Defendants Notice of Filing Marion County Jail Complaint

Filing # 188620887 E-Filed 12/23/2023 09:51:27 PM
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT

IN AND FOR MARION COUNTY, FLORIDA
STATE OF FLORIDA,
Plaintiff, CASE NO. 2019-CF-4193
vs. CASE NO. 2020-CF-2417
CASE NO. 2021-CF-0286
NEIL JOSEPH GILLESPIE, CASE NO. 2022-CF-1143
Defendant.
__________________________________/
DEFENDANT’S NOTICE OF FILING MARION COUNTY JAIL COMPLAINT
Defendant NEIL JOSEPH GILLESPIE, a nonlawyer reluctantly appearing pro se, gives
Notice of Filing Marion County Jail Complaint, and states:
1. The Defendant was held in the Marion County Jail in the above captioned cases.
2. The Marion County Jail (MCJ) is a jail owned and operated by the Marion County
Sheriff’s Office (MCSO) in Marion County, Florida, at 3290 NW 10th St., Ocala, FL 34475.
3. Marion County Sheriff Billy Woods was and is the elected Sheriff of Marion County,
Florida. As the constitutional officer elected in accordance with Chapter 30, Florida Statutes, and
Article VIII, section 1, of the Florida Constitution, Sheriff Woods is tasked with implementing,
ratifying, and approving the policies and practices of the MCSO. Sheriff Billy Woods and/or his
subordinates were at all times the final policymakers for MCSO with respect to the MCJ.
4. Sheriff Woods and the MCSO had custody and control of the Defendant in the MCJ, by
and through its employees and agents. Sheriff Woods and the MCSO acted under the color of
law in the operation of the MCJ and in the custody and control of the Defendant.
5. To hold someone in custody means removing their autonomy. The jailer has exclusive
control over the welfare of the person and is therefore exclusively responsible for the conditions
in which the inmate is held.

6. The MCJ is divided into pods. Each pod is divided into four housing units. Each pod
includes a “rover area,” in which officers are staffed to surveil the housing units in the pod.
7. The Defendant was held as Inmate ID A0255941 in the Medical Pod housing unit known
as Med B for inmates with physical disabilities. The Medical Pod had a housing unit for inmates
with psychological disorders called Med C. The Medical Pod housing units consisted of open
dorms with approximately 67 inmates in Med B, and perhaps 100 inmates in Med-C, each in a
single cavernous room. The inmates in Med B and Med C were locked in the cavernous rooms
by themselves without any guards present, and without direct supervision by the MCJ. This was
an extremely dangerous situation in Med C which was essentially a psychiatric ward.
8. Frequent fights in the Med C psychiatric ward resulted in transfers of dangerous inmates
into the Med B housing unit for inmates with physical disabilities, many of whom were elderly.
9. The Medical Pod also had two suicide protection (SP) housing units, one for male
inmates, and one for female inmates. The SP housing units consisted of locked cells designed for
3 inmates each, but were often overcrowded with 5-6 inmates in each cell. The SP inmates were
required to wear an anti-suicide smock called a “turtle suit”. Each SP housing unit was staffed
with one guard, called a detention deputy or officer, seated on a raised pedestal desk in the unit.
10. Approximately 250 inmates were housed in the Medical Pod at any given time,
but the rover area was typically staffed with only two officers. Guards who were tasked
with supervising pods in the rover’s area had other duties as well, such as picking up
trays from the kitchen for the pod. When one guard would engage in those other tasks,
there would be only one guard left in the rover area to indirectly supervise inmates held
in multiple open dorm style, single cavernous room housing units in the pod.
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11. Trustees are inmates in the MCJ with special privileges who help guards with
various tasks around the jail. Guards in the rover’s area often spent time joking around
with each other or the trustees rather than supervising inmates, and engaging in
unprofessional behavior such as watching YouTube videos when they were supposed to
be surveilling the open dorm housing units. Guards in the Medical Pod rover’s area were
distracted by their computers or other tasks.
12. Public records provided by the MCSO show the MCJ uses AI, Artificial Intelligence, to
provide inmate security through innoVi Genetec Integration, further identified as innoVi by
Agent Vi, Comprehensive AI-Powered Video Analytics, version 30-Nov-2021. Purchase
requisition no. 14227, July 14, 2011 for two Genetec camera licenses shows the Genetec system
has been in use by the jail for about 12 years. Agent Video Intelligence (Agent Vi) is owned by
Irisity AB. Irisity AB is a company headquartered in Israel.
13. Information about innoVi Genetec Integration by Agent Vi is available online.
Essentially, innoVi by Agent Vi uses video cameras to collect images, which images are called
events. The events are evaluated by analytics using proprietary artificial intelligence algorithms.
Custom event rule types can be established, such as Moving in an Area and Crossing a Line, and
then detected, e.g., Person Moving detected, which enable alarms to be received in the Genetec
Security Desk, and viewed on a monitor by a human, a detention deputy in a rover area.
When: Analytics Event - Person Moving Occurs

From: Any entity
Action: Trigger alarm
Alarm: Moving Person detected
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14. MCSO detention deputies are tasked with inmate security in the MCJ. The Defendant
provided a complaint to MCSO General Counsel Timothy McCourt dated June 8, 2023 showing
a lack of adequate security for inmates in the MCJ. The complaint appears in Appendix 1.
15. The complaint appearing at Appendix 1 shows the MCJ failed to protect the Defendant
from Priness Remyre-Antonia Fields, inmate A0078654, who threatened to kill him because he
witnessed Fields take a food tray from Inmate Joseph Gosik. The Defendant provided evidence
that Inmate Fields was arrested and incarcerated 27 times in the MCJ. Inmate Fields had
previously been assigned to Med C, the psychiatric ward, but was later wrongly transferred to
Med B. The complaint also alleged the MJC failed to protect other inmates due to failures by
detention deputies, and the failed AI security system.
16. On July 7, 2023 the Defendant filed Defendant’s Notice of Prosecutorial Misconduct in
case no. 2022-CF-1143 involving Inmate Fields, Filing # 178008132 E-Filed 07/21/2023
09:34:27 PM. The Notice included 186 pages of jail records for Inmate Fields provided by the
MCSO in response to a record request. The MCJ records show Inmate Fields’ history of mental
illness, his PREA violation against another inmate, additional offenses Inmate Fields committed
while held in the jail, and multiple Housing Movements Reports related to moving Inmate Fields
to other parts of the jail after his involvement in incidents with other inmates and/or detention
deputies. The most recent issue with Inmate Fields shown in the records occurred on April 9,
2022, resulting in his jailhouse conviction for battery on Deputy Tommy Frye, as well as
convictions for conduct which disrupts or interferes with jail security, and disobeying orders.
17. The Defendant’s Notice of Prosecutorial Misconduct also showed the State Attorney’s
Office knowingly failed to provide Brady Evidence for Inmate Fields required pursuant to Brady
v. Maryland, 373 U.S. 83 (1963).
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18. On December 12, 2023, the Defendant provided a complaint to MCSO General Counsel
Timothy McCourt with evidence that the failure of the MCJ to protect the Defendant from
Inmate Fields was due to retribution by MCJ detention deputies, including Corporal James, in
support of Deputy Suppes against whom the Defendant had made a PREA complaint.
19. The Defendant’s December 12, 2023 complaint to Mr. McCourt consists of 88 pages and
is attached to this Notice of Filing Marion County Jail Complaint.
20. The Defendant’s December 12, 2023 complaint shows that on February 22, 2022 he
made a complaint against Detention Deputy Rebecca Suppes, ID #6519, under PREA, the Prison
Rape Elimination Act, while he was held as Inmate A0255941 in the MCJ.
21. The Defendant provided his affidavit showing the jail failed to contact his witness, Raul
Lopez, Inmate ID A0254371. A letter dated March 30, 2022 from PREA Coordinator M. Carter
stated in part, “After reviewing all witnesses and video evidence your PREA complaint that was
investigated on February 22, 2022, it has been determined that it does not rise to the level of
PREA sexual harassment.” Under PREA, the misconduct by Deputy Suppes was voyeurism.
22. MCJ Officer Isai Palau, ID 5563 investigated the Defendant’s PREA complaint against
Deputy Suppes. A transcript of the Defendant’s interview with Officer Palau shows he also
complained that earlier in the same shift, Deputy Suppes, and her fellow deputies on duty, failed
to respond to an incident by Yandel Andino, Inmate ID A0262030 with another inmate n.k.a.
Christopher Simmons, Inmate ID A0090737. Inmate Simmons later told the Defendant that the
incident began when Andino stabbed Simmons with a makeshift tattoo needle. A transcript of the
Defendant’s interview with Officer Palau shows he also complained that the jail failed to protect
Steven Plaza, Inmate ID A0259320, who was severely beaten.
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23. A rumor in the MCJ among inmates sought to explain why Deputy Suppes was hostile
toward male inmates. According to the rumor, Suppes was upset over a divorce. Upon release,
the Defendant learned that Suppes is “still hitched” according to her public Facebook page that
glorifies bank robbery.
https://m.facebook.com/people/Rebecca-Suppes/100080107702135/
24. MCJ Detention Deputy Rebecca Suppes, ID 6519, appears in the photo above, second
from the right, holding a “still hitched” sign. Her husband Timothy Suppes is first from the right,
and they are holding hands. Timothy Suppes appears to holding a Thompson sub-machine gun in
his other hand. The woman to Deputy Suppes’ left, name unknown, appears to be holding a
sawed-off shotgun, and a bag with a large dollar sign on it ($). The other man, name unknown,
fourth from right, appears to be holding a Thompson sub-machine gun. There are a number of
other photo images on the public Facebook page of Deputy Suppes, including the two below.
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Deputy Suppes’ public Facebook page

shows a number of images of the MCSO,
other officers, and personal photos, such
as the “crazy face” image of Rebecca
Suppes appearing on the left.
These images may affect the reputation

and integrity of the Marion County Jail,
and the Marion County Sheriff’s Office.
25. The Defendant’s Dec-12-2023 complaint to Mr. McCourt provided this table of contents:
Section/Page TABLE OF CONTENTS
I/3 PREA Incident February 22, 2022 with Deputy Rebecca Suppes, ID #6519
II/5 Failure to provide adequate storage for inmate legal papers
III/10 Fire risk in the Marion County Jail, Ocala, Florida
IV/11 Inmate security in the Bucks County Jail, Doylestown, Pennsylvania
V/15 Stabbing of Christopher Simmons, Inmate ID A0090737
VI/18 Beating of Steven Plaza, Inmate ID A0259320
VII/18 Battery on Robert McGuinness, Inmate ID A0220591
VIII/20 Suicide attempt by Kenneth Clark, Inmate ID A0219592
IX/20 Death of Cory P. Merchant, Inmate ID A0092328
X/23 Reported statement of Oren Miller, Inmate ID A0267181
XI/24 Merchant v. Woods et al, USDC, MDFL, Ocala Div. 5:23-cv-00661-JSM-PRL
XII/24 Whitley v. Woods et al, USDC MDFL, Ocala Div. 5:23-cv-00684-JSM-PRL
XIII/25 Failure of Gov. Ron DeSantis to provide public records (also MCJ record issues)
XIV28 Conclusion
26. Section I of the complaint describes the PREA Incident February 22, 2022 with Suppes.
On February 22, 2022 I awoke around 3:00 AM to a commotion in Med B pod involving
Deputy Rebecca Suppes, ID #6519, and other inmates, and noticed items missing that I
placed on my wheelchair before going so sleep. The items were a jail uniform shirt and
pants, my ID name tag, a thermal top, socks, and a blanket. I was sleeping in my T-shirt
and boxer briefs. The missing items were placed on my wheelchair because my basket
was full of legal papers and there was no room for anything else. I did not have any items
hanging on my bunk, in compliance with the rules. I believe Deputy Suppes took my
missing items.
Officer Palau’s Incident report # 220000936 shows I stated in part that Deputy Suppes
“entered the section without giving an opposite gender announcement” and “Inmate
Gillespie stated he was sleeping in his underwear and that Deputy Suppes stood there
staring at him in his underwear. This made him feel uncomfortable and violated.” My
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witness Raul Lopez told me Suppes was staring at me in my underwear. Other inmates
told me the same. The entire pod was awake and other inmates were complaining about
items taken by Deputy Suppes.
A supplemental report by Deputy Suppes responds to my complaint about her removing

clothing placed on my wheelchair: “I then explained that I gave the section multiple
verbal orders to remove all hanging clothing due to inmate safety rules that he could find
on page 11 of the Inmate handbook.” Page 11 of the handbook I found online, Revised:
December 2017, only pertains to visitation.
Page 12, Paragraph 14 Personal Items, states: “Personal items shall be neatly arranged.
Attaching anything to any surface is prohibited. This includes windows, doors, walls,
vents. Writing or drawing on any surface will not be tolerated. All personal items are to
be contained in the basket provided during the Booking process.” As previously noted,
the basket was not adequate to contain all my personal item and my legal papers.
Regarding “hanging clothing due to inmate safety”, I understand that pertains to hanging
clothing on two level bunk beds that would obstruct the view during a security check.
However, in the Med B pod, the bunks are singles, so any hanging clothing would not
obstruct a security check. While the rule does not differentiate between two level bunk
beds and single beds, in Med B this is not an inmate safety issue. Instead, Deputy Suppes,
and certain other officers, appear to take joy in disrupting the inmates peaceful sleep at
night for their own gratification and sense of domination. Sleep is essential for survival.
Most other officers do not disrupt the pod by taking inmate clothing at 3:00 AM.
Prior to my PREA complaint, very few female officers made an opposite gender
announcement when entering Med B, a male medical pod. The rule, PREA Operational
Directive 6603(E)([§115.15 (5), was ignored with impunity by most female deputies.
That changed after my complaint. But making a verbal opposite gender announcement is
not likely to be heard throughout the pod. Officer Palau’s report concluded, “This
Complaint does not rise to the level of PREA sexual harrassment (sic).” I agree, it is not
sexual harassment. Under the PREA rules it is considered voyeurism, a fact I learned
after watching a PREA video on the kiosk.
I sent a jail Emessage to Gary Lashley, Esq., my court-appointed lawyer, about the PREA
complaint but he did not respond.
The bigger issue is the failure of Deputy Suppes, and other officers, to respond to
violence in the pod, a failure of the jail to protect inmates, and the failure of the Artificial
Intelligence security provided through innoVi Genetec Integration.
Tellingly, Officer Palau’s report does not mention that earlier in the same shift Deputy
Suppes failed to respond to an incident by Yandel Andino, Inmate ID A0262030 with an
inmate n.k.a. Christopher Simmons, Inmate ID A0090737. Inmate Simmons later told me
the incident began when Andino stabbed Simmons with a makeshift tattoo needle. A
transcript of my interview with Officer Palau shows I also complained that the jail failed
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to protect Steven Plaza, Inmate ID A0259320, who was severely beaten. Those
complaints are now provided.
Retribution by officers is also a problem in the Marion County Sheriff’s Office. My

former court-appointed lawyer, Zachary Phipps, said my arrest in case 2020CF2417 was
retribution by the MCSO, and an abuse of discretion by the State Attorney.
Enclosed is an Inmate Medical Request form addressed to Dr. Colon, the Medical
Director, date March 5, 2022 that states: (the date was altered by someone else to April 5,
2022)
Dr. Colon, I believe my blood pressure is up due to stress caused last night when
Officer James refused to send my U.S. Mail placed on the table for outgoing mail
at final count. I believe I am at risk of retribution and harm in the jail. [Note: My
witness to this event is Servando Ferguson, Sr.]
Clearly someone altered the date from March 5, 2022 to April 5, 2022. The Staff Section
shows disposition by “DC” on 4-5-22 time 0800, “released 4-7-22” and at the bottom the
date 4-8-22, with a signature I cannot decipher. Previously Corporal James did not assist
me when I told him Inmate Fields threatened to kill me over witnessing Fields take a
food tray from Inmate Gosik.
Officer Palau’s report also states that when I was in the infirmary [with Covid-19],
Deputy Suppes refused to send out my U.S. mail. Suppes refused to send my mail on two
consecutive days saying she was not going to let me spread Covid-19 outside the jail by
sending my “Covid infected mail” or words to that affect. This was legal mail related to
my Petition For Writ Of Habeas Corpus, case 5:21-cv-463, U.S. District Court, M.D.
Florida, Ocala Division, initially mailed September 11, 2021. I spoke with Dr. Colon in
the infirmary during her treatment of me for Covid-19. Dr. Colon told me Covid is not
spread by mail. I also made a written complaint on an Inmate Request Form about Depuy
Suppes’ refusal to send my mail.
Officer Palau’s report also states “She had also refused to forward his legal documents to
the law library to be copied. Inmate Gillespie stated Deputy Suppes would tear apart his
documents and threw them everywhere. He stated that "it seemed like she's on drugs.
Totally nuts”. I also made a written complaint on an Inmate Request Form about Deputy
Suppes and the copy request issue.
Eventually the jail responded to both of my written complaints saying Deputy Suppes
was counseled on the procedure for mail and law library copies.
27. Section II of the complaint describes a failure of the MCJ to provide adequate storage for
inmate legal papers. The complaint states in part:
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On February 22, 2022 my basket was full of legal papers and there was no room for
anything else. The jail failed to provide enough storage space for my legal papers. The
basket provided by the jail is a cheap, flimsy, laundry basket, with rough edges on the
sides. I once cut my right hand while reaching into the basket, which was jammed full of
legal papers. The jail failed to treat my injured hand until after it got infected. In contrast,
the Bucks County, PA, jail provided every inmate with a sturdy plastic bin, with solid
sides, and a large enough size to hold all my legal papers, spare clothing, and commissary
items.
28. Section II of the complaint shows on February 28, 2022 Deputy Suppes created Incident
Report #220001008 about the Defendant’s storage of his legal papers. Section II is about 5 pages
long, and shows the Defendant had a lot of legal paperwork for his cases, including:
Gillespie v. State of Florida, Constitutional Challenge to Fla. Stat. 934.03, U.S. District
Court, Middle District of Florida, Ocala Div., Case No. 5:21-cv-416-PGB-PRL
Gillespie v. Sheriff Billy Woods, Petition for Writ of Habeas Corpus, U.S. District Court,
Middle District of Florida, Ocala Div., Case No. 5:21-cv-463-WWB-PRL
Gillespie v. Marion County Jail, Petition for Writ of Habeas Corpus, U.S. District Court,
Middle District of Florida, Ocala Div., Case No. 5:22-cv-37-RBD-PRL
Gillespie v. Sheriff Billy Woods, Petition for Writ of Habeas Corpus, Florida Supreme
Court, Case No. SC21-1657
Gillespie v. Federal National Mortgage Association (FNMA) a.k.a. Fannie Mae,

Marion County Circuit Court, Case No. 2021-CA-2179 (Ejectment action)
And many cases in the Florida Fifth District Court of Appeal, civil and criminal.
29. Section III of the complaint describes the fire risk in the MCJ, and begins:
Incident Report #220001008 by Deputy Suppes states in part:
On February 27, 2022, I was assigned to Medical Pod, At 10:12 PM I was present
in Medical Pod Bravo Section, At this time, I removed Inmate Neil Gillespie's
Mattress due to him having an excessive number of Envelopes underneath his
mattress covering his entire bunk creating a fire hazard.
As noted previously, the excessive number of “Envelopes” cited by Deputy Suppes are in
fact large manila envelopes that I purchased from the jail and used as a filing system for
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my legal paperwork. While paper is flammable, it is not subject to spontaneous

combustion.
The primary fire risk in the Marion County Jail is the lack of meaningful supervision of
inmates...
Section III of the complaint to Mr. McCourt shows in detail how inmates successfully started a
fire to cook drugs in full view of the security cameras, where no officers were present. The
complaint also describes an alleged fire where inmates disassembled tablet a computer provided
by Securus Technologies. Apparently no officers were present to prevent this fire.
30. Section IV of the complaint describes direct supervision inmate security in the Bucks
County Jail, Doylestown, Pennsylvania. The complaint states in part:
The Bucks County Jail in Doylestown, Pennsylvania serves as the countywide central
receiving location for all persons committed to the system as either pre-trial detainees or
convicted prisoners. Annually, the facility receives over 7432 prisoners. Medium and
maximum-security classified inmates are housed at this facility. The facility has 10
modular living units utilizing a direct supervision philosophy while providing programs
for the treatment and education of the inmate population.
The facility was designed and built to be operated using a direct supervision philosophy.
This methodology has corrections officers in direct contact and observation with the
inmates throughout the facility. This is important because to hold someone in custody
means removing their autonomy. The jailer has exclusive control over the welfare of the
person and is therefore exclusively responsible for the conditions in which the inmate is
held.
The Bucks County Jail employs professional Corrections Officers who work for the
Department of Corrections. The Marion County Jail employs “Detention Deputies” who
work for Sheriff Billy Woods. This arrangement creates a conflict of interest with the
Marion County Sheriff’s Office, because the jailers and the arresting officers work for the
same law enforcement agency.
Good security is the backbone of any correctional facility. Bucks County Jail Corrections
Officers directly monitor inmates 24 hours a day, 365 days a year. Direct supervision by
officers, sergeants and lieutenants assure that the security and safety needs are met and
that the operational plan of the day is followed.
31. Section V of the complaint describes the stabbing of Inmate Christopher Simmons.
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32. Section VI of the complaint describes the beating of Inmate Steven Plaza.
33. Section VII of the complaint describes a battery on Inmate Robert McGuinness.
34. Section VIII of the complaint describes a suicide attempt by Inmate Kenneth Clark.
35. Section IX of the complaint describes the death of Inmate Cory P. Merchant. The
Defendant was held in the MCJ on November 7, 2021 when Inmate Merchant was fatally
injured. Also present was Inmate Conrad Degon, age 67, a retired law enforcement officer
who’s obituary states he was awarded the New York State Medal of Honor for bravery. Inmate
Degon was in the MCJ infirmary on November 7, 2021 when Cory Merchant was brought in
after being fatally injured. Inmate Degon’s statement before he died to the Defendant about Cory
Merchant alleges Merchant was dead before he left the MCJ on November 7, 2021, contrary to
news reports.
36. Section X of the complaint describes a statement of Oren Miller, Inmate ID A0267181
quoted in a news story February 5, 2023 by Ryan Grim of The Intercept about his time in the
MCJ, see, https://theintercept.com/2023/02/05/ron-desantis-florida-villages-oren-miller/ Inmate
Oren Miller, age 72, was held in the Marion County jail for 74 days, from November 18, 2022 to
January 30, 2023. On November 9, 2023, the Fifth District Court of Appeal overturned Miller’s
jury trial conviction, see Oren Miller v. State of Florida, Case No. 5D23-0846, LT Case No.
2021-CF-4602-A. In its Order, the 5th DCA instructed the trial court to enter a judgment of not
guilty in favor of Miller. The Intercept published Oren Miller’s statement on February 5, 2023:
The last 74 days had been an ordeal. There are about 1,800 people in the county’s lockup
facility; Miller was in a pod with 80, he said, but there were just 56 seats for meals. On
his first day, a jailmate offered to adopt him and get him a seat at meals in exchange for
some of his food, a bargain he eagerly accepted. On the second day, he said, he won
protection from a gang leader. “Oren Miller, you are protected in here because you’re a
senior citizen,” the man said, according to Miller. “‘But understand, don’t cross any
lines.’ … And so I minded my p’s and q’s.” Violence broke out regularly, Miller
recounted, and he watched two men beaten nearly to death. He moved to try to break up
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the first fight, but two men held him back, explaining that if he got involved, he’d be
called later as a witness, and you don’t want to be a witness against somebody who
sleeps in the same open room as you. So he let them fight.
Miller went days without his heart or thyroid medication, and grew weak and dizzy.
Complaining of chest pain, he was eventually given an EKG, which the staff told him
showed no problems. “My EKG hasn’t been good in 15 years,” he said. “I will never
have a good EKG. I’ve got an irregular heartbeat all the time.” He said they gave him
medication despite claiming to detect no heart trouble — the same type of heart
medication he’d been prescribed but hadn’t been getting.
His logistics training from Caterpillar came in handy, and he devised a system for the
headcount process which worked so well that the unit’s numbers were correct more often,
meaning they rarely got punished for the wrong count anymore. He could see the guard
coming from a neighboring unit, and Miller would yell “Headcount!”: a signal for the
men to move to the predesignated places to be counted. He taught his jailmates how to
document abuse and negligence when it occurred, so that if they later filed a complaint,
they’d have something to stand it up. When he left the unit for what he hoped would be
the last time, he turned around and yelled to the men: “Headcount!”
They all shouted back: “Headcount!”
37. Section XI of the complaint cites to Merchant v. Woods et al, USDC, MDFL, Ocala Div.
5:23-cv-00661-JSM-PRL, a wrongful death lawsuit over the death of Inmate Cory Merchant. A
copy of the complaint in Merchant v. Woods et al appears in Appendix 2.
38. Section XII of the complaint cites to Whitley v. Woods et al, USDC MDFL, Ocala Div.
5:23-cv-00684-JSM-PRL, a wrongful death lawsuit over the death of Inmate Scott Whitley. A
copy of the complaint in Whitley v. Woods et al appears in Appendix 3.
39. Section XIII of the complaint describes the failure of Gov. Ron DeSantis to provide
public records (also MCJ record issues). Separately, on December 18, 2023, the Defendant
made a complaint to the Florida Department of Law Enforcement (FDLE) regarding Gov.
DeSantis’ violation of Florida’s pubic records law. The complaint appears in Appendix 4. The
Washington Post is suing to obtain Gov. DeSantis’ records and arguing that a new law limiting
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disclosure is unconstitutional. On December 13, 2023 the Washington Post published a story by
Beth Reinhard, “DeSantis staffers blocked release of travel records, whistleblower says”.
40 Section XIV of the complaint to Mr. McCourt, Conclusion, states:
My PREA complaint against Deputy Suppes led to retribution by deputies of the MCJ
who failed to protect me from Inmate Fields. My PREA complaint was supported by
evidence, and a witness. As set forth in my affidavit, the MCJ failed to contact my
witness, then “determined that it does not rise to the level of PREA sexual harassment.”
Under PREA, I believe the misconduct by Deputy Suppes is considered voyeurism.
The accompanying transcript of my interview with Officer Palau shows I also

complained that earlier in the same shift, Deputy Suppes, and other deputies on duty,
failed to respond to an incident by Inmate Yandel Andino with Inmate Christopher
Simmons, and that the jail failed to protect Inmate Steven Plaza who was severely beaten.
To hold someone in custody means removing their autonomy. The jailer has exclusive
control over the welfare of the person and is therefore exclusively responsible for the
conditions in which the inmate is held. Sheriff Woods is responsible for what is described
in this letter.
Separately, the Defendant provided an addendum letter to Sheriff Woods December 22, 2023.
RESPCTFULLY SUBMITTED December 23, 2023.
NEIL JOSEPH GILLESPIE, Defendant pro se

2801 SW College Rd. STE 3
Ocala, FL 34474-4430
Phone: 352-239-9037
Email: celticein@yahoo.com
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CERTIFICATE OF SERVICE
I hereby certify that on December 23, 2023 the foregoing was served on the Florida Portal to:
Rebecca Rock McGuigan, Bureau Chief State Attorney’s Office

Criminal Appeals Division, Daytona Beach 110 North West 1st Avenue
Office of the Attorney General Suite 5000
444 Seabreeze Blvd., Suite 500 Ocala, FL 34475
Daytona Beach, FL 32118 Eservicemarion@Sao5.Org
(386) 238-4990
E-mail: Rebecca.McGuigan@myfloridalegal.com
E-service: crimappdab@myfloridalegal.com
and to the names on the Florida Portal Notice of Service of Court Documents.
Neil Joseph Gillespie, Defendant pro se
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Sheriff Billy Woods December 22, 2023
Marion County Sheriff’s Office (MCSO)
PO Box 1987
Ocala, FL 34478-1987
RE: Deputy Rebecca Suppes, ID #6519
Sheriff Woods,
This is an addendum to my complaint of December 12, 2023 provided to Mr. Tim McCount,
MCSO General Counsel, who was appointed as Circuit Court Judge on December 21, 2023.
During my time in the Marion County Jail, the Medical Director, Ivette Colon-Reyes, MD, Heart
of Florida Healthcare, approved my use and possession of diabetic footwear, including diabetic
shoes and diabetic socks. In 2022, Deputy Rebecca Suppes took my diabetic socks during a
shakedown and did not return them to me. Raul Lopez, Inmate ID A0254371, witnessed Suppes
talking about diabetic socks while he was in the rovers area immediately after the shakedown.
According to Inmate Lopez, Deputy Suppes claimed my diabetic socks were just ordinary black
socks and therefore prohibited. Suppes told me the same explanation.
Attached to this letter is a representative image of the diabetic socks that Deputy Suppes took
from me, Dr. Scholl’s Diabetes & Circulatory ankle socks, black color.
The jail and/or Dr. Colon-Reyes, Heart of Florida Healthcare, provided me a pass for diabetic
footwear, including one pair of diabetic shoes and one pair of diabetic socks. The jail and/or Dr.
Colon-Reyes, Heart of Florida Healthcare, purchased one pair of diabetic shoes for me from
Lombardo's Comfort & Casual Shoes, 8530 SW Hwy 200, Ocala, FL 34481. Prior to that, I had a
pass to wear my own New Balance shoes and diabetic socks that I wore on the street. I am in the
process of locating a copy of the pass among the records provided to me by the jail, Heart of
Florida Healthcare, and my own records, perhaps over 1,000 pages to search.
Sincerely,
Neil J. Gillespie
2801 SW College Road, Suite 3
Ocala, Florida 34474
Tel: 352-239-9037
Cc: Brittany Colbert, Central Records Manager, S.T.A.R Manager, Marion County Sheriff’s
Office, bcolbert@marionso.com
Attachment/enclosure
Sheriff Billy Woods December 22, 2023
Marion County Sheriff’s Office
Representative image
Dr. Scholl’s Diabetes & Circulatory ankle socks as sold by Walmart in a package of 6 pair.
2
Timothy T. McCourt December 12, 2023
General Counsel
Florida Bar No. 44604
PO Box 1987
Ocala, FL 34478-1987
Tel. (352) 369-6758
RE: PREA Complaint; Ongoing Failure to Protect MCJ Inmates
Mr. McCourt:
On February 22, 2022 I made a complaint against Detention Deputy Rebecca Suppes, ID #6519,
under PREA, the Prison Rape Elimination Act, while I was held as Inmate #A0255941 in the
Marion County Jail (MCJ).
My enclosed affidavit shows the jail failed to contact my witness, Raul Lopez, Inmate ID
A0254371. A letter dated March 30, 2022 from PREA Coordinator M. Carter states in part,
“After reviewing all witnesses and video evidence your PREA complaint that was investigated
on February 22, 2022, it has been determined that it does not rise to the level of PREA sexual
harassment.” Under PREA, I believe the misconduct by Deputy Suppes is considered voyeurism.
On June 8, 2023, I provided you with a corrected complaint alleging that the jail failed to protect
me from Priness Remyre-Antonia Fields, inmate A0078654, who threatened to kill me because I
witnessed him take a food tray from Inmate Gosik. I provided you evidence that Inmate Fields
was arrested and incarcerated 27 times in the MCJ. My complaint also alleged the jail failed to
protect other inmates due to failures by detention deputies, and the failed AI security system.
On July 7, 2023 I filed Defendant’s Notice of Prosecutorial Misconduct in my case no. 2022-CF-
1143 involving Inmate Fields, see Filing # 178008132 E-Filed 07/21/2023 09:34:27 PM. My
Notice included my June 8, 2023 complaint to you, and 186 pages of jail records for Inmate
Fields provided by the jail in response to my record request. The jail records show Fields’
history of mental illness, a PREA violation against another inmate, additional offenses Fields
committed while held in the jail, and multiple Housing Movements Reports related to moving
Fields to other parts of the jail after his involvement in incidents with other inmates and/or
detention deputies. The most recent issue with Fields shown in the records occurred on April 9,
2022, an incident resulting in his jailhouse conviction for battery on Deputy Tommy Frye, as
well as convictions for conduct which disrupts or interferes with security, and disobeying orders.
My Notice also alleged the State Attorney’s Office knowingly failed to provide Brady Evidence
for Inmate Fields required pursuant to Brady v. Maryland, 373 U.S. 83 (1963).
Today I am providing evidence that the failure of the jail to protect me from Inmate Fields was
due to retribution by MCJ detention deputies, including Corporal James, in support of Deputy
Suppes against whom I had made a PREA complaint on February 22, 2022.
Timothy T. McCourt, General Counsel December 12, 2023
Officer Isai Palau, ID 5563 investigated my PREA complaint against Deputy Suppes. A
transcript of my interview with Officer Palau shows I also complained that earlier in the same
shift, Deputy Suppes, and her fellow deputies on duty, failed to respond to an incident by Yandel
Andino, Inmate ID A0262030 with an inmate n.k.a. Christopher Simmons, Inmate ID A0090737.
Inmate Simmons later told me the incident began when Andino stabbed Simmons with a
makeshift tattoo needle. A transcript of my interview with Officer Palau shows I also complained
that the jail failed to protect Steven Plaza, Inmate ID A0259320, who was severely beaten.
A rumor in the jail among inmates sought to explain why Deputy Suppes was hostile toward
male inmates. According to the rumor, Suppes was upset over a divorce. Upon release, I learned
that Suppes is “still hitched” according to her public Facebook page that glorifies bank robbery.
https://m.facebook.com/people/Rebecca-Suppes/100080107702135/
MCJ Detention Deputy Rebecca Suppes, ID #6519, appears in the photo above, second from the
right, holding a “still hitched” sign. Her husband Timothy Suppes is first from the right, and they
are holding hands. Timothy Suppes appears to holding a Thompson sub-machine gun in his other
hand. The woman to Deputy Suppes’ left, name unknown, appears to be holding a sawed-off
shotgun, and a bag with a large dollar sign on it ($). The other man, name unknown, fourth from
right, appears to be holding a Thompson sub-machine gun. There are a number of other photo
images on the public Facebook page of Deputy Rebecca Suppes, including the two below. But I
have not included any other photo images in this complaint for the sake privacy concerns.
2
Deputy Suppes’ public Facebook page

shows a number of images of the MCSO,
other officers, and personal photos, such
as the “crazy face” image of Rebecca
Suppes appearing on the left.
These images may affect the reputation

and integrity of the Marion County Jail,
and the Marion County Sheriff’s Office.
Previously I complained about the lack of adequate security for inmates in the Marion County
Jail, and the failure of the jail to protect inmates while they are being held by Sheriff Billy
Woods, Marion County Sheriff's Office. (MCSO).
The Marion County Jail uses AI, Artificial Intelligence, to provide inmate security through
innoVi Genetec Integration, further identified as innoVi by Agent Vi, Comprehensive AI-
Powered Video Analytics, version 30-Nov-2021. This AI security system has a fatal defect by
using video surveillance in lieu of actual officers physically located within the jail pods.
Section/Page TABLE OF CONTENTS
I/3 PREA Incident February 22, 2022 with Deputy Rebecca Suppes, ID #6519
II/5 Failure to provide adequate storage for inmate legal papers
III/10 Fire risk in the Marion County Jail, Ocala, Florida
IV/11 Inmate security in the Bucks County Jail, Doylestown, Pennsylvania
V/15 Stabbing of Christopher Simmons, Inmate ID A0090737
VI/18 Beating of Steven Plaza, Inmate ID A0259320
VII/18 Battery on Robert McGuinness, Inmate ID A0220591
VIII/20 Suicide attempt by Kenneth Clark, Inmate ID A0219592
IX/20 Death of Cory P. Merchant, Inmate ID A0092328
X/23 Reported statement of Oren Miller, Inmate ID A0267181
XI/24 Merchant v. Woods et al, USDC, MDFL, Ocala Div. 5:23-cv-00661-JSM-PRL
XII/24 Whitley v. Woods et al, USDC MDFL, Ocala Div. 5:23-cv-00684-JSM-PRL
XIII/25 Failure of Gov. Ron DeSantis to provide public records (also MCJ record issues)
XIV28 Conclusion
I. PREA Incident February 22, 2022 with Deputy Rebecca Suppes, ID #6519
On February 22, 2022 I awoke around 3:00 AM to a commotion in Med B pod involving Deputy
Rebecca Suppes, ID #6519, and other inmates, and noticed items missing that I placed on my
wheelchair before going so sleep. The items were a jail uniform shirt and pants, my ID name tag,
a thermal top, socks, and a blanket. I was sleeping in my T-shirt and boxer briefs. The missing
items were placed on my wheelchair because my basket was full of legal papers and there was no
3
room for anything else. I did not have any items hanging on my bunk, in compliance with the
rules. I believe Deputy Suppes took my missing items.
Officer Palau’s Incident report # 220000936 shows I stated in part that Deputy Suppes “entered
the section without giving an opposite gender announcement” and “Inmate Gillespie stated he
was sleeping in his underwear and that Deputy Suppes stood there staring at him in his
underwear. This made him feel uncomfortable and violated.” My witness Raul Lopez told me
Suppes was staring at me in my underwear. Other inmates told me the same. The entire pod was
awake and other inmates were complaining about items taken by Deputy Suppes.
A supplemental report by Deputy Suppes responds to my complaint about her removing clothing
placed on my wheelchair: “I then explained that I gave the section multiple verbal orders to
remove all hanging clothing due to inmate safety rules that he could find on page 11 of the
Inmate handbook.” Page 11 of the handbook I found online, Revised: December 2017, only
pertains to visitation.
Page 12, Paragraph 14 Personal Items, states: “Personal items shall be neatly arranged. Attaching
anything to any surface is prohibited. This includes windows, doors, walls, vents. Writing or
drawing on any surface will not be tolerated. All personal items are to be contained in the basket
provided during the Booking process.” As previously noted, the basket was not adequate to
contain all my personal item and my legal papers. Regarding “hanging clothing due to inmate
safety”, I understand that pertains to hanging clothing on two level bunk beds that would
obstruct the view during a security check. However, in the Med B pod, the bunks are singles, so
any hanging clothing would not obstruct a security check. While the rule does not differentiate
between two level bunk beds and single beds, in Med B this is not an inmate safety issue.
Instead, Deputy Suppes, and certain other officers, appear to take joy in disrupting the inmates
peaceful sleep at night for their own gratification and sense of domination. Sleep is essential for
survival. Most other officers do not disrupt the pod by taking inmate clothing at 3:00 AM.
Prior to my PREA complaint, very few female officers made an opposite gender announcement
when entering Med B, a male medical pod. The rule, PREA Operational Directive
6603(E)([§115.15 (5), was ignored with impunity by most female deputies. That changed after
my complaint. But making a verbal opposite gender announcement is not likely to be heard
throughout the pod. Officer Palau’s report concluded, “This Complaint does not rise to the level
of PREA sexual harrassment (sic).” I agree, it is not sexual harassment. Under the PREA rules it
is considered voyeurism, a fact I learned after watching a PREA video on the kiosk.
I sent a jail Emessage to Gary Lashley, Esq., my court-appointed lawyer, about the PREA
complaint but he did not respond.
The bigger issue is the failure of Deputy Suppes, and other officers, to respond to violence in the
pod, a failure of the jail to protect inmates, and the failure of the Artificial Intelligence security
provided through innoVi Genetec Integration.
Tellingly, Officer Palau’s report does not mention that earlier in the same shift Deputy Suppes
failed to respond to an incident by Yandel Andino, Inmate ID A0262030 with an inmate n.k.a.
4
Christopher Simmons, Inmate ID A0090737. Inmate Simmons later told me the incident began
when Andino stabbed Simmons with a makeshift tattoo needle. A transcript of my interview with
Officer Palau shows I also complained that the jail failed to protect Steven Plaza, Inmate ID
A0259320, who was severely beaten. Those complaints are now provided.
Retribution by officers is also a problem in the Marion County Sheriff’s Office. My former
court-appointed lawyer, Zachary Phipps, said my arrest in case 2020CF2417 was retribution by
the MCSO, and an abuse of discretion by the State Attorney.
Enclosed is an Inmate Medical Request form addressed to Dr. Colon, the Medical Director, date
March 5, 2022 that states: (the date was altered by someone else to April 5, 2022)
Dr. Colon, I believe my blood pressure is up due to stress caused last night when Officer
James refused to send my U.S. Mail placed on the table for outgoing mail at final count. I
believe I am at risk of retribution and harm in the jail. [Note: My witness to this event is
Servando Ferguson, Sr.]
Clearly someone altered the date from March 5, 2022 to April 5, 2022. The Staff Section shows
disposition by “DC” on 4-5-22 time 0800, “released 4-7-22” and at the bottom the date 4-8-22,
with a signature I cannot decipher. Previously Corporal James did not assist me when I told him
Inmate Fields threatened to kill me over witnessing Fields take a food tray from Inmate Gosik.
Officer Palau’s report also states that when I was in the infirmary [with Covid-19], Deputy
Suppes refused to send out my U.S. mail. Suppes refused to send my mail on two consecutive
days saying she was not going to let me spread Covid-19 outside the jail by sending my “Covid
infected mail” or words to that affect. This was legal mail related to my Petition For Writ Of
Habeas Corpus, case 5:21-cv-463, U.S. District Court, M.D. Florida, Ocala Division, initially
mailed September 11, 2021. I spoke with Dr. Colon in the infirmary during her treatment of me
for Covid-19. Dr. Colon told me Covid is not spread by mail. I also made a written complaint on
an Inmate Request Form about Depuy Suppes’ refusal to send my mail.
Officer Palau’s report also states “She had also refused to forward his legal documents to the law
library to be copied. Inmate Gillespie stated Deputy Suppes would tear apart his documents and
threw them everywhere. He stated that "it seemed like she's on drugs. Totally nuts”. I also made
a written complaint on an Inmate Request Form about Deputy Suppes and the copy request issue.
Eventually the jail responded to both of my written complaints saying Deputy Suppes was
counseled on the procedure for mail and law library copies.
II. Failure to provide adequate storage for inmate legal papers
On February 22, 2022 my basket was full of legal papers and there was no room for anything
else. The jail failed to provide enough storage space for my legal papers. The basket provided by
the jail is a cheap, flimsy, laundry basket, with rough edges on the sides. I once cut my right
hand while reaching into the basket, which was jammed full of legal papers. The jail failed to
5
treat my injured hand until after it got infected. In contrast, the Bucks County, PA, jail provided
every inmate with a sturdy plastic bin, with solid sides, and a large enough size to hold all my
legal papers, spare clothing, and commissary items.
On February 28, 2022 Deputy Suppes created Incident Report #220001008 that shows the issue
with inadequate storage for my legal papers. The report states:
On February 27, 2022, I was assigned to Medical Pod, At 10:12 PM I was present in
Medical Pod Bravo Section, At this time, I removed Inmate Neil Gillespie's Mattress due
to him having an excessive number of Envelopes underneath his mattress covering his
entire bunk creating a fire hazard. Inmate Gillespie also had an entire basket filled with
papers and envelopes and his assigned wheelchair pocket full of paper books and
envelopes. I gave Inmate Gillespie an order to go through the envelopes and keep only on
hand what he needed and could be neatly stored in his inmate basket underneath his
assigned bunk, Inmate Gillespie refused stating that everything was legal mail. I advised
Inmate Gillespie that all paperwork that he did not need would be stored in his property
box and could request to retrieve it upon necessity. Inmate Gillespie continued to refuse
my order. I advised my supervisor Sergeant Land of Inmate Gillespie's refusal to go
through the paperwork. At this time, all excessive paperwork in and around Inmate
Gillespie's bed area were removed from the section for Inmate safety. Inmate Gillespie
was given a final Opportunity to go through his property to which he finally complied.
Inmate Gillespie's basket still did not fit underneath his assigned bunk, Inmate Gillespie
took his extra uniform and county issued supplies and threw them in a basket that was
provided to him for organization purposes. Inmate Gillespie stated that he needed a little
more time to go through his basket. I advised Sergeant Land and Inmate Gillespie was
given a deadline to have this corrected by Wednesday March 2, 2022. Inmate Gillespie
stated that he understood, A basket of Inmate Gillespie's paperwork was sent to property
to be stored in his property box.
Note: The excessive number of “Envelopes” cited by Deputy Suppes were in fact large manila
envelopes I purchased from the jail and used as a filing system for my legal paperwork.
Incident Report #220001008 by Deputy Suppes accompanied Incident Report #220000980 also
created by Deputy Suppes. Report #220000980 says it is a supplement to Report # 220000936,
which is the PREA report by Officer Palau, and repeats the narrative written by Deputy Suppes
on February 22, 2022. However, Deputy Suppes changed the date of the narrative to February
24, 2022. Report #220000980 states:
On February 24, 2022, I was assigned to Medical Pod. At approximately 0303 hours, I
entered Medical Pod, Bravo Section, to conduct the hourly security check. Upon entering
I made an opposite Gender announcement as per the PREA Operational Directive,
6603(E)([§115.15 (5). While conducting the hourly Security Check Inmate Gillespie
approached me yelling for removing clothing that was hanging on his wheelchair. I then
explained that I gave the section multiple verbal orders to remove all hanging clothing
due to inmate safety rules that he could find on page 11 of the Inmate handbook. At no
6
time did I ever stare at Inmate Gillespie's groin area. At no time while working in the
Infirmary did, I ever tear, or refuse to send out Inmate Gillespie's legal mail.
This is evidence that Deputy Suppes is linking (in her mind) my PREA complaint against her on
August 22, 2022, with her action on February 28, 2022 of taking my legal paperwork, the
“excessive number of Envelopes”. This linkage of these two events by Suppes is evidence that
the jail’s failure to protect me from Inmate Fields was in retribution to my PREA complaint.
Incident Report #220001008 by Deputy Suppes omitted several important facts, which I
memorialized on February 28, 2022 in two text messages sent to my brother Mark stating that I
was not safe in the jail. I asked Mark to relay the message by email to the U.S. Attorney’s Office
in Tampa, Florida.
Mark’s email March 1, 2022 to the U.S. Attorney’s Office on my behalf stated:
To: Colleen Murphy Davis, Assistant U.S. Attorney

400 North Tampa Street, Suite 3200
Tampa, FL 33602
Dear AUSA Colleen Murphy Davis: I am sending a message relayed by my brother, Neil
Gillespie, who is incarcerated at the Marion County Jail in Ocala Florida. Below is his
message that he sent via text to me:
"I am at risk of harm in the Marion County Jail and request your help with pretrial release
or transfer to another facility. Last night Officer R. Suppen, #6519, committed battery on
me in violation of Fla. Stat. 784.03.1A1. Inmate Hopkins witnessed Suppen's battery on
me at 10:45 PM, Feb-27-2022. [Darrell Pierre Hopkins, Inmate ID# A0263838]
Officer Suppen harassed me prior to her battery on me in retribution for complaints I

made against her on Feb-22-2022. Last night Officer Suppen committed battery on me as
I sat in my wheelchair when she grabbed my left arm, causing me pain. After the battery,
I asked to call legal counsel and was denied. I invoked my Fifth Amendment right not to
speak with Suppen and she threatened me with arrest.
Suppen took all my legal files, stamps and envelopes, my mattress, sheets, blanket,
clothing, etc. Several hours later Suppen returned the items, but kept half of my legal
files, citing a fire risk, and sent the legal files to property.
Separately, the Sheriff's general counsel Tim McCourt wrongly accused me of violating
Federal Election Law relative to a quit claim deed transferring my home to my campaign
in 2019, see https/neil2020.blogspot.com/
McCourt also forbade me from calling the property "my home". My campaign is a
federally protected activity under 18 USC 245(b)(1)(a). I want Mr. McCourt and Officer
Suppen charged with their crimes against me. Thank you.”
7
Sincerely,
/s/
Neil Joseph Gillespie
Marion County Jail, Med-B, 108-B
3290 NW 10th Street
Ocala, FL 34475
Inmate ID: A0255941
The foregoing email was filed in federal court, see DOC 20, NOTICE OF FILING: MARION
COUNTY JAIL NOT SAFE FOR INMATE NEIL GILLESPIE, U.S. District Court, M.D.
Florida, Ocala Division, Petition For Writ of Habeas Corpus, Case 5:22-cv-00037-RBD-PRL. A
copy of DOC 20 accompanies this letter.
DOC 20 states at paragraphs 4 and 5:
4. After Gillespie’s release from jail on April 7, 2022, on his own recognizance (ROR),
the Marion County Sheriff’s Office sent Gillespie a letter dated April 20, 2022, by U.S.
Certified Mail, article number 9214 8901 9403 8300 0073 7806 93. (Exhibit 3). The
letter states in part:
Case Number: MCSO19OFF028054

Name: NEIL GILLESPIE
Address: 8092 SW 115th LOOP, OCALA, FL. 34481
Date: 4-20-22
Dear Sir or Madam,

Upon your release from the Marion County Jail, the following items were left
behind.
LEGAL PAPERWORK
Please pick these items up by 5-20-2022. If they are not picked up by the listed
date, they will be disposed of.
This letter will be your authorization to take custody of the above listed property.
5. The “LEGAL PAPERWORK” the jail claims was left behind was actually Gillespie’s
legal files taken by Officer R. Suppen, #6519, on February 27, 2022. It is unclear whether
the jail actually returned all of Gillespie’s legal files. It is also impossible to determine
whether the jail read Gillespie’s legal files it had in its possession for at least 52 days.
When I was released from the jail on April 7, 2022, the above referenced LEGAL
PAPERWORK was not in my “property box”, as alleged by Deputy Suppes, and therefore my
LEGAL PAPERWORK was not available for me to take home when I left the jail, after being
held for 332 days on no bond.
8
Fortunately the Bucks County Jail allowed me to receive legal mail from my brother Mark
Gillespie, a nonlawyer, for use in my civil and criminal legal cases, including for use in my
Pennsylvania petition for writ of habeas corpus, Commonwealth v Neil Joseph Gillespie, Court
of Common Pleas of Bucks County, Case CP-09-MD-319-2021.
Upon extradition to Florida I brought my Pennsylvania legal mail with me to the Marion County
Jail. Otherwise I would not have had the legal documents I needed to represent myself. The
Marion County Jail does not allow nonlawyers to send legal mail to inmates. And my court
appointed lawyer Gary Lashley refused to send me any legal mail while I was held in the MCJ.
While incarcerated, I represented myself pro se in civil legal cases involving home foreclosure,
habeas corpus, and a constitutional challenge of Fla. Stat. 934.03. I also represented myself pro
se in criminal appellate cases where Mr. Lashely was not appointed. This resulted in a lot of
legal paperwork. The Florida cases are shown below.
Gillespie v. State of Florida, Constitutional Challenge to Fla. Stat. 934.03, U.S. District
Court, Middle District of Florida, Ocala Div., Case No. 5:21-cv-416-PGB-PRL
Gillespie v. Marion County Jail, Petition for Writ of Habeas Corpus, U.S. District Court,
Middle District of Florida, Ocala Div., Case No. 5:22-cv-37-RBD-PRL
Gillespie v. Sheriff Billy Woods, Petition for Writ of Habeas Corpus, Florida Supreme
Court, Case No. SC21-1657
Gillespie v. Federal National Mortgage Association (FNMA) a.k.a. Fannie Mae,

Marion County Circuit Court, Case No. 2021-CA-2179 (Ejectment action)
And many cases in the Florida Fifth District Court of Appeal, civil and criminal.
The verbal order by Deputy Suppes on February 28, 2022, for me to go through my legal
paperwork and keep only on hand what I needed and what could be neatly stored in my inmate
basket underneath my assigned bunk, could not be reasonably completed in the short amount of
time allocated.
The MCJ contends that excess legal papers can be stored in an inmate’s property box and
retrieved as needed. This approach is not workable because it requires the cooperation of hostile
or indifferent deputies, coordinating the work schedules of pod deputies and the property room,
with the later subject to the arrival of newly arrested persons to the booking department at any
9
time, and/or a lack of deputies available to accompany the inmate to the property room to get
their legal papers.
On January 26, 2023 I submitted the attached Inmate Request Form for my phone numbers in my
cell phone, my legal papers, and my medically-necessary diabetic shoes and socks. The jail
responded on January 27, 2023: “You must be transported to property for your numbers &
paperwork. Medical will have to approve socks & shoes and send a med pass to property”,
signed by Markum. On February 2, 2023 I submitted the attached Inmate Property Release
Authorization form to get my legal papers. The form was later returned and marked “Expired
2/8/23” and signed by Markum. I never got my legal papers.
Duane William Cunningham, Medical License No. APRN 9219271, a.k.a. "Andrew
Cunningham", a nurse practitioner employed Heart of Florida Heath Center, the jail’s medical
provider, denied me use of my jail-provided diabetic footwear, resulting in open wounds on both
of my feet. Attached you will find my grievance to the jail with accompanying medical and
inmate request forms. I was never allowed to use my jail-provided diabetic footwear during my
incarceration from January 25, 2023 through March 20, 2023. I have exhausted all available
administrative remedies under PRLA, the Prison Litigation Reform Act, that are required prior to
bringing a lawsuit concerning the conditions of confinement under 42 U.S.C. § 1983 or any other
federal law.
III. Fire risk in the Marion County Jail, Ocala, Florida
Incident Report #220001008 by Deputy Suppes states in part:
On February 27, 2022, I was assigned to Medical Pod, At 10:12 PM I was present in
Medical Pod Bravo Section, At this time, I removed Inmate Neil Gillespie's Mattress due
to him having an excessive number of Envelopes underneath his mattress covering his
entire bunk creating a fire hazard.
As noted previously, the excessive number of “Envelopes” cited by Deputy Suppes are in fact
large manila envelopes that I purchased from the jail and used as a filing system for my legal
paperwork. While paper is flammable, it is not subject to spontaneous combustion.
The primary fire risk in the Marion County Jail is the lack of meaningful supervision of inmates.
Previously I noted the lack of adequate security for inmates in the jail by written complaint to
you June 8, 2023 (corrected), and the failure of the jail to protect inmates while they are being
held by Sheriff Billy Woods, Marion County Sheriff's Office. (MCSO).
To hold someone in custody means removing their autonomy. The jailer has exclusive control
over the welfare of the person and is therefore exclusively responsible for the conditions of their
safety, medical care, and security.
The Marion County Jail uses AI, Artificial Intelligence, to provide inmate security through
innoVi Genetec Integration, further identified as innoVi by Agent Vi, Comprehensive AI-
10
Powered Video Analytics, version 30-Nov-2021. This AI security system has a fatal defect by
using video surveillance in lieu of actual officers physically located within the jail pods.
There are two examples in the jail that show how the lack of officers physically present within
the jail pods create a fire hazard. One fire I personally witnessed. The other fire is alleged be
related to tablet computers provided by Securus Technologies. A tablet computer, commonly
shortened to tablet, is a mobile device, typically with a mobile operating system and touchscreen
display processing circuitry, and a rechargeable battery in a single, thin and flat package.
I witnessed inmates in Med-B start a fire to cook drugs. The process began in the recreation
yard, where inmates used a pair of eyeglasses to focus sunlight on kindling to start a fire. The
inmates did this unimpeded because there were no actual officers physically present, and the
Artificial Intelligence innoVi Genetec Integration system is a failure. Once the kindling was lit,
fuel was fed to the fire to keep it going. The fire was then transferred to an empty trash can. The
trash can containinng the fire was then placed on a wheelchair, and then rushed to the toilet area
of the pod. One toilet was prepared in advance to receive the fire, the handicapped toilet. Sheets
of writing paper were placed on top of the water in the toilet bowel, and left to float. This was
done in advance, and an inmate was posted to guard this toilet, to prevent inmates from
otherwise using the toilet. Once the wheelchair arrived with the trash can, the burning fire was
transferred from the trash can and placed on top of the paper floating on top of the water in the
toilet bowel. Then drugs could be cooked. This event required planning and coordination among
a number of inmates. The inmates were able to act unimpeded because there were no actual
officers physically present. Even though I witnessed this event, I did not understand what
happened until it was later explained to me. The jail security cameras were useless in preventing
this fire.
The other fire I know about came to my attention when the MCJ took all the tablets in the pod
that were provided by Securus Technologies. Apparently inmate(s) in another pod were able to
disassemble the tablet(s) and used the tablet parts to start a fire. A rumor in the MCJ claimed the
inmates in that pod burned their jail clothing and anything else that was flammable. Prior to
making this complaint I called the MCJ and confirmed that the jail discontinued the tablet
program because inmate(s) disassembled tablet(s) and used tablet parts to start a fire.
IV Inmate security in the Bucks County Jail, Doylestown, Pennsylvania

https://www.buckscounty.gov/216/Main-Correctional-Facility
On February 4, 2021 I was apprehended at the Red Roof Inn in Bucks County, Pennsylvania,
while recovering from retina surgery done on January 28, 2021 at Wills Eye Hospital in
Philadelphia, and held in the Bucks County Jail, 1730 S. Easton Rd., Doylestown, PA 18901.
I was held for 95 days until my extradition to Marion County, Florida on May 10, 2021 on a
Governor’s Warrant signed by Florida Governor Ron DeSantis on March 23, 2021. I challenged
my extradition by Petition for Writ of Habeas Corpus denied April 28, 2021, see Commonwealth
v Neil Joseph Gillespie, Court of Common Pleas of Bucks County, Case CP-09-MD-319-2021.
11
On October 23, 2020 I was diagnosed with a detached retina needing surgery. On November 1,
2020 I filed a motion to cancel or continue all hearings until further notice because I had a
detached retina needing surgery, see Filing # 115946049 E-Filed 11/01/2020 09:00:32 PM. I was
essentially blind in my left eye and in pain. Marion County Circuit Judge Gary Sanders
scheduled a motions hearing anyway for January 20, 2021. On January 20, 2021 Judge Sanders
denied my subsequent motion for a 60 day stay for eye surgery under the Americans With
Disabilities Act (ADA) in cases 2019-CF-4193 and 2020-CF-2417. Previously I had been unable
to get timely retinal surgery on Ocala. I did not appear at the January 20th hearing and had gone
to Philadelphia for retina surgery at Wills Eye Hospital. Judge Sanders did not deny my motion
under the ADA until after the hearing, then issued a FTA bench warrant for my arrest.
The Governor’s Warrant showed Judge Sanders had planned to bring me into court to arrest me
on another one-party consent phone call recording crime, which became case no. 2021-CF-286.
Previously I was arrested for one-party consent phone call recording in case no. 2019-CF-4193.
One-party consent phone call recording is lawful under 18 USC 2511(2)(d) when not acting
under color of law, and is the Law of the Land in Florida under the Supremacy Clause of the
U.S. Constitution, Article VI, Clause 2. In addition, all calls on my home office telephone
extension (352) 854-7807 were recorded for quality assurance purposes pursuant to the business
use exemption of Fla. Stat. sec. 934.02(4)(a)(1) and the holding of Royal Health Care Servs.,
Inc. v. Jefferson-Pilot Life Ins. Co., 924 F.2d 215 (11th Cir. 1991), as publicly announced on my
website at https://www.nosue.org/telephone-recording/
The Bucks County Jail in Doylestown, Pennsylvania serves as the countywide central receiving
location for all persons committed to the system as either pre-trial detainees or convicted
prisoners. Annually, the facility receives over 7432 prisoners. Medium and maximum-security
classified inmates are housed at this facility. The facility has 10 modular living units utilizing a
direct supervision philosophy while providing programs for the treatment and education of the
inmate population.
The facility was designed and built to be operated using a direct supervision philosophy. This
methodology has corrections officers in direct contact and observation with the inmates
throughout the facility. This is important because to hold someone in custody means removing
their autonomy. The jailer has exclusive control over the welfare of the person and is therefore
exclusively responsible for the conditions in which the inmate is held.
The Bucks County Jail employs professional Corrections Officers who work for the Department
of Corrections. The Marion County Jail employs “Detention Deputies” who work for Sheriff
Billy Woods. This arrangement creates a conflict of interest with the Marion County Sheriff’s
Office, because the jailers and the arresting officers work for the same law enforcement agency.
Good security is the backbone of any correctional facility. Bucks County Jail Corrections
Officers directly monitor inmates 24 hours a day, 365 days a year. Direct supervision by officers,
sergeants and lieutenants assure that the security and safety needs are met and that the
operational plan of the day is followed.
12
In my complaint to you of June 8, 2023, I noted the following:
In conclusion, I was held in the Bucks County Jail, Doylestown, PA, for 95 days, from
February 4, 2021 through May 10, 2021. The Bucks County Jail had two Correction
Officers present in each pod at all times, providing direct visual supervision of the
inmates. The Correction Officers were virtually all male, and were required to be in good
physical condition to perform their job. They were prohibited from carrying any type of
weapon, no pepper spray, and no stun gun. They only carried handcuffs and a radio. If
pepper spray was needed, it had to be authorized by a sergeant, and was administered in a
group of 5 officers.
The Pennsylvania Correction Officers were very professional, and there were virtually no
problems, compared to the nonsense I witnessed in the Marion County Jail. In addition,
each inmate was assigned a caseworker who had an office in the pod. The pods were two
story style with two man cells, and a few single cells, about 88 inmates total. Inmates
could write letters and send cards to friends and family in stamped envelopes that were
sealed and not read by the jail. Each pod had two large screen televisions with two rows
of theater seating each. Inmates could buy $88 of commissary twice a week. Inmates
could purchase clothing and shoes, along with coffee and chocolate, and a wide range of
items, including full size pens, nail clippers, full size tooth brushes, writing paper,
greeting cards, and all the postage stamps an inmate could afford, without needing
special permission. Inmates could also purchase a personal 13 inch television and/or a
radio.
There was also a functioning law library that provided copies without cost. Inmates were
permitted to receive legal mail from nonlawyers, and personal mail that would fit in a
standard size business envelope. Inmates were provided a large storage bin to hold their
property. The atmosphere was safe and peaceful.
In addition, the Bucks County Jail provided fresh drinking water in each pod by way of a modern
drinking fountain. The drinking fountain provided cold water for drinking, and hot water to make
coffee, soup, or noodles, etc. The drinking fountain in the Marion County Jail Med-B was
removed many years ago and never replaced. Instead the MCJ provides a plastic “keg” with
water or flavored water for inmates only at meal time. This communal keg is often filthy. Water
is dispensed with a communal spigot that spreads germs and disease from one inmate to the next.
Certain inmates do not wash their hands after using the toilet, and then use the communal spigot.
The Bucks County Jail also had two vending machines in each pod where I was held. The
vending machines dispensed food, coffee, candy, bottled water, soft drinks, etc. Inmates had
access the vending machines with a bar code ID wrist band linked to their inmate account.
The Bucks County Jail transported me twice to Wills Eye Hospital for follow-up medical
appointments after retina surgery. But after I was extradited to Florida, the Marion County Jail
failed to provide follow-up eye care. Part of the problem is local prejudice toward jail inmates by
13
medical providers in Ocala. People who are incarcerated face a nearly insurmountable bias in
having medical issues taken seriously. These are high risk factors in bias preventing a person
from accessing the medical care they need. A note entered in my medical file on March 29, 2022
at 10:14 AM by Francine Moon states:
Patient was referred to a Retina Specialist and was scheduled at the Comprehensive
Retinal Consultants on 3/10/22. The inmate was asked to leave the office due to other
patients not feeling comfortable with an inmate being there.
Comprehensive Retinal Consultants is located at 5353 SW College Rd, Ocala, FL 34474

(352) 820-4445. The medical provider, Shalesh Kaushal, MD, PhD, claims “medicine is a
lifestyle choice, not a job” on his website. The note by Francine Moon also states:
I fax a referral, notes and an LOA as requested to the Retina Center and
when I called to follow up, they stated that they will not see inmates.
I called UF Eye Center and they stated we do not have a contract with them,
when I stated we could arrange that she stated that they have no openings.
I fax a referral and note to Vitreo Retinal Assoc as requested an I

received an email stating they will not see inmates.
I called Ocala Eye and they refused to see inmate and stated this inmate
refused to be seen there in 2020.
The response by Ocala Eye is false and misleading. Ocala Eye is located in Ocala. Retina
surgery was only done in Gainesville as an outpatient procedure at the North Florida Surgical
Pavilion. At that time retina surgery was not performed anywhere in Ocala. In 2020 Ocala Eye
required a family member drive the patient to and from the surgery and wait for the patient
during the surgery and recovery, about 5 hours plus travel time. Transport by Uber or taxi was
prohibited. This was the protocol I found at other providers. I do not have family in Ocala. My
brother lived in Texas. My elderly neighbors were not willing to drive to Gainesville. Ocala Eye
also demanded I sign an arbitration agreement prior to surgery. Another issue, the North Florida
Surgical Pavilion demanded payment in advance of a substantial deposit even though I was
covered by Medicare. Later I learned this demand was unlawful pursuant to [42 USC 1395cc]
§1866(a)(1)(N) of the Social Security Act because detached retina is a medical emergency.
https://www.ssa.gov/OP_Home/ssact/title18/1866.htm
Although I got retina surgery at Wills Eye Hospital, my vision now in the affected eye (left eye)
is 20/400, legally blind. For more, see,
NOTICE OF FILING TRANSCRIPT OF MOTIONS HEARING JANUARY 20, 2021

Filing # 180463632 E-Filed 08/24/2023 03:51:03 PM
14
V. Stabbing of Christopher Simmons, Inmate ID A0090737 Pennsylvania
The transcript of my PREA interview with MCJ Investigator Isai Palau on February 22, 2022
shows, beginning on page 8, my complaint that Deputy Suppes failed to break up a fight:
5 MR. GILLESPIE: And I’ll tell you what really bugs me

6 about this. Earlier in the night -- this was the 22nd in the
7 morning -- but on the 21st, right, when she was on duty,
8 there was a fight in there, okay, and there’s a bully in
9 there, and he’s beating up a one-legged man, and he’s lying
10 there and he’s (INDISCERNIBLE) wheelchair, in front of the
11 wheelchair right there. Just had his leg cut off in January
12 and he’s just come over here.
13 This guy, he was on the phone, and this bully comes up
14 and started beating the crap out of him, and he’s a large,
15 (INDISCERNIBLE). This guy was really taking a pounding. And
16 why don’t they come and break those fights up? If they’re
17 going to come in and cause trouble –
18 INV. PALAU: Nobody, nobody came in at all?
19 MR. GILLESPIE: No.
20 INV. PALAU: And you said that was on the 22nd -- on the
21 21st?
22 MR. GILLESPIE: That was on the 21st and it was after
23 the supper count, so it was after, like, 6:30. It was nearly
24 (INDISCERNIBLE), I would say before 9:00, between like 6:30
25 and 9:00. And this poor guy is getting the crap beat out of
MCJ Inv. Palau interview transcript Feb-22-2022, page 9:
1 him
2 And, you know, the rule in here is no people [get] involved in
3 fights or (INDISCERNIBLE) fighting. And the guy that they
4 were beating up, he held his own, but I thought it was wrong.
5 And this guy that caused the trouble, he beat up other people
6 in here.
7 INV. PALAU: But let me ask you this. Do you know who
8 the guys were that were involved? Do you know their names?
9 MR. GILLESPIE: I don’t know the guy that was missing a
10 leg, but he’s easy (INDISCERNIBLE) because he’s the only one
11 with a completely cut off (INDISCERNIBLE) wheelchair, and red
12 suits (sic) [seats] on.
13 INV. PALAU: Right. And that, that’s the guy that you
14 said has the leg problem?
15 MR. GILLESPIE: Right.
16 INV. PALAU: Okay.
15
17 MR. GILLESPIE: (INDISCERNIBLE). And the other guy, his

18 name is something like Yulando Adrena (phonetic).
19 INV. PALAU: What is it?
20 MR. GILLESPIE: Yulando Adrena. Something like that.
(Note, that inmate was Yandel Andino, Inmate ID A0262030)
Shortly after my interview with Officer Palau, I got to know the inmate attacked by Yandel
Andino. His name is Christopher Simmons, Inmate ID A0090737. Simmons had his leg
amputated below the knee shortly before coming to jail. I believe the amputation explained why
he missed a court date and got a failure to appear (FTA), resulting in his incarceration. The
record in his case (2020-CF-1236-A) shows DOC 110, FTA Bench Warrant served Jan-31-2022.
Inmate Simmons told me he was standing near a fire burning trash when somehow a live shotgun
shell was thrown into the fire along with other trash from a shed being cleaned out. The shotgun
shell cooked off and resulting the blast hit him in the foot. Apparently the injury to his foot was
so severe that he opted for amputation and a prosthetic leg. I understand the jail may have failed
to provide him with the necessary follow up medical treatment for his amputated leg. Simmons
did not yet have a prosthetic leg. The jail provided Simmons a unique wheelchair that was easily
identifiable because it was chrome plated with a red seat. All the other jail wheelchairs were
black or blue. [Separately, regarding amputee Ronny Cooper, age 61, Inmate ID 5200, I emailed
you on October 21, 2023 with a message from Inmate Cooper that Dr. Rodriguez of Heart of
Florida, the MCJ medical provider, took Cooper’s malfunctioning prosthetic leg from him and
put it in property rather than repair the leg. I believe this is evidence of disability law violation].
Inmate Simmons said the fight began when he was talking on the telephone, while seated in his
wheelchair, and Andino came up and stabbed him with a makeshift tattoo needle. The Med-B
pod has three inmate telephones located on a wall near the door to the pod. That is where the
fight happened, in plain view of the cameras and the door to the pod. The fight was intense, and
Simmons ended up on the floor because he could not stand and fight with only one leg.
Inmate Simmons was also represented by appointed counsel Gary Lashley. Mr. Lashley also
represented me. As I understand, when Simmons told Mr. Lashley he wanted him to defend the
case, Lashley filed a motion for a competency exam. (DOC 139, Mar-14-2022). The record in
Simmons’ case shows he filed a pro se motion to disqualify Lashley for inadequate assistance of
counsel. (DOC 151, May-19-2022). Apparently Simmons was found competent, but could not
remove his ineffective counsel. On June 6, 2022 the SAO filed a motion to strike discovery
(DOC 159) provided by Mr. Lashley as insufficient and “does not satisfy the Defendant’s
requirements”. Mr. Lashley amended his discovery (DOC 198). Lacking adequate counsel,
Inmate Simmons took a plea deal. (DOC 207).
Deputy Suppes and Deputy Tommy Frye were on duty during the evening shift that began at
supper time on February 21, 2022 and ended at breakfast on February 22, 2022. That was the
same shift where Deputy Suppes violated PREA at 3:00 AM as stated in my complaint.
The transcript of my interview with Officer Palau on Feb-22-2022 continues on page 9:
16
21 And he’s, he beat up Plasma (phonetic). There’s an inmate

22 Plasma (INDISCERNIBLE). And Plasma’s been complaining to the
23 health department about it. Plasma has -- he’s missing an
24 eye. He wears an eyepatch. And he beat the crap out of him
25 in the shower, okay.
The inmate I referred to was Steven Plaza. (Plasma). See the next section, “Beating of Steven
Plaza, Inmate ID A0259320”. The beating took place in the shower area out of sight of the
cameras, and out of sight of the MCJ deputies. FYI, the shower area is also where the inmates set
up their tattooing operation. Out of the sight of the cameras. Because there were no deputies
stationed in the Med-B pod, the inmates had hours of uninterrupted time to tattoo each other.
The transcript of my interview with Officer Palau on Feb-22-2022 continues on page 10:
1 And I happened to be in court with him one day. [Yandel Andino] The
2 reason he’s in here, he was beating up a pregnant woman on
3 the outside. The guy’s a real thug. He’s 23 years old.
4 He’s always looking to fight. His arm is wrapped up, his arm
5 is wrapped up in a bandage, but he seems (INDISCERNIBLE) beat
6 people up pretty easy. He shouldn’t be in here. They’ve
7 taken him out a couple of times and he should be in the
8 regular population, where he can pick on people his own size
9 and his own character, because he’s a menace.
11 MR. GILLESPIE: But she wouldn’t come in for that.
12 And the other one there, Frye, Officer Frye. He’s
13 another useless liar. They will do anything to cause
14 trouble, the two of them.
15 INV. PALAU: Okay. I’m going to, I’m going to get back
16 with you, okay? We’ll pull the video and we’ll see, you
17 know, what all comes of it, okay?
18 MR. GILLESPIE: I’d pull the video from (INDISCERNIBLE).
19 It’ll be right by the telephones, where the telephones are.
20 INV. PALAU: I will.
21 MR. GILLESPIE: All right.
22 INV. PALAU: Okay?
23 MR. GILLESPIE: Thank you, sir.
24 INV. PALAU: You’re welcome.
25 MR. GILLESPIE: I appreciate it.
As far as I know, the MCJ never investigated the stabbing of Inmate Christopher Simmons.
17
VI. Beating of Steven Plaza, Inmate ID A0259320
Steven Plaza is the inmate who wore a black eye patch whom I described to Officer Palau.
Inmate Steven Plaza was severely beaten by more than one inmate in the Med-B shower area.
The beating involved a perceived slight or disrespect to another inmate, and was a case of
jailhouse justice being meted out by certain self-appointed inmate enforcers. I witnessed a brief
part of the fight. But I had a better view of what happened afterward. Inmate Plaza was beaten so
badly that one of the inmates who may have administered the beating became concerned about
Inmate Plaza’s open head and face wounds, bruising, and physical condition as Plaza began to
hyperventilate. He was also concerned that Plaza might report the incident to MCJ deputies.
Inmate Plaza was beaten after supper was served, but prior to the after-supper head count.
Plaza’s head and face were clean shaven. So the open wounds and bruises on his head and face
from the fight were clearly visible to anyone looking at him. Initially it appeared Inmate Plaza
might need sutures to stop the bleeding and close the wounds on his forehead, and on his face
below his eye. Inmate Plaza was also crying and hyperventilating. Another inmate took control
of administering first aid to Plaza. No MCJ deputies responded to the fight. The inmate nursing
Plaza was trying to stop the bleeding of his head and face wounds by applying pressure with a
wash cloth. The inmate nursing Plaza was also telling him to calm down, and take deep breaths
as a way to bring his hyperventilating under control. After 30 minutes or so, Plaza calmed down
somewhat, and the bleeding stopped. But there was no hiding the fact that Inmate Plaza had just
been involved in a severe beating. There were red gashes and bruising on the skin on his shaved
head and face, and his only eye was swollen and red from crying. (The other space where his
missing eye used to be, the empty eye socket, was covered by an eye patch).
A short time later the MCJ deputies on duty came in for the after-supper headcount. Inmate Plaza
stood by his bunk as is the usual headcount procedure. Inmate Plaza had wounds and bruises on
his head and face from the fight that were clearly visible to anyone looking at him. Plaza still
looked upset. But the deputy doing the headcount either did not look at Plaza’s face, or missed
what was clearly visible, or ignored what he or she saw. Then the headcount was concluded.
Some days after Inmate Plaza was beaten, I understand Plaza reported the incident to the medical
staff in either the infirmary or in the clinic. That is what I heard from other inmates. I also know
the perpetrators of the beating were concerned that Plaza was complaining to the medical staff.
But as far as I know, the MCJ never investigated the beating of Inmate Steven Plaza.
VII. Battery on Robert McGuinness, Inmate ID A0220591
The booking photo for Inmate Robert McGuinness shows he arrived at the MCJ wearing a neck
brace on January 29, 2023. The MCJ inmate information page for McGuinness shows his height
as 5’07” tall and weight of 160 pounds. A vehicle crash resulted in injury to McGuinness,
including his neck, right leg, and ribs. Inmate McGuinness was previously a certified process
server in Marion County, and a friend of the family of attorney Robert Stermer.
18
On January 29, 2023 I witnessed another inmate commit battery on Inmate McGuinness. A much
larger inmate grabbed McGuinness by the neck and lifted him off the ground for some alleged
transgression. The MCJ deputies on duty witnessed the battery from outside the Med-B pod. The
aggressor was called out to the rovers area. Apparently the deputies told the aggressor he would
not face consequences because the MCJ video recorder was not operating, and there would not
be any video evidence for prosecution. I know the aggressor and he is a friend. He is also a
former football player and much larger than McGuinness. The aggressor was a long term inmate
in Med-B and popular. I understand Inmate McGuinness made a written complaint about the
battery to Corporal Nathan McClain, ID #5212.
Separately, Inmate Larry Dawson, ID A0256389, took the neck brace from Inmate McGuinness
while McGuinness was in the shower and had left the neck brace on his bunk. Inmate Dawson
took the neck brace from the bunk and placed it in a toilet. After his shower, Inmate McGuinness
reported his neck brace was missing to the MCJ deputies on duty. Eventually McGuinness found
his neck brace in the toilet. You may recall from my prior complaint that Inmate Dawson beat
Inmate John Goodall on February 20, 2023 with a weapon during a 20 minute fight in Med-B
was not stopped by the MCJ deputies on duty.
On August 11, 2023 I made this public records request to the MCSO:
This is a request for records of the Marion County Jail file for Robert McGuinness,
Inmate ID 0220591, regarding complaints he filed during his recent incarceration, from
01/19/2023 through 04/15/2023. He filed two complaints for assault/battery by other
inmates, and complaints about Mr. Cunningham of Heart of Florida. McGuinness
previously was a process server in Marion County, and was a friend of the family of
attorney Robert Stermer.
On August 21, 2023, record custodian Brittany Colbert responded for the MCSO:
Good afternoon Mr. Gillespie:

I’ve located one record related to your below request. Please see attached.
Best regards,
-Brittany Colbert
Ms. Colbert provided Incident Report 230000657 by Deputy K. Davison, ID 5940, dated
February 6, 2023 for a disturbance in the infirmary. Inmate McGuinness was in the infirmary
because his injured leg had become infected and needed treatment. The report states:
On 2/6/23, at approximately 1022 hours, while working in the Infirmary, I observed

Inmate David Posey get up off his bed and walk to the back of his cell. I heard yelling
and went over to cell door 103. I Observed Inmate Posey try to strike Inmate Robert
McGuinness. Inmate McGuiness pushed Inmate Posey away to avoid getting hit. Inmate
Posey fell on the floor landing on his back side. I ordered both Inmates to stop. Inmate
Posey was ordered to stand up and come to the door. Inmate Posey was placed in hand
restraints and sat on the bench and seen by Nurse Frasier noting no injuries. Inmate Posey
19
was re-housed in cell 101 without further incident. Inmate McGuinness was also seen by
Nurse Frasier noting no injuries.
Inmate David Posey, ID A0006647 is a problem inmate who should be housed alone at all times.
On March 28, 2022 I submitted an Inmate Request Form while in the Infirmary to Dr. Colon,
received by Deputy Gilbert, ID 6466. My request form states:
I am getting death threats from inmate David Eugene Posey in the Infirmary - I cannot be
in a cell with this crazy person. Please put me in protective custody - solitary
confinement, immediately. Thank you.
The response from the jail states “Discharge from jail” 4/11/2022 8:47 AM.
Ms. Colbert did not provide any records for the complaint Inmate McGuinness made to Corporal
Nathan McClain. No records were provided for the complaint Inmate McGuinness made about
Mr. Cunningham of Heart of Florida.
VIII Suicide attempt by Kenneth Clark, Inmate ID A0219592
During my incarceration in 2022, Inmate Kenneth Clark, age 70, attempted suicide in Med-B by
strangulation in his bunk. Clark wrapped a makeshift noose around his neck while in his bunk,
and covered himself with a blanket. This happened in the afternoon. As he was dying, but before
he could die, his body made involuntary motions that alerted other inmates to the suicide
attempt. When the blanket was removed, Clark was found with a ligature around his neck, and
his face was purple. The inmates summoned MCJ deputies, and they responded, along with
medical personnel, and removed Clark on a gurney. Clark was eventually returned to Med-B.
Clark had made it known beforehand to other inmates that he was considering suicide.
According to news reports, inmate suicide is a serious problem in the Marion County Jail. In the
year 2018 alone, four inmates committed suicide. The Ocala Star-Banner reported on June 6,
2022 that “jail policy requires detention deputies to check on inmates every 30 minutes”. But in
practice detention deputies do not check on inmates every 30 minutes.
IX Death of Cory P. Merchant, Inmate ID A0092328
I was in the Marion County Jail on November 7, 2021 when Inmate Cory Merchant was fatally
injured at 12:30 AM in a fight, according to a story published in the Ocala Star-Banner on
November 18, 2021. The Star-Banner reported:
Sheriff's Office officials confirmed there was an altercation at the jail and that it was
recorded on surveillance video. They said it started as a verbal exchange between
Merchant and another inmate and led to a short physical altercation.
The other inmate is now known as Eric Lutterloah, Inmate ID A0070076.
20
The Star-Banner reported, “According to the family, they said they were told independently that
Merchant was beaten and, when other inmates tried to alert detention deputies, their pleas were
ignored.” This is an ongoing problem in the jail. There are no detention deputies stationed in the
pod. When inmates try to alert deputies to problems in the pod, they are often met with shouting
from deputies to “GET OFF THE DOOR!”. I have witnessed this scenario many times.
For example, Inmate William Wing, ID A0010513, age 68, suffered from serious infirmaries of
aging, including a colostomy requiring specialized daily healthcare. Inmate Wing was a law-
abiding citizen who worked 20 year at the Ocala water department, and operated a vehicle title
transfer business that the SAO chose to wrongly criminalize. I often watched Inmate Wing plead
in vain at the Med-B pod door to have his colostomy bag changed to no avail. Inmate Wing was
quite ill and was transported to the hospital at least once. Inmate Wing was initially denied bond,
and denied compassionate release at a hearing before Judge Lisa Herndon.
Another inmate in a similar situation was Conrad Degon, ID A0260189, age 67. Inmate Degon
also suffered from serious infirmaries of aging, including a colostomy requiring specialized daily
healthcare. According to his obituary, Degon began his law enforcement career in New York
State as a Malone Police Department Officer and then a Franklin County Sheriff Deputy. He
retired from his law enforcement career with the Department of Corrections in 2014. During his
time with the Corrections Department, Conrad was awarded the New York State Medal of Honor
for bravery as he pulled seven AIDS patient/inmates to safety during a fire while he was
guarding the inmates during their treatment at St. Clair’s Hospital in New York. He was 36 years
old at the time. Inmate Degon told me he saved the life of a motorist involved in a vehicle crash
where he was injured during the rescue and lost most of his fingers on both hands.
Inmate Degon spent a lot of time in the Infirmary. He could not change his colostomy bag
himself because most of his fingers were missing. One day while I was in the Infirmary I
overheard nurse Elizabeth complain to others about Degon asking for help changing his
colostomy bag. Elizabeth laughed and said she was not his slave.
On January 28, 2022 Inmate Degon died of Covid-19 after the MCJ had him rushed him to
Advent Health Hospital. However, in the weeks before he died, Inmate Degon told me what he
saw happen to Inmate Cory Merchant on November 7, 2021 in the Infirmary.
Inmate Degon was in the Infirmary on November 7, 2021 when Cory Merchant was brought in
on a gurney for treatment directly in front of Degon’s cell. Degon told me a female medical
person tried to revive Cory Merchant with a defibrillator. She yelled for an assistant to turn the
electric current on the defibrillator to the maximum. Merchant was given a shock with the
defibrillator paddles but he did not respond. Degon said an EMT who was present shook his
head indicating that Merchant was dead. Then Merchant was taken away. Inmate Degon told me
he believed Cory Merchant was dead before he left the jail on November 7, 2021.
The Star-Banner reported in its story published on November 18, 2021:
21
Cory Merchant died on Nov. 13
Merchant's family said he died at 12:52 a.m. Nov. 13, nearly a week after he was
transported to ORMC in critical condition.
He had tubes in and out of his head when family members visited him, Krysti Merchant
and father Tommie Merchant told the Star-Banner.
The Ocala Star-Banner published a story by Austin L. Miller on December 1, 2021, “Victim's
family: Manslaughter charge too light for fatal jailhouse attack in Ocala” that stated in part:
According to Detective Annemarie Larocque's probable cause report, she went to the
county jail on Nov. 7 to investigate a fight between two inmates...
Report: Lutterloah says the victim woke him up by talking and laughing
...Larocque interviewed Lutterloah, who said he woke up because Merchant was standing
by his bed talking and laughing with another inmate. Authorities said the fight happened
shortly after 1 a.m.
He said they were on lockdown and everyone should have been in their beds. He said
Merchant's bed is on the other side of the pod.
He said he got up and Merchant moved over to the next aisle. Lutterloah said he told
Merchant to move from his area, but he was ignored. He said they argued and then
scuffled. He said he hit Merchant, according to the report...
...Merchant's cause of death was blunt head trauma due to an assault and the manner was
homicide...
...Merchant, 35, had been at the jail since 2019 awaiting resolution of sex charges. He
had filed numerous motions seeking release on bond but was unsuccessful.
Inmate Cory Merchant was entitled to pretrial release on reasonable bond under the U.S. Eighth
Amendment, Article I, Section 14 of the Florida Constitution, and other such. Instead, at the time
of his death, Merchant had been held in the MCJ since November 8, 2019, two years on no bond,
or bond he could not afford, which courts have ruled is the same as no bond.
All human beings, including inmates, have a right to sleep. It is a “foregone conclusion that
human life requires certain acts, among them . . . sleeping.” Johnson, 860 F. Supp. at 350, Bell v.
City of Boise et al., Case No. 1:09-cv-540-REB, U.S.D.C., District of Idaho, Statement of
Interest for the United States (DOC-276). Inmate Lutterloah had a right to sleep at 1:00 AM on
November 7, 2021. Sheriff Woods had a duty to Lutterloah to provide a period of quiet sleep.
22
over the welfare of the person and is therefore exclusively responsible for the conditions in
which the inmate is held. Sheriff Woods was the jailer on November 7, 2021 for Inmate Cory
Merchant, Eric Lutterloah, Conrad Degon, myself, and approximately 1,800 other inmates.
Sheriff Woods is responsible for the death of Cory Merchant. The State Attorney’s Office is
misusing the prosecution of Eric Lutterloah as a scapegoat for the negligence of Sheriff Woods,
and to protect the SAO/Court’s policy of misusing no bond incarceration to compel plea deals.
X Reported statement of Oren Miller, Inmate ID A0267181
Inmate Oren Miller, age 72, was held in the Marion County jail for 74 days, from November 18,
2022 to January 30, 2023. On November 9, 2023, the Fifth District Court of Appeal overturned
Miller’s jury trial conviction, see Oren Miller v. State of Florida, Case No. 5D23-0846, LT Case
No. 2021-CF-4602-A. In its Order, the 5th DCA instructed the trial court to enter a judgment of
not guilty in favor of Miller. Oren Miller was quoted in a news story February 5, 2023 by Ryan
Grim of The Intercept about his time in the Marion County Jail, see,
https://theintercept.com/2023/02/05/ron-desantis-florida-villages-oren-miller/
The last 74 days had been an ordeal. There are about 1,800 people in the county’s lockup
facility; Miller was in a pod with 80, he said, but there were just 56 seats for meals. On
his first day, a jailmate offered to adopt him and get him a seat at meals in exchange for
some of his food, a bargain he eagerly accepted. On the second day, he said, he won
protection from a gang leader. “Oren Miller, you are protected in here because you’re a
senior citizen,” the man said, according to Miller. “‘But understand, don’t cross any
lines.’ … And so I minded my p’s and q’s.” Violence broke out regularly, Miller
recounted, and he watched two men beaten nearly to death. He moved to try to break up
the first fight, but two men held him back, explaining that if he got involved, he’d be
called later as a witness, and you don’t want to be a witness against somebody who
sleeps in the same open room as you. So he let them fight.
Miller went days without his heart or thyroid medication, and grew weak and dizzy.
Complaining of chest pain, he was eventually given an EKG, which the staff told him
showed no problems. “My EKG hasn’t been good in 15 years,” he said. “I will never
have a good EKG. I’ve got an irregular heartbeat all the time.” He said they gave him
medication despite claiming to detect no heart trouble — the same type of heart
medication he’d been prescribed but hadn’t been getting.
His logistics training from Caterpillar came in handy, and he devised a system for the
headcount process which worked so well that the unit’s numbers were correct more often,
meaning they rarely got punished for the wrong count anymore. He could see the guard
coming from a neighboring unit, and Miller would yell “Headcount!”: a signal for the
men to move to the predesignated places to be counted. He taught his jailmates how to
document abuse and negligence when it occurred, so that if they later filed a complaint,
they’d have something to stand it up. When he left the unit for what he hoped would be
the last time, he turned around and yelled to the men: “Headcount!”
23
They all shouted back: “Headcount!”
XI Merchant v. Woods et al, USDC, MDFL, Ocala Div. 5:23-cv-00661-JSM-PRL
On November 6, 2023, Marion County Sheriff Billy Woods was sued in federal court for the
wrongful death of inmate Cory Merchant, see
Merchant v. Woods, et al, U.S. District Court, Middle District of Florida (Ocala),
Case No. 5:23-cv-00661-JSM-PRL
The lawsuit was filed on behalf of Krysti Merchant as Personal Representative for the estate of
Cory Merchant, against Defendant Billy Woods, Sheriff of Marion County, Florida, in his
official capacity, Defendant Justin Kosinski, Deputy, Defendant Joseph Miller, Deputy, and
Defendant Jerome Dukes, Sergeant. The Plaintiff is represented by:
James Murray Slater, Slater Legal PLLC, Tallahassee, FL

Bhavani K. Raveendran, Romanucci & Blandin LLC, Chicago, IL
Sam Harton, Romanucci & Blandin, Chicago, IL 60654
XII Whitley v. Woods et al, USDC MDFL, Ocala Div. 5:23-cv-00684-JSM-PRL
On November 27, 2023, Marion County Sheriff Billy Woods was sued in federal court for the
wrongful death of inmate Scott L. Whitley, III, see,
Whitley v. Woods et al, U.S. District Court, Middle District of Florida (Ocala),
Case No. 5:23-cv-00684-JSM-PRL
The lawsuit was filed on behalf of Pamela C. Whitley, as Personal Representative of the Estate
of Scott L. Whitley, III, on behalf of the Estate, and Scott L. Whitley, Jr. and Margaret M.
Whitley, survivors. against Defendant Billy Woods, in his official capacity as Sheriff of Marion
County, Florida, and the following Defendants:
Defendant: Robert Andrew Walters, Captain

Defendant: Ashleigh Snodgrass, Sargent
Defendant: Arnault Canelle, Corporal
Defendant: Jordon Ortega, Corporal
Defendant: Carl Holmer, Deputy
Defendant: Christopher Kristensen, Deputy
Defendant: Xavier McMiller, Deputy
Defendant: Demontra Smith, Deputy
Defendant: Sa'Quan Wyman, Deputy
The Plaintiff is represented by:
24
Michael Evan Levine, Stewart, Tilghman, Fox & Bianchi, PA, Miami, FL
James Murray Slater, Slater Legal PLLC, Tallahassee, FL
The Ocala Star-Banner published a story by Austin L. Miller on November 29, 2023 that states
in part: Lawsuit blames jail officials for failed practices.
The lawsuit alleges jail staffers were aware that Whitley suffered from significant mental
health issues and should have done more to help him.
In the lawsuit, the lawyers write: "There exist policies and widespread practices at the
Marion County Jail encouraging the wanton use of force and punishment for non-
penological purposes. Those policies also fail to account for mental illness, ensure that
mentally ill detainees are provided adequate treatment, and ensure that detention deputies
engage in crisis intervention or appropriate protocols regarding cell extraction for
prisoners and detainees with mental health issues."
XIII Failure of Gov. Ron DeSantis to provide public records (also MCJ record issues)
My accompanying affidavit of August 18, 2023, Gov. Ron Desantis’ failure to provide public
records, shows on May 18, 2023, I made an online public records request to Gov. DeSantis at
Desantis.OpenGovernment regarding the jail’s AI security system, Agent Video Intelligence
(Agent Vi), headquartered in Israel, and it’s parent company, Irisity AB, as follows:
Please provide records of Governor Ron DeSantis' recent trip to Israel, including an
itinerary, and any contacts with Agent Video Intelligence (Agent Vi), and Irisity AB.
Thank you.
On May 22, 2023, I got an email response from the Office of Open Government stating:
Good morning,
The Governor’s Office of Open Government is in receipt of your request for records as
stated in your email below. If there is a fee associated with your request, you will be
provided with a fee estimate for your review. Thank you for contacting the Executive
Office of the Governor.
Sincerely,
Office of Open Government
No records were provided. On June 8, 2023 I emailed a second request for the records:
To: DeSantis Open Government
25
Second request. This is a Public Records Request, Sections 119.07(1) and 286.011,
Florida Statutes, and Article I, Section 24 of the Florida Constitution. All public records
requests shall be acknowledged promptly and in good faith, F.S. § 119.07(1)(c).
Please provide records of Governor Ron DeSantis' recent trip to Israel, including an
itinerary, and any contacts with Agent Video Intelligence (Agent Vi), and Irisity AB.
Thank you.
On June 9, 2023, I got an email response from the Office of Open Government stating:
Good morning,
The Governor’s Office of Open Government is in receipt of your request for records as
stated in your email below. If there is a fee associated with your request, you will be
provided with a fee estimate for your review. Thank you for contacting the Executive
Office of the Governor.
Sincerely,
Office of Open Government
As of today, Gov. Ron DeSantis’ Office of Open Government has not provided the records I
requested, nor provided any other response. My 3 page public record request email chain with
Gov. Ron DeSantis’ Office of Open Government is attached to the affidavit.
Notably, as of today, Gov. Ron DeSantis’ Office of Open Government has not clamed an
exemption to the public records law with regard to my public records request.
On October 7, 2023, Israel was attached by Hamas, resulting in the 2023 Israel–Hamas war. On
October 13, 2023, the Ocala Star-Banner published a story by Samantha Neely and C. A. Bridges
of the USA TODAY NETWORK - Florida, reporting “DeSantis declared a state of emergency
for Florida over Israel. Here’s what that means”. The news story was linked to Gov. DeSantis’
Executive Order 23-208 (Emergency Management – Impacts of War in Israel). The news story
also stated in part, “According to DeSantis's executive order, these concerns "constitute a major
disaster" and will authorize the leaders of Florida's National Guard and State Guard to activate
their forces "as needed" to respond.”
On October 13, 2023, the New York Times published a story by Patrick Kingsley and Ronen
Bergman, “The Secrets Hamas Knew About Israel’s Military” about a failure in Israel’s security
system. https://www.nytimes.com/2023/10/13/world/middleeast/hamas-israel-attack-gaza.html
On December 2, 2023, the New York Times published a story by Ronen Bergman and Adam
Goldman, “Israel Knew Hamas’s Attack Plan More Than a Year Ago” about prior knowledge.
https://www.nytimes.com/2023/11/30/world/middleeast/israel-hamas-attack-intelligence.html
26
Therefore, it appears Gov. DeSantis’ violation of Florida’s public records law may be a knowing
violation, with malice aforethought, to conceal problems with the AI (Artificial Intelligence)
security system Agent Video Intelligence (Agent Vi), headquartered in Israel, owned by Irisity
AB, that is used by the Marion County Jail. Link to an Irisity press release for Agent Vi:
https://irisity.com/company-investor-relations/press-release/?id=6062D25ECEF09732
Separately I made the following record requests to the MCSO for the Marion County Jail:
June 25, 2023: Records of a letter mailed to Sheriff Woods, MCSO, on or about March 2,
2022 by William Sal Allegra, Inmate #A0258748, from the Marion County Jail.
June 25, 2023: Records of a letter mailed to Mr. Timothy McCourt, General Counsel,
MCSO, by Tyler Noah Dagenhart, Inmate #A0075126, from the Marion County Jail
regarding his request for Kosher meals while incarcerated, or any other matter.
Initially on June 29, 2023, Brittany Colbert, Central Records S.T.A.R Manager, claimed there
were no records responsive to my request.
On July 2, 2023, I responded to Ms. Colbert by email:
You responded “There are no records responsive to your below requests.”
Regarding my request for records of a letter mailed to Sheriff Billy Woods, MCSO, on or
about March 2, 2022 by William Sal Allegra, Inmate #A0258748, from the Marion
County Jail, Mr. Allegra (Bill) showed me the letter, and I read it, and watched it get
mailed from the jail. So what happened to it? Bill is an educated person and a former
corporate executive who wrote to the MCSO about conditions in the jail and its role in
the deprivation of rights of the accused in Marion County.
Regarding my request for records of a letter mailed to Mr. Timothy McCourt, General
Counsel, MCSO, by Tyler Noah Dagenhart, Inmate #A0075126, from the Marion County
Jail regarding his request for Kosher meals while incarcerated, I referred Tyler to Mr.
McCourt after he told me the jail had failed to provide him with Kosher meals after
multiple requests over a nine month period. Tyler told me he was an actively practicing
Messianic Jew, and as I recall, provided a letter from his Rabbi. In the alternative, please
provide all public records regarding the provision of Kosher meals to Tyler Dagenhart by
the jail. Thank you.
On July 6, 2023, Ms. Colberrt provided jail records for Inmate Dagenhart showing his Inmate
Request Form dated May 23, 2021 requesting a Kosher religious diet, and a jail form dated
October 22, 2021 showing his Kosher diet was approved by the chaplain. But no records were
provided of letters by the inmates to Sheriff Woods, or you as general counsel.
27
XIV Conclusion
My PREA complaint against Deputy Suppes led to retribution by deputies of the MCJ who failed
to protect me from Inmate Fields. My PREA complaint was supported by evidence, and a
witness. As set forth in my affidavit, the MCJ failed to contact my witness, then “determined that
it does not rise to the level of PREA sexual harassment.” Under PREA, I believe the misconduct
by Deputy Suppes is considered voyeurism.
The accompanying transcript of my interview with Officer Palau shows I also complained that
earlier in the same shift, Deputy Suppes, and other deputies on duty, failed to respond to an
incident by Inmate Yandel Andino with Inmate Christopher Simmons, and that the jail failed to
protect Inmate Steven Plaza who was severely beaten.
over the welfare of the person and is therefore exclusively responsible for the conditions in
which the inmate is held. Sheriff Woods is responsible for what is described in this letter.
Sincerely,
Neil J. Gillespie
2801 SW College Road, Suite 3
Tel: 352-239-9037
Email: neil.gillespie.wh88@wharton.upenn.edu
Attachments
28
LIST OF EXHIBITS - LETTER DEC-12-2023
TO MCSO GENERAL COUNSEL TIM MCCOURT
A. Facebook page, Rebecca Suppes, pp 1-3

B. PREA Affidavit Neil J. Gillespie
C. Transcript, PREA Interview with Officer Palau
D. Gov. DeSantis PRR Affidavit Neil J. Gillespie
1.a Inmate Request Form, David Posey death threats to Neil J. Gillespie
1.b Incident Report # 230000657, David Posey assault on Robert McGuinness
1.c Inmate booking Robert McGuinness with neck brace
2. PREA Report # 220000936 by Officer Palau
3. Emessage to Gary Lashley, Esq. re PREA complaint
4. Jail mail not sent MCJ Corporal James
5. Incident Report # 220001008 by Deputy Suppes Feb-28-2022
6. DOC 20 USDC MDFL 5:22-cv-00037-RBD-PRL, Marion County Jail Not Safe
7. Gillespie Inmate Request Form for Legal Papers & Diabetic Shoes Jan-26-2023
8. Gillespie Inmate Property Release Form, Feb-02-2023
9. Grievance re Andrew Cunningham, aka
10. Note by F Moon retina provider issues
11. Inmate booking Conrad Degon, and obituary
12. Tyler Dagenhart Kosher diet requests
Also attached separately

Complaint Marion County Jail Inmate Security CORRECTED June 8, 2023
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1
Transcribed in re:
MARION COUNTY SHERIFF’S OFFICE
OCALA, FLORIDA
MCSO INCIDENT REPORT 220000936
IN RE:
NEIL JOSEPH GILLESPIE #A0255941,

PREA Complainant,
Against
REBECCA SUPPES ID#6519, MCSO

a/k/a OFFICER SUPPEN.
_____________________________/
TRANSCRIBED FROM DIGITAL RECORDING
INTERVIEW OF: NEIL JOSEPH GILLESPIE
INTERVIEWER: INVESTIGATOR ISAI PALAU, MCSO

MCJ DETENTION INVESTIGATIONS
LOCATION: Marion County Sheriff’s Office

692 Southwest 30th Avenue
DATE: February 22, 2022
TRANSCRIBED FROM
DOWNLOAD BY: SHELLY L. OWEN, CET
Certified Transcriptionist (AAERT)
AUDIO FILE: Audio of interview with Gillespie

re PREA complaint
OWEN & ASSOCIATES * (352) 624-2258 * owenassocs@aol.com

2
1 February 22, 2022
2 MR. GILLESPIE: On the record, so I have that here.
3 INV. PALAU: Okay. Just tell me, like, what all
4 happened.
5 MR. GILLESPIE: Well, let me just say that I’ve had
6 problems with this officer in the past.
7 INV. PALAU: Hm-hmm.
8 MR. GILLESPIE: When I had COVID-19, I was down in the
9 infirmary. She refused to send out my mail. She said mail
10 spreads COVID. It doesn’t. The medical director down there,
11 Colon told me that COVID is not spread by mail, so we had a
12 problem with that.
13 And then another time, she refused to send my copies to
14 the law library to copy, like my paperwork, my papers. So we
15 had –- when you have a lot of papers to be copied, I send
16 them in a big envelope and attached the request form. She
17 tears everything apart, throws things all around. It seems
18 like she’s on drugs, totally nuts.
20 MR. GILLESPIE: Now, today, last night, February 22nd,
21 Officer Suppen, a female entered (INDISCERNIBLE), early in
22 the morning about 3:00 a.m., and failed to make her officer
23 gender announcement when entering a male ward. I never heard
24 Officer Suppen make an announcement, gender announcement in
25 all the time I’ve been here. I’ve been here since May of

3
1 last year.
2 Obviously, someone took away my uniform shirt and pants
3 that were neatly folded on my wheelchair that was next to my
4 bunk, along with my name tag, a pair of socks, a thermal top
5 I had folded on my wheelchair.
6 I was sleeping in my underwear, when I awoke and, when I
7 reached for my pants, they were gone. Officer Suppen stood
8 in front of me, looking at me in my underwear. It made me
9 feel uncomfortable and vulnerable and violated.
10 I asked her to return my pants and my other items and
11 she refused.
12 Officer Suppen recently finalized a divorce from a man.
13 I believe her (INDISCERNIBLE) violation for my sexual assault
14 is motivated by personal marital, mental problems, resulting
15 (INDISCERNIBLE) her former marriage has caused her to violate
16 the Florida Statute 950.09, Malpractice of Jailers, which is,
17 quote, unquote, guilty of willful inhumanity and oppression
18 to any prisoner under his or her control, care, and custody,
19 end quote. Under Section 950.09, such jailer, quote, shall
20 be punished by removal from office, end quote, for second
21 degree misdemeanor.
22 In my opinion, Suppen is unfit to be an officer,
23 especially in a male dorm. That’s the statement I made
24 (INDISCERNIBLE).
25 INV. PALAU: Okay. Did you have anything else that you

4
1 wanted to add to that?
2 MR. GILLESPIE: There’s a witness, Raul Lopez -- I’m
3 sorry -- Raul Lopez, Number A0254371. He has a bunk near
4 mine and he witnessed the whole thing.
5 But she causes fights and commotion in the dorm, taking
6 these clothes from people. And –-
7 INV. PALAU: So, so it wasn’t just you? She took
8 clothes from other people, too?
9 MR. GILLESPIE: Yes.
11 MR. GILLESPIE: And I know she doesn’t want clothes on
12 the bunk. My clothes were not hanging on the bunk. They
13 were sitting on my wheelchair. And I, and I sleep in my
14 underwear because it’s comfortable. And these pants, I can’t
15 wear them 24 hours a day. And I want them close by, in case
16 I have to use the toilet, I want to be able to put them on.
17 If there’s an emergency, I have to put them on fast to get
18 out of here, I want them ready (INDISCERNIBLE) and that’s the
19 problem.
20 INV. PALAU: Did -- was this another pair of clothes
21 that you had or –-
22 MR. GILLESPIE: I’ve had the pair of pants put away
23 somewhere. This I just got when they made me come out. This
24 is horrible. I take pride in my uniform. I wouldn’t wear
25 this garbage, all right. And because I take pride in my

5
1 uniform, when I find one that fits, I wash it myself. I
2 don’t use a uniform with stains. So these pants -–
3 INV. PALAU: Well, I mean, like your thermal, you said
4 that she took your thermal, but you got one on.
5 MR. GILLESPIE: I had two thermals.
6 INV. PALAU: Oh, so this is another one?
7 MR. GILLESPIE: Yeah, this is a heavier one.
8 INV. PALAU: Okay.
9 MR. GILLESPIE: I had a lighter on, depending on the
10 temperature. And she took that thermal. They’re $8.65. The
11 socks she took were $1.90 from the commissary.
12 INV. PALAU: Okay. And you didn’t get those back, did
13 you?
14 MR. GILLESPIE: No. And I asked for them.
15 INV. PALAU: So did she -– I noticed you said that she
16 doesn’t like when the clothes are hanging on the bed. Did
17 she say something about that earlier in the day, like before?
18 Like, ahead of time, did she say something?
20 INV. PALAU: Oh, okay.
21 MR. GILLESPIE: And I, I took them off at that point.
23 MR. GILLESPIE: (INDISCERNIBLE) other, because I just
24 wear one set, and the other set –- I only had pants. I had
25 another shirt that fit me, because when I was down in the

6
1 infirmary, one of my bunkmates was down there and he gave a
2 shirt, so I gave him one of my good shirts. So that’s what
3 happened to my other good shirt.
4 (INDISCERNIBLE) that the shirt I was wearing and the
5 pants I was wearing and this is my second pair of pants
6 (INDISCERNIBLE).
7 But the pants and the shirts they give me from the
8 uniform exchange, they stink. They’re in bad shape. When I
9 get a good shirt, I hang onto it and wash it myself.
10 INV. PALAU: Okay, so you’re, you’re reason for calling
11 the tip line is because you felt like, because she was
12 standing there in front of you and you were in your
13 underwear, you felt like that was some kind of sexual thing
14 or –-
15 MR. GILLESPIE: I felt uncomfortable about it. And she
16 was standing there, leering and, you know, not moving on, and
17 that’s what the witness said, too. And she came up in the
18 (INDISCERNIBLE) and approached me. Actually, I think he said
19 something (INDISCERNIBLE) the groin or genital area. I just
20 noticed someone standing there, you know.
21 And I tried to reason with her to get my clothes back,
22 and she just (INDISCERNIBLE).
23 INV. PALAU: She just, she was standing there in front
24 of your bunk?
25 MR. GILLESPIE: I was on one side of the bunk with my

7
1 wheelchair and she was on the other side of my bunk. She had
2 come down the aisle, behind my bunk, and came around the
3 corner, and was standing right next to my bunk.
4 INV. PALAU: Just standing there, staring at you?
6 INV. PALAU: Okay. And you said that somebody else said
7 that they saw her looking at you. But you didn’t see her
8 looking at your groin or anything like that, did you?
9 MR. GILLESPIE: Well, I was focused on her face.
10 INV. PALAU: Well, that’s what I mean. You would have
11 been looking at her like you’re looking at me.
12 MR. GILLESPIE: Yeah.
13 INV. PALAU: So you would notice if I was, like, looking
14 at your kneecap, you know what I’m saying, because I wouldn’t
15 be looking at you in your eye.
16 MR. GILLESPIE: I’m blind in one eye and I didn’t have
17 my glasses on. It was, you know, 3:00 in the morning.
19 MR. GILLESPIE: I’m really not the best witness.
20 INV. PALAU: But, well, I mean, you were closest to her,
21 right?
23 INV. PALAU: But you didn’t notice anything?
24 MR. GILLESPIE: I noticed her looking at me.
25 INV. PALAU: Looking at you. Like your face?

8
1 MR. GILLESPIE: Like my whole body.
2 INV. PALAU: Okay. Okay, well, you know, we got video
3 cameras in there, so I’ll have to go back and look at the
4 video cameras and all that.
5 MR. GILLESPIE: And I’ll tell you what really bugs me
6 about this. Earlier in the night –- this was the 22nd in the
7 morning –- but on the 21st, right, when she was on duty,
8 there was a fight in there, okay, and there’s a bully in
9 there, and he’s beating up a one-legged man, and he’s lying
10 there and he’s (INDISCERNIBLE) wheelchair, in front of the
11 wheelchair right there. Just had his leg cut off in January
12 and he’s just come over here.
13 This guy, he was on the phone, and this bully comes up
14 and started beating the crap out of him, and he’s a large,
15 (INDISCERNIBLE). This guy was really taking a pounding. And
16 why don’t they come and break those fights up? If they’re
17 going to come in and cause trouble -–
18 INV. PALAU: Nobody, nobody came in at all?
19 MR. GILLESPIE: No.
20 INV. PALAU: And you said that was on the 22nd –- on the
21 21st?
22 MR. GILLESPIE: That was on the 21st and it was after
23 the supper count, so it was after, like, 6:30. It was nearly
24 (INDISCERNIBLE), I would say before 9:00, between like 6:30
25 and 9:00. And this poor guy is getting the crap beat out of

9
1 him.
2 And, you know, the rule in here is no people involved in
3 fights or (INDISCERNIBLE) fighting. And the guy that they
4 were beating up, he held his own, but I thought it was wrong.
5 And this guy that caused the trouble, he beat up other people
6 in here.
7 INV. PALAU: But let me ask you this. Do you know who
8 the guys were that were involved? Do you know their names?
9 MR. GILLESPIE: I don’t know the guy that was missing a
10 leg, but he’s easy (INDISCERNIBLE) because he’s the only one
11 with a completely cut off (INDISCERNIBLE) wheelchair, and red
12 suits on.
13 INV. PALAU: Right. And that, that’s the guy that you
14 said has the leg problem?
15 MR. GILLESPIE: Right.
17 MR. GILLESPIE: (INDISCERNIBLE). And the other guy, his
18 name is something like Yulando Adrena (phonetic).
19 INV. PALAU: What is it?
20 MR. GILLESPIE: Yulando Adrena. Something like that.
21 And he’s, he beat up Plasma (phonetic). There’s an inmate
22 Plasma (INDISCERNIBLE). And Plasma’s been complaining to the
23 health department about it. Plasma has -– he’s missing an
24 eye. He wears an eyepatch. And he beat the crap out of him
25 in the shower, okay.

10
1 And I happened to be in court with him one day. The
2 reason he’s in here, he was beating up a pregnant woman on
3 the outside. The guy’s a real thug. He’s 23 years old.
4 He’s always looking to fight. His arm is wrapped up, his arm
5 is wrapped up in a bandage, but he seems (INDISCERNIBLE) beat
6 people up pretty easy. He shouldn’t be in here. They’ve
7 taken him out a couple of times and he should be in the
8 regular population, where he can pick on people his own size
9 and his own character, because he’s a menace.
11 MR. GILLESPIE: But she wouldn’t come in for that.
12 And the other one there, Frye, Officer Frye. He’s
13 another useless liar. They will do anything to cause
14 trouble, the two of them.
15 INV. PALAU: Okay. I’m going to, I’m going to get back
16 with you, okay? We’ll pull the video and we’ll see, you
17 know, what all comes of it, okay?
18 MR. GILLESPIE: I’d pull the video from (INDISCERNIBLE).
19 It’ll be right by the telephones, where the telephones are.
20 INV. PALAU: I will.
21 MR. GILLESPIE: All right.
22 INV. PALAU: Okay?
23 MR. GILLESPIE: Thank you, sir.
24 INV. PALAU: You’re welcome.
25 MR. GILLESPIE: I appreciate it.

11
1 INV. PALAU: No problem.
2 (Recording ends.)

12
TRANSCRIPTIONIST’S CERTIFICATE
I, SHELLY L. OWEN, Transcriptionist, certify that I

was authorized to do and did transcribe from digital
recording the interview of NEIL GILLESPIE, recorded on
February 22, 2022, and that the transcript is a true and
correct record of the proceedings recorded to the best
of my ability.
I FURTHER CERTIFY that I am not a relative,

employee, attorney or counsel of any of the parties, nor
am I a relative or employee of any of the parties’
attorney or interested in the action.
DATED this 26th day of September, 2022, at Ocala,

Marion County, Florida.
/slo-534/
SHELLY L. OWEN, CET (AAERT)
CERTIFIED TRANSCRIPTIONIST
OWEN & ASSOCIATES
Post Office Box 157
(352) 624-2258

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Case 5:22-cv-00037-RBD-PRL Document 20 Filed 05/31/22 Page 1 of 10 PageID 640
UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF FLORIDA
OCALA DIVISION
NEIL JOSEPH GILLESPIE,

Plaintiff,
v. Case No. 5:22-cv-37-RBD-PRL
MARION COUNTY JAIL,

Defendant.
________________________________________/
NOTICE OF FILING: MARION COUNTY JAIL NOT SAFE

FOR INMATE NEIL GILLESPIE
Plaintiff NEIL JOSEPH GILLESPIE (“Gillespie”), a nonlawyer appearing pro se, gives
Notice of Filing: Marion County Jail Not Safe for Inmate Neil Gillespie, and states:
1. While held in the Marion County Jail on February 28, 2022, Inmate Gillespie sent two
text messages to his brother Mark stating that he was not safe in the jail, and asked Mark to relay
the message to the U.S. Attorney’s Office in Tampa, Florida.
2. On March 1, 2022, Mark sent the email appearing at Exhibit 1 that states as follows:
yahoo <celticein@yahoo.com>
To: USAFLM.State.Foreclosures@usdoj.gov <usaflm.state.foreclosures@usdoj.gov>,
USAFLM.HUD.Disclaimers@usdoj.gov <usaflm.hud.disclaimers@usdoj.gov>,
USAFLM.HUD@usdoj.gov <usaflm.hud@usdoj.gov>
Cc: gary@lashleylaw.com <gary@lashleylaw.com>,
Tim McCourt <tmccourt@marionso.com>

Tampa, FL 33602
Dear AUSA Colleen Murphy Davis: I am sending a message relayed by my brother, Neil
Gillespie, who is incarcerated at the Marion County Jail in Ocala Florida. Below is his
message that he sent via text to me:
"I am at risk of harm in the Marion County Jail and request your help with pretrial release
or transfer to another facility. Last night Officer R. Suppen, #6519, committed battery on
me in violation of Fla. Stat. 784.03.1A1. Inmate Hopkins witnessed Suppen's battery on

me at 10:45 PM, Feb-27-2022.
Officer Suppen harassed me prior to her battery on me in retribution for complaints I

made against her on Feb-22-2022. Last night Officer Suppen committed battery on me as
I sat in my wheelchair when she grabbed my left arm, causing me pain. After the battery,
I asked to call legal counsel and was denied. I invoked my Fifth Amendment right not to
speak with Suppen and she threatened me with arrest.
Suppen took all my legal files, stamps and envelopes, my mattress, sheets, blanket,
clothing, etc. Several hours later Suppen returned the items, but kept half of my legal
files, citing a fire risk, and sent the legal files to property.
Separately, the Sheriff's general counsel Tim McCourt wrongly accused me of violating
Federal Election Law relative to a quit claim deed transferring my home to my campaign
in 2019, see https/neil2020.blogspot.com/
McCourt also forbade me from calling the property "my home". My campaign is a
federally protected activity under 18 USC 245(b)(1)(a). I want Mr. McCourt and Officer
Suppen charged with their crimes against me. Thank you. "
Sincerely,
/s/
3290 NW 10th Street
Ocala, FL 34475
Inmate ID: A0255941
3. On March 7, 2022 the U.S. Attorney’s Office, MDFL, responded by email. (Exhibit 2)
Gulick, Jennifer (USAFLM) [Contractor] <jennifer.gulick@usdoj.gov>

To: celticein@yahoo.com <celticein@yahoo.com>
Thank you for your request. We strive to address all issues and we will let you know
when your request has been processed.
An investigation has not been opened at this time.
Due to the high volume of requests and limited resources, we cannot guarantee a
resolution to every request.
If you have any additional information that you think will help us to assist you, please
feel free to reply to this email or contact us by phone 813-274-6095.
2
We appreciate your time and attention in the matter and will get back to you as soon as
possible.
Sincerely,
United States Attorney’s Office, MDFL
Civil Division
If you have general questions about Civil Rights and the Middle District of Florida, you
can find useful information on our website:
https://www.justice.gov/usao-mdfl/civil-rights
Here are some important links that may provide you with additional information or
resources.
Bay Area Legal Services: https://bals.org/
Florida Bar Association: https://www.floridabar.org/
Florida Commission of Human Rights: https://fchr.myflorida.com/
4. After Gillespie’s release from jail on April 7, 2022, on his own recognizance (ROR), the
Marion County Sheriff’s Office sent Gillespie a letter dated April 20, 2022, by U.S. Certified
Mail, article number 9214 8901 9403 8300 0073 7806 93. (Exhibit 3). The letter states in part:
Case Number: MCSO19OFF028054
Name: NEIL GILLESPIE

Address: 8092 SW 115th LOOP, OCALA, FL. 34481
Date: 4-20-22
Dear Sir or Madam,
Upon your release from the Marion County Jail, the following items were left behind.
LEGAL PAPERWORK
Please pick these items up by 5-20-2022. If they are not picked up by the listed date, they
will be disposed of.
This letter will be your authorization to take custody of the above listed property.
(signed)______________
Classifications Supervisor
3
5. The “LEGAL PAPERWORK” the jail claims was left behind was actually Gillespie’s
legal files taken by Officer R. Suppen, #6519, on February 27, 2022. It is unclear whether the jail
actually returned all of Gillespie’s legal files. It is also impossible to determine whether the jail
read Gillespie’s legal files it had in its possession for at least 52 days.
RESPECTFULLY SUBMITTED MAY 31, 2022.
NEIL JOSEPH GILLESPIE, Plaintiff pro se

11100 SW 93rd Court Rd.
Suite 10-220
Ocala, FL 34481-5188
Phone: 352-239-9037
CERTIFICATE OF SERVICE
I HEREBY CERTIFY Notice of Filing: Marion County Jail Not Safe for Inmate Neil
Gillespie was emailed May 31, 2022 to the Clerk, on the Court’s Coronavirus and Email Filing
Information page, https://www.flmd.uscourts.gov/coronavirus-and-email-filing-information
United States District Court

Office of the Clerk
207 N.W. Second Street, Room 337
Ocala, Florida 34475-6666
Signed:
NEIL JOSEPH GILLESPIE
4
Verification
I, Neil Joseph Gillespie, declare as follows:
1. I am the Plaintiff in the present case and a citizen of the United States of America, and of
the State of Florida.
2. I have personal knowledge of myself, my activities, and my intentions, including those
set out in the foregoing Notice of Filing: Marion County Jail Not Safe for Inmate Neil Gillespie,
and if called on to testify I would competently testify as to the matters stated herein.
3. I verify under penalty of perjury that the foregoing is true and correct. 28 U.S.C. §
1746(2).
Executed on May 31, 2022.

5/31/2022 Case 5:22-cv-00037-RBD-PRL Document
Marion County 20for Inmate
Jail Not Safe FiledNeil
05/31/22 Page
Gillespie - Yahoo Mail 6 of 10 PageID 645
Marion County Jail Not Safe for Inmate Neil Gillespie Yahoo Mail/0 0 U.S. COURTS...
yahoo <celticein@yahoo.com> Mar 1 at 7:25 PM

To: USAFLM.State.Foreclosures@usdoj.gov <usaflm.state.foreclosures@usdoj.gov>,
USAFLM.HUD.Disclaimers@usdoj.gov <usaflm.hud.disclaimers@usdoj.gov>,
USAFLM.HUD@usdoj.gov <usaflm.hud@usdoj.gov>
Cc: gary@lashleylaw.com <gary@lashleylaw.com>, Tim McCourt <tmccourt@marionso.com>

Tampa, FL 33602
Dear AUSA Colleen Murphy Davis: I am sending a message relayed by my brother, Neil Gillespie, who is incarcerated at the
Marion County Jail in Ocala Florida. Below is his message that he sent via text to me:
"I am at risk of harm in the Marion County Jail and request your help with pretrial release or transfer to another facility. Last
night Officer R. Suppen, #6519, committed battery on me in violation of Fla. Stat. 784.03.1A1. Inmate Hopkins witnessed
Suppen's battery on me at 10:45 PM, Feb-27-2022.
Officer Suppen harassed me prior to her battery on me in retribution for complaints I made against her on Feb-22-2022. Last
night Officer Suppen committed battery on me as I sat in my wheelchair when she grabbed my left arm, causing me pain.
After the battery, I asked to call legal counsel and was denied. I invoked my Fifth Amendment right not to speak with Suppen
and she threatened me with arrest.
Suppen took all my legal files, stamps and envelopes, my mattress, sheets, blanket, clothing, etc. Several hours later Suppen
returned the items, but kept half of my legal files, citing a fire risk, and sent the legal files to property.
Separately, the Sheriff's general counsel Tim McCourt wrongly accused me of violating Federal Election Law relative to a quit
claim deed transferring my home to my campaign in 2019, see https/neil2020.blogspot.com/
McCourt also forbade me from calling the property "my home". My campaign is a federally protected activity under 18 USC
245(b)(1)(a). I want Mr. McCourt and Officer Suppen charged with their crimes against me. Thank you. "
Sincerely,
/s/
3290 NW 10th Street
Ocala, FL 34475
Inmate ID: A0255941
https://mail.yahoo.com/b/folders/145/messages/AGlhR854_qtWYh65hwZc6MsjpQU?.src=ym&folderType=USER&offset=0&unblockNow=false&action=printMes… 1/1
5/31/2022 Case 5:22-cv-00037-RBD-PRL
RE: [EXTERNAL]Document 20Not Filed
Marion County Jail 05/31/22
Safe for Inmate Page
Neil Gillespie 7 of
- Yahoo Mail10 PageID 646
RE: [EXTERNAL] Marion County Jail Not Safe for Inmate Neil Gillespie Yahoo Mail/0 0 U.S. COURTS...
Gulick, Jennifer (USAFLM) [Contractor] <jennifer.gulick@usdoj.gov> Mar 7 at 9:33 AM

To: celticein@yahoo.com <celticein@yahoo.com>
Good Morning,
Thank you for your request. We strive to address all issues and we will let you know when your request has been processed.
An investigation has not been opened at this time.
Due to the high volume of requests and limited resources, we cannot guarantee a resolution to every request.
If you have any additional information that you think will help us to assist you, please feel free to reply to this email or contact us by phone 813-274-6095.
We appreciate your time and attention in the matter and will get back to you as soon as possible.
Sincerely,
United States Attorney’s Office, MDFL
Civil Division
If you have general questions about Civil Rights and the Middle District of Florida, you can find useful information on our website:
https://www.justice.gov/usao-mdfl/civil-rights
Here are some important links that may provide you with additional information or resources.
Bay Area Legal Services: https://bals.org/
Florida Bar Association: https://www.floridabar.org/
2
Florida Commission of Human Rights: https://fchr.myflorida.com/
From: yahoo <celticein@yahoo.com>

Sent: Tuesday, March 1, 2022 7:26 PM
To: USAFLM-State Foreclosures <USAFLM.State.Foreclosures@usa.doj.gov>; USAFLM-HUD Disclaimers <usafllm.hud.disclaim@usa.doj.gov>; USAFLM-HUD
<usaflm.hud@usa.doj.gov>
Cc: gary@lashleylaw.com; Tim McCourt <tmccourt@marionso.com>
Subject: [EXTERNAL] Marion County Jail Not Safe for Inmate Neil Gillespie

Tampa, FL 33602
Dear AUSA Colleen Murphy Davis: I am sending a message relayed by my brother, Neil Gillespie, who is incarcerated at the
Marion County Jail in Ocala Florida. Below is his message that he sent via text to me:
"I am at risk of harm in the Marion County Jail and request your help with pretrial release or transfer to another facility. Last
night Officer R. Suppen, #6519, committed battery on me in violation of Fla. Stat. 784.03.1A1. Inmate Hopkins witnessed
Suppen's battery on me at 10:45 PM, Feb-27-2022.
Officer Suppen harassed me prior to her battery on me in retribution for complaints I made against her on Feb-22-2022. Last
night Officer Suppen committed battery on me as I sat in my wheelchair when she grabbed my left arm, causing me pain.
After the battery, I asked to call legal counsel and was denied. I invoked my Fifth Amendment right not to speak with Suppen
and she threatened me with arrest. Suppen took all my legal files, stamps and envelopes, my mattress, sheets, blanket,
clothing, etc. Several hours later Suppen returned the items, but kept half of my legal files, citing a fire risk, and sent the legal
files to property. Separately, the Sheriff's general counsel Tim McCourt wrongly accused me of violating Federal Election Law
relative to a quit claim deed transferring my home to my campaign in 2019, see https/neil2020.blogspot.com/ McCourt also
forbade me from calling the property "my home". My campaign is a federally protected activity under 18 USC 245(b)(1)(a). I
want Mr. McCourt and Officer Suppen charged with their crimes against me. Thank you. " Sincerely, /s/ Neil Joseph Gillespie
Marion County Jail, Med-B, 108-B 3290 NW 10th Street Ocala, FL 34475 Inmate ID: A0255941
https://mail.yahoo.com/b/folders/145/messages/AJ7QvWZT2DrsYiYXsQcQmLENsss?.src=ym&folderType=USER&offset=0&unblockNow=false&action=printMe… 1/1
3
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Filing # 188620887 E-Filed 12/23/2023 09:51:27 PM

IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT

DEFENDANT’S NOTICE OF FILING MARION COUNTY JAIL COMPLAINT

Notice of Filing Marion County Jail Complaint, and states:

in which the inmate is held.

an extremely dangerous situation in Med C which was essentially a psychiatric ward.

distracted by their computers or other tasks.

Agent Vi, Comprehensive AI-Powered Video Analytics, version 30-Nov-2021. Purchase

Irisity AB. Irisity AB is a company headquartered in Israel.

13. Information about innoVi Genetec Integration by Agent Vi is available online.

When: Analytics Event - Person Moving Occurs

detention deputies, and the failed AI security system.

v. Maryland, 373 U.S. 83 (1963).

is attached to this Notice of Filing Marion County Jail Complaint.

Steven Plaza, Inmate ID A0259320, who was severely beaten.

glorifies bank robbery.

Deputy Suppes’ public Facebook page

These images may affect the reputation

Section/Page TABLE OF CONTENTS

A supplemental report by Deputy Suppes responds to my complaint about her removing

Retribution by officers is also a problem in the Marion County Sheriff’s Office. My

inmate legal papers. The complaint states in part:

Gillespie v. Federal National Mortgage Association (FNMA) a.k.a. Fannie Mae,

Incident Report #220001008 by Deputy Suppes states in part:

my legal paperwork. While paper is flammable, it is not subject to spontaneous

by Securus Technologies. Apparently no officers were present to prevent this fire.

County Jail, Doylestown, Pennsylvania. The complaint states in part:

MCJ, see, https://theintercept.com/2023/02/05/ron-desantis-florida-villages-oren-miller/ Inmate

They all shouted back: “Headcount!”

copy of the complaint in Merchant v. Woods et al appears in Appendix 2.

copy of the complaint in Whitley v. Woods et al appears in Appendix 3.

40 Section XIV of the complaint to Mr. McCourt, Conclusion, states:

The accompanying transcript of my interview with Officer Palau shows I also

RESPCTFULLY SUBMITTED December 23, 2023.

NEIL JOSEPH GILLESPIE, Defendant pro se

Rebecca Rock McGuigan, Bureau Chief State Attorney’s Office

Neil Joseph Gillespie, Defendant pro se

RE: Deputy Rebecca Suppes, ID #6519

RE: PREA Complaint; Ongoing Failure to Protect MCJ Inmates

Deputy Suppes’ public Facebook page

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Section/Page TABLE OF CONTENTS

II. Failure to provide adequate storage for inmate legal papers

To: Colleen Murphy Davis, Assistant U.S. Attorney

Officer Suppen harassed me prior to her battery on me in retribution for complaints I

DOC 20 states at paragraphs 4 and 5:

Case Number: MCSO19OFF028054

Dear Sir or Madam,

Gillespie v. Federal National Mortgage Association (FNMA) a.k.a. Fannie Mae,

III. Fire risk in the Marion County Jail, Ocala, Florida

Incident Report #220001008 by Deputy Suppes states in part:

IV Inmate security in the Bucks County Jail, Doylestown, Pennsylvania

In my complaint to you of June 8, 2023, I noted the following:

Comprehensive Retinal Consultants is located at 5353 SW College Rd, Ocala, FL 34474

I fax a referral and note to Vitreo Retinal Assoc as requested an I

NOTICE OF FILING TRANSCRIPT OF MOTIONS HEARING JANUARY 20, 2021

V. Stabbing of Christopher Simmons, Inmate ID A0090737 Pennsylvania

5 MR. GILLESPIE: And I’ll tell you what really bugs me

MCJ Inv. Palau interview transcript Feb-22-2022, page 9:

17 MR. GILLESPIE: (INDISCERNIBLE). And the other guy, his

The transcript of my interview with Officer Palau on Feb-22-2022 continues on page 9:

21 And he’s, he beat up Plasma (phonetic). There’s an inmate

VI. Beating of Steven Plaza, Inmate ID A0259320

VII. Battery on Robert McGuinness, Inmate ID A0220591

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