IN THE CIRCUIT COURT OF THE

JUDICIAL CIRCUIT IN AND FOR

ORANGE COUNTY, FLORIDA
LAWANNA GELZER,
INNER CITY NEIGHBORHOOD ASSOCIATION,
BETTY GELZER, PEABO CHILD CARE CENTER,
WOMEN OF COLOR LEADERSHIP COALITION,
RACIAL AND SOCIAL JUSTICE ALLIANCE.
Plaintiff,
-vsCITY OF ORLANDO,
a Florida municipal corporation
Defendant.
CASE NO.
COMPLAINT FOR INJUNCTIVE RELIEF
Plaintiff, Lawanna Gelzer sues defendant, CITY OF ORLANDO and alleges:
1. The CITY OF ORLANDO is in violation of Florida State statute 73.013, which
governs conveyance of property taken by eminent domain:
(d) For use in providing public infrastructure;
(e) That occupies, pursuant to a lease, an incidental part of a public property or a
public facility for the purpose of providing goods or services to the public;
(f) Without restriction, after public notice and competitive bidding unless otherwise
provided by general law, if less than 10 years have elapsed since the condemning
authority acquired title to the property and the following conditions are met:
The city has seized private property, to use for the public good by building a soccer
stadium. They have now decided to sell the property to a private buyer. They have not
had the property 10 years, nor did they allow for competitive bidding.
2. The defendant CITY OF ORLANDO is a Florida municipal corporation in Orange
County, Florida.
3. This is an action for injunctive relief, to prevent the sale of the Orlando Soccer
Stadium.
4. Ms. Gelzer has been a resident and community activist and leader with the Women of
Color Leadership Coalition, Inner City Neighborhood Association and Racial and Social
Justice Alliance, organizations that have been closely engaged in the protection of the

Paramour neighborhood that has been affected by the eminent domain actions of the City.
Betty Gelzer owns rental property at 825 West Washington Street Orlando, FL 32805
and business owner of the Peabo childcare center located at 815 Hills Street Orlando, FL
32805, and has been financially affected due to the construction of the soccer stadium
5. Plaintiffs named is, and at all times mentioned in this Complaint was, engaged in the
activity of protecting the local community of Paramour.
6. The City of Orlando owns 601 W. Church Street, which was seized by eminent
domain that was intended to be used for the soccer stadium. The city states that it will not
be part of the purchase, and will remain for public purpose.
7. Unless and until enjoined by order of this court, there will be irreparable injury to the
residents and businesses. It would be an in just sale and misuse of eminent domain.
9. Plaintiff has no adequate remedy at law for the injuries that would be caused by
Defendants sale of the property.
10. Granting a temporary injunction for the Plaintiff is in the public interest because the
public has a right to the orderly regulation of property seized by the state, and right to due
process.
WHEREFORE, Plaintiff demands judgment against Defendant as follows:
1. For a temporary injunction until Plaintiffs right to a permanent injunction is
determined.
2. For a permanent injunction on final trial of the above-entitled cause enjoining
Defendant and Defendants agents, servants, employees, and attorneys, and any persons
in active concert or participation with Defendant selling the property.
4. For costs of suit incurred in this action.
5. For such other and further relief as the court may deem proper.
Respectfully submitted,
By:

/s/ Peri Sedigh

Peri Sedigh, Attorney at Law
2443 Grandview Ave
Sanford Fl 32771
321 230 0589
Fla Bar No. 0116587
Attorney for Plaintiff