IN THE COUNTY COURT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
BILLY RAY KIDWELL5064 Silver Bell Drive
Port Charlotte, FL. 33948,
Plaintiff
v.
JACKSONVILLE JAGUARS, LLC
Corporate Headquarters
1 Everbank Field Dr.
Jacksonville, Florida 32202
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DEFENDANT TO BE SERVED AT:
CT Corporation System
1200 South Pine Island Road
Plantation, Florida 33324
COMPLAINT FOR FRAUDULENT BUSINESS PRACTICES
WITH JURY DEMAND
I. INTRODUCTION
1. The Jacksonville Jaguars, LLC, is registered with the Department of State in Florida as a Limited Liability Company doing business as “Sports Management”. [See attachments.]
2. Professional Sports provide a much-needed Public Service promoting patriotism, and respect for our Military, and our Veterans, including America’s First Responders since 911, as we become one country,when the National Anthem is played, and sung, standing together against the terrorists that attack us, and those that seek to divide, and destroy us.
3. Professional Sports also provides entertainment, an escape from work, and the hardships of life, and unity behind teams, as dedicated fans support their favorite teams.
4. Traditional Professional Sports Teams provide a substantial, financial, boost to the economy in cities where they are based, and because of this economic influence, hundreds of millions of tax-payer dollars are used to assist building stadiums, and for other uses to enhance the Professional Sports Industry.
5. This massive taxpayer investment gives the public a very real interest in the business of Professional Sports, since so many of their tax dollars are invested in this industry.
6. All these benefits from Professional Sports Teams will not work unless those teams are properly regulated, so that the public can depend on Professional Sports Teams to be honest, impartial, and not “tainted” by Racism, Politics, or other factors that could affect their impartially.
7. On August 18, 1995 when the Jacksonville Jaguars played their first preseason game in a brand-new stadium, Everbank Field, over fifty million tax-payer dollars ($50,000,000.00) were used to pay for that new stadium.
8. Thanks to Florida Taxpayers Everbank Field became the proud home of the world’s largest in stadium video boards in 2014.
9. The reimagining of Everbank Field continued in 2016 with a shared investment of Ninety Million Dollars ($90,000,000.00) from the City of Jacksonville, partnered with the Jacksonville Jaguars, LLC.
10. It is because of this Massive Public Tax Dollar Investment that every person in America is entitled to equal access to enjoyment of the Jacksonville Jaguars Professional Football Team, requiring the team to remain completely neutral in racial, and political disputes.
11. These massive investments of Taxpayer dollars would not have been approved if the Jacksonville Jaguars had been honest to the public, and let the public know that their Professional Football Team would not be neutral in politics but would use their National-Recognition, and “Influence” as a Nationally-known Professional Sports Team, and use their Valuable National TV Time, the Jacksonville Jaguars is being paid for, to attack a Republican President.
12. There are over 11 million registered voters in Florida with 41% being Democrat, 36% being Republicans, 20% being Independents, and 3% being minor parties.
13. With Florida electing Republican President Donald Trump it is clearly indisputable that all those millions of taxpayer dollars would not have been given to the Jacksonville Jaguars, LLC, to substantially enrich the Jaguars Owner, and Jaguar’s Overpaid, Unappreciative, Football Players, if the public were told the truth, and knew those taxpayer dollars would also be used to promote “Democrat Attack Politics”, and Un-American Activities.
14. The Jacksonville Jaguars LLC, also used their status as an NFL Professional Football Team, which was obtained in a large part with the millions of taxpayer dollars described herein, to protest the National Anthem, disrespecting America’s Veterans, and especially disrespecting America’s Disabled Veterans, like Plaintiff.
15. A poll released in July by J.D. Power shows that 34% of Adults in America say they are less likely to watch an NFL Game because of the protest by NFL Football Players against the National Anthem, disrespecting America’s Veterans, and especially America’s Disabled Veterans, that shed blood, and limbs, to provide the freedom these overpaid, multimillion dollar Football Players abuse.
16. Since the owner of the Jacksonville Jaguars LLC, united his whole team to disrespect America’s Veterans, by refusing to stand during the National Anthem, CBS took a poll, and discovered that 58% of Americans strongly object to the Jacksonville Jaguars Team refusing to stand for the National Anthem, and consider it blatant disrespect of America’s Veterans, and especially America’s Disabled Veterans.
17. The protest by the Jacksonville Jaguars LLC, as a unified Professional Football Team, has caused political discord all over America, and has done great, irreparable damage to Professional Football in America.
18. Most important, it proves that the millions of taxpayer dollars, obtained by this FOR-PROFIT LLC, the Jacksonville Jaguars LLC Professional Football Team, were fraudulently obtained to make the Jaguars Football Team into a powerful Political Racist Entity, selectively supporting the Democrat Cause of attacking President Trump, while also supporting Racism, and the Black Lives Matter,Racist,Terrorist Group.
19. Despite their recent denials, Black Lives Matter, according to their own words, is a Racist Terrorist Group, with the goal of killing police officers, and seeing them “fried like bacon”[1].
20. It is indisputable Black Lives Matter calls for the murder of police officers.
21. The recent Russian Investigations found that Russia purchased ads on Facebook supporting the Black Lives Matter Terrorist Group, and trying to incite Racial Division, and Hate in America, as the Un-American Jacksonville Jaguars are doing with their Anti-American National Anthem Protests.
22. Because of the Russians, and Racist NFL Jacksonville Jaguar Football Players, the public is divided along racial lines, and arguing, and fighting, about Protesting Football Players, which is not the function of “Sports Management”, and National Football.
23. For the NFL Professional Football Team, the Jacksonville Jaguars LLC, a team that would not have a stadium, and would not exist without taxpayer dollars, to use their Valuable TV time to violate their stated “business” as “Sports Management”,and to use their company to disrespect Veterans, and attack President Trump, and to support Racism, is clearly extremely dishonest, and constitutes being a Fraudulent Business Practice in Florida.
24. The Jacksonville Jaguars is registered with the Florida Department of State to do business as “Sports Management”, not to be a Democrat Political PAC, or to be a Racist Political PAC for Black Lives Matter, or to act as an Anti-American, Veteran Hating, Protest PAC. [See attached exhibits.]
25. The Plaintiff, a 100% Service-Connected Combat Veteran cannot,in good conscience, watch Professional Football again because of the Jacksonville Jaguars blatant disrespect for the National Anthem, their Racism, and support of a Racial Terrorist Group that wants cop’s dead, and fried like bacon.
26. This Court needs to make this For-Profit LLC repay the public, the hundreds of millions of tax dollars it has defrauded the public out of.
27. This Court needs to impose substantial fines, and/or penalties,on the Defendant for his fraud on the public.
28. This Court needs to award Reasonable Damages, in an amount found by a jury to be just, and proper, to Plaintiff for the irreparable harm intentionally inflicted on him, for his extremely Honorable Military Service, by this strongly Anti-American Football Team.
29. And this Court needs to stop the Fraudulent Business Practices by the Defendant, and require the Jacksonville Jaguars LLC to strictly comply with Florida Law, and operate solely as a “Sports Management LLC”, which is the only business the Jacksonville Jaguars LLC is registered, and authorized, to engage in, in the State of Florida.
II. JURY DEMAND
30. Plaintiff DEMANDS a Jury Trial in the instant case.
III. JURISDICTION AND VENUE
31. Plaintiff lives in Charlotte County Florida and suffered from the events giving rise to the claims in this lawsuit in Charlotte County Florida.
32. Plaintiff seeks declaratory relief, compensatory, and punitive damages, and injunctive relief, as well as any other relief that he is entitled to.
33. Plaintiff is a severely disabled Vietnam Veteran, forced to proceed Pro Se, because he cannot afford, and has been unable, to hire counsel, and Plaintiff therefore seeks a very liberal construction of this action, and any jurisdiction authorities, pursuant to the doctrine of Hainesv.Kerner, 404 U.S. 519.
IV. Parties
34. Plaintiff, Billy Ray Kidwell, is a male resident of the State of Florida. He is a disabled person within the meaning of the Americans with Disabilities Act, and is a Vietnam Disabled Combat Veteran rated at 100% Total Service-Connected by the Department of Veterans Affairs.
35. Plaintiff, Billy Ray Kidwell, suffers from a side that is numb; a bad leg from combat, a combat injured back, a severe stomach disorder, a sleeping disorder, a severe stress disorder, a bad heart, and has a history of a stress-caused heart attacks.
36. Undue stress causes the Plaintiff great harm, and endangers his life since it can cause a fatal stress-caused heart attack.
37. Recently Plaintiff suffered a Massive, Stress-Caused, Life-Threatening Heart Attack that caused substantial damage to Plaintiff’s Heart and as a result Plaintiff is on the Department of Veterans Affair’s Heart Failure Program, and is monitored each day.
38. Plaintiff’s address is; Billy Kidwell, 5064 Silver Bell Drive, Port Charlotte, FL. 33948.
39. Defendant, Jacksonville Jaguars LLC, is an NFL Professional Football Team registered as an LLC with the Department of State in Florida.
40. Defendant, Jacksonville Jaguars LLC, is authorized to engage in business in Florida as an LLC doing Sports Management, and is not authorized to engage in any other type of business in Florida.
41. This Defendant's address is; Jacksonville Jaguars LLC, 1 Everbank Field Drive, Jacksonville, Florida 32202.
V. FACTS OF CASE
42. The Jacksonville Jaguars LLC is a Professional NFL Football Team registered as an LLC with the Department of State in Florida to do business as Sports Management.
43. The Jacksonville Jaguars LLCused to provide a Public Service promoting patriotism, and respect for our Military, and our Veterans, including America’s First Responders since 911, by playing the National Anthem before each of its Football Games, as the fans, and Jacksonville Jaguars LLC, stood together as one against the terrorists that attack us, and against those that seek to divide, and destroy us.
44. The Jacksonville Jaguars LLC also used to provide entertainment, an escape from work, and an escape from the hardships of life, byunifying, and encouraging dedicated fans to support their favorite teams.
45. The Jacksonville Jaguars LLC provides a substantial, financial, boost to the economy in Jacksonville Florida, where they are based, and because of this economic influence, hundreds of millions of tax-payer dollars were used to assist building the stadium, Everbank Field.
46. This massive taxpayer investment gives the public a very real interest in the business of Professional Sports, since so many of their tax dollars are invested in the Jacksonville Jaguars.
47. All these benefits from Professional Sports Teams will not work unless those teams are properly regulated, so that the public can depend on Professional Sports Teams to be honest, impartial, and not “tainted” by Racism, Politics, or other factors that could affect their impartially.
48. On August 18, 1995 when the Jacksonville Jaguars played their first preseason game in a brand-new stadium, Everbank Field, over fifty million tax-payer dollars ($50,000,000.00) were used to pay for that new stadium.
49. Thanks to Florida Taxpayers Everbank Field became the proud home of the world’s largest in stadium video boards in 2014.
50. The reimagining of Everbank Field continued in 2016 with a shared investment of Ninety Million Dollars ($90,000,000.00) from the City of Jacksonville, partnered with the Jacksonville Jaguars, LLC.
51. It is because of this Massive Public Tax Dollar Investment that every person in America is entitled to equal access to enjoyment of the Jacksonville Jaguars Professional Football Team, requiring the team to remain completely neutral in racial, and political disputes.
52. These massive investments of Taxpayer dollars would not have been approved if the Jacksonville Jaguars had been honest to the public, and let the public know that their Professional Football Team would not be neutral in politics but would use their National-Recognition, and “Influence” as a Nationally-known Professional Sports Team, and use their valuable National TV Time, the Jacksonville Jaguars was being paid for, to attack a Republican President.
53. There are over 11 million registered voters in Florida with 41% being Democrat, 36% being Republicans, 20% being Independents, and 3% being minor parties.
54. With Florida electing Republican President Donald Trump it is clearly indisputable that all those millions of taxpayer dollars would not have been given to the Jacksonville Jaguars, LLC to substantially enrich the Jaguars Owner, and Jaguar’s Overpaid, Unappreciative, Football Players, if the public were told the truth, and knew those taxpayer dollars would be used to promote “Democrat Attack Politics”, and Un-American Activities.
55. The Jacksonville Jaguars LLC, also used their status as an NFL Professional Football Team, which was obtained in a large part with the millions of taxpayer dollars described herein, to protest the National Anthem, disrespecting America’s Veterans, and especially America’s Disabled Veterans, like Plaintiff.
56. A poll released in July by J.D. Power shows that 34% of Adults in America say they are less likely to watch an NFL Game because of the protest by NFL Football Players against the National Anthem, disrespecting America’s Veterans, and especially America’s Disabled Veterans, that shed blood, and limbs, to provide the freedom these overpaid, multimillion dollar Football Players abuse.
57. Since the owner of the Jacksonville Jaguars LLC, united his whole team to disrespect America’s Veterans, by refusing to stand during the National Anthem, CBS took a poll, and discovered that 58% of Americans strongly object to the Jacksonville Jaguars Team refusing to stand for the National Anthem, and consider it blatant disrespect of America’s Veterans, and especially America’s Disabled Veterans.
58. The protest by the Jacksonville Jaguars LLC, as a unified Professional Football Team, has caused political discord all over America, and has done great, irreparable damage to Professional Football in America.
59. Most important, it proves that the millions of taxpayer dollars, obtained by this FOR-PROFIT LLC, the Jacksonville Jaguars LLC Professional Football Team, were fraudulently obtained to make the Jaguars Football Team into a powerful Political Racist Entity, selectively supporting the Democrat Cause of attacking President Trump, while also supporting Racism, and the Black Lives Matter, Racist, Terrorist Group.
60. Despite their recent denials, Black Lives Matter, according to their own words, is a Racist Terrorist Group, with the goal of killing police officers, and seeing them “fried like bacon”[2].
61. It is indisputable Black Lives Matter calls for the murder of police officers.
62. It is indisputable that the public is divided along racial lines as to Black Lives Matter.
63. For the NFL Professional Football Team, the Jacksonville Jaguars LLC, a team that would not have a stadium, and would not exist without taxpayer dollars, to use their TV time to violate their stated “business” as “Sports Management”, registered with Florida’s Department of State, and to use their company to attack President Trump, and to support Racism, is clearly extremely dishonest, and constitutes being a Fraudulent Business Practice in Florida.
64. The Jacksonville Jaguars is registered with the Florida Department of State to do business as “Sports Management”, not to be a Democrat Political PAC, or to be a Racist Political PAC for Black Lives Matter. [See attached exhibits.]
65. Professional Football Players know the NFL has been paid by the United States Government to respect the military.
66. Professional Football Players know that the public has invested a massive amount of taxpayer dollars in their football team, and that they owe neutrality, and honesty, to the public so their games are not “tainted” with politics, or corruption.
67. The Defendant, Jacksonville Jaguars,knows that TV Time, and endorsements by an NFL National Football Team, are very valuable items that when donated must be reported to the IRS.
Do the Jacksonville Jaguars Have a First Amendment Right to Protest?
68. The Jacksonville Jaguars fraudulently claim that they have a Constitutional Right to register with the Florida Department of State as being a Sports Management Business, and then to engage in the business of being a Political PAC for the Black Lives Matter Terrorist Group, “protesting” in their Official NFL Football Uniforms on National TV, while they are being paid outrageous sums of money to be Neutral Football Players.
69. The Jacksonville Jaguars also claim that they have a Constitutional Right to register with the Florida Department of State as being a Sports Management Business, and then to engage in the business of being a Democrat Political PAC attacking President Trump for his beliefs that NFL Football Players should not disrespect our Country, our Military, Veterans, and First Responders by not standing for the National Anthem in a country that has provided those Football Players opportunities, and riches beyond belief.
70. Professional Football Players in the NFL are not representing themselves when they are wearing their Official NFL Uniform.
71. When NFL Football Players are in their Official NFL Uniform, on the clock at an Official NFL Game, they are representing the NFL, and their NFL Team.
72. They have no Constitutional Right to exercise their Freedom of Expression, and express themselves by wearing high-heels, or a dress, because they are on the clock representing the NFL, and being paid outrageous sums of money to forgo Constitutional Rights while working, and to dress in Official NFL Uniforms.