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Farah & Farah, Floyd Matthews/ City of Jacksonville
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- City: Jacksonville - State: Florida
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ID#: 887 Date Posted: April 22, 2008
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Detailed Information
Please state how you would like Senator Nelson to help you:
(1). I respectfully request that you enforce Fl. Stat. 768.28,
whereas the legislative intent of said provisions were designed
for the protection of all the citizens of the State of Florida,
regardless of race, religion, sex or disability, who suffer injury
as the result of the negligent acts or omissions of municipal
employees in the State of Florida, who do not serve in a
judicial or quasi judicial capacity, whereas I have not been
allotted equal protection or due process of law. (SEE)
Cauley v. Jacksonville 403 So.2d 379, pg. 379, (SEE) The Florida
Senate Interim Project Report 2005-147, pg. 2, (SEE) Advisory
Legal Opinion- AGO 76- 41, February 23, 1976, Subject: Tort
Liability and Sovereign Immunity, pg. 1, (SEE) Florida Statute
768.28 (1), (SEE) Sec. 1, 14th Amendment, Constitution of the
United States.
(2). I respectfully request that you enact a Legislative Claim Bill
pursuant to Fl. Stat. 768.28(5), whereas the damages I incurred
as a result of this accident exceed the statutory limit of
$100.000, (SEE) Damages, (SEE) Cauley v. Jacksonville 403 So.
2d 379, pg. 280, (SEE) The Florida Senate Interim Project
Report 2005- 147, pg 3 “Claims Bill Process”, (SEE) Fl. Stat.
768.28(5), (SEE) Sec. 1, 14th, Amendment, Constitution of the
United States.
This request is made under the interpretations of the Physical
Evaluation Board, of the United States Navy, Washington D.C.,
with supporting documentation which states: Category 1,
Unfitting Conditions 1. Lumbar disc disease with Spinal
stenosis and left lumbar L5- S1 radiculopathy, 1.1 Lumbar and
thoracic paraspinal muscle spasm II, (a) This disability occurred
while entitled to receive basic pay, (b) This disability did not
occur during a period of unauthorized absence., ( c) This
disability is not the result of intentional misconduct or willful
neglect., (12). This disability is permanent, (14). All board
members concurred., (SEE) “Findings of the Physical Evaluation
Board” whereas these determinations reflect in box #23 and
box #24 of my DD214 which states: box #23 Type of
Separation:” Discharged”, box#24 Character of Service
“Honorable”, (SEE) DD214, (3). I respectfully request that you
launch an investigation to vindicate my Constitutional Rights
pursuant to 42 U.S.C 1988, 18 U.S.C. 241 (Conspiracy to
deprive citizens of rights)., 42 U.S.C. 1985 (Conspiracy to
interfere with civil rights) and
prosecute Bruce Gartner (Failure to mitigate damages), Leslie
Jean Scott Bart (Failure to request the direct documentary
evidence, which is the Accident and Investigation Report
pursuant to Ch. 14- 90.005, Equipment and Operational Safety
Standards Governing Bus Transit Safety System), David
Candeleria (Submitting false documents into a court of law),
Complaint and Amended Complaint filed under the “Doctrine
of Dangerous Instrumentality”, inapplicable in the State of
Florida -vs- a Governmental entity, pursuant to a claim filed
under the Waiver of Sovereign Immunity, which is Fl. Stat.
768.28(7)., Charge David Candeleria with 5, Criminal counts
of violating the HIPPA Privacy Act, whereas he intentionally with
held my case file and failed to inform me that Sean Granat
Esquire, Assistant General Counsel, City of Jacksonville had
subpoenaed my protected health information pertaining to
HIV/ PSYC. / DRUG ABUSE PROBLEMS , whereas I was
discharged from the U.S. Navy for a L5- S1 disc injury with
radiculopathy, whereas my case file is in the custody of Floyd
Matthews, Fl. Bar No. 182511, 2237 Riverside Avenue,
Jacksonville Fl. 32204 (904) 384- 0505, I respectfully request
that you send a Agent of the Attorney General’s Office to
retrieve my case file from his office, so that this might
graphically illustrate the validity of my statements in regards
to these dire set of circumstances, I also have three letters
from David Candeleria dated: May 30, 2006, June 12, 2006,
June 27, 2006 after Judge Peter J. Fryfield granted his Motion
to Withdraw, after I fired him, on May 24, 2006,
(* note, that this is the same exact day in which my medical
records were subpoenaed, May 24, 2006) whereas he makes
no reference to my subpoenaed medical records, whereas his
posture is only to forward my case file to another attorney, in
reference to the letter dated June 27, 2006, David Candeleria
states: Dear Mr. Potts: I truly appreciate you keeping us advised
of your progress in securing a new attorney to represent you in
regards to this matter. Please understand our attorney /client
relationship terminated many weeks ago. I want to remind
you that you have no obligation to this office or to me for that
matter. When you retain new counsel, please have that attorney
send me a letter so that I can produce a copy of your case file
for his /her convenience, by and through the written
statements of David Candeleria and the forwarding of
my case file to Floyd Matthews , Fl. Bar No. 182511, 2237
Riverside Avenue, Jacksonville Fl. 32204 (904) 384- 0505, and
the failure to inform me via written correspondence, that my
protected health information had been subpoenaed by Sean
Granat Esquire Assistant General, Counsel City of Jacksonville
pertaining to HIV/ PSYC/ DRUG ABUSE PROBLEMS, for an
accident on a Jacksonville Transit Authority bus, whereas I was
discharged from the United States Navy for a L5-S1 disc injury
with radiculopathy, David Candeleria is in clear violation of Fl.
Bar Rule 4- 1.16 Termination of Representation.(d) Protection
of clients interest., which states: Upon termination of
representation a lawyer shall take steps to the extent
reasonably practicable to protect a client’s interest such as
giving reasonable notice to the client, allowing time for
employment of other counsel, surrendering all paper and
property to which the client is entitled and refunding any
advance payment of fee that has not been earned, the lawyer
may retain papers and other property to the extent permitted
by law
LAW
Florida Statute 395.3025(4)(d) - VIOLATION
5, HIPPA Privacy Act “Criminal” – VIOLATION(S)
4th Amendment, Constitution of the United States - VIOLATION
*note: (SEE) Clerk of Court Inquiry: 5/24/2006, MOTION TO
WITHDRAW AS ATTORNEY- GRNTING, 5/24/2006 SUBPOENA
RETURNED SERVED-
JACKSONVILLE SPINE
CENTER 5/24/2006 SUBPOENA RETURNED SERVED- BAPTIST
BEACHES MEDICAL
CENTER (Records Department), 5/24/2006 SUBPOENA
RETURNED SERVED- BAPTIST
MEDICAL CENTER, 5/24/2006 SUBPOENA RETURNED SERVED-
SHANDS
JACKSONVILLE, THOMAS JEFFERSON UNIVERSITY HOSPITAL -
PHILADELPHIA.
PA., SUBPOENA SERVED UNDOCUMENTED WITHIN THE CLERK
OF COURTS INQUIRY FOR HIV/PSYC./ AND DRUG ABUSE
PROBLEMS, JUNE 26, 2006 (SEE) letter Sean Granat
Esquire Assistant General Counsel, City of Jacksonville, (SEE)
Thomas Jefferson Hospital, Patient Authorization Form (Medical
Records), as it pertains to HIV/PSYC/DRUG ABUSE PROBLEMS
(4). I respectfully request that you launch an investigation to
vindicate my Constitutional Rights pursuant to 42 U.S.C 1988,
18 U.S.C. 241 (Conspiracy to deprive citizens of rights)., 42
U.S.C. 1985 (Conspiracy to interfere with civil rights) and
prosecute Floyd Matthews Esquire and Sean Granat Esquire,
Assistant General Counsel, City of Jacksonville,
whereas they signed a Joint Stipulation, pertaining to an
Amended Complaint, filed on the same date as the Amended
Complaint Apr. 17, 2007, whereas the Amended Complaint
contained no cause of action for Negligence, pursuant to a
claim filed under the Waiver of Sovereign Immunity, which is
Fl Stat 768.28, whereas Floyd Matthews substituted Count 1,
whichshould have illustrated Negligence and substituted Count
1 for Negligence with the Prayer for Relief, in accordance to Am
Jur Pleadings And Practice Forms (6) Checklist - Matters that
should be alleged in complaint, petition, or declaration in
action by a passenger against a common carrier for personal
injuries arising from an accident, the Prayer for Relief, under
instruction, always comes at the end of the complaint, this
defect is duly noted within Sean Granat’s affirmative defenses
as set forth in his response to the Amended Complaint filed by
Floyd Matthews Esquire, Defendants Jacksonville
Transportation Authority’s Answer to Plaintiff’s Second
Amended Complaint, SEVENTH AFFIRMATIVE DEFENSE, which
states: Plaintiff’s Complaint fails to state a cause of action
against Defendant upon which relief can be granted.
Due to the torrid chain of events, which have transpired and
the duration of this abuse, whereas I have suffered
humiliation, financial ruin, marital dissolution,
persecution, Constitutional castration, judicial rape and
sodomy, after defending this country, as a Petty Officer in
the United States Navy in Operation Enduring Freedom, in
direct response to the 911 terrorist attacks, I am
compelled to expose any and all persons involved in this
administrative hell storm via a Youtube documentary dressed
in my Naval uniform displaying any and all medals and awards,
whereas I will directly tie these events directly to the racial
disparity in which Rev. Jeremiah Wright spoke about.
QUESTION
How can Sean Granat Esquire Assistant General Counsel deny
the fact that the former attorney’s of the Office of General
Counsel went before the Supreme Court of the State of Florida
to uphold the validity of Fl. Stat. 768.28, in Cauley v.
Jacksonville 403 So. 2d 279, which was held to be
Constitutional under the 14th Amendment, equal justice, due
process affirmed, whereas Mrs. Cauley was found to be 75%
negligent in the operation of her motor vehicle and allotted
compensation consistent with the damages she incurred as a
result of crashing her vehicle into a long standing road
depression, however in regards to a black male, who was a
Petty Officer in the United States Navy, with no criminal record,
en route to duty aboard the USS John F. Kennedy CV- 67,
injured as a passenger on a Jacksonville Transportation
Authority bus, when the driver ran up on the curb area and
blew out the outside right rear tire, causing my injuries, Sean
Granat Esquire, Assistant General Counsel City of Jacksonville
states:
FOURTH AFFIRMATIVE
DEFENSE - Plaintiff was himself negligent and careless and said
negligence was the sole, direct and proximate cause of his
injuries or contributed to said cause, and damages should be
barred thereby or should be reduced in portion thereto, (SEE)
Defendant Jacksonville Transportation Authority, Answer To
Plaintiffs’ Second Amended Complaint, however the Physica
Evaluation Board, Washington D.C. states:
( c) This disability is not the result of intentional misconduct or
willful neglect., (12). This disability is permanent., (14). All
board members concurred., (SEE) “Findings of the Physical
Evaluation Board” whereas these determinations reflect in box
#23 and box #24 of my DD214 which states: box #23 “Type of
Separation”,” Discharged”, box#24 “Character of Service”
“Honorable”., (SEE) DD214, I guess the only relevant question
to ask, in regards to this matter, is Sean Granat Esquire
Assistant General Counsel, City of Jacksonville, vested with the
inherent authority to over rule The Physical Evaluation Board, a
FEDERAL entity of the United States Government, by and
through the United States Navy, and the Florida Senate in the
enacting of Fl. Stat. 768.28, which is the Waiver of Sovereign
Immunity, am I not a man, am I not a brother.
_______________________
Ronald D. Potts
221 N. Hogan St. #151
Jacksonville Fl. 32202
akaipro2000@yahoo.com
STANDBY YOUTUBE DOCUMENTARY DISPLAYING
ALL YOUR DEFECTIVE PAPER WORK, IT TURNS
OUT REV. WRIGHT WAS RIGHT, I WILL EXPOSE
YOU AND OFFER THE STORY TO ANY AND EVERY
NEWS PAPER, PUBLISHING COMPANY ON THE FACE
OF THE EARTH FOR THE FOOD AND CLOTHING THAT
YOU HAVE TAKEN OUT OF MY CHILDRENS MOUTH
AND OFF OF THERE BACKS AFTER I SERVED THIS
COUNTRY, MY CONTENTION IS TO MACK YOU
LIKE A PIMP FROM A 70\'S BLACKSPLOTATION MOVIE
LOL : )
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