--------

CIVIL COVER SHEET Form 1997 The civil cover sheet and the information contained herein neither replaces nor supplement the filing and

service of pleadings or other papers as required by law This form shall be filed by the plaintiff or petitioner for the use of

the Clerk of Court for the purpose of reporting judicial workload data pursuant to Florida Statute section 25075 (See

instructions for completion)

1 CASE STYLE

In the Circuit Court of the Thirteenth Judicial Circuit for Hillsborough County Florida

ELLEN BETH WACHS 11 5545 Case

Plaintiff(s) Division

vs

ED GO LL0 8 ITH TRACY THOMAS NAN OWENS STEVE BROWN MAIT COOPER GLORIA JULIUS STEVE MILES and JAMES PETE RSON ECE

DEC 05 2011 Defendant(s)

--------shy

------~~~~~~IQ

II TYPE OF CASE Of the case fits more than one type of case select the most definitive category) If the most descriptive label is a subcategory (is indented under a broader category) place an X in both the main category and subcategory boxes

DCondominium

DContracts and indebLedness

CJ Eminent domain

DAuto negligence

DNegligence - other

o Business governance

D Business torts

CJ EnvironmentalfToxic tort

D Third party indemnification

o Construction defect

D Mass tort

D Negligent security

c=J Nursing home negligence

o Premises liability - commercial

o Premises liability - residential

D Products liability

D Real property Mortgage foreclosure

D Commercial foreclosure $0shy

$50000

D Commercial foreclosure $50001 shy

$249 999

D Commercial foreclosure

$250000 or more

D Homestead residential foreclosure

$0 - $50000

D Homestead residential foreclosure

$50001 - $249999

CJ Homestead residential foreclosure

$250000 or more

D Nonhomestead residential

Foreclosure $0 - $50000

D Nonhomestead residential

Foreclosure $5000 I - $249999

o Nonhomestead residential

Foreclosure $250 000 or more

D Other real property actions $0 shy

$50000

D Other real property actions $50001 shy

$249999

D Other real property actions $250000

or more

D Professional malpractice

D Malpractice - business

D Malpractice - medical

D Malpractice - other professional

mOther

D Antitrust trade regulation

D Business transactions

D Constitutional challenge - statute or

ordinance

D Constitutional challenge - proposed

amendment

D Corporate trusts

DDiscrimination - employment or

other

D Insurance claims

D Intellectual property

m LibelSlander

D Shareholder derivative action

o Securities litigation

D Trade secrets

o Trust litigation

II TYPE OF CASE Of the case fits more than one type of case select the most definitive category) If the most descriptive label is a subcategory (is indented under a broader category) place an X in both the main category and subcategory boxes

DCondominium

DContracts and indebLedness

CJ Eminent domain

DAuto negligence

DNegligence - other

o Business governance

D Business torts

CJ EnvironmentalfToxic tort

D Third party indemnification

o Construction defect

D Mass tort

D Negligent security

c=J Nursing home negligence

o Premises liability - commercial

o Premises liability - residential

D Products liability

D Real property Mortgage foreclosure

D Commercial foreclosure $0shy

$50000

D Commercial foreclosure $50001 shy

$249 999

D Commercial foreclosure

$250000 or more

D Homestead residential foreclosure

$0 - $50000

D Homestead residential foreclosure

$50001 - $249999

CJ Homestead residential foreclosure

$250000 or more

D Nonhomestead residential

Foreclosure $0 - $50000

D Nonhomestead residential

Foreclosure $5000 I - $249999

o Nonhomestead residential

Foreclosure $250 000 or more

D Other real property actions $0 shy

$50000

D Other real property actions $50001 shy

$249999

D Other real property actions $250000

or more

D Professional malpractice

D Malpractice - business

D Malpractice - medical

D Malpractice - other professional

mOther

D Antitrust trade regulation

D Business transactions

D Constitutional challenge - statute or

ordinance

D Constitutional challenge - proposed

amendment

D Corporate trusts

DDiscrimination - employment or

other

D Insurance claims

D Intellectual property

m LibelSlander

D Shareholder derivative action

o Securities litigation

D Trade secrets

o Trust litigation

D THIS CASE IS APPROPRIATE FOR ASSIGNME1T TO THE COMPLEX LITIGATION BUSINESS DIVISION PLEASE SEE ATTACHED COMPLEX B SfN ESS LITIGATION DIVISION ADDENDUM FORM

III REMEDIES SOUGHT (Check all that apply)

[Z] Monetary

D Non-monetary declaratory or injW1ctive relief

W Punitive

IV NUMBER OF CAUSES OF ACTION [1 ] (Specuy) ________________________________________________________________

V IS THIS CASE A CLASS ACTION LAWSUIT

DYes

[Z]No

VI HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED

[Z]No

D Yes If yes list all related cases by name case number and court

VII IS JURY TRIAL DEMANDED IN COMPLAINT

DYes

WNo

VI1I IS TRIAL EXPECTED TO LAST MORE THAN TEN (10) TRIAL DA YS (2 WEEKS)

DYes

mNo

I CERTIFY that the information I have provided in this cover sheet is accurate to the best of my knowledge and belief

FL Bar ____ ________

Attorney or Party (Bar if attorney)

SignMe zSllc 4 ~

Type or Print Name Date

COMPLEX BUSINESS LITIGATION DIVISION ADDENDUM

Party or Attornev Filing Action Must Place an X in One of the Boxes Below

The categories of cases set out below shall guide the parties and the Court in the designation of cases for the Complex Business Litigation Division (CBLD)

AMOUNT IN CONTROVERSY GREATER THAN $15000000

D Non-consumer VCC-related transactions

D Purchases and sales of businesses or the assets of a business including contract disputes commercial landlordshytenant claims and business torts

D Non-consumer sale of goods or services by or to business enterprises

D Non-consumer bank or brokerage accounts including loan deposit cash m311agement and investment accounts

D

D

Purchase sale lease of commercial (real or personal) property or security interests therein

Commercial surety bonds

D Franchisee franchisor relationships and liabilities

D Malpractice against professionals except health care providers in cOnIlection with rendering services relating to a business enterprise

CJ Business torts including unfair competition breach of fiduciary duty and tortious interference with contracts

D Complex construction litigation other than consumer home construction disputes unless a court determines that the home construction dispute is business-related and complex or

CJ Insurance coverage bad faith litigation and third party indemnity actions against insurers arising under policies issued to businesses such as claims arising under a commercial general liability policy commercial property policy or title insUr311ce policy not including claims where the underlying dispute is a personal injury claim unless a court determines that the personaJ injury insurance claim is business-related and complex

ANY AMOUNT IN CONTROVERSY

D Internal affairs or governance dissolution or liquidation rights obligations between or among owners (shareholders partners members) or liability or indemnity of managers (officers directors managers trustees or members or partners functioning as managers) of corporations partnerships limited partnerships limited liability companies or partnerships

D Trade secrets and non-compete agreements

D Intellectual property

D Securities or state securities laws

CJ Antitrust statutes

D Shareholder derivative actions and related class actions and

D Corporate trust affairs or director and officer liability_

NOTE A copy of the Civil Cover Sheet and this Addendum must be sened with the Complaint for all Complex Business Litigation Division cases See Administratie Order S-2008-105 for further Complex Business Litigation Division requirements

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY FLORIDA

ELLE~BETH WACHS

Plaintiff 11 15545 Case No ---------------- shy

ED GOLLOBITH TRACY THOMAS N AN OWENS STEVE BROWN MATT COOPER GLORIA JULIUS STEVE MILES and JAMES PETERSON ECEIVE

Defendants DEC 05 2011 ------------------------------------~I

CLER 01= C R ~GIT COURT HILLSBO U H --OUI TY FL

COMPLAINT FOR DEFAMATION

I Introduction

1 This action for defamation is brought by the Plaintiff Ms ELLENBETH WACHS

against the Defendants ED GOLLOBITH TRACY THOMAS NAN OWENS STEVE

BROWN MATT COOPER GLORIA JULIUS STEVE MILES and JAMES PETERSON Ms

WACHS was and asserts that she legally remains the acting president of Atheists of Florida

Inc a Florida Non Profit Corporation (the AoF) The Defendants are or were at the time of the

subject defamation members of the board of directors of the AoF (the Board) This action

arose from an email (Writing f) sent on November 6 2011 by the Defendants to the AoF

membership falsely accusing the Ms WACHS of impropriety and criminal behavior

Specifically this email stated that the Plaintiff has been expelled from the membership for

seriously obstructing the organization s business misappropriating the organizations name

misappropriating the organization s funds and acting in a way that discredits the organization

Page lof8

33782

This same email directed members to a publicly accessible website which repeated these false

claims (Writing II)

ll Jurisdiction

2 This Court has jurisdiction and venue is proper because at least one of the defendants

resides in Hillsborough County and because the amount in controversy exceeds $15000

ill Parties

3 The Plaintiff Ms ELLENBETH WACHS is now and at all times mentioned in this

complaint was a resident of Polk County Florida She is a small business owner She was and

asserts that she remains acting president of the AoF She has served as a board member the vice

president and the legal director of the AoF She resides at 5963 Lake Victoria Drive Lakeland

FL 33813

4 Defendant Mr ED GOLLOBITH is now and at all times mentioned in this complaint

was a resident of Hi llsborough County F lorida This party is or was a member of the Board and

signed Writings I and II This party resides at 4303 S MacDili Ave Tampa FL 33611-1940

5 Defendant Ms TRACY THOMAS is now and at all times mentioned in this complaint

was a resident of Pinellas County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 6411 93rd Terrace 4901 Pinellas Park FL

6 Defendant Ms NAN OWENS is now and at all times mentioned in this complaint was a

resident of Hillsborough County Florida Thi s party is or was a member of the Board and signed

Writings I and II This party resides at 4704 Lakewood Drive Seffner FL 33584

7 Defendant Mr STEVE BROWN is now and at all times mentioned in this complaint was

a resident of Pinellas County Florida This party is or was a member of the Board and signed

Page 2 of8

Writings I and II This party resides at 11640 Shipwatch Drive Villa 1431 Largo FL 33774shy

3742

8 Defendant Mr MATT COOPER is now and at all times mentioned in this complaint was

a resident of Hillsborough County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 15636 Eastboum Drive Odessa FL 33556

9 Defendant Ms GLORIA JULIUS is now and at all times mentioned in this complaint

was a resident of Pinellas County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 6382 18th Street NE St Petersburg FL 33702

10 Defendant Mr STEVE MILES is now and at all times mentioned in this complaint was a

resident of Alachua County Florida This party is or was a member of the Board and signed

Writings I and II This party resides at 6308 N W 136th Street Gainesville FL 32606

11 Defendant Mr JAMES PETERSON is now and at all times mentioned in this complaint

was a resident of Hillsborough County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 6814 Charlotte Harbor Way Tampa FL 33425

IV The Defamatory Writings

12 Writing I the first defamatory writing was sent collectively by all the Defendants via

email on November 6 2011 at 6 05 PM to the mailing list of the AoF approximately 200

individuals Writing I stated

The Board voted to remove EllenBeth Wachs as Vice President of the Organization Additionally [she has] been expelled from the membership for seriously obstructing the organization s business misappropriating the organizations name misappropriating the organizations funds and acting in a way that discredits the organization Meanwhile please keep abreast of the latest Atheists of Florida developments on our temporary website at wwwmetrodirectnetlaof

Writing I was signed

The Board of Directors of Atheists of Florida

Page 3 of8

COMPLEX BUSINESS LITIGATION DIVISION ADDENDUM

Party or Attornev Filing Action Must Place an X in One of the Boxes Below

The categories of cases set out below shall guide the parties and the Court in the designation of cases for the Complex Business Litigation Division (CBLD)

AMOUNT IN CONTROVERSY GREATER THAN $15000000

D Non-consumer VCC-related transactions

D Purchases and sales of businesses or the assets of a business including contract disputes commercial landlordshytenant claims and business torts

D Non-consumer sale of goods or services by or to business enterprises

D Non-consumer bank or brokerage accounts including loan deposit cash m311agement and investment accounts

D

D

Purchase sale lease of commercial (real or personal) property or security interests therein

Commercial surety bonds

D Franchisee franchisor relationships and liabilities

D Malpractice against professionals except health care providers in cOnIlection with rendering services relating to a business enterprise

CJ Business torts including unfair competition breach of fiduciary duty and tortious interference with contracts

D Complex construction litigation other than consumer home construction disputes unless a court determines that the home construction dispute is business-related and complex or

CJ Insurance coverage bad faith litigation and third party indemnity actions against insurers arising under policies issued to businesses such as claims arising under a commercial general liability policy commercial property policy or title insUr311ce policy not including claims where the underlying dispute is a personal injury claim unless a court determines that the personaJ injury insurance claim is business-related and complex

ANY AMOUNT IN CONTROVERSY

D Internal affairs or governance dissolution or liquidation rights obligations between or among owners (shareholders partners members) or liability or indemnity of managers (officers directors managers trustees or members or partners functioning as managers) of corporations partnerships limited partnerships limited liability companies or partnerships

D Trade secrets and non-compete agreements

D Intellectual property

D Securities or state securities laws

CJ Antitrust statutes

D Shareholder derivative actions and related class actions and

D Corporate trust affairs or director and officer liability_

NOTE A copy of the Civil Cover Sheet and this Addendum must be sened with the Complaint for all Complex Business Litigation Division cases See Administratie Order S-2008-105 for further Complex Business Litigation Division requirements

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY FLORIDA

ELLE~BETH WACHS

Plaintiff 11 15545 Case No ---------------- shy

ED GOLLOBITH TRACY THOMAS N AN OWENS STEVE BROWN MATT COOPER GLORIA JULIUS STEVE MILES and JAMES PETERSON ECEIVE

Defendants DEC 05 2011 ------------------------------------~I

CLER 01= C R ~GIT COURT HILLSBO U H --OUI TY FL

COMPLAINT FOR DEFAMATION

I Introduction

1 This action for defamation is brought by the Plaintiff Ms ELLENBETH WACHS

against the Defendants ED GOLLOBITH TRACY THOMAS NAN OWENS STEVE

BROWN MATT COOPER GLORIA JULIUS STEVE MILES and JAMES PETERSON Ms

WACHS was and asserts that she legally remains the acting president of Atheists of Florida

Inc a Florida Non Profit Corporation (the AoF) The Defendants are or were at the time of the

subject defamation members of the board of directors of the AoF (the Board) This action

arose from an email (Writing f) sent on November 6 2011 by the Defendants to the AoF

membership falsely accusing the Ms WACHS of impropriety and criminal behavior

Specifically this email stated that the Plaintiff has been expelled from the membership for

seriously obstructing the organization s business misappropriating the organizations name

misappropriating the organization s funds and acting in a way that discredits the organization

Page lof8

33782

This same email directed members to a publicly accessible website which repeated these false

claims (Writing II)

ll Jurisdiction

2 This Court has jurisdiction and venue is proper because at least one of the defendants

resides in Hillsborough County and because the amount in controversy exceeds $15000

ill Parties

3 The Plaintiff Ms ELLENBETH WACHS is now and at all times mentioned in this

complaint was a resident of Polk County Florida She is a small business owner She was and

asserts that she remains acting president of the AoF She has served as a board member the vice

president and the legal director of the AoF She resides at 5963 Lake Victoria Drive Lakeland

FL 33813

4 Defendant Mr ED GOLLOBITH is now and at all times mentioned in this complaint

was a resident of Hi llsborough County F lorida This party is or was a member of the Board and

signed Writings I and II This party resides at 4303 S MacDili Ave Tampa FL 33611-1940

5 Defendant Ms TRACY THOMAS is now and at all times mentioned in this complaint

was a resident of Pinellas County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 6411 93rd Terrace 4901 Pinellas Park FL

6 Defendant Ms NAN OWENS is now and at all times mentioned in this complaint was a

resident of Hillsborough County Florida Thi s party is or was a member of the Board and signed

Writings I and II This party resides at 4704 Lakewood Drive Seffner FL 33584

7 Defendant Mr STEVE BROWN is now and at all times mentioned in this complaint was

a resident of Pinellas County Florida This party is or was a member of the Board and signed

Page 2 of8

Writings I and II This party resides at 11640 Shipwatch Drive Villa 1431 Largo FL 33774shy

3742

8 Defendant Mr MATT COOPER is now and at all times mentioned in this complaint was

a resident of Hillsborough County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 15636 Eastboum Drive Odessa FL 33556

9 Defendant Ms GLORIA JULIUS is now and at all times mentioned in this complaint

was a resident of Pinellas County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 6382 18th Street NE St Petersburg FL 33702

10 Defendant Mr STEVE MILES is now and at all times mentioned in this complaint was a

resident of Alachua County Florida This party is or was a member of the Board and signed

Writings I and II This party resides at 6308 N W 136th Street Gainesville FL 32606

11 Defendant Mr JAMES PETERSON is now and at all times mentioned in this complaint

was a resident of Hillsborough County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 6814 Charlotte Harbor Way Tampa FL 33425

IV The Defamatory Writings

12 Writing I the first defamatory writing was sent collectively by all the Defendants via

email on November 6 2011 at 6 05 PM to the mailing list of the AoF approximately 200

individuals Writing I stated

The Board voted to remove EllenBeth Wachs as Vice President of the Organization Additionally [she has] been expelled from the membership for seriously obstructing the organization s business misappropriating the organizations name misappropriating the organizations funds and acting in a way that discredits the organization Meanwhile please keep abreast of the latest Atheists of Florida developments on our temporary website at wwwmetrodirectnetlaof

Writing I was signed

The Board of Directors of Atheists of Florida

Page 3 of8

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY FLORIDA

ELLE~BETH WACHS

Plaintiff 11 15545 Case No ---------------- shy

ED GOLLOBITH TRACY THOMAS N AN OWENS STEVE BROWN MATT COOPER GLORIA JULIUS STEVE MILES and JAMES PETERSON ECEIVE

Defendants DEC 05 2011 ------------------------------------~I

CLER 01= C R ~GIT COURT HILLSBO U H --OUI TY FL

COMPLAINT FOR DEFAMATION

I Introduction

1 This action for defamation is brought by the Plaintiff Ms ELLENBETH WACHS

against the Defendants ED GOLLOBITH TRACY THOMAS NAN OWENS STEVE

BROWN MATT COOPER GLORIA JULIUS STEVE MILES and JAMES PETERSON Ms

WACHS was and asserts that she legally remains the acting president of Atheists of Florida

Inc a Florida Non Profit Corporation (the AoF) The Defendants are or were at the time of the

subject defamation members of the board of directors of the AoF (the Board) This action

arose from an email (Writing f) sent on November 6 2011 by the Defendants to the AoF

membership falsely accusing the Ms WACHS of impropriety and criminal behavior

Specifically this email stated that the Plaintiff has been expelled from the membership for

seriously obstructing the organization s business misappropriating the organizations name

misappropriating the organization s funds and acting in a way that discredits the organization

Page lof8

33782

This same email directed members to a publicly accessible website which repeated these false

claims (Writing II)

ll Jurisdiction

2 This Court has jurisdiction and venue is proper because at least one of the defendants

resides in Hillsborough County and because the amount in controversy exceeds $15000

ill Parties

3 The Plaintiff Ms ELLENBETH WACHS is now and at all times mentioned in this

complaint was a resident of Polk County Florida She is a small business owner She was and

asserts that she remains acting president of the AoF She has served as a board member the vice

president and the legal director of the AoF She resides at 5963 Lake Victoria Drive Lakeland

FL 33813

4 Defendant Mr ED GOLLOBITH is now and at all times mentioned in this complaint

was a resident of Hi llsborough County F lorida This party is or was a member of the Board and

signed Writings I and II This party resides at 4303 S MacDili Ave Tampa FL 33611-1940

5 Defendant Ms TRACY THOMAS is now and at all times mentioned in this complaint

was a resident of Pinellas County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 6411 93rd Terrace 4901 Pinellas Park FL

6 Defendant Ms NAN OWENS is now and at all times mentioned in this complaint was a

resident of Hillsborough County Florida Thi s party is or was a member of the Board and signed

Writings I and II This party resides at 4704 Lakewood Drive Seffner FL 33584

7 Defendant Mr STEVE BROWN is now and at all times mentioned in this complaint was

a resident of Pinellas County Florida This party is or was a member of the Board and signed

Page 2 of8

Writings I and II This party resides at 11640 Shipwatch Drive Villa 1431 Largo FL 33774shy

3742

8 Defendant Mr MATT COOPER is now and at all times mentioned in this complaint was

a resident of Hillsborough County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 15636 Eastboum Drive Odessa FL 33556

9 Defendant Ms GLORIA JULIUS is now and at all times mentioned in this complaint

was a resident of Pinellas County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 6382 18th Street NE St Petersburg FL 33702

10 Defendant Mr STEVE MILES is now and at all times mentioned in this complaint was a

resident of Alachua County Florida This party is or was a member of the Board and signed

Writings I and II This party resides at 6308 N W 136th Street Gainesville FL 32606

11 Defendant Mr JAMES PETERSON is now and at all times mentioned in this complaint

was a resident of Hillsborough County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 6814 Charlotte Harbor Way Tampa FL 33425

IV The Defamatory Writings

12 Writing I the first defamatory writing was sent collectively by all the Defendants via

email on November 6 2011 at 6 05 PM to the mailing list of the AoF approximately 200

individuals Writing I stated

The Board voted to remove EllenBeth Wachs as Vice President of the Organization Additionally [she has] been expelled from the membership for seriously obstructing the organization s business misappropriating the organizations name misappropriating the organizations funds and acting in a way that discredits the organization Meanwhile please keep abreast of the latest Atheists of Florida developments on our temporary website at wwwmetrodirectnetlaof

Writing I was signed

The Board of Directors of Atheists of Florida

Page 3 of8

33782

This same email directed members to a publicly accessible website which repeated these false

claims (Writing II)

ll Jurisdiction

2 This Court has jurisdiction and venue is proper because at least one of the defendants

resides in Hillsborough County and because the amount in controversy exceeds $15000

ill Parties

3 The Plaintiff Ms ELLENBETH WACHS is now and at all times mentioned in this

complaint was a resident of Polk County Florida She is a small business owner She was and

asserts that she remains acting president of the AoF She has served as a board member the vice

president and the legal director of the AoF She resides at 5963 Lake Victoria Drive Lakeland

FL 33813

4 Defendant Mr ED GOLLOBITH is now and at all times mentioned in this complaint

was a resident of Hi llsborough County F lorida This party is or was a member of the Board and

signed Writings I and II This party resides at 4303 S MacDili Ave Tampa FL 33611-1940

5 Defendant Ms TRACY THOMAS is now and at all times mentioned in this complaint

was a resident of Pinellas County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 6411 93rd Terrace 4901 Pinellas Park FL

6 Defendant Ms NAN OWENS is now and at all times mentioned in this complaint was a

resident of Hillsborough County Florida Thi s party is or was a member of the Board and signed

Writings I and II This party resides at 4704 Lakewood Drive Seffner FL 33584

7 Defendant Mr STEVE BROWN is now and at all times mentioned in this complaint was

a resident of Pinellas County Florida This party is or was a member of the Board and signed

Page 2 of8

Writings I and II This party resides at 11640 Shipwatch Drive Villa 1431 Largo FL 33774shy

3742

8 Defendant Mr MATT COOPER is now and at all times mentioned in this complaint was

a resident of Hillsborough County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 15636 Eastboum Drive Odessa FL 33556

9 Defendant Ms GLORIA JULIUS is now and at all times mentioned in this complaint

was a resident of Pinellas County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 6382 18th Street NE St Petersburg FL 33702

10 Defendant Mr STEVE MILES is now and at all times mentioned in this complaint was a

resident of Alachua County Florida This party is or was a member of the Board and signed

Writings I and II This party resides at 6308 N W 136th Street Gainesville FL 32606

11 Defendant Mr JAMES PETERSON is now and at all times mentioned in this complaint

was a resident of Hillsborough County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 6814 Charlotte Harbor Way Tampa FL 33425

IV The Defamatory Writings

12 Writing I the first defamatory writing was sent collectively by all the Defendants via

email on November 6 2011 at 6 05 PM to the mailing list of the AoF approximately 200

individuals Writing I stated

The Board voted to remove EllenBeth Wachs as Vice President of the Organization Additionally [she has] been expelled from the membership for seriously obstructing the organization s business misappropriating the organizations name misappropriating the organizations funds and acting in a way that discredits the organization Meanwhile please keep abreast of the latest Atheists of Florida developments on our temporary website at wwwmetrodirectnetlaof

Writing I was signed

The Board of Directors of Atheists of Florida

Page 3 of8

Writings I and II This party resides at 11640 Shipwatch Drive Villa 1431 Largo FL 33774shy

3742

8 Defendant Mr MATT COOPER is now and at all times mentioned in this complaint was

a resident of Hillsborough County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 15636 Eastboum Drive Odessa FL 33556

9 Defendant Ms GLORIA JULIUS is now and at all times mentioned in this complaint

was a resident of Pinellas County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 6382 18th Street NE St Petersburg FL 33702

10 Defendant Mr STEVE MILES is now and at all times mentioned in this complaint was a

resident of Alachua County Florida This party is or was a member of the Board and signed

Writings I and II This party resides at 6308 N W 136th Street Gainesville FL 32606

11 Defendant Mr JAMES PETERSON is now and at all times mentioned in this complaint

was a resident of Hillsborough County Florida This party is or was a member of the Board and

signed Writings I and II This party resides at 6814 Charlotte Harbor Way Tampa FL 33425

IV The Defamatory Writings

12 Writing I the first defamatory writing was sent collectively by all the Defendants via

email on November 6 2011 at 6 05 PM to the mailing list of the AoF approximately 200

individuals Writing I stated

The Board voted to remove EllenBeth Wachs as Vice President of the Organization Additionally [she has] been expelled from the membership for seriously obstructing the organization s business misappropriating the organizations name misappropriating the organizations funds and acting in a way that discredits the organization Meanwhile please keep abreast of the latest Atheists of Florida developments on our temporary website at wwwmetrodirectnetlaof

Writing I was signed

The Board of Directors of Atheists of Florida

Page 3 of8

Ed Golly Chair and acting President Tracy Thomas Secretary Nan Owens Treasurer Steve Brown Member of the board Matt Cooper Member of the board Gloria Julius Member of the board Steve Miles Member of the board James Peterson Member of the board

Note that Ed Golly in the list above is an alias used by the Defendant ED GOLLOBITH

13 Writing II the second defamatory writing was posted (still available as of November 29

2011) on a public website to which Writing I aftirmatively directed AoF members As quoted

above that link is http wwwmetrodirectnetlaof That website repeats the defamation

EllenBeth Wachs [has] been expelled from the membership for seriously obstructing the organizations business misappropriating the organization s name misappropriating the organizations funds and acting in a way that discredits the organization

Writing II again specifically names each of the Defendants and also calls them Signatories It

also lists three other Board members as Non Signatories Writing II has remained up and

available for any Internet users who might search for the AoF The website wwwmetrodirectnet

and its sub-domains are owned and controlled by the Defendant JAMES PETERSON

v Falsity

14 The assertions III Writing I and Writing II that Ms WACHS obstructed the AoF s

business misappropriated its name and funds and discredited the AoF are entirely false

VI Publication to Third Parties

15 Writing I was sent by email from the Defendants to approximately 200 members of the

AoF who were also directed to Writing II

16 Writing II was made and remains pubJicaly available to all Internet users who might seek

information regarding the AoF The Ledger a prominent newspaper in Ms WACHS hometown

Page 4 of8

of Lakeland Polk County Florida quoted Writing II in an article written November 7 2011

publicizing the Defendants defamatory statements to thousands of readers The article states

The action involving Wachs the vice president came Sunday morning at a

board meeting Posted on the website Monday [she has] been expelled from the

membership for seriously obstructing the organizations business misappropriating

the organizations name misappropriating the organizations funds and acting In a

way that discredits the organization [emphasis added]

VIT Injunction

17 It is appropriate and Ms WACHS moves that this Court declare an immediate injunction

pending the outcome of the his case requiring the Defendants to remove Writing II from the

Internet and to generally cease all dissemination of the assertions regarding Ms WACHS made

in Writings I and II

VIII Inj ury to Plaintiff and Damages

18 The Defendants engaged in defamation per se when they falsely accused Ms WACHS of

misappropriating the AoFs name and funds and obstructing and discrediting the AoF The

Defendants statements accused Ms WACHS of criminal behavior and behavior

incompatible with both her business and her office within the organization The

Defendants statements amount to defamation per se and Ms WACHS injury is presumed

19 Regardless Writing I and Writing II clearly expose Ms WACHS to hatred contempt

and ridicule from the AoF membership-those over whom she exercises a position of

trust-and from the public when they read that the Defendants assert that she has

obstructed organization business misappropriated its name and funds and discredited the

organization

Page 5 of8

20 As a proximate result of the Defendants defamatory writings Ms WACHS has suffered

loss of her reputation shame mortification and injury to her feelings Further she has expended

much time away from tending her business to combat the Defendants false statements All this

is to her damage in the total amount of$100000

21 In alterative or addition to negligence the Defendants published Writings I and II with

malice with reckless disregard as to whether-or with knowledge that- the defamatory

statements were false with hatred and ill will towards Ms WACHS and seeking to

destroy her reputation Because of the Defendants malice Ms WACHS seeks punitive

damages in the total amount of$100000

IX Joint and Several Liability

22 Because the Defendants acted in concert as is shown by their names listed at the bottom

of Writings I and II they are jointly and severally liable for damages

WHEREFORE the Plaintiff Ms ELLEN BETH WACHS demands judgment against the

Defendants jointly and severally

1 Compensatory damages in the amount of $100000

2 Punitive damages of in the amount of $100000

3 Interest as allowed by law

4 Reasonable attorneys fees costs and expenses

5 Immediate Injunctive relief in the Defendants ceasing of all dissemination of the

defamatory statements and

6 Such other and further relief as this court may deem just and proper

Page 6 of8

I ElienBeth Wachs do hereby verify under penalty of perjury under the laws of the United

States of America that the foregoing complaint is true to the best of my knowledge

information and belief is based upon my personal knowledge and is true and correct

Dated 0+Ic IJ ELLENBETH WACHS

Page 7 of8

PARTIES ON WHOM TO SERVE COMPLAINT

BROWN Steve 11640 Shipwatch Drive Villa 1431 Largo FL 33774-3742 727 595-4864 brownsteveverizonnet

COOPER Matt 15636 Eastbourn Drive Odessa FL 33556 813 920-0231 mattprogressgmaiLcom Cell 626 808-7490

GOLLOBITH Ed 4303 S MacDil1 Ave Tampa FL 33611-1940 813 839-7567 Edgollystudioaolcom Cell 813 325-9139

JULIUS Gloria 6382 18th Street NE St Petersburg FL 33702 727 525-1446 glojuliusmsncom

MILES Steven 6308 NW 136th Street Gainesville FL 32606 352 332-1727 smileschemufledu

OWENS Nan 4704 Lakewood Drive Seffner FL 33584 813 662-6612 nanowensix netcomcom Cell 813 424-2558

PETERSON Jim 6814 Charlotte Harbor Way Tampa FL 33425 813 531-8138 jamestpij net Cell 727 271-3549

THOMAS Tracy 6411 93rd Terrace 4901 Pinellas Park FL 33782 727 235-3220 mschachatampabayrrcom

Page8of8

20 As a proximate result of the Defendants defamatory writings Ms WACHS has suffered

loss of her reputation shame mortification and injury to her feelings Further she has expended

much time away from tending her business to combat the Defendants false statements All this

is to her damage in the total amount of$100000

21 In alterative or addition to negligence the Defendants published Writings I and II with

malice with reckless disregard as to whether-or with knowledge that- the defamatory

statements were false with hatred and ill will towards Ms WACHS and seeking to

destroy her reputation Because of the Defendants malice Ms WACHS seeks punitive

damages in the total amount of$100000

IX Joint and Several Liability

22 Because the Defendants acted in concert as is shown by their names listed at the bottom

of Writings I and II they are jointly and severally liable for damages

WHEREFORE the Plaintiff Ms ELLEN BETH WACHS demands judgment against the

Defendants jointly and severally

1 Compensatory damages in the amount of $100000

2 Punitive damages of in the amount of $100000

3 Interest as allowed by law

4 Reasonable attorneys fees costs and expenses

5 Immediate Injunctive relief in the Defendants ceasing of all dissemination of the

defamatory statements and

6 Such other and further relief as this court may deem just and proper

Page 6 of8

I ElienBeth Wachs do hereby verify under penalty of perjury under the laws of the United

States of America that the foregoing complaint is true to the best of my knowledge

information and belief is based upon my personal knowledge and is true and correct

Dated 0+Ic IJ ELLENBETH WACHS

Page 7 of8

PARTIES ON WHOM TO SERVE COMPLAINT

BROWN Steve 11640 Shipwatch Drive Villa 1431 Largo FL 33774-3742 727 595-4864 brownsteveverizonnet

COOPER Matt 15636 Eastbourn Drive Odessa FL 33556 813 920-0231 mattprogressgmaiLcom Cell 626 808-7490

GOLLOBITH Ed 4303 S MacDil1 Ave Tampa FL 33611-1940 813 839-7567 Edgollystudioaolcom Cell 813 325-9139

JULIUS Gloria 6382 18th Street NE St Petersburg FL 33702 727 525-1446 glojuliusmsncom

MILES Steven 6308 NW 136th Street Gainesville FL 32606 352 332-1727 smileschemufledu

OWENS Nan 4704 Lakewood Drive Seffner FL 33584 813 662-6612 nanowensix netcomcom Cell 813 424-2558

PETERSON Jim 6814 Charlotte Harbor Way Tampa FL 33425 813 531-8138 jamestpij net Cell 727 271-3549

THOMAS Tracy 6411 93rd Terrace 4901 Pinellas Park FL 33782 727 235-3220 mschachatampabayrrcom

Page8of8

I ElienBeth Wachs do hereby verify under penalty of perjury under the laws of the United

States of America that the foregoing complaint is true to the best of my knowledge

information and belief is based upon my personal knowledge and is true and correct

Dated 0+Ic IJ ELLENBETH WACHS

Page 7 of8

PARTIES ON WHOM TO SERVE COMPLAINT

BROWN Steve 11640 Shipwatch Drive Villa 1431 Largo FL 33774-3742 727 595-4864 brownsteveverizonnet

COOPER Matt 15636 Eastbourn Drive Odessa FL 33556 813 920-0231 mattprogressgmaiLcom Cell 626 808-7490

GOLLOBITH Ed 4303 S MacDil1 Ave Tampa FL 33611-1940 813 839-7567 Edgollystudioaolcom Cell 813 325-9139

JULIUS Gloria 6382 18th Street NE St Petersburg FL 33702 727 525-1446 glojuliusmsncom

MILES Steven 6308 NW 136th Street Gainesville FL 32606 352 332-1727 smileschemufledu

OWENS Nan 4704 Lakewood Drive Seffner FL 33584 813 662-6612 nanowensix netcomcom Cell 813 424-2558

PETERSON Jim 6814 Charlotte Harbor Way Tampa FL 33425 813 531-8138 jamestpij net Cell 727 271-3549

THOMAS Tracy 6411 93rd Terrace 4901 Pinellas Park FL 33782 727 235-3220 mschachatampabayrrcom

Page8of8

PARTIES ON WHOM TO SERVE COMPLAINT

BROWN Steve 11640 Shipwatch Drive Villa 1431 Largo FL 33774-3742 727 595-4864 brownsteveverizonnet

COOPER Matt 15636 Eastbourn Drive Odessa FL 33556 813 920-0231 mattprogressgmaiLcom Cell 626 808-7490

GOLLOBITH Ed 4303 S MacDil1 Ave Tampa FL 33611-1940 813 839-7567 Edgollystudioaolcom Cell 813 325-9139

JULIUS Gloria 6382 18th Street NE St Petersburg FL 33702 727 525-1446 glojuliusmsncom

MILES Steven 6308 NW 136th Street Gainesville FL 32606 352 332-1727 smileschemufledu

OWENS Nan 4704 Lakewood Drive Seffner FL 33584 813 662-6612 nanowensix netcomcom Cell 813 424-2558

PETERSON Jim 6814 Charlotte Harbor Way Tampa FL 33425 813 531-8138 jamestpij net Cell 727 271-3549

THOMAS Tracy 6411 93rd Terrace 4901 Pinellas Park FL 33782 727 235-3220 mschachatampabayrrcom

Page8of8