In The 13th Judicial Circuit

Tampa, Florida Division

1. Darryl Schneider

Plaintiff

Case 25-CA-11806

1. Alex Rothschild

Sued as an Individual

2. Victor Crist

Sued as an Individual

3. JP Morgan Chase & Co.

Sued as a Corporation

Defendants

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Complaint

1. Main Introduction:

Every statement in this complaint is unambiguous, and not only sum sufficiently believable to a reasonably prudent person on its face (“four corners” rule), but clearly proven as seen by reviewing the appendices. Any arguments pled in writing by any officer of the court, including the judge, NOT based on material evidence submitted, and used as a false means to dismiss this case, is an attempt to violate Title 18, Chapter 83, Section 1346; F.S. 838.022(a);(b);&(c); and 112.3173(e)(6) (honest services fraud). All the statements made in this complaint are relevant facts, written as SHORT AS POSSIBLE WITHOUT ARGUMENT, when there were rather large numbers of FRB contracted/paid retaliatory agents, relentlessly out to injure both the Plaintiff and his wife!

2. All of the Defendants cited in this complaint, have sum sufficiently been proven guilty of having capably or intentionally participated in specific violations of either the: 1) RICO Act; 2) constitutional amendment rights; 3) state and federal statutes; 4) duty to render aid; or 4) state and federal common laws, which resulted in Mrs. Kimball’s death, either as an intentional or culpable tort (murder under F.S. 782.04(1)(a), or aggravated manslaughter under F.S. 782.07(1)). Unfortunately it cannot be determined which type of murder was committed on Mrs. Kimball and by whom, due to the concealment of 1) medical records and the 2) full FHP murder video, by respectively John Couris and State of Florida (SOF) through FHP.

3. This complaint’s viewable online for more participants to become plaintiffs in class action lawsuits against the private FRB owners. The Corner Post, Inc. Vs. Federal Reserve case, proves private FRB owners do exist, and are allowed to be sued individually or through any one of their banking cartels they own as individual entities, used for racketeering purposes (FRB or commercial subsidiary banking investment corporations). Bozeman Financial LLC v. Federal Reserve Bank of Atlanta, 955 F. 3D 971. The Federal Reserve Banks were established as chartered corporate instrumentalities (really a cartel) of the United States under the Federal Reserve Act of 1913. See 12 U.S.C. § 221 et seq. Unlike the Postal Service, which was at issue in Return Mail, the Banks’s enabling statute, does not establish them as part of an executive agency, but rather each Bank is a “body corporate.” 12 U.S.C. §341. Like any other private corporation, the Banks each have a board of directors to enact bylaws and to govern the business of banking like corporations. But the FRB isn’t registered as a corporation within states, just merely as a cartel/organization/association-in-fact banking syndicate. Moreover, the Bank may sue or be sued in “any federal court of law or equity.” The four elements of Rule 23(a) require a showing that: (1) the class is so numerous that joinder of all members is impracticable; (2) there are questions of law or fact common to the class; (3) the claims or defenses of the representative parties are typical of the claims or defenses of the class; and (4) the representative parties will fairly and adequately protect the interests of the class. Plaintiffs may argue that the Supreme Court decision in Bridge v. Phoenix Bond & Indemnity Co. (discussed in § 33 above) eases the requirements for certification of a RICO class. In Bridge, a RICO case that did not involve a class action, the Court held that a plaintiff asserting a RICO claim predicated on mail fraud, may be able to establish proximate cause without showing that the plaintiff relied on the alleged misrepresentations. However, the circumstances of that case were unique because the plaintiff could show that it was directly injured by fraud on which third-party government officials relied, as is the case in this matter committed by judges and cops (DHS & TPD). Government agents within local concerts, make up the frauds they commit themselves, with others turning blind eyes. This requirement is met when judges within a circuit or district, commit honest services frauds with mail and/or wire misrepresentations, consequently their Imputed after the fact benefactors can be sued either in federal or state court for non-compliance, in that state, or against the FRB headquarters directly (NY), only in federal court under 12 U.S.C. §632. The private FRB owners knowingly and intentionally use their banking corporations to transfer their private hot moneys to: This Court; Defendant Dawson’s State Farm Insurance Company as an FRB affiliate (see Appendix A); TGH; SOF; and COT, as highly biased and illegal benefactor participants in this case, always involved in judicial court case scams, due to their contracted/paid/bribed judges under state governor orders to benefit them illegally at will, by approving conversion and interference scams on consumers within their courtrooms. Suing under the RICO Act, is NEVER a continuation of a prior lawsuit, but a new tort made possible by racketeering judges during prior court cases!

4. When the word bribed is stated in this complaint, it means: 1) Bribery under (Title 18, Chapter 96, Section 201); and 2) Extortion under (Section 1951); perpetrated to implement racketeering activities. And agent salaries and perks constitute as agreeable bribes, or forced extortions depending on the amounts offered, but both are used in making FRB agents comply to committing racketeering activities for their FRB benefactors, when these benefactors own and control the American money supply and most of the world’s businesses.

5. When the FRB and FRB owners’ commercial subsidiary banking investment corporations’ fund, invest or collect agency proceeds, with some of the hot loot coming from consumers’ laundered and misappropriated moneys owed (blood moneys) using FRB contracted/paid judges, a RICO relationship is most DEFINITELY in place between the FRB owners/controllers and their subordinate judicial agents. So the 4 doctrines of law cited repeatedly within this complaint DEFINITELY apply.

6. Jurisdiction:

This court has subject matter jurisdiction to hear all of the Counts against all of the Defendants in this complaint based on either 1) their residential locations being within local courthouse limits and 2) all of the injuries having occurred within the same limits, or 3) the Defendants do business locally within Tampa, Florida limits. Where the injuries occurred, is the correct jurisdiction for all the Defendants to be sued. This local federal courthouse has subject matter jurisdiction over this action pursuant to 28 USCS § 1331, as this action arises under federal laws, specifically, but not limited to: 18 U.S.C. § 1346 (honest services frauds); 18 U.S.C. §§ 1341; 1343; (mail and wire frauds); and `U.S.C. §§ 1513 (retaliation against witnesses); and under Title 28, Chapter 190, Section 5001.

7. The focus of specific personal jurisdiction is on the defendant’s/company’s conduct within the forum state, and the lawsuit must arise from that conduct. Consequently, the defrauding of the Plaintiff and his wife in this matter, arose from the advantageous money making relationship the FRB and the other Defendants continue to have with each other, by way of hot funds/investments/bribes originating from the FRB, being reallocated/recycled as seen on FRB’s, TAS and IPAC debit/credit ledger transfer sheets within its supercomputers, transfers made to either Governor DeSantis, or directly to State of Florida agencies, along with government monetary transfers/distributions to local public/private Florida based agencies/agents like Centene and Defendant Couris (Appendix A & D). All the different addresses/structures housing FRB contracted/paid/bribed agents, public/private, make up the one (1) illegal FRB enterprise operating as both an enterprise when investing moneys to acquire and interest in, for the control of racketeering activities in the future, and as an association-in-fact enterprise operating within owner/controller concerts for organizational purposes. The FRB operates from within both types of enterprises.

***7.5 Relevant Statements of Fact concerning statute of limitation to file claims in this matter:

***7.6 2 years after the CAUSE of the Wrongful Death and Survival Action claims are discovered under Applicable F.S. 95.11(5)(c) – – the limitation of actions within this subsection shall be limited to the health care provider and persons in privity with the provider of health care (Mrs. Kimball). In those actions covered by this paragraph in which it can be shown that fraud, concealment, or intentional misrepresentation of fact prevented the discovery of the injury the period of limitations is extended forward 2 years from the time that the injury is discovered or should have been discovered with the exercise of due diligence, but in no event to exceed 7 years from the date the incident giving rise to the injury occurred. This intentional tort with an indefinite statute of limitations of up to 7 years, and for an additional 2 years after Mrs. Kimball’s medical records are disclosed. If TGH spoliated Mrs. Kimball’s medical records, Defendant TGH has another 4 years to be sued under F.S. 95.11(3)(n) when it’s determined it did so.

***7.7 4 year statute of limitations: F.S. 95.11(3)(i) – – due to a legal or Equitable Action founded on FRAUD, such as having filed a complaint for Equitable Relief in state court (25-CA-8096) by a state court judge, and having it illegally transferred to federal court by FRB contracted/paid Defendant Crist, Clerk of the Court and Comptroller of the 13th Judicial Circuit, for the purpose of being illegally dismissed by federal court judge Thomas Barber the next day (case 25-CV-3077), when a notice of the Plaintiff dismissing the FRB from the state case (25-CA-8096) was given to Judge Barber before he illegally dismissing case 25-CV-3077. And four (4) of the defendants were already being sued in this same courthouse for federal violations under case 25-CV-2181, so Judge Barber had NO jurisdiction to do anything! His false order is VOID! This is an intentional tort with a 4 year statute of limitations, which applies to Defendant Crist as contracted/paid individual, working for the FRB in defrauding the Plaintiff in 11/2025.

***7.8 4 year statute of limitations: F.S. 95.11(3)(n) – – due to an action for assault, battery, false arrest, malicious prosecution, malicious interference, false imprisonment, or any other intentional tort, Defendants Dawson (individual); COT; SOF; TPD; Rothschild (individual); and Crist (individual) are being sued in this matter. The Plaintiff was Falsely Imprisoned until 12-13-23, consequently he had no knowledge of Mrs. Kimball’s murder until he was released from jail. Under F.S. 95.11(3)(n), the four (4) year statute of limitations starts on 12-13-23.

***7.9 Whoever, through culpable negligence, exposes another person to personal injury commits a misdemeanor of the second degree, punishable as provided in s. 775.082 or s. 775.083. Whoever, through culpable negligence, inflicts actual personal injury on another commits a misdemeanor of the first degree, punishable as provided in s. 775.082 or s. 775.083. And the statute of limitations starts to accrue, when it is discovered.

8. Statements of Fact in Mrs. Gloria Schneider’s 7-1-12 murder by her caregiver, which relevantly started the Plaintiff feud with John Rockefeller who’s the proximate cause of this complaint:

9. For at least 10 years prior to Gloria Schneider’s murder in 2012, her money was being laundered into Richard Murphy’s pension fund by Richard, his wife Sybil and her sister Cyrie Schneider, Mrs. Schneider’s caregiver.

10. The Plaintiff married Mrs. Kimball in 2010, with her drug use making her an easy TPD agent cop target in public for civil right violations. This forced the Plaintiff to protect his wife’s constitutional rights being violated as TPD sport, with FRB profits pouring in from her illegal court case fines; fees; and jail sentences, from the Plaintiff’s wallet!

11. Early in 2012, the Plaintiff made himself Mrs. Kimball’s guardian advocate for the purpose of giving her moral support and to stop the fleecing of his wife by FRB contracted/paid agent judges and cops, by having the right to stand up for her rights in criminal court, but Mrs. Kimball’s right to consent ALWAYS remained with her under during this advocacy program.

12. A few days later, the Plaintiff argued with HCSO Colonel James Previtera about his wife being given the wrong medications while in jail. James retaliated by sending his deputies to the Plaintiff’s house immediately to harass and intimidate him for days with their guns drawn.

13. The Plaintiff made complaints about James Previtera’s retaliatory actions above to both TPD and FDLE, which resulted in James being asked to leave HCSO (fired).

14. Right after this, Sheriff David Gee had the Plaintiff’s guardian advocacy illegally cancelled by Judge Isom, with everyone in the courtroom, other than the Plaintiff, stating Mrs. Kimball supposedly didn’t need a guardian against the FRB’s agent judges and cops.

15. After 7-1-12, the Plaintiff’s contested the false will drafted for his mother by probate attorney Robert Welker without her knowledge. Every probate attorney in town, even Robert Welker, stated Mrs. Schneider wasn’t alive long enough for her signed will to be valid when she died, no was murdered, 2 days after she signed a will solely acquired by her caregiver. Mrs. Schneider was never taken to a doctor the last year of her life; denied her antibiotics for pneumonia; lied to about what she had medically wrong with her; and left for dead after signing the false will.

16. Relevant Statements of Fact after Mrs. Schneider’s murder:

17. From 2012 to 2019, the Plaintiff fought with trial and appellate judges to 1) have his mother’s culpable or intentional murder investigated, and to 2) reverse the conversion and interference scams committed on his mother by respectively the Murphys and their attorneys starting at least around 2020, but to no avail.

18. Case 20-CV-78 was filed, NOT as a rendition of the local court case fights with the Murphys for committing conversion frauds and implementing tortious interference scams committed by their attorneys, but as a bona fide RICO Act complaint, due to the judges and opposing counsels having combined forces to commit honest services frauds on the Plaintiff, financially saving their benefactor John Rockefeller and his FRB, by keeping Gloria Schneider’s stolen loot in Richard Murphy’s pension funds, held by the FRB for McDonald Douglas and Lockheed Martin.

19. In early to mid-2020, John Rockefeller was phoned by the Plaintiff numerous times to resolve the matter. What was stated is cited in the Rockefeller letters (Appendix A).

20. Throughout 2021, the Plaintiff’s wife had a total of $1,600 of her SSI money converted into the pockets of her neighbors, by them drugging her, with Mayor Jane Castor from COT and Stephanie Banks (ironic last name) from social security contacted.

21. In late 2021, Agent Mark Braswell from DHS, was not acting in accordance with DHS’s standard Blue Campaign management plans; policies; and operational procedures (mandates and policies), so the Plaintiff is currently suing DHS for its illegal involvement in also causing his injuries: 1) The Plaintiff’s email service provider, mail.com, called him on his phone, stating that someone at the DHS office in Orlando, Florida was trying really hard for days to log into his email account. 2) A month later, this same agent was pounding on the Plaintiff’s front door with a letter addressed to him, which demanded the Plaintiff to stop calling the local social security manager, Stephanie Banks, about reimbursing his wife for her stolen SSI moneys (Appendix B). This was a ruse because the Plaintiff had stopped contacting Ms. Banks two (2) months prior. 3) While at the Plaintiff’s home, this agent started knocking on neighbors’ doors to obtain any gossip about Mrs. Kimball. 4) A couple weeks later, DCF was pounding at Mrs. Kimball’s door to investigate a complaint this same agent had made to them about the Plaintiff supposedly having STRUCK his wife, not about human trafficking (see the DCF reports in Appendix B). The Plaintiff was asked by DCF why a false complaint was made by a DHS agent, but he couldn’t answer the question. 5) A week later, this same agent started leaving voicemail and text messages on the Plaintiff’s phone, not about Mrs. Kimball, but about his FRB scammed inheritance, due to John Rockefeller’s joint venture pension funds through Lockheed Martin and McDonald Douglas (see Appendix E video). 6) A month later, a confidential law enforcement friend of the Plaintiff, advised him that a DHS agent was talking to TPD’s chief of police, Brian Dugan, about DHS wanting the Plaintiff illegally arrested and charged with human trafficking of his wife. 7) A month after filing a Writ of Mandamus on Ronald DeSantis in 2025 (Appendix A), with the video of agent Braswell included, the Plaintiff received a voice mail message from Agent Braswell screaming his first name, and then disconnecting the call. See Appendix B.

22. No probable cause was made to search or arrest the Plaintiff on 2-24-22, based on material evidence in violation of any Florida statute, or a conversation with competent Mrs. Kimball beforehand, just an Amazon purchased port-a-potty with liners was used as a ploy to illegally obtain a search warrant and arrest the Plaintiff on, which TPD subordinate agent cops called a bucket, and a good bust (Appendix B).

23. At the local Tampa Bay courthouse on the morning of 2-23-22, a bogus search warrant was obtained by local FRB contracted/paid/bribed TPD cops before any conversation with competent Mrs. Kimball, using no material evidence of a crime committed (bona fide material evidence to a crime committed, is MISSING from case file 22-CF-2324-A).

24. At the local courthouse in the afternoon of 2-23-22, Mrs. Kimball was FRB agent cop (TPD) browbeaten on courthouse audio/video, in a secured backroom, in front of her attorney, Marc Joseph, during case 21-CF-006147-A, while the conversation was also TPD agent cop recorded (bona fide material evidence).

25. Mrs. Kimball was against her will, made to speak with TPD agent cops, or be arrested and charged with a made up crime, while one of them dangled handcuffs in her face (bona fide material evidence on audio/video).

26. Mrs. Kimball made NO incriminating statements against the Plaintiff, the topic of the conversation, so then an FRB contracted/paid/bribed agent prosecutor working for Andrew Warren, offered her attorney a commonly used FRB BRIBE to nolle process her felony charge, if she’d allow FRB agent cops to take her to another location. This was done to 1) desperately obtain any evidence for legally arresting the Plaintiff on the next day and 2) to keep Mrs. Kimball from going home, so cops would have an easier time illegally arresting her husband (bona fide material evidence in case files 22-CF-2324-A & 21-CF-006147-A).

27. In the evening of 2-23-22, Mrs. Kimball was unknowingly taken to TPD agent, Corporal Crystal Shiver’s HOME, and pressured for, what the Plaintiff was told by his wife was overnight, to talk about her husband with further rewards promised. Then she was taken to a federal FRB funded half-way house, told she couldn’t go home, and periodically browbeaten for 3 weeks while being audio recorded (bona fide material evidence MISSING from case files 22-CF-2324-A & 21-CF-006147-A). See Appendix B.

28. On 2-24-22, TPD agents showed up at Mrs. Kimball’s residence with a bogus search warrant for the property, obtained without any material evidence provided to local Judge Twine of a crime committed. This warrant basically stated FRB agent cops had the right to look for evidence of abuse and neglect committed by a caregiver under Florida Chapter 825, as though Mrs. Kimball was disabled under Florida Chapter 825, when she wasn’t! When cops were finished searching, all they found were stools in the family port-a-potty, with the Plaintiff being illegally charged with neglect as though a port-a-potty was illegal and he was a caregiver under Florida Chapter 825, who supposedly forced his wife to use their port-a-potty, along with theft/exploitation, also under Florida Chapter 825, as though Mrs. Kimball didn’t have the capacity for consenting to her husband protecting her properties (ID & food stamp cards found in his wallet). So Mrs. Kimball was supposedly incompetent, because a wife would supposedly never let her husband pick up groceries at the store for her! The Plaintiff married Sandra Kimball before she started receiving SSI benefits and always tried to keep her from spending her money or trading her belongings, like her food stamp card and ID, for street drugs. If the Plaintiff hadn’t done this, and knowing his constitutional rights aren’t worth a damn in America, complements of the FRB owners, he would’ve probably been charged with aiding and abetting in his wife’s drug use and murder! DEVILS! Mrs. Kimball was NEVER disabled under Florida Chapter 825, because she had NO permanent mental or physical disability classifying her as either mentally incompetent or physically impaired! According to social security, Mrs. Kimball suffered from manic depressive bipolar disorder, due to years of street drug use, which left her with a non-permanent nervous condition that social security tested for every 2 years to confirm she still couldn’t work because of it, but was competent when on her medications, not street drugs (bona fide material evidence in Appendix C).

29. Mrs. Kimball was her own representative payee (RP) for her SSI benefits, which were deposited into her own bank account! And the Plaintiff was never anyone’s caregiver! Mrs. Kimball never had a caregiver due to never needing one! This is evident when NO material evidence of: 1) The Plaintiff ever being a caregiver; 2) the Plaintiff ever stealing Mrs. Kimball’s benefits, or abusing her physically or mentally; nor 3) Mrs. Kimball being incompetent, was ever produced by SOF/COT/TPD agents in case 22-CF-2324-A! No judge in 25 years of Mrs. Kimball being arrested for drug use, ever brought up competency issues! Mental evaluations were only ordered by judges on Mrs. Kimball, after her attorney intelligently brought up the subject to fool prosecutors and the legal system into dismissing her MISDEMEANOR charges a half dozen times before 2021 (bona fide material evidence held by Attorney Alex Stavrou), due to Mrs. Kimball really being temporality blitzed half the time on street drugs. Mrs. Kimball suffered from severe momentary depression, and needed either medications or street drugs to stop her from having these reoccurring episodes. Unfortunately her medications weren’t sufficient all of the time.

30. Mrs. Kimball was NOT incompetent when she needed to pass competency evaluations, and did so during three (3) of them (bona fide material evidence in case 21-CF-006147-A) (Appendix C), with Attorney Marc Joseph as a witness! The Plaintiff can honestly testify to his wife showing more basic knowledge, logic and good sense, when off street drugs and on her medications, than he ever did!

31. All of the incriminating statements made, not only in the arrest affidavit, but throughout case 22-CF-2324-A, are COT/TPD/SOF agent made up, originating possibly from the Plaintiff’s neighbors residing kitty-corner from him at 10407 N 25 Street, Tampa, FL 33612, retaliating against him due to his phone calls to FRB agent cops, made about their illegal activities. Consequently, FRB agent cops intentionally lied to Judge Twine about the validity of their oral/written statements, when they had NO material evidence to support this judge granting them a search warrant on the Plaintiff’s house. The bogus search warrant was needed, so cops would be able to search for anything illegal they could find to legally charge the Plaintiff with, AFTER illegally arresting him! (desired FRB/DHS/COT/TPD agent cop goal with hindsight being 20/20).

32. The false imprisonment of the Plaintiff and the murder of Mrs. Kimball:

33. The Plaintiff and his wife were represented by Attorney Matthew Kimball McDowell during case 22-CF-2324-A, who told the Plaintiff that his wife COULD live at home, as it was a gray area of law which allowed both him and his wife to live at the same property, due to the no contact order only being on the Plaintiff, with the property solely owned by him. So the Plaintiff technically didn’t have to leave when his wife was home.

34. In mid-2023, the prosecution found out about Mrs. Kimball’s living arrangement and illegally arrested the Plaintiff 2 more times for his wife’s presence at her house, with Judge Goudie NOT granting the Plaintiff bail, and with Fox News at 5 airing false information about the Plaintiff on TV, so he was forced to plead out, or be injured by inmates. The second time TPD found the Plaintiff’s wife at her house, the Plaintiff was jailed for 4.5 months using a bogus TPD search warrant with planted items used to arrest with his wife murdered on the streets!

35. How the 4 doctrines of law cited throughout this complaint are applicable in this matter:

36. Imputation and subsequently acquiescing in, by not implementing the appropriate corrective measures after having knowingly benefited by a fraud, keeps all wrong doers on the hook for both PRIOR and FUTURE damages!

37. The Law of Agency establishes a set of rules for determining when, in relation to third parties, an agent’s conduct or knowledge should be imputed to his or her principal. See Restatement (Third) of Agency §§ 2.01 – 2.04, 5.03 (2006). For example, in transactions with third parties, an agent’s conduct will be imputed to the principal, if the agent acted with actual or apparent authority (attorney/client relationship), or if the principal ratified the agent’s conduct. See Fergus v. Ross, 477 Mass. 563, 566-568, 79 N. E. 3d 421 (2017). See also Restatement (Third) of Agency, supra at §§ 2.01 – 2.03, 4.02.

38. In the realm of torts, the tortious conduct committed by an agent in the scope of his or her agency, will be imputed to the principal under a theory of Respondeat Superior. See Lev v. Beverly Enters.-Mass., Inc., 457 Mass. 234, 238, 929 N.E. 2d 303 (2010). See also Restatement (Third) of Agency, supra at § 2.04. Knowledge that an agent acquires in the scope of his or her employment can also be imputed to the principal. See Sunrise Props., Inc. v. Bacon, Wilson, Ratner, Cohen, Salvage, Fialky & Fitzgerald, P.C., 425 Mass. 63, 66-67, 679 N.E. 2d 540 (1997). See also Restatement (Third) of Agency, supra at § 5.03. Merrimack Coll. v. KPMG LLP, 480 Mass. 614, 108 N. E. 3d 430, 438 (2018).

39. The result of imputation is that the principal bears the legal consequences of the agent’s conduct. Thus, if an agent with actual or apparent authority enters into a contract with a third party, the principal will be bound by that contract. See, e.g., Linkage Corp. v. Trustees of Boston Univ., 425 Mass. 1, 4, 17, 679 N. E. 2d 191, cert. denied, 522 U.S. 1015, 118 S. Ct. 599, 139 L. Ed. 2d 488 (1997) (university bound by agreement signed by vice-president where vice-president had apparent authority).

40. If an agent negligently injures a third party while acting within the scope of the agency, the principal will be held vicariously liable for that negligence. See, e.g., Dias v. Brigham Med. Assocs., Inc., 438 Mass. 317, 323, 780 N. E. 2d 447 (2002) (corporation could be held vicariously liable for alleged medical malpractice of its physician-employee). Merrimack Coll. v. KPMG LLP, 480 Mass. 614, 108 N. E. 3d 430, 438 (2018). Imputation serves various functions. It creates incentives for principals to choose their agents wisely. See Restatement (Third) of Agency, supra at § 5.03 comment b, at 360. It also encourages principals to supervise their agents and to share information with them. Id. The ultimate purpose behind these rules of imputation, however, is to fairly allocate risks between principals and innocent third parties. As explained in Kansallis Fin. Ltd. v. Fern, 421 Mass. 659, 664-665, 659 N. E. 2d 731 (1996).

41. Kansallis:

“Standing behind [the] diverse concepts of vicarious liability is a principle that helps to rationalize them. This is the principle that as between two innocent parties — the principal-master and the third party — the principal-master who for his own purposes, places another in a position to do harm to a third party, should bear the loss. A principal who requires an agent to transact his business, and can only get that business done, if third parties deal with the agent as if with the principal, cannot complain if the innocent third party suffers loss by reason of the agent’s act. Similarly, the master who must put an instrument into his servant’s hands in order to get his business done … must also bear the loss, if the servant causes harm to a stranger in the use of that instrument as the business is transacted.” (Citations omitted.) Merrimack Coll. v. KPMG LLP, 480 Mass. 614, 108 N. E. 3d 430, 438 (2018).

42. Vicarious Liability under the Respondeat Superior Doctrine: “Qui Facit per alium facit per se”, i.e., he who acts through others, acts through himself. And “respondeat superior”, i.e., let the master be liable. A master (owner/controller) is primarily liable for the actions of his or her hired servants.

43. Statements of Fact against David Dawson II:

44. While the Plaintiff was in jail until 12/2023, Defendant Dawson, who was driving his car at 3:40am on 8-19-23, purposely overtook a parked car next to a visible crosswalk within an intersection with a traffic light, without slowing down and struck Mrs. Kimball, a pedestrian within a visible crosswalk, a violation of F.S. 316.130(9), and never got out of his car to see what he could do to help, nor did he call in the emergency to 911, a violation of his duty to render aid under F.S. 316.062. Thus a culpable or intentional tort was committed by David Dawson by striking Mrs. Kimball illegally with his car.

45. FHP still refuses to provide the full video of the homicide to the victim’s spouse, without having done a mandatory drug screening of Defendant Dawson at the time of the homicide (see report in Appendix A). It’s still undetermined if Dawson was culpably or intentionally negligent when he struck Mrs. Kimball with his car hard without slowing down, as if he was trying to murder her.

46. Defendant Dawson clearly overtook a vehicle parked at a stop light, in front of a crosswalk, a violation of F.S. 316.130(9) – – Whenever any vehicle is stopped at a marked crosswalk, or at any unmarked crosswalk at an intersection, to permit a pedestrian to cross the roadway, the driver of any other vehicle approaching from the rear, shall not overtake and pass such stopped vehicle! This reads exactly on par with what the video footage of Mrs. Kimball’s homicide shows! This intentional, or culpable, negligence on the part of Defendant Dawson, resulted in at least the aggravated manslaughter (statutorily cited later on in the Counts section) of Mrs. Kimball (capable negligence is aggravated manslaughter, which is a type of murder)! At this point it’s speculative as to what Defendant Dawson was doing at 3:40pm on a Saturday morning, driving at a high speed. This speculation became highly alarming to the Plaintiff, when FHP failed to conduct MANY of its mandatory statutory duties right after the homicide as State of Florida mandated policies. Part of the homicide can be watched from a partial clip in Appendix E.

47. The Plaintiff hired credible investigator “Star” to determine, if Defendant Dawson was negligent, or deliberate, when he CRIPPLED Mrs. Kimball with his car (see homicide report Appendix A). According to A) hearsay witness testimony, along with B) FHP having intentionally violated both the Plaintiff and his wife’s state and federal 14^th amendment rights; and state and federal mandatory statutory duty to properly investigate a homicide, by doing a drug screening and review of the full video obtained for criminal/racketeering activities, with the spouse NOT being given a copy of everything FHP obtained; and to MAINTAIN its standard management plans; policies; and operational procedures during both the homicide and in case 24-CA-7358, but intentionally failed to: 1) Apply required F.S. 316.103(9) to its homicide report; 2) do a mandatory drug screening of Defendant Dawson at the scene of the homicide (very suspicious FHP violation of homicide procedures (pre-spoliation of evidence)); 3) correct its false homicide report which wrongly states Mrs. Kimball was at fault while in the crosswalk (Appendix B), thus WRONGLY stating she caused the accident (very suspicious when pedestrians have the right of way, and under F.S. 316.130(9); 4) concealed/spoliated the rest of the murder video, part of which was inadvertently provided to the Plaintiff (hindsight 20/20), so A) no one else could determine who jump out of Defendant Dawson’s car right after the homicide and ran off (as stated by witness Brandon Santiago cited in the FHP’s homicide report); or B) who was chasing/luring Mrs. Kimball into the crosswalk (very suspicious); and C) who had been stalking Mrs. Kimball for hours the morning of 8-19-23; and 5) intentionally having its attorney in case 24-CA-7358, blatantly state FHP spoliated the homicide video to conceal the rest of it, when it’s MANDATORY for FHP to keep complete video tapes on all homicides, as stated to the Plaintiff in mid-2025, by Tampa based Lt. Eric French, FHP (extremely suspicious)! The manager of the Take 5 oil change shop which made the video, stated to the Plaintiff that an FHP officer had downloaded a full days’ worth of the video!

48. These facts along with credible testimony from a couple of shop owners and a dozen homeless witnesses working/living in the immediate vicinity of Mrs. Kimball’s homicide (not material evidence, but a good start for obtaining more), all stated to both the Plaintiff and his investigator, they either had personal knowledge of who murdered Mrs. Kimball and why it was committed, but were too scared to give the details, or heard credible hearsay information that the car driver (Defendant Dawson) who caused the homicide (3:40am on 8-19-23), was a drug dealer/runner working out of another location in west Brandon, Florida for covertness, who had a known drug pusher/distributor in his car at the time, who were both looking to injure Mrs. Kimball (first or second degree murder) for supposedly stealing drugs from the pusher, as well as from his local buyers/users for months. Credible witnesses recently told the Plaintiff they tried to keep Mrs. Kimball hidden the night she was murdered, so she couldn’t be found by Defendant Dawson and his passenger! At this point, Defendant Dawson should’ve already had his driving privileges suspended for illegally mowing Mrs. Kimball down with his car, a violating F.S. 316.103(9)!

49. Since a murder occurred, and FHP’s a department within the State of Florida (SOF), there’s no statute of limitations in suing SOF, or one of its employees, for intentionally covering up the murder video by spoliation, for the FULL recoverable damage amounts in this case, through its benefactor the FRB, with the deepest pockets, currently being sued in state court!

50. Relevant Statements of Fact about Tampa General Hospital for spoliation of evidence and Fraud on the Court committed:

51. Defendant TGH, along with its owner John Couris, knowingly and intentionally denied Mrs. Kimball’s spouse her TGH medical records, when a personal representative has never been appointed in this matter, a violation of F.S. 395.3025(1). John Couris was directly notified in early 2025, that Mrs. Kimball’s spouse, a reasonably prudent person, believed she had been murdered by his funding source, the FRB, due to the Plaintiff threatening to sue the FRB through John Rockefeller. A letter directly sent to John Rockefeller in 2020, with a copy of the 2025 Rockefeller letter, both in Appendix A, was sent to Mr. Couris, who’s now at least an accessory after the fact (AATF) in either the culpable, or intentional, murder of Mrs. Kimball by Defendant Dawson, but it’s still unknown if John Couris didn’t in fact intentionally cause Mrs. Kimball’s death as a benefit to his FRB funding source through TGH, thus also assisting in the murder of Mrs. Kimball, with her TGH medical records possibly spoliated as stated in case 24-CA-7358, as a misrepresentation used to cover-up TGH’s involvement in Mrs. Kimball’s murder.

52. TGH is an AATF in at least the aggravated manslaughter of Mrs. Kimball, by covering up her medical details to benefit itself; its funding and investing source the FRB; and Dawson. John Couris screwed up when he failed to provide Mrs. Kimball’s medical records, after he was directly notified of her being murdered, at least as an F.S. 782.07(1) violation. Now TGH is being correctly sued for Mrs. Kimball’s medical records being technically spoliated (concealed or destroyed). And the statute of limitation on wrongful death demands that TGH continue to be sued for wrongful death to preserve the filing date, because it fraudulently spoliated Mrs. Kimball’s medical records!

53. The Plaintiff is suing TGH due to John Couris’ many law violations: 1) He covered up the details of Mrs. Kimball’s murder, by tortiously interfering in the Plaintiff obtaining Mrs. Kimball’s medical records directly from TGH, starting in the beginning of 2024 (Appendix A); and by having 2) hired attorneys to misrepresent the facts in court as an accessory after the fact in Mrs. Kimball’s murder during court case 24-CA-7358, when he knew beforehand Mrs. Kimball was probably murdered (no court ruling of murder needs to be made on this subject to civilly sue for murder.

54. John Couris is being sued through TGH for knowingly and intentionally stopping TGH from providing the Plaintiff with his wife’s medical records, a violation of F.S. 395.3025(1) (Appendix A). John Couris had his attorneys brazenly lie in court case 24-CA-7358, stating that the Plaintiff couldn’t have Mrs. Kimball’s TGH medical records, because he wasn’t married to her in 2010, for their marriage license not being on file with Hillsborough County’s, Clerk of the Court, until after her death! A total bull chip lie! What’s John Couris been hiding for 2 years?

55. John Couris also tortiously interfered with the Plaintiff’s expectancy to obtain his murdered wife’s medical records in a timely fashion from TGH, starting in the beginning of 2024, now considered spoliated evidence (mandatory court sanction required, if he doesn’t produce the records after this case is officially open)! And John Couris will be in violation of U.S. Code § 1519 (destruction, alteration, or falsification of records), if he no longer has them!

56. It’s probable that John Couris through TGH committed culpable or intentional wrongful death on Mrs. Kimball using his TGH agents, a violation of both Florida Statutes 768.16 (wrongful death); and 46.021 (survival action claim for 3.5 days of suffering), because of the spoliation/concealment of Mrs. Kimball’s TGH medical records as an AATF in her murder. If this is later found to be incorrect, the Plaintiff will amend his complaint and delete these Counts, but you cannot add them to this complaint after 2 years, so these Counts have to stay with TGH until after discovery. John Couris’ fault for not providing the records.

57. John Couris committed a compounding offense after tortiously interfering in the Plaintiff obtaining his wife’s medical records, which also makes him at least an AATF to whoever was the proximate cause of her death. It consists of three (3) basic elements: (1) knowledge of the crime (direct notice was given to both Governor DeSantis and John Couris, cited in Appendix A); (2) the agreement not to prosecute or inform (Mrs. Kimball’s medical records were withheld or destroyed (spoliated)) by the illegal participation/involvement of both DeSantis and Couris, respectively cases 25-CV-564 & 24-CA-7358); and (3) the receipt of consideration – – continued state funding to TGH from the FRB through DeSantis; Medicaid; and USF, for the purpose of continuing to have TGH SAVE the FRB from indirectly having to pay the Plaintiff, and possibly other consumers, restitution/compensation through TGH. The offense is concluded when there’s an agreement to either withhold evidence of the crime, conceal it, or fail to prosecute it. “English common law states: The “crime of compounding” is committed when a perpetrator, prosecutor, any other official or another person enters into an agreement with the victim of a crime or an official, whereby some, or other benefits, are transferred between the parties in order to stop, withdraw or alter the reporting or prosecution of an offense,” explains Charles De Meillon, Florida Chapter 843, Obstructing Justice 843.14 – – Compounding Felony. The Plaintiff had one Defendant complain because he cited criminal statutes in his state complaint. The Plaintiff can’t sue under any criminal statute. But he can show all of the RELEVANT law violations which resulted in his personal injuries. If the Plaintiff can have his mug shot all over the Internet because of John Rockefeller, he can accurately state what real criminal violations his agents committed during this matter!

58. John Couris is also being sued under Title 18, Chapter 96, Sections 1961(1)A & B; specifically Section 1341 (paper by mail used in knowingly and intentionally giving out misinformation of the facts in court case 24-CA-7358, about the Plaintiff not being married to Mrs. Kimball); Section 1343 (wire by Internet used in knowingly and intentionally giving out misinformation of the facts in court case 24-CA-7358 about the Plaintiff not being married to Mrs. Kimball), resulting in Fla. Stat. §838.022(a);(b);&(c); 112.3173(e)(6); and Section 1346 violations – – TGH committed honest services fraud, by not providing Mrs. Kimball’s medical records to the Plaintiff, as well as being an accomplice to the FRB’s contracted/paid/bribed judge in case 24-CA-7358 doing the same.

59. John Couris is guilty of letting either a culpable or intentional tort committed at his hospital stand, after the Plaintiff directly notified him of Mrs. Kimball’s being murdered! This makes John Couris either an AATF, or before the fact (ABTF) as an accomplice in the murder of Mrs. Kimball, DURING HER STAY AT TGH, depending on what’s in her TGH medical records the Plaintiff still doesn’t have! By 2) John Couris continuing to aid and abet the FRB (a source of funding for TGH, by tortiously interfering with the Plaintiff obtaining his wife’s medical records, after being directly imputed by the Plaintiff to stop doing so when she was murdered (Appendix A), John Couris is now at least an AATF to whoever was the proximate cause of her death! Since hindsight’s 20/20, John Couris’ actions/inactions (omissions) after being imputed with the facts in this matter early this year (his letter contained a copy of the 2025 Rockefeller letter referenced in Appendix A), he’s aided and abetted in the cover-up of Mrs. Kimball’s murder as an AATF, either on the street, or at his hospital! The million dollar question is did Defendant Couris aid and abet FRB agents in purposely ending Mrs. Kimball’s life? Due to the spoliation of evidence under Fla. R. Civ. P. 1.380(b)(2)F), makes both Couris and TGH, at least accessories after the fact in her aggravated manslaughter committed by the rest of the Defendants and their concert members. You lose the evidence, you pay for the crime as if you committed it!

60. John Couris’ actions/inactions (omissions) during case 24-CA-7358, continue to injure the Plaintiff and maximize FRB funds officially remaining with TGH, an FRB funded and invested in corporation (Appendix A), in a two (2) step, multitier judicially implemented, tortious interference scam (case 24-CA-7358) to misappropriate Mrs. Kimball’s medical records owed to the Plaintiff – – medical records illegally allowed by FRB contracted/paid/bribed judges in cases 24-CA-7358 and 25-CA-564, to ultimately be hospital kept/spoliated, which profits the FRB in NOT having to compensate/reimburse its TGH business affiliate for any medical malpractice or hospital regulation violation committed, but also by the rest of the FRB funded/invested in Defendants who technically murdered her too, not having to pay restitution, amounting to a huge amount of FRB SAVINGS.

61. Both Defendant Couris and his hospital, which technically spoliated (concealed/destroyed) Mrs. Kimball’s medical records, are liable for her wrongful death, because of: 1) The spoliation committed, and 2) the competent hearsay testimony from a unbiased TGH emergency room nurse, who imparted to the Plaintiff, both TGH and its owner, John Couris, were vicarious liable in NOT adhering to professional hospital standards! These standards amounted to having a board certified neurosurgeon available in the morning hours of 8-19-23, or getting one in FAST! You don’t let a person going unconscious with a head injury go untreated for long, or his or her head will swell up with fluid, and their brain DIES! These standards are violated when a hospital intern such as a residing USF doctor, completing his or her residency at TGH, wrongly/illegally acts as a board certified neurosurgeon. Consequently, TGH and/or its owners can be held accountable for not having one available to perform a needed surgery quickly and correctly after admitting a patient! This liability applies to issues of inadequate staffing, or insufficient training, for handling an emergency, like when the one (1) main TGH board certified neurosurgeon is needed, but has the weekend OFF and some other staff member makes a BAD decision! It’s the Plaintiff choice to either sue TGH or the owner, and there’s no doubt whatsoever Defendant Couris is intentionally/culpably negligent when he needs to racketeer with the FRB’s controller in Florida (Governor DeSantis), for FRB savings/retaliation purposes (Appendix A)! Hindsight in this matter is 20/20!

62. So according to competent hearsay testimony from TGH, by it not having performed Mrs. Kimball’s lifesaving procedure in time, or at least pulled in a board certified neurosurgeon quickly, or had its helicopter team transport her to another hospital with a competent board certified neurosurgeon waiting on hand to immediately perform the procedure, one who finished his or her neurosurgeon residency, Mrs. Kimball’s NOW DEAD! Consequently, if what the nurse above stated is true, Defendant Couris is at least vicariously, no intentionally, liable for Mrs. Kimball’s wrongful death, due to really being an AATF, AFTER having been imputed by the Plaintiff of his wife having been murdered, but still isn’t the proximate cause of damages, the FRB is! To find out how John Couris and his hospital were involved in Mrs. Kimball’s murder, all of her TGH medical records need to be reviewed!

63. Relevant Statements of Fact about City of Tampa (COT):

64. COT agent cops (TPD), obtained a false search warrant of Mrs. Kimball’s house in the morning of 2-23-22, without providing any physical evidence of a violation of Florida statute, as indicated from the warrant used to search (see Appendix B). TPD interrogated Mrs. Kimball in the afternoon of 2-23-22 in front of her attorney Marc Joseph, and threatened her when she stated that she didn’t want to talk to them, with ultimately COT/TPD having to offer her a bribe to dismiss her felony case with an 18 month sentence in prison, if she allowed them to take her to an unknown place, thus illegally keeping her from going home as planned for 1.5 years (2-23-22 to 8-21-23), while further interrogating her for 3 weeks without any crime having been committed, as evident from referencing cases 22-CF-2324-A and 21-CF-006147-A. DHS’s involvement in this matter was to involve COT; and SOF as concert members, for FRB retaliatory purposes. Without obtaining any information from Mrs. Kimball of a crime committed by her husband the Plaintiff, TPD illegally searched her house on 2-24-22, committed theft; conversion; and destruction of her and her husband’s properties (case 22-CF-2324-A photos show a trashed house, not from the Plaintiff or his wife, but from COT/TPD agent cops).

65. The results of this search yielded no sign of Mrs. Kimball being abused or neglected by anyone, as confirmed by one of the TPD agent cops who executed the bogus search warrant, later deposed by Attorney McDowell, recorded on film, and viewable in Appendix E! On 2-24-22, TPD agent cops wrongly arrested and charged the Plaintiff with both neglect and theft under Florida Chapter 825, which entails crimes against adults having either a permanent mental or physical disabilities of the magnitude to be easily exploited. Mrs. Kimball being blitzed on street drugs most of the time, doesn’t count. So she wasn’t disabled under this statute!

66. Because TPD found stools in the family’s legally owned and operated port-a-potty, it wrongly claimed that, by Mrs. Kimball using a port-a-potty made for human waste (see a photo of in Appendix D), not a flushing toilet, the Plaintiff had somehow abused his wife under Chapter 825. COT; and Jane Castor; through TPD agent cops; were instrumental in initially railroading the Plaintiff onto SOF, so Jane Castor’s entire local concert could keep the Plaintiff’s wife from going home, due to the type of bogus charges TPD agent cops filed on him. And due to the illegal arrangement DHS had with COT/TPD/SOF, all accomplices in Jane Castor’s local concert, with all of these agencies/agents knowing no crime was committed by the Plaintiff in case 22-CF-2324-A.

67. After being illegally detained for 3 weeks by COT/TPD agent cops starting on 2-23-22, Mrs. Kimball was shown the streets by them, with nowhere to go and where Attorney Matthew Kimball McDowell found her 3 month later in Pinellas County Florida, living and sleeping on CONCRETE without her medications! If Mrs. Kimball was really COT/TPD’s witness they were trying to protect, where was the evidence given to them by Mrs. Kimball before or after the Plaintiff’s arrest to prove a crime was committed by him? It certainly wasn’t placed into case 22-CF-2324-A. If after Mrs. Kimball having given SOF through COT/TPD, NO testimony it could use to prosecute the Plaintiff with (no affidavit signed, or audio/video filed in case 22-CF-2324-A, incriminating the Plaintiff in any Florida statute violation), and both SOF; and COT/TPD knew Mrs. Kimball was disabled and in need of her medications, which her attorney Matthew Kimball McDowell provided to her on the streets only once, multiple state and city agents, like Jane Castor; Andrew Warren; Susan Lopez; Lynn Goudie; and Mellissa Grajales, are at least culpably negligent in her aggravated manslaughter (MURDER), by intentionally violating the survival action statute (F.S. 46.021), to intentionally keep her on the streets with the false no contact order on her husband still in place! This was done to both aggravate the Plaintiff and to keep arresting him every time COT/TPD found his wife at home.

68. I n this case, all state entities (municipalities and employees) are being sued in state court for any one of their employees having committed a negligent or intentionally tort, while acting within the scope of his or her employment which 1) breached a state government policy. And they’re also being sued in federal court for having 2) implemented a state government policy in violation of their duty to the public under the U.S. Constitution. The plaintiff is suing COT in federal court under, but not limited to the following: 1) Title 28, Chapter 190, Section 5001; 2) (Title 18, Chapter 13, U.S. Codes § 241); 3) Title 42, Chapter 21, Section 1983; and 4) Title 18, Chapter 13, U.S. Code § 241. Punitive damages and attorney’s fees are owed for common law frauds and breaches of fiduciary duties to the public by municipalities. “A public official, acts as trustee for the citizens and the State … and thus owes the normal fiduciary duties of a trustee, e.g., honesty and loyalty to them.” United States v. Kincaid-Chauncey, 556 F. 3d 923, 939 (9th Cir. 2009) (quoting United States v. Silvano, 812 F. 2d 754, 759 (1st Cir. 1987) and United States v. Mandel, 591 F. 2d 1347, 1363 (4th Cir. 1979) (internal quotation marks omitted)).

69. Defendant COT/TPD working together in concert with SOF, with joint and several liability applicable, due to intentional fraud committed, were in violation of the Plaintiff’s 4th and 5th state and federal amendment rights, while being falsely searched; arrested; imprisoned; maliciously prosecuted; and wrongly processed by the court system during case 22-CF-2324-A, when no crime was committed by anyone except Jane Castor’s local concert. This was accomplished by the wrongful actions of Jane Castor instructing TPD agent cops working for COT. Both the Plaintiff and his wife were clearly injured by COT starting on 2-23-2022, using TPD officers while they worked in their official capacities, but were adhering to a different set of DHS Blue Campaign, management plans, polices and operating procedures, under a different and illegal, non-standard set of operating requirements, due to Jane Castor being technically the director of COT. The Blue Campaign, see Appendix A, was originally, and still is, for stopping the migration of immigrant slave laborers into America (typically Cuba and South America). It’s always been an informational and educational program to inform local law enforcement agencies what to look for, not for DHS to get involved in to the point of knowingly and intentionally violating DHS policies, due to having participated directly in illegal arrests, thus breaching human and civil rights it was supposedly trying to uphold for illegal aliens. During the latter part of 2021, DHS had specific mandatory operating requirements for informing local law enforcement agencies on how to identify and implement DHS’s Blue Campaign on violators, not to participate in doing so itself! DHS crossed the line, by conducting an unwarranted investigation on local Americans Mrs. Kimball and her husband, which resulted in him being falsely imprisoned for 225 days, with his wife suffering on the streets for 1.5 years until murdered, due to the no contact order illegally placed on the Plaintiff, initiated by DHS through Jane Castor’s local concert (COT/TPD/SOF).

70. The decision to adopt a different set of management plans, policies and operating procedures is a discretionary function, but its implementation of an incomplete or illegal set of them isn’t. In Maryls Bear Medicine v. United States (9th Cir. 2000) 241 F.3d 1208. When a state or federal agency has acted contrary to mandates or directives, imposing liability doesn’t require a court to second-guess legislative and administrative decisions grounded in social, economic or political policy. “When a suit charges an agency with failing to act in accord with a specific mandatory directive, the discretionary function exception doesn’t apply.” (Berkovitz, 486 U.S. at 544, 108 S.Ct. at 1963.) and (Faber v. United States (9th Cir. 1995) 56 F.3d 1122). A “failure to effectuate policy choices already made, will not be protected under the discretionary function exception.” (Id., 241 F.3d at 1215, emphasis added.)

71. Defendant COT failed to adhere to its STANDARD management plans, policies and operating procedures, opting to initiate an illegal type of DHS Blue Campaign, to intentionally injure the Plaintiff and his wife. Defendant COT was absolutely instructed by its superiors, DHS and Jane Castor, to adhere to a made up set of illegal Blue Campaign operational requirements, to intentionally injure the Plaintiff and his wife. Clearly the reason for the Plaintiff’s injuries (hindsight’s 20/20). During 2022, COT had specific mandatory operating requirements in place, but knowingly and intentionally adhered to a DIFFERENT set of illegal operating requirements, instructing its agent cops to use inapplicable Florida Chapter 825 and a set of illegal DHS’s Blue Campaign instructions on at least the Plaintiff and his wife. This is evident when COT/TPD agent cops, intentionally injured the Plaintiff and his wife, in violation of STANDARD MANDATES, imposed on COT/TPD by Jane Castor and Mark Braswell as their own set of made up operating requirements! Basically DHS’s Blue Campaign mandates are illegally changed whenever desired by DHS agents to implement a witch hunt for prosecuting any FRB marked consumer for actions taken that can be misconstrued as obtaining labor for free. What Agent Braswell from DHS in Orlando, Florida did, was illegally involve his agency in injuring the Plaintiff and his wife as an FRB retaliatory act through COT/TPD/SOF.

72. The Department of Homeland Security (see Appendix A) FUNDS COT/TPD and most local law enforcement agencies to keep them inline with what it wants and when it wants it by, or they’ll be investigated and charged like Judge Hannah Dugan, a Milwaukee County Circuit judge was. The Homeland Security provides to local state agencies, a suite of risk-based grants to assist state, local, tribal and territorial efforts in preventing, protecting against, mitigating, responding to and recovering from acts of terrorism and other threats. So they say. The point is COT/TPD; and Jane Castor have their hands in DHS’s pockets. Consequently if COT/TPD; and Jane Castor fail to take orders from DHS, they’re funding could quickly stop along with DHS perks!

73. A municipality or employee is a proper defendant under Title 42, Chapter 21, Section 1983, where the conduct complained of relates to an official municipal policy, custom, or practice causing the U.S. constitutional tort. Monell v. Dep’t of Soc. Servs. of New York, 436 U.S. 658, 691, 98 S. Ct. 2018 (1972). If COT/TPD, or bastard Mayor Jane Castor, can produce any physical evidence of 1) Mrs. Kimball having been disabled under Florida Chapter 825; 2) the Plaintiff having been Mrs. Kimball’s caregiver; or 3) the Plaintiff having abused/stolen from Mrs. Kimball in violation of any Florida statue, he’ll drop this lawsuit! The corpus delicti rule requires that the prosecution present independent evidence to establish that a crime has occurred. This evidence should include physical evidence, which directly establishes the fact of a crime. In contrast, witness testimony alone in an affidavit ISN’T sufficient to establish corpus delicti. People v. McMahan. See Appendix B.

74. The funding of TPD comes from COT, which is FRB funded, directly and indirectly, by both the quasi-government FRB and FRB commercial subsidiary banking investment corporations, like Chase Manhattan; Rothschild & Co. and their subsidiaries investments like Rockefeller Brothers Fund; Citigroup; Blackrock; Vanguard; and State Street shell corporations. And COT/TPD’s is funded through federal government agencies too, like DHS.

75. COT (a municipality) is being sued in state court for their employees (about 4 dozen, including Jane Castor) having committed intentional and culpable torts while acting within the scope of agent employment, which 1) breached a state government policy. But is also being sued by the Plaintiff in federal court for having 2) implemented a state government policy in violation of their duty to the public under the U.S. Constitution. There were federal violations of, but not limited to, the following federal statutes by Jane Castor acting through COT; and TPD agent cops, along with concert member SOF: 1. Title 18, Chapter 13, U.S. Code § 241; 2. Title 42, Chapter 21, Section 1983; and Title 18, Chapter 13, U.S. Code § 241.

76. The federal statute of limitations in a circuit is tolled permanently on acts to defraud and deprive a plaintiff of his or her human/civil/constitutional rights done in conjunction with committing a Fraud on the Court, (F.S. 1540 or federal 60(b)(3)), or being at least an accessory after the fact (AATF) in a murder under Title 18, U.S. Code § 3, as is the case in this matter!

77. Racketeering under the RICO Act is automatically an intentional breach of government policy, at least according to state and federal constitutions; statutes; rules; duty to render aid; and common laws still in place!

78. The Federal Constitution, Florida Constitution, Florida state laws, rules and regulations, don’t allow immunity, if a state agent acted willfully, maliciously, fraudulently, in bad faith, beyond his or her authority, or under a mistaken interpretation of the law.

79. When determining whether qualified immunity applies, the central questions are: (1) whether the facts alleged, taken in the light most favorable to the plaintiff, demonstrate that the defendant’s conduct violated a statutory or constitutional right, and (2) whether the right at issue was clearly established. Committee To Protect Our Agricultural Water, et al., Plaintiffs, v. Occidental Oil and Gas Corporation, et al, Defendants. No. 1: 15–cv–01323–DAD–JLT. Signed 01/20/2017. Jane Castor and her co-conspiring agent cops through Defendant COT, absolutely knew what they had been committing on consumers periodically for years, violated the Plaintiff and his wife’s state and federal constitutional rights under the 4^th amendment.

80. Government officials enjoy qualified immunity from civil damages, unless their conduct violates “clearly established statutory or constitutional rights of which a reasonable prudent person would have known.” Jeffers v. Gomez, 267 F. 3d 895, 910 (9th Cir. 2001) (quoting Harlow v. Fitzgerald, 457 U.S. 800, 818, 102 S. Ct. 2727, 73 L. Ed. 2d 396 (1982)); see also Bruce v. Ylst, 351 F. 3d 1283, 1290 (9th Cir. 2003).

81. According to the American Bar Association, Volume 18, Number 3 January/February 2009, by Razzano and Kristin H. Jones, since the enactment of 18 U.S.C. § 1346, federal courts have tried to step into this gap. They have divided the universe of honest services fraud into two spheres: public and private honest services fraud. Public honest services fraud is the instrument used by federal prosecutors to impose the federal government’s view of good government on state and local officials. Since the national government under our federal system cannot pass bribery or conflict of interest laws covering local and state officials, the honest services fraud statute has become its vehicle for enforcing its view of good government on state and local jurisdictions. The theory is that when a local or state official 1) takes a bribe, or 2) is embroiled in a conflict of interest, he or she defrauds the people of the state or locality of their right to that public official’s honest services. The courts have widely recognized two theories of honest services fraud in public-sector honest services fraud prosecutions: (1) bribery, where a public official was paid, with some type of valued benefit (not necessarily with money), for a particular decision or action, or (2) a failure to disclose a conflict of interest resulting in personal gain (something of value, but not necessarily monetary).

82. The 11th Circuit’s position is that “[p]ublic officials inherently owe a fiduciary duty to the public to make governmental decisions in the public’s best interest. ‘If the official instead secretly makes his decision based on his own personal interests. . . the official has defrauded the public of his honest services.’” United States v. DeVegter, 198 F. 3d 1324, 1328 (11th Cir. 1999) (quoting United States v. Lopez-Lukis, 102 F. 3d 1164, 1169 (11th Cir. 1997) (emphasis added) (internal citation omitted). The First, Fourth, Ninth, and Eleventh Circuit Courts have all held that the federal statute does not limit the meaning of “honest services” to violations of state law.

83. Plaintiffs have been allowed to bring RICO actions for acts of public corruption that resulted in pecuniary (monetary) injury to them. Envtl. Tectonics v. W. S. Kirkpatrick, Inc., 847 F. 2d 1052, 1067 (3d Cir. 1988); (business competitor had standing to challenge defendant’s alleged use of bribery of foreign government officials to obtain contracts), judgment aff’d, 493 U.S. 400 (1990); Town of Kearny v. Hudson Meadows Urban Renewal Corp., 829 F. 2d 1263, 1268 (3d Cir. 1987) (land developer allowed to bring RICO action for injuries sustained from defendants’ bribery of town officials) and Bieter Co. v. Blomquist, 987 F. 2d 1319, 1327 (8th Cir. 1993) (permitting builder to pursue RICO claim where alleged bribery of public officials raised issue of fact concerning proximate cause of builder’s injury from failure to obtain rezoning). Also, all extortion statutes require that a threat must be made to the person or property of the victim. And a threat to harm a person in his or her career, job or reputation, is also an act of extortion.

84. Nowhere in America, does any statute acknowledge eye witness testimony as being the equivalent to physical/material evidence, and thus only witness testimony being substantial enough to accept as corpus delicti evidence needed to prosecute, or litigate an economic offence. If this were the case, sum sufficient evidence (more likely than not) of wrongs being committed, could be obtained merely by FRB contracted/paid agents, seeking to injure consumers physically/monetarily/emotionally for increased illegal spoils going into FRB owned and operated circulation. Consequently, the State of Florida failed to prove a prima facie case based on physical (material) evidence of a crime committed, so the Plaintiff’s conviction in case 22-CF-2324-A is VOID, due to both former state attorney Andrew Warren; Susan Lopez; Lynn Goudie; and Mellissa Grajales (court case 22-CF-2324-A) accepting and using only false agent cop testimony on official government forms with official letterheads and seals attached, when there was a bona fide conflict of interest present, for the purpose of injuring the Plaintiff and his wife, for FRB monetary and retaliatory purposes. Testimony evidence might be admissible if from unbiased witnesses, but it’s NOT material evidence of an offence committed! Many corrupt judges use witness testimony wrongly as if material evidence, but it’s not! If there’s no corpus delicti, thus no physical evidence amounting to a violation of statute, then there’s been no crime committed! TALK IS CHEAP LADIES! Witness testimony has wrongly been used by judges and prosecutors for decades to convict innocent parties for the FRB, which employs biased/bribed/extorted witnesses for illegal FRB profits/gains/retaliations! Consumer injuries occurring in both criminal/civil court cases, due to lying public/private, FRB contracted/paid/bribed agent witnesses, results in HUGE increases in consumers’ monetary losses going to the FRB owners, by way of either government agencies/agents; but mostly by vendor agent thieves; or private agent thieves making FRB purchases with consumers’ stolen moneys on FRB goods at 500% to 1000% mark ups. COPS and JUDGES aren’t neutral unbiased witnesses to crimes to be used in place of physical/material evidence when needing to substantiate statute violations! COPS and JUDGES work for, and are contracted/paid/bribed agents of the FRB, a privately owned and operated funding/investing/organization/cartel/enterprise.

85. Witness testimony often fills gaps when physical evidence is unavailable. It provides firsthand accounts that can corroborate or contradict other non-material evidence. However, its reliability is carefully examined, as human testimony can be falsely made on purpose, due to witnesses being paid by the same entities as the ones who benefit from the testimony. Witnesses are excluded from testifying, if there is a conflict of interest to tell the truth because of who they work for, as is the case with expert witness cops (officers of the court). A conflict of interests will disqualify an expert witness from testifying on behalf of a party (State of Florida). If there’s a concern that an expert witness has, or will illegally provide false testimony to financially benefit their employer, the witness will be disqualified. Any expert can have a conflict of interest. Such a conflict may exist, if the expert has been formerly employed by, or previously hired as, an expert for the opposing side. This is the case with judges, cops and attorneys (officers of the court) working for the State of Florida! They’re all employed by FRB owners/controllers through their FRB contracted/paid/bribed/coerced/extorted/agencies/corporations! Consequently, FRB contracted/paid/bribed/extroted cops, attorneys and judges, working together with FRB owners/controllers as a multilevel retaliatory group against blacklisted consumers, implementing RICO predicate acts on them, is called RACKETEERING, which always results in liability through the 4 Doctrines of law cited! Agent caused physical injuries ALWAYS results in consumer monetary losses, ultimately going to the FRB owners who fund/bribe/extort/invest in just about every mixed market business under the sun. And this makes them MAJOR END RECIPIENTS of hot cash flows during illegal commerce based transactions!

86. COT, a municipality, operates under its own local government charter.

87. Sovereign immunity doesn’t apply in this matter to any of the Defendants:

(A). Where there are state and federal operational decisions made as to how policies will be implemented, there’s no governmental sovereign immunity from policy violations! What Jane Castor did through COT/TPD, was adhere to a made up illegal management plan; policy; and operating procedure, while racketeering, which were breaches of state and federal standard mandated ones!

88. Relevant Statements of Fact about the State of Florida (SOF):

89. State of Florida agents A) Andrew Warren; and B) Susan Lopez, wrongly prosecuted the Plaintiff from 3/2022 to 12/2023 in case 22-CF-2324-A, when no crime was committed by anyone except government agents. SOF committed 3 other injuries on the Plaintiff in 2025, but before 8-21-25. These 3 injuries committed in 2025, before 8-21-25, tolls the statute to file on SOF for all the violations committed, by at least another 3 years. And C) Ronald DeSantis from case 25-CA-564 in 5/2025, refused to investigate as his mandatory constitutional duty – – under Florida’s Constitution, Section 6, Article 4: 1) what was on the full Take 5, FHP obtained, murder video of the Plaintiff’s wife; 2) the Plaintiff being exonerated from the false conviction in case 22-CF-2324-A; 3) the Plaintiff having his mother and wife’s murders officially looked into; and 4) the Plaintiff obtaining Mrs. Kimball’s medical records from TGH (again case 25-CA-564). AHCA denied the Plaintiff’s TGH complaint on 7/2025, which requested AHCA to officially order TGH to provide him his wife’s medical records. See Appendix A. To date, the Plaintiff has not obtained these records. Consequently, the Plaintiff is STILL being defrauded by SOF through DeSantis (case 25-CA-564 appealed); AHCA records request denied by ACHA in Appendix A; and FHP not allowing the Plaintiff his wife’s full murder video from case 24-CA-7358, all still denied at the time he files this complaint.

90. This is a lawsuit where the Continuous Tort Doctrine is definitely applicable. The first set of SOF injuries happened in 3/2022 when it through Andrew Warren, wrongly filed the paperwork to prosecute the Plaintiff with nonexistent physical evidence of: 1) neglect and 2) theft violations, filed with his office by DHS through Jane Castor’s local concert (SOF/COT/TPD). Damages from this case lasted until 12/2023 when the Plaintiff was released from jail. The next set of injuries occurred in 5/2025, when SOF through Governor DeSantis, who illegally came into case 25-CA-564 after a default judgment was file on him by the Clerk of the Court of Leon County, requested that Judge Sjostrom illegally dismiss the case to stop the Plaintiff from acquiring more evidence to sue TGH/DHS/COT/SOF; and Jane Castor for any injuries its agents caused him and his wife. Now the Plaintiff can sue TGH for spoliation of evidence in his wife’s aggravated manslaughter (murder).

91. TGH is believed to have intentionally finishing Mrs. Kimball off by committing a breach of its hospital regulatory procedures – – TGH should’ve quickly remove a bone fragment lodged in Mrs. Kimball’s brain. After which ACHA in 7/2025 denied the Plaintiff’s request to order TGH to provide him with his wife’s medical records (Appendix A), wrongly claiming he had supposedly asked ACHA, not TGH, for his wife’s medical records. A total bull chip lie! AHCA doesn’t store medical records from hospitals! The Plaintiff begged ACHA starting in the beginning of 2024 for his wife’s medical records, while Kim Smoak laughed in his ear and then hung up the phone. See Appendix A.

92. SOF was a concert member participant involved with DHS/COT/TPD in this matter, when Jane Castor had authorized the illegal detaining of Mrs. Kimball on 2-23-22, using TPD agent cops. After 3 weeks, Mrs. Kimball was shown the streets by TPD agent cops with nowhere to go and where Attorney Matthew Kimball McDowell found her 3 month later in Pinellas County Florida, living and sleeping on CONCRETE without her medications! If Mrs. Kimball was really SOF’s witness, where was the physical evidence given to them by COT/TPD before or after the Plaintiff’s arrest to prove a crime was committed by him? It certainly wasn’t placed into case file 22-CF-2324-A? If after COT/TPD having given SOF, NO testimony it could use to prosecute the Plaintiff with (no affidavit signed, or audio/video filed in case 22-CF-2324-A, incriminating the Plaintiff in any Florida statute violation), and SOF/COT/TPD/DHS; and Jane Castor knew Mrs. Kimball was disabled and in need of her medications, which her attorney Matthew McDowell provided to her on the streets only once, multiple state and city agents, like Jane Castor; Andrew Warren; Susan Lopez; Lynn Goudie; and Mellissa Grajales, are at least culpably negligent in her aggravated manslaughter (MURDER), by having intentionally violated the survival action statute (F.S. 46.021) by keeping her on the streets, with the false no contact order on her husband, currently still in place!

93. The statute for malicious prosecution is 4 years from the time case 22-CF-2324-A ended under F.S. 95.11. And a complaint for wrongful death, has to be filed 2 years from the date of death. SOF’s second tort committed on the Plaintiff was 5 months before the wrongful death of Mrs. Kimball tolled, which is at the time of the last filed amended complaint. Consequently the defrauding of the Plaintiff by DeSantis in 5/2025; FHP in early 2025; and AHCA in 7/2025, tolls the wrongful death and survival action statutes for suing SOF for another three (3.5) years, with no statute of limitations for crimes committed involving murder under the RICO Act. This gives SOF its 6 months to investigate all the injuries it’s liable for through its agents.

94. Continuous torts – – federal courts have found the statute of limitations must accrue from the date of the last wrongful act where there is another separate wrong committed by the same entity. Leonhard v United States, 633 F. 2d 599, 613 (2d Cir. 1980). Thus, under the continuous violation doctrine, “the limitation period for a continuing offence does not began until the offence, or offences, are completed.” United States v Rivera-Ventura, 72 F. 3d 277, 281 (2d Cir. 1995). The nature of Plaintiff’s claim is such that the 1) continued Fraud on the Court committed by DeSantis; the 2) defrauding of the Plaintiff out of his wife’s medical records by AHCA; and FHP committing a Fraud on the Court to do the Plaintiff out of his wife’s full murder video, all happened in 2025, as well as other facts and information relating thereto, constitutes a continuing tort violation by SOF for at least an addition 3.5 years in both state and federal court. Whether Mrs. Kimball could’ve been saved, had a medical procedure been correctly performed (malpractice), or had the procedure been performed in a timely fashion in accordance with state and federal hospital medical regulations (wrongful death), the wrongful spoliation of records allowed to stand by SOF through AHCA, haven’t been corrected! So the plaintiff is still being injured by SOF. Consequently, SOF is still liable to the Plaintiff for damages resulting from court cases 22-CF-2324-A; 21-CF-006147-A; 24-CA-7358; 25-CA-564; and AHCA – – the Plaintiff was not able to obtain his wife’s medical records to have sued TGH for any particular type of injury within the 2 year statute of limitations. Every time an SOF employee intentionally defrauds the Plaintiff by committing a NEW OFFENCE on him, they monetary injure him, SAVING the FRB moneys due to racketeering. Yes the FRB, because there’s no other reason for FRB contracted/paid/bribed public and private agents intentionally committing frauds on perfect strangers like the Plaintiff and his wife, but to profit their benefactors the FRB!

95. State Attorney Andrew Warren and Susan Lopez illegally prosecuted the Plaintiff with no corpus delicti and no prima facie case made. They had sneaky; obvious; and mean prosecutor Mellissa Grajales; and twisted Judge Goudie, knowingly and intentionally lie for the State of Florida, on record in case 22-CF-2324-A (watch the films in Appendix E), that the Plaintiff had supposedly:

1. Stolen over $50,000 of his wife’s money;

2. Abused his wife by making her relieve herself in a bucket;

3. Didn’t properly care for his wife when she was supposedly disabled under Florida Chapter 825; and

4. The Plaintiff was supposedly his wife’s caregiver, due to a 2012 cancelled guardian advocacy contract, all without producing one bit of physical evidence substantiating these blatant lies!

96. SOF is being sued in state court for dozens of its agents having committed a negligent or intentional tort while acting within the scope of his or her employment, which 1) breached a state government policy (Andrew Warren; Susan Lopez; Lynn Goudie; Mellissa Grajales). And it’s also being sued in federal court, for having 2) implemented a government policy in violation of their duty to the public under the U.S. Constitution. The plaintiff is suing SOF in federal court under, but not limited to the following: 1) Title 28, Chapter 190, Section 5001; 2) (Title 18, Chapter 13, U.S. Codes § 241); 3) Title 42, Chapter 21, Section 1983; and 4) Title 18, Chapter 13, U.S. Code § 241. Punitive damages and attorney’s fees are owed for common law frauds and breaches of fiduciary duties to the public by municipalities. “A public official, acts as trustee for the citizens and the State … and thus owes the normal fiduciary duties of a trustee, e.g., honesty and loyalty to them.” United States v. Kincaid-Chauncey, 556 F. 3d 923, 939 (9th Cir. 2009) (quoting United States v. Silvano, 812 F. 2d 754, 759 (1st Cir. 1987) and United States v. Mandel, 591 F. 2d 1347, 1363 (4th Cir. 1979) (internal quotation marks omitted)).

97. Defendant SOF was working with DHS/COT/TPD; and Jane Castor, through SOF agents Andrew Warren and Susan Lopez, but both of them were adhering to a different set of management plans, polices and operating procedures, a type of racketeering plan for the purpose of injuring the Plaintiff and his wife. So consequently SOF was operating under a different, NON-STANDARD set of operating requirements, due to Jane Castor being technically the director of the local FRB contracted/paid/bribed CONCERT which included Andrew Warren and Susan Lopez.

98. SOF (a municipality) is being sued in state court for its agents/employees (DeSantis; Warren; Lopez; Smoak) having committed culpable and/or intentionally torts while acting within the scope of his or her employment which 1) breached a state government policy. It’s also being sued in federal court for having 2) implemented a state government policy in violation of their duty to the public under the U.S. Constitution – – 1. Title 18, Chapter 13, U.S. Codes § 241; 2. Title 42, Chapter 21, Section 1983; and Title 18, Chapter 13, U.S. Code § 241.

99. Relevant Statements of Fact against Defendant Rothschild:

100. Defendant Rothschild is an FRB owner and controller within the Rothschild & Co. banking cartel, and has been a racketeering participant owner and controller under Title 18, Chapter 96, Sections 1962 (b & d) in this matter, through at least his joint investment ventures with the cartel owners of: JP Morgan Chase & Co., JP Morgan Securities LLC, Chase Manhattan Investment Holdings, LP.; Chase Manhattan BSP Holdings Corp.; Rockefeller Brothers Fund; Rothschild & Co. Continuation Holdings; Rothschild & Co.; State of Florida; and at least shell corporations BlackRock; Vanguard; and State Street. This is because 1) Defendant Rothschild as the CEO of Rothschild & Co. US Inc., personally profits as an owner; controller; and profiteer of the corporations cited above, who has access to some of his family’s assets/resources/holdings/proceeds used for investing in the FRB and FRB commercial subsidiary investment corporations (owned and invested in shell, mergers and acquisitions), and is not a mere shareholder awarded only dividends from any FRB commercial subsidiary investment corporation. Defendant Rothschild funds the FRB through his FRB commercial subsidiary banking investment corporations – – Rothschild & Co., which is funded through its commercial subsidiary investment corporations; and shell corporations, as well as the FRB. Defendant Rothschild is also an owner of some of the Rothschild assets/resources/holdings of the FRB, making up over 40% of the FRB, a private cartel of FRB banking syndicates. Consequently Imputed/Benefactor/AATF Defendant Rothschild, is AS liable to the Plaintiff as the FRB and its agents.

101. Defendant Rothschild through his quasi-government FRB and his FRB commercial subsidiary investment banking corporations, funds and invests in the DHS; SOF; COT; and TPD agencies – – most of the Defendants named in this complaint along with being the benefactor of the presiding judge on this case. Under Section 1962(b) a defendant only has to acquire and interest in, for the control of, an agency or corporation (a public/private business), due to racketeering activities. Davis-Lynch, Inc. v. Moreno, 667 F.3d 539, 550-51 (5th Cir. 2012). And Defendant Rothschild and his family either own or are invested in just about every agency, corporation and agent on the planet!

102. Relevant Statements of Fact against JPMorgan Chase & Co.; Rothschild & Co, and about the Federal Reserve Bank (FRB) and its owners:

103. JPMorgan Chase & Co. agreed to a $92 million settlement with 24 states, including Florida, and the District of Columbia for its alleged role in a nationwide scheme to rig bids and engage in anti-competitive, fraudulent conduct relating to municipal bond derivatives. Florida entities involved in the settlement were: Florida Intergovernmental Finance Commission, Florida Municipal Power Agency, Florida Water Services Corp. Tampa Bay Water Authority, Hillsborough County, Hillsborough County Port District, Florida State Department of Transportation. If there’s moneys being paid out on bond derivatives by a municipal under a FRB banking contract, there’s a thousand other municipals under contract for multiple types of FRB funding and services within the same state, and all of these municipals share hot FRB funds and hot FRB proceeds, thus the term intergovernmental transfers (federal to state; state to local; and local to local/state agencies).

104. Chase; Rothschild and the FRB are liable for all the law violations committed in this matter, using the 4 doctrines of law cited: Vicarious Liability; Imputation; Respondeat Superior; and Continuous Tort; and Section 1349; along with RICO Act violations (predicate acts), when it knowingly and intentionally allowed its contracted/paid/bribed agents to get away with committing them, after being imputed with the knowledge of their agents’ crimes through its agents; and owners/controllers under Section 1962(b & d) – – Imputed John Rockefeller; and Alex Rothschild in 2020 and/or 2025 (Appendix A), yet they only turned a blind eye to them, when they were in a position to take corrective measures. A fraud permitted to stand by an employer, after he or she has knowingly benefited by the fraud, is just as much wrong as an employer knowingly permitting a fraud to be committed by an employee before being benefited. Quick v. Peoples Bank of Cullman Cnty., 993 F. 2d 793, 797 (11th Cir. 1993).

105. This is a RICO case merely because all the Defendants committed racketeering activities which benefited the FRB financially, except for Defendant Dawson. And since this matter involves FRB agents, due to all the Defendants, including Defendant Dawson’s State Farm Insurance Company, being Chase/Rothschild/FRB contracted/paid while they were committing racketeering activities, which profited the FRB owners with their acquired interest in, for control of, the same public/private agencies and corporations involved in this matter, Chase/Rothschild are also being sued for the Plaintiff’s personal injuries sustained, as a result of Chase/Rothschild/FRB agent conversion frauds and tortious interference scams committed by all of the Defendants except Defendant Dawson. There has to be conspiracies to commit RICO predicate acts, with these types of acts having been committed, or there’s no racketeering violation. So the list of racketeering activities committed by Chase/Rothschild/FRB were, and still are, through the same Defendants in this complaint; under the same corresponding Counts; and for committing the same corresponding law violations (allegations). Consequently, Chase/FRB is liable for every injury committed by its contracted/paid agents and owners/controllers (Rockefeller & Rothschild) cited in this complaint.

106. Unfortunately this Court is also a contracted/paid/bribed with his salary and perks FRB agent, who will probably illegally dismiss this complaint with prejudice and be in violation of Fla. Stat. §838.022(a);(b);&(c); 112.3173(e)(6); Sections 1346; 1341; Chapter 817; & 1343; but mainly the RICO Act. The 4 doctrines of law, which give the Plaintiff the same standing to sue the Defendants in this complaint, allows him to also sue Chase/Rothschild/FRB as their BENEFACTOR, due to the Plaintiff having imputed to both John and Alex, the facts of this matter, prior to, and during this state court case (2025). Chase/Rothschild/FRB were directly notified through both John Rockefeller and Alex Rothschild of Chase/Rothschild/FRB agent racketeering activities committed on the Plaintiff and his wife over the past 13 years (see Appendix A). Having done this with the fact the Plaintiff is now having to sue all the owners of Chase through Chase/Rothschild, means John and Alex failed as at least Chase/Rothschild/FRB controllers under Section 1962(b & d), to take corrective measures in stopping the local racketeering still being continuously committed on the Plaintiff and his murdered wife, and paying them restitution. Although any money awarded by a court in this matter will be paid by the Defendants, it’s all being held and used by the FRB owners, but there’s no limit on the amount obtainable from the deep pocketed FRB as an awarded amount.

107. By looking at the facts the Plaintiff imputed directly to John Rockefeller in both 2020 and 2025 (Appendix A), there’s no doubt John was motivated into implementing the Plaintiff’s illegal arrest and his wife’s injuries through Chase/FRB contracted/paid/bribed local government agents, making him the proximate cause of liability for injuries sustained by the Plaintiff and his wife. Alex Rothschild as the current CEO of Rothschild & Co. US Inc. can be readily tied to local agent liability as a CURRENT Chase/Rothschild/FRB benefactor (owner/controller) in this matter, by A) using the 4 doctrines of law cited, along with also B) having been imputed with the facts in this matter (knowledge & intent), thus proving the participating agencies and corporations involved, were contract/paid/bribed through not only Chase/Rothschild/FRB as its funding source, but by Chase/Rothschild commercial subsidiary banking investment corporations, invested in with some assets owned by Defendant Rothschild as a private investment source, with an acquired interest in, for control of, under Section 1962(b & d). So the Plaintiff has tied Chase/Rothschild/FRB contracted/paid agents in this matter to Chase/Rothschild/FRB.

108. Chase/Rothschild/FRB and Chase/Rothschild/FRB commercial subsidiary CONTRACTS with agencies and corporations, are performance driven service contracts for receiving both Chase/Rothschild/FRB funding and Chase/Rothschild commercial subsidiary investment loans with required agency proceeds summited to the Chase/Rothschild commercial subsidiary banks quarterly (Fedwire & Chase/Rothschild commercial subsidiary banks). FRB quasi-government funding (intra & intergovernmental transfers, see Appendix D) flow through the Treasury to agencies to perform daily services, which also routes their municipal proceeds back to pay the Chase/Rothschild commercial subsidiary banking investment corporations, its interest on loans, with defrauded consumers always used as the collateral on both the funding and investing CONTRACTS. These CONTRACTS are for FRB moneys used to pay for, but not limited to, infrastructure costs; law enforcement salaries; judicial salaries; and perk money payments, in return for agent performance, and this is what binds and solidifies FRB contracted/paid agents to Chase/Rothschild owners in a corrupt racketeering banking relationship (Appendix D), even though we don’t know who all the FRB owners are, but under the RICO Act, the private owners of the quasi-government FRB and their mainly Chase/Rothschild commercial subsidiary businesses, which do business with the FRB; agencies; and corporations involved in this matter, are one in the same entity.

109. The FRB may be sued in any appropriate state or district court pursuant to 28 U.S.C. 1338, which means the FRB is a person not a government entity, which grants state and federal courts jurisdiction to hear lawsuits against it, period. So the Plaintiff has standing to sue the FRB owners through Chase/Rothschild, when they knowingly and intentionally funds/invests hot stolen proceeds within all agencies and most major corporations in America, through their quasi-government and commercial subsidiary banking corporations, who’ve acquired an interest in, for the control of, as many public/private businesses as it can within the state of Florida, due to racketeering activities (Title 18, Chapter 96, Sections 1962(b & d). Under the RICO Act, the businesses; the enterprise; and its owners, are one in the same entity. This also means the FRB’s contracted/paid agents’ illegal actions committed while under CONTRACT to perform for the FRB and Chase/Rothschild commercial subsidiary banking investment corporations, by generating hot stolen income for them through conversion and tortious interference scams committed on the Plaintiff, and a million other consumers, allow Chase/Rothschild/FRB be sued by the Plaintiff under the: 1) Respondeat Superior Doctrine; 2) Imputation Doctrine; 3) Vicarious Liability Doctrine; 4) Continuous Tort Doctrine; and 5) Section 1349. The FRB owners/controllers require and achieve production of hot stolen income mainly through their JUDICIAL and POLICING agents operating in courthouses, after official consumer complaints are filed, using bribes (Section 201) and extortion (Section 1951) tactics implemented by governors and federal appointees, as seen in local cases 22-CF-2324-A; 21-CF-006147-A; 25-CA-564; and 24-CA-7358.

110. Chase/Rothschild/FRB uses bribes and extortion methods (the motivational factor behind the predicate acts committed, not an allegation related to any Count yet) on elected officials it helped put in office, for the purpose of maintaining conversion frauds (F.S. 812.014) and tortious interference scams (F.S. 768.72/§§ 95.11(3)(o & p), implemented on consumers to illegally increase FRB owner profits and gains, with FRB owner/controller knowledge and approval through state governors (case 25-CA-564). See Appendix A. Many owners/controllers of the FRB were directly noticed by the Plaintiff in early 2025 of their agents’ scams, but they only turned blind eyes (acquiesced) to taking the proper corrective measures in remedying the wrongs committed by their agents. So now Chase/Rothschild are being sued for their agents’ wrongs committed (Counts). The wrongful conduct by the Chase/Rothschild, acting through its agents, after the fact (AATF) as IMPUTED employers, makes them guilty under Respondeat Superior; Imputation; and Vicarious Liability for the Plaintiff and his wife sustained injuries, as if it they had permitted the frauds beforehand!

111. Chase/Rothschild commercial subsidiary CONTRACTS to perform services for receiving Chase/Rothschild investment moneys with required agency/corporate proceeds summited to them quarterly (Fedwire & Chase/Rothschild commercial subsidiary banks); and 2) the flow of FRB quasi-government funding (intra and intergovernmental transfers, see Appendix D) to agencies to perform daily services, also routes their municipal proceeds back to Chase/Rothschild to pay the interest on their Chase/Rothschild subsidiary loans, with defrauded consumers always used as the collateral on both the investing and funding CONTRACTS. These CONTRACTS are for FRB moneys used to pay for, but not limited to, infrastructure costs; law enforcement salaries; judicial salaries; and perk money payments, in return for agent performance in racketeering activities involving honest services frauds; wire; and mail misrepresentation, committed during cases 22-CF-2324-A; 21-CF-006147-A; 25-CA-564; and 24-CA-7358. These self-renewing agency performance contracts for moneys, are what binds and solidifies Chase/Rothschild/FRB agents to the FRB owners in a corrupt racketeering banking relationship. These contracts are performance based ones with penalties (extortions) for non-production, using consumers as both the collateral on Chase/Rothschild notes and the premiums acquired by fleecing them. Thus Chase/Rothschild/FRB controls the largest resource on the planet, injured for obtaining maximum amounts of profits, and used as the source of surety/collateral by elected agency managers in securing banking contract with Chase/Rothschild commercial subsidiary banks. There isn’t one agency that doesn’t do this! See Appendix D.

112. Thus the Plaintiff has standing to sue any Chase/Rothschild/FRB owners/controllers, at least under Title 18, Chapter 96, Sections 1962(b as controllers & d as conspirators) as an organization/cartel/association-in-fact enterprise.

113. Since the privately owned Chase/Rothschild companies 1) are invested in 95% of all the banks and major conglomerates in America, due to mergers and acquisitions with other cartel members, it basically owns the American economy (see Appendix D), so it’s able to not only obtain a defrauded consumer’s moneys once through thieving vendor agents involved in conversion frauds, but multiple times on the same goods and services needed to be consumer purchased again and again, illegally using its administrative/judicial agents, like banking chairmen and judges, to officially launder the loot home to the FRB owners and their commercial investment corporations. By the FRB owners/controllers sanctioning their contracted/paid agents’ crimes, by turning blind eyes to defrauded consumers’ complaints, consumers have to spend MORE moneys on vendor agent thieves’ goods and services. Consequently, the Rockefellers and Rothschilds, who own the majority of the assets/resources/holdings within the FRB (85%), knowingly and intentionally acquire consumers’ hot stolen moneys through their mixed market, investment corporations, invested in by other cartel members 95% of the time, for increased repetitive use of consumers’ stolen and owed moneys, which are vendor and private agent thieve deposited immediately as seen on ledger sheet transfers into FRB commercial subsidiary banks within merchant accounts. VERY SLICK!

114. Relevant Statements of Fact against Defendant Crist:

115. Defendant Crist is the Clerk of the Court and Comptroller for the 13^th Judicial Circuit and is paid by Hillsborough County authorized by its BOCC, a public agency contracted and paid for by the FRB Cartel and FRB commercial subsidiary investment banking corporations.

116. Case 25-CA-8096 was filed on the FRB parent corporation, through its agent branch in San Francisco, CA., not on this branch, and Defendant Crist and his agents knew this, yet the style of the case in Fisher & Phillip LLP was wrong. Kathleen Rocamora at 813-460-6710, was involved in this murder cover-up of Mrs. Kimball, and the cover-up of the intentional torts sanctioned by Defendant Crist, when she falsely told the Plaintiff that Judge Barber had case 25-CA-8096 removed from state court and that the federal case was already open! This can’t legally happen.

117. The FRB had its local paid attorneys at Fisher & Phillips, LLP, illegally demand the Clerk of the Court, Defendant Crist and his agents there, to illegally transfer case 25-CA-8096 to the Middle District of Florida immediately and without a hearing! Had a hearing been scheduled, but after all parties were served, the Plaintiff would’ve told Judge Nash that he was already suing four (4) parties from case 15-CA-8096, in the middle district, case 25-CV-2181, and would’ve gladly dropped the FRB from the state case due to 12 USC Statute 632.

118.1 In mid-11/2025, Defendant Crist’s office was contacted at 813-307-7027 (Amy) a dozen times by the Plaintiff with messages left a week before the his state case was illegally dismissed in case 25-CV-3077, but prior to this, Crist intentionally never had the Plaintiff’s case file transferred back to state court, ignoring his phone calls.

118.2 Defendant Crist committed intentional torts on the Plaintiff through his agents working at the 13^th Judicial Circuit in 11/2025. This complaint is against Defendant Crist, not the local state courthouse or its employees.

***118.5 State courts must entertain federal claims, but not for the purpose of enforcing them, as if the state court was to be treated as a Federal court. Consequently all statute violations are cited, but the Defendant only have to answer to their state violations.

119. Counts; with elements of; and statute violations for Defendant Rothschild:

120. Plaintiff repeats and realleges the allegations and legal precedence set forth in paragraphs 1 through 42; 63 through 87; 88 through 98; 99 through 101; and 113 through 118 as if fully set forth herein, and Defendant Rothschild being the proximate cause thereof.

The Plaintiff is seeking compensation (relief) from the Defendant Rothschild, due to being Mrs. Kimball’s spouse and under Law of Agency; Imputation; Respondeat Superior; and Vicarious Liability Doctrines; and for being the defendant in bogus case 22-CF-2324-A:

The criminal/civil wrongs Defendant Rothschild is liable for during FRB contracted/paid Mark Braswell’s unwarranted and illegal participation in this matter as an DHS agent, acting through FRB contracted/paid local agents Jane Castor and her local concert (SOF; COT; TPD) (Appendix B), to intentionally injured the Plaintiff and his wife physically; emotionally; and monetarily when no crime was committed in case 22-CF-2324-A, are reasonably proven probable (sum sufficient) in the Appendices:

Count 1: Participation of Defendant Rothschild as an owner/controller/racketeer of DHS; and Jane Castor’s local concert, including Defendant Crist, under Title 18, Chapter 96, Sections 1962(b & d) – – FRB owner/controller level position – – against Rothschild;

121. Imputed/Benefactor/AATF Rothschild, through his FRB and FRB commercial subsidiary investment banking corporations, was a racketeering AATF in concert with DHS; Jane Castor; SOF; COT; TPD; and Crist, to illegally injure both the Plaintiff and his wife physically, emotionally and monetarily, violations under the RICO Act under, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Section 1346; 1341; 1343; 1513 and Chapter 817, when no crime was committed in case 22-CF-2324-A – – against Rothschild;

Count 2: Wrongful Death (768.16), due to Imputed/Benefactor/AATF Rothschild, through SOF’s prosecution of the Plaintiff, with Jane Castor; and DHS/COT/TPD agents having relocated Mrs. Kimball to the streets of Clearwater; Tampa; and Brandon, Florida, telling her each time not to go home, which lasted for 1.5 years until her murder, due to an illegal no contact order on her husband, required in abuse cases, with no one removing this false order still in place, when the Plaintiff had asked his attorneys to do so, along with Mrs. Kimball having asked Matthew McDowell, Esq. to do so (due diligence). Matthew McDowell was the one who wrote Mrs. Kimball’s affidavits for her to sign, and had them to file, but never submitted them with a hearing request (Appendix A); but mainly due to FRB contracted/paid Jane Castor; and COT being a joint and several liability partner in intentional frauds committed with SOF; and DHS on the Plaintiff and his wife – – against Rothschild;

122. Defendant Rothschild’s liable as the proximate cause of his contracted/paid local; state; and federal agents working in concert, initiating the illegal searches; arrests; prosecution; process; murder; and survival action damages committed in this matter, under the Law of Agency; the Imputation; Respondeat Superior; and Vicarious Liability Doctrines; and when no crime was committed in case 22-CF-2324-A;

Count 3: Wrongful Death Damages (768.21) are owed, due to Mrs. Kimball being forced off her medications and made to live on the streets by imputed/benefactor/AATF Rothschild’s contracted/paid DHS/SOF/COT/TPD agents all working in concert, who told Mrs. Kimball she couldn’t go home from 2/2022 to 8-19-23, because of the false no contact order on her husband, when no crime was committed in case 22-CF-2324-A – – against Rothschild;

123. Imputed/Benefactor/AATF Rothschild, through his FRB and FRB commercial subsidiary investment banking corporations, is liable as the proximate cause in all of the damages to the Plaintiff and his wife through his contracted/paid DHS/SOF/COT/TPD agents, by way of the Law of Agency; Imputation; Respondeat Superior; and Vicarious Liability Doctrines; and when no crime was committed in case 22-CF-2324-A;

Count 4: Survival Action for 1.5 years (46.021), due to Mrs. Kimball being forced off her medications and made to live on the streets by FRB contracted/paid DHS/SOF/COT/TPD agents who told Mrs. Kimball from 2/2022 to 8-19-23, not to go home because of the illegal no contact order on her husband, when all FRB contracted/paid agents knew no crime was committed in case 22-CF-2324-A – – against Rothschild;

124. Imputed/Benefactor/AATF Defendant Rothschild, through his FRB and FRB commercial subsidiary investment banking corporations, is liable for any pain; and suffering, initiated through his contracted/paid agents working at the DHS/COT/TPD/SOF, who made Mrs. Kimball wrongly live on the streets, due to an illegal no contact order on her husband, not on her;

125. And Mrs. Kimball, due to the no contact order being ONLY on her husband, was legally allowed to continue living at home, when the Plaintiff was the sole owner of the property and technically didn’t have to leave;

Count 5: F.S. 782.07(1) (aggravated manslaughter) violation by Rothschild through his FRB and FRB commercial subsidiary investment banking corporations, financially supported, and still is supporting, Jane Castor; and her local concert of DHS/SOF/COT/TPD agents, who knowingly and intentionally kept Mrs. Kimball in need of the bare necessities in order to survive, on the streets of Clearwater, then again in Tampa, then again in Brandon, for SOF to continue wrongly prosecuting the Plaintiff for violations of probation, when Mrs. Kimball would keep legally returning to her house, turning a blind eyes to her suffering from 2-22 to 8/23, when it knew no crime was committed in case 22-CF-2324-A – – against Rothschild;

126. Imputed/Benefactor/AATF Rothschild, through his FRB and FRB commercial subsidiary investment banking corporations, is the proximate cause of at least the capable negligence/aggravated manslaughter committed on Mrs. Kimball through his local contracted/paid concert – – DHS; Jane Castor; COT; SOF; and TPD, when no crime was committed in case 22-CF-2324-A; and due to the Law of Agency; Imputation; Respondeat Superior; and Vicarious Liability Doctrines;

Count 6: Imputed/Benefactor/AATF Rothschild, is liable for the Plaintiff’s False Imprisonment for 225 Days, a violation under Florida Statute 787.02, due to Defendant Rothschild being a participant in this matter through his FRB and FRB commercial subsidiary investment banking corporations, when his contracted/paid DHS/SOF/COT/TPD agents, kept the Plaintiff in jail for 225 days, a violation under Florida Statute 787.02, not limited to, RICO Act violations – – Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Section 1346; 1341; 1343; 1513; and Chapter 817, when no crime was committed in case 22-CF-2324-A – – against Rothschild;

127. Imputed/Benefactor/AATF Defendant Rothschild, through his FRB and FRB commercial subsidiary investment banking corporations, is the proximate cause of the Plaintiff’s three (3) False Imprisonments during case 22-CF-2324-A, initiated by Rothschild’s contracted/paid agents at the DHS/SOF/COT, starting in 2/2022 and ending in 12/2023, RICO Act violations – – Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Section 1346; 1341; 1343; 1513; and Chapter 817, when no crime was committed in case 22-CF-2324-A, making Rothschild as liable as his local contracted/paid agents, due to the Law of Agency; Imputation; Respondeat Superior; and Vicarious Liability Doctrines; and when no crime was committed in case 22-CF-2324-A;

Count 7: Malicious Prosecution was committed by imputed benefactor AATF Rothschild, when he participated with DHS; Jane Castor; and her local concert (SOF/COT/TPD), by financially supporting all of them, through his FRB and FRB commercial subsidiary investment banking corporations, for the improper purpose of illegally prosecuting the Plaintiff, violations of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Section 1346; 1341; 1343; Title 18, Chapter 73, Sections 1513(e & f); and Chapter 817, when no crime was committed in case 22-CF-2324-A – – against Rothschild;

128. Imputed/Benefactor/AATF Defendant Rothschild, through his FRB and FRB commercial subsidiary investment banking corporations, is the proximate cause of the Plaintiff’s Malicious Prosecution during case 22-CF-2324-A, initiated by Rothschild’s contracted/paid/bribed agents at the DHS/SOF/COT, making Rothschild as liable as his local contracted/paid agents, due to the Law of Agency; Imputation; Respondeat Superior; and Vicarious Liability Doctrines, intentional violations of the RICO Act under, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Section 1346; 1341; 1343; 1513; and Chapter 817, when no crime was committed in case 22-CF-2324-A;

Count 8: Abuse of Process was committed by imputed benefactor AATF Rothschild, when he participated with Jane Castor’s local concert, by financially supporting her concert, through his FRB and FRB commercial subsidiary investment banking corporations, for the improper use of the court system to injure the Plaintiff and his wife physically; emotionally; and monetarily, violations under Title 18, Chapter 73, Sections 1513(e & f). Rothschild was a RICO Act AATF participant with Jane Castor’s local concert (DHS/SOF/COT/TPD), committing violations of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Section 1346; 1341; 1343; and Chapter 817, when no crime was committed in case 22-CF-2324-A – – against Rothschild;

129. Imputed/Benefactor/AATF Rothschild’s liable as the proximate cause of the abuse of process committed on the plaintiff during court case 22-CF-2324-A, by way of the Law of Agency; Imputation; Respondeat Superior; and Vicarious Liability Doctrines; and when no crime was committed in case 22-CF-2324-A;

Count 9: Fraud on the Court (F.S. 1540) was committed in court cases 24-CA-7358 22-CF-2324-A; 21-CF-006147-A; 25-CA-564; and 24-CA-7358, by Rothschild’s contracted/paid local agents, making him the proximate cause of these violations as an Imputed AATF with Jane Castor; COT; SOF; TPD; and DHS – – against Rothschild;

130. Imputed benefactor Rothschild, was a participant AATF with Jane Castor’s FRB contracted/paid local concert, by financially supporting this concert, through his FRB and FRB commercial subsidiary investment banking corporations, for the purpose of illegally prosecuting the Plaintiff, when Judge Goudie defrauded him herself, and allowed SOF to do the same in her kangaroo court, as if deaf, dumb and blind, when no crime was committed in case 22-CF-2324-A;

Count 10: Title 18, Chapter 73, Section 1513, an FRB retaliation crime implemented by Imputed/Benefactor/AATF Rothschild, through his FRB contracted/paid local concert (DHS/SOF/COT/TPD; and Jane Castor), a Rothschild FRB and FRB commercial subsidiary investment banking supported concert, against witnesses (Plaintiff & his wife) – – against Rothschild;

131. Imputed AATF Rothschild’s liable as the proximate cause of DHS; SOF; TPD; COT; and Jane Castor working in concert to retaliate in violation of Section 1513 above, because he knowingly and intentionally financed this concert, through his FRB and FRB commercial subsidiary investment banking corporations, when it injured the Plaintiff and his wife physically; emotionally; and monetarily, violations of the RICO Act under, but not limited to, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Section 1346; 1341; 1343; 1513; and Chapter 817, when no crime was committed in case 22-CF-2324-A. Defendant Rothschild was knowingly a funding and investing source for John Rockefeller’s retaliation plan, after the Plaintiff threatened to sue the FRB through John in 2020, for obtaining the Plaintiff’s laundered inheritance around 2000;

Count 11: Imputed AATF Rothschild, has standing to be sued on all Counts, just like any other FRB owner who was an Imputed AATF accomplice, in his or her contracted/paid agents’ perpetrated wrongs, due to the Law of Agency; Vicarious Liability; Imputation; and Respondeat Superior Doctrines of Law – – against Rothschild;

132. Imputed benefactor AATF Rothschild’s liable as the proximate cause of his agents’ wrongful actions, which caused the Plaintiff and his wife damages, due to Vicarious Liability; Imputation; and Respondeat Superior Doctines; and the Law of Agency;

Count 12: Fla. Stat. §838.022(a);(b);&(c); §112.3173(e)(6); & Section 1346 (private and public scams to defraud Plaintiff and his wife out of honest services, by imputed AATF benefactor Rothschild, working through his contracted/paid agent Ronald DeSantis, a Rothschild FRB and FRB commercial subsidiary bank funded, and invested in, agent, who unethically turns a blind eye to John Couris at TGH and state courthouse judges, who commit honest services frauds before and after he pays them with Defendant Rothschild’s moneys, some of whom presided on cases 24-CA-7358 22-CF-2324-A; 21-CF-006147-A; 25-CA-564; and 24-CA-7358 – – against Rothschild;

133. Imputed AATF benefactor Rothschild’s in violation of both state and federal honest services frauds – – 838.022(a);(b);&(c); 112.3173(e)(6); & federal Section 1346), committed through his local contracted/paid agents at the DHS; COT; SOF; TPD; and TGH, directly and indirectly paid by Defendant Rothschild through his FRB and FRB commercial subsidiary investment banking corporations, most of the time using his contracted/paid State of Florida agent Ronald DeSantis, from 2-22 to present.

Count 13: Title 18, Chapter 63, Section 1349 (attempt and conspiracy) – – against Rothschild;

134. Imputed/Benefactor/AATF Rothschild’s liable for the false search warrant; false imprisonment; malicious prosecution; abuse of process; wrongful death; and survival action for 1.5 years, which damaged the Plaintiff and his wife physically; emotionally; and monetarily, committed by DHS; COT; TPD; SOF; and Jane Castor during court case 22-CF-2324-A, when no crime was committed;

Count 14: Title 18, Chapter 13, U.S. Codes § 241, conspiracy against the rights of the Plaintiff and his wife – – against Rothschild;

135. Imputed/Benefactor/AATF Rothschild’s liable for the false search warrant; false imprisonment; malicious prosecution; abuse of process; wrongful death; and survival action for 1.5 years, which damaged the Plaintiff and his wife physically; emotionally; and monetarily, committed by DHS; COT; TPD; SOF; and Jane Castor during court case 22-CF-2324-A, when no crime was committed;

Count 15: Title 42, Chapter 21, Section 1983, assisting in wrongs committed by any government agency or agent – – against Rothschild;

136. Imputed/Benefactor/AATF Rothschild’s liable for the false search warrant; false imprisonment; malicious prosecution; abuse of process; wrongful death; and survival action for 1.5 years, which damaged the Plaintiff and his wife physically; emotionally; and monetarily, committed by DHS; COT; TPD; SOF; and Jane Castor during court case 22-CF-2324-A, when no crime was committed.

Count 16: Imputed/Benefactor/AATF Rothschild’s liable for the theft; conversion; and destruction of the Plaintiff and his wife’s properties within their house, committed by both TPD and SOF, due to no legitimate search warrant and no material evidence of a crime committed in case 22-CF-2324-A, violations under F.S. 771.11(1) & 812.014, compensation now owed to the Plaintiff – – 100% on $60,000. USD, before and during case 22-CF-2324-A (crimes committed on both 2-24-22 & 7-26-23) – – against Rothschild;

137. Imputed/Benefactor/AATF Rothschild’s contracted/paid local agents committed theft; conversion; and destruction of Plaintiff and his wife’s properties within their house, which he is now liable for;

Count 17: Spoliation of Mrs. Kimball’s TGH medical records under FloridaRCP 1.380(b)(2)F), by Rothschild’s funded/invested in local private agent John Couris – – against Rothschild;

138. Imputed/Benefactor/AATF Rothschild’s liable for Mrs. Kimball’s injuries as if he had caused them before her accident on 8-19-23, by HIS TGH funded/invested in private agent, John Couris, having spoliated Mrs. Kimball’s medical record evidence through TGH, to hide the proximate cause of her death, stopping Rothschild from having to reimburse TGH;

Count 18: Florida Chapter 843, Obstructing Justice 843.14, Compounding Felony violation – – against Rothschild;

139. Imputed/Benefactor/AATF Rothschild’s liable for knowingly and intentionally committing a criminal violation of obstructing justice, when he through his contracted/paid local agents at TGH, concealed Mrs. Kimball’s medical records, because she was in fact murdered;

Count 19: Fraud on the Court violation in case 24-CA-7358 (F.S. 1540) – – against Rothschild;

140. Imputed/Benefactor/AATF Rothschild’s liable for knowingly and intentionally through his contracted/paid agents John Couris and Ronald DeSantis, having committed Frauds on the Court in cases 24-CA-7358 and 25-CA-7358, when they stated that the Plaintiff wasn’t married to Mrs. Kimball.

Count 20: 4th amendment right violations – – against Rothschild;

141. Defendant Rothschild through his contracted/paid DHS/COT/SOF/TPD agents violated the Plaintiff and his wife’s rights to not have their house searched; property stolen; converted; and damaged during 3 illegal TPD searches; and a fourth (4) illegal one by federal marshals after Judge Lynn Goudie issued a false warrant for the Plaintiff’s arrest, because he supposedly knew his wife was around the corner at the northern intersection from his home address, when he was driving his car down his block. Marshals used his illegally obtained house keys from within his pocket for 45 minutes, to go to his house and search it, permanently keeping his wallet with its full contents, possibly for SOF/COT/TPD to go through, but it was never to be seen by the Plaintiff again;

142. Due Defendant Rothschild through his contracted/paid agents at the SOF/COT/TPD, an illegal concert, the Plaintiff was illegally arrested on: 2-24-22; and again by federal marshals on the street a few months later, complements of criminal minded Lynn Goudie; and a third time on 7-26-23;

143. Defendant Rothschild thorough his contracted/paid agents at the SOF/COT/TPD, illegally imprisoned the Plaintiff for 225 days in total;

144. Defendant Rothschild through his contracted/paid agents at the DHS/SOF/COT/TPD, and illegal concert, illegally removed Mrs. Kimball from her home, or made her leave it, each time they found her at home, keeping her on the streets to be foreseeably injured or killed.

Relief sought:

145. Money amounts the Plaintiff is seeking from Defendant Rothschild in this complaint for personal injuries:

A. Economic damages amount to roughly $400,000. USD for Mrs. Kimball’s lost SSI income from age 41 to 75 (34 years’ worth);

B. about $1,050. USD for the Plaintiff being extorted into paying the court costs on bogus case 22-CF-2324-A;

C. $60,000. USD for Rothschild, through DHS; COT/TPD; and Jane Castor, stealing and damaging $20,000. USD of the Plaintiff and his wife’s properties within their home, during two (2) illegal TPD searches, implemented on 2-24-22 and 7-26-23, violations under F.S. §772.11 (1), 5 years statute of limitations, see court documents Appendix B. This Defendant has now been given 30 days to pay the Plaintiff $60,000. USD. (Appendix B & court case 22-CF-2324-A) (Attorney Joseph Davis, the Plaintiff’s former attorney, is a witness to the thefts and damages);

D. Rothschild through TPD’s illegal search of Plaintiff’s house on 7-26-23, due to no search warrant, cost him $3,500. USD in legal fees from Attorney Joseph Davis; and

E. the Plaintiff’s punitive and non-economic amounts for his own personal pain and suffering, along with Mrs. Kimball’s personal injury – – 1.5 years’ of being made to survive on the streets, all non-economic/punitive, intentional/culpable, torts/scams, committed by Rothschild’s contracted/paid agents, total well over $60. Million USD, by referencing verdicts on similar federal and state violations.

146. Counts; with elements of; and statute violations for Defendant Crist:

147. Plaintiff repeats and realleges the allegations and legal precedence set forth in paragraphs 1 through 42; 63 through 87; and 113 through 118, as if fully set forth herein:

The Plaintiff is seeking compensation (relief) from the Defendant Crist, due to being Mrs. Kimball’s spouse and under Law of Agency; Imputation; Respondeat Superior; and Vicarious Liability Doctrines; for being the defendant in bogus case 22-CF-2324-A; and the Plaintiff in case 25-CA-8096:

The criminal/civil wrongs Defendant Crist is liable for during case 25-CA-8096, were intentional torts to injure (see Appendix E).

FRB contracted/paid Victor Crist’s unwarranted and illegal participation in this matter, acting through his FRB contracted/paid local courthouse agents to intentionally injure the Plaintiff emotionally; and monetarily when no crime was committed in case 22-CF-2324-A, are reasonably proven probable (sum sufficient) in the Appendices:

Count 1: Defendant Crist was a managing participant under Title 18, Chapter 96, Sections 1962(c & d), which makes him liable for damages under the Law of agency; Imputation; Respondeat Superior; and Vicarious Liability Doctrines – – against Crist;

148. Crist racketeered in concert with Jane Castor’s concert and with his own immediate agents at the state courthouse, in violation of the Law of Agency; Imputation; Repondeat Superior; and Vicarious Liability Doctrines, by illegally allowing the transfer of the Plaintiff’s state case to the federal courthouse so it could be illegally dismissed under federal common laws, when it was a state case governed by state common laws (shotgun pleading laws don’t apply in state court).

Count 2: Fraud on the Court (F.S. 1540 and Rule 60(b) in federal court) in court cases 25-CV-3077 was assisted by Crist, due to being a participant under the RICO Act with Judge Barber and the FRB, violations of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; and Title 18, Chapter 73, Sections 1513(e & f), when no court order was submitted by Judge Nash with a required hearing in case 25-CA-8096 for it to be transferred by the Clerk of the Court – – against Crist;

149. Crist was a concert member involved in the illegal transfer of the Plaintiff state case, acting as a racketeering participant under the RICO Act, violations of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; and Title 18, Chapter 73, Sections 1513(e & f), when no crime was committed in case 22-CF-2324-A – – against COT;

Count 3: Title 18, Chapter 73, Section 1513, an FRB retaliation crime initiated through Defendant Crist by Fisher & Phillips – – against Crist;

150. Crist was working in concert with the law firm of Fisher & Phillips, LLP; hired by the FRB, to commit retaliatory acts for the purpose of emotional; and monetary injuring the Plaintiff, committed in violation of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; and Title 18, Chapter 73, Sections 1513(e & f), as an accessory after the fact (AATF) with Jane Castor’s local concert, having committed racketeering during case 22-CF-2324-A, implemented by the John Rockefeller and his think tank, after the Plaintiff threatened to sue the FRB through John in 2020 for obtaining his laundered inheritance beginning around 2000;

Count 4: Crist has standing to be sued for agent perpetrated wrongs on all his Courts cited in this Count section, due to the Law of Agency; Vicarious Liability; Imputation; and Respondeat Superior Doctrines – – against Crist;

151. Crist is liable for any of its employees’ wrongful actions and omissions which caused the Plaintiff damages, due to Vicarious Liability; Imputation; Respondeat Superior Doctrines and the Law of Agency;

Count 5: Fla. Stat. §838.022(a);(b);&(c); §112.3173(e)(6); Section 1346; and Sections 1341; 1343; and Chapter 817 – – private and public scams to defraud Plaintiff and his wife out of honest services, implemented by the FRB, and initiated through the law firm of Fisher & Phillips, using the Clerk of the Court during cases 25-CA-8096 and 25-CV-3077 – – against Crist;

152. Crist is in violation of both state and federal honest services, committed by any and all of his employees during cases 25-CA-8096 and 25-CV-3077, starting in 11/2025, due to him being a racketeering participant under the RICO Act, violations of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; Title 18, Chapter 73, Sections 1513(e & f); and Chapter 817, when there was no court order to transfer state case 25-CA-8096 anywhere;

Count 6: Title 18, Chapter 63, Section 1349 (attempt and conspiracy) – – against Crist;

153. Crist is liable for the false transfer of case 25-CA-8096 to federal court, when he knew no official judicial court order was issued to do so by state judge Nash;

Count 7: Title 18, Chapter 13, U.S. Codes § 241, conspiracy against the rights of the Plaintiff and his wife – – against Crist;

154. Crist is liable for the false transfer of case 25-CA-8096 to federal court, when he knew no official judicial court order was issued to do so by state judge Nash;

Count 8: Title 42, Chapter 21, Section 1983, assisting in wrongs committed by any government agency or agent – – against Crist;

155. Crist is liable for the false transfer of case 25-CA-8096 to federal court, when he knew no official judicial court order was issued to do so by state judge Nash;

Count 9: 5th amendment right violations for illegally acting as a judge in place of Judge Nash – – against Crist;

156. Crist is liable for the false transfer of case 25-CA-8096 to federal court, case 25-CV-3077, so this case could be illegally dismissed there using an inappropriate case law, currently being used on the Plaintiff in federal case 25-CV-2181 (appealed), without the proper jurisdiction (4 Defendant already were being sued there under the same Counts), when he knew no official judicial court order was issued to do so by state judge Nash in case 25-CA-8096;

Count 10: Tortious Interference under F.S. 768.72/§§ 95.11(3)(o & p) – – against Crist;

157. 1) Crist is liable for any intentional or culpable acts or omissions, which caused injuries to the Plaintiff, when he acted as an accessory after the fact (AATF) in covering up Mrs. Kimball’s murder, by aiding and abetting both the FRB and their paid local law firm, Fisher & Phillips LLP, in spoliating critical evidence of her murder, a culpable or intentional tort, and costing the Plaintiff additional time and moneys;

158. 2) Crist is liable as an accessory after the fact (AATF) in at least the aggravated manslaughter of Mrs. Kimball, for aiding and abetting as an AATF, in concealing medical record evidence in cases 25-CA-8096, by violating Sections 1341; 1343; 1346; Chapter 817; and Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6) – – mail; wire; and honest services frauds as an accomplice with the judge in case 25-CV-3077;

159. 3) The FRB and their hired law firm Fisher & Phillips working through Crist, were participants under Title 18, Chapter 96, Sections 1962(c & d) under the RICO Act;

160. 4) Crist was working in concert as an FRB contracted/paid member in an association-in-fact enterprise, during cases 25-CV-8096 and 25-CV-3077 which lasted a day, as an unwelcomed intruder to these cases, aiding and abetting in concealing evidence of Mrs. Kimball’s murder by either Defendant Dawson and/or TGH;

Count 11: 14th amendment right violation – – Crist is liable for violating the Plaintiff’s 14th amendment rights, due to having managed the illegal transfer of case 25-CA-8096 to case 25-CV-3077, from inside the 13^th Judicial Circuit – – against Crist;

161. Crist violated the Plaintiff and his wife’s 14^th amendment rights, to both substantive and procedural due process rights in case 25-CA-8096, illegally transferring this case out of the courthouse, when he knew no official judicial court order was issued to do so by state judge Nash;

Count 12: Honest Services Fraud violations – – Crist committed honest services frauds under Fla. Stat. §838.022(a);(b);&(c); 112.3173(e)(6); and federal Sections 1341; 1343; 1346; and Chapter 817, during case 25-CA-8096, a public scams to defraud Plaintiff out of honest services directly at the local courthouse – – against Crist;

162. Crist committed state and federal honest services frauds violations in cases 25-CA-8096 and 25-CV-3077, by misrepresenting to the through his agents, that either the Federal courthouse or the law firm Fisher & Phillips LLP, was to blame for the false transfer of case 25-CA-8096 to federal court, when he knew no official judicial court order was issued to do so by state judge Nash;

Count 13: Florida Chapter 843, Obstructing Justice 843.14, Compounding Felony violation – – against Crist;

163. Crist knowingly and intentionally committed a criminal violation of obstructing justice when he illegally transferred case to conceal Mrs. Kimball’s medical records to benefit TGH; and its funding and investing sources – – the State of Florida and the FRB, because she was in fact murdered, which involved FRB contracted/paid government agents and the FRB;

Count 14: Title 42, Chapter 21, Section 1983 violations – – against Crist;

164. Crist an public FRB contracted/paid agent, worked with FRB contracted/paid private agent Fisher & Phillips LLP in the false transfer of the Plaintiff’s state case (25-CA-8096) to federal court, an intentional tort to emotionally and monetarily injure the Plaintiff, when he knew no official judicial court order was issued to do so by state judge Nash;

Count 15: Spoliation of medical and video records under Florida RCP 1.380(b)(2)F) – – against Crist;

165. Crist is liable for all of Mrs. Kimball’s injuries as if he caused them, by being an accessory after the fact in spoliating both her murder video (SOF) and medical record evidence (TGH), as to who was involved, and how exactly her death was caused.

Relief sought:

166. Money amounts the Plaintiff’s seeking from Defendant Crist in this complaint for personal injuries:

A. Any Economic damage amounts lost during this new case filed in state court a SECOND TIMEWITHOUT Judge Nash – – roughly $400,000. USD for Mrs. Kimball’s lost SSI income from age 41 to 75 (34 years’ worth);

B. 50% shared expense by SOF; and TPD, in $60,000. USD owed, for TPD stealing and damaging $20,000. USD of the Plaintiff and his wife’s properties within their home, during two (2) illegal TPD searches, implemented on 2-24-22 & 7-26-23, violations under F.S. §772.11 (1), 5 year statute of limitations, see court documents Appendix B. COT has now been given 30 days to pay the Plaintiff $30,000. USD. (Appendix B & court case 22-CF-2324-A) (Attorney Joseph Davis, the Plaintiff’s former attorney, is a witness to the thefts and damages);

C. 100% in TPD’s illegal search of Plaintiff’s house on 7-26-23, due to no search warrant while still being illegally prosecuted by SOF up until 12/2023, costing him $3,500. USD in legal fees from Attorney Joseph Davis – – so $1,750 USD is the amount both SOF and COT owe the Plaintiff;

D. the Plaintiff’s punitive and non-economic amounts for his own personal pain and suffering, along with Mrs. Kimball’s personal injury – – 1.5 years’ of being made to survive on the streets by FRB/DHS/SOF/COT/TPD; and Jane Castor, all non-economic/punitive, intentional/culpable, torts/scams, all committed by FRB contracted/paid agents, total well over $60. million USD, by referencing verdicts on similar federal and state violations.

167. Elements of the Causes of Action – – statutory or duty of care violations:

168. All of the Defendants had a direct, or indirect duty through their contracted/paid agents, not to breach multiple state and federal statutes either capably, but mainly intentionally, injuring the Plaintiff and his wife, compensation now owed to them.

169. Prayer for Relief:

170. The relief sought from all of the Defendants is punitive with compensatory, due to being the defendant in cases 22-CF-2324-A; 25-CA-8096; and 25-CV-3077 with attorney’s fee and costs when applicable.

171. Expedited Trial by Jury is asked for.

Affidavit of Verification:

STATE OF FLORIDA, COUNTY OF HILLSBOROUGH

I, Darryl Schneider, being duly sworn, deposes and say: I the Plaintiff in the above entitled action, have read the foregoing petition and know the contents of it, and say that to the best of my knowledge, its “contents” ARE TRUE and CORRECT.

______________________________________Signature

Subscribed and sworn before me on _____________________to certify which witness signed by my hand and official seal. Driver License# ______________________________________

__________________________________________Name

______________________________________Signature

___________________________Notary Public State of Florida Seal

Certificate of Service:

I HEREBY CERTIFY that a true and correct copy of the foregoing was placed into the case file with notification to each Defendant.

Darryl Schneider Plaintiff

_________________________

Signature

10406 N 26 Street

Tampa, FL 33612

813-585-0552

Adverse Parties:

1. Alex Rothschild

c/o Rothschild & Co. US Inc.

33 Floor

1251 Avenue of the Americas

New York, NY 10020

USA

212-403-3500

2. Victor Crist

7126 Wareham Drive

Tampa, FL 33647

JP Morgan Chase & Co.

270 Park Avenue

New York City, NY 10017

c/o

CT Corporation System

28 Liberty Street

42nd Floor

New York, NY 10005

Circuit Civil Division of The

13th Judicial Circuit, Tampa,

Florida

Appendix A: Cases 25-CA-564 & 24-CA-7358

Appendix B: Cases 22-CF-2324-A & 21-CF-006147-A

Appendix C: Competency Evaluation

Appendix D: FRB Investments

Appendix E: Films

Appendix F: NCUA & TBFCU

Appendix G: Common Laws

Appendix E: Fraudulent Transfer of Case 25-CA-8096

In The 13th Judicial Circuit

Tampa, Florida Division

1. Darryl Schneider

Plaintiff

Case 25-CA-11800

1. David Dawson II, Et. Al

Sued as an Individual

2. Tampa General Hospital (TGH)

3. City of Tampa (COT)

4. State of Florida (SOF)

Defendants

___________________________/

Complaint

1. Main Introduction:

Every statement in this complaint is unambiguous, and not only sum sufficiently believable to a reasonably prudent person on its face (“four corners” rule), but clearly proven as seen by reviewing the appendices. Any arguments pled in writing by any officer of the court, including the judge, NOT based on material evidence submitted, and used as a false means to dismiss this case, is an attempt to violate Title 18, Chapter 83, Section 1346; F.S. 838.022(a);(b);&(c); and 112.3173(e)(6) (honest services fraud). All the statements made in this complaint are relevant facts, written as SHORT AS POSSIBLE WITHOUT ARGUMENT, when there were rather large numbers of FRB contracted/paid retaliatory agents, relentlessly out to injure both the Plaintiff and his wife!

2. All of the Defendants cited in this complaint, have sum sufficiently been proven guilty of having capably or intentionally participated in specific violations of either the: 1) RICO Act; 2) constitutional amendment rights; 3) state and federal statutes; 4) duty to render aid; or 4) state and federal common laws, which resulted in Mrs. Kimball’s death, either as an intentional or culpable tort (murder under F.S. 782.04(1)(a), or aggravated manslaughter under F.S. 782.07(1)). Unfortunately it cannot be determined which type of murder was committed on Mrs. Kimball and by whom, due to the concealment of 1) medical records and the 2) full FHP murder video, by respectively John Couris and State of Florida (SOF) through FHP.

3. This complaint’s viewable online for more participants to become plaintiffs in class action lawsuits against the private FRB owners. The Corner Post, Inc. Vs. Federal Reserve case, proves private FRB owners do exist, and are allowed to be sued individually or through any one of their banking cartels they own as individual entities, used for racketeering purposes (FRB or commercial subsidiary banking investment corporations). Bozeman Financial LLC v. Federal Reserve Bank of Atlanta, 955 F. 3D 971. The Federal Reserve Banks were established as chartered corporate instrumentalities (really a cartel) of the United States under the Federal Reserve Act of 1913. See 12 U.S.C. § 221 et seq. Unlike the Postal Service, which was at issue in Return Mail, the Banks’s enabling statute, does not establish them as part of an executive agency, but rather each Bank is a “body corporate.” 12 U.S.C. §341. Like any other private corporation, the Banks each have a board of directors to enact bylaws and to govern the business of banking like corporations. But the FRB isn’t registered as a corporation within states, just merely as a cartel/organization/association-in-fact banking syndicate. Moreover, the Bank may sue or be sued in “any federal court of law or equity.” The four elements of Rule 23(a) require a showing that: (1) the class is so numerous that joinder of all members is impracticable; (2) there are questions of law or fact common to the class; (3) the claims or defenses of the representative parties are typical of the claims or defenses of the class; and (4) the representative parties will fairly and adequately protect the interests of the class. Plaintiffs may argue that the Supreme Court decision in Bridge v. Phoenix Bond & Indemnity Co. (discussed in § 33 above) eases the requirements for certification of a RICO class. In Bridge, a RICO case that did not involve a class action, the Court held that a plaintiff asserting a RICO claim predicated on mail fraud, may be able to establish proximate cause without showing that the plaintiff relied on the alleged misrepresentations. However, the

circumstances of that case were unique because the plaintiff could show that it was directly

injured by fraud on which third-party government officials relied, as is the case in this matter committed by judges and cops (DHS & TPD). Government agents within local concerts, make up the frauds they commit themselves, with others turning blind eyes. This requirement is met when judges within a circuit or district, commit honest services frauds with mail and/or wire misrepresentations, consequently their Imputed after the fact benefactors can be sued either in federal or state court for non-compliance, in that state, or against the FRB headquarters directly (NY), only in federal court under 12 U.S.C. §632. The private FRB owners knowingly and intentionally use their banking corporations to transfer their private hot moneys to: This Court; Defendant Dawson’s State Farm Insurance Company as an FRB affiliate (see Appendix A); TGH; SOF; and COT, as highly biased and illegal benefactor participants in this case, always involved in judicial court case scams, due to their contracted/paid/bribed judges under state governor orders to benefit them illegally at will, by approving conversion and interference scams on consumers within their courtrooms. Suing under the RICO Act, is NEVER a continuation of a prior lawsuit, but a new tort made possible by racketeering judges during prior court cases!

4. When the word bribed is stated in this complaint, it means: 1) Bribery under (Title 18, Chapter 96, Section 201); and 2) Extortion under (Section 1951); perpetrated to implement racketeering activities. And agent salaries and perks constitute as agreeable bribes, or forced extortions depending on the amounts offered, but both are used in making FRB agents comply to committing racketeering activities for their FRB benefactors, when these benefactors own and control the American money supply and most of the world’s businesses.

5. When the FRB and FRB owners’ commercial subsidiary banking investment corporations’ fund, invest or collect agency proceeds, with some of the hot loot coming from consumers’ laundered and misappropriated moneys owed (blood moneys) using FRB contracted/paid judges, a RICO relationship is most DEFINITELY in place between the FRB owners/controllers and their subordinate judicial agents. So the 4 doctrines of law cited repeatedly within this complaint DEFINITELY apply.

6. Jurisdiction:

This court has subject matter jurisdiction to hear all of the Counts against all of the Defendants in this complaint based on either 1) their residential locations being within local courthouse limits and 2) all of the injuries having occurred within the same limits, or 3) the Defendants do business locally within Tampa, Florida limits. Where the injuries occurred, is the correct jurisdiction for all the Defendants to be sued. This local federal courthouse has subject matter jurisdiction over this action pursuant to 28 USCS § 1331, as this action arises under federal laws, specifically, but not limited to: 18 U.S.C. § 1346 (honest services frauds); 18 U.S.C. §§ 1341; 1343; (mail and wire frauds); and `U.S.C. §§ 1513 (retaliation against witnesses); and under Title 28, Chapter 190, Section 5001.

7. The focus of specific personal jurisdiction is on the defendant’s/company’s conduct within the forum state, and the lawsuit must arise from that conduct. Consequently, the defrauding of the Plaintiff and his wife in this matter, arose from the advantageous money making relationship the FRB and the other Defendants continue to have with each other, by way of hot funds/investments/bribes originating from the FRB, being reallocated/recycled as seen on FRB’s, TAS and IPAC debit/credit ledger transfer sheets within its supercomputers, transfers made to either Governor DeSantis, or directly to State of Florida agencies, along with government monetary transfers/distributions to local public/private Florida based agencies/agents like Centene and Defendant Couris (Appendix A & D). All the different addresses/structures housing FRB contracted/paid/bribed agents, public/private, make up the one (1) illegal FRB enterprise operating as both an enterprise when investing moneys to acquire and interest in, for the control of racketeering activities in the future, and as an association-in-fact enterprise operating within owner/controller concerts for organizational purposes. The FRB operates from within both types of enterprises.

***7.5 Relevant Statements of Fact concerning statute of limitation to file claims in this matter:

***7.6 2 years after the CAUSE of the Wrongful Death and Survival Action claims are discovered under Applicable F.S. 95.11(5)(c) – – the limitation of actions within this subsection shall be limited to the health care provider and persons in privity with the provider of health care (Mrs. Kimball). In those actions covered by this paragraph in which it can be shown that fraud, concealment, or intentional misrepresentation of fact prevented the discovery of the injury the period of limitations is extended forward 2 years from the time that the injury is discovered or should have been discovered with the exercise of due diligence, but in no event to exceed 7 years from the date the incident giving rise to the injury occurred. This intentional tort with an indefinite statute of limitations of up to 7 years, and for an additional 2 years after Mrs. Kimball’s medical records are disclosed. If TGH spoliated Mrs. Kimball’s medical records, Defendant TGH has another 4 years to be sued under F.S. 95.11(3)(n) when it’s determined it did so.

***7.7 4 year statute of limitations: F.S. 95.11(3)(i) – – due to a legal or Equitable Action founded on FRAUD, such as having filed a complaint for Equitable Relief in state court (25-CA-8096) by a state court judge, and having it illegally transferred to federal court by FRB contracted/paid Defendant Crist, Clerk of the Court and Comptroller of the 13th Judicial Circuit, for the purpose of being illegally dismissed by federal court judge Thomas Barber the next day (case 25-CV-3077), when a notice of the Plaintiff dismissing the FRB from the state case (25-CA-8096) was given to Judge Barber before he illegally dismissing case 25-CV-3077. And four (4) of the defendants were already being sued in this same courthouse for federal violations under case 25-CV-2181, so Judge Barber had NO jurisdiction to do anything! His false order is VOID! This is an intentional tort with a 4 year statute of limitations, which applies to Defendant Crist as contracted/paid individual, working for the FRB in defrauding the Plaintiff in 11/2025.

***7.8 4 year statute of limitations: F.S. 95.11(3)(n) – – due to an action for assault, battery, false arrest, malicious prosecution, malicious interference, false imprisonment, or any other intentional tort, Defendants Dawson (individual); COT; SOF; TPD; Rothschild (individual); and Crist (individual) are being sued in this matter. The Plaintiff was Falsely Imprisoned until 12-13-23, consequently he had no knowledge of Mrs. Kimball’s murder until he was released from jail. Under F.S. 95.11(3)(n), the four (4) year statute of limitations starts on 12-13-23.

***7.9 Whoever, through culpable negligence, exposes another person to personal injury commits a misdemeanor of the second degree, punishable as provided in s. 775.082 or s. 775.083. Whoever, through culpable negligence, inflicts actual personal injury on another commits a misdemeanor of the first degree, punishable as provided in s. 775.082 or s. 775.083. And the statute of limitations starts to accrue, when it’s discovered.

8. Statements of Fact in Mrs. Gloria Schneider’s 7-1-12 murder by her caregiver, which relevantly started the Plaintiff feud with John Rockefeller who’s the proximate cause of this complaint:

9. For at least 10 years prior to Gloria Schneider’s murder in 2012, her money was being laundered into Richard Murphy’s pension fund by Richard, his wife Sybil and her sister Cyrie Schneider, Mrs. Schneider’s caregiver.

10. The Plaintiff married Mrs. Kimball in 2010, with her drug use making her an easy TPD agent cop target in public for civil right violations. This forced the Plaintiff to protect his wife’s constitutional rights being violated as TPD sport, with FRB profits pouring in from her illegal court case fines; fees; and jail sentences, from the Plaintiff’s wallet!

11. Early in 2012, the Plaintiff made himself Mrs. Kimball’s guardian advocate for the purpose of giving her moral support and to stop the fleecing of his wife by FRB contracted/paid agent judges and cops, by having the right to stand up for her rights in criminal court, but Mrs. Kimball’s right to consent ALWAYS remained with her under during this advocacy program.

12. A few days later, the Plaintiff argued with HCSO Colonel James Previtera about his wife being given the wrong medications while in jail. James retaliated by sending his deputies to the Plaintiff’s house immediately to harass and intimidate him for days with their guns drawn.

13. The Plaintiff made complaints about James Previtera’s retaliatory actions above to both TPD and FDLE, which resulted in James being asked to leave HCSO (fired).

14. Right after this, Sheriff David Gee had the Plaintiff’s guardian advocacy illegally cancelled by Judge Isom, with everyone in the courtroom, other than the Plaintiff, stating Mrs. Kimball supposedly didn’t need a guardian against the FRB’s agent judges and cops.

15. After 7-1-12, the Plaintiff’s contested the false will drafted for his mother by probate attorney Robert Welker without her knowledge. Every probate attorney in town, even Robert Welker, stated Mrs. Schneider wasn’t alive long enough for her signed will to be valid when she died, no was murdered, 2 days after she signed a will solely acquired by her caregiver. Mrs. Schneider was never taken to a doctor the last year of her life; denied her antibiotics for pneumonia; lied to about what she had medically wrong with her; and left for dead after signing the false will.

16. Relevant Statements of Fact after Mrs. Schneider’s murder:

17. From 2012 to 2019, the Plaintiff fought with trial and appellate judges to 1) have his mother’s culpable or intentional murder investigated, and to 2) reverse the conversion and interference scams committed on his mother by respectively the Murphys and their attorneys starting at least around 2020, but to no avail.

18. Case 20-CV-78 was filed, NOT as a rendition of the local court case fights with the Murphys for committing conversion frauds and implementing tortious interference scams committed by their attorneys, but as a bona fide RICO Act complaint, due to the judges and opposing counsels having combined forces to commit honest services frauds on the Plaintiff, financially saving their benefactor John Rockefeller and his FRB, by keeping Gloria Schneider’s stolen loot in Richard Murphy’s pension funds, held by the FRB for McDonald Douglas and Lockheed Martin.

19. In early to mid-2020, John Rockefeller was phoned by the Plaintiff numerous times to resolve the matter. What was stated is cited in the Rockefeller letters (Appendix A).

20. Throughout 2021, the Plaintiff’s wife had a total of $1,600 of her SSI money converted into the pockets of her neighbors, by them drugging her, with Mayor Jane Castor from COT and Stephanie Banks (ironic last name) from social security contacted.

21. In late 2021, Agent Mark Braswell from DHS, was not acting in accordance with DHS’s standard Blue Campaign management plans; policies; and operational procedures (mandates and policies), so the Plaintiff is currently suing DHS for its illegal involvement in also causing his injuries: 1) The Plaintiff’s email service provider, mail.com, called him on his phone, stating that someone at the DHS office in Orlando, Florida was trying really hard for days to log into his email account. 2) A month later, this same agent was pounding on the Plaintiff’s front door with a letter addressed to him, which demanded the Plaintiff to stop calling the local social security manager, Stephanie Banks, about reimbursing his wife for her stolen SSI moneys (Appendix B). This was a ruse because the Plaintiff had stopped contacting Ms. Banks two (2) months prior. 3) While at the Plaintiff’s home, this agent started knocking on neighbors’ doors to obtain any gossip about Mrs. Kimball. 4) A couple weeks later, DCF was pounding at Mrs. Kimball’s door to investigate a complaint this same agent had made to them about the Plaintiff supposedly having STRUCK his wife, not about human trafficking (see the DCF reports in Appendix B). The Plaintiff was asked by DCF why a false complaint was made by a DHS agent, but he couldn’t answer the question. 5) A week later, this same agent started leaving voicemail and text messages on the Plaintiff’s phone, not about Mrs. Kimball, but about his FRB scammed inheritance, due to John Rockefeller’s joint venture pension funds through Lockheed Martin and McDonald Douglas (see Appendix E video). 6) A month later, a confidential law enforcement friend of the Plaintiff, advised him that a DHS agent was talking to TPD’s chief of police, Brian Dugan, about DHS wanting the Plaintiff illegally arrested and charged with human trafficking of his wife. 7) A month after filing a Writ of Mandamus on Ronald DeSantis in 2025 (Appendix A), with the video of agent Braswell included, the Plaintiff received a voice mail message from Agent Braswell screaming his first name, and then disconnecting the call. See Appendix B.

22. No probable cause was made to search or arrest the Plaintiff on 2-24-22, based on material evidence in violation of any Florida statute, or a conversation with competent Mrs. Kimball beforehand, just an Amazon purchased port-a-potty with liners was used as a ploy to illegally obtain a search warrant and arrest the Plaintiff on, which TPD subordinate agent cops called a bucket, and a good bust (Appendix B).

23. At the local Tampa Bay courthouse on the morning of 2-23-22, a bogus search warrant was obtained by local FRB contracted/paid/bribed TPD cops before any conversation with competent Mrs. Kimball, using no material evidence of a crime committed (bona fide material evidence to a crime committed, is MISSING from case file 22-CF-2324-A).

24. At the local courthouse in the afternoon of 2-23-22, Mrs. Kimball was FRB agent cop (TPD) browbeaten on courthouse audio/video, in a secured backroom, in front of her attorney, Marc Joseph, during case 21-CF-006147-A, while the conversation was also TPD agent cop recorded (bona fide material evidence).

25. Mrs. Kimball was against her will, made to speak with TPD agent cops, or be arrested and charged with a made up crime, while one of them dangled handcuffs in her face (bona fide material evidence on audio/video).

26. Mrs. Kimball made NO incriminating statements against the Plaintiff, the topic of the conversation, so then an FRB contracted/paid/bribed agent prosecutor working for Andrew Warren, offered her attorney a commonly used FRB BRIBE to nolle process her felony charge, if she’d allow FRB agent cops to take her to another location. This was done to 1) desperately obtain any evidence for legally arresting the Plaintiff on the next day and 2) to keep Mrs. Kimball from going home, so cops would have an easier time illegally arresting her husband (bona fide material evidence in case files 22-CF-2324-A & 21-CF-006147-A).

27. In the evening of 2-23-22, Mrs. Kimball was unknowingly taken to TPD agent, Corporal Crystal Shiver’s HOME, and pressured for, what the Plaintiff was told by his wife was overnight, to talk about her husband with further rewards promised. Then she was taken to a federal FRB funded half-way house, told she couldn’t go home, and periodically browbeaten for 3 weeks while being audio recorded (bona fide material evidence MISSING from case files 22-CF-2324-A & 21-CF-006147-A). See Appendix B.

28. On 2-24-22, TPD agents showed up at Mrs. Kimball’s residence with a bogus search warrant for the property, obtained without any material evidence provided to local Judge Twine of a crime committed. This warrant basically stated FRB agent cops had the right to look for evidence of abuse and neglect committed by a caregiver under Florida Chapter 825, as though Mrs. Kimball was disabled under Florida Chapter 825, when she wasn’t! When cops were finished searching, all they found were stools in the family port-a-potty, with the Plaintiff being illegally charged with neglect as though a port-a-potty was illegal and he was a caregiver under Florida Chapter 825, who supposedly forced his wife to use their port-a-potty, along with theft/exploitation, also under Florida Chapter 825, as though Mrs. Kimball didn’t have the capacity for consenting to her husband protecting her properties (ID & food stamp cards found in his wallet). So Mrs. Kimball was supposedly incompetent, because a wife would supposedly never let her husband pick up groceries at the store for her! The Plaintiff married Sandra Kimball before she started receiving SSI benefits and always tried to keep her from spending her money or trading her belongings, like her food stamp card and ID, for street drugs. If the Plaintiff hadn’t done this, and knowing his constitutional rights aren’t worth a damn in America, complements of the FRB owners, he would’ve probably been charged with aiding and abetting in his wife’s drug use and murder! DEVILS! Mrs. Kimball was NEVER disabled under Florida Chapter 825, because she had NO permanent mental or physical disability classifying her as either mentally incompetent or physically impaired! According to social security, Mrs. Kimball suffered from manic depressive bipolar disorder, due to years of street drug use, which left her with a non-permanent nervous condition that social security tested for every 2 years to confirm she still couldn’t work because of it, but was competent when on her medications, not street drugs (bona fide material evidence in Appendix C).

29. Mrs. Kimball was her own representative payee (RP) for her SSI benefits, which were deposited into her own bank account! And the Plaintiff was never anyone’s caregiver! Mrs. Kimball never had a caregiver due to never needing one! This is evident when NO material evidence of: 1) The Plaintiff ever being a caregiver; 2) the Plaintiff ever stealing Mrs. Kimball’s benefits, or abusing her physically or mentally; nor 3) Mrs. Kimball being incompetent, was ever produced by SOF/COT/TPD agents in case 22-CF-2324-A! No judge in 25 years of Mrs. Kimball being arrested for drug use, ever brought up competency issues! Mental evaluations were only ordered by judges on Mrs. Kimball, after her attorney intelligently brought up the subject to fool prosecutors and the legal system into dismissing her MISDEMEANOR charges a half dozen times before 2021 (bona fide material evidence held by Attorney Alex Stavrou), due to Mrs. Kimball really being temporality blitzed half the time on street drugs. Mrs. Kimball suffered from severe momentary depression, and needed either medications or street drugs to stop her from having these reoccurring episodes. Unfortunately her medications weren’t sufficient all of the time.

30. Mrs. Kimball was NOT incompetent when she needed to pass competency evaluations, and did so during three (3) of them (bona fide material evidence in case 21-CF-006147-A) (Appendix C), with Attorney Marc Joseph as a witness! The Plaintiff can honestly testify to his wife showing more basic knowledge, logic and good sense, when off street drugs and on her medications, than he ever did!

31. All of the incriminating statements made, not only in the arrest affidavit, but throughout case 22-CF-2324-A, are COT/TPD/SOF agent made up, originating possibly from the Plaintiff’s neighbors residing kitty-corner from him at 10407 N 25 Street, Tampa, FL 33612, retaliating against him due to his phone calls to FRB agent cops, made about their illegal activities. Consequently, FRB agent cops intentionally lied to Judge Twine about the validity of their oral/written statements, when they had NO material evidence to support this judge granting them a search warrant on the Plaintiff’s house. The bogus search warrant was needed, so cops would be able to search for anything illegal they could find to legally charge the Plaintiff with, AFTER illegally arresting him! (desired FRB/DHS/COT/TPD agent cop goal with hindsight being 20/20).

32. The false imprisonment of the Plaintiff and the murder of Mrs. Kimball:

33. The Plaintiff and his wife were represented by Attorney Matthew Kimball McDowell during case 22-CF-2324-A, who told the Plaintiff that his wife COULD live at home, as it was a gray area of law which allowed both him and his wife to live at the same property, due to the no contact order only being on the Plaintiff, with the property solely owned by him. So the Plaintiff technically didn’t have to leave when his wife was home.

34. In mid-2023, the prosecution found out about Mrs. Kimball’s living arrangement and illegally arrested the Plaintiff 2 more times for his wife’s presence at her house, with Judge Goudie NOT granting the Plaintiff bail, and with Fox News at 5 airing false information about the Plaintiff on TV, so he was forced to plead out, or be injured by inmates. The second time TPD found the Plaintiff’s wife at her house, the Plaintiff was jailed for 4.5 months using a bogus TPD search warrant with planted items used to arrest with his wife murdered on the streets!

35. How the 4 doctrines of law cited throughout this complaint are applicable in this matter:

36. Imputation and subsequently acquiescing in, by not implementing the appropriate corrective measures after having knowingly benefited by a fraud, keeps all wrong doers on the hook for both PRIOR and FUTURE damages!

37. The Law of Agency establishes a set of rules for determining when, in relation to third parties, an agent’s conduct or knowledge should be imputed to his or her principal. See Restatement (Third) of Agency §§ 2.01 – 2.04, 5.03 (2006). For example, in transactions with third parties, an agent’s conduct will be imputed to the principal, if the agent acted with actual or apparent authority (attorney/client relationship), or if the principal ratified the agent’s conduct. See Fergus v. Ross, 477 Mass. 563, 566-568, 79 N. E. 3d 421 (2017). See also Restatement (Third) of Agency, supra at §§ 2.01 – 2.03, 4.02.

38. In the realm of torts, the tortious conduct committed by an agent in the scope of his or her agency, will be imputed to the principal under a theory of Respondeat Superior. See Lev v. Beverly Enters.-Mass., Inc., 457 Mass. 234, 238, 929 N.E. 2d 303 (2010). See also Restatement (Third) of Agency, supra at § 2.04. Knowledge that an agent acquires in the scope of his or her employment can also be imputed to the principal. See Sunrise Props., Inc. v. Bacon, Wilson, Ratner, Cohen, Salvage, Fialky & Fitzgerald, P.C., 425 Mass. 63, 66-67, 679 N.E. 2d 540 (1997). See also Restatement (Third) of Agency, supra at § 5.03. Merrimack Coll. v. KPMG LLP, 480 Mass. 614, 108 N. E. 3d 430, 438 (2018).

39. The result of imputation is that the principal bears the legal consequences of the agent’s conduct. Thus, if an agent with actual or apparent authority enters into a contract with a third party, the principal will be bound by that contract. See, e.g., Linkage Corp. v. Trustees of Boston Univ., 425 Mass. 1, 4, 17, 679 N. E. 2d 191, cert. denied, 522 U.S. 1015, 118 S. Ct. 599, 139 L. Ed. 2d 488 (1997) (university bound by agreement signed by vice-president where vice-president had apparent authority).

40. If an agent negligently injures a third party while acting within the scope of the agency, the principal will be held vicariously liable for that negligence. See, e.g., Dias v. Brigham Med. Assocs., Inc., 438 Mass. 317, 323, 780 N. E. 2d 447 (2002) (corporation could be held vicariously liable for alleged medical malpractice of its physician-employee). Merrimack Coll. v. KPMG LLP, 480 Mass. 614, 108 N. E. 3d 430, 438 (2018). Imputation serves various functions. It creates incentives for principals to choose their agents wisely. See Restatement (Third) of Agency, supra at § 5.03 comment b, at 360. It also encourages principals to supervise their agents and to share information with them. Id. The ultimate purpose behind these rules of imputation, however, is to fairly allocate risks between principals and innocent third parties. As explained in Kansallis Fin. Ltd. v. Fern, 421 Mass. 659, 664-665, 659 N. E. 2d 731 (1996).

41. Kansallis:

“Standing behind [the] diverse concepts of vicarious liability is a principle that helps to rationalize them. This is the principle that as between two innocent parties — the principal-master and the third party — the principal-master who for his own purposes, places another in a position to do harm to a third party, should bear the loss. A principal who requires an agent to transact his business, and can only get that business done, if third parties deal with the agent as if with the principal, cannot complain if the innocent third party suffers loss by reason of the agent’s act. Similarly, the master who must put an instrument into his servant’s hands in order to get his business done … must also bear the loss, if the servant causes harm to a stranger in the use of that instrument as the business is transacted.” (Citations omitted.) Merrimack Coll. v. KPMG LLP, 480 Mass. 614, 108 N. E. 3d 430, 438 (2018).

42. Vicarious Liability under the Respondeat Superior Doctrine: “Qui Facit per alium facit per se”, i.e., he who acts through others, acts through himself. And “respondeat superior”, i.e., let the master be liable. A master (owner/controller) is primarily liable for the actions of his or her hired servants.

43. Statements of Fact against Defendant Dawson:

44. While the Plaintiff was in jail until 12/2023, Defendant Dawson, who was driving his car at 3:40am on 8-19-23, purposely overtook a parked car next to a visible crosswalk within an intersection with a traffic light, without slowing down and struck Mrs. Kimball, a pedestrian within a visible crosswalk, a violation of F.S. 316.130(9), and never got out of his car to see what he could do to help, nor did he call in the emergency to 911, a violation of his duty to render aid under F.S. 316.062. Thus a culpable or intentional tort was committed by David Dawson by striking Mrs. Kimball illegally with his car.

45. FHP still refuses to provide the full video of the homicide to the victim’s spouse, without having done a mandatory drug screening of Defendant Dawson at the time of the homicide (see report in Appendix A). It’s still undetermined if Dawson was culpably or intentionally negligent when he struck Mrs. Kimball with his car hard without slowing down, as if he was trying to murder her.

46. Defendant Dawson clearly overtook a vehicle parked at a stop light, in front of a crosswalk, a violation of F.S. 316.130(9) – – Whenever any vehicle is stopped at a marked crosswalk, or at any unmarked crosswalk at an intersection, to permit a pedestrian to cross the roadway, the driver of any other vehicle approaching from the rear, shall not overtake and pass such stopped vehicle! This reads exactly on par with what the video footage of Mrs. Kimball’s homicide shows! This intentional, or culpable, negligence on the part of Defendant Dawson, resulted in at least the aggravated manslaughter (statutorily cited later on in the Counts section) of Mrs. Kimball (capable negligence is aggravated manslaughter, which is a type of murder)! At this point it’s speculative as to what Defendant Dawson was doing at 3:40pm on a Saturday morning, driving at a high speed. This speculation became highly alarming to the Plaintiff, when FHP failed to conduct MANY of its mandatory statutory duties right after the homicide as State of Florida mandated policies. Part of the homicide can be watched from a partial clip in Appendix E.

47. The Plaintiff hired credible investigator “Star” to determine, if Defendant Dawson was negligent, or deliberate, when he CRIPPLED Mrs. Kimball with his car (see homicide report Appendix A). According to A) hearsay witness testimony, along with B) FHP having intentionally violated both the Plaintiff and his wife’s state and federal 14th amendment rights; and state and federal mandatory statutory duty to properly investigate a homicide, by doing a drug screening and review of the full video obtained for criminal/racketeering activities, with the spouse NOT being given a copy of everything FHP obtained; and to MAINTAIN its standard management plans; policies; and operational procedures during both the homicide and in case 24-CA-7358, but intentionally failed to: 1) Apply required F.S. 316.103(9) to its homicide report; 2) do a mandatory drug screening of Defendant Dawson at the scene of the homicide (very suspicious FHP violation of homicide procedures (pre-spoliation of evidence)); 3) correct its false homicide report which wrongly states Mrs. Kimball was at fault while in the crosswalk (Appendix B), thus WRONGLY stating she caused the accident (very suspicious when pedestrians have the right of way, and under F.S. 316.130(9); 4) concealed/spoliated the rest of the murder video, part of which was inadvertently provided to the Plaintiff (hindsight 20/20), so A) no one else could determine who jump out of Defendant Dawson’s car right after the homicide and ran off (as stated by witness Brandon Santiago cited in the FHP’s homicide report); or B) who was chasing/luring Mrs. Kimball into the crosswalk (very suspicious); and C) who had been stalking Mrs. Kimball for hours the morning of 8-19-23; and 5) intentionally having its attorney in case 24-CA-7358, blatantly state FHP spoliated the homicide video to conceal the rest of it, when it’s MANDATORY for FHP to keep complete video tapes on all homicides, as stated to the Plaintiff in mid-2025, by Tampa based Lt. Eric French, FHP (extremely suspicious)! The manager of the Take 5 oil change shop which made the video, stated to the Plaintiff that an FHP officer had downloaded a full days’ worth of the video!

48. These facts along with credible testimony from a couple of shop owners and a dozen homeless witnesses working/living in the immediate vicinity of Mrs. Kimball’s homicide (not material evidence, but a good start for obtaining more), all stated to both the Plaintiff and his investigator, they either had personal knowledge of who murdered Mrs. Kimball and why it was committed, but were too scared to give the details, or heard credible hearsay information that the car driver (Defendant Dawson) who caused the homicide (3:40am on 8-19-23), was a drug dealer/runner working out of another location in west Brandon, Florida for covertness, who had a known drug pusher/distributor in his car at the time, who were both looking to injure Mrs. Kimball (first or second degree murder) for supposedly stealing drugs from the pusher, as well as from his local buyers/users for months. Credible witnesses recently told the Plaintiff they tried to keep Mrs. Kimball hidden the night she was murdered, so she couldn’t be found by Defendant Dawson and his passenger! At this point, Defendant Dawson should’ve already had his driving privileges suspended for illegally mowing Mrs. Kimball down with his car, a violating F.S. 316.103(9)!

49. Since a murder occurred, and FHP’s a department within the State of Florida (SOF), there’s no statute of limitations in suing SOF, or one of its employees, for intentionally covering up the murder video by spoliation, for the FULL recoverable damage amounts in this case, through its benefactor the FRB, with the deepest pockets, currently being sued in state court!

50. Relevant Statements of Fact against Tampa General Hospital for spoliation of evidence and Fraud on the Court committed:

51. Defendant TGH, along with its owner John Couris, knowingly and intentionally denied Mrs. Kimball’s spouse her TGH medical records, when a personal representative has never been appointed in this matter, a violation of F.S. 395.3025(1). John Couris was directly notified in early 2025, that Mrs. Kimball’s spouse, a reasonably prudent person, believed she had been murdered by his funding source, the FRB, due to the Plaintiff threatening to sue the FRB through John Rockefeller. A letter directly sent to John Rockefeller in 2020, with a copy of the 2025 Rockefeller letter, both in Appendix A, was sent to Mr. Couris, who’s now at least an accessory after the fact (AATF) in either the culpable, or intentional, murder of Mrs. Kimball by Defendant Dawson, but it’s still unknown if John Couris didn’t in fact intentionally cause Mrs. Kimball’s death as a benefit to his FRB funding source through TGH, thus also assisting in the murder of Mrs. Kimball, with her TGH medical records possibly spoliated as stated in case 24-CA-7358, as a misrepresentation used to cover-up TGH’s involvement in Mrs. Kimball’s murder.

52. TGH is an AATF in at least the aggravated manslaughter of Mrs. Kimball, by covering up her medical details to benefit itself; its funding and investing source the FRB; and Dawson. John Couris screwed up when he failed to provide Mrs. Kimball’s medical records, after he was directly notified of her being murdered, at least as an F.S. 782.07(1) violation. Now TGH is being correctly sued for Mrs. Kimball’s medical records being technically spoliated (concealed or destroyed). And the statute of limitation on wrongful death demands that TGH continue to be sued for wrongful death to preserve the filing date, because it fraudulently spoliated Mrs. Kimball’s medical records!

53. The Plaintiff is suing TGH due to John Couris’ many law violations: 1) He covered up the details of Mrs. Kimball’s murder, by tortiously interfering in the Plaintiff obtaining Mrs. Kimball’s medical records directly from TGH, starting in the beginning of 2024 (Appendix A); and by having 2) hired attorneys to misrepresent the facts in court as an accessory after the fact in Mrs. Kimball’s murder during court case 24-CA-7358, when he knew beforehand Mrs. Kimball was probably murdered (no court ruling of murder needs to be made on this subject to civilly sue for murder.

54. John Couris is being sued through TGH for knowingly and intentionally stopping TGH from providing the Plaintiff with his wife’s medical records, a violation of F.S. 395.3025(1) (Appendix A). John Couris had his attorneys brazenly lie in court case 24-CA-7358, stating that the Plaintiff couldn’t have Mrs. Kimball’s TGH medical records, because he wasn’t married to her in 2010, for their marriage license not being on file with Hillsborough County’s, Clerk of the Court, until after her death! A total bull chip lie! What’s John Couris been hiding for 2 years?

55. John Couris also tortiously interfered with the Plaintiff’s expectancy to obtain his murdered wife’s medical records in a timely fashion from TGH, starting in the beginning of 2024, now considered spoliated evidence (mandatory court sanction required, if he doesn’t produce the records after this case is officially open)! And John Couris will be in violation of U.S. Code § 1519 (destruction, alteration, or falsification of records), if he no longer has them!

56. It’s probable that John Couris through TGH committed culpable or intentional wrongful death on Mrs. Kimball using his TGH agents, a violation of both Florida Statutes 768.16 (wrongful death); and 46.021 (survival action claim for 3.5 days of suffering), because of the spoliation/concealment of Mrs. Kimball’s TGH medical records as an AATF in her murder. If this is later found to be incorrect, the Plaintiff will amend his complaint and delete these Counts, but you cannot add them to this complaint after 2 years, so these Counts have to stay with TGH until after discovery. John Couris’ fault for not providing the records.

57. John Couris committed a compounding offense after tortiously interfering in the Plaintiff obtaining his wife’s medical records, which also makes him at least an AATF to whoever was the proximate cause of her death. It consists of three (3) basic elements: (1) knowledge of the crime (direct notice was given to both Governor DeSantis and John Couris, cited in Appendix A); (2) the agreement not to prosecute or inform (Mrs. Kimball’s medical records were withheld or destroyed (spoliated)) by the illegal participation/involvement of both DeSantis and Couris, respectively cases 25-CV-564 & 24-CA-7358); and (3) the receipt of consideration – – continued state funding to TGH from the FRB through DeSantis; Medicaid; and USF, for the purpose of continuing to have TGH SAVE the FRB from indirectly having to pay the Plaintiff, and possibly other consumers, restitution/compensation through TGH. The offense is concluded when there’s an agreement to either withhold evidence of the crime, conceal it, or fail to prosecute it. “English common law states: The “crime of compounding” is committed when a perpetrator, prosecutor, any other official or another person enters into an agreement with the victim of a crime or an official, whereby some, or other benefits, are transferred between the parties in order to stop, withdraw or alter the reporting or prosecution of an offense,” explains Charles De Meillon, Florida Chapter 843, Obstructing Justice 843.14 – – Compounding Felony. The Plaintiff had one Defendant complain because he cited criminal statutes in his state complaint. The Plaintiff can’t sue under any criminal statute. But he can show all of the RELEVANT law violations which resulted in his personal injuries. If the Plaintiff can have his mug shot all over the Internet because of John Rockefeller, he can accurately state what real criminal violations his agents committed during this matter!

58. John Couris is also being sued under Title 18, Chapter 96, Sections 1961(1)A & B; specifically Section 1341 (paper by mail used in knowingly and intentionally giving out misinformation of the facts in court case 24-CA-7358, about the Plaintiff not being married to Mrs. Kimball); Section 1343 (wire by Internet used in knowingly and intentionally giving out misinformation of the facts in court case 24-CA-7358 about the Plaintiff not being married to Mrs. Kimball), resulting in Fla. Stat. §838.022(a);(b);&(c); 112.3173(e)(6); and Section 1346 violations – – TGH committed honest services fraud, by not providing Mrs. Kimball’s medical records to the Plaintiff, as well as being an accomplice to the FRB’s contracted/paid/bribed judge in case 24-CA-7358 doing the same.

59. John Couris is guilty of letting either a culpable or intentional tort committed at his hospital stand, after the Plaintiff directly notified him of Mrs. Kimball’s being murdered! This makes John Couris either an AATF, or before the fact (ABTF) as an accomplice in the murder of Mrs. Kimball, DURING HER STAY AT TGH, depending on what’s in her TGH medical records the Plaintiff still doesn’t have! By 2) John Couris continuing to aid and abet the FRB (a source of funding for TGH, by tortiously interfering with the Plaintiff obtaining his wife’s medical records, after being directly imputed by the Plaintiff to stop doing so when she was murdered (Appendix A), John Couris is now at least an AATF to whoever was the proximate cause of her death! Since hindsight’s 20/20, John Couris’ actions/inactions (omissions) after being imputed with the facts in this matter early this year (his letter contained a copy of the 2025 Rockefeller letter referenced in Appendix A), he’s aided and abetted in the cover-up of Mrs. Kimball’s murder as an AATF, either on the street, or at his hospital! The million dollar question is did Defendant Couris aid and abet FRB agents in purposely ending Mrs. Kimball’s life? Due to the spoliation of evidence under Fla. R. Civ. P. 1.380(b)(2)F), makes both Couris and TGH, at least accessories after the fact in her aggravated manslaughter committed by the rest of the Defendants and their concert members. You lose the evidence, you pay for the crime as if you committed it!

60. John Couris’ actions/inactions (omissions) during case 24-CA-7358, continue to injure the Plaintiff and maximize FRB funds officially remaining with TGH, an FRB funded and invested in corporation (Appendix A), in a two (2) step, multitier judicially implemented, tortious interference scam (case 24-CA-7358) to misappropriate Mrs. Kimball’s medical records owed to the Plaintiff – – medical records illegally allowed by FRB contracted/paid/bribed judges in cases 24-CA-7358 and 25-CA-564, to ultimately be hospital kept/spoliated, which profits the FRB in NOT having to compensate/reimburse its TGH business affiliate for any medical malpractice or hospital regulation violation committed, but also by the rest of the FRB funded/invested in Defendants who technically murdered her too, not having to pay restitution, amounting to a huge amount of FRB SAVINGS.

61. Both Defendant Couris and his hospital, which technically spoliated (concealed/destroyed) Mrs. Kimball’s medical records, are liable for her wrongful death, because of: 1) The spoliation committed, and 2) the competent hearsay testimony from a unbiased TGH emergency room nurse, who imparted to the Plaintiff, both TGH and its owner, John Couris, were vicarious liable in NOT adhering to professional hospital standards! These standards amounted to having a board certified neurosurgeon available in the morning hours of 8-19-23, or getting one in FAST! You don’t let a person going unconscious with a head injury go untreated for long, or his or her head will swell up with fluid, and their brain DIES! These standards are violated when a hospital intern such as a residing USF doctor, completing his or her residency at TGH, wrongly/illegally acts as a board certified neurosurgeon. Consequently, TGH and/or its owners can be held accountable for not having one available to perform a needed surgery quickly and correctly after admitting a patient! This liability applies to issues of inadequate staffing, or insufficient training, for handling an emergency, like when the one (1) main TGH board certified neurosurgeon is needed, but has the weekend OFF and some other staff member makes a BAD decision! It’s the Plaintiff choice to either sue TGH or the owner, and there’s no doubt whatsoever Defendant Couris is intentionally/culpably negligent when he needs to racketeer with the FRB’s controller in Florida (Governor DeSantis), for FRB savings/retaliation purposes (Appendix A)! Hindsight in this matter is 20/20!

62. So according to competent hearsay testimony from TGH, by it not having performed Mrs. Kimball’s lifesaving procedure in time, or at least pulled in a board certified neurosurgeon quickly, or had its helicopter team transport her to another hospital with a competent board certified neurosurgeon waiting on hand to immediately perform the procedure, one who finished his or her neurosurgeon residency, Mrs. Kimball’s NOW DEAD! Consequently, if what the nurse above stated is true, Defendant Couris is at least vicariously, no intentionally, liable for Mrs. Kimball’s wrongful death, due to really being an AATF, AFTER having been imputed by the Plaintiff of his wife having been murdered, but still isn’t the proximate cause of damages, the FRB is! To find out how John Couris and his hospital were involved in Mrs. Kimball’s murder, all of her TGH medical records need to be reviewed!

63. Relevant Statements of Fact against City of Tampa (COT):

64. COT agent cops (TPD), obtained a false search warrant of Mrs. Kimball’s house in the morning of 2-23-22, without providing any physical evidence of a violation of Florida statute, as indicated from the warrant used to search (see Appendix B). TPD interrogated Mrs. Kimball in the afternoon of 2-23-22 in front of her attorney Marc Joseph, and threatened her when she stated that she didn’t want to talk to them, with ultimately COT/TPD having to offer her a bribe to dismiss her felony case with an 18 month sentence in prison, if she allowed them to take her to an unknown place, thus illegally keeping her from going home as planned for 1.5 years (2-23-22 to 8-21-23), while further interrogating her for 3 weeks without any crime having been committed, as evident from referencing cases 22-CF-2324-A and 21-CF-006147-A. DHS’s involvement in this matter was to involve COT; and SOF as concert members, for FRB retaliatory purposes. Without obtaining any information from Mrs. Kimball of a crime committed by her husband the Plaintiff, TPD illegally searched her house on 2-24-22, committed theft; conversion; and destruction of her and her husband’s properties (case 22-CF-2324-A photos show a trashed house, not from the Plaintiff or his wife, but from COT/TPD agent cops).

65. The results of this search yielded no sign of Mrs. Kimball being abused or neglected by anyone, as confirmed by one of the TPD agent cops who executed the bogus search warrant, later deposed by Attorney McDowell, recorded on film, and viewable in Appendix E! On 2-24-22, TPD agent cops wrongly arrested and charged the Plaintiff with both neglect and theft under Florida Chapter 825, which entails crimes against adults having either a permanent mental or physical disabilities of the magnitude to be easily exploited. Mrs. Kimball being blitzed on street drugs most of the time, doesn’t count. So she wasn’t disabled under this statute!

66. Because TPD found stools in the family’s legally owned and operated port-a-potty, it wrongly claimed that, by Mrs. Kimball using a port-a-potty made for human waste (see a photo of in Appendix D), not a flushing toilet, the Plaintiff had somehow abused his wife under Chapter 825. COT; and Jane Castor; through TPD agent cops; were instrumental in initially railroading the Plaintiff onto SOF, so Jane Castor’s entire local concert could keep the Plaintiff’s wife from going home, due to the type of bogus charges TPD agent cops filed on him. And due to the illegal arrangement DHS had with COT/TPD/SOF, all accomplices in Jane Castor’s local concert, with all of these agencies/agents knowing no crime was committed by the Plaintiff in case 22-CF-2324-A.

67. After being illegally detained for 3 weeks by COT/TPD agent cops starting on 2-23-22, Mrs. Kimball was shown the streets by them, with nowhere to go and where Attorney Matthew Kimball McDowell found her 3 month later in Pinellas County Florida, living and sleeping on CONCRETE without her medications! If Mrs. Kimball was really COT/TPD’s witness they were trying to protect, where was the evidence given to them by Mrs. Kimball before or after the Plaintiff’s arrest to prove a crime was committed by him? It certainly wasn’t placed into case 22-CF-2324-A. If after Mrs. Kimball having given SOF through COT/TPD, NO testimony it could use to prosecute the Plaintiff with (no affidavit signed, or audio/video filed in case 22-CF-2324-A, incriminating the Plaintiff in any Florida statute violation), and both SOF; and COT/TPD knew Mrs. Kimball was disabled and in need of her medications, which her attorney Matthew Kimball McDowell provided to her on the streets only once, multiple state and city agents, like Jane Castor; Andrew Warren; Susan Lopez; Lynn Goudie; and Mellissa Grajales, are at least culpably negligent in her aggravated manslaughter (MURDER), by intentionally violating the survival action statute (F.S. 46.021), to intentionally keep her on the streets with the false no contact order on her husband still in place! This was done to both aggravate the Plaintiff and to keep arresting him every time COT/TPD found his wife at home.

68. I n this case, all state entities (municipalities and employees) are being sued in state court for any one of their employees having committed a negligent or intentionally tort, while acting within the scope of his or her employment which 1) breached a state government policy. And they’re also being sued in federal court for having 2) implemented a state government policy in violation of their duty to the public under the U.S. Constitution. The plaintiff is suing COT in federal court under, but not limited to the following: 1) Title 28, Chapter 190, Section 5001; 2) (Title 18, Chapter 13, U.S. Codes § 241); 3) Title 42, Chapter 21, Section 1983; and 4) Title 18, Chapter 13, U.S. Code § 241. Punitive damages and attorney’s fees are owed for common law frauds and breaches of fiduciary duties to the public by municipalities. “A public official, acts as trustee for the citizens and the State … and thus owes the normal fiduciary duties of a trustee, e.g., honesty and loyalty to them.” United States v. Kincaid-Chauncey, 556 F. 3d 923, 939 (9th Cir. 2009) (quoting United States v. Silvano, 812 F. 2d 754, 759 (1st Cir. 1987) and United States v. Mandel, 591 F. 2d 1347, 1363 (4th Cir. 1979) (internal quotation marks omitted)).

69. Defendant COT/TPD working together in concert with SOF, with joint and several liability applicable, due to intentional fraud committed, were in violation of the Plaintiff’s 4th and 5th state and federal amendment rights, while being falsely searched; arrested; imprisoned; maliciously prosecuted; and wrongly processed by the court system during case 22-CF-2324-A, when no crime was committed by anyone except Jane Castor’s local concert. This was accomplished by the wrongful actions of Jane Castor instructing TPD agent cops working for COT. Both the Plaintiff and his wife were clearly injured by COT starting on 2-23-2022, using TPD officers while they worked in their official capacities, but were adhering to a different set of DHS Blue Campaign, management plans, polices and operating procedures, under a different and illegal, non-standard set of operating requirements, due to Jane Castor being technically the director of COT. The Blue Campaign, see Appendix A, was originally, and still is, for stopping the migration of immigrant slave laborers into America (typically Cuba and South America). It’s always been an informational and educational program to inform local law enforcement agencies what to look for, not for DHS to get involved in to the point of knowingly and intentionally violating DHS policies, due to having participated directly in illegal arrests, thus breaching human and civil rights it was supposedly trying to uphold for illegal aliens. During the latter part of 2021, DHS had specific mandatory operating requirements for informing local law enforcement agencies on how to identify and implement DHS’s Blue Campaign on violators, not to participate in doing so itself! DHS crossed the line, by conducting an unwarranted investigation on local Americans Mrs. Kimball and her husband, which resulted in him being falsely imprisoned for 225 days, with his wife suffering on the streets for 1.5 years until murdered, due to the no contact order illegally placed on the Plaintiff, initiated by DHS through Jane Castor’s local concert (COT/TPD/SOF).

70. The decision to adopt a different set of management plans, policies and operating procedures is a discretionary function, but its implementation of an incomplete or illegal set of them isn’t. In Maryls Bear Medicine v. United States (9th Cir. 2000) 241 F.3d 1208. When a state or federal agency has acted contrary to mandates or directives, imposing liability doesn’t require a court to second-guess legislative and administrative decisions grounded in social, economic or political policy. “When a suit charges an agency with failing to act in accord with a specific mandatory directive, the discretionary function exception doesn’t apply.” (Berkovitz, 486 U.S. at 544, 108 S.Ct. at 1963.) and (Faber v. United States (9th Cir. 1995) 56 F.3d 1122). A “failure to effectuate policy choices already made, will not be protected under the discretionary function exception.” (Id., 241 F.3d at 1215, emphasis added.)

71. Defendant COT failed to adhere to its STANDARD management plans, policies and operating procedures, opting to initiate an illegal type of DHS Blue Campaign, to intentionally injure the Plaintiff and his wife. Defendant COT was absolutely instructed by its superiors, DHS and Jane Castor, to adhere to a made up set of illegal Blue Campaign operational requirements, to intentionally injure the Plaintiff and his wife. Clearly the reason for the Plaintiff’s injuries (hindsight’s 20/20). During 2022, COT had specific mandatory operating requirements in place, but knowingly and intentionally adhered to a DIFFERENT set of illegal operating requirements, instructing its agent cops to use inapplicable Florida Chapter 825 and a set of illegal DHS’s Blue Campaign instructions on at least the Plaintiff and his wife. This is evident when COT/TPD agent cops, intentionally injured the Plaintiff and his wife, in violation of STANDARD MANDATES, imposed on COT/TPD by Jane Castor and Mark Braswell as their own set of made up operating requirements! Basically DHS’s Blue Campaign mandates are illegally changed whenever desired by DHS agents to implement a witch hunt for prosecuting any FRB marked consumer for actions taken that can be misconstrued as obtaining labor for free. What Agent Braswell from DHS in Orlando, Florida did, was illegally involve his agency in injuring the Plaintiff and his wife as an FRB retaliatory act through COT/TPD/SOF.

72. The Department of Homeland Security (see Appendix A) FUNDS COT/TPD and most local law enforcement agencies to keep them inline with what it wants and when it wants it by, or they’ll be investigated and charged like Judge Hannah Dugan, a Milwaukee County Circuit judge was. The Homeland Security provides to local state agencies, a suite of risk-based grants to assist state, local, tribal and territorial efforts in preventing, protecting against, mitigating, responding to and recovering from acts of terrorism and other threats. So they say. The point is COT/TPD; and Jane Castor have their hands in DHS’s pockets. Consequently if COT/TPD; and Jane Castor fail to take orders from DHS, they’re funding could quickly stop along with DHS perks!

73. A municipality or employee is a proper defendant under Title 42, Chapter 21, Section 1983, where the conduct complained of relates to an official municipal policy, custom, or practice causing the U.S. constitutional tort. Monell v. Dep’t of Soc. Servs. of New York, 436 U.S. 658, 691, 98 S. Ct. 2018 (1972). If COT/TPD, or bastard Mayor Jane Castor, can produce any physical evidence of 1) Mrs. Kimball having been disabled under Florida Chapter 825; 2) the Plaintiff having been Mrs. Kimball’s caregiver; or 3) the Plaintiff having abused/stolen from Mrs. Kimball in violation of any Florida statue, he’ll drop this lawsuit! The corpus delicti rule requires that the prosecution present independent evidence to establish that a crime has occurred. This evidence should include physical evidence, which directly establishes the fact of a crime. In contrast, witness testimony alone in an affidavit ISN’T sufficient to establish corpus delicti. People v. McMahan. See Appendix B.

74. The funding of TPD comes from COT, which is FRB funded, directly and indirectly, by both the quasi-government FRB and FRB commercial subsidiary banking investment corporations, like Chase Manhattan; Rothschild & Co. and their subsidiaries investments like Rockefeller Brothers Fund; Citigroup; Blackrock; Vanguard; and State Street shell corporations. And COT/TPD’s is funded through federal government agencies too, like DHS.

75. COT (a municipality) is being sued in state court for their employees (about 4 dozen, including Jane Castor) having committed intentional and culpable torts while acting within the scope of agent employment, which 1) breached a state government policy. But is also being sued by the Plaintiff in federal court for having 2) implemented a state government policy in violation of their duty to the public under the U.S. Constitution. There were federal violations of, but not limited to, the following federal statutes by Jane Castor acting through COT; and TPD agent cops, along with concert member SOF: 1. Title 18, Chapter 13, U.S. Code § 241; 2. Title 42, Chapter 21, Section 1983; and Title 18, Chapter 13, U.S. Code § 241.

76. The federal statute of limitations in a circuit is tolled permanently on acts to defraud and deprive a plaintiff of his or her human/civil/constitutional rights done in conjunction with committing a Fraud on the Court, (F.S. 1540 or federal 60(b)(3)), or being at least an accessory after the fact (AATF) in a murder under Title 18, U.S. Code § 3, as is the case in this matter!

77. Racketeering under the RICO Act is automatically an intentional breach of government policy, at least according to state and federal constitutions; statutes; rules; duty to render aid; and common laws still in place!

78. The Federal Constitution, Florida Constitution, Florida state laws, rules and regulations, don’t allow immunity, if a state agent acted willfully, maliciously, fraudulently, in bad faith, beyond his or her authority, or under a mistaken interpretation of the law.

79. When determining whether qualified immunity applies, the central questions are: (1) whether the facts alleged, taken in the light most favorable to the plaintiff, demonstrate that the defendant’s conduct violated a statutory or constitutional right, and (2) whether the right at issue was clearly established. Committee To Protect Our Agricultural Water, et al., Plaintiffs, v. Occidental Oil and Gas Corporation, et al, Defendants. No. 1: 15–cv–01323–DAD–JLT. Signed 01/20/2017. Jane Castor and her co-conspiring agent cops through Defendant COT, absolutely knew what they had been committing on consumers periodically for years, violated the Plaintiff and his wife’s state and federal constitutional rights under the 4th amendment.

80. Government officials enjoy qualified immunity from civil damages, unless their conduct violates “clearly established statutory or constitutional rights of which a reasonable prudent person would have known.” Jeffers v. Gomez, 267 F. 3d 895, 910 (9th Cir. 2001) (quoting Harlow v. Fitzgerald, 457 U.S. 800, 818, 102 S. Ct. 2727, 73 L. Ed. 2d 396 (1982)); see also Bruce v. Ylst, 351 F. 3d 1283, 1290 (9th Cir. 2003).

81. According to the American Bar Association, Volume 18, Number 3 January/February 2009, by Razzano and Kristin H. Jones, since the enactment of 18 U.S.C. § 1346, federal courts have tried to step into this gap. They have divided the universe of honest services fraud into two spheres: public and private honest services fraud. Public honest services fraud is the instrument used by federal prosecutors to impose the federal government’s view of good government on state and local officials. Since the national government under our federal system cannot pass bribery or conflict of interest laws covering local and state officials, the honest services fraud statute has become its vehicle for enforcing its view of good government on state and local jurisdictions. The theory is that when a local or state official 1) takes a bribe, or 2) is embroiled in a conflict of interest, he or she defrauds the people of the state or locality of their right to that public official’s honest services. The courts have widely recognized two theories of honest services fraud in public-sector honest services fraud prosecutions: (1) bribery, where a public official was paid, with some type of valued benefit (not necessarily with money), for a particular decision or action, or (2) a failure to disclose a conflict of interest resulting in personal gain (something of value, but not necessarily monetary).

82. The 11th Circuit’s position is that “[p]ublic officials inherently owe a fiduciary duty to the public to make governmental decisions in the public’s best interest. ‘If the official instead secretly makes his decision based on his own personal interests. . . the official has defrauded the public of his honest services.’” United States v. DeVegter, 198 F. 3d 1324, 1328 (11th Cir. 1999) (quoting United States v. Lopez-Lukis, 102 F. 3d 1164, 1169 (11th Cir. 1997) (emphasis added) (internal citation omitted). The First, Fourth, Ninth, and Eleventh Circuit Courts have all held that the federal statute does not limit the meaning of “honest services” to violations of state law.

83. Plaintiffs have been allowed to bring RICO actions for acts of public corruption that resulted in pecuniary (monetary) injury to them. Envtl. Tectonics v. W. S. Kirkpatrick, Inc., 847 F. 2d 1052, 1067 (3d Cir. 1988); (business competitor had standing to challenge defendant’s alleged use of bribery of foreign government officials to obtain contracts), judgment aff’d, 493 U.S. 400 (1990); Town of Kearny v. Hudson Meadows Urban Renewal Corp., 829 F. 2d 1263, 1268 (3d Cir. 1987) (land developer allowed to bring RICO action for injuries sustained from defendants’ bribery of town officials) and Bieter Co. v. Blomquist, 987 F. 2d 1319, 1327 (8th Cir. 1993) (permitting builder to pursue RICO claim where alleged bribery of public officials raised issue of fact concerning proximate cause of builder’s injury from failure to obtain rezoning). Also, all extortion statutes require that a threat must be made to the person or property of the victim. And a threat to harm a person in his or her career, job or reputation, is also an act of extortion.

84. Nowhere in America, does any statute acknowledge eye witness testimony as being the equivalent to physical/material evidence, and thus only witness testimony being substantial enough to accept as corpus delicti evidence needed to prosecute, or litigate an economic offence. If this were the case, sum sufficient evidence (more likely than not) of wrongs being committed, could be obtained merely by FRB contracted/paid agents, seeking to injure consumers physically/monetarily/emotionally for increased illegal spoils going into FRB owned and operated circulation. Consequently, the State of Florida failed to prove a prima facie case based on physical (material) evidence of a crime committed, so the Plaintiff’s conviction in case 22-CF-2324-A is VOID, due to both former state attorney Andrew Warren; Susan Lopez; Lynn Goudie; and Mellissa Grajales (court case 22-CF-2324-A) accepting and using only false agent cop testimony on official government forms with official letterheads and seals attached, when there was a bona fide conflict of interest present, for the purpose of injuring the Plaintiff and his wife, for FRB monetary and retaliatory purposes. Testimony evidence might be admissible if from unbiased witnesses, but it’s NOT material evidence of an offence committed! Many corrupt judges use witness testimony wrongly as if material evidence, but it’s not! If there’s no corpus delicti, thus no physical evidence amounting to a violation of statute, then there’s been no crime committed! TALK IS CHEAP LADIES! Witness testimony has wrongly been used by judges and prosecutors for decades to convict innocent parties for the FRB, which employs biased/bribed/extorted witnesses for illegal FRB profits/gains/retaliations! Consumer injuries occurring in both criminal/civil court cases, due to lying public/private, FRB contracted/paid/bribed agent witnesses, results in HUGE increases in consumers’ monetary losses going to the FRB owners, by way of either government agencies/agents; but mostly by vendor agent thieves; or private agent thieves making FRB purchases with consumers’ stolen moneys on FRB goods at 500% to 1000% mark ups. COPS and JUDGES aren’t neutral unbiased witnesses to crimes to be used in place of physical/material evidence when needing to substantiate statute violations! COPS and JUDGES work for, and are contracted/paid/bribed agents of the FRB, a privately owned and operated funding/investing/organization/cartel/enterprise.

85. Witness testimony often fills gaps when physical evidence is unavailable. It provides firsthand accounts that can corroborate or contradict other non-material evidence. However, its reliability is carefully examined, as human testimony can be falsely made on purpose, due to witnesses being paid by the same entities as the ones who benefit from the testimony. Witnesses are excluded from testifying, if there is a conflict of interest to tell the truth because of who they work for, as is the case with expert witness cops (officers of the court). A conflict of interests will disqualify an expert witness from testifying on behalf of a party (State of Florida). If there’s a concern that an expert witness has, or will illegally provide false testimony to financially benefit their employer, the witness will be disqualified. Any expert can have a conflict of interest. Such a conflict may exist, if the expert has been formerly employed by, or previously hired as, an expert for the opposing side. This is the case with judges, cops and attorneys (officers of the court) working for the State of Florida! They’re all employed by FRB owners/controllers through their FRB contracted/paid/bribed/coerced/extorted/agencies/corporations! Consequently, FRB contracted/paid/bribed/extroted cops, attorneys and judges, working together with FRB owners/controllers as a multilevel retaliatory group against blacklisted consumers, implementing RICO predicate acts on them, is called RACKETEERING, which always results in liability through the 4 Doctrines of law cited! Agent caused physical injuries ALWAYS results in consumer monetary losses, ultimately going to the FRB owners who fund/bribe/extort/invest in just about every mixed market business under the sun. And this makes them MAJOR END RECIPIENTS of hot cash flows during illegal commerce based transactions!

86. The Plaintiff is suing COT, a municipality, which operates under its own local government charter.

87. Sovereign immunity doesn’t apply in this matter to any of the Defendants:

(A). Where there are state and federal operational decisions made as to how policies will be implemented, there’s no governmental sovereign immunity from policy violations! What Jane Castor did through COT/TPD, was adhere to a made up illegal management plan; policy; and operating procedure, while racketeering, which were breaches of state and federal standard mandated ones!

88. Relevant Statements of Fact against the State of Florida (SOF):

89. State of Florida agents A) Andrew Warren; and B) Susan Lopez, wrongly prosecuted the Plaintiff from 3/2022 to 12/2023 in case 22-CF-2324-A, when no crime was committed by anyone except government agents. SOF committed 3 other injuries on the Plaintiff in 2025, but before 8-21-25. These 3 injuries committed in 2025, before 8-21-25, tolls the statute to file on SOF for all the violations committed, by at least another 3 years. And C) Ronald DeSantis from case 25-CA-564 in 5/2025, refused to investigate as his mandatory constitutional duty – – under Florida’s Constitution, Section 6, Article 4: 1) what was on the full Take 5, FHP obtained, murder video of the Plaintiff’s wife; 2) the Plaintiff being exonerated from the false conviction in case 22-CF-2324-A; 3) the Plaintiff having his mother and wife’s murders officially looked into; and 4) the Plaintiff obtaining Mrs. Kimball’s medical records from TGH (again case 25-CA-564). AHCA denied the Plaintiff’s TGH complaint on 7/2025, which requested AHCA to officially order TGH to provide him his wife’s medical records. See Appendix A. To date, the Plaintiff has not obtained these records. Consequently, the Plaintiff is STILL being defrauded by SOF through DeSantis (case 25-CA-564 appealed); AHCA records request denied by ACHA in Appendix A; and FHP not allowing the Plaintiff his wife’s full murder video from case 24-CA-7358, all still denied at the time he files this complaint.

90. This is a lawsuit where the Continuous Tort Doctrine is definitely applicable. The first set of SOF injuries happened in 3/2022 when it through Andrew Warren, wrongly filed the paperwork to prosecute the Plaintiff with nonexistent physical evidence of: 1) neglect and 2) theft violations, filed with his office by DHS through Jane Castor’s local concert (SOF/COT/TPD). Damages from this case lasted until 12/2023 when the Plaintiff was released from jail. The next set of injuries occurred in 5/2025, when SOF through Governor DeSantis, who illegally came into case 25-CA-564 after a default judgment was file on him by the Clerk of the Court of Leon County, requested that Judge Sjostrom illegally dismiss the case to stop the Plaintiff from acquiring more evidence to sue TGH/DHS/COT/SOF; and Jane Castor for any injuries its agents caused him and his wife. Now the Plaintiff can sue TGH for spoliation of evidence in his wife’s aggravated manslaughter (murder).

91. TGH is believed to have intentionally finishing Mrs. Kimball off by committing a breach of its hospital regulatory procedures – – TGH should’ve quickly remove a bone fragment lodged in Mrs. Kimball’s brain. After which ACHA in 7/2025 denied the Plaintiff’s request to order TGH to provide him with his wife’s medical records (Appendix A), wrongly claiming he had supposedly asked ACHA, not TGH, for his wife’s medical records. A total bull chip lie! AHCA doesn’t store medical records from hospitals! The Plaintiff begged ACHA starting in the beginning of 2024 for his wife’s medical records, while Kim Smoak laughed in his ear and then hung up the phone. See Appendix A.

92. SOF was a concert member participant involved with DHS/COT/TPD in this matter, when Jane Castor had authorized the illegal detaining of Mrs. Kimball on 2-23-22, using TPD agent cops. After 3 weeks, Mrs. Kimball was shown the streets by TPD agent cops with nowhere to go and where Attorney Matthew Kimball McDowell found her 3 month later in Pinellas County Florida, living and sleeping on CONCRETE without her medications! If Mrs. Kimball was really SOF’s witness, where was the physical evidence given to them by COT/TPD before or after the Plaintiff’s arrest to prove a crime was committed by him? It certainly wasn’t placed into case file 22-CF-2324-A? If after COT/TPD having given SOF, NO testimony it could use to prosecute the Plaintiff with (no affidavit signed, or audio/video filed in case 22-CF-2324-A, incriminating the Plaintiff in any Florida statute violation), and SOF/COT/TPD/DHS; and Jane Castor knew Mrs. Kimball was disabled and in need of her medications, which her attorney Matthew McDowell provided to her on the streets only once, multiple state and city agents, like Jane Castor; Andrew Warren; Susan Lopez; Lynn Goudie; and Mellissa Grajales, are at least culpably negligent in her aggravated manslaughter (MURDER), by having intentionally violated the survival action statute (F.S. 46.021) by keeping her on the streets, with the false no contact order on her husband, currently still in place!

93. The statute for malicious prosecution is 4 years from the time case 22-CF-2324-A ended under F.S. 95.11. And a complaint for wrongful death, has to be filed 2 years from the date of death. SOF’s second tort committed on the Plaintiff was 5 months before the wrongful death of Mrs. Kimball tolled, which is at the time of the last filed amended complaint. Consequently the defrauding of the Plaintiff by DeSantis in 5/2025; FHP in early 2025; and AHCA in 7/2025, tolls the wrongful death and survival action statutes for suing SOF for another three (3.5) years, with no statute of limitations for crimes committed involving murder under the RICO Act. This gives SOF its 6 months to investigate all the injuries it’s liable for through its agents.

94. Continuous torts – – federal courts have found the statute of limitations must accrue from the date of the last wrongful act where there is another separate wrong committed by the same entity. Leonhard v United States, 633 F. 2d 599, 613 (2d Cir. 1980). Thus, under the continuous violation doctrine, “the limitation period for a continuing offence does not began until the offence, or offences, are completed.” United States v Rivera-Ventura, 72 F. 3d 277, 281 (2d Cir. 1995). The nature of Plaintiff’s claim is such that the 1) continued Fraud on the Court committed by DeSantis; the 2) defrauding of the Plaintiff out of his wife’s medical records by AHCA; and FHP committing a Fraud on the Court to do the Plaintiff out of his wife’s full murder video, all happened in 2025, as well as other facts and information relating thereto, constitutes a continuing tort violation by SOF for at least an addition 3.5 years in both state and federal court. Whether Mrs. Kimball could’ve been saved, had a medical procedure been correctly performed (malpractice), or had the procedure been performed in a timely fashion in accordance with state and federal hospital medical regulations (wrongful death), the wrongful spoliation of records allowed to stand by SOF through AHCA, haven’t been corrected! So the plaintiff is still being injured by SOF. Consequently, SOF is still liable to the Plaintiff for damages resulting from court cases 22-CF-2324-A; 21-CF-006147-A; 24-CA-7358; 25-CA-564; and AHCA – – the Plaintiff was not able to obtain his wife’s medical records to have sued TGH for any particular type of injury within the 2 year statute of limitations. Every time an SOF employee intentionally defrauds the Plaintiff by committing a NEW OFFENCE on him, they monetary injure him, SAVING the FRB moneys due to racketeering. Yes the FRB, because there’s no other reason for FRB contracted/paid/bribed public and private agents intentionally committing frauds on perfect strangers like the Plaintiff and his wife, but to profit their benefactors the FRB!

95. State Attorney Andrew Warren and Susan Lopez illegally prosecuted the Plaintiff with no corpus delicti and no prima facie case made. They had sneaky; obvious; and mean prosecutor Mellissa Grajales; and twisted Judge Goudie, knowingly and intentionally lie for the State of Florida, on record in case 22-CF-2324-A (watch the films in Appendix E), that the Plaintiff had supposedly:

1. Stolen over $50,000 of his wife’s money;

2. Abused his wife by making her relieve herself in a bucket;

3. Didn’t properly care for his wife when she was supposedly disabled under Florida Chapter 825; and

4. The Plaintiff was supposedly his wife’s caregiver, due to a 2012 cancelled guardian advocacy contract, all without producing one bit of physical evidence substantiating these blatant lies!

96. SOF is being sued in state court for dozens of its agents having committed a negligent or intentional tort while acting within the scope of his or her employment, which 1) breached a state government policy (Andrew Warren; Susan Lopez; Lynn Goudie; Mellissa Grajales). And it’s also being sued in federal court, for having 2) implemented a government policy in violation of their duty to the public under the U.S. Constitution. The plaintiff is suing SOF in federal court under, but not limited to the following: 1) Title 28, Chapter 190, Section 5001; 2) (Title 18, Chapter 13, U.S. Codes § 241); 3) Title 42, Chapter 21, Section 1983; and 4) Title 18, Chapter 13, U.S. Code § 241. Punitive damages and attorney’s fees are owed for common law frauds and breaches of fiduciary duties to the public by municipalities. “A public official, acts as trustee for the citizens and the State … and thus owes the normal fiduciary duties of a trustee, e.g., honesty and loyalty to them.” United States v. Kincaid-Chauncey, 556 F. 3d 923, 939 (9th Cir. 2009) (quoting United States v. Silvano, 812 F. 2d 754, 759 (1st Cir. 1987) and United States v. Mandel, 591 F. 2d 1347, 1363 (4th Cir. 1979) (internal quotation marks omitted)).

97. Defendant SOF was working with DHS/COT/TPD; and Jane Castor, through SOF agents Andrew Warren and Susan Lopez, but both of them were adhering to a different set of management plans, polices and operating procedures, a type of racketeering plan for the purpose of injuring the Plaintiff and his wife. So consequently SOF was operating under a different, NON-STANDARD set of operating requirements, due to Jane Castor being technically the director of the local FRB contracted/paid/bribed CONCERT which included Andrew Warren and Susan Lopez.

98. SOF (a municipality) is being sued in state court for its agents/employees (DeSantis; Warren; Lopez; Smoak) having committed culpable and/or intentionally torts while acting within the scope of his or her employment which 1) breached a state government policy. It’s also being sued in federal court for having 2) implemented a state government policy in violation of their duty to the public under the U.S. Constitution – – 1. Title 18, Chapter 13, U.S. Codes § 241; 2. Title 42, Chapter 21, Section 1983; and Title 18, Chapter 13, U.S. Code § 241.

99. Relevant Statements of Fact about Alex Rothschild:

100. Defendant Rothschild is an FRB owner and controller within the Rothschild & Co. banking cartel, and has been a racketeering participant owner and controller under Title 18, Chapter 96, Sections 1962 (b & d) in this matter, through at least his joint investment ventures with the cartel owners of: Chase Manhattan Investment Holdings, LP.; Chase Manhattan BSP Holdings Corp.; Rockefeller Brothers Fund; Rothschild & Co. Continuation Holdings; Rothschild & Co.; State of Florida; and at least shell corporations BlackRock; Vanguard; and State Street. This is because 1) Defendant Rothschild as the CEO of Rothschild & Co. US Inc., personally profits as an owner; controller; and profiteer of the corporations cited above, who has access to some of his family’s assets/resources/holdings/proceeds used for investing in the FRB and FRB commercial subsidiary investment corporations (owned and invested in shell, mergers and acquisitions), and is not a mere shareholder awarded only dividends from any FRB commercial subsidiary investment corporation. Defendant Rothschild funds the FRB through his FRB commercial subsidiary banking investment corporations – – Rothschild & Co., which is funded through its commercial subsidiary investment corporations; and shell corporations, as well as the FRB. Defendant Rothschild is also an owner of some of the Rothschild assets/resources/holdings of the FRB, making up over 40% of the FRB, a private cartel of FRB banking syndicates. Consequently Imputed/Benefactor/AATF Defendant Rothschild, is AS liable to the Plaintiff as the FRB and its agents.

101. Defendant Rothschild through his quasi-government FRB and his FRB commercial subsidiary investment banking corporations, funds and invests in the DHS; SOF; COT; and TPD agencies – – most of the Defendants named in this complaint along with being the benefactor of the presiding judge on this case. Under Section 1962(b) a defendant only has to acquire and interest in, for the control of, an agency or corporation (a public/private business), due to racketeering activities. Davis-Lynch, Inc. v. Moreno, 667 F.3d 539, 550-51 (5th Cir. 2012). And Defendant Rothschild and his family either own or are invested in just about every agency, corporation and agent on the planet!

102. Relevant Statements of Fact against JPMorgan Chase & Co.; Rothschild & Co, and about the Federal Reserve Bank (FRB) and its owners:

103. JPMorgan Chase & Co. agreed to a $92 million settlement with 24 states, including Florida, and the District of Columbia for its alleged role in a nationwide scheme to rig bids and engage in anti-competitive, fraudulent conduct relating to municipal bond derivatives. Florida entities involved in the settlement were: Florida Intergovernmental Finance Commission, Florida Municipal Power Agency, Florida Water Services Corp. Tampa Bay Water Authority, Hillsborough County, Hillsborough County Port District, Florida State Department of Transportation. If there’s moneys being paid out on bond derivatives by a municipal under a FRB banking contract, there’s a thousand other municipals under contract for multiple types of FRB funding and services within the same state, and all of these municipals share hot FRB funds and hot FRB proceeds, thus the term intergovernmental transfers (federal to state; state to local; and local to local/state agencies).

104. Chase; Rothschild and the FRB are liable for all the law violations committed in this matter, using the 4 doctrines of law cited: Vicarious Liability; Imputation; Respondeat Superior; and Continuous Tort; and Section 1349; along with RICO Act violations (predicate acts), when it knowingly and intentionally allowed its contracted/paid/bribed agents to get away with committing them, after being imputed with the knowledge of their agents’ crimes through its agents; and owners/controllers under Section 1962(b & d) – – Imputed John Rockefeller; and Alex Rothschild in 2020 and/or 2025 (Appendix A), yet they only turned a blind eye to them, when they were in a position to take corrective measures. A fraud permitted to stand by an employer, after he or she has knowingly benefited by the fraud, is just as much wrong as an employer knowingly permitting a fraud to be committed by an employee before being benefited. Quick v. Peoples Bank of Cullman Cnty., 993 F. 2d 793, 797 (11th Cir. 1993).

105. This is a RICO case merely because all the Defendants committed racketeering activities which benefited the FRB financially, except for Defendant Dawson. And since this matter involves FRB agents, due to all the Defendants, including Defendant Dawson’s State Farm Insurance Company, being Chase/Rothschild/FRB contracted/paid while they were committing racketeering activities, which profited the FRB owners with their acquired interest in, for control of, the same public/private agencies and corporations involved in this matter, Chase/Rothschild are also being sued for the Plaintiff’s personal injuries sustained, as a result of Chase/Rothschild/FRB agent conversion frauds and tortious interference scams committed by all of the Defendants except Defendant Dawson. There has to be conspiracies to commit RICO predicate acts, with these types of acts having been committed, or there’s no racketeering violation. So the list of racketeering activities committed by Chase/Rothschild/FRB were, and still are, through the same Defendants in this complaint; under the same corresponding Counts; and for committing the same corresponding law violations (allegations). Consequently, Chase/FRB is liable for every injury committed by its contracted/paid agents and owners/controllers (Rockefeller & Rothschild) cited in this complaint.

106. Unfortunately this Court is also a contracted/paid/bribed with his salary and perks FRB agent, who will probably illegally dismiss this complaint with prejudice and be in violation of Fla. Stat. §838.022(a);(b);&(c); 112.3173(e)(6); Sections 1346; 1341; Chapter 817; & 1343; but mainly the RICO Act. The 4 doctrines of law, which give the Plaintiff the same standing to sue the Defendants in this complaint, allows him to also sue Chase/Rothschild/FRB as their BENEFACTOR, due to the Plaintiff having imputed to both John and Alex, the facts of this matter, prior to, and during this state court case (2025). Chase/Rothschild/FRB were directly notified through both John Rockefeller and Alex Rothschild of Chase/Rothschild/FRB agent racketeering activities committed on the Plaintiff and his wife over the past 13 years (see Appendix A). Having done this with the fact the Plaintiff is now having to sue all the owners of Chase through Chase/Rothschild, means John and Alex failed as at least Chase/Rothschild/FRB controllers under Section 1962(b & d), to take corrective measures in stopping the local racketeering still being continuously committed on the Plaintiff and his murdered wife, and paying them restitution. Although any money awarded by a court in this matter will be paid by the Defendants, it’s all being held and used by the FRB owners, but there’s no limit on the amount obtainable from the deep pocketed FRB as an awarded amount.

107. By looking at the facts the Plaintiff imputed directly to John Rockefeller in both 2020 and 2025 (Appendix A), there’s no doubt John was motivated into implementing the Plaintiff’s illegal arrest and his wife’s injuries through Chase/FRB contracted/paid/bribed local government agents, making him the proximate cause of liability for injuries sustained by the Plaintiff and his wife. Alex Rothschild as the current CEO of Rothschild & Co. US Inc. can be readily tied to local agent liability as a CURRENT Chase/Rothschild/FRB benefactor (owner/controller) in this matter, by A) using the 4 doctrines of law cited, along with also B) having been imputed with the facts in this matter (knowledge & intent), thus proving the participating agencies and corporations involved, were contract/paid/bribed through not only Chase/Rothschild/FRB as its funding source, but by Chase/Rothschild commercial subsidiary banking investment corporations, invested in with some assets owned by Defendant Rothschild as a private investment source, with an acquired interest in, for control of, under Section 1962(b & d). So the Plaintiff has tied Chase/Rothschild/FRB contracted/paid agents in this matter to Chase/Rothschild/FRB.

108. Chase/Rothschild/FRB and Chase/Rothschild/FRB commercial subsidiary CONTRACTS with agencies and corporations, are performance driven service contracts for receiving both Chase/Rothschild/FRB funding and Chase/Rothschild commercial subsidiary investment loans with required agency proceeds summited to the Chase/Rothschild commercial subsidiary banks quarterly (Fedwire & Chase/Rothschild commercial subsidiary banks). FRB quasi-government funding (intra & intergovernmental transfers, see Appendix D) flow through the Treasury to agencies to perform daily services, which also routes their municipal proceeds back to pay the Chase/Rothschild commercial subsidiary banking investment corporations, its interest on loans, with defrauded consumers always used as the collateral on both the funding and investing CONTRACTS. These CONTRACTS are for FRB moneys used to pay for, but not limited to, infrastructure costs; law enforcement salaries; judicial salaries; and perk money payments, in return for agent performance, and this is what binds and solidifies FRB contracted/paid agents to Chase/Rothschild owners in a corrupt racketeering banking relationship (Appendix D), even though we don’t know who all the FRB owners are, but under the RICO Act, the private owners of the quasi-government FRB and their mainly Chase/Rothschild commercial subsidiary businesses, which do business with the FRB; agencies; and corporations involved in this matter, are one in the same entity.

109. The FRB may be sued in any appropriate state or district court pursuant to 28 U.S.C. 1338, which means the FRB is a person not a government entity, which grants state and federal courts jurisdiction to hear lawsuits against it, period. So the Plaintiff has standing to sue the FRB owners through Chase/Rothschild, when they knowingly and intentionally funds/invests hot stolen proceeds within all agencies and most major corporations in America, through their quasi-government and commercial subsidiary banking corporations, who’ve acquired an interest in, for the control of, as many public/private businesses as it can within the state of Florida, due to racketeering activities (Title 18, Chapter 96, Sections 1962(b & d). Under the RICO Act, the businesses; the enterprise; and its owners, are one in the same entity. This also means the FRB’s contracted/paid agents’ illegal actions committed while under CONTRACT to perform for the FRB and Chase/Rothschild commercial subsidiary banking investment corporations, by generating hot stolen income for them through conversion and tortious interference scams committed on the Plaintiff, and a million other consumers, allow Chase/Rothschild/FRB be sued by the Plaintiff under the: 1) Respondeat Superior Doctrine; 2) Imputation Doctrine; 3) Vicarious Liability Doctrine; 4) Continuous Tort Doctrine; and 5) Section 1349. The FRB owners/controllers require and achieve production of hot stolen income mainly through their JUDICIAL and POLICING agents operating in courthouses, after official consumer complaints are filed, using bribes (Section 201) and extortion (Section 1951) tactics implemented by governors and federal appointees, as seen in local cases 22-CF-2324-A; 21-CF-006147-A; 25-CA-564; and 24-CA-7358.

110. Chase/Rothschild/FRB uses bribes and extortion methods (the motivational factor behind the predicate acts committed, not an allegation related to any Count yet) on elected officials it helped put in office, for the purpose of maintaining conversion frauds (F.S. 812.014) and tortious interference scams (F.S. 768.72/§§ 95.11(3)(o & p), implemented on consumers to illegally increase FRB owner profits and gains, with FRB owner/controller knowledge and approval through state governors (case 25-CA-564). See Appendix A. Many owners/controllers of the FRB were directly noticed by the Plaintiff in early 2025 of their agents’ scams, but they only turned blind eyes (acquiesced) to taking the proper corrective measures in remedying the wrongs committed by their agents. So now Chase/Rothschild are being sued for their agents’ wrongs committed (Counts). The wrongful conduct by the Chase/Rothschild, acting through its agents, after the fact (AATF) as IMPUTED employers, makes them guilty under Respondeat Superior; Imputation; and Vicarious Liability for the Plaintiff and his wife sustained injuries, as if it they had permitted the frauds beforehand!

111. Chase/Rothschild commercial subsidiary CONTRACTS to perform services for receiving Chase/Rothschild investment moneys with required agency/corporate proceeds summited to them quarterly (Fedwire & Chase/Rothschild commercial subsidiary banks); and 2) the flow of FRB quasi-government funding (intra and intergovernmental transfers, see Appendix D) to agencies to perform daily services, also routes their municipal proceeds back to Chase/Rothschild to pay the interest on their Chase/Rothschild subsidiary loans, with defrauded consumers always used as the collateral on both the investing and funding CONTRACTS. These CONTRACTS are for FRB moneys used to pay for, but not limited to, infrastructure costs; law enforcement salaries; judicial salaries; and perk money payments, in return for agent performance in racketeering activities involving honest services frauds; wire; and mail misrepresentation, committed during cases 22-CF-2324-A; 21-CF-006147-A; 25-CA-564; and 24-CA-7358. These self-renewing agency performance contracts for moneys, are what binds and solidifies Chase/Rothschild/FRB agents to the FRB owners in a corrupt racketeering banking relationship. These contracts are performance based ones with penalties (extortions) for non-production, using consumers as both the collateral on Chase/Rothschild notes and the premiums acquired by fleecing them. Thus Chase/Rothschild/FRB controls the largest resource on the planet, injured for obtaining maximum amounts of profits, and used as the source of surety/collateral by elected agency managers in securing banking contract with Chase/Rothschild commercial subsidiary banks. There isn’t one agency that doesn’t do this! See Appendix D.

112. Thus the Plaintiff has standing to sue any Chase/Rothschild/FRB owners/controllers, at least under Title 18, Chapter 96, Sections 1962(b as controllers & d as conspirators) as an organization/cartel/association-in-fact enterprise.

113. Since the privately owned Chase/Rothschild companies 1) are invested in 95% of all the banks and major conglomerates in America, due to mergers and acquisitions with other cartel members, it basically owns the American economy (see Appendix D), so it’s able to not only obtain a defrauded consumer’s moneys once through thieving vendor agents involved in conversion frauds, but multiple times on the same goods and services needed to be consumer purchased again and again, illegally using its administrative/judicial agents, like banking chairmen and judges, to officially launder the loot home to the FRB owners and their commercial investment corporations. By the FRB owners/controllers sanctioning their contracted/paid agents’ crimes, by turning blind eyes to defrauded consumers’ complaints, consumers have to spend MORE moneys on vendor agent thieves’ goods and services. Consequently, the Rockefellers and Rothschilds, who own the majority of the assets/resources/holdings within the FRB (85%), knowingly and intentionally acquire consumers’ hot stolen moneys through their mixed market, investment corporations, invested in by other cartel members 95% of the time, for increased repetitive use of consumers’ stolen and owed moneys, which are vendor and private agent thieve deposited immediately as seen on ledger sheet transfers into FRB commercial subsidiary banks within merchant accounts. VERY SLICK!

114. Relevant Statements of Fact against Defendant Crist:

115. Defendant Crist is the Clerk of the Court and Comptroller for the 13th Judicial Circuit and is paid by Hillsborough County authorized by its BOCC, a public agency contracted and paid for by the FRB Cartel and FRB commercial subsidiary investment banking corporations.

116. Case 25-CA-8096 was filed on the FRB parent corporation, through its agent branch in San Francisco, CA., not on this branch, and Defendant Crist and his agents knew this, yet the style of the case in Fisher & Phillip LLP was wrong. Kathleen Rocamora at 813-460-6710, was involved in this murder cover-up of Mrs. Kimball, and the cover-up of the intentional torts sanctioned by Defendant Crist, when she falsely told the Plaintiff that Judge Barber had case 25-CA-8096 removed from state court and that the federal case was already open! This can’t legally happen.

117. The FRB had its local paid attorneys at Fisher & Phillips, LLP, illegally demand the Clerk of the Court, Defendant Crist and his agents there, to illegally transfer case 25-CA-8096 to the Middle District of Florida immediately and without a hearing! Had a hearing been scheduled, but after all parties were served, the Plaintiff would’ve told Judge Nash that he was already suing four (4) parties from case 15-CA-8096, in the middle district, case 25-CV-2181, and would’ve gladly dropped the FRB from the state case due to 12 USC Statute 632.

118.1 In mid-11/2025, Defendant Crist’s office was contacted at 813-307-7027 (Amy) a dozen times by the Plaintiff with messages left a week before the his state case was illegally dismissed in case 25-CV-3077, but prior to this, Crist intentionally never had the Plaintiff’s case file transferred back to state court, ignoring his phone calls.

118.2 Defendant Crist committed intentional torts on the Plaintiff through his agents working at the 13th Judicial Circuit in 11/2025. This complaint is against Defendant Crist, not the local state courthouse or its employees.

Relevant Statements of Fact against Defendant Crist:

***118.5 State courts must entertain federal claims, but not for the purpose of enforcing the right, as if the state court was to be treated as a Federal court. Consequently all statute violations are cited, but the Defendant only have to answer to their state violations.

119. Counts; with elements of; and statute violations for Defendant Dawson:

120. Plaintiff repeats and realleges the allegations and legal precedence set forth in paragraphs 1 through 42; and 43 through 49 as if fully set forth herein.

The Plaintiff is seeking compensation (relief) from Defendant Dawson due to being Mrs. Kimball’s spouse.

The specific criminal/civil violations Defendant Dawson committed with his unidentified passenger, which injured the Plaintiff and his wife, as at least reasonably proven probable (sum sufficient) in the Appendices:

Count 1: Wrongful Death (768.16) – – against Dawson and his passenger;

121. Dawson and his passenger are seen in both the full FHP and enclosed partial FHP video, striking down Mrs. Kimball with his car, while she was walking within a crosswalk with the right of way, due to being a pedestrian under F.S. 316.130(9);

Count 2: Wrongful Death Damages ((768.21) – – against Dawson and his passenger;

122. Dawson and his passenger are both liable for culpable or intentional injuries sustained by Mrs. Kimball when they both contributed to violating F.S. 316.130(9), by apparently looking to cause her some sort of injure on purpose;

Count 3: Survival Action (46.021 & 3.5 days) – – against Dawson and his passenger;

123. Dawson and his passenger caused Mrs. Kimball’s survival action damages after the accident they caused, because her death was not immediate, lasting 3.5 days;

Count 3: Aggravated Manslaughter under F.S. 782.07(1), by violation of F.S. 316.130(9) – – against Dawson and his passenger;

124. Dawson was at least culpable or intentional in having caused Mrs. Kimball’s injuries, as seen in the partial video, along with witness testimony that the vehicular injuries to Mrs. Kimball were culpably or intentionally caused by Dawson and his occupant, because Dawson’s car never slowed down until he violated F.S. 316.130(9), by hitting Mrs. Kimball;

Count 4: RICO Act violation under Title 18, Chapter 96, Sections 1962(c & d) as an association-in-fact members – – against Dawson and his passenger;

125. Dawson was acting in concert with at least his fleeing passenger as an association-in-fact enterprise under Title 18, Chapter 96, Sections 1962(c & d), out to injure Mrs. Kimball for supposedly stealing their street drugs, according to credible testimony from a dozen witnesses, which will be sum sufficiently proven, or this Count will be removed after discovery, when Dawson’s passenger is also identified with his deposition taken;

Relief sought:

126. Money amounts the Plaintiff’s seeking from Defendant Dawson and his passenger in this complaint, are for personal injuries:

A. Economic damages amount to roughly $400,000. USD for Mrs. Kimball’s lost SSI income from age 41 to 75 (34 years’ worth);

B. punitive and non-economic amounts for the Plaintiff’s own personal pain and suffering, along with Mrs. Kimball’s personal injury – – 3.5 days’ of being made to survive at TGH without the proper treatments given at the proper time, totaling well over $60. million USD, by referencing verdicts on similar federal and state violations, where there’s a capable or intentional tort to injure.

127. Counts; with elements of; and statute violations for Defendant TGH:

128. Plaintiff repeats and realledges the allegations and legal precedence set forth in paragraphs 1 through 42; and 50 through 62 as if fully set forth herein.

The Plaintiff is seeking compensation (relief) from Defendant TGH due to being Mrs. Kimball’s spouse; and under the Law of Agency; Imputation; Respondeat Superior; and Vicarious Liability Doctrines;

The specific criminal/civil violations Defendant TGH is liable for through its owner John Couris and his TGH staff members, which injured the Plaintiff and his wife, as at least reasonably proven probable (sum sufficient) in the Appendixes:

Count 1: TGH owner and FRB contracted/paid agent John Couris through the State of Florida, is a TGH perpetrator/owner under Title 18, Chapter 96, Sections 1962(c & d) – – a TGH concert level position – – against TGH;

129. TGH was racketeering in concert with the FRB funded State of Florida, through Ronald DeSantis as TGH’s source of funding and investing, again the FRB, by illegally keeping medical information about the murder of Mrs. Kimball from her husband, violations of state and federal laws under the RICO Act (predicate acts committed under, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; and Chapter 817;

Count 2: Wrongful Death (768.16) – – under – – against TGH;

130. TGH is liable for any pain; suffering; and death that it caused Mrs. Kimball, by not acting properly according to hospital policies; procedures; and regulatory standards;

131. TGH covering up evidence of her murder as an AATF, to protect Dawson & his passenger; the FRB; and FRB affiliates like TGH from liability;

Count 3: Wrongful death Damages (768.21)are owed – – against TGH;

132. TGH is liable to compensate for any pain; suffering; and death that it caused Mrs. Kimball, by not acting properly according to hospital policies; procedures; and regulatory standards; and by covering up evidence of her murder as an AATF, to protect Dawson and his passenger; the FRB; and FRB affiliates like TGH from liability;

Count 4: Survival Action (for 3.5 days under F.S. 46.021) – – against TGH;

133. TGH is liable to compensate for any pain; and suffering it caused to Mrs. Kimball for 3.5 days by not acting properly according to hospital policies; procedures; and regulatory standards; and by covering up evidence of her murder as an AATF, to protect Dawson; the FRB; and FRB affiliates like TGH from liabilities;

Count 5: Tortious Interference under F.S. 768.72/§§ 95.11(3)(o & p) – – against TGH;

134. 1) TGH is liable for any intentional or culpable,, acts or omissions, which caused injuries to Mrs. Kimball, when it spoliated critical evidence of her murder (culpable or intentional);

135. 2) TGH is liable as an accessory after the fact (AATF) in at least the aggravated manslaughter of Mrs. Kimball, for concealing medical record evidence directly at TGH, and in case 24-CA-7358, by violating Sections 1341; 1343; 1346; Chapter 817; and Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6) – – mail; wire; and honest services frauds as an accomplice with the judge in case 24-CA-7358;

136. 3) John Couris through TGH, was the managing TGH agent participants under Title 18, Chapter 96, Sections 1962(c & d);

137. 4) John Couris was working in concert as an FRB funded and invested in association-in-fact enterprise member during case 24-CA-7358 with SOF (FHP) as another party to this case; and with FRB contracted/paid Ronald DeSantis, the respondent in case 25-CA-564, to conceal Mrs. Kimball’s medical records from the Plaintiff during TGH case 24-CA-7358 and directly at TGH;

Count 6: 14th amendment right violation – – TGH is liable for violating the Plaintiff’s 14th amendment rights, due to having committed a violation of F.S. 395.3025(1) (medical records request) – – against TGH;

138. TGH violated F.S. 395.3025(1) and the 14th amendment rights of the Plaintiff directly at TGH, when no probate actions were in effect, only the Plaintiff supposedly not being Mrs. Kimball’s husband, with the local Clerk of the Court having recorded the 2010 marriage certificate as authentic;

Count 7: Honest Services Fraud violations – – TGH committed honest services frauds under Fla. Stat. §838.022(a);(b);&(c); 112.3173(e)(6); and federal Sections 1341; 1343; Chapter 817; and 1346 directly at TGH and during case 24-CA-7358 (private and public scams to defraud Plaintiff out of honest services directly at TGH; and in case 24-CA-7358) – – against TGH;

139. TGH committed state and federal honest services frauds violations directly at TGH and in court case 24-CA-7358, by misrepresenting to the Plaintiff; the court; and many others, that the Plaintiff wasn’t married to Mrs. Kimball to conceal her medical records from him, to apparently save TGH; State of Florida; and there FRB funding and investing source moneys;

Count 8: 5th amendment right violations in court case 24-CA-7358 – – against TGH;

140. TGH deliberately misrepresented a few times to the court during case 24-CA-7358, that the Plaintiff wasn’t married to Mrs. Kimball, when it had in possession a filed copy of Mrs. Kimball’s marriage license prior to this Pure Bill of Discover case;

Count 9: TGH has standing to be sued for its agents perpetrated wrongs on all Counts, due to the Law of Agency; Vicarious Liability; Imputation; and Respondeat Superior Doctrines – – against TGH;

141. TGH agents violated both the plaintiff’s 5th amendment rights in case 24-CA-7358 and his 14th amendment rights directly at TGH, by concealing his wife’s medical records from him. TGH also has standing to be sued for all its agents’ perpetrated wrongs, due to the Law of Agency; Vicarious Liability; Imputation; and Respondeat Superior Doctrines. Any wrongful acts committed by TGH employees while Mrs. Kimball was under their Duty of Care, allows either John Couris or TGH, to be sued for Mrs. Kimball’s damages;

Count 10: Florida Chapter 843, Obstructing Justice 843.14, Compounding Felony violation – – against TGH;

142. TGH knowingly and intentionally committed a criminal violation of obstructing justice when it concealed Mrs. Kimball’s medical records to benefit TGH; and its funding and investing sources – – the State of Florida and the FRB, because she was in fact murdered, which involved FRB contracted/paid government agents and the FRB;

Count 11: Fraud on the Court violation in case 24-CA-7358 (F.S. 1540) – – against TGH;

143. TGH knowingly and intentionally committed a Fraud on the Court in court case 24-CA-7358, when it stated orally and in writing, the Plaintiff wasn’t married to Mrs. Kimball;

Count 12: Title 42, Chapter 21, Section 1983 violations – – TGH worked with FRB contracted/paid Governor DeSantis under contract as a State of Florida affiliate/accomplice in denying Mrs. Kimball’s medical records to the Plaintiff – – against TGH;

144. DeSantis; John Couris; and TGH were working together to deny the Plaintiff his wife’s medical records during cases 24-CA-7358 and 25-CA-564 (they were involved in both cases). This ultimately benefited only their funding and investing source, the FRB;

Count 14: Spoliation of medical records under FloridaRCP 1.380(b)(2)F) – – against TGH;

145. TGH is liable for all of Mrs. Kimball’s injuries as if it caused them, by spoliating her medical record evidence as to who was involved in causing her death the most, either Defendant Dawson or TGH.

Relief sought:

146. Money amounts the Plaintiff’s seeking from Defendant TGH in this complaint for personal injuries:

A. Economic damages amount to roughly $400,000. USD for Mrs. Kimball’s lost SSI income from age 41 to 75 (34 years’ worth);

B. punitive and non-economic amounts for the Plaintiff’s own personal pain and suffering, along with Mrs. Kimball’s personal injury – – 3.5 days’ worth by being made to survive at TGH without the proper treatments given at the proper time, total well over $60. million USD, by referencing verdicts on similar federal and state violations.

147. Counts; with elements of; and statute violations for Defendant COT:

148. Plaintiff repeats and realleges the allegations and legal precedence set forth in paragraphs 1 through 42; and 63 through 87 as if fully set forth herein.

The Plaintiff is seeking compensation (relief) from Defendant COT, due to being Mrs. Kimball’s spouse; under the Law of Agency; Imputation; Respondeat Superior; and Vicarious Liability Doctrines; and for being the defendant in case 22-CF-2324-A:

The specific criminal/civil violations Defendant COT is liable for through Jane Castor and her local concert of SOF/COT/TPD participating agents in this matter (Appendix B), which injured the Plaintiff, as at least reasonably proven probable (sum sufficient) in the Appendixes:

Count 1: COT employee and FRB contracted/paid agent Jane Castor, an COT perpetrator/manager of her local concert (COT/TPD/SOF), under Title 18, Chapter 96, Sections 1962(c & d) – – a COT concert level position – – against COT;

149. Jane Castor was racketeering in concert with COT; SOF; DHS; and TPD agents, to illegally injure both the Plaintiff and his wife physically, emotionally and monetarily, violations of state and federal laws under, but not limited to, RICO predicate acts committed in violation of Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and federal Sections 1346; 1341; 1343; Chapter 817; and 1513 (honest services frauds committed for retaliatory purposes);

Count 2: Wrongful Death (768.16) of Mrs. Kimball, due to SOF/COT/TPD having relocated Mrs. Kimball to the streets of Clearwater; Tampa; and Brandon, Florida, telling her each time not to go home, which lasted for 1.5 years until her murder – – against COT;

150. COT is liable for TPD having relocated Mrs. Kimball to the streets of Clearwater; Tampa; and Brandon, Florida, telling her each time not to go home, which lasted for 1.5 years until her murder, due to an illegal no contact order on her husband, required in abuse cases, with no one removing this false order still in place, when the Plaintiff had asked his attorneys to do so, along with Mrs. Kimball having asked Matthew McDowell, Esq. to do so (due diligence). Matthew McDowell was the one who wrote Mrs. Kimball’s affidavits for her to sign, and had them to file, but never submitted them with a hearing request (Appendix A), but Mrs. Kimball’s murder was mainly due to FRB/DHS contracted/paid Jane Castor; and COT/SOF/TPD all being joint and several liability partners in the intentional frauds committed on the Plaintiff and his wife, when all agents involved knew no crime was committed in case 22-CF-2324-A;

Count 3: Wrongful Death Damages (768.21) are owed, due Mrs. Kimball being forced off her medications and made to live on the streets by SOF agents – – against COT;

151. COT through TPD, was a coconspirator with DHS/SOF, when it initiated the illegal search; arrest; prosecution; process; murder; and survival action damages committed in this matter, when it knew no crime was committed in case 22-CF-2324-A. COT is liable for all damages to the Plaintiff and his wife through its employees, due to the Law of Agency; Imputation; Respondeat Superior; and Vicarious Liability Doctrines, when it knew no crime was committed in case 22-CF-2324-A;

Count 4: Survival Action for 1.5 years (46.021) – – against COT;

152. Due to Mrs. Kimball being forced off her medications and made to live on the streets by COT agents, due to being told by TPD from 3/2022 to 8-19-23, not to go home because of the false no contact order on her husband, when it knew no crime was committed in case 22-CF-2324-A, COT is liable for any pain and suffering its employees caused Mrs. Kimball, by wrongly making her live on the streets for 1.5 years, due to an illegal no contact order on her husband, not on her;

153. And Mrs. Kimball, due to the no contact order being ONLY on her husband, was legally allowed to continue living at home, when the Plaintiff was the sole owner of the property and technically didn’t have to leave;

Count 5: F.S. 782.07(1) (aggravated manslaughter) Jane Castor; and COT, through TPD, knowingly and intentionally put Mrs. Kimball in need of the bare necessities in order to survive, on the streets to live in Clearwater, then again in Tampa, then again in Brandon, for SOF to continue wrongly prosecuting the Plaintiff for violations of probation, when Mrs. Kimball would keep legally returning to her house, turning a blind eyes to her suffering from 2-22 to 8/23, when it knew no crime was committed in case 22-CF-2324-A – – against COT;

154. COT is at least capably negligent in the aggravated manslaughter of Mrs. Kimball, with Jane Castor placed permanently in a prison cell, due to no crime having been committed in case 22-CF-2324-A;

Count 6: The Plaintiff’s False Imprisonment by COT for 225 Days, a violation under Florida Statute 787.02 – – against COT;

155. COT, due to it being a racketeering participant in this matter under the RICO Act, violations of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; Chapter 817; and Title 18, Chapter 73, Sections 1513(e & f), is liable for the Plaintiff’s False Imprisonment, when it helped wrongly put him in jail three (3) times, when it knew no crime was committed in court case 22-CF-2324-A;

Count 7: Malicious Prosecution of the Plaintiff, by COT employee Jane Castor’s local concert – – against COT;

156. Both DHS; and Jane Castor orchestrated and initiated this illegal matter through COT/TPD/SOF. So participant COT/TPD was in violation of, but not limited to, under Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; Chapter 817; and Title 18, Chapter 73, Sections 1513(e & f). So COT’s liable for the Malicious Prosecution of the plaintiff during case 22-CF-2324-A, when it knew no crime was committed;

Count 8: Abuse of Process of the Plaintiff, by COT employee Jane Castor’s local concert – – against COT;

157. Both DHS; and Jane Castor orchestrated and initiated this illegal matter through COT/TPD/SOF. So participant COT/TPD was in violation of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; Chapter 817; and Title 18, Chapter 73, Sections 1513(e & f). So COT’s liable for the Malicious Prosecution of the plaintiff during case 22-CF-2324-A, when it knew no crime was committed;

Count 9: Fraud on the Court (F.S. 1540 and Rule 60(b) in federal court) in court cases 22-CF-2324-A was committed by COT, due to being a participant under the RICO Act with DHS/SOF/TPD; and Jane Castor, violations of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; Chapter 817; and Title 18, Chapter 73, Sections 1513(e & f), when no crime was committed in case 22-CF-2324-A – – against COT;

158. COT was a concert member involved in the prosecution of the Plaintiff, when Judge Goudie defrauded the Plaintiff herself, and allowed SOF to do the same in her kangaroo court, as if deaf, dumb and blind, acting as a racketeering participant under the RICO Act, violations of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; Chapter 817; and Title 18, Chapter 73, Sections 1513(e & f), when no crime was committed in case 22-CF-2324-A – – against COT;

Count 10: Title 18, Chapter 73, Section 1513, an FRB retaliation crime initiated by DHS; and Jane Castor through SOF/COT/TPD (Jane Castor’s local concert) – – against COT;

159. COT was working in concert with Jane Castor; DHS/SOF/TPD to commit retaliatory acts for the purpose of physical; emotional; and monetary injuring the Plaintiff and his wife, committed in violation of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; Chapter 817; and Title 18, Chapter 73, Sections 1513(e & f), when no crime was committed in case 22-CF-2324-A, implemented by the John Rockefeller and his think tank, after the Plaintiff threatened to sue the FRB through John in 2020 for obtaining his laundered inheritance beginning around 2000;

Count 11: COT has standing to be sued for agent perpetrated wrongs on all Counts, due to the Law of Agency; Vicarious Liability; Imputation; and Respondeat Superior Doctrines – – against COT;

160. COT is liable for any of its employees’ wrongful actions and omissions which caused the Plaintiff and his wife damages, due to Vicarious Liability; Imputation; Respondeat Superior Doctrines and the Law of Agency;

Count 12: Fla. Stat. §838.022(a);(b);&(c); §112.3173(e)(6); & Section 1346 – – private and public scams to defraud Plaintiff and his wife out of honest services, implemented by the FRB, and initiated through DHS/SOF/TPD/COT in cases 22-CF-2324-A; & 21-CF-006147-A – – against COT;

161. COT is in violation of both state and federal honest services, committed by any and all of its employees during cases 22-CF-2324-A; & 21-CF-006147-A, starting from 2-22, due to it being a racketeering participant under the RICO Act, violations of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; Chapter 817; and Title 18, Chapter 73, Sections 1513(e & f), when no crime was committed in case 22-CF-2324-A;

Count 13: Title 18, Chapter 63, Section 1349 (attempt and conspiracy) – – against COT;

162. COT is liable for the false search warrant; false imprisonment; malicious prosecution; abuse of process; wrongful death; and survival action for 1.5 years, committed by Jane Castor; and DHS;SOF;COT/TPD, on the Plaintiff and his wife during case 22-CF-2324-A, when it knew no crime was committed;

Count 14: Title 18, Chapter 13, U.S. Codes § 241, conspiracy against the rights of the Plaintiff and his wife – – against COT;

163. COT is liable for the false search warrant; false imprisonment; malicious prosecution; abuse of process; wrongful death; and survival action for 1.5 years, committed by Jane Castor; and DHS;SOF;COT/TPD, on the Plaintiff and his wife during case 22-CF-2324-A, when it knew no crime was committed;

Count 15: Title 42, Chapter 21, Section 1983, assisting in wrongs committed by any government agency or agent – – against COT;

164. COT is liable for the false search warrant; false imprisonment; malicious prosecution; abuse of process; wrongful death; and survival action for 1.5 years, committed by Jane Castor; and DHS;SOF;COT/TPD, on the Plaintiff and his wife during court case 22-CF-2324-A, when it knew no crime was committed;

Count 16: COT is liable for theft; conversion; and destruction of the Plaintiff and his wife’s properties within their house by TPD, under F.S. 771.11(1) & 812.014 – – against COT;

165. COT committed theft; conversion; and destruction of Plaintiff and his wife’s properties within their house through TPD, so it now owes the Plaintiff 50% on $60,000. USD, before and during case 22-CF-2324-A (crimes committed on both 2-24-22 & 7-26-23).

Count 17: 4th amendment right violations – – against COT;

160. FRB/DHS/COT/SOF through TPD violated the Plaintiff and his wife’s rights to not have their house searched; property stolen; converted; and damaged during 3 illegal TPD searches; and a fourth (4) illegal one by federal marshals after Judge Lynn Goudie issued a false warrant for the Plaintiff’s arrest, because he supposedly knew his wife was around the corner at the northern intersection from his home address, when he was driving his car down his block. Marshals used his illegally obtained house keys from within his pocket for 45 minutes, to go to his house and search it, permanently keeping his wallet with its full contents, possibly for SOF/COT/TPD to go through, but it was never to be seen by the Plaintiff again;

166. Due to Jane Castor; FRB/SOF/COT/TPD, an illegal concert, the Plaintiff was illegally arrested on: 2-24-22; and again by federal marshals on the street a few months later, complements of criminal minded Lynn Goudie; and a third time on 7-26-23;

167. FRB/SOF/COT/TPD; and Jane Castor, illegally imprisoned the Plaintiff for 225 days in total;

168. Jane Castor; and FRB/DHS/SOF/COT/TPD agents illegally removed Mrs. Kimball from her home, or made her leave it, each time they found her at home, keeping her on the streets to be foreseeably injured or killed.

Relief sought:

169. Money amounts the Plaintiff’s seeking from Defendant COT in this complaint for personal injuries:

A. Economic damages amount to roughly $400,000. USD for Mrs. Kimball’s lost SSI income from age 41 to 75 (34 years’ worth);

B. 50% shared expense by SOF; and TPD, in $60,000. USD owed, for TPD stealing and damaging $20,000. USD of the Plaintiff and his wife’s properties within their home, during two (2) illegal TPD searches, implemented on 2-24-22 & 7-26-23, violations under F.S. §772.11 (1), 5 year statute of limitations, see court documents Appendix B. COT has now been given 30 days to pay the Plaintiff $30,000. USD. (Appendix B & court case 22-CF-2324-A) (Attorney Joseph Davis, the Plaintiff’s former attorney, is a witness to the thefts and damages);

C. 50% shared expense by TPD; and SOF, in TPD’s illegal search of Plaintiff’s house on 7-26-23, due to no search warrant while still being illegally prosecuted by SOF up until 12/2023, costing him $3,500. USD in legal fees from Attorney Joseph Davis – – so $1,750 USD is the amount both SOF and COT owe the Plaintiff;

D. the Plaintiff’s punitive and non-economic amounts for his own personal pain and suffering, along with Mrs. Kimball’s personal injury – – 1.5 years’ of being made to survive on the streets by FRB/DHS/SOF/COT/TPD; and Jane Castor, all non-economic/punitive, intentional/culpable, torts/scams, all committed by FRB contracted/paid agents, total well over $60. million USD, by referencing verdicts on similar federal and state violations.

170. Counts; with elements of; and statute violations for Defendant SOF:

171. Plaintiff repeats and realleges the allegations and legal precedence set forth in paragraphs 1 through 42; 63 through 87; and 88 through 98 as if fully set forth herein.

The Plaintiff is seeking compensation (relief) from Defendant SOF due to being Mrs. Kimball’s spouse and under Law of Agency; Imputation; Respondeat Superior; and Vicarious Liability Doctrines; and for being the defendant in bogus case 22-CF-2324-A:

The specific criminal/civil violations Defendant SOF is liable for committing through Andrew Warren; Susan Lopez; Ronald DeSantis; and Kim Smoak, which injured the Plaintiff and his wife, as at least reasonably proven probable (sum sufficient) in the Appendixes – – against SOF;

Count 1: Andrew Warren; Susan Lopez; Ronald DeSantis; and Kim Smoak – – SOF perpetrators/managers of Jane Castor’s local concert under Title 18, Chapter 96, Sections 1962(c & d) – – SOF concert level position – – against SOF;

172. SOF was racketeering in concert with Jane Castor; and DHS/COT/TPD, before and during cases 22-CF-2324-A and 21-CF-006147-A, to illegally injure both the Plaintiff and his wife physically, emotionally and monetarily, due to it being a racketeering participant under the RICO Act, violations of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; Chapter 817; and Title 18, Chapter 73, Sections 1513(e & f), when no crime was committed in case 22-CF-2324-A – – against COT;

Count 2: Wrongful Death (768.16) of Mrs. Kimball, due to SOF/COT/TPD having relocated Mrs. Kimball to the streets of Clearwater; Tampa; and Brandon, Florida, telling her each time not to go home, which lasted for 1.5 years until her murder – – against SOF;

173. SOF is liable for the illegal no contact order on her husband, required in abuse cases, with no one removing this false order still in place, when the Plaintiff had asked his attorneys to do so, along with Mrs. Kimball having asked Matthew McDowell, Esq. to do so (due diligence). Matthew McDowell was the one who wrote Mrs. Kimball’s affidavits for her to sign, and had them to file, but never submitted them with a hearing request (Appendix A), but Mrs. Kimball’s murder was mainly due to FRB/DHS contracted/paid Jane Castor; and COT/SOF/TPD all being joint and several liability partners in the intentional frauds committed on the Plaintiff and his wife, when all agent involved knew no crime was committed in case 22-CF-2324-A;

Count 3: Wrongful Death Damages (768.21) are owed, due Mrs. Kimball being forced off her medications and made to live on the streets by SOF agents – – against SOF;

174. SOF was a coconspirator working in conjunction with DHS/COT/TPD agents, who told Mrs. Kimball she couldn’t go home from 3.2022 to 8-19-23, because of the false no contact order on her husbands. SOF was a concert member which helped initiate the illegal search; arrest; prosecution; process; murder; and survival action damages committed in this matter. SOF is liable for all damages to the Plaintiff and his wife through its employees, due to the Law of Agency; Imputation; Respondeat Superior; and Vicarious Liability Doctrines, when it knew no crime was committed in case 22-CF-2324-A;

Count 4: Survival Action for 1.5 years (46.021), due to Mrs. Kimball being forced off her medications and made to live on the streets by SOF agents, working in conjunction with Jane Castor; and DHS/COT/TPD agents telling her from 3/2022 to 8-19-23, she couldn’t go home because of the false no contact order on her husband, when it knew no crime was committed in case 22-CF-2324-A – – against SOF;

175. Due to Mrs. Kimball being forced off her medications and made to live on the streets by SOF agents working in conjunction with COT/TPD agents telling her she from 3/2022 to 8-19-23, not to go home because of the false no contact order on her husband, when SOF knew no crime was committed in case 22-CF-2324-A, SOF’s liable for any pain and suffering its agents caused Mrs. Kimball, by wrongly making her live on the streets for 1.5 years, due to an illegal no contact order on her husband, not on her;

176. And Mrs. Kimball, due to the no contact order being ONLY on her husband, was legally allowed to continue living at home, when the Plaintiff was the sole owner of the property and technically didn’t have to leave;

Count 5: F.S. 782.07(1) (aggravated manslaughter) a violation by DHS, whose affiliated concert members: Jane Castor; and her local concert of DHS/SOF/COT/TPD agents, were being financially supported by the FRB and the FRB through DHS, which knowingly and intentionally had Jane Castor’s concert keep Mrs. Kimball in need of the bare necessities in order to survive, on the streets of Clearwater, then again in Tampa, then again in Brandon, so SOF could continue prosecuting the Plaintiff for violations of probation, when Mrs. Kimball would keep returning to her house, turning a blind eyes to her suffering from 2-22 to 8/23, violations of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; Chapter 817; and 1513, when no crime was committed in case 22-CF-2324-A. Title 28, Chapter 190, Section 5001 is applicable – – against SOF;

177. SOF is at least capably negligent in the aggravated manslaughter of Mrs. Kimball, with Andrew Warren, Susan Lopez and Judge Lynn Goudie placed permanently in a prison cells, due to all of them knowing no crime was committed in case 22-CF-2324-A;

Count 6: The Plaintiff’s False Imprisonment by SOF for 225 Days, a violation under Florida Statute 787.02 – – against SOF;

178. SOF is liable for damages, due to it being a racketeering participant in this matter under the RICO Act, violations of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; Chapter 817; and Title 18, Chapter 73, Sections 1513(e & f), liable for the Plaintiff’s False Imprisonment, when it helped wrongly put him in jail three (3) times, when it knew no crime was committed in court case 22-CF-2324-A, but kept wrongly prosecuting him to keep putting him back in jail;

Count 7: Malicious Prosecution of the Plaintiff, by Jane Castor’s local concert – – against SOF;

179. Both DHS; and Jane Castor orchestrated and initiated this illegal matter through COT/TPD; and SOF. So participant SOF is in violation of, but not limited to, under Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; Chapter 817; and Title 18, Chapter 173, Sections 1513(e & f). So SOF’s liable for the Malicious Prosecution of the plaintiff, when no crime was committed in case 22-CF-2324-A;

Count 8: Abuse of Process of the Plaintiff, by COT employee Jane Castor’s local concert – – against SOF;

180. Both DHS; and Jane Castor orchestrated and initiated this illegal matter through COT/TPD; and SOF. SOF was working in concert with Jane Castor; DHS/COT/TPD, for the improper purpose of injuring the Plaintiff and his wife physically; emotionally; and monetarily as racketeers against the Plaintiff under Title 18, Chapter 73, Sections 1513(e & f), due to Jane Castor; and COT/TPD being RICO Act participants with DHS/SOF, violations of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; Chapter 817; and 1513, when no crime was committed in case 22-CF-2324-A;

Count 9: Fraud on the Court (F.S. 1540 and Rule 60(b) in federal court) in cases 22-CF-2324-A was committed – – SOF, due to being a participant under the RICO Act, violations of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)6); and Section 1346; 1341; 1343; Chapter 817; and 1513, when no crime was committed in case 22-CF-2324-A – – against SOF;

181 SOF was a concert member involved in the prosecution of the Plaintiff, when Judge Goudie defrauded the Plaintiff herself, and allowed SOF to do the same in her kangaroo court, as if deaf, dumb and blind, violations under, but not limited to, being a racketeering participant under Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; Chapter 817; and 1513, when no crime was committed in case 22-CF-2324-A;

Count 10: Title 18, Chapter 73, Section 1513, an FRB retaliation crime initiated by DHS; and Jane Castor through SOF/COT/TPD (Jane Castor’s local concert) – – against SOF;

182. SOF was working in concert with Jane Castor; and DHS/COT/TPD to commit retaliatory acts for the purpose of physical; emotional; and monetary injuring the Plaintiff and his wife, committed in violation of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; Chapter 817; and Title 18, Chapter 73, Sections 1513(e & f), when no crime was committed in case 22-CF-2324-A, implemented by the John Rockefeller and his think tank, after the Plaintiff threatened to sue the FRB through John for obtaining his laundered inheritance beginning around 2000;

Count 11: SOF has standing to be sued for agent perpetrated wrongs on all Counts, due to the Law of Agency; Vicarious Liability; Imputation; and Respondeat Superior Doctrines – – against SOF;

183. SOF is liable for any of its employees’ wrongful actions and omissions which caused the Plaintiff and his wife damages, due to Vicarious Liability; Imputation; Respondeat Superior Doctrines and the Law of Agency;

Count 12: Fla. Stat. §838.022(a);(b);&(c); §112.3173(e)(6); & Section 1346 (private and public scams to defraud Plaintiff and his wife out of honest services, implemented by the FRB and initiated through SOF in cases 22-CF-2324-A; 21-CF-006147-A; 25-CA-564; and 24-CA-7358 and through AHCA – – against SOF;

184. SOF is in violation of both state and federal honest services, committed by any and all of its employees during cases 22-CF-2324-A; & 21-CF-006147-A, starting from 2-22, due to it being a racketeering participant under the RICO Act, violations of, but not limited to, Florida Statutes 838.022(a);(b);&(c) and 112.3173(e)(6); and Sections 1346; 1341; 1343; Chapter 817; and Title 18, Chapter 73, Sections 1513(e & f), when no crime was committed in case 22-CF-2324-A;

Count 13: Title 18, Chapter 63, Section 1349 (attempt and conspiracy) – – against SOF;

185. SOF is liable for the false search warrant; false imprisonment; malicious prosecution; abuse of process; wrongful death; and survival action for 1.5 years, all committed by Jane Castor; DHS/COT/TPD; and SOF on the Plaintiff and his wife, during court cases 22-CF-2324-A and 21-CF-006147-A, when it knew no crime was committed;

Count 14: Title 18, Chapter 13, U.S. Codes § 241, conspiracy against the rights of the Plaintiff and his wife – – against SOF;

186. SOF is liable for the false search warrant; false imprisonment; malicious prosecution; abuse of process; wrongful death; and survival action for 1.5 years, all committed by Jane Castor; DHS/COT/TPD; and SOF on the plaintiff and his wife, during court cases 22-CF-2324-A and 21-CF-006147-A, when it knew no crime was committed;

Count 15: Title 42, Chapter 21, Section 1983, assisting in wrongs committed by any government agency or agent – – against SOF;

187. SOF is liable for the false search warrant; false imprisonment; malicious prosecution; abuse of process; wrongful death; and survival action for 1.5 years, all committed by Jane Castor; DHS/COT/TPD; and SOF on the plaintiff and his wife, during court cases 22-CF-2324-A and 21-CF-006147-A, when it knew no crime was committed;

Count 16: SOF is 50% liable for TPD’s theft; conversion; and destruction of the Plaintiff and his wife’s properties within their house, under F.S. 771.11(1) & 812.014 – – against SOF;

188. SOF is liable for the theft; conversion; and destruction of Plaintiff and his wife’s properties within their house through TPD, so it now owes the Plaintiff 50% on $60,000. USD, before and during case 22-CF-2324-A (crimes committed on both 2-24-22 & 7-26-23).

Count 17: 4th amendment right violations – – against SOF;

189. FRB/DHS/COT/SOF/ through TPD violated the Plaintiff and his wife’s rights to not have their house searched; property stolen; converted; and damaged during 3 illegal TPD searches; and a fourth (4) illegal one by federal marshals after Judge Lynn Goudie issued a false warrant for the Plaintiff’s arrest, because he supposedly knew his wife was around the corner at the northern intersection from his home address, when he was driving his car down his block. Marshals used his illegally obtained house keys from within his pocket for 45 minutes, to go to his house and search it, permanently keeping his wallet with its full contents, possibly for SOF/COT/TPD to go through, but it was never to be seen by the Plaintiff again;

190. Due to Jane Castor; FRB/SOF/COT/TPD, an illegal concert, the Plaintiff was illegally arrested on: 2-24-22; and again by federal marshals on the street a few months later, complements of criminal minded Lynn Goudie; and a third time on 7-26-23;

191. FRB/SOF/COT/TPD; and Jane Castor, illegally imprisoned the Plaintiff for 225 days in total;

192. Jane Castor; and FRB/DHS/SOF/COT/TPD agents illegally removed Mrs. Kimball from her home, or made her leave it, each time they found her at home, keeping her on the streets to be foreseeably injured or killed.

Relief sought:

193. Money amounts the Plaintiff’s seeking from Defendant SOF in this complaint for personal injuries:

A. Economic damages amount to roughly $400,000. USD for Mrs. Kimball’s lost SSI income from age 41 to 75 (34 years’ worth);

B. 50% shared expense by SOF; and TPD, in $60,000. USD owed, for TPD stealing and damaging $20,000. USD of the Plaintiff and his wife’s properties within their home, during two (2) illegal TPD searches, implemented on 2-24-22 & 7-26-23, violations under F.S. §772.11 (1), 5 year statute of limitations, see court documents Appendix B. COT has now been given 30 days to pay the Plaintiff $30,000. USD. (Appendix B & court case 22-CF-2324-A) (Attorney Joseph Davis, the Plaintiff’s former attorney, is a witness to the thefts and damages);

C. 50% shared expense by TPD; and SOF, in TPD’s illegal search of Plaintiff’s house on 7-26-23, due to no search warrant while still being illegally prosecuted by SOF up until 12/2023, costing him $3,500. USD in legal fees from Attorney Joseph Davis – – so $1,750 USD is the amount both SOF and COT owe the Plaintiff;

D. the Plaintiff’s punitive and non-economic amounts for his own personal pain and suffering, along with Mrs. Kimball’s personal injury – – 1.5 years’ of being made to survive on the streets by FRB/DHS/SOF/COT/TPD; and Jane Castor, all non-economic/punitive, intentional/culpable, torts/scams, all committed by FRB contracted/paid agents, total well over $60. million USD, by referencing verdicts on similar federal and state violations.

194. Elements of the Causes of Action – – statutory or duty of care violations:

195. All of the Defendants had a direct, or indirect duty through their contracted/paid agents, not to breach multiple state and federal statutes either capably, but mainly intentionally, injuring the Plaintiff and his wife, compensation now owed to them.

196. Prayer for Relief:

197. The relief sought from all of the Defendants is punitive with compensatory, due to being the defendant in case 22-CF-2324-A; Plaintiff in case 25-CA-8096; and/or Mrs. Kimball’s husband, and requests attorney’s fee and costs when applicable.

198. Expedited Trial by Jury is asked for.

Affidavit of Verification:

STATE OF FLORIDA, COUNTY OF HILLSBOROUGH

I, Darryl Schneider, being duly sworn, deposes and say: I the Plaintiff in the above entitled action, have read the foregoing petition and know the contents of it, and say that to the best of my knowledge, its “contents” ARE TRUE and CORRECT.

______________________________________Signature

Subscribed and sworn before me on _____________________to certify which witness signed by my hand and official seal. Driver License# ______________________________________

__________________________________________Name

______________________________________Signature

___________________________Notary Public State of Florida Seal

Certificate of Service:

I HEREBY CERTIFY that a true and correct copy of the foregoing was placed into the case file with notification to each Defendant.

Darryl Schneider Plaintiff

_________________________

Signature

10406 N 26 Street

Tampa, FL 33612

813-585-0552

Adverse Parties:

1. David Dawson II

732 Holly Terrace

Brandon, FL 33511-5416

2. TGH

c/o John Couris

5707 Bayshore Blvd.

Tampa, FL 33611

or

1 Tampa General Circle

c/o Risk Management

1 Davis Blvd.

Suite 402

Tampa, FL 33606

813-844-7000

3. City of Tampa

Risk Management

306 East Jackson Street

Suite 4-E

Tampa, FL 33602

813-274-8211

4. State of Florida

Florida Department of Financial Services Division of Risk Management

200 E. Gaines St.

Tallahassee, FL 32399-0338

850-413-3122

Circuit Civil Division of The

13th Judicial Circuit, Tampa,

Florida

Appendix A: Cases 25-CA-564 & 24-CA-7358

Appendix B: Cases 22-CF-2324-A & 21-CF-006147-A

Appendix C: Competency Evaluation

Appendix D: FRB Investments

Appendix E: Films

Appendix F: NCUA & TBFCU

Appendix G: Common Laws

Appendix H: Fraudulent Transfer of Case 25-CA-8096