Man Says Off-Duty BSO Cop Arrested Him for Taking a Parking Space

8/10/2019 Man Says Off-Duty BSO Cop Arrested Him for Taking a Parking Space

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Fourteenth Amendments to the United States Constitution, and the tort law of Florida.

Jurisdiction is founded on 28 U.S.C. 1331, 1343, 42 U.S.C. 1988, the constitutional

provisions mentioned above, and under the tort law of Florida.

4. Plaintiff has fully complied with all conditions precedent to bringing this action

imposed by the laws of the State of Florida, and particularly by the provisions of 768.28 of the

Florida Statutes. A copy of Plaintiff's notice letter and return correspondence is attached hereto,

and made a part hereof, as composite Exhibit A.

PARTIES

5.

Plaintiff CLAUSEL J. PIERRE is a citizen and resident of Port Saint Lucie,

Florida.

6. At all times referred to herein, Defendant FRANK MAIO [hereinafter MAIO or

Defendant MAIO] was employed as police officer for Defendant BROWARD COUNTY

SHERIFFS OFFICEand was acting under the direction and control of the Defendant

BROWARD COUNTY SHERIFFS OFFICE, in such capacity as an agent, servant and

employee of Defendant BROWARD COUNTY SHERIFFS OFFICE.

7. Defendant, SCOTT J. ISRAEL, is the duly elected Sheriff of Broward County,

Florida, a constituent officer pursuant to Florida Statues 768.28(9)(a), successor in interest to

AL LAMBERTI, who was the prior Sheriff of Broward County, Florida, who served in that

capacity on the date of the incident described herein below (hereinafter referred to as ISRAEL,

BROWARD COUNTY SHERIFFS OFFICE, BSO).

8. Said Defendant, ISRAEL, is responsible, as Sheriff, for the conduct of the

deputies in his employ and ensuring that his deputies, employees, servants and agents obey the

Case 0:14-cv-62683-RNS Document 1 Entered on FLSD Docket 11/25/2014 Page 2 of 20

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laws of the State of Florida and the United States.

9. Defendant ISRAEL is being sued in his official capacity.

10. Defendant ISRAEL, being sued in his official capacity, is synonymous with the

Broward County Sheriffs Office.

11. Broward County Sheriffs Officeis a Florida municipal corporation located in the

Southern District of Florida, and organized and existing under the laws of the State of Florida. In

this cause, the BROWARD COUNTY SHERIFFS OFFICE acted through its agents, employees,

and servants, including Defendant MAIO and others.

12.

Defendant, MAIO, is a resident of Broward County, Florida.

13. At all times material hereto, MAIO was acting within the course and scope of his

employment as a police officer with the Broward County Sheriffs Office. As a consequence

thereof, BROWARD COUNTY SHERIFFS OFFICEis liable as hereinafter alleged under the

Doctrine of Respondeat Superior.

14. At all times material hereto, MAIO, were acting under color of law, to- wit: under

color of the statutes, ordinances, regulations, customs and usages of the United States and of the

State of Florida and the Broward County Sheriffs Office, pursuant to their respective authority to

maintain a municipal police department.

15. Said Defendant, MAIO, is being sued in his individual and official capacities.

16. Plaintiff has retained the Law Offices of Brown & Associates, P.A., to represent

him in this matter and has agreed to pay a reasonable fee for its services.

FACTUAL ALLEGATIONS

Plaintiff repeats and realleges Paragraphs 1 through 11 above as if more fully set forth herein and


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further alleges:

17. On January 27, 2011, at approximately 6:00 PM Detective Frank Maio of the

Broward County Sheriffs Office was doingoff-duty detail work at 888 Shoes which is located at

3200 West Hillsboro Blvd in Deerfield Beach in Broward County Florida and the Southern

District of Florida.

18. On or about January 27, 2011, Detective Frank Maio of the Broward County

Sheriffs Office was doing off-duty detail work at 888 Shoes in Broward County Florida.

19. On or about January 27, 2011, Plaintiff CLAUSEL J. PIERRE arrived at 888

Shoes.

20. After arriving at the shopping center, the Defendant Clausel Pierre parked his

S.U.V. in a parking spot in front of the 888 Shoe store.

21. Detective Maio allegedly attempted to park his S.U.V. in the same parking spot

prior to the Defendant taking the same parking spot.

22. As the Defendant exited his vehicle, Detective Maio approached and informed the

Defendant his automobile needed to be moved from the parking spot.

23. Defendant refused to move his automobile.

24. As a result, Detective Maio attempted to arrest the Defendant. After an alleged

altercation between the Defendant and Detective Maio, the Defendant was arrested.

25. Subsequently, the State Attorneys Office filed a 2-Count Information against the

Defendant for Battery on a Law Enforcement Officer and Resisting Arrest with Violence.

26. For the charge of battery and resisting an officer with violence, a conviction for

either offense requires proof that the officer was engaged in the performance of a lawful duty.


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27. The Defendant MAIO was in police uniform during this entire encounter.

28. The Defendant, MAIO was negligent in his actions.

29. The Defendant, MAIO, used excessive force by repeating hitting the plaintiff.

30. The actions of the defendant, MAIO endangered the life of the plaintiff.

31. The Plaintiff was placed in grave danger by the conduct of the Defendant.

32. Plaintiff suffered severe injuries due to the actions of the Defendant MAIO.

33. That as a direct and proximate result of the severe, unjustified and illegal,

unprovoked, intentional force inflicted upon the Plaintiff by MAIO while acting as agents and/or

employees of the Defendant, BROWARD COUNTY SHERIFFS OFFICE, the plaintiff suffered

severe injuries.

34. At all times material to this incident, BROWARD COUNTY SHERIFFS

OFFICE and its agent and/or employee, MAIO, acted in reckless disregard to the United States

and Florida Constitutional and statutory prohibitions and guarantees under color of the State law.

35. Plaintiff suffered the following injuries, losses and damages:

a. Suffered mental and physical pain from his injuries received at the hands

of Defendant, MAIO;

b. Had his civil rights guaranteed to him by the United States and Florida

Constitution and Statutes violated;

c. Incurred the expense of hiring an attorney to represent him as a result of

the false and malicious criminal charges placed against him;

d. Lost wages and time from work;

e. Spent time incarcerated as a result of the false and malicious charges


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placed against him by Defendant;

f. Incurred medical expenses in the treatment of his injuries, which will

continue into the future.

CAUSES OF ACTION

COUNT I

VIOLATION OF 42 U.S.C. 1983

Plaintiff repeats and realleges Paragraphs 1 through 35 above as if more fully set forth

herein and further alleges:

36. MAIO, while acting under color of State Law and as agent and/or employee of

BROWARD COUNTY SHERIFFS OFFICE, used excessive force, unnecessary force, assaulted

and battered the plaintiff, CLAUSEL J. PIERRE, in violation of his constitutional rights

guaranteed by the Constitution and laws of the United States; in particular, violation of his

privileges and immunities including equal protection under the due process clause of the

Fourteenth Amendment of the United States Constitution.

37. That MAIO, while acting under the color of State law during the incident

described herein, did then and there illegally and unnecessarily use force to assault, batter and

arrest the Plaintiff causing injuries and wounds which ultimately resulted in the Plaintiff

undergoing medical care and treatment.

38.

That the foregoing actions on the part of MAIO constitute excessive, unnecessary

and illegal use of force and authority and were below the reasonable standard of care to be

exercised on behalf of the police officer dealing with the members of the public.


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39. MAIO did unlawfully and wrongfully assault, batter, injure, and arrest CLAUSEL

J. PIERRE, thereby depriving him of his rights, privileges and immunities secured by the

Constitution and laws of the United States. The assault, battery and use of excessive and/or

illegal , unnecessary force used by MAIO operated to deprive Plaintiff of the following

Constitutionally guaranteed rights and privileges:

a. The right and privilege to be secure in his person while in the custody of

the State of Florida;

b. The right and privilege not to be deprived of his right and liberty without

due process of law;

c. The right and privilege to be free from unlawful attacks upon the physical

integrity of his person;

d. The right and privilege not to be subjected to punishment without due

process of law;

e. The right and privilege to be immune while in the custody of persons

acting under color of law of the State of Florida from illegal assault and battery by any person

exercising the authority of said state; and

f. The right and privilege to be free from cruel and unusual punishment.

40. As a direct and proximate result of the actions described aforesaid committed

under color of law as a BSO Police officer acting within the scope of his employment and

pursuant to authority vested in him by BSO, MAIO caused the Plaintiff to sustain severe injuries

to his body and mind, be unlawfully arrested and incarcerated and spend sums of money to

defend himself from Defendants illegal acts.


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41. MAIOS use of excessive, illegal and unjustified force without legal provocation

or probable cause, committed under color of State law, deprived Plaintiff of his rights, privileges

and immunities under the Law and Constitution of the United States. MAIO acted illegally and in

total disregard of the human rights of the Plaintiff when MAIO unlawfully and without

provocation assaulted and battered the Plaintiff during the incident described herein.

WHEREFORE, Plaintiff prays this Court assess compensatory damages against the

Defendant MAIOE, in excess of Fifteen Thousand ($15,000.00) Dollars together with reasonable

attorneys fees and costs as provided in 42 U.S.C. 1988, and such other and further relief as this

Court deems just and proper under the circumstances.

COUNT II

DEPRIVATION OF CIVIL RIGHTS

Plaintiff repeats and realleges Paragraphs 1 through 35 above as if more fully set forth

herein and further alleges:

42. This is an action for damages pursuant to 42 U.S.C. 1983.

43.

Defendant, BROWARD COUNTY SHERIFFS OFFICE, as policy making

officials have a duty to adequately train and supervise the police officers of the BROWARD

COUNTY SHERIFFS OFFICEin proper techniques and use of force. These Defendants are also

under a duty to detect, prevent and correct excessive uses of force by police officers in BSO in

order to avoid unconstitutional deprivations of citizens rights guaranteed pursuant to the 14 th

Amendment of the United States Constitution and the laws of the United States.

44. Furthermore, Defendant BROWARD COUNTY SHERIFFS OFFICEhas a duty


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as policy making officials to ensure safe apprehension of suspects, to adequately supervise and

provide adequate supervision, to prevent assaults and batterys to arrestees and to prevent

unconstitutional deprivation of citizens rights pursuant to the 14thAmendment of the United

States Constitution and the laws of the United States while an arrestee is in the custody of BSO.

45. Defendant BROWARD COUNTY SHERIFFS OFFICE, as policy making

officials have continually failed to establish appropriate police procedures and train not only

other police personnel, but in this instance, specifically Officer MAIO:

a. to prevent unconstitutional deprivations by MAIO of the right to and

privilege to PIERRE to be secure in his person while in custody of the State of Florida;

b. to prevent unconstitutional deprivations by MAIO, of the right and

privilege of PIERRE not to be deprived of his rights and liberty without due process of law;

c. to prevent unconstitutional deprivations by MAIO, of the right and

privilege of PIERRE not to be subject to punishment without due process of law;

d. to prevent unconstitutional deprivations by MAIO, of the right and

privilege of PIERRE to be free from cruel and unusual punishment;

e. employing other police officers as well as MAIO whose employment in

law enforcement presented an unreasonable risk of harm to persons including PIERRE;

f. failing to guard against a potential hazard to members of the public by not

selecting proper or competent police officers;

g. Failing to provide proper guidelines and regulations concerning the proper

use of weapons or force during an arrest.

46. These deprivations are continuing and systemic in nature and not merely an


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isolated incident sufficient to create a formal custom or policy of the BROWARD COUNTY

SHERIFFS OFFICE.

47. Moreover, Defendants MAIO and BROWARD COUNTY SHERIFFS OFFICE

knew or should have known of these continuing deprivations of civil rights and knew or should

have known of these actual and potential problems and have failed to take the adequate and

necessary steps to correct or prevent them. Thus, Defendants, MAIO AND BROWARD

COUNTY SHERIFFS OFFICEhave failed to exercise their duties and supervise the institution

under their control.

48.

As a result of this deprivation of constitutional rights, Plaintiff suffered the

following injuries, losses and damages:

a. suffered mental and physical pain from his injuries received at the hands

of MAIO;

b. Lost time from work;

c. incurred medical expenses in the treatment of his injuries which will

continue in the future;

d. incurred the expense of hiring an attorney to represent him.

Wherefore, Plaintiff demands Judgment against Defendants MAIO AND Defendant

ISRAEL, in his official capacity with the Broward County Sheriffs Office, in excess of Fifteen

thousand dollars ($15,0000) together with interest, costs and attorney fees pursuant to 42 U.S.C.

1988 and other such relief as this court would deem necessary and proper.

COUNT III

FEDERAL LAW CLAIM AGAINST DEFENDANT MAIO, INDIVIDUALLY, FOR


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FALSE ARREST/FALSE IMPRISONMENT, COGNIZABLE UNDER 42 U.S.C.

1983

For his cause of action against Defendant MAIO, individually, in Count III, Plaintiff

realleges and adopts, as if fully set forth in Count I and II, the allegations of paragraphs 1 through

35.

49. Defendant MAIO, acting under color of state law, proximately caused Plaintiff's

physical seizure and arrest and detention in the absence of probable cause that Plaintiff

committed any criminal offense.

50.

The conduct of Defendant MAIO, individually, towards Plaintiff was objectively

unreasonable and violated Plaintiff's clearly established rights under the Fourth and Fourteenth

Amendments and 42 U.S.C. 1983, to be free from unlawful seizure of his person, and arrest and

detention in the absence of probable cause.

51.

As a direct and proximate result of the acts described herein, in violation of 42

U.S.C. 1983, Plaintiff has suffered grievously, has been brought into public scandal, and with

great humiliation, mental suffering, and damaged reputation.

52. As a further direct and proximate result of the conduct of Defendant MAIO,

individually, Plaintiff suffered loss of his liberty and freedom, loss of personal property, bodily

injury and resulting pain and suffering, disability, disfigurement, mental anguish, loss of capacity

for the enjoyment of life, expense of hospitalization, and medical care and treatment, loss of

earnings, loss of ability to earn money. Defendant MAIO also failed to safeguard Plaintiffs

personal property following Plaintiffs arrest, resulting in the loss or destruction of Plaintiffs

property. Plaintiffs losses are either permanent or continuing and Plaintiff will suffer the losses


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in the future, in violation of Plaintiff's civil rights. Plaintiff has also agreed to pay the

undersigned a reasonable fee for his services herein.

WHEREFORE, Plaintiff demands Judgment against Defendant MAIO for:

a. Judgment for compensatory damages in excess of $15,000 dollars;

b. Judgment for exemplary damages;

c. Cost of suit;

d. Reasonable attorney's fees, pursuant to 42 U.S.C. 1983;

e. Trial by jury as to all issues so triable; and

f. Such other relief as this Honorable Court may deem just and appropriate.

COUNT IV

FEDERAL LAW CLAIM AGAINST DEFENDANT MAIO, INDIVIDUALLY, FOR

EXCESSIVE USE OF FORCE, COGNIZABLE

UNDER 42 U.S.C. 1983

For his cause of action against Defendant MAIO, individually, in Count IV, Plaintiff realleges

and adopts, as if fully set forth in all prior counts, the allegations of paragraphs 1 through 35.

53. The force used by Defendant MAIO against Plaintiff, while acting under color of

state law, was unnecessary for Defendant MAIO to defend himself, or any other person, from

bodily harm during the arrest of Plaintiff.

54.

The force used by Defendant MAIO against Plaintiff was objectively

unreasonable, and constitutes the excessive use of force, in violation of Plaintiff's clearly

established constitutional rights under the Fourth and Fourteenth Amendments and 42 U.S.C.


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1983.

55. As a result of the conduct of Defendant MAIO, Plaintiff suffered internal injuries

including broken bones.

56. As a direct and proximate result of the acts described herein, in violation of 42

U.S.C. 1983, Plaintiff has suffered grievously, has been brought into public scandal, and with

great humiliation, mental suffering, and damaged reputation.

57. As a further direct and proximate result of the conduct of Defendant MAIO,

Plaintiff suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental

anguish, loss of capacity for the enjoyment of life, expense of hospitalization, and medical care

and treatment, loss of earnings, loss of ability to earn money. The losses are either permanent or

continuing and Plaintiff will suffer the losses in the future, in violation of Plaintiff's civil rights.

Plaintiff has also agreed to pay the undersigned a reasonable fee for his services herein.



b. Judgment for exemplary damages;

c. Cost of suit;

d. Reasonable attorney's fees, pursuant to 42 U.S.C. 1988;

e. Trial by jury as to all issues so triable; and

f. Such other relief as this Honorable Court may deem just and appropriate.

COUNT V

STATE LAW CLAIM AGAINST DEFENDANT BROWARD COUNTY SHERIFFS

OFFICE FOR FALSE ARREST/FALSE IMPRISONMENT


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For his cause of action against Defendant BROWARD COUNTY SHERIFFS OFFICEin Count

V, Plaintiff realleges and adopts, as if fully set forth in all prior counts, the allegations of

paragraphs 1 through 35.

58. The conduct of Defendant MAIOproximately caused Plaintiffs arrest without

probable cause, and in the absence of lawful authority. The conduct of Defendant MAIO

constitutes false arrest/false imprisonment.

59. The conduct of Defendant MAIO, as set forth herein, occurred within the course

and scope of his employment as a law enforcement officer for Defendant BROWARD COUNTY

SHERIFFS OFFICE. Pursuant to 768.28 (9)(a) of the Florida Statutes, Defendant BROWARD

COUNTY SHERIFFS OFFICEis liable to Plaintiff in tort for false arrest/false imprisonment,

based upon the conduct of Defendant MAIO.

60. As a direct and proximate result of the acts described herein, Plaintiff has suffered

grievously, has been brought into public scandal, and with great humiliation, mental suffering,

and damaged reputation.

61. As a further direct and proximate result of the conduct described above, Plaintiff

suffered loss of his liberty and freedom, loss of personal property, bodily injury and resulting

pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment

of life, expense of hospitalization, and medical care and treatment, loss of earnings, loss of ability

to earn money. The losses are either permanent or continuing and Plaintiff will suffer the losses

in the future, in violation of Plaintiff's rights.

WHEREFORE, Plaintiff demands Judgment Defendant ISRAEL, in his official capacity

with the Broward County Sheriffs Officefor:


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b. Cost of suit;

c. Trial by jury as to all issues so triable; and

d. Such other relief as this Honorable Court may deem just and appropriate.

COUNT VI

STATE LAW CLAIM AGAINST DEFENDANT MAIO, INDIVIDUALLY, FOR FALSE

ARREST/FALSE IMPRISONMENT

For his cause of action against Defendant MAIO in Count VI, Plaintiff realleges and adopts, as if

fully set forth in all prior counts, the allegations of paragraphs 1 through 48.

62. The conduct of Defendant MAIO, individually, proximately caused Plaintiffs

arrest without probable cause, and in the absence of lawful authority. The conduct of Defendant

MAIO, individually, constitutes false arrest/false imprisonment.

63.

Alternatively to the allegations set forth in Count V of Plaintiffs Complaint, and

pursuant to Federal Rule of Civil Procedure 8(e), and 768.28 (9)(a) of the Florida Statutes,

Plaintiff alternatively alleges that the conduct of Defendant MAIO occurred outside the course

and scope of his employment as a police officer for Defendant BROWARD COUNTY

SHERIFFS OFFICE, in bad faith, with malicious purpose, or in a manner exhibiting wanton and

willful disregard of human rights, safety, or property. Defendant MAIO, therefore, is

individually liable to Plaintiff in tort for false arrest/false imprisonment.

64.

As a direct and proximate result of the acts described herein, Plaintiff has suffered




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suffered loss of his liberty and freedom, loss of personal property, bodily injury and resulting

pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the enjoyment

of life, expense of hospitalization, and medical care and treatment, loss of earnings, loss of ability

to earn money. The losses are either permanent or continuing and Plaintiff will suffer the losses

in the future, in violation of Plaintiff's rights.



b. Cost of suit;



COUNT VII

STATE LAW CLAIM FOR BATTERY/UNNECESSARY USE OF FORCE AGAINST

DEFENDANT BROWARD COUNTY SHERIFFS OFFICE

For his cause of action against Defendant BROWARD COUNTY SHERIFFS OFFICEin Count

VII, Plaintiff realleges and adopts, as if fully set forth in all prior counts, the allegations of

paragraphs 1 through 35.

66. Defendant MAIO intentionally, unnecessarily, and without legal justification,

struck Plaintiff with his fist, thereby causing great bodily harm and internal injuries to Plaintiff.

67.

The force used by Defendant MAIO was unreasonable and unnecessary for

Defendant MAIO to defend himself, or any other person, from bodily harm.

68. The unreasonable and unnecessary use of force by Defendant MAIO was clearly


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excessive and objectively unreasonable under the circumstances, and resulted, as Defendant

MAIO reasonably should have foreseen, in a harmful and offensive contact of Plaintiff, against

his will. The conduct of Defendant MAIO constitutes battery/unnecessary force under the laws

of the State of Florida, pursuant to Broward County Sheriffs Officev. Sanders, 672 So.2d 46, 47

(3rd DCA 1996).

69. The conduct of Defendant MAIO, as set forth herein, occurred within the course

and scope of his employment as a law enforcement officer for Defendant BROWARD COUNTY

SHERIFFS OFFICE. Pursuant to 768.28 (9)(a) of the Florida Statutes, Defendant BROWARD

COUNTY SHERIFFS OFFICEis liable to Plaintiff in tort for battery/unnecessary use of force,

based upon the conduct of Defendant MAIO.

70. As a direct and proximate result of the acts described above, Plaintiff has suffered




suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish,

loss of capacity for the enjoyment of life, expense of hospitalization, and medical care and

treatment, loss of earnings, loss of ability to earn money. The losses are either permanent or

continuing and Plaintiff will suffer the losses in the future, in violation of Plaintiff's rights.

WHEREFORE, Plaintiff demands Judgment against Defendant ISRAEL, in his official

capacity with the Broward County Sheriffs Officefor:


b. Cost of suit;


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COUNT VIII

STATE LAW CLAIM FOR BATTERY/UNNECESSARY USE OF FORCE AGAINST

DEFENDANT MAIO, INDIVIDUALLY

For his cause of action against Defendant MAIO, individually, in Count VIII, Plaintiff realleges

and adopts, as if fully set forth in all prior counts, the allegations of paragraphs 1 through 35.

72.

Defendant MAIO, in his individual capacity, intentionally, unnecessarily, and

without legal justification, shot bullets at Plaintiff, thereby striking Plaintiff with a bullet causing

great bodily harm including internal injuries.

73. The force used by Defendant MAIO, in his individual capacity, was unreasonable

and unnecessary for Defendant MAIO to defend himself, or any other person, from bodily harm.

74. The unreasonable and unnecessary use of force by Defendant MAIO, in his

individual capacity, was clearly excessive and objectively unreasonable under the circumstances,

and resulted, as Defendant MAIO reasonably should have foreseen, in a harmful and offensive

contact of Plaintiff, against his will. The conduct of Defendant MAIO constitutes

battery/unnecessary use of force under the laws of the State of Florida, pursuant to Broward

County Sheriffs Officev. Sanders, 672 So. 2d 46, 47 (3rd DCA 1996).

75.

Alternatively to the allegations set forth in Count V of Plaintiffs Amended

Complaint, and pursuant to Federal Rule of Civil Procedure 8(e), and 768.28 (9)(a) of the

Florida Statutes, Plaintiff alternatively alleges that the conduct of Defendant MAIO occurred


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outside the course and scope of his employment as a police officer for Defendant BROWARD

COUNTY SHERIFFS OFFICE, in bad faith, with malicious purpose, or in a manner exhibiting

wanton and willful disregard of human rights, safety, or property. Defendant MAIO, therefore, is

individually liable to Plaintiff in tort for battery/unnecessary use of force.

76. As a direct and proximate result of the acts described above, Plaintiff has suffered




suffered bodily injury and resulting pain and suffering, disability, disfigurement, mental anguish,

loss of capacity for the enjoyment of life, expense of hospitalization, and medical care and

treatment, loss of earnings, loss of ability to earn money. The losses are either permanent or

continuing and Plaintiff will suffer the losses in the future, in violation of Plaintiff's rights.



b. Cost of suit;



DEMAND FOR JURY TRIAL

Plaintiff demands trial by jury on all issues so triable as of right.

[Signature on the next page]


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Respectfully submitted,

Law Offices of Brown & Associates, P.A.

Counsel for Plaintiff

12 Southeast 7thStreet

Suite 700Ft. Lauderdale, FL 33301

Telephone: (954) 764-6828

Fax: (954) 764-0287

By: /S/ Christopher M. Brown

Christopher M. Brown, Esq.

Fla. Bar 0056170


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Documents

Man Says Off-Duty BSO Cop Arrested Him for Taking a Parking Space