
TROPIC GARDEN INVESTMENTS, INC.
Filing Information
Document Number
FEI/EIN Number
Date Filed
State
Status
Last Event
Event Date Filed
F17408
59-2077430
01/26/1981
FL
ACTIVE
REINSTATEMENT
10/19/2000
Principal Address
6925 S.W. 8 STREET
MIAMI, FL 33144
Changed: 12/27/1999
Mailing Address
6925 S.W. 8 STREET
MIAMI, FL 33144
Changed: 12/27/1999
Registered Agent Name & Address
DEL REY, JULIO JR.
6925 S.W. 8 STREET
MIAMI, FL 33144
Name Changed: 12/27/1999
Address Changed: 08/01/1989
Officer/Director Detail
Name & Address
Title PD
DEL REY, JULIO JR.
6925 S.W. 8 STREET
MIAMI, FL 33144
Exhibit B, page 22
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Annual Reports
Report Year
2014
2015
2016
Filed Date
02/11/2014
01/22/2015
03/02/2016
Document Images
03/02/2016 -- ANNUAL REPORT
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10/19/2000 -- REINSTATEMENT
Copyright and Privacy Policies

State of Florida, Department of State
Exhibit B, page 23
8/8/2016
2016 FLORIDA PROFIT CORPORATION ANNUAL REPORT
FILED
Mar 02, 2016
Secretary of State
CC9784541261
DOCUMENT# 416316
Entity Name: GOHEMOR INVESTMENT CORPORATION
Current Principal Place of Business:
6925 S.W. 8TH ST.
MIAMI, FL 33144
Current Mailing Address:

6925 S.W. 8TH ST.
MIAMI, FL 33144
FEI Number: 59-1477365
Certificate of Status Desired: Yes
Name and Address of Current Registered Agent:

DEL REY, JULIO JR
6925 S.W. 8 STREET
MIAMI, FL 33144 US
The above named entity submits this statement for the purpose of changing its registered office or registered agent, or both, in the State of Florida.
SIGNATURE:
Date
Electronic Signature of Registered Agent
Officer/Director Detail :
Title
PD
Name
DEL REY, JULIO JR.
Address
6925 S.W. 8TH ST.
City-State-Zip:
MIAMI FL 33144
I hereby certify that the information indicated on this report or supplemental report is true and accurate and that my electronic signature shall have the same legal effect as if made under
oath; that I am an officer or director of the corporation or the receiver or trustee empowered to execute this report as required by Chapter 607, Florida Statutes; and that my name appears
above, or on an attachment with all other like empowered.
SIGNATURE: JULIO DEL REY
PRESIDENT
Electronic Signature of Signing Officer/Director Detail
Exhibit B, page 24
03/02/2016
Date
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Florida Profit Corporation
GOHEMOR INVESTMENT CORPORATION
Filing Information
Document Number
FEI/EIN Number
Date Filed
State
Status
Last Event
Event Date Filed
416316
59-1477365
01/09/1973
FL
ACTIVE
REINSTATEMENT
10/19/2000
Principal Address
6925 S.W. 8TH ST.
MIAMI, FL 33144
Changed: 09/23/1974
Mailing Address
6925 S.W. 8TH ST.
MIAMI, FL 33144
Changed: 09/23/1974
Registered Agent Name & Address
DEL REY, JULIO JR
6925 S.W. 8 STREET
MIAMI, FL 33144
Name Changed: 12/27/1999
Address Changed: 12/27/1999
Officer/Director Detail
Name & Address
Title PD
DEL REY, JULIO JR.
6925 S.W. 8TH ST.
MIAMI, FL 33144
Exhibit B, page 25
8/8/2016
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Annual Reports
Report Year
2014
2015
2016
Filed Date
02/12/2014
01/22/2015
03/02/2016
Document Images
10/19/2000 -- REINSTATEMENT

Exhibit B, page 26
8/8/2016
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EXECUTIVE TROPIC GARDENS
Filing Information
Registration Number
Status
Filed Date
Expiration Date
Current Owners
County
Total Pages
Events Filed
FEI/EIN Number
G03274900027
ACTIVE
10/01/2003
12/31/2018
2
MIAMI-DADE
3
2
NONE
Mailing Address
6925 S.W. 8 STREET
MIAMI, FL 33144
Owner Information
GOHEMOR INVESTMENT CORPORATION
6925 S.W. 8 STREET
MIAMI, FL 33144
FEI/EIN Number: 59-1477365
Document Number: 416316
TROPIC GARDEN INVESTMENTS, INC.
6925 S.W. 8 STREET
MIAMI, FL 33144
FEI/EIN Number: 59-2077430
Document Number: F17408
Document Images
10/01/2003 -- REGISTRATION
07/26/2013 -- Fictitious Name Renewal Filing
08/01/2008 -- RENEWAL
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Exhibit B, page 27
http://sunbiz.org/scripts/ficidet.exe?action=DETREG&docnum=G03274900027&rdocnum=... 8/8/2016
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Exhibit D, page 1
Exhibit D, page 2
Exhibit D, page 3
Exhibit D, page 4
Exhibit D, page 5
Exhibit D, page 6
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Marcia Del Rey

Member in Good Standing
Eligible to Practice Law in Florida
Bar Number:
17780
Mail Address:
Law Offices of Marcia Del Rey, P.

1800 SW 27th Ave Ste 500
Miami, FL 33145-2400
United States
Office: 305-529-0255
Fax: 305-529-0360
Email:
mdelrey@drlpa.com
Personal Bar URL:
www.floridabar.org/mybarprofile/17780
vCard:
County:
Miami-Dade
Circuit:
11
Admitted:
11/01/2005
10-Year Discipline History:
None
Law School:
Florida International University, College of Law
Sections:
Family Law
Trial Lawyers
Exhibit E, page 1
http://www.floridabar.org/wps/portal/flbar/home/directories/MBR/!ut/p/z1/jY_LDoIwEEU_... 8/9/2016
Exhibit E, page 2
Exhibit E, page 3
Exhibit E, page 4
Exhibit E, page 5
Exhibit E, page 6
Exhibit E, page 7
Exhibit E, page 8
Exhibit E, page 9
Exhibit E, page 10
Exhibit E, page 11
Exhibit E, page 12
Exhibit E, page 13
Exhibit E, page 14
Exhibit F, page 1
Exhibit F, page 2
I keep telling people that I couldnt smoke enough dope to dream up some
http://crespogram.com/index_public_html/MARCIA_DEL_REY_RUNNING_FOR_JUDGE.html
Exhibit F, page 3
2/20/16, 12:39 AM
Page 1 of 6
Exhibit F, page 4
Exhibit F, page 5
Exhibit G, page 1
Exhibit G, page 2
Exhibit G, page 3
Exhibit H, page 1
Exhibit H, page 2
Contributions Query Results - Division of Elections - Florida Department of State
Page 1 of 1
Contributions Query Results

About the Campaign Finance Data Base
If all contributions for a reporting period are less than 1 dollar they may not be displayed.
Search Criteria:
Detail of Committees
Election Year: 2016 General Election
With Candidate Last Name Starts With: stand up to violence
Committee Type: All
Candidate/Committee
Date
Amount
-------------------------------------------------- ---------- ---------------Stand Up To Violence (PAC)
05/04/2016
10,000.00
Stand Up To Violence (PAC)
06/01/2016
75,000.00
07/20/2016
100,000.00
-----------------------------------------------------------------------------Total:
185,000.00
3 Contribution(s) Selected
Typ
--CHE
CHE
CHE
Contributor Name
---------------------------------------DEL REY JULIO
DEL REY JULIO
DEL REY JULIO
Address
---------------191 VERA COURT
191 VERA COURT
191 VERA CT
Query the Campaign Finance Data Base

[Department of State] [Division of Elections] [Campaign Finance - Contributions]
Exhibit I, page 1
http://dos.elections.myflorida.com/cgi-bin/contrib.exe
8/9/2016
Expenditures Query Results - Division of Elections - Florida Department of State
Page 1 of 1
Expenditures Query Results

Search Criteria:
With Committee Name Starts With: stand up to violence
Committee Type: All
Candidate/Committee
Date
Amount
-------------------------------------------------- ---------- ---------------Stand Up To Violence (PAC)
05/09/2016
31.08
05/16/2016
1,000.00
05/31/2016
3,000.00
06/14/2016
3,670.00
06/15/2016
4,582.08
06/27/2016
18,000.00
07/05/2016
4,650.00
07/05/2016
6,000.00
07/18/2016
7,826.88
-----------------------------------------------------------------------------Total:
48,760.04
9 Contribution(s) Selected
Payee Name
---------------------------------------FEDEX
COATES LAW FIRM, PL
SALEM MEDIA GROUP
GROVE MEDIA PARTNERS
THE MIAMI HERALD
U MEDIA
CARILLO, KANDY
RADIO PEP, INC.
THE MIAMI HERALD
Address
-------------------942 SOUTH SHADY GROV
115 EAST PARK AVENUE
5757 BLUE LAGOON DRI
2601 S. BAYSHORE DRI
3511 NW 91 AVENUE
927 CATALONIA AVENUE
1145 NE 133 ST
1055 NW 125 ST
3511 NW 91ST AVE

[Department of State] [Division of Elections] [Campaign Finance - Expenditures]
Exhibit I, page 2
http://dos.elections.myflorida.com/cgi-bin/expend.exe
8/9/2016
Other Distributions Query Results - Division of Elections - Florida Department of State
Page 1 of 1
Other Distribututions Query Results

Search Criteria:
With Committee Name Starts With: stand up to violence
Committee Type: All
Candidate/Committee
Date
Amount Distributed To
Address
-------------------------------------------------- ---------- ---------------- ---------------------------------------- -------------------Stand Up To Violence (PAC)
07/05/2016
4,650.00 RADIO COIN
1055 NE 125 STREET
-----------------------------------------------------------------------------Total:
4,650.00
1 Other Distributions Selected
[Department of State] [Division of Elections] [Other Distributions]
Exhibit I, page 3
http://dos.elections.myflorida.com/cgi-bin/otherdis.exe
8/9/2016
Exhibit J, page 1
INVOICE
Invoicee No.
No.::
Invoic
Date:
185 US Highway 46, Fairfield, NJ 07004
03724444
12/04/15
Account Executive: Canola, Teresa
(973) 575-6900
CONTRACT
CT
CONTRA
NUMBER
Upon
pon R
Receip
eceiptt
Term: Due U
ER P.O
P.O././
CUSTOMER
CUSTOM
CONTRACT
CT NU
NUMBER
MBER
CONTRA
ACCOUNT
NT
ACCOU
NUMBER
R
NUMBE
2044171
1102149
JULIO DEL REY

191 VERA CT
CORAL GABLES
ADVERTISER:
ISER: JULIO DEL REY
ADVERT
FL 33143
BILLING
G PER
PERIOD
IOD
BILLIN
DESCRIPTION
PTION
DESCRI
AMOUNT
12/07/15 To
1/03/16
MIAMI - BUS EXTERIORS - SALES TAX
12/07/15 To
1/03/16
MIAMI - BUS EXTERIORS - KONGS W/EXTENSIONS
48.08
6,739.92
DUE::
TOTAL AMOUNT DUE
6,788.00
CORRESPONDENCE
NDENCE AND WHE
WHEN
N REMITTING
PLEASE REFER TO INVOICE NUMBER IN ANY CORRESPO
Page:
Detachh and
Please Detac
Payment
nt
Submit with Payme
Invoice No.:
Date:
03724444
12/04/15
Account No.:
1102149
Contract No.:
2044171
Due::
Total Amount Due
to::
Remit Payment to
JULIO DEL REY
191 VERA CT
CORAL GABLES
P.O. Box 33074
Newark, NJ 07188-0074
Exhibit J, page 2
account
nt at myout
myoutfront
frontmedia
media.com
.com
Manage your accou
FL 33143
6,788.00
INVOICE
Invoicee No.
No.::
Invoic
Date:
03743888
1/01/16
(973) 575-6900
CONTRACT
CT
CONTRA
NUMBER
Upon
pon R
Receip
eceiptt
Term: Due U
CUSTOMER
ER P.O
P.O././
CUSTOM
CONTRACT
CT NU
NUMBER
MBER
CONTRA
ACCOUNT
NT
ACCOU
NUMBER
R
NUMBE
2044171
1102149
JULIO DEL REY

191 VERA CT
CORAL GABLES
ADVERTISER:
ISER: JULIO DEL REY
ADVERT
FL 33143
BILLING
G PER
PERIOD
IOD
BILLIN
DESCRIPTION
PTION
DESCRI
AMOUNT
1/04/16 To
1/31/16
1/04/16 To
1/31/16
48.08
6,739.92
DUE::
TOTAL AMOUNT DUE
6,788.00
CORRESPONDENCE
NDENCE AND WHE
WHEN
N REMITTING
Page:
Detachh and
Please Detac
Payment
nt
Submit with Payme
Invoice No.:
03743888
Account No.:
1102149
Date:
1/01/16
Contract No.:
2044171
Due::
Total Amount Due
to::
Remit Payment to
JULIO DEL REY
191 VERA CT
CORAL GABLES
P.O. Box 33074
Newark, NJ 07188-0074
Exhibit J, page 3
account
nt at myout
myoutfront
frontmedia
media.com
.com
Manage your accou
FL 33143
6,788.00
INVOICE
Invoicee No.
No.::
Invoic
Date:
03768848
2/01/16
(973) 575-6900
CONTRACT
CT
CONTRA
NUMBER
Upon
pon R
Receip
eceiptt
Term: Due U
CUSTOMER
ER P.O
P.O././
CUSTOM
CONTRACT
CT NU
NUMBER
MBER
CONTRA
ACCOUNT
NT
ACCOU
NUMBER
R
NUMBE
2044171
1102149
JULIO DEL REY

191 VERA CT
CORAL GABLES
ADVERTISER:
ISER: JULIO DEL REY
ADVERT
FL 33143
BILLING
G PER
PERIOD
IOD
BILLIN
DESCRIPTION
PTION
DESCRI
AMOUNT
2/01/16 To
2/28/16
2/01/16 To
2/28/16
48.08
6,739.92
DUE::
TOTAL AMOUNT DUE
6,788.00
CORRESPONDENCE
NDENCE AND WHE
WHEN
N REMITTING
Page:
Detachh and
Please Detac
Payment
nt
Submit with Payme
Invoice No.:
03768848
Account No.:
1102149
Date:
2/01/16
Contract No.:
2044171
Due::
Total Amount Due
to::
Remit Payment to
JULIO DEL REY
191 VERA CT
CORAL GABLES
P.O. Box 33074
Newark, NJ 07188-0074
Exhibit J, page 4
account
nt at myout
myoutfront
frontmedia
media.com
.com
Manage your accou
FL 33143
6,788.00
INVOICE
Invoicee No.
No.::
Invoic
Date:
03768849
2/01/16
(973) 575-6900
CONTRACT
CT
CONTRA
NUMBER
Upon
pon R
Receip
eceiptt
Term: Due U
CUSTOMER
ER P.O
P.O././
CUSTOM
CONTRACT
CT NU
NUMBER
MBER
CONTRA
ACCOUNT
NT
ACCOU
NUMBER
R
NUMBE
2044171
1102149
JULIO DEL REY

191 VERA CT
CORAL GABLES
ADVERTISER:
ISER: JULIO DEL REY
ADVERT
FL 33143
BILLING
G PER
PERIOD
IOD
BILLIN
DESCRIPTION
PTION
DESCRI
AMOUNT
2/29/16 To
3/27/16
2/29/16 To
3/27/16
48.08
6,739.92
DUE::
TOTAL AMOUNT DUE
6,788.00
CORRESPONDENCE
NDENCE AND WHE
WHEN
N REMITTING
Page:
Detachh and
Please Detac
Payment
nt
Submit with Payme
Invoice No.:
03768849
Account No.:
1102149
Date:
2/01/16
Contract No.:
2044171
Due::
Total Amount Due
to::
Remit Payment to
JULIO DEL REY
191 VERA CT
CORAL GABLES
P.O. Box 33074
Newark, NJ 07188-0074
Exhibit J, page 5
account
nt at myout
myoutfront
frontmedia
media.com
.com
Manage your accou
FL 33143
6,788.00
INVOICE
Invoicee No.
No.::
Invoic
Date:
03790383
3/01/16
(973) 575-6900
CONTRACT
CT
CONTRA
NUMBER
Upon
pon R
Receip
eceiptt
Term: Due U
CUSTOMER
ER P.O
P.O././
CUSTOM
CONTRACT
CT NU
NUMBER
MBER
CONTRA
ACCOUNT
NT
ACCOU
NUMBER
R
NUMBE
2044171
1102149
JULIO DEL REY

191 VERA CT
CORAL GABLES
ADVERTISER:
ISER: JULIO DEL REY
ADVERT
FL 33143
BILLING
G PER
PERIOD
IOD
BILLIN
DESCRIPTION
PTION
DESCRI
AMOUNT
3/28/16 To
4/24/16
3/28/16 To
4/24/16
48.08
6,739.92
DUE::
TOTAL AMOUNT DUE
6,788.00
CORRESPONDENCE
NDENCE AND WHE
WHEN
N REMITTING
Page:
Detachh and
Please Detac
Payment
nt
Submit with Payme
Invoice No.:
03790383
Account No.:
1102149
Date:
3/01/16
Contract No.:
2044171
Due::
Total Amount Due
to::
Remit Payment to
JULIO DEL REY
191 VERA CT
CORAL GABLES
P.O. Box 33074
Newark, NJ 07188-0074
Exhibit J, page 6
account
nt at myout
myoutfront
frontmedia
media.com
.com
Manage your accou
FL 33143
6,788.00
INVOICE
Invoicee No.
No.::
Invoic
Date:
03812673
4/01/16
(973) 575-6900
CONTRACT
CT
CONTRA
NUMBER
Upon
pon R
Receip
eceiptt
Term: Due U
CUSTOMER
ER P.O
P.O././
CUSTOM
CONTRACT
CT NU
NUMBER
MBER
CONTRA
ACCOUNT
NT
ACCOU
NUMBER
R
NUMBE
2044171
1102149
JULIO DEL REY

191 VERA CT
CORAL GABLES
ADVERTISER:
ISER: JULIO DEL REY
ADVERT
FL 33143
BILLING
G PER
PERIOD
IOD
BILLIN
DESCRIPTION
PTION
DESCRI
AMOUNT
4/25/16 To
5/22/16
4/25/16 To
5/22/16
48.08
6,739.92
DUE::
TOTAL AMOUNT DUE
6,788.00
CORRESPONDENCE
NDENCE AND WHE
WHEN
N REMITTING
Page:
Detachh and
Please Detac
Payment
nt
Submit with Payme
Invoice No.:
03812673
Account No.:
1102149
Date:
4/01/16
Contract No.:
2044171
Due::
Total Amount Due
to::
Remit Payment to
JULIO DEL REY
191 VERA CT
CORAL GABLES
P.O. Box 33074
Newark, NJ 07188-0074
Exhibit J, page 7
account
nt at myout
myoutfront
frontmedia
media.com
.com
Manage your accou
FL 33143
6,788.00
Exhibit J, page 8
Exhibit J, page 9
Exhibit J, page 10
Exhibit J, page 11
Exhibit J, page 12
Exhibit J, page 13
Exhibit J, page 14
Exhibit J, page 15
Exhibit J, page 16
Prog-id:BLRP28
Page No:
1
11 02149
OUTFRONT Media
ACCOUNT STATEMENT
From-Cycle: 12/15 To-Cycle: 08/16
Julio Del Rey

191 Vera Ct
Coral Gables
Last Payment Date:
03724444 12/04/15 30428
03743888 01/01/16 30428
03768848 02/01/16 30428
03768849 02/01/16 30428
03790383 03/01/16 30428
03812673 04/01/16 30428
7/22/16
FL 33143
Invoice Invoice Order Contract

-Billing Period-- Batch
No.
Date
No.
No.
Fac
Med
Date
Date
No.
-------- -------- ------ -------- ------- --- -------- -------- -----03724175 12/03/15 28877
Date 08/04/16
Time:11:55:03
2052019
2044171
2044171
2044171
2044171
2044171
2044171
Invoice
Check
Payment
Amount
No.
Date
------------ -------- --------
M23 001 PRD 12/07/15 12/07/15 PK97X5

PY45ZR
M23 001 PRD 12/07/15 12/07/15 PK97X5
PY45ZR
M23 003 PRD 12/07/15 12/07/15 PK97X5
PY45ZR
M23 003 PRD 12/07/15 12/07/15 PK97X5
PY45ZR
1,265.00
749 001 TAX 12/07/15 01/03/16 PK97X9

PY45ZR
749 001 485 12/07/15 01/03/16 PK97X9
PY45ZR
48.08
749 001 TAX 01/04/16 01/31/16 ME13TZ

PY46EM
749 001 485 01/04/16 01/31/16 ME13TZ
PY46EM
749 001 TAX 02/01/16 02/28/16 ME13T5
PY46QI
749 001 485 02/01/16 02/28/16 ME13T5
PY46QI
749 001 TAX 02/29/16 03/27/16 ME13T5
PY464O
749 001 485 02/29/16 03/27/16 ME13T5
PY464O
749 001 TAX 03/28/16 04/24/16 ME13UB
PY47A1
749 001 485 03/28/16 04/24/16 ME13UB
PY47A1
749 001 TAX 04/25/16 05/22/16 ME13UH
PY47UX
749 001 485 04/25/16 05/22/16 ME13UH
PY47UX
Check
Amount
-----------
1757
12/21/15
1,265.00
1757
12/21/15
88.55
1757
12/21/15
300.00
1757
12/21/15
21.00
1756
12/21/15
48.08
1756
12/21/15
6,739.92
1577
01/20/16
48.08
1577
01/20/16
6,739.92
1592
02/18/16
48.08
1592
02/18/16
6,739.92
1609
03/18/16
48.08
1609
03/18/16
6,739.92
1614
03/30/16
48.08
1614
03/30/16
6,739.92
1627
05/16/16
48.08
1627
05/16/16
6,739.92
Invoice
Balance
-----------
88.55
300.00
21.00
.00
6,739.92
.00
48.08
6,739.92
.00
48.08
6,739.92
.00
48.08
6,739.92
.00
48.08
6,739.92
.00
48.08
6,739.92
Exhibit J, page 17
.00
Prog-id:BLRP28
Page No:
2
11 02149
OUTFRONT Media
ACCOUNT STATEMENT
From-Cycle: 12/15 To-Cycle: 08/16
Julio Del Rey
Last Payment Date:
Invoice Invoice Order Contract

-Billing Period-- Batch
No.
Date
No.
No.
Fac
Med
Date
Date
No.
-------- -------- ------ -------- ------- --- -------- -------- -----03844604 05/25/16 30430
03860327 06/01/16 30430
03869884 06/30/16 30871
03882986 07/01/16 30430
03905964 08/01/16 30430
2044171B 749 001 TAX 05/23/16 06/19/16 PK98AL

PY48EW
749 001 485 05/23/16 06/19/16 PK98AL
PY48EW
2044171B 749 001 TAX 06/20/16 07/17/16 ME13UT
PY48QV
749 001 485 06/20/16 07/17/16 ME13UT
PY48QV
2198769
Date 08/04/16
Time:11:55:03
7/22/16
Invoice
Check
Payment
Amount
No.
Date
------------ -------- --------
Check
Amount
-----------
Invoice
Balance
-----------
48.08
1129
06/25/16
48.08
1129
06/25/16
12,364.92
1645
07/22/16
48.08
1645
07/22/16
12,364.92
12,364.92
.00
48.08
12,364.92
.00
M23 003 INS 06/22/16 06/22/16 PK98C2

M23 003 PRD 06/22/16 06/22/16 PK98C2
M23 003 PRD 06/22/16 06/22/16 PK98C2
250.00
300.00
21.00
571.00
2044171B 749 001 TAX 07/18/16 08/14/16 ME13UZ

749 001 485 07/18/16 08/14/16 ME13UZ
48.08
12,364.92
12,413.00
2044171B 749 001 TAX 08/15/16 09/11/16 ME13U5

749 001 485 08/15/16 09/11/16 ME13U5
48.08
12,364.92
12,413.00
Account Balance for 11 02149
92,625.55
=============
Exhibit J, page 18
67,228.55
=============
25,397.00
=============

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Complaint Filed 8-10-2016 PDF

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Complaint Filed 8-10-2016 PDF

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Filing # 45025402 E-Filed 08/10/2016 12:32:17 AM

IN THE CIRCUIT COURT OF THE

This is a complaint for declaratory and injunctive relief.

Jason Bloch v. Marcia Del Rey, et al.

Plaintiff JASON BLOCH (Bloch) is a candidate for the position of

Defendant MARCIA DEL REY (Del Rey) is a candidate for the

STANDUP TO VIOLENCE is an Electioneering Communications

Organization (ECO) organized under the laws of Florida.

JORGE ALBERTO BALLESTE is the Chairperson of Stand Up to

Defendant CHRISTINA WHITE (Supervisor of Elections) is the

Supervisor of Elections of Miami-Dade County, Florida, and is responsible for

Defendant KEN DETZNER (Secretary of State) is the Secretary of

Section 8, Article II of the Florida Constitution requires a candidate

Jason Bloch v. Marcia Del Rey, et al.

At the time she purportedly qualified for judicial office on May 3,

The Form 6 filed by Defendant Del Rey is materially deficient in

several constitutional aspects. First, although every judicial candidate seeking

Jason Bloch v. Marcia Del Rey, et al.

Second, compliance with the constitutional financial disclosure

requirement obligates a candidate to disclose each source of the candidates

Jason Bloch v. Marcia Del Rey, et al.

source of the income. That affirmative and material omission is improper,

public financial disclosure requirement, she is not constitutionally qualified to seek

Defendant Del Reys campaign materials assert she is an advocate for

Defendant Del Rey disclosed in her Form 6 Financial Disclosure

(previously identified as Exhibit A) that she is a 33% owner of Tropic Gardens

Jason Bloch v. Marcia Del Rey, et al.

Defendant Del Reys financial disclosure information, by not

Defendant Del Reys material misstatements and omissions are part

and parcel of a purposeful effort to mislead the public as to matters required to be

Jason Bloch v. Marcia Del Rey, et al.

Documents (attached as Exhibit E) establish Defendant Del Rey was

Jason Bloch v. Marcia Del Rey, et al.

Because Defendant Del Rey is not properly qualified as a candidate for

This complaint is submitted in advance of the August 30, 2016,

election, and is based upon factual information demonstrating her lack of

In addition, Defendant Del Rey has been the beneficiary of many

thousands of dollars in advertising by an Electioneering Communications

Jason Bloch v. Marcia Del Rey, et al.

Perhaps even more indicative of Defendant Del Reys total disregard

Further, Defendant Del Rey is engaged in a secretive financial scheme

Jason Bloch v. Marcia Del Rey, et al.

This entire matter is appropriate to be advanced on the calendar for

Plaintiff repeats and re-alleges Paragraphs 1 through 25, all of which

are incorporated herein by reference.

The Plaintiff is in doubt as to his right, title, status, or interest as to his

This is a material and legitimate concern that requires a judicial

Jason Bloch v. Marcia Del Rey, et al.

Plaintiff is entitled to a judicial declaration as to his rights, title, status,

or interest, declaring that Defendant Del Rey is not constitutionally qualified to be

Plaintiff repeats and re-alleges Paragraphs 1 through 25, all of which

are incorporated herein by reference.

Plaintiff is entitled to the entry of a temporary and permanent

Plaintiff is entitled to the entry of a temporary and permanent

Plaintiff is entitled to immediate entry of a temporary and permanent

Jason Bloch v. Marcia Del Rey, et al.

Plaintiff repeats and re-alleges Paragraphs 1 through 25, all of which

are incorporated herein by reference.

The activities of the ECO, by engaging in express advocacy, are

contrary to law and cannot be permitted to continue.

Plaintiff is entitled to the entry of a temporary and permanent

injunction prohibiting Stand Up to Violence, and its chairperson, Jorge Alberto