Google Lawsuit First Amended Complaint

Filing # 195700282 E-Filed 04/08/2024 02:18:51 PM
MARION COUNTY CIRCUIT COURT

FIFTH JUDICIAL CIRCUIT, FLORIDA
LAWSUIT
Gillespie v. Google
NEIL J. GILLESPIE,
Plaintiff,
Case Number: 2024-CA-0209
vs. JURY TRIAL DEMANDED
ALPHABET INC., a Foreign Profit Corporation,

GOOGLE LLC, a Foreign Limited Liability Company,
VERIZON COMMUNICATIONS, INC., a Foreign
Profit Corporation,
VERIZON WIRELESS SERVICES, LLC, a Foreign
Limited Liability Company,
TRACFONE WIRELESS, INC., a Foreign Profit
Corporation,
Defendants.
______________________________________/
FIRST AMENDED COMPLAINT
Plaintiff pro se Neil J. Gillespie, a nonlawyer, pursuant to Rule 1.190(a) and (c), files his
First Amended Complaint, and states:
1. On February 1, 2024 the Plaintiff sued the Defendants to recover possession of property
located Marion County, Florida.
2. On February 7, 2024 the Clerk issued summonses for all the Defendants.
3. On February 8, 2024 the Plaintiff moved pursuant to Fla. Stat. sec. 78.065(1) for a writ of
replevin against the Defendants Alphabet, Inc., and Google LLC, or in the alternative, for an
order to show cause to serve on all the Defendants. (sec. 78.065(2)). Under sec. 78.065(1) “The
court without delay shall examine the complaint filed; and, if on the basis of the complaint and
further showing of the plaintiff in support of it the court finds that the defendant has waived in
accordance with s. 78.075 his or her right to be notified and heard, the court shall promptly issue
an order authorizing the clerk of the court to issue a writ of replevin.”

First Amended Complaint
4. The Court failed to act under sec. 78.065(1) or sec. 78.065(2), or on any other basis.
5. On February 28, 2024, Attorneys for Alphabet Inc. and Google LLC removed this case to
federal court: U.S. District Court, Middle District of Florida, Ocala Division, Case No. 5:24-cv-
101-MMH-PRL. Damon J. Whitaker, Esq., Florida Bar No. 0923591, and Ezequiel Romero,
Esq., Florida Bar No. 107216, each of the firm BRYAN CAVE LEIGHTON PAISNER LLP,
appear as Attorneys for Alphabet Inc. and Google LLC on the Notice of Removal.
6. On March 21, 2024 in Case No. 5:24-cv-101-MMH-PRL the Plaintiff moved for a writ of
replevin against Defendants Alphabet Inc. and Google LLC, or in the alternative, for an order to
show cause to serve on all the Defendants.
7. On March 26, 2024 the U.S. district court remanded the case back to this court.
8. On March 29, 2024 the Plaintiff filed in this court, “Plaintiff’s Notice of Remand and
Pending Amended Motion for Writ of Replevin”, Filing # 195093686 E-Filed 03/29/2024.
9. On March 29, 2024 the Plaintiff filed in this court “Plaintiff’s Notice of Filing Proof of
Service of Process on the Defendants”, Filing # 195094139 E-Filed 03/29/2024.
10. Defendant Google LLC has not filed its 2024 Foreign Limited Liability Company Annual
Report with the Florida Secretary of State. Pursuant to sec. 605.0714 Florida Statutes, the
department may dissolve a limited liability company administratively.
11. Henceforth, pursuant to sec. 48.062 Florida Statutes, the Plaintiff will serve the office of
the Florida Secretary of State court documents for Google LLC to the Department of State
Agency Clerk Jenna McLanahan at Email: DOS.GeneralCounsel@DOS.MyFlorida.com, as well
as to Damon J. Whitaker, FL Bar No. 0923591 and Ezequiel Romero, FL Bar No. 107216.
12. As of the date and time of the filing of this First Amended Complaint, Gregory C.
Harrell, FL Bar No. 173975, Marion County Clerk of Court and Comptroller, has not complied
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with the Order of the U.S. district court March 26, 2024 remanding this case to the “Circuit
Court of the Fifth Judicial Circuit in and for Marion County Florida.” The Clerk has not
reopened the remanded case in this court, case no. 2024-CA-0209.
13. The failure of the Clerk to remand this case as ordered by the U.S. district court violates
the Plaintiff’s speech and redress rights under the FIRST AMENDMENT, U.S. Constitution:
Congress shall make no law respecting an establishment of religion, or prohibiting the

free exercise thereof; or abridging the freedom of speech, or of the press; or the right of
the people peaceably to assemble, and to petition the Government for a redress of
grievances.
14. The failure of the Court to act under sec. 78.065(1) or sec. 78.065(2), or any other basis
violated the Plaintiff’s speech redress rights under the FIRST AMENDMENT, U.S.
Constitution.
15. The Court and Clerk have deprived the Plaintiff of his civil rights, and did so in support
of, or in combination with, the Defendants, in violation of 42 U.S.C. § 1983:
42 U.S.C. § 1983 - Civil action for deprivation of rights

Every person who, under color of any statute, ordinance, regulation, custom, or usage, of
any State or Territory or the District of Columbia, subjects, or causes to be subjected, any
citizen of the United States or other person within the jurisdiction thereof to the
deprivation of any rights, privileges, or immunities secured by the Constitution and laws,
shall be liable to the party injured in an action at law, suit in equity, or other proper
proceeding for redress, except that in any action brought against a judicial officer for an
act or omission taken in such officer’s judicial capacity, injunctive relief shall not be
granted unless a declaratory decree was violated or declaratory relief was unavailable.
For the purposes of this section, any Act of Congress applicable exclusively to the
District of Columbia shall be considered to be a statute of the District of Columbia.
Count I: REPLEVIN, Fla. R. Civ. P. Form 1.937
16. Defendants Alphabet Inc. and Google LLC (collectively “Google”) have wrongly
detained the Plaintiff’s property, his Google Account, neilgillespie@mfi.net, the Neil Gillespie
Blooger user profile, blogger.com/profile/12580744990628852454, and his blogs, including the
following domains:
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Neil 2020 blog, neil2020.blogspot.com

Justice Network blog, nosueorg.blogspot.com
Music and Video - Election 2020 blog, music4life2.blogspot.com
and the Neil Gillespie YouTube channel: @neilgillespie4184. Google has also wrongly detained
the Plaintiff’s Account dissolvetfb@gmail.com and blog domain http://dissolvetfb.blogspot.com/
17. Defendants Verizon Communications Inc., Verizon Wireless Services LLC, and Tracfone
Wireless Inc. (collectively “Verizon”) have wrongly detained the Plaintiff’s Google Account
recovery phone #352-615-3819, and Plaintiff’s current account for #352-850-5009.
18. To the best of Plaintiff’s knowledge, information, and belief, the value of the property is
$136,650, determined as follows:
A. The Plaintiff’s Google Account, neilgillespie@mfi.net: $138,500, including the Neil
Gillespie Blogger profile with his blogs, and the Neil Gillespie YouTube channel:
• Neil 2020 blog, neil2020.blogspot: $13,800

• Justice Network blog, nosueorg.blogspot: $104,000
• Music and Video - Election 2020 blog, music4life2.blogspot: $18,200
• Neil Gillespie YouTube channel @neilgillespie4184: $500
• Account dissolvetfb@gmail.com and http://dissolvetfb.blogspot.com/: $2,000
B. The telephone number 352-615-3819: $136,650
C. The Plaintiff’s current Tracfone account for 352-850-5009: $149.96
19. A. The Plaintiff is entitled to the possession of his Google Account
neilgillespie@mfi.net, Neil Gillespie Blooger user profile, including the Neil 2020 blog, the
Justice Network blog, the Music and Video - 2020 Election blog, the Neil Gillespie YouTube
channel, the Plaintiff’s Google Account dissolvetfb@gmail.com and blog domain
http://dissolvetfb.blogspot.com/ his intellectual property under the Google Terms of Service
(“Google TOS”) January 5, 2022, a copy of which appears at Appendix A to the Complaint for
Replevin.
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B. The Plaintiff is entitled to the possession the telephone number 352-615-3819 under a
Retail Installment Contract with Verizon Wireless Services LLC dated November 29, 2022, a
copy of which appears at Appendix B to the Complaint for Replevin.
C. The Plaintiff is entitled to the possession of his current Tracfone account for 352-850-
5009 under a Tracfone 1 Year and 400 minutes phone card activated November 3, 2023.
20. The property is wrongfully detained by the Defendants in the following particulars:
A. Google came into possession of the Plaintiff property each time he opened a Google
Account: #1 neilgillespie@mfi.net, #2 dissolvetfb@gmail.com. To the Plaintiff’s best
knowledge, information, and belief, Google detains the property because it cannot be sure the
accounts belong to the Plaintiff, Neil J. Gillespie. Separately and in addition, the timing and
circumstances of Google’s wrongful detainer of the Plaintiff’s property shows a prior restraint on
political speech, and election interference, under the laws and constitution of Florida, and of the
United States. (Appendix C to the Complaint for Replevin).
B. Verizon is in breach of a Retail Installment Contract with the Plaintiff November 29,
2022, to port his former pre-paid Tracfone number 352-615-3819 to a new post-paid Moto G
Pure Verizon wireless phone. (Appendix B, Complaint for Replevin). The Plaintiff’s phone no.
352-615-3819 is his recovery phone for his Google Account neilgillespie@mfi.net. TracFone
Wireless, Inc. is owned by Verizon, and all Tracfone brands are now a part of the Verizon
family. To the Plaintiff’s best knowledge, information, and belief, Verizon detained his phone
number 352-615-3819, then failed to port the number to a new wireless device, preventing him
from getting a verification code from Google sent to 352-615-3819, a verification code needed to
access his Google Account neilgillespie@mfi.net. Without the verification code, Google claims
it cannot be sure Google Account neilgillespie@mfi.net belongs to the Plaintiff, Neil J. Gillespie.
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C. Verizon refused the Plaintiff possession of his current Tracfone account for 352-850-
5009 under a pre-paid “365-DAY PLAN” activated on November 3, 2023. The Tracfone #352-
850-5009 makes and receive texts and calls, but the Plaintiff cannot log into his account because
Tracfone claims “We are unable to validate the information you provided.” The Plaintiff
obtained a pre-paid 365-DAY PLAN for the purpose of managing his online accounts, including
Google and its services Gmail, Blooger and YouTube; and also X (formerly Twitter), Yahoo,
Scribd, Facebook, and others.
21. On August 20, 2023 the Plaintiff got an email from Google, “Updating our Google
Account inactivity policy”. The essence of the policy, “This change starts rolling out today and
will apply to any Google Account that’s been inactive, meaning it has not been signed into or
used within a two-year period. An inactive account and any content in it will be eligible for
deletion from December 1, 2023.” The Plaintiff will forever loose his intellectual property
because he cannot sign into or use his Google, Blogger, or YouTube accounts.
22. On August 15, 2023 the Plaintiff got an email from Google announcing Squarespace
recently announced that it entered into an agreement to purchase all domain name registrations
and related customer accounts from Google Domains. The Google Official Site - Google
Domains page announced “On September 7, 2023 Squarespace acquired all domain registrations
and related customer accounts from Google Domains”. A Google Domains Help page announced
“When you buy and register a domain through Google Domains, you must be signed in to a
Google Account that you’ll use to manage your domain. The Plaintiff is unable to login to
Squarespace because he cannot sign into his Google Account neilgillespie@mfi.net because
Google claims it cannot be sure the account belongs to the Plaintiff, Neil J. Gillespie.
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23. On January 20, 2024 the Plaintiff got an email from the Verizon Class Action Settlement
Administrator informing him that a proposed settlement has been reached in a class action
lawsuit regarding his prior Verizon post-paid wireless account for 352-239-9037:
Esposito et al. v. Cellco Partnership d/b/a Verizon Wireless

Docket No. MID-L-6360-23
Superior Court of the State of New Jersey
The lawsuit claimed that Cellco Partnership d/b/a Verizon Wireless (“Verizon”) charged a
monthly Administrative Charge and/or Administrative and Telco Recovery Charge (collectively,
“Administrative Charge”) on Verizon post-paid individual consumer wireless accounts that was
unfair and not adequately disclosed. The Settlement Class, including the Plaintiff in this case,
Neil Gillespie, is represented by the law firm DeNittis, Osefchen, Prince, P.C., and the law firm
Hattis & Lukacs. Verizon is represented by the law firm Faegre Drinker Biddle & Reath, and the
law firm Quinn Emanuel Urquhart & Sullivan, LLP. On January 23, 2024, Settlement Class
member Neil Gillespie gave written notice to the Verizon Administrative Charge Settlement
Administrator to opt-out, to be excluded from the Settlement Class in the lawsuit.
24. ICANN, the Internet Corporation for Assigned Names and Numbers, is a global
multistakeholder group and nonprofit organization incorporated in the state of California and
responsible for coordinating the maintenance and procedures of databases related to the
namespaces and numerical spaces of the Internet. Much of its work has concerned the Internet's
global Domain Name System (DNS). Therefore, the Plaintiff contacted globalsupport@icann.org
to get his domain ownership documents for his blogger domains.
25. On April 3, 2024, ICANN Global Support referred the Plaintiff to his registrar.
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26. MarkMonitor, Inc., 1120 S. Rackham Way, Suite 300, Meridian, Idaho 83642, is the
registrar for Blogspot.com. Markmonitor is a subsidiary of Newfold Digital, Inc., a Foreign
Profit Corporation, located at 5335 Gate Parkway, Jacksonville, FL, 32256.
27. On April 6, 2024 the Plaintiff emailed MarkMonitor, Inc. (Exhibit 4) for his domain
ownership documents for the following blogspot blogs:
Neil J. Gillespie for President 2024

https://neil2024.blogspot.com/
Justice Network blog

https://neil4justice.blogspot.com/
Neil J. Gillespie
https://www.blogger.com/profile/10759042183268192614

Justice Network blog, NoSue.org

https://nosueorg.blogspot.com/
Music and Video - Election 2020, Music4Life2

https://music4life2.blogspot.com/
Neil Gillespie
Dissolve The Florida Bar

https://dissolvetfb.blogspot.com/
28. The Plaintiff’s property has not been taken for any tax, assessment, or fine under law.
29. The property has not been taken under an execution or attachment against the Plaintiff’s
property.
30. Therefore, the Plaintiff demands judgment for possession of his property.
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THE PARTIES
31. The Plaintiff is Neil J. Gillespie (“Gillespie”), a nonlawyer age 68, individually, and
doing business as Justice Network, a fictitious name. Justice Network was registered with the
Florida Department of State on January 25, 2018 at 8092 SW 115th Loop, Ocala, Florida, 34481.
The Fictitious Name Registration Number of Justice Network is G18000014506, currently
located at 2801 SW College Rd., STE 3, Ocala, FL 34474. In addition, Gillespie was in the past,
and currently is, a No Party Affiliation (NPA) candidate for U.S. president, see,
Neil J. Gillespie for President (Statement of Organization)

Principal Campaign Committee ID C00627810
Neil J. Gillespie (Statement of Candidacy)

Candidate ID P60022993
32. Defendant Google LLC (“Google”) is a limited liability company organized and existing
under the laws of the State of Delaware, with its principal place of business in Mountain View,
California. Google is an online company providing internet-related products directly and through
subsidiaries and business units it owns and controls such as Gmail, Blogger and YouTube.
33. Defendant Alphabet Inc. (“Alphabet”) is a publicly traded company incorporated and
existing under the laws of the State of Delaware and headquartered in Mountain View,
California. Alphabet was created as a holding company for Google in late 2015, and Alphabet
controls Google’s day-to-day operations. Virtually all of Alphabet’s revenue comes from
Google. Since December 2019, Alphabet and Google have had the same Chief Executive
Officer, Sundar Pichai. As a result of Alphabet’s operational control, Google is Alphabet’s alter
ego. This Complaint refers to Google and Alphabet together as “Google.”
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34. Defendant Verizon Communications, Inc., is a publicly traded American multinational
telecommunications conglomerate incorporated and existing under the laws of the State of
Delaware and headquartered in New York City. (1095 Avenue of the Americas, NY, NY).
35. Defendant Verizon Wireless Services, LLC is an American wireless network operator
limited liability company organized and existing under the laws of the State of Delaware, and a
division of Verizon Communications, Inc., with its principal place of business in Basking Ridge,
New Jersey. This Complaint refers to Verizon Communications, Inc. and Verizon Wireless
Services, LLC together as “Verizon”.
36. Defendant TracFone Wireless, Inc. is an American pre-paid, no-contract mobile phone
provider incorporated and existing under the laws of the State of Delaware and headquartered in
Miami, Florida. Tracfone is a subsidiary owned by Verizon. This Complaint refers to Verizon
and Tracfone together as “Verizon”.
JURISDICTION AND VENUE
37. Replevin is governed by Chapter 78 of the Florida Statutes (Fla. Stat.) The Plaintiff has a
right to replevin under Fla. Stat. 78.01, to recover his personal and intellectual property wrongly
taken or detained by the Defendants, and any damages sustained by reason of the wrongful
taking or detention.
38. An action for replevin must be brought in a court of competent jurisdiction based on the
value of the property sought to be replevied. Fla. Stat. 78.03. The Marion County Circuit Court
is a court of competent jurisdiction. Fla. Stat. 26.012(2).
39. An action for replevin may be brought in any county where the property sought to be
replevied is located, where the contract was signed, where the defendant resides, or where the
cause of action accrued. Fla. Stat. 78.032. The Plaintiff’s property sought to be replevied is
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located on his computer located in Marion County, Florida, and is viewable online on the
Internet in Marion County, Florida. The Plaintiff’s contracts with the Defendants were executed
in Marion County, Florida. The cause of action accrued in Marion County, Florida.
GOOGLE TERMS OF SERVICE
40. The Google Terms of Service (“Google TOS”), effective January 5, 2022, appear in
Appendix A, at Exhibit A.1 to the Complaint for Replevin.
41. The Google TOS define Google’s relationship with the Plaintiff, and how the Plaintiff
interacts with Google’s services.
42. Under the Google TOS, Google is the Service Provider; Google services are provided by,
and the Plaintiff is contracting with Google.
43. Under the Google TOS, the Plaintiff, age 68, meets the age requirements to own and
manage his Google Account neilgillespie@mfi.net.
44. The Google TOS establishes Definitions, including: (Appendix A, Exhibit A.1, page 14,
Complaint for Replevin)
“business user” means

“An individual or entity who is not a consumer (see consumer)”
“consumer” means:
“An individual who uses Google services for personal, non-commercial purposes outside
of their trade, business, craft, or profession. (See business user)”.
“copyright” means:
“A legal right that allows the creator of an original work (such as a blog post, photo, or
video) to decide if and how that original work may be used by others, subject to certain
limitations and exceptions (such as “fair use” and “fair dealing”).
“intellectual property rights (IP rights)” means:

“Rights over the creations of a person’s mind, such as inventions (patent rights); literary
and artistic works (copyright); designs (design rights); and symbols, names, and images
used in commerce (trademarks). IP rights may belong to you, another individual, or an
organization.”
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“liability” means:
“Losses from any type of legal claim, whether the claim is based on a contract, tort
(including negligence), or other reason, and whether or not those losses could have been
reasonably anticipated or foreseen.”
“organization” means:
“A legal entity (such as a corporation, non-profit, or school) and not an individual person.”
“services” mean:
“The Google services that are subject to these terms are the products and services listed
at https://policies.google.com/terms/service-specific, including:
• apps and sites (like Search and Maps)
• platforms (like Google Shopping)
• integrated services (likeMaps embedded in other companies’ apps or sites)
• devices and other goods (like Google Nest)
Many of these services also include content that you can stream or interact with.”
“trademark” means:
“Symbols, names, and images used in commerce that are capable of distinguishing the
goods or services of one individual or organization from those of another.”
“warranty” means:
“An assurance that a product or service will perform to a certain standard.”
“your content” means:

“Things that you create, upload, submit, store, send, receive, or share using our services,
such as:
• Docs, Sheets, and Slides you create
• blog posts you upload through Blogger
• reviews you submit through Maps
• videos you store in Drive
• emails you send and receive through Gmail
• pictures you share with friends through Photos
• travel itineraries that you share with Google”
45. Under the Google TOS, Google provides services to the Plaintiff, including a Google
Account, neilgillespie@mfi.net, a Blogger account, the Neil Gillespie Blooger user profile,
blogger.com/profile/12580744990628852454, and several blogs, including:
• Neil 2020 blog, neil2020.blogspot.com

• Justice Network blog, nosueorg.blogspot.com
• Music and Video - Election 2020 blog, music4life2.blogspot.com
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and the Plaintiff’s Google Account dissolvetfb@gmail.com and blog domain
http://dissolvetfb.blogspot.com.
46. Under the Google TOS, the Plaintiff has Google’s permission to use Google’s services,
including a Google Account, a Blogger Account, and a YouTube Account.
47. Blogger is an American online content management system founded in 1999 which
enables its users to write blogs with time-stamped entries. Pyra Labs developed it before being
acquired by Google in 2003. Google hosts blogs at https://www.blogger.com/about/ and states
Get a domain. Give your blog the perfect home. Get a blogspot.com domain or buy a
custom domain with just a few clicks.
48. The Blogger Content Policy states in part:
Blogger is a service for self-expression and communication. We believe Blogger

increases the availability of information, encourages healthy debate, and makes possible
new connections between people. It is our belief that censoring this content is contrary to
a service that bases itself on freedom of expression.
49. YouTube is an American online video sharing and social media platform owned by
Google, and governed by the Google TOS. YouTube is also governed by a separate YouTube
Terms of Service dated December 15, 2023, and appearing in Appendix A at Exhibit A.3 to the
Complaint for Replevin.
50. Under the Google TOS, and YouTube TOS, Google provides services to the Plaintiff,
including a Google Account, neilgillespie@mfi.net, and the Neil Gillespie YouTube account or
channel: @neilgillespie4184, and the Plaintiff’s Google Account dissolvetfb@gmail.com and
blog domain http://dissolvetfb.blogspot.com.
LICENSE
51. The Google TOS provides the Plaintiff a “License”, found on page 6 (Appendix A at
Exhibit A.1 to the Complaint for Replevin) that states:
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License
Your content remains yours, which means that you retain any intellectual property rights
that you have in your content. For example, you have intellectual property rights in the
creative content you make, such as reviews you write. Or you may have the right to share
someone else’s creative content if they’ve given you their permission.
We need your permission if your intellectual property rights restrict our use of your
content. You provide Google with that permission through this license.
What’s covered
This license covers your content if that content is protected by intellectual property
rights.
What’s not covered

• This license doesn’t affect your privacy rights — it’s only about your intellectual
property rights
• This license doesn’t cover these types of content:
• publicly-available factual information that you provide, such as corrections to
the address of a local business. That information doesn’t require a license
because it’s considered common knowledge that everyone’s free to use.
• feedback that you offer, such as suggestions to improve our services.
Feedback is covered in the Service-related communications section below.
Scope
This license is:
• worldwide, which means it’s valid anywhere in the world
• non-exclusive, which means you can license your content to others
• royalty-free, which means there are nomonetary fees for this license
Rights
This license allows Google to:
• host, reproduce, distribute, communicate, and use your content — for example, to
save your content on our systems and make it accessible from anywhere you go
• publish, publicly perform, or publicly display your content, if you’ve made it visible
to others
• modify and create derivative works based on your content, such as reformatting or
translating it
• sublicense these rights to:
• other users to allow the services to work as designed, such as enabling you to
share photos with people you choose
• our contractors who’ve signed agreements with us that are consistent with
these terms, only for the limited purposes described in the Purpose section
below
Purpose
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This license is for the limited purpose of:
• operating and improving the services, which means allowing the services to work as
designed and creating new features and functionalities. This includes using automated
systems and algorithms to analyze your content:
• for spam, malware, and illegal content
• to recognize patterns in data, such as determining when to suggest a new
album in Google Photos to keep related photos together
• to customize our services for you, such as providing recommendations and
personalized search results, content, and ads (which you can change or turn
off in Ads Settings)
This analysis occurs as the content is sent, received, and when it is stored.
• using content you’ve shared publicly to promote the services. For example, to
promote a Google app, we might quote a review you wrote. Or to promote Google
Play, we might show a screenshot of the app you offer in the Play Store.
developing new technologies and services for Google consistent with these terms
Duration
This license lasts for as long as your content is protected by intellectual property rights.
If you remove from our services any content that’s covered by this license, then our
systems will stop making that content publicly available in a reasonable amount of time.
There are two exceptions:
• If you already shared your content with others before removing it. For example, if
you shared a photo with a friend who then made a copy of it, or shared it again, then
that photo may continue to appear in your friend’s Google Account even after you
remove it from your Google Account.
• If you make your content available through other companies’ services, it’s possible
that search engines, including Google Search, will continue to find and display your
content as part of their search results.
THE PLAINTIFF’S PROPERTY
52. The Plaintiff has property rights under his Google Account neilgillespie@mfi.net, the
Neil Gillespie Blooger user profile, blogger.com/profile/12580744990628852454 and several
blogs, including:
• Neil 2020 blog, neil2020.blogspot.com, (Exhibit 2)

• Justice Network blog, nosueorg.blogspot.com, (Exhibit 3)
• Music and Video - Election 2020 blog, music4life2.blogspot.com, (Exhibit 4)
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and the Neil Gillespie YouTube account or channel, @neilgillespie4184, and the Plaintiff’s
Google Account dissolvetfb@gmail.com and blog domain http://dissolvetfb.blogspot.com.
53. The Plaintiff’s Google Account, neilgillespie@mfi.net, is valued at $136,000.
54. The Plaintiff’s Google Account neilgillespie@mfi.net was formed in February 2011. The
Plaintiff had three active Blogger blogs on January 20, 2021, the date of his last blog post.
A. The Plaintiff’s Justice Network blog is valued at $104,000, calculated as follows:
The Plaintiff worked an average of 10 hours a week on his blog, amounting to 520 hours
in a year (10 x 52 weeks); resulting in 5,200 hours worked in 10 years (2011-2021); at an
hourly rate of $20 per hour; for a total of $104,000. Justice Network is engaged in
advocacy, education, news gathering & dissemination, and helping people fight injustice.
B. The Plaintiff’s Neil 2020 blog, since September 22, 2019, is valued at $13,800
calculated as follows: The Plaintiff worked approximately 10 hours a week on this blog
through January 20, 2021, amounting to 690 hours worked (10 x 69 weeks); at an hourly
rate of $20 per hour; for a total of $13,800. Neil 2020 is a blog of Neil J Gillespie, a
candidate for U.S. president in 2020.
C. The Plaintiff’s Music and Video - Election 2020 blog, since April 19, 2019, is valued
at $18,200 calculated as follows: The Plaintiff worked approximately 10 hours a week on
this blog through January 20, 2021, amounting to 910 hours worked (10 x 91 weeks); at
an hourly rate of $20 per hour; for a total of $18,200. This blog is a demonstration project
showing relatively inexpensive ways of reaching people and providing political and other
information through YouTube videos, alternatives to expensive political campaigns with
the inherent expectations of big donors. A List of most-viewed YouTube videos is found
on Wikipedia, https://en.wikipedia.org/wiki/List_of_most-viewed_YouTube_videos
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No. 16, “Counting Stars” by OneRepublic, shows 3.95 billion views. “Counting Stars” is
an example of a popular video featuring social, political and religious content.
D. The Plaintiff’s Neil Gillespie YouTube account or channel with the video, “13th
Circuit JNC Interviews, June 15, 2010, Tampa, FL” is valued at $500 for production cost.
E. The Plaintiff’s Google Account dissolvetfb@gmail.com and blog domain
http://dissolvetfb.blogspot.com is valued at $2,000.
55. Under the Google TOS, Google has provided the Plaintiff a License and warranty, and
given the Plaintiff permission to use Google’s services, for the Plaintiff’s creative content
uploaded and published on Blogger and YouTube, certain rights as a business user under his
Google Account neilgillespie@mfi.net, and dissolvetfb@gmail.com including copyright,
intellectual property rights (IP rights), trademark, and implicit First Amendment rights.
56. Google is liable to the Plaintiff for any breach of its License and warranty to him.
57. Presently the Plaintiff cannot access or use his Google Account neilgillespie@mfi.net,
including his Blogger Account and YouTube Account, because Google claims it cannot be sure
the Google Account neilgillespie@mfi.net belongs to the Plaintiff, Neil J. Gillespie.
58. On March 13, 2024 the Plaintiff provided evidence by email to Mr. Whitaker et al of new
claims: (Exhibit 2)
Mr. Whitaker,
Please take notice (second) of new claims in 5:24-cv-00101
On August 18,2014 I created the Dissolve The Florida Bar blog, DissolveTFB.blogspot
http://dissolvetfb.blogspot.com/ with my Google Account dissolvetfb@gmail.com
My only post was made August 18, 2014, Subversive Organization: The Florida Bar
http://dissolvetfb.blogspot.com/2014/08/subversive-organization-florida-bar.html
"Section 876.05 of the Florida Statutes requires all employees of the state to take a
loyalty oath to "support the Constitution of the United States and of the State of Florida."
However The Florida Bar recently disclosed it does not have section 876.05 loyalty oaths
17
for its employees. Therefore, on information and personal belief, The Florida Bar is a
"subversive organization" within the meaning of Chapter 876, Florida Statutes, Criminal
Anarchy, Treason, and Other Crimes Against Public Order, and "shall be dissolved" as
provided by section 876.26, Fla.Stat.. .."
The Blogger profile for my Google Account dissolvetfb@gmail.com

https://www.blogger.com/profile/09440083834237528l73
Unfortunately I cannot log into my Google Account "dissolvettb@gmail.com" using the

correct email address, and the correct password, because "Google doesn't have enough
info to be sure this account is yours." (Exhibit 3)
Google sent me a verification code to my Google recovery email

"dissolvetfb@inbox.com", but lnbox sent me a message stating "Your account does not
exist anymore. We are sorry, but your account has been canceled due to inactivity".
My blog post is accompanied by the following Scribd PDFs

9 Flalur2d Civil Servants, Sec. 111 Loyalty Oath
CONNELL v. HIGGINBOTHAM ET AL. 403 U.S. 207 (1971)
Florida Bar 2012 Hawkins Commi.ssion FULL REPORT, Review of Discipline System
Florida Bar 2012 Hawkins Commission Report, Survey Results Federal Judges
Florida Bar 2012 Hawkins Commission Report, Survey Results State Judges
Florida Bar 2012 Hawkins Commission Report, page 24 (102), State Judge Response
For some reason Google is the only company that has continued to block access to my
online accounts, which happen to criticize the government, specifically the judicial
branch.
Clearly the Google security protocols in place are ineffective, making Google products
such as Blogger, Gmail, and YouTube, defective. Attached you will find PDF evidence
of the defective Blogger product.
GOOGLE’S UNLAWFUL DETAINER OF THE PLAINTIFF’S GOOGLE ACCOUNT
59. On March 19, 2024 the Plaintiff provided email evidence to Mr. Whitaker et al that
Google has wrongly detained his Google Account neilgillespie@mfi.net. Appearing at Exhibit 1
is a Google Critical security alert email of March 13, 2024, Sign-in attempt was blocked,
forwarded to Mr. Whitaker et al on March 19, 2024.
Dear Mr. Whitaker,
Forwarded below is a Google "Critical security alert" email to neilgillespie@mfi.net that

I received Wednesday, March 13, 2024 at 9:17 AM.
18
In the email Google wrote: "Sign-in attempt was blocked" "neilgillespie@mfi.net"

"Someone just used your password to try to sign in to your account. Google blocked
them, but you should check what happened."
I am the person who used my password to sign into my Google account

neilgillespie@mfi.net, and I am the person whom Google blocked from trying to sign in
to my Google account. Thank you.
Now Mr. Whitaker et al have personal knowledge of Google’s unlawful detainer of the account.
60. Google is blocking the Plaintiff’s legitimate sign-in attempt to his Google Account
neilgillespie@mfi.net because the Plaintiff cannot get a verification code Google sent to the
Plaintiff’s wireless phone number 352-615-3819; Verizon has wrongly detained the Plaintiff’s
wireless phone number 352-615-3819 as pled in this complaint.
62. The Plaintiff has access to his Google Account email address, neilgillespie@mfi.net, and
clearly used the correct password for his Google Account neilgillespie@mfi.net. In fact,
Google’s critical security alert to the Plaintiff at neilgillespie@mfi.net states:
“Someone just used your password to try to sign in to your account. Google blocked
them, but you should check what happened.”
“Someone” is the Plaintiff. YES, the Plaintiff just used his password to try to sign in to his
account, but Google blocked him. The Plaintiff knows what happened: Google is wrongly
blocking the Plaintiff’s legitimate attempts to sign in to his own Google Account.
63. Google’s verification page for neilgillespie@mfi.net stated “Verify it’s you” and “To
help keep your account safe, Google wants to make sure it’s really you trying to sign in” at
neilgillespie@mfi.net and “Confirm you’re not a robot” via a CAPTCHA. The Plaintiff correctly
completed the CAPTCHA and confirmed he is not a robot.
64. A Google Blogger “Welcome” page for neilgillespie@mfi.net said “enter your
password”. The Plaintiff entered his password where indicated on the page.
19
65. A Google Blogger “Account recovery” page for neilgillespie@mfi.net said, “To help
keep your account safe, Google wants to make sure it’s really you trying to sign in” to the
Plaintiff’s Google Account neilgillespie@mfi.net. Google said “Get a verification code” and “To
get a verification code, first confirm the phone number you added to your account (•••) •••-••19.
Standard rates apply.” The Plaintiff entered the phone number 352-615-3819 and pushed the
send button.
66. A Google Blogger Account recovery page said, “To help keep your account safe, Google
wants to make sure it’s really you trying to sign in” to the Plaintiff’s Google Account
neilgillespie@mfi.net. The Google Blogger Account recovery page also said “A text message
with a 6-digit verification code was just sent to (352) 615-3819.” The page provided an input
box to “Enter the code”. The page also had another option: “I don’t have my phone”. The
Plaintiff does not have his phone to receive a text at (352) 615-3819, because Verizon has
wrongly detained the phone number (352) 615-3819 that Verizon promised to provide to the
Plaintiff under a Retail Installment Contract with Verizon dated November 29, 2022. A copy of
the Contract appears in Appendix B, Exhibit B.2, to the Complaint for Replevin.
67. A Google Blogger page then said “Couldn’t sign you in” to the Plaintiff’s Google
Account neilgillespie@mfi.net. Google said, “You didn’t provide enough info for Google to be
sure this account is really yours. Google asks for this info to keep your account secure. To
recover your account, try again and answer each question shown.” However Google did not
provided any questions to answer. The only option Google provided was a link, “More tips to
recover your account”. In regard to the Plaintiff’s Google Account neilgillespie@mfi.net, the
link is ultimately a “rabbit hole” of futile suggestions.
20
68. Google does not provide telephone support to resolve issues with the Plaintiff’s Google
Account neilgillespie@mfi,net. Therefore, the Plaintiff contacted Google in writing.
69. On May 10, 2023, the Plaintiff wrote to Google:
Sundar Pichai (CEO) Google LLC

1600 Amphitheatre Parkway
Mountain View, California 94043
RE: Google Account: neilgillespie@mfi.net
The Plaintiff’s letter to Google LLC appears in Appendix A at Exhibit A.4 to the Complaint for
Replevin. A UPS Proof of Delivery shows the letter was delivered on May 12, 2023 at 9:52 AM,
tracking # 1Z64589F0291957636. Google did not respond to the Plaintiff’s letter that began:
My name is Neil J. Gillespie. Currently I cannot access my Google account linked to

neilgillespie@mfi.net because that email address no longer works, see enclosed my
affidavit. Also, my cell phone number 352-615-3819 linked to my Google account was
lost when service on my 3G phone ended, so I do not have a way to get an account
recovery verification code, see enclosed my affidavit.
Subsequently the Plaintiff regained access to his email neilgillespie@mfi.net, descried below.
70. On June 1, 2023, the Plaintiff sent a Notice of Litigation to Alphabet, Inc./Google LLC,
and to its Registered Agent, Corporation Service Company. No response was received.
Kenneth H. Yi, Director Corporation Service Company

Alphabet, Inc./Google LLC 1201 Hays Street
Legal - Securities, Corporate Tallahassee, FL 32301-2525
Governance & Finance
1600 Amphitheatre Parkway
Mountain View, California
Email: kyi@google.com
The Plaintiff’s Notice of Litigation to Alphabet, Inc./Google LLC appears in Appendix A at
Exhibit A.5 to the Complaint for Replevin. The Notice was provided by to Alphabet, Inc./Google
LLC by U.S. Certified Mail, Tracking No. 70192970000057339543. Return Receipt Tracking
No. 9590 9402 7830 2234 4295 41, and the Return Card, show the Notice was delivered to
21
Alphabet/Google on June 7, 2023. The Notice to Corporation Service Company was provided by
U.S. Certified Mail, Tracking No. 70192970000057339550. Return Receipt Tracking No. 9590
9402 7830 2234 4295 58, and the Return Card, show the Notice was delivered to Mona Lisa Hart
at Corporation Service Company. The Plaintiff’s Notice of Litigation to Google states in part:
Google as also failed to respond to my letter May 10, 2023 to Sundar Pichai, CEO,
Google LLC, delivered to him on May 12, 2023, see attached the proof of delivery for
UPS shipment tracking number lZ64589F0291957636.
Unfortunately Google has left me no option other than to litigate. My unanswered letter
to Sundar Pichai, CEO, Google LLC, and Jisha's emails to me, are evidence of Google's
violation of my civil rights. Please be advised that my political campaign is, inter alai, a
federally protected activity under 18 USC 245(b)(1)(a).
71. On October 20, 2023, the Plaintiff served Alphabet/Google on the Florida Portal:
DEFENDANT’S NOTICE OF CONFLICT WITH THE STATE ATTORNEY’S

OFFICE, Filing # 184402021 E-Filed 10/20/2023 09:25:51 AM
The above captioned pleading appears in Appendix A at Exhibit A.6 to the Complaint for
Replevin. The Plaintiff is the founder and owner of Justice Network. On Thursday, August 6,
2020, the Plaintiff profiled a story from the American Civil Liberties Union (ACLU) on his
Justice Network blog, entitled “Is a Florida Chief Judge Taking Cues From a Prosecutor?” The
story, by Jacqueline Azis, Staff Attorney, ACLU of Florida & Somil Trivedi, Senior Staff
Attorney, ACLU Criminal Law Reform Project, is about Brad King, the elected state attorney of
Marion County, Florida, and public corruption.
72. On February 4, 2021 the Plaintiff was arrested and ultimately extradited to Florida on a
Governor’s Warrant by Gov. Ron DeSantis, after Marion County Judge Gary Sanders denied
Gillespie’s motion under the Americans With Disabilities Act for a 60 day stay in a political
prosecution so he could get retina surgery, done at Wills Eye Hospital in Philadelphia. The
Plaintiff unsuccessfully challenged the extradition and was incarcerated on no bond for over a
22
year. During that time the Plaintiff lost his email neilgillespie@mfi.net and his wireless phone
number 352-615-3819. The only response the Plaintiff got from Google was a Removal From
The Service List notice appearing in Appendix A, at Exhibit A.7 to the Complaint for Replevin.
73. On January 13, 2021, the Plaintiff filed in the USSC a MOTION FOR LEAVE TO FILE,
RULE 17, PROCEDURE IN AN ORIGINAL ACTION, and a Rule 23 Stay for the Inauguration
of Joe Biden and Kamala Harris, directed to Justice Thomas. The Plaintiff made a post about his
USSC filing on his Justice Network Google Blogger blog neilgillespie@mfi.net on January 20,
2021 that appears in Appendix C at Exhibit C.1 tot he Complaint for Replevin. The Plaintiff’s
USSC filing challenged a Federal Election Commission (FEC) letter to him as a candidate. In the
U.S. Supreme Court case Ex parte Garland, 71 U.S. 333 (1866), the USSC held counselors are
officers of the court, not officers of the United States, and that their removal was an exercise of
judicial power, not legislative power. The Plaintiff’s FEC complaint argued that under the
separation of powers doctrine, Joe Biden and Kamala Harris are not eligible to serve in an
executive branch office such as president/VP because each of them are lawyers and part of the
judicial branch of government. A lawyer admitted to practice is an officer of the court, part of the
judiciary. A lawyer, officer of the court, in the executive branch would usurp the separation of
powers doctrine set forth in the U.S. Constitution, and is part of a seditious conspiracy by the
judicial branch that is a threat to our Republic. See Appendix C, Exhibit C.1 and Exhibit C.2 to
the Complaint for Replevin.
74. The Plaintiff contends that his 2021 USSC filing, and the holding in Ex parte Garland, 71
U.S. 333 (1866), was relevant to a case that was then before the U.S. Supreme Court:
DONALD J. TRUMP, PETITIONER v. NORMA ANDERSON, ET AL.,

RESPONDENTS, USSC PETITION NO. 23-719
23
Pursuant to USSC Rule 37, the Petitioner requested consent of the Parties in USSC 23-719 to file
an amicus curiae brief. The Petitioner’s amicus brief will bring to the attention of the Court
relevant matter that he believes has not already been brought to its attention by the Parties and
may be of considerable help to the Court. See Appendix C, Exhibit C.2, Complaint for Replevin.
75. On December 27, 2023 the Petitioner emailed the Marion County Clerk about filing a
Complaint for Replevin to return his online intellectual property on Google, and on X (formerly
Twitter), and cited story on the American Bar Association Journal says the DOJ is used a writ of
replevin against a former White House adviser to recover emails. The Plaintiff provided a copy
of the email to Kenneth H. Yi, Director, Alphabet/Google, kyi@google.com. Director Mr.
Yi/Alphabet/Google did not respond. Appendix A, at Exhibit A.8, Complaint for Replevin.
76. On January 4, 2024 the Plaintiff regained access to his email address used with Google
and others, neilgillespie@mfi.net. The Plaintiff was then able to recover his account with X
(formerly Twitter), @Justice_Network.
77. On January 17, 2024 the Plaintiff got email at neilgillespie@mfi.net from Lee Rawles of
the American Bar Association (ABA), lee.rawles@americanbar.org, Subject Not read:
USSC RULE 17 MOTION FOR LEAVE TO FILE AN ORIGINAL ACTION (Exhibit 24).
Your message
To: Lee Rawles
Subject: USSC RULE 17 MOTION FOR LEAVE TO FILE AN ORIGINAL ACTION.pdf
Sent: Wednesday, January 13, 2021 7:46:06 PM (UTC-06:00) Central Time (US &
Canada) was deleted without being read on Wednesday, January 17, 2024 10:40:05 AM
(UTC-06:00) Central Time (US & Canada).
Lee Rawles is an assistant managing editor for the ABA web, see
https://www.abajournal.com/authors/4765/
78. The foregoing proves the Plaintiff owns his Google Account neilgillespie@mfi.net.
79. Google has wrongly detained the Plaintiff’s Google Account neilgillespie@mfi.net.
24
80. Therefore the Plaintiff is entitled to recover his Google Account neilgillespie@mfi.net.
GOOGLE’S VIOLATION OF THE PLAINTIFF’S PRIVACY

FOURTH AMENDMENT, U.S. CONSTITUTION
81. On March 26, 2024 the Plaintiff emailed Mr. Whitaker his affidavit on Google’s violation
of his privacy. The Affidavit of Neil J. Gillespie appears at Exhibit 5, and states in part:
2. My current desktop computer has a Windows operating system by Microsoft

Corporation. I do not “sync” my computers or wireless devices.
3. On March 12, 2024, I removed Google Chrome, a web browser developed by Google,
from my computer. Before I removed Google Chrome, I deleted my browsing history,
and other saved settings, including my bookmarks, my saved passwords, and my saved
payment methods.
4. On March 12, 2024 I made Mozilla Firefox the default browser on my desktop
computer. I manually reinstalled on Firefox my bookmarks, passwords and address
autofill.
5. I selected “DuckDuckGo” as my default search engine on the Firefox browser. I

deselected “Google” and “Amazon.com” as alternative search engines. I did not install
any of the 5,008 available search engine extensions found in Firefox Search Tools.
6. While using the Firefox browser, I am logged in to my Firefox account.
7. I do not log in to a Google Account unless required to use a Google product.
8. I continue to receive unwanted sign in requests from Google while not signed in to a
Google Account after removing Google Chrome and Google Search from my computer,
9. On March 25, 2024, a Google sign in pop-up request appeared on my computer screen
when I began signing in to my X (formerly Twitter) account. The Google message said:
Sign in with Google

Use your Google Account to sign into twitter.com
No more passwords to remember. Signing in is fast, simple and secure.
10. Below is an image I made of the Google pop-up request I got on March 25, 2024
when I began to sign in to my X (formerly Twitter) account on my desktop computer.
25
11. I have been getting similar Google pop-up requests on my other online accounts even
after removing Google Chrome and Google Search, and not signed in to a Google
Account.
12. Since removing Google Chrome and Google Search from my desktop computer, it
appears Google still tracks every search I make, every click I take, every move I make,
every step I take, while I am not signed in to a Google Account.
82. On April 7, 2024, the Plaintiff logged in to his Google Account Neil4Justice@gmail.com
and found a likely cause for Google’s breach of his privacy. Even though Google Chrome was
no longer installed on the Plaintiff’s desktop computer, Google was still tracking “every search I
make, every click I take, every move I make, every step I take” as follows:
https://chrome.google.com/sync
Chrome data in your account
“When you sign in to Chrome, you can save your bookmarks, history, passwords, and
other settings in your Google Account. This saved data can be used on any device. You
can choose what info is saved in your Google Account.”
You can download a copy of your data with Google Takeout.
Even though the Plaintiff told Google not to keep his browsing history, Google had other plans:
History = 0
26
Website addresses you entered in the address bar. Other synced browsing history isn’t
counted here, but can be viewed in Chrome on the history page.
Bookmarks = 2,327
Pages you bookmarked in Chrome. 2,327
Reading list = 0
Pages you added to your reading list in Chrome.
Open tabs = 22
Tabs that are currently open in Chrome on one of your devices.
Addresses and more = 314
Information you entered into online forms, like phone numbers, email addresses, and
some addresses.
Passwords = 0
Passwords and passkeys you saved in your Google Account, and a list of sites where you
requested Chrome to never save passwords. To manage them, go to Google Password
Manager.
Settings = 61
Settings in Chrome.
Apps = 2
Apps that you use in Chrome from the Chrome Web Store, Play Store, and more.
Extensions = 0
Extensions from the Chrome Web Store.
Themes = 1
Your theme from your settings or the Chrome Web Store.
“Clear data (button)” This will clear your Chrome data that has been saved in your
Google Account. This might clear some data from your devices.
Synced: Apr 2, 2024 at 5:44 AM
After pushing the “Clear data” button: No Chrome data saved in your Google Account.
You can sign in & save Chrome info to your Google Account.
83. The Plaintiff’s Google Account Neil4Justice showed the following for Google Takeout:
Select data to include, 52 of 53 selected

Google is creating a copy of data from 52 products
Choose file type, frequency & destination
Export progress
This process can take a long time (possibly hours or days) to complete. You'll receive an
email when your export is done.
Created: April 7, 2024, 7:09PM
The Plaintiff received his Google Takeout by gmail on Sun, Apr 7, 2024 at 7:15 PM. The data
consisted of 698 MB and 644 items. The Plaintiff then deleted all the Google Takeout data.
84. The Plaintiff’s Google Account Neil4Justice, opened with “Welcome”
27
Welcome, Neil Gillespie (Justice Network)

Manage your info, privacy, and security to make Google work better for you. Learn more
https://myaccount.google.com/
See a summary of the services you use and the data saved in your Google Account
Download your data option
“You can download a copy of your data to save locally or to use with another account”
Delete a service
“You can delete a specific Google service from your account, like YouTube or Gmail
Recently used Google services (4)

• Google Play - 106 apps
Last installed app: Casual Hookup Dating - Kasual on April 3 (Note: Installed while
waiting on tax prep at H&R Block; does not show the app was deleted minutes later.)
• YouTube
2 videos (0 private, 2 public), 1 playlist, (0 private, 1 public), 334 subscriptions (private)
2 comments
• Gmail
179 conversations, 5 in inbox, 1 sent
• Calendar
1 calendar, neil4justice@gmail.com
Other Google services (6)

• Android Backups, 1 backup, SM-A037U (38 apps backed up)
• Blogger, 3 blogs, Most recent post: Welcome to Justice Network, Neil4Justice on
January 9; 7 profile entries
• Books, 1 book in your library, 10 bookshelves, Browsing history (1 book) 9 more
bookshelves
• Chrome, last sync: March 28, 2,327 bookmarks, 389 other items (Note: I do not sync)
• Payments, 1 payment profile, Neil J. Gillespie, ID: 0558-7781-8076, United States
• Tasks, 1 task list, Most recent: My Tasks on July 12, 2023
GOOGLE’S VIOLATION OF THE CAN-SPAM ACT of 2003: 15 USC 103, CONTROLLING

THE ASSAULT OF NON-SOLICITED PORNOGRAPHY AND MARKETING
http://uscode.house.gov/view.xhtml?path=/prelim@title15/chapter103&edition=prelim
85. On March 12, 2024 the Plaintiff provided evidence to Mr. Whitaker and co-counsel that
Google likely violated the Fourth Amendment, and the CAN-SPAM Act of2003, by sending him
unwelcome emails of a sexual nature through GOOGLE CLASSROOM and GOOGLE MEET to
him at neilgillespie@mfi.net on March 10, 2024 and February 3, 2024.
28
RICO: RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS

18 U.S.C. ch. 96 as 18 U.S.C. §§ 1961–1968
86. The Racketeer Influenced and Corrupt Organizations Act, permits a private individual
"damaged in his business or property" to file a civil suit.
87. On March 2, 2024 the Plaintiff provided evidence to Mr. Whitaker et al that Google’s
unlawful detainer of his Google Account neilgillespie@mfi.net has caused him damage in his
business; the Plaintiff is unable to respond to reader requests to make news posts, like this
request by Emma Carey:
Hi there Neil,
I saw your page nosueorg.blogspot.com/, and I wanted to thank you for supporting the
Black community.
As this month we're celebrating Black History Month, I looked into some resources to
share with my contacts. Actually, that's how I found your piece, which I recommended to
some friends :) I thought some of my other findings might also be relevant to your
readers. One of them, which a lot of my friends appreciated, is an article that lists more
than 150 Black-owned businesses in North America. I was so happy to see that some
people care about helping these companies thrive!
The article is here: https://www.websiteplanet.com/blog/support-black-owned-
businesses/
I think sharing this list on your page would be a great way to help promote these Black-
owned sites and stores. I think it will be a great addition to your site and that your
audience will love this new resource!
88: The Plaintiff was threatened with garnishment and arrest on March 19, 2024 by Sandi
Kola, from the Google Gmail account sandikola5463@gmail.com (Exhibit 6). This is one
example of an ongoing stream of threatening emails coming from Google Gmail accounts.
89. Google Gmail accounts are also a favorite of money scams like one from Dávid Kósi
davidkosdo@gmail.com to the Plaintiff, who in turn provided it to Mr. Whitaker et al.
“I have left an international certified bank draft for you, worth about $500.000 USD,
cashable anywhere in the world for your past effort, contact my secretary and he will give
you full details on how to receive your $500.000 USD, into your account...”
GOOGLE IS A THREAT TO NEWS GATHERING AND PUBLISHING

Antitrust cases brought by the United States Department of Justice (DOJ)
29
against Google LLC allege violation of the Sherman Antitrust Act
90. As pled in GANNETT CO INC v. GOOGLE LLC and ALPHABET INC, US District
Court, Southern District of New York, case no. 1:23-cv-5177:
14. Google’s scheme has been wildly profitable. For example, in 2022 alone, Google
made $30 billion from manipulating auctions for ad space across the internet. That is six
times more revenue than every single U.S. news publication made from digital
advertising, combined. Google, as middleman, has dwarfed the content creators that
invest in journalists, editors, photographers, and many others to produce important news
content.
20. Defendant Alphabet Inc. (“Alphabet”) is a publicly traded company incorporated

and existing under the laws of the State of Delaware and headquartered in Mountain
View, California. Alphabet was created as a holding company for Google in late 2015,
and Alphabet controls Google’s day-to-day operations. Virtually all of Alphabet’s
revenue comes from Google. Since December 2019, Alphabet and Google have had the
same Chief Executive Officer. As a result of Alphabet’s operational control, Google is
Alphabet’s alter ego. This Complaint refers to Google and Alphabet together as
“Google.”
21. This action arises under Sections 1 and 2 of the Sherman Act, 15 U.S.C. §§ 1–2,
and Sections 4 and 16 of the Clayton Act, 15 U.S.C. §§ 15 and 26. The Court has subject-
matter jurisdiction under 15 U.S.C. § 4, and 28 U.S.C. §§ 1331 and 1337(a).
91. U.S. and Plaintiff States v. Google LLC [2020]

https://www.justice.gov/atr/case/us-and-plaintiff-states-v-google-llc
A U.S. Department of Justice antitrust lawsuit is pending against Google in the U.S. Court of
Appeals for the District of Columbia, USCA Case #24-5006, on Appeal from the U.S. District
Court for the District of Columbia Nos. 1:20-cv-03010-APM & 1:20-cv-03715-APM. The
district court consolidated United States v. Google LLC, No. 1:20-cv-3010 (D.D.C. filed Oct. 20,
2020), and State of Colorado v. Google LLC, No. 1:20-cv-03715 (D.D.C. filed Dec. 17, 2020).
The Government alleges that Defendant-Appellee Google LLC has illegally monopolized
certain markets for search services and search advertising in violation of Section 2 of the
Sherman Act, 15 U.S.C. § 2. Specifically, since at least 2010, Google has maintained
monopolies in these markets through exclusionary conduct that deprives rivals of the
scale necessary to compete effectively, discourages competition from potential rivals, and
forecloses rivals through exclusive distribution agreements. These agreements include
agreements with Apple Inc., with manufacturers of Android mobile devices and wireless
30
carriers, and with third-party developers of web browsers, whereunder Google agrees to
share advertising revenue with its counterparty in exchange for placement as the default
search engine.
Additionally, the Government plaintiffs in Case No. 1:20-cv-03715 allege that Google
also harmed competition through its operations of its SEM tool SA360, which is enabled
by the impact of the exclusionary distribution contracts and general search engine rivals’
resultant and limited ability to attract advertisers. They further allege that as Google’s
monopoly flows downstream, Google’s rivals are weakened in their ability to make
arrangements with other industry partners that would increase their ability to attract users
and build scale.
https://www.justice.gov/atr/case-document/motion-plaintiffs-appellees-dismiss-appeal
92. United States v. Google LLC (2023)

https://en.wikipedia.org/wiki/United_States_v._Google_LLC_(2023)
United States v. Google LLC is an ongoing federal antitrust case brought by the United
States Department of Justice (DOJ) against Google LLC on January 24, 2023.[1] The suit
accuses Google of illegally monopolizing the advertising technology (adtech) market in
violation of sections 1 and 2 of the Sherman Antitrust Act of 1890. The suit is separate
from an ongoing DOJ antitrust case launched in 2020 accusing Google of illegally
monopolizing the search engine market.
Filed in the United States District Court for the Eastern District of Virginia, the suit aims
to force Google to sell off significant portions of adtech business and require the
company to cease certain business practices.[2] The case is set to go to trial on September
9, 2024.[3]
93. Through unjust enrichment, Google has purchased companies like Blogger and YouTube,
and harmed consumers like the Plaintiff with it policies. Virtually every wireless phone contains
Google which is an unwelcome violation of privacy and the Fourth Amendment: “Every search
you make, every click you take, every move you make, every step you take, I’ll be watching
you”. A Family sued Google after Maps directed their father off a collapsed bridge:
CNN reported on September 23, 2023, “Family sues Google alleging its Maps app led
father to drive off collapsed bridge to his death,...”
https://www.cnn.com/2023/09/21/us/father-death-google-gps-drive-off-bridge-lawsuit-
north-carolina/index.html
Vice News reported on September 20, 2023 that “Google Flat-Out Refuses to Bargain
With Workers, Prompting YouTube Music Strike”
31
https://www.vice.com/en/article/k7zn5y/google-flat-out-refuses-to-bargain-with-workers-
prompting-youtube-music-strike
The New York Times reported, “How Google Protected Andy Rubin, the ‘Father of
Android’ The internet giant paid Mr. Rubin $90 million and praised him, while keeping
silent about a misconduct claim.”
https://www.nytimes.com/2018/10/25/technology/google-sexual-harassment-andy-
rubin.html
DEFENDANT VERIZON WIRELESS
94. The Plaintiff is entitled to the possession the telephone number 352-615-3819 under a
Retail Installment Contract with Verizon Wireless Services LLC dated November 29, 2022, a
copy of the Contract being attached. (Appendix B, Exhibit B.2, Complaint for Replevin).
95. The Plaintiff requires his telephone number 352-615-3819 to get a verification code from
Google to access his Google Account neilgillespie@mfi.net.
96. Verizon has refused to provide the Plaintiff his property, his telephone no. 352-615-3819.
97. The Plaintiff’s Google Account neilgillespie@mfi.net is currently detained by Google
because the Plaintiff cannot get a verification code Google sent to telephone no. 352-615-3819.
98. Verizon is cooperating with Google to detain the Plaintiff’s Google Account
neilgillespie@mfi.net
99. Separately, the Verizon Class Action Settlement Administrator notified the Plaintiff he is
owed a settlement in Esposito et al. v. Cellco Partnership d/b/a Verizon Wireless.
100. The Plaintiff gave written notice to the Verizon Administrative Charge Settlement
Administrator to opt-out, to be excluded from the Settlement Class in the lawsuit.
101. The Plaintiff includes his claims in Esposito et al. v. Cellco Partnership d/b/a Verizon
Wireless in this complaint against Verizon.
102. Therefore the Plaintiff is entitled to recover his telephone no. 352-615-3819.
32
103. The Plaintiff is entitled to the possession of his current Tracfone account for 352-850-
5009 under a Tracfone 1 Year and 400 minutes phone card, a “365-DAY PLAN” activated
November 3, 2023.
104. The Plaintiff obtained a Tracfone pre-paid 365-DAY PLAN for the purpose of managing
verification codes for his online accounts, including Google and its services Gmail, Blooger and
YouTube; and also X (formerly Twitter), Yahoo, Scribd, Facebook, and others.
105. Verizon TracFone has refused the Plaintiff possession of his current account for 352-850-
5009 under a pre-paid “365-DAY PLAN” activated on November 3, 2023 and valid to
November 2, 2024. The Plaintiff’s wireless device functions to make and receive texts and calls,
but he cannot log into his account because “We are unable to validate the information you
provided.”
106. The Plaintiff recently got a phone call from 305-715-6500 from a person claiming to be a
customer service representative. The person confirmed the Plaintiff’s email address on the
account for 352-850-5009. However the Plaintiff still cannot login to the account. The Plaintiff
told the person he is disgusted with Verizon and plans to get an iPhone, which he did get one.
107. Without access to his account for 352-850-5009 under a pre-paid “365-DAY PLAN” the
Plaintiff cannot make updates to his account to assure its proper function and purpose in
managing verification codes for his online accounts, including Google and its services Gmail,
Blooger and YouTube; and also X (formerly Twitter), Yahoo, Scribd, Facebook, and others.
108. The Plaintiff’s account for 352-850-5009 is being wrongly detained.
109. The Plaintiff is entitled to access his account for 352-850-5009 under a “365-DAY
PLAN” activated on November 3, 2023 and valid to November 2, 2024.
110. Therefore the Plaintiff is entitled to recover his account for 352-850-5009.
33
111. Brett B. Goodman, Esq., GOODMAN LAW FIRM, APC, 11440 W. Bernardo Ct. Suite
300, San Diego, CA 92127 purports to represent Verizon including Tracfone, but has not
entered his appearance in either the federal or Florida case.
112. On March 12, 2024, the Plaintiff provided Mr. Goodman evidence of new claims against
Verizon. A letter Sep-12-2022 to Manon Brouillette, EVP and CEO, Verizon Consumer Group,
for violation of the Telecommunications Act of 1996, federal and state consumer law, and
perhaps Florida criminal law, for its offenses regarding Plaintiff’s Verizon account.
• A letter Jan-02-2023 to Vandana Venkatesh, Verizon EVP & Chief Legal Officer
• A letter to McCarthy, Burgess & Wolfe, Verizon debt collector
113. On March 27, 2024, the Plaintiff provided Mr. Goodman a letter with additional evidence
of wrongdoing by Verizon including Tracfone. Apparently Verizon and Tracfone routinely make
false statements to a consumer in order to induce the sale of wireless services and wireless
devices affecting interstate commerce. The letter also noted on page 4,
On Dec-01-2022, I did a Google search for 352-615-3819, the name Kjo Adanaghh (not
likely a real person) appeared with a link to a Spokeo people search website.
and
Today I called 352-615-3819 and got a recorded message that said in part, “The wireless
customer you are calling is not available. Please try again later.”
Some person or entity may have the number 352-615-3819 parked or otherwise detained
in order to prevent my access to the number I need to get a code from Google to log in to
my Google Account neilgillespie@mfi.net, and therefore prevent my access to my
detained property, my Google Account neilgillespie@mfi.net.
Like Google, Verizon and Tracfone do as they please without regard to law or ethics. Any
punishment they might receive is monetary (not a restraint of liberty) and simply viewed as the
cost of doing business. The only option for a consumer is to change providers, and look for other
34
ways to live life without corrupt racketeer organizations. The government has the power and
authority to enforce antitrust laws and other such in a meaningful way.
FIRST AMENDMENT - US CONSTITUTION
114. The FIRST AMENDMENT to the U.S. Constitution states:
Congress shall make no law respecting an establishment of religion, or prohibiting the

free exercise thereof; or abridging the freedom of speech, or of the press; or the right of
the people peaceably to assemble, and to petition the Government for a redress of
grievances.
115. As pled in para. 12, as of the date and time of the filing of this First Amended Complaint,
Gregory C. Harrell, FL Bar No. 173975, Marion County Clerk of Court and Comptroller, has not
complied with the March 26, 2024 Order of the U.S. district court remanding this case to the
“Circuit Court of the Fifth Judicial Circuit in and for Marion County Florida.” Clerk Harrell has
not reopened the remanded case in this court, case no. 2024-CA-0209.
116. The failure of the Clerk to remand this case as ordered by the U.S. district court violates
the Plaintiff’s speech and redress rights under the FIRST AMENDMENT, U.S. Constitution.
117. The failure of the Court to act under sec. 78.065(1) or sec. 78.065(2), or on any other
basis also violated the Plaintiff’s speech and redress rights under the FIRST AMENDMENT.
118. The Court and Clerk apparently deprived the Plaintiff of his civil rights, and did so in
support of, or in combination with, the Defendants, in violation of 42 U.S.C. § 1983:
42 U.S.C. § 1983 - Civil action for deprivation of rights

Every person who, under color of any statute, ordinance, regulation, custom, or usage, of
any State or Territory or the District of Columbia, subjects, or causes to be subjected, any
citizen of the United States or other person within the jurisdiction thereof to the
deprivation of any rights, privileges, or immunities secured by the Constitution and laws,
shall be liable to the party injured in an action at law, suit in equity, or other proper
proceeding for redress, except that in any action brought against a judicial officer for an
act or omission taken in such officer’s judicial capacity, injunctive relief shall not be
granted unless a declaratory decree was violated or declaratory relief was unavailable.
For the purposes of this section, any Act of Congress applicable exclusively to the
District of Columbia shall be considered to be a statute of the District of Columbia.
35
119. The Defendants, and the Clerk and the Court, acting under the color or law, deprived the
Plaintiff his civil rights in violation of 18 U.S.C. 245(b)(1)(A), 18 U.S.C. §. 242, Deprivation Of
Rights Under Color Of Law, and/or 18 U.S. Code § 241 - Conspiracy against rights
120. October 20, 2023 the Plaintiff proffered in his Notice of Conflict With the State
Attorney’s Office (Appendix A, Exhibit A.6, page 5, Complaint for Replevin) that his
“Blogger/Google account linked to his MFI.com email address is constitutionally protected
speech under the First Amendment of the U.S. Constitution, and a federally protected activity
under 18 U.S.C. 245(b)(1)(a).” and,
18. In addition, because the Defendant cannot access his Blogger, YouTube and Google
accounts associated with his email neilgillespie@mfi.net, he cannot serve his clients.
19. On such client is Ronny Scott Cooper, Inmate ID #0005200, Marion County Jail,
Med B, held without bond since May 1, 2019, case no. 2019-CF-1050, for violation of
section 812.133.2A, Florida Statutes, Carjacking While Armed. Circuit Judge Peter M.
Brigham presiding. The docket shows Mr. Cooper is represented by John Wayne
Witherspoon, Bar ID #1008179, Crim. Conflict & Civ. Reg. Counsel, 5th Circuit.
20. Mr. Cooper filed a pro se motion to dismiss counsel dated October 3, 2023 (DOC
569). Judge Brigham entered a Transport Order on October 3, 2023 (DOC 657) to
transport Mr. Cooper to the Marion County Courthouse for the “purpose of appearing for
a psychological evaluation to be performed by Dr. Tonia Werner at 1:00 pm, October
25,2023, the defendant will be placed in holding cell between courtroom 3A and 3B
courtroom.”.
21. The Defendant has found a private attorney willing to represent Mr. Cooper for
$10,000, but is unable to commence fundraising because the Defendant cannot access his
Blogger, YouTube and Google accounts associated with his email neilgillespie@mfi.net.
PUNITIVE AND TREBLE DAMAGES AGAINST GOOGLE
121. The Plaintiff makes a claim under Fla. Stat. sec. 768.72(1) for punitive damages against
Defendant Google because there is a reasonable showing by evidence in the record and proffered
by the Plaintiff which would provide a reasonable basis for recovery of such damages.
Under Fla. Stat. sec. 768.72(2)
36
(2) A defendant may be held liable for punitive damages only if the trier of fact, based on
clear and convincing evidence, finds that the defendant was personally guilty of
intentional misconduct or gross negligence. As used in this section, the term:
(a) “Intentional misconduct” means that the defendant had actual knowledge of the
wrongfulness of the conduct and the high probability that injury or damage to the
claimant would result and, despite that knowledge, intentionally pursued that course of
conduct, resulting in injury or damage.
(b) “Gross negligence” means that the defendant’s conduct was so reckless or wanting in
care that it constituted a conscious disregard or indifference to the life, safety, or rights of
persons exposed to such conduct.
122. The Plaintiff has shown in this Complaint by evidence in the record and proffered here,
that Sundar Pichai (CEO) Google LLC, and Kenneth H. Yi, Director, Alphabet, Inc./Google
LLC, Legal - Securities, Corporate Governance & Finance, engaged in “Intentional misconduct”
and “Gross negligence” in the following particulars:
1. Google breached a duty of care to the Plaintiff under the Constitution and laws of
Florida, and of the United States, including the First Amendment;
2. Google breached the Google Terms of Service and License with the Plaintiff;
3. Google failed to provide the Plaintiff domain ownership documents under ICANN;
4. Google is the cause of the breach of care and duty to the Plaintiff;
5. The Plaintiff sustained damages as the result of Google’s intentional misconduct and
gross negligence.
and Google engaged in intentional misconduct and gross negligence with malice aforethought.
DEMAND FOR JURY TRIAL
123. Pursuant to Rule 1.430(b), of the Florida Rules of Civil Procedure, Demand For Jury
Trial, and Article I, Section 22, of the Florida Constitution, Trial by Jury, the Plaintiff demands a
jury trial of all issues so triable.
WHEREFORE, the Plaintiff respectfully requests the Court to enter judgment in its favor
against the Defendants as follows:
37
a. A writ of replevin against Google to recover the Plaintiff’s property being wrongly
detained: The Plaintiff’s Google Account, neilgillespie@mfi.net, the Neil Gillespie Blooger user
profile, blogger.com/profile/12580744990628852454 and his blogs, including:
• Neil 2020 blog, neil2020.blogspot.com

• Justice Network blog, nosueorg.blogspot.com
• Music and Video - Election 2020 blog, music4life2.blogspot.com
and the Neil Gillespie YouTube channel: @neilgillespie4184; and his Google Account
dissolvetfb@gmail.com and blog domain http://dissolvetfb.blogspot.com/
b. Judgment against Google for damages, treble damages, punitive damages,
and/or restitution in an amount to be determined at trial;
c. Judgment against Google for pre-and post-judgment interest;
d. Judgment against Google for the Plaintiff’s costs of suit, including reasonable
attorneys’ fees and expenses;
e. Judgment against Google for any and all such other relief as the Court may deem
proper.
f. A writ of replevin against Verizon to recover the Plaintiff’s property being wrongly
detained: The Plaintiff’s wireless telephone number 352-615-3819;
g. Judgment against Verizon for damages, treble damages, punitive damages,
and/or restitution in an amount to be determined at trial;
h. Judgment against Verizon for pre-and post-judgment interest;
i. Judgment against Verizon for the Plaintiff’s costs of suit, including reasonable
attorneys’ fees and expenses;
j. Judgment against Verizon for any and all such other relief as the Court may deem
proper;
38
k. A writ of replevin to recover the Plaintiff’s property being wrongly detained: The
Plaintiff’s current account for 352-850-5009 under a 1 Year and 400 minutes phone card, a “365-
DAY PLAN” activated November 3, 2023 and valid to November 2, 2024;
RESPECTFULLY SUBMITTED April 8, 2024.
NEIL J. GILLESPIE, Plaintiff pro se

2801 SW College Rd., STE 3
Ocala, FL 34474
Tel: 352-239-9037
Email: Neil4Justice@yahoo.com
Email: celticein@yahoo.com
(Florida Portal E-Service)
CERTIFICATE OF SERVICE
I hereby certify the First Amended Complaint was served April 8, 2024 on the Florida
Portal to the names shown below:
Department of State Agency Clerk Jenna McLanahan

Email: DOS.GeneralCounsel@DOS.MyFlorida.com
Damon J. Whitaker, damon.whitaker@bclplaw.com

Ezequiel Romero, ezequiel.romero@bclplaw.com
Bryan Cave Leighton Paisner LLP (Alphabet Inc. and Google LLC)
Benjamin Margo, bmargo@wsgr.com

Avishai Don, adon@wsgr.com
Wilson Sonsini (Alphabet Inc. and Google LLC)
Vandana Venkatesh, vandana.venkatesh@verizon.com

Verizon Executive Vice President & Chief Legal Officer
Brett B. Goodman, Esq. at brett@goodmanlawapc.com (not of record)
(the Verizon/Tracfone Defendants)
Neil J. Gillespie
39
Fw: Critical security alert
From: Neil J. Gillespie (celticein@yahoo.com)

To: damon.whitaker@bclplaw.com; celticein@yahoo.com; adon@wsgr.com; bmargo@wsgr.com;
ezequiel.romero@bclplaw.com; brett@goodmanlawapc.com; neil4justice@yahoo.com
Date: Tuesday, March 19, 2024 at 03:59 PM EDT
Damon J. Whitaker
Bryan Cave Leighton Paisner LLP
One Atlantic Center 14th Floor
1201 W. Peachtree St., N.W.
Atlanta, GA 30309-3471
RE: Google Critical security alert, Sign-in attempt was blocked
Dear Mr. Whitaker,
Forwarded below is a Google "Critical security alert" email to

neilgillespie@mfi.net that I received Wednesday, March 13, 2024 at
9:17 AM.
In the email Google wrote: "Sign-in attempt was blocked"

"neilgillespie@mfi.net" "Someone just used your password to try to
sign in to your account. Google blocked them, but you should check
what happened."
I am the person who used my password to sign into my Google

account neilgillespie@mfi.net, and I am the person whom Google
blocked from trying to sign in to my Google account. Thank you.
Sincerely,
/s/
NEIL J. GILLESPIE, Plaintiff pro se
2801 SW College Rd., STE 3
1
Ocala, FL 34474
Tel: 352-239-9037 (wireless)
Tel: 352-581-2600 (land line)
Email: celticein@yahoo.com (Florida Portal E-Service)]
----- Forwarded Message -----

From: Google <no-reply@accounts.google.com>
To: "neilgillespie@mfi.net" <neilgillespie@mfi.net>
Sent: Wednesday, March 13, 2024 at 09:17:40 AM EDT
Subject: Critical security alert
Sign-in attempt was blocked

neilgillespie@mfi.net
Someone just used your password to try to sign in to your account.

Google blocked them, but you should check what happened.
Check activity
You can also see security activity at

https://myaccount.google.com/notifications
You received this email to let you know about important changes to your
Google Account and services.
© 2024 Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043,
USA
Dissolve The Florida Bar http://dissolvetfb.blogspot.com/

Monday, August 18, 2014 About Me
Dissolve TFB
Subversive Organization: The Florida Bar
View my complete profile
Section 876.05 of the Florida Statutes requires all employees of the state to take a loyalty oath to "support the
Constitution of the United States and of the State of Florida."
However The Florida Bar recently disclosed it does not have section 876.05 loyalty oaths for its employees.
Therefore, on information and personal belief, The Florida Bar is a "subversive organization" within the meaning of
Chapter 876, Florida Statutes, Criminal Anarchy, Treason, and Other Crimes Against Public Order, and "shall be
dissolved" as provided by section 876.26, Fla.Stat.
876.26 Unlawful for subversive organizations to exist or function.—

"It shall be unlawful for any subversive organization or foreign subversive organization to exist or function in the
state and any organization which by a court of competent jurisdiction is found to have violated the provisions of
this section shall be dissolved,..."
_________________________________________________________________________________
Florida Jurisprudence 2d, Volume 9, Civil Servants, § 111 Loyalty Oaths (2007)
All public employees are required to take an oath to support the Constitution of the United States and of the State
of Florida. [fn1] An employee who refuses to take the required loyalty oath must be discharged. [fn2].
The oath's requirement for pledging to support the state and federal Constitutions is constitutionally valid. [fn3]
Although the oath refers to the affirmant as being a citizen of the United States and State of Florida, [fn4] to ban
lawful aliens from public employment is unconstitutional and aliens may use a modified oath with the words "a
citizen of the State of Florida and of the United States of America" stricken. [fn5]
Fn1. § 876.05(1), Fla. Stat.

Fn2. § 876.06
Fn3. Connell v. Higginbotham, 403 U.S. 207, 91 S. Ct. 1772, 29 L. Ed. 2d 418 (1971).
Fn4. § 876.05(1), Fla. Stat.
Fn5. City of Orlando v. State of Fla., 751 F. Supp. 974 (M.D. Fla. 1990).
________________________________________________________________________________
CONNELL v. HIGGINBOTHAM ET AL. 403 U.S. 207 (1971)
http://scholar.google.com/scholar_case?case=17784843264017020647
No. 79. Supreme Court of United States.
Argued November 19, 1970
Decided June 7, 1971
APPEAL FROM THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF FLORIDA
Sanford Jay Rosen argued the cause for appellant.

With him on the brief were Tobias Simon and Melvin L. Wulf.
Stephen Marc Slepin argued the cause for appellees.

With him on the brief were Rivers Buford, Jr., and James W. Markel.
PER CURIAM
This is an appeal from an action commenced in the United States District Court for the Middle District of Florida
challenging the constitutionality of §§ 876.05-876.10 of Fla. Stat. (1965), and the various loyalty oaths upon which
appellant's employment as a school teacher was conditioned. The three-judge U. S. District Court declared three of
the five clauses contained in the oaths to be unconstitutional,[*] and enjoined the State from conditioning 208*208
employment on the taking of an oath including the language declared unconstitutional. The appeal is from that
portion of the District Court decision which upheld the remaining two clauses in the oath: I do hereby solemnly
swear or affirm (1) "that I will support the Constitution of the United States and of the State of Florida"; and (2) "that
I do not believe in the overthrow of the Government of the United States or of the State of Florida by force or
violence."
2
On January 16, 1969, appellant made application for a teaching position with the Orange County school system.
She was interviewed by the principal of Callahan Elementary School, and on January 27, 1969, appellant was
1 of 8 3/13/2024, 9:53 AM
Blogger https://accounts.google.com/v3/signin/rejected?TL=ADg0xR0OMd571...
3
1 of 1 3/13/2024, 10:29 AM
Domain Name: BLOGSPOT.COM
From: Neil4Justice (neil4justice@yahoo.com)

To: abusecomplaints@markmonitor.com; custserv@markmonitor.com; compliance@markmonitor.com;
celticein@yahoo.com; neil4justice@yahoo.com
Date: Saturday, April 6, 2024 at 09:17 PM EDT
MarkMonitor, Inc.
1120 S. Rackham Way
Suite 300
Meridian, Idaho 83642
Tel. 1+208.389.5740
custserv@markmonitor.com
compliance@markmonitor.com
RE: Domain Name: BLOGSPOT.COM

Registrar WHOIS Server: whois.markmonitor.com
Registrar: MarkMonitor Inc.
Registrar Abuse Contact Email: abusecomplaints@markmonitor.com
Registrar Abuse Contact Phone: +1.2086851750
Registrant Organization: Google LLC
Dear MarkMonitor, Inc.:
My name is Neil J. Gillespie. I am contacting you as the Registrar for

BLOGSPOT.COM, owned by Google LLC. I am the founder and
owner of Justice Network, engaged in advocacy, education, news
gathering & dissemination, and helping people fight injustice. I am
also a 2024 candidate for U.S. president, NPA, no party affiliation
ICANN, the Internet Corporation for Assigned Names and Numbers,

suggested I contact you for my domain ownership documents for the
following blogspot blogs:
4
Justice Network blog

https://neil4justice.blogspot.com/
Neil J. Gillespie

Justice Network blog, NoSue.org

https://nosueorg.blogspot.com/
Music and Video - Election 2020, Music4Life2

https://music4life2.blogspot.com/
Neil Gillespie

https://dissolvetfb.blogspot.com/
Google LLC has unlawfully detained a number of my blogs. Google

claims it cannot verify that I own certain Goggle Accounts associated
with my blogs because I lost a recovery phone number. However I
have the correct email address and password for my Google
Accounts. This matter is currently in litigation, see Neil J. Gillespie v.
Alphabet/Google et al, Marion County Florida Circuit Court, case
2024-CA-0209, removed to United States District Court, Middle
District of Florida, Ocala Division, case 5:24-cv-101, remanded back
to Florida on March 26, 2024.
In addition, please provide the SSL certificates for my blogspot blogs

shown above.
Thank you.
Sincerely,
/s/
Neil J. Gillespie
Justice Network
2801 SW College Rd
Ocala, FL 34474
Tel: 352-581-2600 (land line)
Tel: 352-239-9037 (wireless)
Email: celticein@yahoo.com
(Florida Portal E-Service)
Neil J. Gillespie for President (Statement of Organization)

Principal Campaign Committee ID C00627810
https://docquery.fec.gov/cgi-bin/fecimg/?C00627810
Neil J. Gillespie (Statement of Candidacy)

Candidate ID P60022993
https://docquery.fec.gov/cgi-bin/fecimg/?P60022993
AFFIDAVIT OF NEIL 1. GILLESPIE
Unwanted sign in requests from Google
STATE OF FLORIDA )
) SS.:
COUNTY OF MARION )
BEFORE ME, this day personally appeared NEIL J. GILLESPIE, who upon oath deposes
upon personal knowledge and states:
1. I am over the age of eighteen and competent to testify as to the facts and matters set
forth below. I make this affidavit upon personal knowledge unless otherwise expressly stated.
2. My current desktop computer has a Windows operating system by Microsoft

Corporation. I do not "sync" my computers or wireless devices.
3. On March 12,2024, I removed Google Chrome, a web browser developed by Google,

from my computer. Before I removed Google Chrome, I deleted my browsing history, and other
saved settings, including my bookmarks, my saved passwords, and my saved payment methods.
4. On March 12,2024 I made Mozilla Firefox the default browser on my desktop computer.
I manually reinstalled on Firefox my bookmarks, passwords and address autofill.
5. I selected "DuckDuckGo" as my default search engine on the Firefox browser. I

deselected "Google" and "Amazon.com" as alternative search engines. I did not install any of the
5,008 available search engine extensions found in Firefox Search Tools.
6. While using the Firefox browser, I am logged in to my Firefox account.
7. I do not log in to a Google Account unless required to use a Google product.
8. I continue to receive unwanted sign in requests from Google while not signed in to a
Google Account after removing Google Chrome and Google Search from my computer,
9. On March 25,2024, a Google sign in pop-up request appeared on my computer screen

when I began signing in to my X (formerly Twitter) account. The Google message said:
Sign in with Google

Use your Google Account to sign into twitter.com
No more passwords to remember. Signing in is fast, simple and secure.
5
AFFIDAVIT OF NEIL J. GILLESPIE
Unwanted sign in requests from Google
10. Below is an image I made of the Google pop-up request I got on March 25,2024 when I
began to sign in to my X (formerly Twitter) account on my desktop computer.
x
~
l··.~ ~tllll (ium:Jc h\,;lnull hi
Sign in to X
Ul!j""l",.,,tl'\~i
• 5-<!n" "on A.pI<

PI
'~I~:I' pJUflJIlt
11. I have been getting similar Google pop-up requests on my other online accounts even
after removing Google Chrome and Google Search, and not signed in to a Google Account.
12. Since removing Google Chrome and Google Search from my desktop computer, it
appears Google still tracks every search I make, every click I take, every move I make, every
step I take, while I am not signed in to a Google Account.
FURTHER AFFIANT SAYETH NOT.
The foregoing instrument was acknowledged before me, this ;)IoTlJ day of March, 2024,
by Neil 1. Gillespie, who is personally known to me, or who has produced ~LDL q4-2..1 <.o?:loSbOC/CjO
as identification and states that he is the person who made this affidavitand that its contents are
truthful to the best of his knowledge.
,,~~',lt:', HEATHER MCCONNELL

~~~e:NotarY Publlc-STdle of Florida
LXtl.t1 )-lC CCIL.UL(
SEAL ~. ;E Commission # H H 413639 NOTARY PUBLIC
~''i' 'iI:~ My Commission Expires
'I,,?:;,,:;,,'
We crf{, ~ er
June 22. 2077
f\-l CCohV1 e I (
My Commission Expires: 0 lc - 2--1- - 2- D2 I Print Name of Notary Public
2
Re: WAGES CAN BE GARNISH*
From: Sandi Kola (sandikola5463@gmail.com)

To: sandikola5463@gmail.com
Bcc: celticein@yahoo.com
Date: Tuesday, March 19, 2024 at 01:20 PM EDT
Garnishment Notification and Arrest Notice
Case File#: JMD-01147791

Last Date of Lawsuit: March 26th, 2024
Settlement Amount of Today: $850.00
Dear Debtor,
This letter is to notify you that we have received a Summons of Garnishment on your wages. This means
that someone you owe money to has been awarded a judgment by the court for payment of the debt. The
court has ordered us your employer to deduct 25% percent of your disposable earnings and make
payment to the court on your behalf. The following applies to you:
Before you are arrested
If you pay in full, or make a part-payment before you are arrested, the warrant will be recalled and amended.
However, it will be immediately re-issued if the debt is not paid in full.
After you are arrested
Once the warrant has been served, your only options are to serve the time in prison or pay the debt (plus
costs) in full at the courthouse.
If you want to stop the garnishment deductions from your paycheck, you must obtain a release or pay the
entire amount you owe, which you can pay with the help of AMERICAN EXPRESS CARD in order to close
this account.
What is garnishment?
Garnishment is a legal process that allows a creditor to remove funds from your [bank]/ [credit union]
account to satisfy a debt that you have not paid. In other words, if you owe money to a person or company,
they can obtain a court order directing your bank to take money out of your account to pay off your debt. If
this happens, you cannot use that money in your account.
Why am I receiving this notice?
On March 19th, 2024 we received a garnishment order from a court to [freeze/remove] funds in your
account. The amount of the garnishment order was for $1418.16. We are sending you this notice to let you
know what we have done in response to the garnishment order. You can contact your creditor for a
settlement amount.
YOU CAN APPLY FOR AN OUT OF COURT RESOLVE OPTION (OOCR): THEN IMMEDIATELY CONTACT
US THRU EMAIL BETWEEN WORKING HOURS

Google Lawsuit First Amended Complaint

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Google Lawsuit First Amended Complaint

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Google Lawsuit First Amended Complaint

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Filing # 195700282 E-Filed 04/08/2024 02:18:51 PM

MARION COUNTY CIRCUIT COURT

ALPHABET INC., a Foreign Profit Corporation,

FIRST AMENDED COMPLAINT

First Amended Complaint, and states:

located Marion County, Florida.

an order authorizing the clerk of the court to issue a writ of replevin.”

show cause to serve on all the Defendants.

Service of Process on the Defendants”, Filing # 195094139 E-Filed 03/29/2024.

department may dissolve a limited liability company administratively.

Agency Clerk Jenna McLanahan at Email: DOS.GeneralCounsel@DOS.MyFlorida.com, as well

reopened the remanded case in this court, case no. 2024-CA-0209.

Congress shall make no law respecting an establishment of religion, or prohibiting the

of, or in combination with, the Defendants, in violation of 42 U.S.C. § 1983:

42 U.S.C. § 1983 - Civil action for deprivation of rights

Count I: REPLEVIN, Fla. R. Civ. P. Form 1.937

Blooger user profile, blogger.com/profile/12580744990628852454, and his blogs, including the

Neil 2020 blog, neil2020.blogspot.com

the Plaintiff’s Account dissolvetfb@gmail.com and blog domain http://dissolvetfb.blogspot.com/

recovery phone #352-615-3819, and Plaintiff’s current account for #352-850-5009.

$136,650, determined as follows:

A. The Plaintiff’s Google Account, neilgillespie@mfi.net: $138,500, including the Neil

• Neil 2020 blog, neil2020.blogspot: $13,800

B. The telephone number 352-615-3819: $136,650

C. The Plaintiff’s current Tracfone account for 352-850-5009: $149.96

19. A. The Plaintiff is entitled to the possession of his Google Account

channel, the Plaintiff’s Google Account dissolvetfb@gmail.com and blog domain

http://dissolvetfb.blogspot.com/ his intellectual property under the Google Terms of Service

copy of which appears at Appendix B to the Complaint for Replevin.

Account: #1 neilgillespie@mfi.net, #2 dissolvetfb@gmail.com. To the Plaintiff’s best

United States. (Appendix C to the Complaint for Replevin).

Scribd, Facebook, and others.

Esposito et al. v. Cellco Partnership d/b/a Verizon Wireless

Administrator to opt-out, to be excluded from the Settlement Class in the lawsuit.

to get his domain ownership documents for his blogger domains.

registrar for Blogspot.com. Markmonitor is a subsidiary of Newfold Digital, Inc., a Foreign

Profit Corporation, located at 5335 Gate Parkway, Jacksonville, FL, 32256.

ownership documents for the following blogspot blogs:

Neil J. Gillespie for President 2024

Justice Network blog

Neil J. Gillespie for President 2020

Justice Network blog, NoSue.org

Music and Video - Election 2020, Music4Life2

Dissolve The Florida Bar

The Fictitious Name Registration Number of Justice Network is G18000014506, currently

Neil J. Gillespie for President (Statement of Organization)

Neil J. Gillespie (Statement of Candidacy)

ego. This Complaint refers to Google and Alphabet together as “Google.”

34. Defendant Verizon Communications, Inc., is a publicly traded American multinational

Services, LLC together as “Verizon”.

and Tracfone together as “Verizon”.

JURISDICTION AND VENUE

is a court of competent jurisdiction. Fla. Stat. 26.012(2).

GOOGLE TERMS OF SERVICE

Appendix A, at Exhibit A.1 to the Complaint for Replevin.

interacts with Google’s services.

and the Plaintiff is contracting with Google.

manage his Google Account neilgillespie@mfi.net.

Complaint for Replevin)