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UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION
SARAH JACKSON,
Plaintiff,
v.

Case No.: __________________

CAMERON GIOVANELLI,
SARAH GIOVANELLI, and
IMMANUEL BAPTIST CHURCH,
Defendants.
/
COMPLAINT
Plaintiff, SARAH JACKSON, by and through his undersigned counsel, sues Defendants,
CAMERON GIOVANELLI, SARAH GIOVANELLI, and IMMANUEL BAPTIST CHURCH;
and alleges:
JURISDICTION, PARTIES AND VENUE
1.

This is an action for damages arising out of the defamation of Plaintiff’s

character.
2.

This Court has jurisdiction pursuant to 28 U.S.C. § 1332 since the amount in

controversy exceeds $75,000, exclusive of interest, costs, and attorneys’ fees, ad is between
citizens of different states.
3.

Venue is proper in the Middle District of Florida pursuant to 28 U.S.C. § 1391 as

the Defendant has its principal place of business in Duval County, Florida. Pursuant to Middle
District Local Rule 1.02(c), venue is proper in the Jacksonville Division of the Middle District of
Florida because the cause of action accrued in one of the counties of which the Tampa Division
is comprised, as set forth in local Rule 1.02(b)(4).

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4.

Defendant, Immanuel Baptist Church, is a Florida not for profit corporation, with

its principal place of business in Duval County, Florida, within the Middle District of Florida.
5.

At all times material, Defendant, Immanuel Baptist Church, was the employer of

Defendant, Cameron Giovanelli.
6.

Defendant, Cameron Giovanelli, is a citizen of the state of Iowa.

7.

Defendant, Sarah Giovanelli, is a citizen of the state of Iowa.

8.

Plaintiff, Sarah Jackson, is a citizen of the state of Maryland.

9.

All conditions precedent to the maintenance of the causes of action alleged herein,

if any, have occurred or been performed, excused, or waived.
GENERAL ALLEGATIONS
10.

Cameron Giovanelli abused his position of leadership, abused the trust of the

members of his church and congregation, and committed unspeakable acts of sexual abuse
against Sarah Jackson.
11.

After suffering in silence for over a decade from Cameron Giovanelli’s abuse, she

decided to share her story and shared the following:

(May 11, 2018 post).

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12.

Following that, Sarah published an open letter to Cameron regarding her journey

to find the courage to expose the truth. She posted:
I’m sure you have now seen the article that came out about what happened in
2006-2007. If not, I am sure that you soon will and you will try to do some
damage control. If I know you like Im pretty sure I do, you feel betrayed.
Betrayed that I I keep “our secret” after I had promised so many years to do so.
You made sure to tell me for so many years of each pastor that was “found out”
and how much that “scared you”. Remember all the times you acted like you were
going to call things off between us as a way to intimidate me to reassure you that I
would never speak a word of our relationship? Me too. So very vividly.
(December 9, 2018 post).
13.

In response, the Defendants took part in a coordinated effort to deliberately and

knowingly communicate false information in an attempt to destroy Sarah Jackson’s credibility,
including attacks on her family and her children.
14.

Greg Neal, the de facto sole leader of Defendant, Immanuel Baptist Church, is no

stranger to claims of sexual abuse of minors under its care.
15.

Greg Neal previously faced similar accusations of improper sexual behavior

towards minors.
16.

Assistant State Attorney James Colaw described the evidence of Greg Neal’s

video voyeurism of minors changing clothes in his office as “overwhelming.”1
17.

Rather than admitting what he had done was wrong, Greg Neal decided to try

another approach: shame the victim and accuse the victims of lying about the abuse. Id.2

1

Scanlan, Dan, “Orange Park co-pastor declares innocence in video voyeurism case”, October 5, 2011, available
online at https://www.jacksonville.com/article/20111005/NEWS/801243291 (last accessed April 9, 2020).
2

At that time, the Neal Enterprise employed another accused abuser, David Hyles. David Hyles, and the Hyles
Enterprise also taught Greg Neal how to deal with these situations by denying the accusations and smearing the
character of the victims. The Hyles Enterprise is now facing a RICO lawsuit in the Northern District of Illinois for
its coverup of similar sexual abuse by its leaders/employees.

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18.

Greg Neal was ultimately able to escape prosecution because the statute of

limitations had expired, but the lessons learned in that situation formed the same playbook to
confront the allegations against Cameron Giovanelli.
19.

Defendant, Immanuel Baptist Church, was in the final stages of launching a new

“college” and it had a large church, school, and publishing company; there was much to protect
financially and ensure there would not be a stain on its reputation that would stop people from
sending their children or dollars to Defendant, Immanuel Baptist Church.
20.

To protect their financial interests, Defendants began to attack Sarah Jackson to

ensure her story was not believed, beginning with Cameron Giovanelli himself:
In May of 2018, Sarah (Hall) Jackson took to social media and falsely accused me
of having a sexual relationship with her during her Senior year of high school.
This accusation is false!
These blatant lies about me have caused me to resign from a position of
leadership . . . . The morning after Sarah (Hall) Jackson posted her lie to
Facebook I called Stacey Shiflett to let him know that it was not true and that I
would pray that God would give him the spiritual discernment needed as he dealt
with it.
***
Why would Sarah (Hall) Jackson do such a thing? That question has raced
through my mind many times over. That question has been asked me by many
too. I have no idea why she would lie, and especially why she would pick me to
lie about. If I am guilty of anything it is of helping the Hall family through family
disputes, wayward teenagers, struggling marriages, disjointed family
relationships, and other such family related issues that they faced through the
years I was their pastor.
(May 30, 2019 “Statement from Cameron Giovanelli) (emphasis in original).
21.

Apparently, calling Sarah Jackson a liar was not enough, so Cameron Giovanelli

continued the attacks by digging up things from Sarah Jackson’s family’s past as an attempt to
smear Sarah Jackson’s character by incidents of her family (whether true or not).

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22.

Cameron Giovanelli then continued the attacks on Sarah Jackson personally and

disclosed to the world matters that were shared within the confines of a confidential clergypenitent relationship:
Sarah (Hall) Jackson has had a troubled past, and as her pastor, and the pastor of
her family for many years I counseled them all through some difficult times. An
allegation like this is terrible and evil, but it is a practice that has become a trend
in her family. Her older sister made the same accusation about one of their family
members, and her mother made accusation of a church member making
inappropriate advances to her as well; both of those accusations were before I
came to Calvary. Both mom and daughter (older sister) sought counsel regarding
those situations due to the division that it had caused in the family. Both men
denied those claims as I deny this accusation, and neither claim ever led to any
legal action!
***
After she graduated from High school, I received a call at the once that Sarah
(Hall) Jackson wanted to meet with me. We scheduled that meeting in the church
offices and she proceeded to tell me that she had had an affair with a married man
whom she had met at work. She was seeking counsel because the man was
married and she felt that she needed to go and tell his wife.
Over the years many members from Calvary have messaged and/or called to ask
Sarah and I to pray and Sarah (Hall) Jackson was no different. Sarah (Hall)
Jackson has asked for prayer when she found that her husband was having an
affair with her best friend who had been living with them at the time. Sarah (Hall)
Jackson asked for prayer when she “lost” her baby. However, she posted to social
media that she had an abortion.
(May 30, 2019 “Statement from Cameron Giovanelli).
23.

Cameron Giovanelli could not have been more forceful in his denial, which is

now known to be a lie, when he attacked Sarah Jackson:
I do not deny the fact that Sarah (Hall) Jackson has had a rough life and may have
been abused at some point in her life, but it was not by me!
***
Sarah (Hall) Jackson has concocted a fabricated story of vague occurrences of her
and I meeting and things that never happened. She has fabricated a story and
timeline using places that I would preach, teach, and state openly as places of
special meaning to me with my family, or where I spent time with God – never
her! Her claims are all fabricated and not one can be supported with evidence.

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Sarah (Hall) Jackson is a liar and her day of dragging my name through the
mud is done! For over one year I have allowed her to smear my name, seek to
destroy my reputation, and harass my family through social media.
***
I did not do what Sarah (Hall) Jackson has accused me of and I am appalled at the
way that Stacey Shiflett handled it. How dare he blame others for not performing
a “full investigation” when he himself did no-such-thing!
(May 30, 2019 “Statement from Cameron Giovanelli) (emphasis in original).
24.

Cameron Giovanelli ended his post by stating: “I have no further intention of

speaking on this issue.” But, of course, that would prove to be yet another lie.
25.

On June 6, 2019, Cameron Giovanelli would go on to post additional attacks on

Sarah through the guise of “asking questions.”
26.

But, still, the attacks were not over. The next post was by Sarah Giovanelli, who

wrote:
I know you Sarah. I know what kind of troubled teenage girl you were. I know
your immorality and your promiscuous lifestyle. I know the person you are. You
are a victim, but certainly not of my husband. You are a victim of your own
wickedness. You are a victim of your own sinfulness. You are a victim of the
blame you place on others for the choices you have made. You are a victim of
those people who are using you for their agenda. You are a victim of your own
desire for attention.
***
I am not afraid to stand up to my husband if he was indeed guilty, which I know
for a fact he is not. I am also not afraid to stand up to your false accusations. I
rebuke you for what you have said about my husband. I rebuke you for your
abortion. I rebuke you for your adulterous behavior. I rebuke you for your
scandalous pictures and posts. I rebuke you for being more like the Proverbs 7
woman than the Proverbs 31 woman. I call for you to repent and confess your sins
to God.
***
I am writing to rebuke you before them. They need to know who it is they are
following. They need to know the truth about the lady who made up these wicked
lies. You need to be exposed Sarah Jackson, not for the sake of those who are the
enemies of righteousness, but for those who you have confused with your error.
(June 12, 2019 Statement by Sarah Giovanelli).

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27.

And the group trying to hide Cameron Giovanelli’s misdeeds even enlisted

Cameron Giovanelli’s mother-in-law (Sarah Giovanelli’s Mother) to join the attacks, who called
Sarah Jackson’s post “disgusting and absurd” and vouched for Cameron Giovanelli’s character
as a “loving husband and a caring father.” (June 4, 2019 Statement by Earlene Knight).
28.

Cameron Giovanelli targeted and attacked Sarah Jackson in hopes the truth would

not actually come out.
29.

Cameron Giovanelli and Sarah Giovanelli were not in this alone. Featured

prominently on each post and each page of the website:

30.

Immanuel Baptist Church participated, orchestrated, and coordinated the attacks

on Sarah Jackson in order to protect not just one of their own but to ensure their church,
publishing company, and soon-opening college would not suffer financially from this blemish on
its record.
31.

Cameron Giovanelli bragged about his status as a past “college president” and

soon anticipated being in a college leadership position again.
32.

Cameron Giovanelli finally admitted the truth when he pleaded guilty on

December 4, 2019.
33.

Cameron Giovanelli told the sentencing judge he “admitted responsibility” for his

actions as he pleaded guilty to the charges of a fourth-degree sex offense and a second-degree
assault for his actions against Sarah Jackson.

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34.

After the sexual abuse finally came to light, Cameron Giovanelli did what all

abusers do: try to discredit the accuser and hope to paint the victim as a liar so the world will not
believe the truth about the abuse.
35.

Here, even more egregious, Cameron Giovanelli used information obtained

confidentially in a counseling relationship with both Sarah and her family to try this tactic.
36.

Defendants orchestrated a smear campaign designed to destroy Sarah Jackson’s

reputation so that it would help paint her accusations about Cameron Giovanelli as false.
37.

This group of allies published false statements about Sarah’s truthful recitation of

Cameron Giovanelli’s abuse and false statements regarding alleged sexual misconduct by Sarah.
38.

These false statements were knowingly false and published with the actual intent

to harm Sarah Jackson and her reputation.
39.

When Cameron Giovanelli was finally faced with the truth about his abuse of Ms.

Jackson, he responded with these false attacks: (1) he stated he was “falsely accused”; (2) he
called Ms. Jackson’s horrific abuse “blatant lies”; (3) he tried to convince people Ms. Jackson
had “posted [a] lie”; (4) he vigorously attempted to make others believe Ms. Jackson “concocted
a fabricated story”; and (5) did so by using every trick in the book to destroy Ms. Jackson’s
reputation and make the world believe “Sarah [] Jackson is a liar.”
40.

Sarah Giovanelli similarly tried to suppress the truth about her husband with false

attacks. She broadcasted: (1) baseless accusations of “immorality and [a] promiscuous lifestyle”;
(2) described Ms. Jackson’s childhood abuse as “false accusations”; (3) falsely accused Ms.
Jackson of “adulterous behavior”; and (4) tried to convince the world the horrific abuse suffered
by Ms. Jackson were simply “wicked lies.”

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41.

These statements by Cameron Giovanelli and Sarah Giovanelli were knowingly

false, communicated to the world through the internet, and caused Sarah irreparable damage.
COUNT I
42.

Plaintiff re-alleges and incorporates by reference the above paragraphs as if fully

set forth herein.
43.

Defendants, Cameron Giovanelli and Sarah Giovanelli, made the above false

statements with the intent for them to be widely disseminated and repeated.
44.

Defendants, Cameron Giovanelli and Sarah Giovanelli, published the false

statements with malice as he communicated the false statements with actual knowledge of their
falsity, or with reckless disregard for their falsity, in an attempt to protect and further the
financial interests of Defendants, Cameron Giovanelli and Sarah Giovanelli.
45.

Defendant, Cameron Giovanelli, published the false statements while he was

acting in the course and scope of his employment with Defendant, Immanuel Baptist Church, and
did so at its behest in order to protect its financial interests.
46.

Plaintiff has been damaged by these false statements because the statements

subject Plaintiff to hatred, distrust, ridicule, contempt, and disgrace.
47.

Plaintiff has been damaged by these false statements because the false statements

injured Plaintiff’s reputation, profession, and business.
WHEREFORE Plaintiff demands judgment against Defendants for compensatory
damages to be determined, punitive damages to be determined, together with Plaintiff’s costs,
expenses, and such further relief as this Court deems just and proper.

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DEMAND FOR JURY TRIAL
48.

The Plaintiff requests trial by jury on all issues so triable.

Respectfully submitted this 22nd day of September, 2020.
WEBER, CRABB & WEIN, P.A.
/s/ Jeremy D. Bailie
Jeremy B. Bailie, Esq.
FBN: 118558
Kyle D. Bass, Esq.
FBN: 122158
Jeremy.Bailie@webercrabb.com
Kyle.Bass@webercrabb.com
Secondary lisa.willis@webercrabb.com
Weber, Crabb & Wein, P.A.
5453 Central Avenue
St. Petersburg, FL 33710
(t): 727-828-9919
(f): 727-828-9924
Attorneys for Plaintiff

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