Animal Welfare

Advocates Of SW
FIorida

May31, 2018

The Honorable Stephen B. Russell VIA CERTIFIED MAIL

O鮪cc ofthc Statc Attomcy, 20th Judicial Circuit AND EMAIL
2000 Main St.
Fort Myers, FIorida 3390 1

RE: Section 1983 Complaint against ChiefAssist. State Attomey Amira Fox

Dear Mr. Russell,

Anima看WeIfare Advocates Of SW FIorida, rePreSentmg l ,355 animal advocates with concem

OVer the lack of law enforcement and prosecution ofthe 4 illegal slaughterhouses that are
OPerating to this day in Lee County.

Please find attached制ed Section 1983’Freedom of Speech complaints agamSt ChiefAssist.

State Attomey Amira Fox and’Amira Fox for State Attomey for deleting, and/or banning/

b]ocking citizens fi-Om theいAmira Fox for State Attomey,, Facebook Page. This is a violation of

COnSt血tional rights 42 U.S.C. § 1983.

“A Federal District Co皿Judge ruled that residcnt Trump can't block people from his

Twitter feed. Judge Naomi Reice Buchwald, Ofthe U.S. Dis証ct Court for the Southem District

OfNew York, Sajd President Trump’s Tw組er account is a public forum and blocking people who

reply to his tweets with differing opmio宣lS COnStitutes viewpoint discrimination, Which violates

the First Amendment. - ‘`Because no govemment O描cial is above the law and because all

govemment o締cials are presumed to fo11ow the law once thejudiciary has said what the law is,
WC muSt aSSumC that the President and Scavino will remedy the blocking we have held to be
しmCOnStitutional:’Buchwald wrote. (Fro′′7 7T妬#lLL)

We肌y expect, the Honorable State Attomey Stephen Russe喜l w紺fo=ow Judge Buchwald’s

decision and remove Chie†Assist・ State Attomey Amira Fox from her position at the State

Attomey O館ce for violations of Constitutionally protected Frecdom of Speech.

Please contact us via Email, eflana象an75@gmail"COm. We look forward to a prompt response to

this matter.

乙___《_
Edward Flanagan
Animal We賞fare Advocates Of SW FIorida

Animal Welfare Advocates Of SW FIorida

May 29, 2018

The Honorable Stephen B. Russell

O綿ce ofthe State Attomey, 20th Judicial Circuit

2000 Main St.

Fort Myers, FIorida 33901

RE: Freedom of Speech Sec. 1983 Complaint against Assist. State Attorney Amira Fox

Dear Mr. Russe11,

As a longtlme Animal Rights Advocate, I expressed my concem over the lack ofprosecution of
the 4 illegal slaughterhouses that are operating in Lee County on the “Amira Fox for State

Attomey” Facebook Political Public Forum page, Only to have my posts immediately deleted.

That is a violation of Constitutiona11y protected Freedom of Speech rights 42 U.S.C. § 1983.

This resulted in my commentlng infommg “Amira Fox for State A請Omey”, that deleting
COmmentS is a violation of First Amendment Freedom of Speech. And, Still had my posts deleted
as well as others commentmg On my POSt, their comments deleted.

There has been型response from Amira Fox on any posts asking for response. Any supporters of

Amira Fox, attaCking people were not deleted from the Amira Fox for State Attomey Facebook
Page. The only deleted posts were those that were disagreeal)1e or asking questions which the
ChiefAssist. State Attomey did not want to answer.

The policy to delete comments, block individuals from postmg, then calls into question the
investigation and evidence from the Lee County Sheri紺s O能ce with the State Attomey O触ce
in the 4 illegal slaughte血ouses that are allowed to operate with some ofthe most horrific animal

al)uSe Witnessed by ARM Animal Recovery Mission・

(deleted posts attached)

Recently, a Federal District Court Judge ruled President Trump can’t block people to prevent

from expressmg differing opmions on his Tw誼er account “Knight Institute v. Trump’’・ President

Trump’s Twitter account, aS =Amira Fox for State Attomey,, Facebook page is a public forum

and blocking, PreVentmg PeOPle with differing opmions const血tes vleWPOint discrimination,

which violates the First Amendment.

Judge Buchwald wrote, “Because no govemment o触cial is above the law and because all

goverrment o揃cials are presumed to follow the law once the judiciary has said what the law is,
we must assume that the President and Scavino will remedy the blocking we have held to be
unconstitutional. ”

1454 Ocean Shore BIvd., Suite lO6, Ormond Beach FL 32176

The State Attomey O純ce is entrusted by血e Public to uphold the Law; CamOt be mired in

COntrOVersy and distrust by a Chief Assist. State Attomey, Amira Fox that would engage in
Violating pcople’s constitutionally protected rights of Freedom of Speech.

ChiefAssist. State Attomey lS entnrsted by the people to uphold the Law, aS an O純cer ofthe

Court ruming for血e highest position in the 20th Judicial Cireuit of血e State ofFIohda needs to

be held to the highest standard. The State Attomey O能ce camot be above the law.

I fully expect the Honorable State A請Omey Stephen Russell ask ChiefAssist. State Attomey

Amira Fox to immediately reslgn from her position at the State Attomey O能ce for conduct that

is unconstitutional, violates the First Amendment.

I Iook forward to a prompt response to this ma備er.

Sincerely,

四四四
Sal)ina Kowalczyk
Animal Rights Advocate
IVOTEforAnimal s(初貧mail. com

1454 Ocean Shore BIvd., Suite lO6, Omond Beach FL 32176

Below are screenshots of deleted posts. There are other posts of people commenting,
responding to my posts that have been deleted・ Which can be seen, nO longer there since on
Facebook there is a comment count. But, When you click to view the comments… nOne are

displayed.

DELETED POST -AMIRA FOX FOR STATE ATTORNEY 5-11-18

ぐ  C きSecuie https声WW.facebook.com高、守主語d正昭㌦

Ami「a Fox fo「 State Attomey

塵」ike S¥ Fo=ow ,多Share

(高 Sabina KowalczykAmlra Fox YOU ST忙L HAVE NOT

RESPONDED you are 「unnmg fo「State Atto「ney pe「haps

you would care to comment slnCe thiS IS yOur CamPalgn Page

and. you have done P「ess video 「efuslng tO P「osecute the
ho「両C da=y sIaughte…g guttIng and skmnlng O仙ve anlmals
animal sac而ICe同egaI agg「ess10n tralnIng Of dogs fo「 the blood
SpO直dog¶gh佃g

中ust walched the ARM lnvestigat10∩ Vldeo of a cow the th「Oai

SIItWlde open on the floo「 m POOI of blood d「alnlng Out Chest
S岨open thelegsbeIngSkinned ailVe thecow, ALIVE lay
W冊e冊g On trle f【oo「肌POOIs o川S OWn btood thIS Went On
fo「 20 minuteSI

ThiS gOeS On fo「 h…d「eds ofanimals each day atthe 4 Iilegal

SlaしIghte「houses ope「atIng旧yOu「 County川

Lee County has been glVen ail the evldence ThlS has been
gomg on s肌Ce 2015 --- NO InvestlgatiOn NO P「OSeCUt10nl
PLEASE RESPOND

」ike R印中「n「

/1
工ノ/

Amira Fox fo「 State Attorney

同封きる再32即「

1454 Ocean Shore BIvd., Suite lO6, Omond Beach FL 32176

DELETED POST REPOSTED - AMIRA FOX FOR STATE ATTORNEY 5-11-18
No慣ng deleting comments is viola慣on of First Amendment

Sam Steele, aCCOrding to him, is a Goverrment empIoyee who,s corrment is sexist and violates
Federal law.

ぐ   C i Se⊂ule∴https ww.fa⊂ebook.com立¥t`へへ∴口証二鳥”`‘>`

Ami「a Fox fo「 State Attomey Q

細LIke S¥Fo=ow ‘吟Sha「e

Sam SteeIe B「ainS and beautydangerous conlblnatlOn YoしI

have my vo-e

」庇e 〔ミe書中 2n

Pat Jones S佃not unde「Standl11g Why用ose 「anches a「e s佃

UP and 「uming? Why canit sonleOne a=he ve「y least go ln and
CeaSe ail ope「atlOnS ban the people f「om値ose 「anches f「om
havlng animais based of白he vldeod evldence? l白t’s
lnadmiSS心ie to p「OSeCU See Mc「e
Ami「a Fox for State
」叛e Rep母∴1h
⑪
Atto「ney

〈高 Sabina KowalczykAmi「a Fox I posted ea画er and see my

P。St deleted That -S a V-OlatlOn Of constitUtlOna=y protecled

Fl「St Amendment Sec 1983 whlC旧he State Atto「ney OfflCe has
Home
ai「eadY had complaInls flled -- The ChIefAssISt Sta(e Atto「ney
to engage m v101ating F「eedom of Speech川m…g fo「 State
About
Alto「ney askmg yOll 「eSlgn --- We cannOt have peopie ent「usted
to enfo「ce the Laws, themselves lnVOIved ln ViOIating the Law
lssues

YOU STILL HAVE NOT RESPONDED you a「e runnlng for

E ndo「SementS
State Atto「ney perhaps you wouId ca「e to comment s-nCe仙s
IS yOu「CamPa'gn Page and you have done P「ess v-deo
Videos 「efus冊g tO P「osecute the ho「「lfic da一(y siaughte「mg gu章ting a'1d
Sklnnlng O川ve a印mals, anlmaI sacrmce用egal agg「essIOn
Posts
training Of dogs fo「 the blood sport dogflghtlng

Events 巾St WatChed the ARM lnvestigatlOn VIdeo of a cow the th「Oat
S帆Wlde open on the floo「 ln POO1 0f b10Od d「a剛ng Out Chest
Photos S=tOPen, the legs belng Sklnned a白Ve the cow, ALlVE lay
WItherlng On the fIoo「 In POOIs o白t’s own blood thlS Went On

Comm即時 fo「 20 mlnUteSI

ThlS gOeS O両o「 hund「eds of anlmals each day a=he 4川egal

細田的五五 SIaughte「hoIISeS OPe「at ng ln yOu「 CountyIII

LeeCo…ty has been glVen a旧heev-dence ThlS has been

golng On S一nCe 2015 ○○- NO lnvestigat‘On, NO P「OSeCutiOnl

PLEASE RESPOND

」庇e Re函「nl

1454 Ocean Shore BIvd., Suite lO6, Omond Beach FL 32176

DELETED POST -AMIRA FOX FOR STATE ATTORNEY

Post was deleted after posting to notify it is vio看ation of First Amendment to delete posts・

ぐ  C i SecuIe https,′′′www.facebook.comlflつ、車IS高畠∴l当主),

Amira Fox fo「 State Attomey

向Llke ;` Fo=ow ′牟Share
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(紺sabina Kowa-czyk Am-ra Fox
しhonored’fundraISlng haveVOteS
ge(tlng you ata
'no- s-1ame
Charlty tO be
forc回d「en

heiped wIth tlle「aPy ho「ses When the「e are slaughte「houses

「平子的要吉 in Lee County that a「e i=egally sIaughte「mg butcrle間g and
Se冊g horse mea主-- ho「SeS that we「e someones pets

Amira Fox you 「efuse to P「osecute ---A=ow suppo「‖l(egaI

Slaughte「 Of horses sale of horse meat

」座号∴承eply ln「

1454 Ocean Shore BIvd., Suite lO6, Ormond Beach FL 32176

DELETED Linda Sue Response to My POST -AMIRA FOX FOR STATE ATTORNEY

Linda Sue post was “Immediately de賞eted,,, aS SOOn a§ I went to Like, the post --- reCeived

the message, “The comment you’re trying to react to was de量eted. Try refreshing the page’’

I was watching a Live Stream of Richard Couto, A則M reviewing the Lee County Sheri鯖’s

O縦ce investigation report received through a Freedom of Information request. Where the
LCSO Detective witnesslng Criminal animal abuse did not arrest. The claim was camera
WaS nOt WOrking at the time. 〇〇〇 When is an O鮪cer, Detective’s sworn tes償mony not
admissible in a court of Iaw?

Described in the Detective,s Report, WaS a Pig having his body parts cut off while alive,
then stabbed… this went on for 30 min. while the pig was alive.

We have a Sheriff,s O縦ce and State Attomey O鮪ce coverlng uP, the mo§t horrific animal
S賞aughter of live animals) eVer Witnessed by A則M 〇〇〇 Fe獲ony criminal abu§e Of animals・

In this Country we have Humane Slaughter Laws.

What A則M witnessed were Live animals’throats slit, body cut open, boiled, Skinned
ALIVE allowed to su∬er, tOrture for 20-30 minutes, i11egal horse s萱aughter… aggreSSion
training of dogs for Fe賞ony dog鯖ghting・ 〇〇〇〇 Lee County Detective witnessed? nO arreSt Or

PrOSeCution.

This has been known to Sheri請うs O鮪ce since 2015.

㊥慧‡慧誓喜郎調即せ
! 《悪業細め鋤鍋融0跡地のし勝
e轟き餓,        却珊紺91oV直は

曲順●  鍵Co競軸 分納調 船・

⊥ ㍉ 言 l i 言 i i “ l
●n鶴          uロ録も直

朗事            (塙I短細江

丁-)e C買Im糾y〇両e中年等の「eaC( :○ ↓∂S deel∞申子e府Sh明く短pa匂e

I請eoYe町脚部めれ〇二で」 No「宝玉
像も撮職で○朗同¥れ競れ青竹紬o断的蜘
pd叩糾uのめは畔e手脚肌

秘謀議雑器蕊諒恕諾認諾嵩。
Ⅲ鵡e請e臓糊慣ら8巾e柳○○(ev〉如競獅.打OS○○ut轟測
cαMde創_ W京寄り§物e刊調的冊周仇小鳩S館はA櫨〇億ey
o鵬海部e的R鵬e寄鍋ifar耽…調香を偽や    ⑫ケ
曲き 京磯や 甑

草 間的su●S却的的吋8駆寄は塙弧爪-相調e$両川も
￣ h同軸d同調AいV∈lo硬I舶tく飼ゆ崎珊請同調h
○○心利のp(軸1川e巾l同調同種(肌S Ial竹的b観山栂
的○○ト同鴎の叫か抑飢dヽiI雌〔印也b叱り的1(he
綿的I重出的掛)9 00肌しe○co同(y c創削れ朋〇時1船 曲尺勧 め 駁弱
脚出張的鵜けらうめ的…
しく具c 只OかY 糾
薫 蒸鑓認諾諾蓋露語

1454 Ocean Shore BIvd., Suite lO6, Omond Beach FL 32176

DELETED Linda Sue Response to My POST -AMIRA FOX FOR STATE ATTORNEY
screenshot taken 5-30-18’does not show Linda Sue,s post reply to my post’it was deleted・

The posts were tO Amira Fox posted response to Cecil Pendergrass Letter asking the SAO
fdr investigation of the slaughterhouses posted as response by SAO・ The referred to LCSO
Detective Report was from the FOX4NOW News, ((FORT MYERS, Fla. ○○ Docments
obtained by 4 In Your Comer shed light onto under cover investigations by the Lee County
sheriffs O純ce into fams”... huge stack of LSCO Reports on the investigation including
the LSCO Detective who witnessed animal crue量ty of the live pig having testicles cut o∬ to
be sold to a customer’the pig stabbed with the pig alive for 30 minutes・

NO ARREST BY DETECTIVE.

h調S ://wW.fck4now.com/newsnocal-neWS/undercover-血vesti軸tionl}fL辿鈍ed-Slaug哩丁哩

ぐ∴∴∴○ ○ Secし- e 冊PS 剛ねceb○○k⊂Om買, 、へ¥ 、て涌†つ

Ami「a Fox fo「 Sta(e Attomey

高¥ sabina Kowalczyk The「e iS Nothlng用ega‖n the ARM lnVeStlgatlOn

__ Otner Collnties State Atto「ney OfflCeS have llSed the exact same

type ofevldence P「osecuted and ConvICted」一What lS the

p「obIem wlth thIS State Atto「ney Offlce Steve Russell Amira Fox
that lS mCaPable of p「osec画g and spends a冊el「time tryIng tO
dlSC「edit ARM InStead of do-ng a C「edlble lnVeStigat-On and a「「estI --
- Or lS theしee County Sherlff‘s Off'Ce川St aS inCaPable of dolng an

lnVeStngat-On aS the State Attorney.s Offree ln P「OSeCut-ng?ll

The Sher洞's OfflCe dld thei「 '一Lega=nvestlgat-On fo「 2 yea「S川ow

Iong does lt take to lnVeStLgate a∩d cha「ge when you have
DetectlVeS that面nessed c「-m-nal Anlma! C「ueIty and D-d Not
cha「geI- C-ai…ng, because d‘d no- ge白t on video --- 1 am ‘NOT
awa「e of any anmaI cruefty cases whe「e the abuse had to be on
vldeo NOTONE Case!
-In the 「eporf, detectlVeS Say they w-tneSSed wo「ke「S Cut Off the

hog.s tes佃es w帥e It WaS S冊油Ve a∩d stab the pig ln the冊Oat
Although they wltneSSed the lnC'den=he 「eport sayS detectIVeS
could not make an ar「est because the…nde「COVe「 Vldeo d-d not
show the kl=lng When lt happened:

when lS Law enfo「cement swom w-tneSS teSt‘mOny “r‘Ot“ admlSS-bie

in COu「t? - Aml「a Fox maYbe yoll WOuId ca「e to anSWe「 that -

pしEASE RESPOND and D…Ot De-ete my Post Tha。S a VIOぬtlOn

of Sec 1983. FlrSt Amendmen洋「eedom Of Speech
㊥ト
」Ike Re[時 6〔j

Nicole Gustin l have been at eve「Y P「OteSt SinCe the ve「y

beg…ing l have w緬essed so many …egal act一VitleS COm‘ng f「om
a旧arms Why a「e they contlnued to ope「ate withou川CenSeS
iLLEGAL wlthout InSPeCtlO=S, iしLEGAしW冊OUt Paylng (axeS?
忙しEGAL Theyadmlt See上1ore
⑱∴
」椋e Reply 6d

E「ika McDe「mott The Lee County She「醇e Deparfment Ag「lClllture

Deputy has a 「epo柵a白S Pub旧hat he ¥画essed testlCle§ beng
cut offa ve「y "ve plg 'ttook ove「冊y m…teS and they we「e be肌g
sold l do beIieVe that lS anlma=o面子e and an ar「est couid have
been made lmmedlate-y Co「「ect me I= am w「Ong Why has then
been hldden 8∩d nothmg dor‘e about lt?

1454 Ocean Shore BIvd., Suite 106, Omond Beach FL 32176

FOX4NOW News, “4 In Your Comer requested reports to find out how the Sheriffs O縦ce is

responding the the animal abuse claims. They provided hundreds ofpages of documents
detailing undercover investigations conducted over two years.負

ht巾S ://www.fox4now.com/news/1ocal-n eWS/undercover-investigation-Of」alle雄d-Slau如ter-farms

Detective who witnessed animal crueIty of the live pig having tes債c量es cut ofl stabbed○○

NO ARREST BY DETECTIVE.

"Dul!ng thIs tlme章OII the men had

種bIg hog tled to a fence attemptIng

to cut o請Itls testlcIes. Due to the sI基e
and resIstance from the anlmaI. 1t
t0Ok the men opplO責Imately 3O mInutes
to筒na=y cut the anlmさis testlcIes o請購

1454 Ocean Shore BIvd., Suite lO6, Ormond Beach FL 32176

 BEFORE THE OFFICE OF THE STATE ATTORNEY
20TH JUDICIAL CIRCUIT OF FLORIDA

Stephen B. Russe11
State Attomey - 20th Judicial Circuit
Post O珊ce Box 399
Fort Myers, Florida 33902-0399; and

Amira Fox for State Attomey and Amira Fox, ChiefAssist. State Attomey
Post O能ce Box 399
Fort Myers, FIorida 33902-0399

COMPLAINT

RE: Section 1983 Complaint against Chief Assist. StaLte A請orney Amira Fox

ChiefAssist. State Attomey Amira Fox is rummg for State Attomey for the 20th Judicial Circuit
and has a Politうca] Facebook Campalgll Page. “Amira Fox for State Attomey.

Recently, m SPeaking out about the most hoI丁ific abuses ofanimals uncovered in the ARM

Investlgation occumng a[ 4 Illegal SlaしIghterhouses operatmg m yOur County, aSking for

invcstlgation and lack ofprosccution by you宣・ O綿cc and’Amira Fox particularly’my COmmCntS

were deleted, and/or l was bamed from the “Amira Fox for State Attomey’’Facebook Page. This

is a violation ofmy constitutional rights 42 U.S.C・ § 1983.

1t is a violation ofSection 1983 for a state or municIPal govemment to take actio皿designed to

PreVent Or intimidate peopIc from exercismg their First AmC丁ldlnent rights, Or Punうsh them for
doing so, and there can be no dispute that complaining about inhumane conditions at 4 Illegal
Slaughterhouses operatlng in Lee County for which ChiefAssist. State Attomey Amira Fox has
Publicly stated that she w川not prosecute is a protected right・

In fact, this was a dircct response to delete comments and prevent from speaking about the
abuses and lack ofprosecution by Lee County Prosecutors.
A cjtizcn no{ only has thc First Amcndment t.ight to §Peak out agalnSt a gOVellmerltal elltlty’he

or she also has a const血tiona11y protected right to demand that the govcmment correct the

Wl'OngS that are identificd. As the Supreme Court has stated, a gOVemment entity “may not deny

a benefit to a person on a basis that infringes his constitutionally protected interests-eSPeCially.

his intcrcst in frccdom of spccch.’’

The policy to delete comments and ban individuals from speaking out are so obviously contrary
to our country,s fundamental prlnCip置es of liberty and clearly皿constitutiol-al, I am asking that

ChiefAssist, State Attomey Amira Fox reslgn her position in the State Attomey’s O揃ce.

Respectfu11y Submitted,

αしの噂eし亀子

Email :
 t Name:
之ミ§ G

SWORNBEFOREME atthecity of烏γ十n`「<rS

艶革器登山s
」OAN唯日U同G球

A Notary Public for 購Yぐ年・-SS-O潮昨製靴

l・′弾ES:心州1〇・柳柳
The State of FIorida 的細で両uゆ-博滅相露同調場
My Commission Expires し直匂l24

下と子切博し上手…へも博一 園田四国
 BEFORE THE OFFICE OF THE STATE ATTORNEY
20TH JUDICIAL CIRCUIT OF FLORIDA

Stephen B. Russe=
State Attomey - 20th Judjcial Cjrcuit
Post O冊ce Box 399
Fort Myers, FIorida 33902-0399; and

Amira Fox for State Attomey and Amira Fox, ChiefAssist. State Attomey
Post O舘ce Box 399
Fort Myers, FIorida 33902-0399

COMPLAINT

RE: Section 1983 Complaint against ChiefAssist. State Attorney Amira Fox

Chief Assist. State Attomey Amira Fox is rummg for State Attomey for the 20th Judicial Circuit
and has a Politica喜Facebook Campa獲gn Page. “Amira Fox for State Attomey.

Recently, m SPeaking out about the most horrific abuses ofanimals uncovered in the ARM
Investlgation occ皿mg at 4 Illegal Slaし1ghterhoしISeS OPeratmg m yOur County, aSking for

invcstlgation and lack ofprosccution by your O粕cc and’Amira Fox pa11icularly・ my COmmCntS

were deleted, alld/or l was banned from the `Amira Fox for State Attomey,, Facebook Page. This
is a violation ofmy constitutional rights 42 U.S.C・ § 1983.

1t is a violation of Section 1983 for a state or municIPal govemment to take action designed to
prevent or intimidatc people from cxcrcismg their First Amcndment rightS’Or Punish tIlem for
doing so, and there can be no dispute that complaimng about inhumane conditions at 4 Illegal
Slaughterhouses operatlng in Lee County for which ChiefAssist. State Attomey Amira Fox has
publicly stated that she wi11 not prosecute is a protected right.
In factJhis was a direct response 10 delete comments and prevent from speaking about the
abuses and lack ofprosecution by Lee County Pl●OSeCutOrS.

A citizcn not only has the First Amcndmcnt l-ight to spcak ol-t agamSt a gOVCmmCntal cmtlty’hc

or she also has a constitutionally protected right to demand that the govemment correct the
wrongs that are identified. As the Supreme Court has stated, a gOVemment Cntltyいmay nOt deny
a benefit to a person on a basis that infringes his constitutiona11y protected interests-eSPeCially・

his intcrcst in frccdom of spccch.’’

The policy to delete comments and ban individuals from speaking out are so obviously contrary
to our co皿try,s fuldamental pmCiples of liberty and c]early unconstitutiona工I am asking that

ChierAssist. State Attomev Amira Fox 「eslgn her POSitioll in the State Attomcy’s O揃ce.

Respectfully Submitted’

Email : し○○に_-eO nへ
SWORN B oREMEat,h。。i,,。f f千言n`HerLS
in the State of FIorida this

A Notary Public for

The State of FIorida
My Commission Expires
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 BEFORE THE OFFICE OF THE STATE ATTORNEY
20TH JUDICIAL CIRCUIT OF FLORIDA

Stephen B. Russe=
State At↓omcy - 20th Judicial Cjrcuit

Post O珊ce Box 399

Fort Myers, Florida 33902-0399; and

Amira Fox for State Attomey and Amira Fox’ChiefAssist. State Attomey

Post Office Box 399

Fort Myers, FIorida 33902-0399

COMPLÅINT

RE: Section 1983 Complaint against ChiefAssist. State Attornev Amira Fox

ChiefAssist. State Attomey Amira Fox is rummg for State Attomey for the 20th Judicial Circuit
and has a Po=tical Facebook Campalgn Page, “Amira Fox for State Attomey.

Recently, 1n SPeaking out about the most horrific abuses ofanimals uncovered in the ARM
lnvestlgation occumng at 4 Illegal Slaし1ghterhoしISeS OPeratmg m yOur County’aSking for

invcstlgation and lack ofprosccution by your O鮒cc and’Amira Fox particularly, my COmmCntS

were deleted, and/or l was bamed fro n the "Amira Fox for State Attomey Facebook Page. This
is a violation ofmy constitutional rights 42 U.S.C. § 1983.

1t is a violation ofSection 1983 for a state or municIPal govemment to take action designed to
prevent or intimidate pcop'e from cxercISlng thc証irst Amcnd-nCnt rights’Or Punish tllCm for
doing so, and there can be no disputc that complainlng about inl…nane COnditions at 4 Illegal

SlaしIghterhouses operatlng in Lee County for which ChiefAssist. State Attomey Amira Fox has

publicly stated that she will not prosecute is a protected right.

In frty this was a direct rcsponse to de置etc commentS and prcvent from speaking about the

abuses and lack ofprosccution by Lee CoしInty Pl・OSCCutOrS.

A citizen not onIy has the First Amcnd-TICr血・1ght to speak oし1t agamSt a gOVel「…Cntal cntlty点e

or she also has a constitutionally protected right to demand that the govemment COrreCt the
wrongs that are identified. As the Supreme Court has stated・ a gOVemment entlty "may not dcny

a benefit to a person on a basis that infringes his const血tionally protected interests-eSPeCially‘

his intcrcst in frocdom of spccch.’’

The policy to dclete commcnts and ban individuals from speaking oししt are SO Obviously contrary

to our coしmtry,s fundamenta- p一・1nCiples ofliberty and c】early ullCOnStitutiona口am asking that

ChiefAssist. State Attomcy Amira Fox rcslgn her position in the State Attomey,s O揃cc・

Respect餌1y Submitted,

ヽ いQ・  ぐl

s‥ユSn__∩し)i堂山J巳〉・単軸亀戸

〇台m売主Uo草へ
Print Name:

SWORN BE OREMEatthecityof 円.' /Y¥咋Yつ

in the State of FIorida this
虞リセへ

」OAM冨8∪閤韻
A Notary Public for
w oo潮約〇細評拙腿
The State of FIorida 的鵬:帥19・捌)
My Commission Expires 如佃…帥砂は珊帥農

市中α均祐…へん狙
園園田
 BEFORE THE OFFICE OF THE STATE ATTORNEY
20TH JUDICIAL CIRCUIT OF FLORIDA

Stephen B. Russe11
State Attomcy - 20th Judicial Grcuit
Post Office Box 399
Fort Myers, FIorida 33902-0399; and

Amira Fox for State Attomey and Amira Fox, ChiefAssist. State Attomey
Post O批ce Box 399
Fort Myers, FIorida 33902-0399

COMPLAINT

RE: Section 1983 Complaint against ChiefAssist. State Attomey Amira Fox

ChiefAssist. State Attomey Amira Fox is rumlmg for State Attomey fo量・ the 20th Judicial Circuit

and has a Political Facebook Campalgn Page, “Amira Fox for State Attomey.

Recently, m SPeaking out about the most hoITific abuses of animals uncovered in the ARM
Investlgation occum11g at 4 Illegal SlaしIghterhoししSeS OPeratmg m yOur County, aSking for

invcstlgation and lack of prosccution by your O餓cc and, Amira Fox particularly, my COmmCntS

were deleted, and/or I was bamed from the “Amira Fox for State Attomey” Facebook Page. This

is a violation ofmy constitutional rights 42 U.S.C. § 1983.

1t is a violation ofSection 1983 for a state or municIPal govemment to take action designed to
prcvent or jntjmidate peopIc from cxercISmg thcir First Amendment rights’Or Punish them for
doing so, and therc can be no dispute that complaimng about inhumane conditions at 4 Illegal
SlaしIghterhouses operatmg in Lee County for which ChiefAssist. State Attomey Amira Fox has

publicly stated that she will not prosecute is a protected right.

In fac=his was a direct response to delete comments and prevent from speaking aboしIt the

abし1SeS and lack ofprosccution by Lee County Prosecutors.

A citizcn not only has thc First Amend-nCnt一・ight to spcak oしIt agamSt a gOVCmmCntal cntlty’he

or she also has a constitutiona11y protected right to demand that the govemment correct the
wrongs that are iden捕ed. As the Supreme Court has stated・ a gOVemment entlty "may not deny
a benefit to a person on a basis that in鉦nges his constitutionally proしected interests-eSPeCially‘

his intcrcst in frccdom of spccch.’’

The policy to delete comments and ban individuals宜om speaking out are so obviously contrary

to our countl・y,s fuldamental p宣・1nCiples of [iberty and clearly unconstitutional’I am asking that

Chie†Assist. State Attomey Amira Fox reslgn he一・ POSition in the State Attomcy,s Office.

Respectfully Submitted,

晒ロー鞠
Email :

新砂(←の伽
 玖他州So Å」

SWORN BEFORE ME at the city of f毛/十nヽtfr S

しk Co…山 , intheStateofFIorida皿s
-呈出とda声M久当 ・ 20⊥五

A Notary Public for

」OANN帥U鼠e曲
The State of FIorida
調Y高潮SS-ON引評的5線
My Commission Expires 的はES.A巾1 19.柳柳
的調的高調的甑町S●南〃機

←古rも博しり‰wへも叱
動発売星
 BEFORE THE OFFICE OF THE STATE ATTORNEY
20TH JUDICIAL CIRCUIT OF FLORIDA

Stephen B. Russe=
State Attomey - 20th Judicial Circuit
Post Office Box 399
Fort Myers, FIorida 33902-0399; and

Amira Fox for State Attomey and Amira Fox, ChiefAssist. State Attomey
Post Office Box 399
Fort Myers, FIorida 33902-0399

COMPLAINT

RE: Section 1983 Comp賞aint against Chief Assist・ State Attomev Amira Fox

ChiefAssist. State Attomey Amira Fox is runnmg for State Attomey for the 20th Judicial Circuit
and has a Political Facebook Campalgn Page. ‘`Amira Fox for State Attomey”.

Recently, m SPeaking out about the most hoITific abuses ofanimals uncovered in the ARM
Investlgation occumng at 4 Illegal Slaし1ghterhouses operatmg m yOur County, aSking氏〉r

invcstlgation and lack ofprosccution by your O舘cc and, Amira Fox particularly, my COmmCntS

were deleted, and/or l was banned from the “Amira Fox for State Attomey” Facebook Page. This

is a violation ofmy cons両utional rights 42 U.S.C・ § 1983.

1t is a violation ofSection 1983 for a state or municIPal govemment to take action designed to
prcvent or intimidatc pcople from exercISmg their First Amendment rights’Or Punish them for
doing so, and there can be no dispute that complainmg about inhし1mane COnditions at 4 n1egal

Slaughterhouses operatlng in Lee County for which Chief Assist・ State Attomey Amira Fox has

Publicly stated that she wi11 not prosecute is a protected right・

In fact言his was a direct response to delete comments and prcvcnt from speaking about the

abuses and lack ofprosecution by Lee Coしmty Prosecutors.

A cit三zen not only haS the First Amend-T`ent占ght to叩eak ol-t agamSt a gOVC`1￨lmental elltlty’he

or she also has a const血tionally protectcd right to demand that the govemment COrreCt the

wrongs tllat are identified. As the Supreme Court has stated・ a gOVemment entlty “may nOt deny

a bene鉦to a person on a basis that in鉦nges his constitutionally protected interests-eSPeCially.

his intcrcst in frccdom of spccch.’●

The policy to delcte comments and ban individuals from speaking out are so obviously contrary
to our country,s fundamental prtnciples of liberty and clearly mconstitutio11al’I am asking that

ChiefAssist. State Attomey Amira Fox reslgn her position in the State Attomey’s O舘cc.

Respect餌1y Submitted,

四四四日
Email:
琳帯需勅高
l’畔、Ⅵ∪ ▼ ￣l ￣
ノ

SWORNBEFOREMEatthecityof F+. ∩¥Y<rS

」と乞とれハト
_室生扉草地㌢衰運血s
」OA録NとBU買G各員
A Notary Public for
MY C○間男SS10冊晴議5顔2
The State of Florida 軟PI髄S:小郡19,柳的
My Commission Ex 恥的川向的同債岬o(叩直れ心賀

園田圏
セぅo「高上古間…、七時Q一
 BEFORE THE OFFICE OF THE STATE ATTORNEY
20TH JUDICIAL CIRCUIT OF FLORIDA

Stephen B. Russell
State Attomey - 20th Judicial Grcuit
Post O綿ce Box 399
Fort Myers, FIorida 33902-0399; and

Amira Fox for State Attomey and Amira Fox, Chief Assist. State Attomey
Post O餓ce Box 399
Fort Myers, FIorida 33902-0399

COMPLATNT

RE: Section 1983 Complaint against ChiefAssist. State Attorney Amira Fox

ChiefAssist. State Attomey Amira Fox is rummg for State Attomey for the 20th Judicial Circuit
and has a Poljtical Facebook Campalgn Page∴`Amira Fox for State Attomey’’.

Recently, m SPeaking out about the most hon‘ific abuses of animals uncovered in the ARM

Investlgation occumng a[ 4 Illegal Slaし1ghterhouses operatmg ln yOur County, aSking for

invcstlgation and lack ofprosccution by your O珊cc and, Amira Fox particularly, my COmmCntS

were deleted, and/or l was bamed from theし`Amira Fox for State Attomey” Facebook Page. This

is a violation ofmy constitutional rights 42 U.S.C. § 1983.

1t is a violation ofSection 1983氏)r a State Or municIPal govemment to take action designed to

PreVent Or intimidatc people from exercISmg their First Amendment rights’Or Punish them for
doing so, and there can be no dispute that complainmg about illhumane conditions at 4 Illegal
Slaughterhouses operating in Lee County for which ChiefAssist・ State Attomey Amira Fox has

Publicly stated that she wi11 not prosecute is a protected right・

In fact, this was a direct response to de漢ete comments and prevent from speaking about the

abuses and lack ofprosecution by Lee County Prosccutors.

A citjzcn not only h孔s thc First Amcndmcnt一・ight to spcak out agilmSt n gOVCmmCntal cntlty, hc

or she also has a constitutionally protected right to demand that the govemment correct the
WrOngS that are identified. As the Supreme Court has stated・ a gOVemmCnt entlty “may nOt deny

a benefit to a person on a basis that infringes his constitutionally protected interests-eSPeCially,

his intcrest in frccdom of spccch.’’

The policy to delete comments and ban individuals from speaking out are so obviously contrary
to our country,s fundamental pt.1nCiples of liberty and clear[y unconstitutional' I am asking that
ChiefAssist. State Attomey Amira Fox reslgn her positio-1 in the State Attomey’s Office.

Respect餌1y Submitted,

蒜s畿二二二二二二二
Email: 乙部V¥
SWORN BEFORE ME at the cityof fZ,了十r‘へいCrS
in the State of FIorida this
し耳  , 20○○」を

」OA州唯B鵬誠
A Notary Public for
購Y COM聞SS10N鯵肝的輯繊
The State of FIorida ∈炸脂お:小鴨同色郷却
My Commission Expires 功引zo. 帥種巾同調的議定町e動鴫農

セγう…しlっれ…山肌乙

園田園