This is a verbatim transcript of the town’s filing. The town and Megan Logan, their attorney of record, should be censored for providing such wrongful and blatant lies to the court. But as Johnny Cash used to say, you hang out with dogs you are going to get fleas. Megan Logan AND THUS HER CLIENT has lied to the court or at a minimum has provided “HEARSAY” EVIDENCE AS FACT TO THE COURT.)
My comments are in RED.
White Springs is a small town of 772 residents. Doc. 24-3 at 13. The Town has 9 full time employees and 2 part time employees. Id. Plaintiffs Joe and Karin
Griffin are self-described political activists and concerned citizens. Doc. Iat 121;
Doc. 24-5 at 37, 39. Joe Griffin moved to White Springs in 1999. Doc. 24-5 at 6-
7. Upon moving to White Springs, Mr. Griffin and the Town immediately clashed regarding Mr. Griffin parking his large work truck on his residential property. Doc. 24-11 at 7-8. (NOT TRUE, THE ORIGINAL CLASH WAS OVER MY BIG TRUCK TAKING OUT SOME WIRES (WHICH IS NOT POSSIBLE WITH SEMI TRAFFIC ON MILL) AND ME BLOCKING THE ROAD WAY WHEN I WAS MOVING INTO MY HOUSE.)
During the 16 years he has lived in White Springs, Mr. Griffin, acting pro se, has brought suit against the Town on nineteen occasions, all related to alleged violations of public records laws, laws governing standards of conduct applicable to public officials, as well as a local ordinance governing zoning and land use. Doc. 24-5 at 12-13. Mr. Griffin did not prevail in any of the nineteen lawsuits and in the process was declared a vexatious litigant and prohibited from filing further lawsuits against the Town without the assistance of an attorney. Doc. 24-5 at 13.
In 2000, Mr. Griffin, along with another citizen, made an in-person demand for public records upon Town Clerk Shirley Heath. Doc. 24-2 at 13-4. Heath advised the men that the documents they sought were not ready but that she would
have them the next day. (THIS IS AN OUT AND OUT LIE. THE NEXT DAY WOULD HAVE BEEN A SATURDAY. ADDITIONALLY THE RECORDS REQUSTED HAD BEEN ASKED FOR A MONTH BEFORE THE INCIDENT.) Id. at 13-4. Mr. Griffin became irate and came across the open counter (WHAT AM I A TRACK STAR? YOU CAN’T JUMP OR CLIMB OVER THE COUNTER. Where is the proof of this event?) in Town Hall, taunting Ms. Heath and another female employee that was present. Id. Mr. Griffin’s violent response caused Ms. Heath to contact the Mayor and the Hamilton County Sheriff’s Office. (ANOTHER LIE, I CONTACTED THE SHERIFF’S DEPARTMENT) Id. After the responding Sheriff’s Deputy repeatedly advised Mr. Griffin to calm down, which Mr. Griffin did not do, Mr. Griffin was arrested. Id. As a result of this encounter, the Town installed Plexiglass and later black metal bars above the counter in Town Hall so as to provide a barrier between Town employees and citizens. Id.
Throughout the years that Ms. Heath served as Clerk, she was subjected to written letters both left at Town Hall and later sent to her personally. Doc. 24-2 at
15. Several of these letters contained threats, including one which stated “Why
don’t you wonderful Christian people come talk to me and see if we can work this thing out before any blood is shed.” (WHERE ARE THE LETTERS?) Id. The issuance of these letters and the threats made within these letters resulted in the issuance of a temporary restraining order (WHICH WAS THROWN OUT IMMEDIATELY BY JUDGE PEACH) in favor of Ms. Heath against Mr. Griffin. Id. Mr. Griffin would repeatedly call Ms. Heath while she was working at Town Hall. Id. at 16. Mr. Griffin would use vulgar language which would result in Ms. Heath hanging up on him. Id. Mr. Griffin would also trespass into the backyards of former Town Council members and later describe what he had observed so as to let the council members know that he had been in or around their yards. (NOT TRUE, I NEVER WENT INTO ANY COUNCILMEMBERS BACK YARDS, WHERE IS THE PROOF THAT I DID?) Id. at ,r 7. Mr. Griffin has also made vicious verbal attacks (WHERE IS THE PROOF?) on Town officials such as former Mayor Joseph McKire, referring to him as “Uncle Tom” and posting flyers around town containing the same language. Id. at ,r 9. (Mr. McKire never did anything for the Black Community as a whole. That makes him an Uncle Tom in my book.) Mr. Griffin personally delivered a copy of the flyer to McKire at is home, while McKire was caring for his dying wife. Id. (WHERE IS THE PROOF THAT I KNEW MRS. MCKIRE WAS ILL AND EVEN IF I KNOW WHAT LAW WAS BROKEN?). Mr. Griffin also became physically violent with former Town Council member Tracy Woodard at the library where she worked (WHERE IS THE PROOF? THE TOWN POLICE WOULD CERTAINLY HAVE ARRESTED ME IF THIS WERE TRUE) causing the library to change its hours which remain in effect today. Doc. 24-4 at ,r 7.
After Joe met Karin on the Internet, she moved to White Springs in 2011.
Doc. 24-5 at 7-8. The two were married in 2012. Id. at 7.
Since 2012, Mr. and Mrs. Griffin have operated a blog known as the White Springs Journal. Doc. 24-5 at 22, 24-25. The blog can be found at
http://www.whitespringsnews.com. Doc. I,,r 24. Mr. Griffin has served as editor of the
blog since its inception, with the exception of an approximate l0 month period from April of 2014 to February of 2015 when Mrs. Griffin took over as editor. Doc. 24-5 at 23. Both Mr. and Mrs. Griffin contribute content to the blog on a daily basis. Doc. 24-5 at 23, 25; Doc. 24-6 at 15. Unlike the content of the blog which is completely unrestricted, as editor, Mr. Griffin restricts what reader
comments, if any, are posted to the blog, stating that if it “it’s crude, rude and socially unacceptable it doesn’t go on the blog. Anything that calls me or Karin a nasty name doesn’t go on the blog.” (MY BLOG, MY RULES) Doc. 24-5 at 26-27. Miller, Tomlinson and Rodriquenz do not regularly read the blog. Docs. 24-11 at 12; 29 at 29, 24-9 at 13. Mr. Griffin requests records from the Town almost every day. (NOT TRUE BUT SO WHAT?) Doc. 24-5 at
54. Mrs. Griffin does not make public records requests but instead relies upon Mr.
Griffin to request any records she may need. Doc. 24-6 at 36.
Despite or maybe because of their extreme dislike for the Town and its management, the Griffins have repeatedly offered their services to the Town, on a volunteer basis, as an elected official and as paid employees. Doc. 24-5 at 27-28. Mr. Griffin sought employment as the Town Manager on three occasions. Doc. 24- 5 at 29-30. Mrs. Griffin previously applied for the position of Administrative Assistant which ultimately went to Anita Rivers. Doc. 24-6. at 18-19.
In February of 2014, Mr. Griffin applied for the vacant Town Manager position. J. Griffin Dep. at 34. Mrs. Griffin, on her husband’s behalf, completed his application for Town Manager. Doc. 24-5 at 34-35; Doc. 24-6 at 19-20. Mr. Griffin signed the application, but did not otherwise complete the application or provide any attachments to the application, including his resume. Doc. 24-5 at 35; Doc. 24-6 at 20. (THIS IS TRUE, OTHER THAN SIGNING THE APPLICATION I NEVER SAW THE APPLICATION OR WHAT KARIN PUT IN IT.)
In the application, Mr. Griffin alleged that during his military service he had received three bronze stars and two silver medals. (I ALLEGED NO SUCH THING, EVEN THE TOWN AGREES.) In support of these claims, Mrs. Griffin attached copies of certificates showing that Mr. Griffin had received these military honors. Doc. 24-6 at 21. The Town later requested that Mr. Griffin provide a DD214 which would list all military honors awarded to Joe Griffin. In response to questions regarding whether Mr. Griffin had in fact received the military honors alleged in the employment application, both Mr. and Mrs. Griffin asserted (NOT TRUE!, AT LEAST AT THE TIME, THERE WAS NO INVESTIGATION MADE THAT WE WERE AWARE OF) their Fifth Amendment right against self-incrimination. Doc. 24-5 at 9, 42-43; Doc. 24-6 at 21-22.
During the hiring process, Mr. Griffin submitted a public records request to the Town for the applications of all applicants for the vacant Town Manager position. Doc. 24-5 at 35. Using the contact information provided by the applicants on their applications, Mr. Griffin contacted most of the candidates to determine for himself, the candidates’ respective qualifications and interest in coming to White Springs should he or she be offered the position. 1 Id. at 36-37. During these discussions, Mr. Griffin advised each candidate that he or she would get to know him very well if they were to accept the Town Manager position. Doc. 24-5 at 39. Mr. Griffin also directed the applicants to his blog and advised them to
1 The parties dispute whether Mr. Griffin introduced himself to candidates as a council member or otherwise suggested some affiliation with the Town at the time he contacted the candidates for Town Manager. Doc. 24-11 at 16; Doc. 24-5 at 41.
read the blog to understand what was happening in White Springs. Doc. 24-5 at 41.
As a result of the false statements contained in Mr. Griffin’s employment application, the Town turned the application over fo the State Attorneys’ Office (SAO) and specifically Assistant State Attorney Karen Hatton for investigation and
possible prosecution. (NOT TRUE, KAREN HATTON DID NO INVESTIGATING, ALL OF THAT WAS DONE BY THE WHITE SPRINGS POLICE DEPARTMENT.) Doc. 24-7 at 6-7.2 The SAO had hoped that the federal
government would intervene and prosecute under the Stolen Valor Act, however the federal government declined to do so, leaving it to the state to prosecute. voe. 24-7 at 77. The White Springs Police Department, acting at the behest of the SAO, arrested Mr. Griffin on five counts of uttering a forged instrument. Doc. 24-5 at
50. Mr. Griffin and the SAO ultimately entered into a Deferred Prosecution Agreement. Doc. 24-7 at 54. Pursuant to the terms of this agreement, Mr. Griffin was required to pay monetary fines and court costs, refrain from any further use or entitlement to the military honors claimed in his employment application and to avoid breaking any laws for a period of 12 months. Id.; Doc. 24-5 at 51.
After repeated complaints from Mayor Helen Miller, Town Clerk/Finance Director Pam Tomlinson and Administrative Assistant Anita Rivers regarding what they perceived to be harassment (WHAT HARASSMENT? WHERE IS THE PROOF) by the Griffins, Chief Rodriquenz contacted ASA
2 The page numbers of Karen Hatton’s deposition referenced herein refer to the page numbers assigned by the Court’s CM/ECF system and not the actual page numbers of the deposition.
Hatton. Doc. 24-9 at 9, 12-13, 35. This harassment included statements made by the Griffins about each woman on their blog as well as frequent and repetitive harassing emails to Town Hall under the guise of public records requests and interference in the Town’s selection of a new Town Manager. (WHERE ARE THE LETTERS? WHERE IS THE PROOF?) Id. ASA Hatton disputes telling Rodriquenz to file a complaint, but admits telling Rodriquenz that if she filed a complaint, she should do so through an independent agency such as the Hamilton County Sheriff’s Office or FDLE. Doc. 24-7 at 17, 19. Rodriquenz then contacted the Hamilton County Sheriff’s Office. Doc. 24-9 at 69.
Deputy Pearsall Fouraker responded to the call placed by Chief Rodriquenz. Doc. 24-10 at 13. Upon his arrival, Chief Rodriquenz explained to Deputy Fouraker the instances of harassment (WHAT HARASSMENT? WHERE IS THE PROOF?) alleged by Miller, Tomlinson and Rivers. Doc. 24-9 at 72. In describing the harassment, Rodriquenz put Deputy Fouraker on the telephone with ASA Hatton. Doc. 24-9 at 65. During this short telephone call, ASA Hatton advised Deputy Fouraker to conduct his investigation, but never provided any recommendation as to whether criminal charges should be filed. Doc. 24-7 at 22. Although Chief Rodriquenz was present for the telephone call
3 Although Miller and Tomlinson refer to “119 requests” within their Witness Statements, Miller and Tomlinson use this term generically to refer to all requests
sent by Mr. Griffin to Town Hall. See Doc. 24-3 at 18; Doc. 24-11 at 18. While
some of Mr. Griffin’s requests seek production of documents pursuant to Chapter 119, Florida Statutes, other requests merely contain statements, questions or insults directed toward Town officials. Doc. 24-3 at 19;
between Deputy Fouraker and ASA Hatton, she did not participate in this call. Doc. 24-10 at 33
At approximately 4:30 p.m., Miller, Tomlinson and Rivers4 prepared written witness statements at the request of Hamilton County Sheriff’s Office Deputy Fouraker. Doc. 24-10 at 20; Doc. 1-2, 1-3 and 1-4. Tomlinson did not complain about Mr. Griffin’s requests for records pursuant to Chapter 119, Florida Statutes but instead complained about the petty and negative statements (WHAT? WHERE IS THE PROOF, PRODUCE THE LETTERS. WHEN IS A NEGATIVE OR PETTY STATEMENT, IF SUCH EVEN EXISTS, AGAINST THE LAW.) Doc. 24-10 at 17.
Deputy Fouraker believed probable cause existed for a charge of cyberstalking in violation of Fla. Stat. 784.048(1)(a). Doc. 24-10 at 36. In concluding that probable caused existed for the charge of cyberstalking, Deputy Fouraker relied upon all of the evidence available to him, including the frequency and terminology contained within the emails (WHAT EVIDENCE? WHERE IS IT?). Doc. 24-10. at 17-19, 23. Deputy Fouraker could not recall how this statute came to his attention, but likely would have looked up the appropriate statute on his laptop or statute book. Doc. 24-10 at (IF HE HAD DONE SO HE WOULD HAVE READ THAT THE TOWN CANNOT BE CYBERSTALKED, ONLY INDIVIDUALS. IT IS THE FIRST REQUIMENT OF THE STATUTE. NOT ONLY DOES THE TOWN LIE, BUT IT THIS IS TRUE FOREAKER IS A LIAR AS WELL.)
35. Deputy Fouraker also conferred with ASA Hatton regarding whether there would be grounds for an arrest for cyberstalking based on the evidence available. Doc. 24-10 at 33. (WHAT WAS THE SUBSTANCE OF SUCH A “CONFERRING?”)
4 Anita Rivers, the Administrative Assistant for the Town, was initially named as a defendant in this litigation but was voluntarily dismissed without prejudice after discovery. Doc. 18.
Several days after taking statements from the defendants at Town Hall, Deputy Fouraker went to Mr. and Mrs. Griffins’ home to obtain statements from the Griffins. (AGAIN NOT TRUE, HE CAME THE SAME DAY.) Doc. 24-10 at 28. When the Griffins declined to be interviewed, (AFTER BEING READ OUR MIRANDA RIGHTS AND THRREATED WITH ARREST FOR SOME UNKNOWN CRIME) Deputy Fouraker politely left. Doc. 24-10 at 22, 29. Although the Offense Reports states that “Chief Rodriquenz request warrants for Joe and Karin Griffin on the above charge,” Deputy Fouraker explained that this refers to a request by the complaining party that the case be evaluated and charges filed if warranted. Doc. 1-5; Doc. 24-10 at 27, 43. No one from the Town of White Springs requested that Joe or Karin Griffin be arrested. (YEAH, RIGHT) Docs. 24-9 at 79; 24-10 at 42. Deputy Fouraker did not make arrests on the charge of cyberstalking but instead requested warrants, which he regularly does when he is not assured that the conduct falls within the statute under which the defendant is charged. Doc. 24-10 at 36. Warrants were never issued for either Joe or Karin Griffin. Id. at 37. Deputy Fouraker did not have any further discussions with ASA Hatton regarding the fate of the charges and only learned that the State Attorney declined to prosecute the charges after receiving written notification from the State Attorneys’ Office. Doc. 24-10 at 35. (NO CHARGE FROM THE STATE’S ATTORNEY BECAUSE, THEY UNLIKE FOREAKER, READ THE LAW AND REALIZED THAT ORGANIZATIONS CAN’T BE CYBERSTALKED.)
Based on information that Mr. Griffin was harassing her witnesses in the open case against him arising from false statements made on his employment application to the Town – a case in which the Town (THE TOWN COULD NOT BE THE VICTIM IN EITHER CASE. IN THE FRAUD CASE HOW WAS THE TOWN INJURED? IN THE CYBERSTACKING CASE THE TOWN COULDN’T BE THE VICTIM) was the victim- Ms. Hatton alone made the decision to revoke the Deferred Prosecution Agreement. Doc. 24-7 at 31, 48-49. No one associated with the Town of White Springs requested that Hatton revoke Mr. Griffin’s Deferred Prosecution Agreement. Doc. 24-7 at 45-46, (EXCEPT TO THE MAYOR WHO WROTE THE “SMOKING GUN LETTER” ALSO OUR CRIMINAL ATTORNEY WAS ADVISED THAT HATTON WAS TIRED OF THE NUMEROUS PHONE CALLS COMPLAINING ABOUT THE BLOG AND OTHER THINGS))
48. Moreover, no one associated with the Town encouraged or influenced Hatton’s decision to revoke the Deferred Prosecution Agreement. Id. The letter to Mr. Griffin revoking his Deferred Prosecution Agreement is dated June 19, 2014, the same date on which Miller, Tomlinson and Rivers provided the witness statements giving rise to this litigation. Doc. 24-7 at 76. However, the transmission of information between ASA Hatton and the Diversion Program Administrator, Ken Botbyl, to revoke Mr. Griffin’s Deferred Prosecution Agreement occurred prior to June 19, 2014, before Miller, Tomlinson and Rivers had ever written their witness statements. (NOT TRUE!) Doc. 24-7 at 35-36.
Miller never spoke with ASA Hatton regarding the Griffins’ blog or public records request. Doc. 24-11 at 13-14. The only communications between Miller and ASA Hatton were in relation to Mr. Griffin’s employment application and claims that he had been awarded military honors which could not be confirmed. (WHAT CRIME IS THAT? SINCE WHEN DOES A PERSON WHO DIDN’T FILL OUT AN APPLICATION GET CHARGED WITH A CRIME? ) Doc. 24-11 at 14. Miller attended a pre-trial hearing, only to learn that there had been a continuance and a hearing would not take place. Id. Other than this in person exchange, Miller never had any further conversations with ASA Hatton. Id.
In July, ASA Hatton sent the Town a letter advising that it could make a Victim Impact Statement in the prosecution against Joe Griffin related to his falsification of military credentials on his employment application. Mayor Helen Miller received a copy of ASA Hatton’s letter in her box at Town Hall and drafted a proposed response. (THE INFAMOUS SMOKING GUN LETTER) Doc. 24-11 at 51. Before sending the proposed response to ASA Hatton, Miller emailed the response to Town Attorney Fred Koberlein for his review. Id. Koberlein advised the Mayor not to send the response. Although the response was circulated amongst the Town Council (WHICH IS PU8LISHING A FORGED DOCUMENT SINCE IT WAS A PUBLIC MEETING; THEREFORE IT IS A PUBLIC RECORD EVEN THOUGH MILLER LIED. ALSO KOBERLEIN DID NOT TELL THE MAYOR NOT TO SEND IT BUT RATHER TOLD THE MAYOR TO TAKE IT BEFORE THE COUNCIL), the Council voted not to send the response. As a result, the proposed Victim Impact Statement authored by Miller was never signed or sent to ASA Hatton or anyone else at the State Attorney’s Office. Doc. 24-11 at 51, 64; Doc. 24-7 at 45.
While at the Wellborn Blueberry Festival, Miller also had an exchange with Jeffrey Seigmeister, the State Attorney for the Third Judicial Circuit. Doc. 24-11 at 57. During this discussion, Mr. Seigmeister advised that Mr. Griffin had entered into a Deferred Prosecution Agreement with the State Attorney’s Office as a result of the charges against him for uttering forged instruments in relation to the false medals claimed in his employment application. Id. Mr. Seigmeister advised that under the terms of the Agreement, Mr. Griffin was required to “be good” for one year. Id. Miller advised that she did not believe Mr. Griffin was “being good”
because he was continuing to harass the Town by way of his interference with applicants for the vacant Town Manager position. Id. (WHAT LAW WAS BROKEN? NONE. how can me speaking to applicants be harassment of the town? former manager Bill Lawrence in his deposition stated what Joe Griffin did was not unlawful and that Joe Griffin said he was a concerned citizen.)
Mr. Griffin’s Deferred Prosecution Agreement was later reinstated by another prosecutor. Doc. 24-7 at 36. Mr. Griffin successfully completed his Deferred Prosecution Agreement in February of 2015 (SIX MONTHS EARLY). Doc. 24-5 at 44. Regardless of any action taken by the individual defendants, the State Attorney’s Office or the Sheriff s Office, the Griffins’ written commentary regarding the Town, its officials and employees remains as robust and critical as ever. See Doc. 24-1. (YOU BET Ya!)
NONE OF THIS WOULD HAVE HAPPENED IF THE TOWN HAD FOLLOWED THE LAW BUT FOR EVERY ACTION THE TOWN HAS TAKEN AGAINST US, WE HAVE NOT LAID DOWN AND DIED AS THEY WISH. WHAT THEY HAVE DONE TO US WITH THEIR LIES AND FALSE ACCUSATIONS IS BEYOND THE PALE. THE TOWN HAS LIED SO MUCH I AM NOT CERTAIN THEY KNOW WHAT THE TRUTH REALLY IS AND THE THINGS WHICH WERE SAID ABOUT JOE ARE ABSOLUTELY RIDICULOUS. AS HIS SPOUSE, I KNOW HIM BETTER THAN ANY OF YOU AND IT IS YOU WHO HAVE MADE UP ALL THESE TERRIBLE THINGS NOT ONLY ABOUT HIM BUT ABOUT ME WITH THE HELP OF YOUR ANONYMOUS FRIENDS.