Filing "E?Filed 12/23/2019 05:09:55 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR HENDRY COUNTY, FLORIDA CIVIL DIVISION CHRISTOPHER CLAY SELF, Plaintiff, vs. Case No. STEVE WHIDDEN, in his official capacity As Sheriff of Hendry County, Florida, CHARLES A. WHITE, in his of?cial capacity and individually, and SUSAN HARRELE, in her of?cial capacity and individually, Defendants. COMPLAINT AND DEMAND FOR JURY TRIAL COMES NOW, the Plaintiff, CHRISTOPHER CLAY SELF, by and through his attorneys, states and avers as follows against the above-names Defendants: JURISDICTION, VENUE, AND CONDITIONS PRECEDENT 1. This is a civil rights action in which the Plaintiff seeks relief for the violations of his rights secured by 42 U.S.C. 1983, the First, Fourth, and Fourteenth Amendments, the general laws of the United States and the laws of the State of Florida. 2. The amount in controversy is in excess of $15,000.00. 3. The events that give rise to this lawsuit took place at 435 S. Utopia Street, Clewiston, Hendry County, Florida. 4. Venue is prOper in Hendry County, Florida as the Plaintiff is a resident of Hendry County, Florida and the events complained of took place in Hendry County, Florida. Electronically Filed Hendry Case 19000884CAAXMX 12/23/2019 05:09:55 PM 5. Pursuant to Florida Statues, Plaintiff has noti?ed the Hendry County Sheriffs Of?ce of his claims prior to the ?ling of this action and said claims were not resolved as the Hendry County Sheriff 8 Office did not respond to said notice. 6. Plaintiff has also complied with by providing notice of service to the Florida Department of Financial Services. All conditions precedent to the ?ling of this action have occurred, accrued, or have been waived as a matter of law. PARTIES 7. Plaintiff, CHRISTOPHER CLAY SELF, (hereinafter ?Plaintiff? or ?Mr. Self was all times relevant hereto, a citizen of Florida domiciled in Hendry County, Florida and was over the age of eighteen. 8. Defendant, STEVE WHIDDEN, (hereinafter ?Sheriff in his of?cial capacity, is the Sheriff of Hendry County, Florida and as such, is a constitutional of?cer of the State of Florida, who position is organized and exists under and by virtue of the laws of the State of Florida, and as such is responsible for hiring, supervising and managing all employees of the Hendry County Sheriffs Of?ce. 9. At all times relevant, Defendant, CHARLES A. WHITE, (hereinafter ?Deputy White?), was a deputy sheriff employed by the Hendry County Sheriff 8 Office, acting within the course and cope of his employment with the Hendry County Sheriff 5 Of?ce, and under the color of law, is sued in his of?cial and individual capacity. 10. At all times relevant, Defendant, SUSAN HARRELL, (hereinafter ?Deputy Captain Harrelle?) was a deputy sheriff employed by the Hendry County Sheriff? 3 Of?ce, and under the color of law, is sued in her of?cial and individual capacity. GENERAL ALLEGATIONS 11. On December 26, 2015, Mr. Self was lawfully on the premises located at 435 S. Utopia Street, Clewiston, Hendry County, Florida. 12. Mr. Self had permission to be on the property to care for his chickens which he was breeding to preserve cultural blood lines. 13. By way of an agreement with Adalel Tapanez, as renter from landowner Gaston Gabrierra, Mr. Self had been granted use of the west end of the property located at 435 S. Utopia Street to raise his blood line chickens in return for feeding animals of Mr. Tapanez. l4_. Unbeknownst to the Plaintiff, Mr. Self, the Hendry County Sheriff? 3 Department was in the process of servicing a search warrant on the property upon a basis of suspected violations of Florida Statute 828.122 regarding Fighting or Baiting Animals. 15. At the time of the execution of the Search Warrant, Mr. Self had approximately 83 male, female chickens and chicks housed in his pens on the west end of the property. 16. Hendry County Deputy, Charles A. White, was one of the deputies involved in the operation conducted by the Hendry County Sheriff? Of?ce regarding an alleged cock ?ghting raid. 17. At said time and place, Deputy White, approached Mr. Self who told Deputy White the chickens on the west side of the property belonged to him. 18. Deputy White informed Mr. Self that he was being placed under arrest for a Violation of Florida Statute 828.122 for attending an animal ?ght or baiting. Mr. Self was subsequently searched and transported to the Hendry County Sheriffs Department. 19. No probable cause or reasonable suspicion existed to arrest, detain and search Mr. Self. 20. While being processed on the scene, Mr. Self talked with Captain Susan Harrelle. Mr. Self told her about his birds and asked what was going to happen to them. At that time, he inquired as to what would happen to his birds and was told the birds would be destroyed and then incinerated. Mr. Self asked for an Order of Destruction and was denied a copy of the same by Captain Harrelle. 21. Subsequently 83 of Mr. Self? 3 birds were destroyed by the Hendry County Sheriff?s Department. 22. No probable cause or reasonable suspicion existed to arrest, detain, and search Mr. Self or destroy his chickens. COUNT I: U.S.C. ?1983 FALSE ARREST AND DETENTION (Against Deputy White) 23. Mr. Self re-alleges and re?avers the allegations contained in paragraphs 1 through 22 above as if fully set forth herein. 24. At all times relevant herein, Defendant Deputy White, acted within the scope of his employment with the Hendry County Sheriffs Department. 25. Mr. Self has a clearly established constitutional right to be free of any unreasonable seizures and a right to be free from the unlawful abuse of power by agents of the State. 26. Title 42 U.S.C. ?1983 states, inter alia: ?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 of laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress 27. As described more fully above, on December 26, 2015, Deputy White, acting under the color of state law, intentionally caused Mr. Self to be unlawfully detained and deprived of his liberty and freedom of movement against his will. 28. The ongoing detention was intentional, unreasonable, without Mr. Self?s consent, against Mr. Self? will, and was done to intimidate Mr. Self with a show of force and to be vindictive. 29. Deputy White?s actions violated Mr. Self 3 rights recognized by the Constitution and in 42 US. C. ?1983. 30. The continued detention of Mr. Self was intentional and not warranted by the factual circumstances as they were known at the time of the 11111an arrest. 31. There was no probable cause to arrest Mr. Self, as demonstrated by Deputy White?s knowledge that Mr. Self was lawfully on the premises. 32. As a direct and proximate cause of the actions of Deputy White, Mr. Self was injured and suffered damages that include bodily harm, physical discomfort and pain, physical suffering, medical expenses, mental suffering, embarrassment, humiliation, disgrace and injury the physical and emotional aspects of which are continuing to this day and are likely to continue into the future. WHEREFORE, Mr. Self demands judgment against Deputy White for compensatory damages and exemplary damages, together with interest, court costs, reasonable attorney?s fees pursuant to 42 U.S.C ?l988, and such further relief as the Court deems proper. COUNT II: U.S.C. $1983 FALSE ARREST AND DETENTION (Against Deputy Harrelle) 33. Mr. Self re?alleges and re?avers the allegations contained in paragraphs 1 through 33 above as if fully set forth herein. 34. At all times relevant herein, Defendant Deputy Captain Susan Harrelle, acted within the scope of her employment with the Hendry County Sheriff Department. 35. Mr. Self has a clearly established constitutional right to be free of any unreasonable seizures and a right to be free from the unlawful abuse of power by agents of the State. 36. Title 42 U.S.C. ?l983 states, inter alia: ?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 of laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress 37. As described more fully above, on December 26, 2015, Deputy Captain Susan Harrell White, acting under the color of state law, intentionally caused Mr. Self to be unlawfully detained and deprived of his liberty and freedom of movement and property against his will. 38. The ongoing detention was intentional, unreasonable, without Mr. Self? consent, against Mr. Self? will, and was done to intimidate Mr. Self with a show of force and to be vindictive and to deprive him of his property rights. 39. Deputy Harrelle?s actions violated Mr. Self?s rights recognized by the Constitution and in 42 US. C. ?l983. 40. The continued detention of Mr. Self was intentional and not warranted by the factual circumstances as they were known at the time of the unlawful arrest. 41. There was no probable cause to arrest Mr. Self, as demonstrated by Deputy Captain Harrelle?s knowledge that Mr. Self was lawfully on the premises. 42. As a direct and proximate cause of the actions of Deputy Captain Harrelle, Mr. Self was injured and suffered damages that include bodily harm, physical discomfort and pain, physical suffering, medical expenses, mental suffering, embarrassment, humiliation, destroying property, disgrace and injury the physical and emotional aspects of which are continuing to this day and are likely to continue into the ?iture. WHEREFORE, Mr. Self demands judgment against Deputy Captain Harrelle for compensatory damages and exemplary damages, together with interest, court costs, reasonable attorneys fees pursuant to 42 U.S.C ?1988, and such further relief as the Court deems proper. COUNT U.S.C. $1983 MALICIOUS PROSECUTION (Against Deputy White) 43. Mr. Self re-alleges and re-avers the allegations contained in paragraphs 1 through 42 above as if fully set forth herein. 44. The United States Constitution and Florida Statutes requires law enforcement of?cers to possess suf?cient probable cause before charging a citizen with a criminal offense. 45. Deputy White intentionally, knowingly, and maliciously, recklessly, unreasonably, and/or gross negligently arrested Mr. Self and initiated criminal proceedings against him when they incarcerated him and charged him with criminal offenses. 46. Mr. Self? arrest and the initiation of criminal charges against him was without suf?cient probable cause, legal justi?cation, just cause, or any other legally valid reason. 47. Deputy White?s and Deputy Harrelle?s initiation of criminal charges against Mr. Self was done with malice and bad faith where they had no knowledge of any fact or circumstance which would lead a reasonable person to believe that Mr. Self committed any criminal offense. 48. The criminal charges against Mr. Self were terminated in his favor when the State Attorney?s Of?ce for the 20?11 Judicial Circuit declined to ?le an information against Mr. Self and ?led a Notice of Nolle Prosequi on October 5, 2016. 49. As a direct and proximate result of the constitutional violations and acts described above, Mr. Self was injured and suffered damages that include bodily harm, physical discomfort and pain, physical suffering, medical expenses, mental suffering, embarrassment, humiliation, disgrace and injury, the physical and emotional aspects of which are continuing to this day and are likely to continue into the future. WHEREFORE, Mr. Self requests judgment against Deputy White for compensatory damages and exemplary damages, together with interest, court costs, reasonable attorney?s fees pursuant to 42 U.S.C. ?l988, and such further relief as the Court deems proper. COUNT IV: U.S.C. $1983 MALICIOUS PROSECUTION (Against Deputy Harlem 50. Mr. Self re-alleges and re?avers the allegations contained in paragraphs 1 through 49 above as if fully set forth herein. 51. The United States Constitution and Florida Statutes requires law enforcement offi cers to possess suf?cient probable cause before charging a citizen with a criminal offense. 52. Deputy Harrelle intentionally, knowingly, and maliciously, recklessly, unreasonably, and/or gross negligently arrested Mr. Self and initiated criminal proceedings against him when they incarcerated him and charged him with criminal offenses. 53. Mr. Self? arrest and the initiation of criminal charges against him was without sufficient probable cause, legal justi?cation, just cause, or any other legally valid reason. 54. Deputy Harrelle?s initiation of criminal charges against Mr. Self was done with malice and bad faith where they had no knowledge of any fact or circumstance which would lead a reasonable person to believe that Mr. Self committed any criminal offense. 55. The criminal charges against Mr. Self were terminated in his favor when the State Attorney?s Office for the 20th Judicial Circuit declined to file an information against Mr. Self and filed a Notice of Nolle Prosequi on October 5, 2016. 56. As a direct and proximate result of the constitutional violations and acts described above, Mr. Self was injured and suffered damages that include bodily harm, physical discomfort and pain, physical suffering, medical expenses, mental suffering, embarrassment, humiliation, disgrace and injury, the physical and emotional aspects of which are continuing to this day and are likely to continue into the ?iture. WHEREFORE, Mr. Self requests judgment against Deputy Harrelle for compensatory damages and exemplary damages, together with interest, court costs, reasonable attorney?s fees pursuant to 42 U.S.C. ?l988, and such further relief as the Court deems proper. COUNT V: U.S.C. $1983 MALICIOUS PROSECUTION gAgainst Sheriff) 57. Mr. Self re?alleges and re-avers the allegations contained in paragraphs 1 through 56 above as if fully set forth herein. 58. The United States Constitution and Florida Statutes requires law enforcement of?cers to possess suf?cient probable cause before charging a citizen with a criminal offense. 59. Deputy White intentionally, knowing and maliciously, recklessly, unreasonably, and/or gross negligently arrested Mr. Self and initiated criminal proceedings against him when they incarcerated him and charged him with criminal offenses. 60. Mr. Self? arrest and the initiation of criminal charges against him was without suf?cient probable cause, legal justi?cation, just cause, or any other legally valid reason. 61. Deputy White?s initiation of criminal charges against Mr. Self was done with malice and bad faith where they had no knowledge of any fact or circumstance which would lead a reasonable person to believe that Mr. Self committed any criminal offense. 62. Sheriff Steve Whidden acting in his of?cial capacity as Sheriff of the Hendry County Sheriff 5 Of?ce, was aware of various lawsuits complaining that his deputies falsely arrested other citizens. These lawsuits demonstrate a patter and practice of Hendry County Sheriff? 8 Of?ce impermissibly training its of?cers to make arrests in circumstances where it is objectively apparent that no law has been broken. 10 63. The criminal charges against Mr. Self were terminated in his favor when the State Attorney?s Of?ce for the 20th Judicial Circuit declined to file an information against Mr. Self and dismissed all charges on October 5, 2016. 64. The de facto policies, customs, and practices of Sheriff Whidden, acting in his of?cial capacity as Sheriff of Hendry County Sheriff? Of?ce, were the moving force behind the false arrest and deprivation of constitutional rights suffered by Mr. Self and had not been remedied. 65. Deputy White?s conduct occurred in the course and scope of his employment with the Hendry County Sheriff 5 Of?ce. 66. Supervising deputies and ensuring Mr. Self? 3 safety from deputies is a non?delegable duty of Sheriff Whidden. 67. As a result, Sheriff Whidden vicariously liable in his of?cial capacity for the actions of Deputy White. 68. As a direct and proximate result of the constitutional Violations and acts described above. Mr. Self was injured and suffered damages that include bodily harm, physical discomfort and pain, physical suffering, medical expenses, mental suffering, embarrassment, humiliation, disgrace and injury, the physical and emotional aspects of which are continuing to this day and are likely to continue int the future. WHEREFORE, Mr. Self requests judgment against Sheriff Whidden acting in his of?cial capacity as Sheriff of the Hendry County Sheriff? Of?ce, for compensatory damages and exemplary damages, together with interest, court costs, reasonable attorney?s fees pursuant to 42 U.S.C. ?l988, and such further relief as the Court deems proper. 11 COUNT VI: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS (Against Deputy White) 69. Mr. Self re?alleges and re?avers the allegations contained in paragraph 1 through 68 above as if fully set forth herein. 70. Deputy White knew that the conduct described herein, leading to Mr. Self? 5 false arrest, use of excessive force, and unlawful detention, would result in physical and emotional distress to Mr. Self. 71. Deputy White?s conduct was extreme and outrageous, goes well beyond all bounds of decency, and is odious and utterly intolerable in a civilized community. 72. The extreme and outrageous conduct of Deputy White caused damages that include bodily harm, physical discomfort and pain, physical suffering, medical expenses, mental suffering, embarrassment, humiliation, disgrace and injury, the physical and emotional aspects of which are continuing to this day and are likely to continue into the future. 73. The emotional distress suffered by Mr. Self was severe. WHEREFORE, Mr. Self requests judgment against Deputy White for compensatory damages and exemplary damages, together with interest, court costs, reasonable attorney?s pursuant to 42 U.S.C. ?1988, and such further relief as the Court deems proper. COUNT VII: INTENTIONAL INELICTION OF EMOTIONAL DISTRESS (Against Deputy Captain Susan Harrell? 74. Mr. Self re-alleges and re?avers the allegations contained in paragraph 1 through 73 above as if fully set forth herein. 12 75. Deputy Captain Harrelle knew that the conduct described herein, leading to Mr. Self?s false arrest, use of excessive force, and unlawful detention, would result in physical and emotional distress to Mr. Self. 76. Deputy Captain Harrelle?s conduct was extreme and outrageous, goes well beyond all bounds of decency, and is odious and utterly intolerable in a civilized community. 77. The extreme and outrageous conduct of Deputy Captain Harrelle caused damages that include physical discomfort and pain, physical suffering, property damage, mental suffering, embarrassment, humiliation, disgrace and injury, the physical and emotional aspects of which are continuing to this day and are likely to continue into the future. 78. The emotional distress suffered by Mr. Self was severe. WHEREFORE, Mr. Self requests judgment against Deputy Captain Harrelle for compensatory damages and exemplary damages, together with interest, court costs, reasonable attorney?s pursuant to 42 U.S.C. ?1988, and such further relief as the Court deems proper. COUNT 42 U.S.C. $1988 RETALIATION gAgainst Sheriff) 79. Mr. Self re?alleges and re-avers the allegations contained in paragraph 1 through 78 above as if fully set forth herein. 80. Deputy White and Deputay Captain Harrelle, while acting under the color of law, violated 42 U.S.C. ?l988 by retaliating against Mr. Self for exercising his Constitutional rights. 81. As discussed above Deputies White and Harrelle retaliated against Mr. Self for arresting Mr. Self. 82. Sheriff Whidden, acting in his of?cial capacity as Sheriff of the Hendry County Sheriffs Office, implemented a policy, custom, or practice of allowing Hendry County Sheriffs l3 Office deputies to retaliate against citizens who question their authority and assert their constitutional rights. 83. As a direct and proximate result of the constitutional violations and acts described above, Mr. Self was injured and suffered damages that include bodily harm, physical suffering, medical expenses, mental suffering, embarrassment, humiliation, disgrace and injury, the physical and emotional aspects of which are continuing to this day and are likely to continue into the future. WHEREFORE, Mr. Self requests judgment against Sheriff Whidden acting in his official capacity as Sheriff of the Hendry County Sheriff Office for compensatory damages and exemplary damages, together with interest, court costs, reasonable attorney?s fees pursuant to 42 42 U.S.C. ?l988 and such further relief as the Court deems proper. COUNT IX: 42 U.S.C. $1988 RETALIATION (Against Deputy White) 84. Mr. Self re-alleges and re?avers the allegations contained in paragraph 1 through 83 above as if fully set forth herein. 85. Deputy White, while acting under the color of law, violated 42 U.S.C. ?l988 by retaliating against Mr. Self for exercising his Constitutional rights. 86. As discussed above in greater detail, Deputy White retaliated against Mr. Self for exercising his constitutionally protected rights by unlawfully detaining and falsely arresting Mr. Self. 87. As a direct and proximate result of the constitutional violations and acts described above, Mr. Self was injured and suffered damages that include bodily harm, physical discomfort an pain, physical suffering, medical expenses, mental suffering, embarrassment, humiliation, 14 disgrace and injury, the physical and emotional aspects of which are continuing to this day and are likely to continue into the future and property damage. WHEREFORE, Mr. Self requests judgment against Deputy White for compensatory damages and exemplary damages, together with interest, court costs, reasonable attorney?s fees pursuant to 42 U.S.C. ?l988 and such further relief as the Court deems proper. COUNT X: 42 U.S.C. 81988 RETALIATION (Against Deputy Captain Harrelle) 88. Mr. Self re-alleges and re?avers the allegations contained in paragraph 1 through 87 above as if fully set forth herein. 89. Deputy Captain Harrelle, while acting under the color of law, violated 42 U.S.C. ?1988 by retaliating against Mr. Self for exercising his Constitutional rights. 90. As discussed above in greater detail, Deputy Captain Harrelle retaliated against Mr. Self for exercising his constitutionally protected rights. 91. As a direct and proximate result of the constitutional violations and acts described above, Mr. Self was injured and suffered damages that include bodily harm, physical discomfort an pain, physical suffering, medical expenses, mental suffering, embarrassment, humiliation, disgrace and injury, the physical and emotional aspects of which are continuing to this day and are likely to continue into the future. WHEREFORE, Mr. Self requests judgment against Deputy Captain Harrelle for compensatory damages and exemplary damages, together with interest, court costs, reasonable attorney?s fees pursuant to 42 U.S.C. ?l988 and such further relief as the Court deems prOper. COUNT XI: 42 U.S.C. 81988 NEGLIGENT TRAINING AND SUPERVISION {Against Sheriff! 15 92. Mr. Self re?alleges and re?avers the allegations contained in paragraph 1 through 91 above as if fully set forth herein. 93. At all times relevant, Defendant Sheriff Whidden promulgated and maintained a de facto unconstitutional custom, policy, or practice or permitting, ignoring, and condoning andJor encouraging officers, deputes, and other employees and agents to unlaw?illy arrest citizens where no probable cause or reasonable suspicion exists that a citizen has committed a crime, to the extent that such practice has been rati?ed by Sheriff Whidden, despite its illegal and unconstitutional impact on citizens. 94. Mr. Self is informed, believes, and thereon alleges that Sherriff Whidden, Deputy White and Deputy Captain Harrelle knew or should have known of a history, custom, propensity, and pattern in which deputies, supervisors and other employees openly charged citizens with crime where no probable cause or reasonable suspicion exists. 95. The arrest of Mr. Self demonstrates that Deputy White and Deputy Captain Harrelle were not properly trained to distinguish between probable cause for an arrest and a mere civil dispute. 96. Sheriff Whidden, Deputy White, Deputy Captain Harrelle owed Mr. Self a duty to protect him from unreasonable searches and seizures, false arrests, excessive force, and wrongful imprisonment. 97. This duty was breached by failing to properly train, instruct, oversee, and/or manage all levels of the Hendry County Sheriff? 3 Office deputies to ensure that they adequately, reasonably, and responsibly performed their duties not to harm or abuse the public, including falsely arresting and utilizing excessive force against Mr. Self. 16 98. Sheriff Whidden acting in his of?cial capacity as Sheriff of the Hendry County Sheriffs Of?ce, had complete control and authority over all deputies in the Hendry County Sheriffs Of?ce, including Deputy White and Deputy Captain Harrelle. The Hendry County Sheriffs Of?ce, acting through Sheriff Whidden inadequately trained, supervised, and/or disciplined Deputy White, Deputy Captain Harrelle and other Hendry County Sheriffs Of?ce deputies. Sheriff Whidden?s de?ciencies in training include, but are not limited to, failing to: A. Educate deputies in the standards of law enforcement; B. Ensure that Hendry County Sheriffs Of?ce deputies understand both the concepts of probable cause and reasonable suspicion, and the natural limits of those concepts; and C. Instruct Hendry County Sheriffs of?ce deputies on how to avoid abusing the power reposed in them, including training them on the usage of force, how to differentiate between criminal conduct and a mere civil dispute, and training of?cers to not falsely report on of?cial documents. 99. As described in more detail above, the failure of Sheriff Whidden, acting in his of?cial capacity as Sheriff of the Hendry County Sheriffs Of?ce, to adequately train and supervise Hendry County Sheriffs Of?ce deputies resulted in Mr. Self being the victim of a barrage of tortious conduct as the hand of Hendry County Sheriffs Of?ce deputies, including but not limited to being subjected to false arrest, the use of excessive force, and wrongful imprisonment. 100. Despite knowledge of systematic training de?ciencies, which led Hendry County Sheriffs Of?ce practices of making false arrests, using excessive force, and imprisoning citizens, and despite being on notice of the need for further training and supervision in those areas, Sheriff Whidden continued to make a deliberate choice not to take any action. 17 101-. As a direct and greximaie result of the eenstitutienal Viela?en?s and eats desefibed. abeve? Mr. Selfwas injured. and suffered damages the? ieelude bedily harm.) physical diseemfe? and paint, phyeieal suffering meciieal expenses, mental suffering, embanfa?issment? humiliatlen, disgrace and inj-umg the physieal and emotional aspects 0f Which are continuing is this day and are lilcely to continue into the ?lmre. WHEREFGRE, Mr. Self request judgment against acting in his ef?cial capacity as Sheriff of the Hendry County Sheriff 3 Office, fer cempeneatery damages and exemplary damages, together with intereet, eeurt costs, reasonable attorneys fees pursuant to; 42 U.S.C. ?19'88,_ and such further relief as the Court deem-s preper. DEMANE DRY TRIAL Plaintiff here-by. demands a trial by jury an all issues triable herein. Dated: December 2-3, 2019. Respectfully Submitted, ., Florida Bar No. 145-564 WILBUR ATTORNEYS AT LAW 2200 BreadWay; 3?:i Fleer Fm. Myers, FL 33901 Tel: 2396343696 Fax: 239-334?3669 Primary: Secondary: CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that 011 December 23, 2019, electronically ?led the foregoing with "the Clerk of the Court by using Flerida E-Filing Forte, which will provide service to? attorneys of record. 18 Fierida Bar 145564 19