COVID-19 Complaint To Dept of Health Re Marion County Florida

Dr. Scott A.
Rivkees July 26, 2020

Florida Surgeon General
Florida Department of Health (DOH)
4052 Bald Cypress Way, Bin C75
Tallahassee, Florida 32399-3260 COVID-19 Complaint
MQA.ConsumerServices@flhealth.gov Marion County, Fla.
Dr. Rivkees:
This is a COVID-19 complaint for Marion County, Florida. My name is Neil J. Gillespie. I am
age 64, and a person with disabilities including type 2 diabetes, BMI >40, and obstructive
breathing/sleep apnea. I am at increased risk of being infected with COVID-19. If I get infected,
I am at an increased risk of death. I have lived in Marion County Florida since 2005.
This COVID-19 complaint is directed against persons and entities in Marion County, Florida:
1. Timothy McCourt and the Marion County Sheriff’s Office (MCSO)

2. Zachary Phipps, Office of Criminal Conflict and Civil Regional Counsel, 5th DCA
3. The Marion County Jail, Sheriff William Woods
4. Anthony M. Tatti, Circuit Court Judge, Marion County, Florida Fifth Judicial Circuit
On July 14, 2020 I emailed the Department of Health COVID-19 Call Center about COVID-19
Legal Protections. I got a response - eleven days later - on July 25, 2020. (Exhibit A).
Apparently the COVID-19 Call Center is unaware of the enforcement authority available to the
DOH under Fla. Stat. § 381.0012. Given the role of law enforcement under Fla. Stat. § 381.0012,
nonfeasance by Mr. McCourt and the MCSO’s amounts to negligence per se.
Public Health in Florida is governed by Title XXIX of the Florida Statutes. The Department of
Health is responsible for the state’s public health system which shall be designed to promote,
protect, and improve the health of all people in the state. (Fla. Stat. § 381.001). The Duties and
powers of the Department of Health are found in Fla. Stat. § 381.0011.
The Department of Health declared coronavirus is a disease or condition to be reported, see

FAC 64D-3.029 Diseases or Conditions to be Reported.
https://www.flrules.org/gateway/ruleNo.asp?id=64D-3.029
To update the rule to add COVID-19 to the list of reportable diseases and conditions.
The declaration under FAC 64D-3.029 that coronavirus is a communicable disease allows the
DOH enforcement authority (381.0012) of the Governor’s COVID-19 Executive Orders
governing this communicable disease (381.003), see,
381.0012(1) The department may commence and maintain all proper and necessary actions...
381.0012 (2) The department may apply for an injunction to the proper circuit court,...
381.0012 (3) The department may commence and maintain all proper and necessary actions...
Dr. Scott A. Rivkees, Florida Surgeon General July 26, 2020
Florida Department of Health
COVID-19 Complaint Marion County, Fla.
381.0012 (4) The department may appear before any trial court judge [Judge Tatti] empowered
to issue warrants in criminal cases and request the issuance of a warrant. The trial court judge
shall issue a warrant directed to any sheriff, deputy, or police officer to assist in any way to carry
out the purpose and intent of this chapter. [To remove Sarah Thompson from my home].
Enforcement authority under 381.0012 (5) applies to the MCSO and State Attorney Brad King:
(5) It shall be the duty of every state and county attorney, sheriff, police officer, and other
appropriate city and county officials upon request to assist the department or any of its
agents in enforcing the state health laws, rules, and orders adopted under this chapter.
1. Complaint against Timothy McCourt and Marion County Sheriff’s Office (MCSO)
Mr. McCourt, Fla. Bar No. 44604, is general counsel to the Marion County Sheriff’s Office. On
May 19, 2020 I emailed Mr. McCourt asking about COVID-19 protections and Sarah Thompson.
Ms. Thompson, age 35, is an unremarried widow to whom I offered good faith assistance until it
became apparent her personal issues were beyond my ability to help. In January 2020 I referred
[415.1034] Sarah as a vulnerable adult [415.102(28)] to the local authorities including the
MCSO, the public defender, and State Attorney Brad King, all to no avail.
My email to McCourt appears at Exhibit 1 and states in relevant part:
RE: COVID-19 protections and Sarah Thompson
Mr. McCourt:
On April 1, 2020 Gov. DeSantis issued Executive Order #20-91, Essential Services and
Activities During COVID-19 Emergency that required, inter alia, Florida residents to
remain at home, and to wear a mask or respirator while in pubic places for essential
services and activities. I provided a paper copy of Executive Order #20-91 shown at this
link to Sarah Thompson https://www.flgov.com/wp-content/uploads/orders/2020/EO_20-91.pdf
Sarah is skeptical about COVID-19 and has not complied with any of the orders or
recommendations that I know about. I have not seen Sarah wear a mask, even while
shopping at Walmart. Sarah has ignored the stay home provisions, and travels freely in
Marion County as she did before the COVID-19 Emergency.
What legal protections do I have while living under the same roof with Sarah, who is
skeptical about COVID-19 and has not complied with any of the orders or
recommendations?
On the night of May-07-2020 through May-08-2020 Sarah had two visitors but refused to
discuss this with me. One visitor, perhaps with ties to Oak Run, appeared in my driveway
for Sarah. The other visitor came to my attention when I was awakened at 2:29 AM by a
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phone call from Envera Systems security announcing that Jeremiah Young was here to
visit Sarah. See attached a PDF of the email from Envera Systems.
I do not recall to what extent I discussed COVID-19 and these visitors with Deputy T.
Marton (5743) and MCSO Deputy Pope (6377) on May-08-2020 who arrived to assist
me. Perhaps the public records for Case No. 2005080039 will show my discussion, if
any.
Currently Sarah has a pile of clothing and belongings strewn in my garage, see the
attached photos. I believe this clothing may represent a COVID-19 risk by contamination
from Sarah and/or one of her many social and intimate contacts. FYI, Sarah’s "Dolly-
style" escort page shows it is active again, see https://www.eroticmonkey.ch/dolly-style-
escort-ocala-608178
Sarah claims someone at the MCSO told her she has a week to pick up her stuff, see the
attached text message from Sarah to me. Please identify the person who told this to
Sarah. In another text message Sarah admits taking my laptop as a form of hostage to get
her stuff "and it hasn’t been gone thru" whatever that means. Sarah herself went through
her stuff and left it a mess. Sarah also warns about putting her stuff on shelves I bought
for that purpose, but I put some of Sarah’s things on the shelves before getting her text,
items she left outside on the patio, and in my home.
Law professor Alan Dershowitz claims the state has wide authority to enforce COVID-19
precautions for public health, including forced vaccination, under the Tenth Amendment,
see https://www.wnd.com/2020/05/alan-dershowitz-state-right-plunge-needle-arm/ and
on YouTube https://youtu.be/Hjk1-a98xag
Thank you.
Sincerely,
/s/
Neil J. Gillespie (signature block omitted)
Mr. McCourt responded in relevant part by email May 19, 2020 at 12:11 PM. (Exhibit 2)
Mr. Gillespie,
I do not know who told Ms. Thompson that.
Regarding the recourse and protections you may have regarding Ms. Thompson choosing
not to comply with recommendations and orders, I would suggest you consult an attorney
who can render legal advice to you. Unfortunately, as staff attorney for this agency, the
agency has a monopoly on my legal advice.
I reviewed the clerk’s docket in your criminal case and see that Mr. Phipps remains your
counsel of record. Accordingly, he is copied on this e-mail.
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Thank you.
Timothy T. McCourt
General Counsel
Marion County Sheriff’s Office
Florida Bar No. 44604
PO Box 1987
Ocala, FL 34478-1987
Tel. (352) 369-6758
I replied in relevant part to Mr. McCourt by email on May 19, 2020 at 1:53 PM: (Exhibit 2)
Mr. McCourt, does your agency enforce COVID-19 provisions in Marion County? If not,
who does enforce COVID-19 provisions in Marion County?
Does Ms. Colbert still work for the MCSO as a public records person? If not, please
identify the custodian for public records. Thank you.
Neil J. Gillespie
Mr. McCourt responded in relevant part by email May 19, 2020 at 2:26 PM: (Exhibit 2)
Yes, as do other law enforcement agencies and regulatory agencies (DBPR, DOH, etc.).
Yes, she does.
Timothy T. McCourt
General Counsel
PO Box 1987
Ocala, FL 34478-1987
Tel. (352) 369-6758
So, McCourt admitted that the MCSO enforced COVID-19 provisions in Marion County, but he
refused to enforce the provisions to assist me in any way.
I concluded my remarks to McCourt by email May 19, 2020 at 2:41 PM: (Exhibit 2)
Fine. At this time I request a trespass warning be served on Sarah May Thompson
regarding my property to protect me from COVID-19 and the other threats she brings. As
to Ms. Colbert, she has not responded to my public records requests.
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Mr. McCourt and the Marion County Sheriff’s Office have refused to enforce a Trespass
Authorization dated January 13, 2020 against Sarah Thompson that appears at Exhibit 3.
2. Complaint against Zachary Phipps, Office of Criminal Conflict and Civil Regional
Counsel, 5th DCA
Zachary Phipps, Fla. Bar No. #65936, is a lawyer with the Office of Criminal Conflict and Civil
Regional Counsel, 5th DCA who was wrongly appointed as substitute counsel to represent me on
an unsigned and incomplete Application To Determine Criminal Indigence under F.S. § 27.52.
On June 11, 2020 at 9:03 AM I emailed Mr. Phipps about COVID-19 protections and Sarah
Thompson. My email to Phipps appears at Exhibit 4, and states:
Zachary Glenn Phipps

OCCCRC for 5th D.C.A.
307 NW 3rd St
Ocala, FL 34475-6638
Email: zphipps@rc5state.com
Mr. Phipps.
Mr. McCourt is unable to answer my questions about COVID-19, see my email to him
forwarded below. McCourt responded:
Regarding the recourse and protections you may have regarding Ms.
Thompson choosing not to comply with recommendations and orders, I would
suggest you consult an attorney who can render legal advice to you.
Unfortunately, as staff attorney for this agency, the agency has a monopoly on
my legal advice.
I reviewed the clerk’s docket in your criminal case and see that Mr. Phipps
remains your counsel of record. Accordingly, he is copied on this e-mail.
Therefore I direct my COVID-19 questions to you, as you remain counsel of record, and I
cannot obtain adequate counsel. FYI,
"Hillsborough County Sheriff Chad Chronister said Rodney Howard-Browne,

pastor at The River at Tampa Bay Church, was arrested for "intentionally and
repeatedly" disregarding state health orders. The sheriff said the church
gatherings "put his congregation and our community in danger.""
https://www.upi.com/Top_News/US/2020/03/30/Florida-pastor-arrested-for-
holding-church-during-COVID-19-restrictions/5221585610610/
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The same or similar could be said about Ms. Thompson who "intentionally and
repeatedly" disregarded state health orders." Her clandestine meetings of people in my
home for random sex, and random drug use, put me (a vulnerable class under COVID-
19), residents of the Oak Run Country Club (most residents are in a vulnerable class
under COVID-19), and our community in danger.
Thank you.
Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Ocala, Florida 34481
Tel. 352-854-7807
Email: neilgillespie@mfi.net
Unfortunately Mr. Phipps did not respond. So I emailed him again June 12, 2020 at 2:28 PM, but
again Phipps did not respond. (Exhibit 4)
3. Complaint against the Marion County Jail, MCSO, Sheriff William Woods
On June 14, 2020, while held in the Marion County Jail, MCSO Jailer Gonzalez claimed
COVID-19 is a "fake virus" and refused to follow COVID-19 rules. I made a complaint on the
Inmate Request Form, attached as Exhibit 5. However I was released from jail prior to time
permitted for submission of the Inmate Request Form.
Personally I am in a high-risk group, over age 50 with type 2 diabetes. But from McCourt on
down, they must think COVID-19 is a joke or fake. For example, a "nurse" at the jail refused to
wear gloves while performing glucose tests on inmates. This alleged "nurse" instructed inmates
to pass the glucose test meter from one to the next, none of the inmates wore gloves or even
washed hands. While I am type 2 diabetic, I skipped that risk. My email to County Attorney Guy
Minter and the BOCC is attached as Exhibit 6.
I requested information on COVID-19 at the jail, by email July 20, 2020 to Mr. McCourt. My
email appears at Exhibit 7, and states:
Timothy T. McCourt
General Counsel
Brittany Colbert, Records
RE: COVID-19 Cases

Mr. McCourt:
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This is a request for the number of Coronavirus or COVID-19 cases among the
following:
1. Inmates incarcerated at the Marion County Jail

2. Employees working at the Marion County Jail
3. Sworn Officers of the Marion County Sheriff’s Department.
Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Ocala, FL 34481
Tel. 352-854-7807
Mr. McCourt responded with a 10 page email, July 21, 2020 at 12:50 PM: (Exhibit 8).
McCourt’s voluminous documents show the amount owed for records is either $11.25, or $4.15
or zero, depending upon the valuation of my ice cooler stolen by Lt. Charles Welch. My cooler is
selling for $11.95, I believe at RaceTrac Petroleum, Inc.
Mr. Gillespie,
I am in receipt of your inquiry.
To the extent that you are requesting records, your outstanding balance from your prior
record request has not been paid and your public records requests will not be fulfilled
until it is. Please see the attached e-mail to help refresh your recollection.
To the extent that you are simply asking a question, this agency is not required to answer
your question. In re Report of Supreme Court Workgroup on Pub. Records, 825 So. 2d
889, 898 (Fla. 2002)(“The custodian is required to provide access to or copies of records
but is not required either to provide information from records or to create new records in
response to a request.”). See also Op. Atty. Gen Fla.. 92-38 (1992)(In response to an
inquiry regarding whether a town was required to make its financial officer available to
be interviewed by certified public accountants, the Attorney General opined, “While
every person has a right of access to the public records held by a public agency, I have
not found, nor have you directed my attention to, any provision in Ch. 119, F.S., which
would require the town to provide the financial officer for interrogation by certified
public accountants acting on behalf of a private citizen who has requested access to
financial records pursuant to the Public Records Law. Whether the town chooses to
provide the financial officer under such circumstances would appear to be a matter of
policy which the town must decide, not this office.”)
Thank you.
Timothy T. McCourt
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General Counsel
PO Box 1987
Ocala, FL 34478-1987
Tel. (352) 369-6758
However, I am not requesting records. Any records pertaining to inmates, jail workers or sworn
officers would be protected from disclosure by HIPAA, The Health Insurance Portability and
Accountability Act of 1996 (HIPAA). As a lawyer McCourt ought to know this fact.
Therefore I redirected my request to Sgt. Paul Bloom, Director of the Public Information Office
for the MCSO. My email July 23, 2020 4:15 PM to Sgt. Bloom appears at Exhibit 9.
Sgt. Paul Bloom

Director of the Public Information Office
This is a request for public information on the number of coronavirus or COVID-19 cases
among the following:

Thank you.
Unfortunately Sgt. Bloom was unable to do his job and provide public information. McCourt
hijacked my information request to Bloom and perverted it to a record request, see McCourt’s
email July 23, 2020 at 4:47 PM appearing at Exhibit 10:
Mr. Gillespie,
I am in receipt of your inquiry submitted to Sgt. Bloom (see below). This is the same
inquiry you made on July 20th. See attached e-mail (this e-mail contains another e-mail,
attached to it, which in turn contains two pieces of correspondence). I trust you already
have these in your possession but provide them to you for your ready reference.
As I noted on the 20th, to the extent that you are requesting records, your outstanding
balance from your prior record request has not been paid and your public records requests
will not be fulfilled until it is. Please see the attached e-mail to help refresh your
recollection.
To the extent that you are simply asking a question, this agency is not required to answer
your question. In re Report of Supreme Court Workgroup on Pub. Records, 825 So. 2d
8
889, 898 (Fla. 2002)(“The custodian is required to provide access to or copies of records
but is not required either to provide information from records or to create new records in
response to a request.”). See also Op. Atty. Gen Fla.. 92-38 (1992)(In response to an
inquiry regarding whether a town was required to make its financial officer available to
be interviewed by certified public accountants, the Attorney General opined, “While
every person has a right of access to the public records held by a public agency, I have
not found, nor have you directed my attention to, any provision in Ch. 119, F.S., which
would require the town to provide the financial officer for interrogation by certified
public accountants acting on behalf of a private citizen who has requested access to
financial records pursuant to the Public Records Law. Whether the town chooses to
provide the financial officer under such circumstances would appear to be a matter of
policy which the town must decide, not this office.”)
I have copied Mr. Phipps on this e-mail.
Thank you.
Timothy T. McCourt
General Counsel
PO Box 1987
Ocala, FL 34478-1987
Tel. (352) 369-6758
I responded to McCourt by email July 23, 2020 at 5:00 PM, see Exhibit 11:
Mr. McCourt: I am not requesting records, I am preparing a complaint to the Department

of Health for the MCSO, you and Phipps, and bar complaints for you and Phipps. I
requested information form the Public Information Office which you have obstructed.
Fine, my complaints will show your obstruction. Neil J. Gillespie
McCourt responded by email July 23, 2020 at 5:43 PM that appears at Exhibit 12:
Mr. Gillespie,
We do have an obligation to give you public records in accordance with Chapter 119,
which we will not be doing until you pay your outstanding balance for prior public
records requests. This is specifically allowed by law. See Florida Agency for Healthcare
Administration v. Zuckerman Spaeder LLP, 221 So. 3d 1260 (Fla. 1st DCA 2017);
Lozman v. City of Riviera Beach, 995 So. 2d 1027 (Fla. 4th DCA 2008).
If you can point to some legal authority that requires this agency to answer questions you
e-mail us, I’d be interested to know what it is.
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Thank you.
Timothy T. McCourt
General Counsel
PO Box 1987
Ocala, FL 34478-1987
Tel. (352) 369-6758
4. Complaint against Anthony M. Tatti, Circuit Court Judge, Marion County, Florida
Fifth Judicial Circuit
Attorney Adam Stout, Stout Defense, P.A., 5215 SW 91st Terrace, Gainesville, FL 32608 sued
Marion County Sheriff Billy Woods, and Marion County Circuit Court Judge Anthony Tatti,
according to a story appearing in July 1, 2020 in the Ocala Post, attached as Exhibit 13 and here:
Lawsuit filed against Marion County Sheriff, Billy Woods

https://www.ocalapost.com/lawsuit-filed-against-marion-county-sheriff-billy-woods/
The case caption is LOUIS EARLY PAYTON vs. BILLY WOODS, AS SHERIFF OF
MARION COUNTY AND STATE OF FLORIDA, Lower Tribunal Case(s):19-CF-001821-A
• COVID-19 Presents a Lethal Threat of Harm to Plaintiff in Violation of Article I, Section 17

of the Florida Constitution
• Habeas corpus is the proper remedy to challenge incarceration due to denial of a request for
bond. Seymour v. State, 132 So.3d 300, 303 (Fla. 4th DCA 2014).
• The Florida Constitution states that “cruel and unusual punishment” is forbidden.
Criminal Habeas Corpus Petition from Marion County (Court document available)
Appellate Case Number 5D20-1442
Criminal Prohibition Petition from Marion County (Court document available)

Appellate Case Number 5D 20-1479
Lawsuit filed against Marion County Sheriff, Billy Woods

By Ocala-Post July 1, 2020
UPDATE: On July 2, 2020, at approximately 8 a.m., less than 24 hours after this
article was published, Judge Anthony Tatti signed an Order Releasing Defendant
on His Own Recognizance with Conditions of Release.
Gainesville Attorney Adam Stout said that he believes his client’s release saved
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[his] life.
In part, the release states, “The Defendant shall be confined to the interior of his
residence unless traveling to the office or other location of a licensed physician or
the purpose of meeting with his attorney.”
You can read the release here.
Original article
Shortly before Marion County Sheriff Billy Woods accused attorneys and “his
citizens” of being “keyboard warriors,” Gainesville Attorney Adam Stout filed a
lawsuit against the sheriff.
The lawsuit was filed on July 1. (Read the lawsuit here)
Woods is being accused of violating the Florida Constitution by allowing inmates

to be housed in unsanitary conditions and knowingly putting elderly inmates in
grave danger. In some instances, sections of the jail were without running water
and A/C.
Woods said the problems were fixed quickly, but many disagree with his definition
of quickly.
The lawsuit has been filed on behalf of Louis Early Payton, a 74-year-old inmate
who has serious health problems and is being held without bond after he violated
his probation conditions on a misdemeanor charge.
In the lawsuit, it states, “Defendant, Billy Woods, as Sheriff of Marion County,

Florida is in continual violation of Plaintiff’s constitutional right against cruel and
unusual punishment.” It goes on to say, “An outbreak of the novel coronavirus is
imminent or already occurring at the Marion County Jail, where inmates are
confined in conditions that threaten their lives.”
As an inmate in the Marion County Jail, the Plaintiff, Mr. Payton is being
subjected to the following treatment by the Defendant:
a. Mr. Payton does not have a safe way to dry his hands;
b. Mr. Payton must sleep within three feet of other inmates;
c. High touch surfaces within the jail pod are sanitized once or twice a day;
d. Mr. Payton and other inmates in his pod have not been provided masks;
e. Temperature checks are not being performed; and
f. Social distance is not being observed/enforced.
“Mr. Payton is forced to suffer conditions that deny him the precautions and
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protections necessary to mitigate the severe threat of COVID-19. This constitutes

cruel and unusual punishment forbidden by the state constitution,” the lawsuit states.
The lawsuit comes after more than two dozen inmates and nearly a dozen staff
members reportedly tested positive for COVID-19.
In fact, the lawsuit states, “On June 22, 2020, Mr. Payton’s attorney received an
e-mail authored by Timothy T. McCourt, general counsel for the Marion County
Sheriff’s Office. This e-mail advised that one jail staff member tested positive for
COVID-19 and had been sent home, and eight (8) inmates were exhibiting viruslike
symptoms and were being quarantined for safety.”
However, just days later, the Star-Banner published that 44 inmates and 10 staff
members were positive for the COVID-19 virus.
Another inmate, who has not been named in the lawsuit, had been feeling sick
and was tested. However, that inmate, despite showing symptoms, was not
permitted to see a doctor. Essentially, that inmate tested positive for COVID-19.
Not only have inmates filed complaints, but some of Woods’ own staff have come
forward via e-mail, corroborating what inmates have been saying since Woods
took over the jail.
And, like the Star-Banner, Ocala Post has received e-mails in regards to the
complaints. Several of the e-mails came from MCSO employees who requested to
remain anonymous.
“Woods does not like to be questioned as witnessed by the public and the media
in multiple videos. You cannot question his authority or you will pay the price,” one
employee wrote. Adding, “If only people knew what the sheriff intentionally hides
from the public.”
Another employee, wrote, “Most staff does exactly what he tells them to do no
matter how wrong or unethical. It is shameful because one of the deputies who is
forced to speak the sheriff’s words is a soft-spoken good man. Billy does not
uphold his sworn oath…he is about as transparent with the public as stained
glass. He honestly believes the town belongs to him”
Woods has a history of not being transparent and failing to answer public records
requests, as can be proven by a number of e-mails.
A jail staff member, wrote, “Medical treatment is nonexistent here. Inmates

practically have to beg. No sanitizer, nothing. The virus will spread like wildfire and
it will eventually claim a life if this is not taken more seriously by the sheriff.
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Instead of trying to get Facebook likes, he should be worried about human life
and stop referring to people as scumbags, dirtbags, cry babies, etc.”
In the footnotes of the lawsuit, it states, “Mr. Payton’s life is in danger due to the
outbreak of COVID-19 in the Marion County Jail. The failure of the trial court to timely
enter a final order should not preclude Mr. Payton from proceeding with this writ of
habeas corpus.
Mr. Payton’s attorney was contacted by the trial court on the morning of June 26th to see
if all parties were available for a VOP trial in mid to late July 2020. That same morning,
the Plaintiff advised the court he needed time to check with his witnesses’ availability.
Unfortunately, Mr. Payton was not given an opportunity to do this and a VOP trial was
unilaterally set on June 26, 2020.”
The lawsuit also states, “Mr. Payton is a 74-year-old combat veteran who was exposed to
agent orange in Vietnam. This has caused him to develop many serious health conditions,
to include chronic kidney disease, obstructive sleep apnea, diabetic neuropathy, chronic
lung disease, and colon cancer.”
The jail is aware of Payton’s serious medical conditions.
According to the CDC guidelines, as noted in the lawsuit, Payton’s medical conditions
absolutely put him at greater risk for death if he were to contract COVID-19.
In addition to the lawsuit filed against Woods, a motion has been filed with the court to
recuse or disqualify Judge Anthony Tatti because of prejudice or bias in the case, which
the lawsuit states would prevent Payton from receiving a fair trial.
The lawsuit states that Judge Tatti, without proper reason or legal explanation, has denied
a petition for Payton’s bail three times.
Currently, there are dozens of inmates being held for misdemeanor violations. Charges
range from Open Container, Misdemeanor Possession of Marijuana (a charged that has
been decriminalized in numerous counties), Driving While License Suspended, and
numerous more.
In a letter, Woods wrote, “The people who are in jail are all in jail for a reason.
Everyone’s reason is unique, but what they all have in common is that there is a court
order of some kind requiring them to be there –to serve a sentence, to be held until bond
is posted, to be held without bail until trial, or to be held until unpaid child-support is
paid.”
COVID-19 has caused hardships for many, even law-abiding citizens who, at no fault of
their own, might have fallen behind on child support. A reasonable person could
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conclude that it could happen to anyone and [that] does not make any particular person a
dangerous or hardened criminal.
In dozens of previous cases, attorneys have also said that holding a person for
misdemeanor possession of marijuana is laughable.
According to hundreds who have turned to social media, the public and other watchdog
groups have made it clear that they are not asking for violent criminals to be released, but
that is how the sheriff made it seem in his letter.
In regard to being held without bond, the lawsuit states:
• Habeas corpus is the proper remedy to challenge incarceration due to denial of a

request for bond. Seymour v. State, 132 So.3d 300, 303 (Fla. 4th DCA 2014).
• COVID-19 Presents a Lethal Threat of Harm to Plaintiff in Violation of Article I,
Section 17 of the Florida Constitution
• The Florida Constitution states that “cruel and unusual punishment” is forbidden.
The lawsuit states that Payton agreed to wear an ankle monitor if a bond was granted and
the court is aware of that fact.
Many have said it is not about getting out of jail…it’s about proper healthcare for a 74-
year-old man.
In the justice system, one is supposed to be presumed innocent until proven guilty.
However, in Marion County, most have long felt that it has been the opposite.
• The Florida Bar Lawyer Referral Service
I contacted The Florida Bar Lawyer Referral Service after Mr. McCourt refused to provide
assistance with COVID-19 legal issues, violations by Sarah Thompson. I got two referrals:
Patricia Duffy, Attorney at Law Pravesh Bobby Rumalla, Esq.

855 E University Ave. 2537 SE 17th St
Gainesville, FL 32601-5508 Ocala, FL 34471-5522
Email: duffylaw@gmail.com Email: pbrlaw@embarqmail.co
(Exhibit 14) (Exhibit 15)
Ms. Duffy never responded. Eventually I spoke with Mr. Rumalla about representation in other
matters, but not for COVID-19 legal issues. By that time I determined the DOH had jurisdiction
under Chapter 381 of the Florida Statutes.
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• News Reports of COVID-19 in Florida and in Marion County.
Because Mr. McCourt refused to provide information about COVID-19 in Marion County, I
must rely on second-hand reports from news outlets.
On July 10, 2020, Ocala.com reported “More Ocala jail inmates test positive for COVID-19”.
https://www.ocala.com/news/20200710/more-ocala-jail-inmates-test-positive-for-covid-19
The number has gone from 44 to 49 to the current 74. Fifteen jail workers also have
tested positive.” (Exhibit 16).
The number of inmates at the Marion County Jail who have tested positive for COVID-
19 has increased significantly within the past week, and the figure could rise as officials
receive more test results.
While testifying during a bail modification hearing on Friday, Dr. Tabitha Downey told
the court that as of Thursday, 74 inmates has tested positive for COVID-19. She said
results are pending for 150 more inmates.
On July 11, 2020, Ocala.com reported, “The state on Saturday reported that Marion now stands
at a cumulative 1,403 positive test results for COVID-19. That’s a gain of 96 since Friday.”
https://www.ocala.com/news/20200711/marion-now-up-to-1403-positive-tests-for-covid-19
On July 12, 2020, The Washington Post reported, “Florida shatters single-day infection record
with 15,300 new cases”. https://www.washingtonpost.com/nation/2020/07/12/coronavirus-update-us/
Conclusion
The Department of Health has enforcement authority (381.0012) of the Governor’s COVID-19
Executive Orders governing this communicable disease (381.003). Under 381.0012 (4) The
department may appear before any trial court judge empowered to issue warrants in criminal
cases and request the issuance of a warrant. The trial court judge shall issue a warrant directed to
any sheriff, deputy, or police officer to assist in any way to carry out the purpose and intent of
this chapter. Enforcement authority under 381.0012 (5) applies to the MCSO and State Attorney
Brad King: (5) It shall be the duty of every state and county attorney, sheriff, police officer, and
other appropriate city and county officials upon request to assist the department or any of its
agents in enforcing the state health laws, rules, and orders adopted under this chapter.
• Mr. McCourt is a former Assistant State Attorney in the Office of State Attorney of Brad
King. McCourt is also a member of the Marion County Bar Association, Inc.
• Judge Anthony Tatti is a former Assistant State Attorney, and a member of the Marion
County Bar Association, Inc., and benefits from unopposed judicial elections.
15
COVID-19 Call Center available 24/7 | +1 (866) 779-6121 or email COVID-19@flhealth.gov
Thank you.
Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Tel. 352-854-7807

http://www.floridahealth.gov/
COVID-19@flhealth.gov
Joint Information Center on COVID-19 for the State of Florida

http://www.floridahealth.gov/newsroom/2020/03/032320-1100-covid19.pr.html
ESF14@em.myflorida.com
NewsMedia@flhealth.gov
850-245-4111
High Risk Populations

https://floridahealthcovid19.gov/high-risk-populations/
Enclosures
16
Page 1 of 1
Neil Gillespie
From: "COVID-19" <COVID-19@flhealth.gov>

To:
Sent:
Subject:
"Neil Gillespie" <neilgillespie@mfi.net>
Saturday, July 25, 2020 2:20 PM
Re: COVID-19 Legal Protections?
A
Thank you for writing to the COVID-19 Call Center.
I am sorry, that sounds like a frustrating and scary situation. I recommend that you contact your local
authorities to find out how to have the person removed from your premises if you do not want them living
there.
This is an emerging, rapidly evolving situation. The CDC and State of Florida will continue to provide updated
information and guidance through their websites.
Please be sure to visit and regularly monitor the Department's dedicated COVID-19 webpage
at www.FloridaHealth.gov/COVID-19. This remains the best and most up-to-date resource for information and
guidance regarding COVID-19 in Florida.
You may also visit CDC’s website for more information regarding COVID-19
at https://www.cdc.gov/coronavirus/2019-ncov/
The Call Center can be reached by calling 1-866-779-6121 or emailing COVID-19@flhealth.gov and is
available 24 hours a day, 7 days a week.
COVID-19 Call Center
From: Neil Gillespie <neilgillespie@mfi.net>

Sent: Tuesday, July 14, 2020 1:07 PM
To: COVID-19 <COVID-19@flhealth.gov>; ESF14@em.myflorida.com <ESF14@em.myflorida.com>;
Feedback, NewsMedia <NewsMedia@flhealth.gov>
Cc: neilgillespie@mfi.net <neilgillespie@mfi.net>
Subject: COVID-19 Legal Protections?
COVID-19@flhealth.gov
ESF14@em.myflorida.com
NewsMedia@flhealth.gov
I am a person age 64 with type 2 diabetes and have followed COVID-19 orders to protect my health since I am
in a high risk group. Recently a person age 35 visited/lived in my home and was openly critical of COVID-19
orders calling the pandemic a hoax. This person never wears a mask, and travels in and around Marion County
just as she did before COVID-19. This person brought at least three strangers to my home to have sex and/or
do drugs. The person age 35 is a squatter in my home with no lease, and is not a relative, and not in a romantic
relationship with me. What legal protections do I have to protect myself from the behavior of this person that
violates Governor Ron DeSantis’ COVID-19 Executive Orders? The local police, the Marion County Sheriff’s
Office, does not take the COVID-19 threat seriously and has ignored my request for assistance. Thank you.
Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Tel. 352-854-7807 (no calls, no texts)
neilgillespie@mfi.net
7/26/2020
Page 1 of 2
Neil Gillespie
From: "Neil Gillespie" <neilgillespie@mfi.net>

To: "McCourt,Tim" <Tmccourt@marionso.com>
Cc: "Douglas, Robert (Chief)" <rdouglas@marionso.com>; "Lt. Welch MCSO" <cwelch@marionso.com>;
<TMarton@marionso.com>; "Neil Gillespie" <neilgillespie@mfi.net>
Sent: Tuesday, May 19, 2020 12:05 PM
Attach: Text messages of Sarah Thompson to Neil Gillespie.pdf; 2020, 05-19-20, clothing and property of
Sarah Thompson.pdf; 2020, 05-08-20, jeremiah young (One Time Visitor) was added 2.29 AM.pdf
Subject: COVID-19 protections and Sarah Thompson
Timothy T. McCourt
General Counsel
Florida Bar No. 44604 1
Cc: Douglas, Robert (Chief)
Cc: Lt. Charles Welch
Cc: Deputy T. Marton
Mr. McCourt:
On April 1, 2020 Gov. DeSantis issued Executive Order #20-91, Essential Services and Activities
During COVID-19 Emergency that required, inter alia, Florida residents to remain at home, and to wear
a mask or respirator while in pubic places for essential services and activities. I provided a paper copy of
Executive Order #20-91 shown at this link to Sarah Thompson. https://www.flgov.com/wp-
content/uploads/orders/2020/EO_20-91.pdf
Sarah is skeptical about COVID-19 and has not complied with any of the orders or recommendations
that I know about. I have not seen Sarah wear a mask, even while shopping at Walmart. Sarah has
ignored the stay home provisions, and travels freely in Marion County as she did before the COVID-19
Emergency.
What legal protections do I have while living under the same roof with Sarah, who is skeptical about
COVID-19 and has not complied with any of the orders or recommendations?
On the night of May-07-2020 through May-08-2020 Sarah had two visitors but refused to discuss this
with me. One visitor, perhaps with ties to Oak Run, appeared in my driveway for Sarah. The other
visitor came to my attention when I was awakened at 2:29 AM by a phone call from Envera Systems
security announcing that Jeremiah Young was here to visit Sarah. See attached a PDF of the email from
Envera Systems.
I do not recall to what extent I discussed COVID-19 and these visitors with Deputy T. Marton (5743)
and MCSO Deputy Pope (6377) on May-08-2020 who arrived to assist me. Perhaps the public records
for Case No. 2005080039 will show my discussion, if any.
Currently Sarah has a pile of clothing and belongings strewn in my garage, see the attached photos. I
believe this clothing may represent a COVID-19 risk by contamination from Sarah and/or one of her
many social and intimate contacts. FYI, Sarah’s "Dolly-style" escort page shows it is active again, see
https://www.eroticmonkey.ch/dolly-style-escort-ocala-608178
6/25/2020
Page 2 of 2
Sarah claims someone at the MCSO told her she has a week to pick up her stuff, see the attached text
message from Sarah to me. Please identify the person who told this to Sarah. In another text message
Sarah admits taking my laptop as a form of hostage to get her stuff "and it hasn’t been gone thru"
whatever that means. Sarah herself went through her stuff and left it a mess. Sarah also warns about
putting her stuff on shelves I bought for that purpose, but I put some of Sarah’s things on the shelves
before getting her text, items she left outside on the patio, and in my home.
Law professor Alan Dershowitz claims the state has wide authority to enforce COVID-19 precautions
for public health, including forced vaccination, under the Tenth Amendment, see
https://www.wnd.com/2020/05/alan-dershowitz-state-right-plunge-needle-arm/ and on YouTube
https://youtu.be/Hjk1-a98xag
Thank you.
Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Tel. 352-854-7807
6/25/2020
Page 1 of 1
Neil Gillespie
From: <noreply@enverasystems.com>
To: <neilgillespie@mfi.net>
Sent: Friday, May 08, 2020 2:29 AM
Subject: MyEnvera information update!
Your Visitors List was changed by Envera Operator. jeremiah young (One Time Visitor) was added.
If you did not request this change, please email CustomerService@EnveraSystems.com or call 877-936-
8372.
Please disable 'Notifications' in your profile if you do not wish to receive these messages.
5/17/2020
Photo made 05-19-2020 of clothing and property Sarah Thompson left in the garage of Neil Gillespie, 8092
SW 115th Loop, Ocala, FL 34481.
2
Text messages of Sarah Thompson to Neil Gillespie
I put some of Sarah’s things on the shelves before getting her text not to do so, items she left outside on the
patio, and in my home.
Kindly provide the name of the person Sarah spoke with at the MCSO.
Page 1 of 4
Neil Gillespie

Cc: "Douglas, Robert (Chief)" <rdouglas@marionso.com>; "Welch, Charles" <cwelch@marionso.com>;
"Marton, Timothy" <tmartin@marionso.com>; "Neil Gillespie" <neilgillespie@mfi.net>
Subject: Re: COVID-19 protections and Sarah Thompson
Fine. At this time I request a trespass warning be served on Sarah May Thompson regarding my
property to protect me from COVID-19 and the other threats she brings. As to Ms. Colbert, she has not
responded to my public records requests.
----- Original Message -----

From: McCourt,Tim
To: Neil Gillespie
Cc: Douglas, Robert (Chief) ; Welch, Charles ; Marton, Timothy ; zphipps@rc5state.com
Subject: RE: COVID-19 protections and Sarah Thompson
2
Yes, as do other law enforcement agencies and regulatory agencies (DBPR, DOH, etc.).

Yes, she does.

Timothy T. McCourt
General Counsel
PO Box 1987
Ocala, FL 34478-1987
Tel. (352) 369-6758

To: McCourt,Tim <Tmccourt@marionso.com>
Cc: Douglas, Robert (Chief) <rdouglas@marionso.com>; Welch, Charles
<cwelch@marionso.com>; Marton, Timothy <tmartin@marionso.com>
Mr. McCourt, does your agency enforce COVID-19 provisions in Marion County? If not, who does
enforce COVID-19 provisions in Marion County?
Does Ms. Colbert still work for the MCSO as a public records person? If not, please identify the
custodian for public records. Thank you.
Neil J. Gillespie
From: McCourt,Tim
To: Neil Gillespie
7/25/2020
Page 2 of 4
Mr. Gillespie,


Regarding the recourse and protections you may have regarding Ms. Thompson choosing not to comply
with recommendations and orders, I would suggest you consult an attorney who can render legal advice
to you. Unfortunately, as staff attorney for this agency, the agency has a monopoly on my legal advice.

I reviewed the clerk’s docket in your criminal case and see that Mr. Phipps remains your counsel of
record. Accordingly, he is copied on this e-mail.

Thank you.

Timothy T. McCourt
General Counsel
PO Box 1987
Ocala, FL 34478-1987
Tel. (352) 369-6758

<cwelch@marionso.com>; Marton, Timothy <tmartin@marionso.com>; Neil Gillespie
<neilgillespie@mfi.net>
Timothy T. McCourt
General Counsel
Mr. McCourt:
During COVID-19 Emergency that required, inter alia, Florida residents to remain at home, and to
wear a mask or respirator while in pubic places for essential services and activities. I provided a
7/25/2020
Page 3 of 4
paper copy of Executive Order #20-91 shown at this link to Sarah Thompson.
https://www.flgov.com/wp-content/uploads/orders/2020/EO_20-91.pdf
ignored the stay home provisions, and travels freely in Marion County as she did before the COVID-
19 Emergency.
security announcing that Jeremiah Young was here to visit Sarah. See attached a PDF of the email
from Envera Systems.
and MCSO Deputy Pope (6377) on May-08-2020 who arrived to assist me. Perhaps the public
records for Case No. 2005080039 will show my discussion, if any.
many social and intimate contacts. FYI, Sarah’s "Dolly-style" escort page shows it is active again,
see https://www.eroticmonkey.ch/dolly-style-escort-ocala-608178
Thank you.
Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Tel. 352-854-7807
Under Florida Law, e-mail addresses are public records. If you do not want your e-mail address
released in response to a public-records request, do not send electronic mail to this entity. Instead,
contact this office by phone or in writing. CONFIDENTIALITY NOTICE: This message and any
7/25/2020
Page 4 of 4
attachments are for the sole use of the intended recipient(s) and may contain confidential and
privileged information that is exempt from public disclosure. Any unauthorized review, use,
disclosure, or distribution is prohibited. If you have received this message in error please contact the
sender (by phone or reply electronic mail).
attachments are for the sole use of the intended recipient(s) and may contain confidential and privileged
information that is exempt from public disclosure. Any unauthorized review, use, disclosure, or
distribution is prohibited. If you have received this message in error please contact the sender (by
phone or reply electronic mail).
7/25/2020
MARlON COUNTY SHERIFF'S OFFICE
Trespass Authorization
. l,<ttt P
--IL~:.Jk~~~~'-P'-'=;:'.....LI,,"':::::;'7'7"=-"2.--r.-=r-'
am the owner' b
the bus' ess/property located at
It> ~ I hereby nominate and appoint the Marion County
Sheriff, and is deputIes, as my authorized representatives/agents to act on my behalf in warning and
directing persons to leave the property located at ~ .
It is my intention that the Marion County Sheriff, and his deputies, enforce §810.08 and §81O.09,
Florida Statutes regarding trespassing at the aforementioned property. I agree to aid in the prosecution
of those persons arrested. I further understand that this Authorization will remain in effect until such
time as I revoke it in writing deliverable by certified mailing to the Marion County Sheriffs Office.
WITNESS WHEREOF, I have set my hand and seal on this v-=-__ day of J;gpv
(Witness signature) (owner phone number)
(witness printed name)
STATE OF FLORIDA
COUNTY OF MARION 3
BE IT KNOWN, that on the r$.JIi day of '-I-f/"l4.v+(~ efore me, appeared
_-.Jl=-,,0e,,--,i-lo-l~GLIJ.'t-:'-=-U~ec::...:!f::..r-:.i--",c..~ -" who i ersonally known to me or presented
_ _ _ _ _ _ _ _ _ _ _ _ _ _ as identification ithin Trespass
Authorization, and who acknowledges said Trespass Authorization to be his/her act and deed.
............... GLfNDA HOUCK '
My Commission Expires: {:{~/;."':~ CommiSSIon' GG 154542 -N~O~RrllYtddlpU~B:;...L--!IC~~:Z£~-----
\~.~ ....~ Expires Februaly 23. 2022
....~f.ii.f::?~.. BcndId 1lw TIllY Fein -.nee 8QO.3&5.10tt
Billy Woods, Sheriff

PO Box 1981. Ocala. Florida"3441B-1987 Main Office: 352-132-8181 Civil: 352--402-6025 Emergency Management: 352~-8100 Jail: 352-351-8077
/.--e () I j
I
NOTICE OF TRESPASS l!t3!2,d
TO: Sarah May Thompson Ii; 11 kk
Florida ID Card: T512-793-85-709-0
14671 SW 41st. Ave. Rd. j&~~
Ocala, FL 34473
Text: 352-872-7666
Text: 352-571-8641
Consistent with the text notification given to you on January 12,2020, I hereby notify you that
as of Sunday, January 12,2020, SARAH MAY THOMPSON is not authorized, licensed, or
invited to enter or remain my property.
Neil 1. Gillespie
8092 SW 115th Loop
Ocala, FL 34481
Pursuant to Florida Statute 810,08, violation of this notice will result in prosecution for trespass
of a structure or conveyance.
DATED this 12th day of January, 2020.
Sincerely,
lsi
Neil J. Gillespie
8092 SW 115th Loop
Ocala, FL 34481
352-854-7807
------
·13z·~q, I'
--"- \.
MAINOFFICE 1352,732-3181
Page 1 of 4
Neil Gillespie

To: "Neil Gillespie" <neilgillespie@mfi.net>; <zphipps@rc5state.com>
Cc: "Douglas, Robert (Chief)" <rdouglas@marionso.com>; "Welch, Charles" <cwelch@marionso.com>;
"Marton, Timothy" <tmartin@marionso.com>; "McCourt,Tim" <Tmccourt@marionso.com>
Sent: Friday, June 12, 2020 2:28 PM
307 NW 3rd St
Ocala, FL 34475-6638
Email: zphipps@rc5state.com 4
Mr. Phipps:
I do not show a response from you on COVID-19 protections and Sarah Thompson. Please respond by
the end of business today or I will proceed on that basis.
Also, are you a member of the Marion County Bar Association, Inc.?
Thank you.
Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Tel. 352-854-7807

From: Neil Gillespie
To: zphipps@rc5state.com
Cc: Douglas, Robert (Chief) ; Welch, Charles ; Marton, Timothy ; McCourt,Tim ; Neil Gillespie
Sent: Thursday, June 11, 2020 9:03 AM

307 NW 3rd St
Ocala, FL 34475-6638
Email: zphipps@rc5state.com
Mr. Phipps.
Mr. McCourt is unable to answer my questions about COVID-19, see my email to him forwarded
below. McCourt responded:
Regarding the recourse and protections you may have regarding Ms. Thompson choosing not to
comply with recommendations and orders, I would suggest you consult an attorney who can render
legal advice to you. Unfortunately, as staff attorney for this agency, the agency has a monopoly on
7/25/2020
Page 2 of 4
my legal advice.

Therefore I direct my COVID-19 questions to you, as you remain counsel of record, and I cannot
obtain adequate counsel. FYI,
"Hillsborough County Sheriff Chad Chronister said Rodney Howard-Browne, pastor at The
River at Tampa Bay Church, was arrested for "intentionally and repeatedly" disregarding state
health orders. The sheriff said the church gatherings "put his congregation and our community in
danger."" https://www.upi.com/Top_News/US/2020/03/30/Florida-pastor-arrested-for-holding-
church-during-COVID-19-restrictions/5221585610610/
The same or similar could be said about Ms. Thompson who "intentionally and repeatedly"
disregarded state health orders." Her clandestine meetings of people in my home for random sex, and
random drug use, put me (a vulnerable class under COVID-19), residents of the Oak Run Country
Club (most residents are in a vulnerable class under COVID-19), and our community in danger.
Thank you.
Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Tel. 352-854-7807
From: McCourt,Tim
To: Neil Gillespie
Mr. Gillespie,


Regarding the recourse and protections you may have regarding Ms. Thompson choosing not to comply
with recommendations and orders, I would suggest you consult an attorney who can render legal advice
to you. Unfortunately, as staff attorney for this agency, the agency has a monopoly on my legal advice.


Thank you.

7/25/2020
Page 3 of 4
Timothy T. McCourt
General Counsel
PO Box 1987
Ocala, FL 34478-1987
Tel. (352) 369-6758

<cwelch@marionso.com>; Marton, Timothy <tmartin@marionso.com>; Neil Gillespie
<neilgillespie@mfi.net>
Timothy T. McCourt
General Counsel
Mr. McCourt:
During COVID-19 Emergency that required, inter alia, Florida residents to remain at home, and to
wear a mask or respirator while in pubic places for essential services and activities. I provided a
paper copy of Executive Order #20-91 shown at this link to Sarah Thompson.
https://www.flgov.com/wp-content/uploads/orders/2020/EO_20-91.pdf
ignored the stay home provisions, and travels freely in Marion County as she did before the COVID-
19 Emergency.
security announcing that Jeremiah Young was here to visit Sarah. See attached a PDF of the email
from Envera Systems.
7/25/2020
Page 4 of 4
and MCSO Deputy Pope (6377) on May-08-2020 who arrived to assist me. Perhaps the public
records for Case No. 2005080039 will show my discussion, if any.
many social and intimate contacts. FYI, Sarah’s "Dolly-style" escort page shows it is active again,
see https://www.eroticmonkey.ch/dolly-style-escort-ocala-608178
Thank you.
Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Tel. 352-854-7807
7/25/2020
•• • • • • • • •
081922
II]
•
SHERIFF'S OFFICE
Marion County
Inmate Request Form
5
TO:
FOOD SERVICES D CANTEEN/INMATE ACCOUNTS D
LAW LIBRARY D CLASSIFICATIONS D
PROGRAMS D PUBLIC DEFENDER D
PROPERTY D DISCIPLINARY REPORT APPEALS D
CHAPLAIN D OTHER D
(Pin Number)
(Date) t f (Pod/Section/Cell #)
(Received from inmate by Officer Signature and 10 #) (Oaterrime)
REQUEST/COMPLAINT:
-:5A;""~ GoN2A(e~
RESPONSE:
(Response to inmate by Officer Signature and 10 #) (Daterrime)
White Copy - Classification once the response is compiled.

Page 1 of 2
Neil Gillespie

To: "Guy Minter" <matthew.minter@marioncountyfl.org>; "Jeff Gold" <Jeff.Gold@marioncountyfl.org>;
"Michelle Stone" <Michelle.Stone@marioncountyfl.org>; "Carl Zalak"
<Carl.zalak@marioncountyfl.org>; "David Moore" <David.moore@marioncountyfl.org>; "Kathy
Bryant" <Kathy.bryant@marioncountyfl.org>; "Neil Gillespie" <neilgillespie@mfi.net>
Cc: "Douglas, Robert (Chief)" <rdouglas@marionso.com>; "Pulford, Louis" <lpulford@marionso.com>;
"Joiner, Dennis" <djoiner@marionso.com>; "Bloom, Paul" <pbloom@marionso.com>; "Woods,
William" <Sheriff.Woods@marionso.com>; "Welch, Charles" <cwelch@marionso.com>; "Colbert,
Brittany" <bcolbert@marionso.com>; <Eservicemarion@Sao5.Org>; <jgainey@sao5.org>;
<asmith@sao5.org>; <bking@sao5.org>; "Zachary Phipps" <zphipps@rc5state.com>
Sent: Thursday, June 25, 2020 9:39 PM
Attach: 215.322.pdf; NO RESPONSE Zachary Phipps, OCCCRC for 5th DCA COVID-19.pdf; MCSO Jailer
Gonzalez says COVID-19 is fake virus.pdf; High-Risk Populations _ Florida Department of Health
COVID-19 Outbreak.pdf; EMAIL Response of MCSO Tim McCourt to COVID-19.pdf; EMAIL
GILLSPIE to MCSO re COVID-19.pdf
Subject: Fw: MCSO, COVID-19, and F.S. sec 215.322 Acceptance of credit cards
Matthew Minter
Marion County BOCC
RE: MCSO, COVID-19, and Fla. Stat. sec. 215.322 Acceptance of credit cards
Mr. Minter:
Just to follow-up, COVID-19 is another reason for the MCSO to comply with Fla. Stat. sec. 215.322
Acceptance of credit cards, rather than paying in person.
Does the BOCC believe COVID-19 is a real threat? Florida, California and Texas are all seeing a surge
in coronavirus cases, with record high number of new cases. That is not surprising in Florida given the
attitudes I found from Tim McCourt, Zachary Phipps, and MCSO Jailer Gonzalez who claims COVID-
19 is a "fake virus" and refused to follow COVID-19 rules. For example, a "nurse" at the jail refused to
wear gloves while performing glucose tests on inmates. This alleged "nurse" instructed inmates to pass
the glucose test meter from one to the next, none of the inmates wore gloves or even washed hands.
While I am type 2 diabetic, I skipped that risk.
Personally I am in a high-risk group, over age 50 with type 2 diabetes. But from McCourt on down, they
must think COVID-19 is a joke or fake.
In my view the BOCC ought to immediately close down the jail.
Thank you.
Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Tel. 352-854-7807

7/25/2020
Page 2 of 2
To: Guy Minter ; Neil Gillespie

Cc: McCourt,Tim
Sent: Thursday, June 25, 2020 8:03 PM
Subject: MCSO and F.S. sec 215.322 Acceptance of credit cards
Matthew Minter
Marion County BOCC
RE: MCSO and F.S. sec 215.322 Acceptance of credit cards
Mr. Minter:
The MCSO refuses to comply with Fla. Stat. sec. 215.322 Acceptance of credit cards, charge cards,
debit cards, or electronic funds transfers by state agencies, units of local government, and the judicial
branch. The statute is attached.
Please advise if the BOCC will compel compliance by the MCSO, or if litigation is needed.
Thank you.
Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Ocala, FL 34481
Tel. 352-854-7807
7/25/2020
Page 1 of 1
Neil Gillespie

To: "McCourt,Tim" <Tmccourt@marionso.com>; "Colbert, Brittany" <bcolbert@marionso.com>
Cc: "Neil Gillespie" <neilgillespie@mfi.net>
Sent: Monday, July 20, 2020 3:34 PM
Subject: COVID-19 Cases
Timothy T. McCourt
General Counsel
Marion County Sheriff’s Office 7
RE: COVID-19 Cases
Mr. McCourt:
This is a request for the number of Coronavirus or COVID-19 cases among the following:

Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Ocala, FL 34481
Tel. 352-854-7807
7/25/2020
Page 1 of 2
Neil Gillespie
From: "McCourt,Tim" <Tmccourt@marionso.com>

To: "Neil Gillespie" <neilgillespie@mfi.net>; "Colbert, Brittany" <bcolbert@marionso.com>
Cc: <zphipps@rc5state.com>
Attach: ATT00086.eml
Subject: RE: COVID-19 Cases
Mr. Gillespie,

8
I am in receipt of your inquiry.

To the extent that you are requesting records, your outstanding balance from your prior record request has
not been paid and your public records requests will not be fulfilled until it is. Please see the attached e-mail
to help refresh your recollection.

To the extent that you are simply asking a question, this agency is not required to answer your question. In
re Report of Supreme Court Workgroup on Pub. Records, 825 So. 2d 889, 898 (Fla. 2002)(“The custodian is
required to provide access to or copies of records but is not required either to provide information from
records or to create new records in response to a request.”). See also Op. Atty. Gen Fla.. 92-38 (1992)(In
response to an inquiry regarding whether a town was required to make its financial officer available to be
interviewed by certified public accountants, the Attorney General opined, “While every person has a right of
access to the public records held by a public agency, I have not found, nor have you directed my attention
to, any provision in Ch. 119, F.S., which would require the town to provide the financial officer for
interrogation by certified public accountants acting on behalf of a private citizen who has requested access
to financial records pursuant to the Public Records Law. Whether the town chooses to provide the financial
officer under such circumstances would appear to be a matter of policy which the town must decide, not
this office.”)

Thank you.

Timothy T. McCourt
General Counsel
PO Box 1987
Ocala, FL 34478-1987
Tel. (352) 369-6758

Sent: Monday, July 20, 2020 3:34 PM
To: McCourt,Tim <Tmccourt@marionso.com>; Colbert, Brittany <bcolbert@marionso.com>
Cc: Neil Gillespie <neilgillespie@mfi.net>
Subject: COVID-19 Cases
Timothy T. McCourt
General Counsel
7/25/2020
Page 2 of 2

RE: COVID-19 Cases
Mr. McCourt:
This is a request for the number of Coronavirus or COVID-19 cases among the following:

Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Ocala, FL 34481
Tel. 352-854-7807
Under Florida Law, e-mail addresses are public records. If you do not want your e-mail address released
in response to a public-records request, do not send electronic mail to this entity. Instead, contact this
office by phone or in writing. CONFIDENTIALITY NOTICE: This message and any attachments are
for the sole use of the intended recipient(s) and may contain confidential and privileged information that
is exempt from public disclosure. Any unauthorized review, use, disclosure, or distribution is prohibited.
If you have received this message in error please contact the sender (by phone or reply electronic mail).
7/25/2020
June , 2020
Neil Gillespie
Via e-mail only
RE: Public Records request received: June , 2020
Dear Mr. Gillespie:
You have requested WKDW, provide you the following records, pursuant to Florida's public record
laws:&HUWLILHGFRS\RIDSXEOLFUHFRUG\RXUHPDLOEHORZZLWKWKHDWWDFKHGHPDLORI6DUDK
7KRPSVRQ7XHVGD\)HEUXDU\DW$0DQG\RXUHPDLOUHVSRQVH:HGQHVGD\)HEUXDU\
DW$0
A review of prior public records requests reveals that you made a public records request for
UHFRUGV IRU WKH %8'*(7 ),1$1&( ',9,6,21 $FFRXQWLQJ 6HUYLFHV 8QLW WKH DJHQF\¶V
DQQXDO EXGJHW IRU VXEPLVVLRQ WR WKH 0DULRQ &RXQW\ %RDUG RI &RXQW\ &RPPLVVLRQHUV WKH EXGJHW
IRU WKH SDVW \HDUV $OVR WKH SROLFLQJ SROLF\ ZLWK WKH 0DULRQ &RXQW\ %RDUG RI &RXQW\
&RPPLVVLRQHUV RQ -XQH WK Pursuant to s. 119.07(4), Florida Statutes, fees may be charged in
association with public records requests. In response to your previous request, on June th
you were advised the cost to produce the records was $1.15 (see attached e-mailDQGLQYRLFH).
However, you have not yet paid the fees associated with the prior request and the requested
records have not been delivered to you.
Courts have held that an agency may refuse to produce public records if the fees charged for a previous
request for records have not been paid by the requestor. See Florida Agency for Healthcare
Administration v. Zuckerman Spaeder LLP, 221 So. 3d 1260 (Fla. 1st DCA 2017); Lozman v. City of
Riviera Beach, 995 So. 2d 1027 (Fla. 4th DCA 2008).
While it is our desire to provide you with the records to which you are lawfully entitled in
an expeditious matter, the legislature has authorized the assessment of fees to ensure that taxpayers
do not shoulder the entire expense of complying with a public records request. Accordingly, until
such time as you pay the fees for the June th request in the amount of $1.15 our agency will
not EHDEOHWRSURGXFHWKHUHFRUGVUHTXHVWHGE\\RXRQ-XQHWKUpon payment of the amount of
$1.15, we will EHJLQSURFHVVLQJ\RXU-XQHWKUHTXHVW
WILLIAM “BILLY” WOODS
SHERIFF OF MARION COUNTY
___________________________
By: Timothy Thomas McCourt
General Counsel
Service Fee Calculation
Total
Amount
COPY SERVICES
Case Report Copies X $0.15 per page = $0.00
Certified Copies X $1.00 per page = $0.00
NOTARY SERVICES X $5.00 per notary = $0.00
BACKGROUND CHECKS
Initial Background X $5.00 per initial background = $0.00
Additional Name, i.e., Maiden Name X $1.00 per name = $0.00

Hyphenated Names, aka's
Per Page of Background X $0.15 per page = $0.00
CLERICAL RESEARCH
First Hour X $20.00 per hour = $0.00
Additional Research Time 2 X $5.00 per quarter hour = $10.00
Other / Misc.
Includes DVD's, CD's etc.. 1 X $1.15 per disk = $1.15
TOTAL FEES (minus $7.00 - cooler) $11.15

NEW TOTAL = $4.15
CASH TENDERED
Note: Clerical research fees are not accessed for the first 15 minutes spent responding to a public records request.
Thereafter, each quarter-hour spent is billed at the rate of $5.00 per full quarter hour. If only a portion of a quarter hour
is used, time should be rounded down to the nearest quarter hour increment.
CHANGE DUE
MCSO Form #14-400Rev.

Rev.06/19/19
12/08/17
From: Colbert, Brittany
To: McCourt,Tim
Subject: FW: Public Records Request (PRR), annual budget, policing policy
Date: Thursday, June 25, 2020 2:51:11 PM
Attachments: image001.png
Invoice.pdf

Sent: Monday, June 15, 2020 4:42 PM
To: 'neilgillespie@mfi.net' <neilgillespie@mfi.net>
Subject: RE: Public Records Request (PRR), annual budget, policing policy

Mr. Gillespie,

Please find attached an invoice totaling $11.15. You can pick it up at our main operations located at 692 NW 30th
Avenue Ocala, FL 34475 or mail payment in the form of cash, money order or cashier’s check (no personal checks)
to the below address. Once payment is received, your request will be mailed to you.

Attention: Records - Brittany
PO Box 1987
Ocala, FL 34478

Best regards,
Brittany Colbert
Central Records Manager
S.T.A.R Manager
Post Office Box 1987
Ph: 352-732-8181
bcolbert@marionso.com

To: Colbert, Brittany <bcolbert@marionso.com>
Subject: Public Records Request (PRR), annual budget, policing policy

Brittany Colbert
Central Records/S.T.A.R Manager
RE: Public Records Request (PRR), Art. I, Sec. 24, Fla. Const. All public
records requests shall be acknowledged promptly and in good faith, F.S. §
119.07(1)(c)
119.011 Definitions.—As used in this chapter, the term: (12) "Public records"
means all documents, papers, letters, maps, books, tapes, photographs, films,
sound recordings, data processing software, or other material, regardless of the
physical form, characteristics, or means of transmission, made or received
pursuant to law or ordinance or in connection with the transaction of official
business by any agency.
Ms. Colbert,
Provide records for the BUDGET & FINANCE DIVISION, Accounting Services Unit, the
agency’s annual budget for submission to the Marion County Board of County
Commissioners, the budget for the past 3 years.
Also, the policing policy with the Marion County Board of County Commissioners.
Thank you.
Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Tel. 352-854-7807
June , 2020
Neil Gillespie
Via e-mail only
RE: Public Records request received: June , 2020
Dear Mr. Gillespie:
You have requested WKDW, provide you the following records, pursuant to Florida's public record
laws:&HUWLILHGFRS\RIDSXEOLFUHFRUG\RXUHPDLOEHORZZLWKWKHDWWDFKHGHPDLORI6DUDK
7KRPSVRQ7XHVGD\)HEUXDU\DW$0DQG\RXUHPDLOUHVSRQVH:HGQHVGD\)HEUXDU\
DW$0
A review of prior public records requests reveals that you made a public records request for
UHFRUGV IRU WKH %8'*(7 ),1$1&( ',9,6,21 $FFRXQWLQJ 6HUYLFHV 8QLW WKH DJHQF\¶V
DQQXDO EXGJHW IRU VXEPLVVLRQ WR WKH 0DULRQ &RXQW\ %RDUG RI &RXQW\ &RPPLVVLRQHUV WKH EXGJHW
IRU WKH SDVW \HDUV $OVR WKH SROLFLQJ SROLF\ ZLWK WKH 0DULRQ &RXQW\ %RDUG RI &RXQW\
&RPPLVVLRQHUV RQ -XQH WK Pursuant to s. 119.07(4), Florida Statutes, fees may be charged in
association with public records requests. In response to your previous request, on June th
you were advised the cost to produce the records was $1.15 (see attached e-mailDQGLQYRLFH).
However, you have not yet paid the fees associated with the prior request and the requested
records have not been delivered to you.
Courts have held that an agency may refuse to produce public records if the fees charged for a previous
request for records have not been paid by the requestor. See Florida Agency for Healthcare
Administration v. Zuckerman Spaeder LLP, 221 So. 3d 1260 (Fla. 1st DCA 2017); Lozman v. City of
Riviera Beach, 995 So. 2d 1027 (Fla. 4th DCA 2008).
While it is our desire to provide you with the records to which you are lawfully entitled in
an expeditious matter, the legislature has authorized the assessment of fees to ensure that taxpayers
do not shoulder the entire expense of complying with a public records request. Accordingly, until
such time as you pay the fees for the June th request in the amount of $1.15 our agency will
not EHDEOHWRSURGXFHWKHUHFRUGVUHTXHVWHGE\\RXRQ-XQHWKUpon payment of the amount of
$1.15, we will EHJLQSURFHVVLQJ\RXU-XQHWKUHTXHVW
WILLIAM “BILLY” WOODS
SHERIFF OF MARION COUNTY
___________________________
By: Timothy Thomas McCourt
General Counsel
Service Fee Calculation
Total
Amount
COPY SERVICES
Case Report Copies X $0.15 per page = $0.00
Certified Copies X $1.00 per page = $0.00
NOTARY SERVICES X $5.00 per notary = $0.00
BACKGROUND CHECKS
Initial Background X $5.00 per initial background = $0.00
Additional Name, i.e., Maiden Name X $1.00 per name = $0.00

Hyphenated Names, aka's
Per Page of Background X $0.15 per page = $0.00
CLERICAL RESEARCH
First Hour X $20.00 per hour = $0.00
Additional Research Time 2 X $5.00 per quarter hour = $10.00
Other / Misc.
Includes DVD's, CD's etc.. 1 X $1.15 per disk = $1.15
TOTAL FEES $11.15
CASH TENDERED
Note: Clerical research fees are not accessed for the first 15 minutes spent responding to a public records request.
Thereafter, each quarter-hour spent is billed at the rate of $5.00 per full quarter hour. If only a portion of a quarter hour
is used, time should be rounded down to the nearest quarter hour increment.
CHANGE DUE ($11.15)
MCSO Form #14-400Rev.

Rev.06/19/19
12/08/17
To: McCourt,Tim
Subject: FW: Public Records Request (PRR), annual budget, policing policy
Date: Thursday, June 25, 2020 2:51:11 PM
Attachments: image001.png
Invoice.pdf

Sent: Monday, June 15, 2020 4:42 PM
To: 'neilgillespie@mfi.net' <neilgillespie@mfi.net>
Subject: RE: Public Records Request (PRR), annual budget, policing policy

Mr. Gillespie,

Please find attached an invoice totaling $11.15. You can pick it up at our main operations located at 692 NW 30th
Avenue Ocala, FL 34475 or mail payment in the form of cash, money order or cashier’s check (no personal checks)
to the below address. Once payment is received, your request will be mailed to you.

Attention: Records - Brittany
PO Box 1987
Ocala, FL 34478

Best regards,
Brittany Colbert
Central Records Manager
S.T.A.R Manager
Post Office Box 1987
Ph: 352-732-8181
bcolbert@marionso.com

To: Colbert, Brittany <bcolbert@marionso.com>
Subject: Public Records Request (PRR), annual budget, policing policy

Brittany Colbert
Central Records/S.T.A.R Manager
RE: Public Records Request (PRR), Art. I, Sec. 24, Fla. Const. All public
records requests shall be acknowledged promptly and in good faith, F.S. §
119.07(1)(c)
119.011 Definitions.—As used in this chapter, the term: (12) "Public records"
means all documents, papers, letters, maps, books, tapes, photographs, films,
sound recordings, data processing software, or other material, regardless of the
physical form, characteristics, or means of transmission, made or received
pursuant to law or ordinance or in connection with the transaction of official
business by any agency.
Ms. Colbert,
Provide records for the BUDGET & FINANCE DIVISION, Accounting Services Unit, the
agency’s annual budget for submission to the Marion County Board of County
Commissioners, the budget for the past 3 years.
Also, the policing policy with the Marion County Board of County Commissioners.
Thank you.
Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Tel. 352-854-7807
Page 1 of 1
Neil Gillespie

To: <pbloom@marionso.com>
Sent: Thursday, July 23, 2020 4:15 PM
Subject: request for public information
9
Sgt. Paul Bloom
This is a request for public information on the number of coronavirus or COVID-19 cases among the
following:

Thank you.
7/25/2020
Page 1 of 2
Neil Gillespie

To: "Neil Gillespie" <neilgillespie@mfi.net>
Cc: "Bloom, Paul" <pbloom@marionso.com>; <zphipps@rc5state.com>
Sent:
Attach:
Subject:
Thursday, July 23, 2020 4:47 PM
RE_ COVID-19 Cases.eml
RE: request for public information
10
Mr. Gillespie,

I am in receipt of your inquiry submitted to Sgt. Bloom (see below). This is the same inquiry you made on
July 20th. See attached e-mail (this e-mail contains another e-mail, attached to it, which in turn contains two
pieces of correspondence). I trust you already have these in your possession but provide them to you for
your ready reference.

As I noted on the 20th, to the extent that you are requesting records, your outstanding balance from your
prior record request has not been paid and your public records requests will not be fulfilled until it is. Please
see the attached e-mail to help refresh your recollection.

re Report of Supreme Court Workgroup on Pub. Records, 825 So. 2d 889, 898 (Fla. 2002)(“The custodian is
required to provide access to or copies of records but is not required either to provide information from
interviewed by certified public accountants, the Attorney General opined, “While every person has a right of
access to the public records held by a public agency, I have not found, nor have you directed my attention
to, any provision in Ch. 119, F.S., which would require the town to provide the financial officer for
interrogation by certified public accountants acting on behalf of a private citizen who has requested access
to financial records pursuant to the Public Records Law. Whether the town chooses to provide the financial
officer under such circumstances would appear to be a matter of policy which the town must decide, not
this office.”)


Thank you.

Timothy T. McCourt
General Counsel
PO Box 1987
Ocala, FL 34478-1987
Tel. (352) 369-6758

From: Bloom, Paul <pbloom@marionso.com>
Subject: FW: request for public information
7/26/2020
Page 2 of 2

Sergeant Paul Bloom
Public Information Director
Desk: (352) 368-3527
Cell: (352) 299-7186
www.marionso.com

To: Bloom, Paul <pbloom@marionso.com>
Sgt. Paul Bloom

following:

Thank you.
7/26/2020
Page 1 of 2
Neil Gillespie

Subject: Re: request for public information
Mr. McCourt: I am not requesting records, I am preparing a complaint to the Department of Health for
the MCSO, you and Phipps, and bar complaints for you and Phipps. I requested information form the
Public Information Office which you have obstructed. Fine, my complaints will show your
obstruction. Neil J. Gillespie

From: McCourt,Tim
To: Neil Gillespie
Cc: Bloom, Paul ; zphipps@rc5state.com
Sent: Thursday, July 23, 2020 4:47 PM 11
Subject: RE: request for public information
Mr. Gillespie,

July 20th. See attached e-mail (this e-mail contains another e-mail, attached to it, which in turn contains
two pieces of correspondence). I trust you already have these in your possession but provide them to you
for your ready reference.

prior record request has not been paid and your public records requests will not be fulfilled until it is.
Please see the attached e-mail to help refresh your recollection.

re Report of Supreme Court Workgroup on Pub. Records, 825 So. 2d 889, 898 (Fla. 2002)(“The custodian
is required to provide access to or copies of records but is not required either to provide information from
interviewed by certified public accountants, the Attorney General opined, “While every person has a right
of access to the public records held by a public agency, I have not found, nor have you directed my
attention to, any provision in Ch. 119, F.S., which would require the town to provide the financial officer
for interrogation by certified public accountants acting on behalf of a private citizen who has requested
access to financial records pursuant to the Public Records Law. Whether the town chooses to provide the
financial officer under such circumstances would appear to be a matter of policy which the town must
decide, not this office.”)


Thank you.

Timothy T. McCourt
General Counsel
7/26/2020
Page 2 of 2

PO Box 1987
Ocala, FL 34478-1987
Tel. (352) 369-6758


Sergeant Paul Bloom
Desk: (352) 368-3527
Cell: (352) 299-7186
www.marionso.com

Sgt. Paul Bloom

following:

Thank you.
7/26/2020
Page 1 of 3
Neil Gillespie

To: "Neil Gillespie" <neilgillespie@mfi.net>
Sent:
Subject:
Thursday, July 23, 2020 5:43 PM
RE: request for public information
Mr. Gillespie,
12

We do have an obligation to give you public records in accordance with Chapter 119, which we will not be
doing until you pay your outstanding balance for prior public records requests. This is specifically allowed by
law. See Florida Agency for Healthcare Administration v. Zuckerman Spaeder LLP, 221 So. 3d 1260 (Fla. 1st DCA
2017); Lozman v. City of Riviera Beach, 995 So. 2d 1027 (Fla. 4th DCA 2008).

If you can point to some legal authority that requires this agency to answer questions you e-mail us, I’d be
interested to know what it is.

Thank you.

Timothy T. McCourt
General Counsel
PO Box 1987
Ocala, FL 34478-1987
Tel. (352) 369-6758

Cc: Bloom, Paul <pbloom@marionso.com>; zphipps@rc5state.com
Subject: Re: request for public information
Mr. McCourt: I am not requesting records, I am preparing a complaint to the Department of Health for
the MCSO, you and Phipps, and bar complaints for you and Phipps. I requested information form the
Public Information Office which you have obstructed. Fine, my complaints will show your
obstruction. Neil J. Gillespie
From: McCourt,Tim
To: Neil Gillespie
Cc: Bloom, Paul ; zphipps@rc5state.com
Subject: RE: request for public information
Mr. Gillespie,

July 20th. See attached e-mail (this e-mail contains another e-mail, attached to it, which in turn contains
two pieces of correspondence). I trust you already have these in your possession but provide them to you
7/26/2020
Page 2 of 3
for your ready reference.

prior record request has not been paid and your public records requests will not be fulfilled until it is.
Please see the attached e-mail to help refresh your recollection.

re Report of Supreme Court Workgroup on Pub. Records, 825 So. 2d 889, 898 (Fla. 2002)(“The custodian
is required to provide access to or copies of records but is not required either to provide information from
interviewed by certified public accountants, the Attorney General opined, “While every person has a right
of access to the public records held by a public agency, I have not found, nor have you directed my
attention to, any provision in Ch. 119, F.S., which would require the town to provide the financial officer
for interrogation by certified public accountants acting on behalf of a private citizen who has requested
access to financial records pursuant to the Public Records Law. Whether the town chooses to provide the
financial officer under such circumstances would appear to be a matter of policy which the town must
decide, not this office.”)


Thank you.

Timothy T. McCourt
General Counsel
PO Box 1987
Ocala, FL 34478-1987
Tel. (352) 369-6758


Sergeant Paul Bloom
Desk: (352) 368-3527
Cell: (352) 299-7186
www.marionso.com

7/26/2020
Page 3 of 3

Sgt. Paul Bloom

following:

Thank you.
7/26/2020
7/19/2020 Ocala Post - Lawsuit filed against Marion County Sheriff, Billy Woods
Lawsuit ﬁled against Marion County Sheriff,

Billy Woods
By Ocala Post - July 1, 2020
Save Share 8
13
UPDATE: On July 2, 2020, at approximately 8 a.m., less than 24 hours after this
article was published, Judge Anthony Tatti signed an Order Releasing Defendant
on His Own Recognizance with Conditions of Release.
Gainesville Attorney Adam Stout said that he believes his client’s release saved
[his] life.
In part, the release states, “The Defendant shall be confined to the interior of his
residence unless traveling to the office or other location of a licensed physician or
the purpose of meeting with his attorney.”
You can read the release here.
Original article
Shortly before Marion County Sheriff Billy Woods accused attorneys and “his
citizens” of being “keyboard warriors,” Gainesville Attorney Adam Stout filed a
lawsuit against the sheriff.
The lawsuit was filed on July 1. (Read the lawsuit here)
Woods is being accused of violating the Florida Constitution by allowing inmates

to be housed in unsanitary conditions and knowingly putting elderly inmates in
grave danger. In some instances, sections of the jail were without running water
and A/C.
Woods said the problems were fixed quickly, but many disagree with his definition
of quickly.
The lawsuit has been filed on behalf of Louis Early Payton, a 74-year-old inmate
who has serious health problems and is being held without bond after he violated
his probation conditions on a misdemeanor charge.
In the lawsuit, it states, “Defendant, Billy Woods, as Sheriff of Marion County,

Florida is in continual violation of Plaintiff’s constitutional right against cruel and
unusual punishment.” It goes on to say, “An outbreak of the novel coronavirus is
imminent or already occurring at the Marion County Jail, where inmates are
confined in conditions that threaten their lives.”
As an inmate in the Marion County Jail, the Plaintiff, Mr. Payton is being
subjected to the following treatment by the Defendant:
a. Mr. Payton does not have a safe way to dry his hands;
b. Mr. Payton must sleep within three feet of other inmates;
c. High touch surfaces within the jail pod are sanitized once or twice a day;
d. Mr. Payton and other inmates in his pod have not been provided masks;
e. Temperature checks are not being performed; and
f. Social distance is not being observed/enforced.
“Mr. Payton is forced to suffer conditions that deny him the precautions and
protections necessary to mitigate the severe threat of COVID-19. This constitutes
cruel and
unusual punishment forbidden by the state constitution,” the lawsuit states.
The lawsuit comes after more than two dozen inmates and nearly a dozen staff
members reportedly tested positive for COVID-19.
In fact, the lawsuit states, “On June 22, 2020, Mr. Payton’s attorney received an
e-mail authored by Timothy T. McCourt, general counsel for the Marion County
Sheriff’s Office. This e-mail advised that one jail staff member tested positive for
COVID-19 and had been sent home, and eight (8) inmates were exhibiting virus-
like symptoms
and were being quarantined for safety.”
However, just days later, the Star-Banner published that 44 inmates and 10 staff
members were positive for the COVID-19 virus.
Another inmate, who has not been named in the lawsuit, had been feeling sick
and was tested. However, that inmate, despite showing symptoms, was not
permitted to see a doctor. Essentially, that inmate tested positive for COVID-19.
Not only have inmates filed complaints, but some of Woods’ own staff have come
forward via e-mail, corroborating what inmates have been saying since Woods
took over the jail.
And, like the Star-Banner, Ocala Post has received e-mails in regards to the
complaints. Several of the e-mails came from MCSO employees who requested to
remain anonymous.
“Woods does not like to be questioned as witnessed by the public and the media
in multiple videos. You cannot question his authority or you will pay the price,” one
employee wrote. Adding, “If only people knew what the sheriff intentionally hides
from the public.”
Another employee, wrote, “Most staff does exactly what he tells them to do no
matter how wrong or unethical. It is shameful because one of the deputies who is
forced to speak the sheriff’s words is a soft-spoken good man. Billy does not
uphold his sworn oath…he is about as transparent with the public as stained
glass. He honestly believes the town belongs to him”
Woods has a history of not being transparent and failing to answer public records
requests, as can be proven by a number of e-mails.
A jail staff member, wrote, “Medical treatment is nonexistent here. Inmates

practically have to beg. No sanitizer, nothing. The virus will spread like wildfire and
it will eventually claim a life if this is not taken more seriously by the sheriff.
Instead of trying to get Facebook likes, he should be worried about human life
and stop referring to people as scumbags, dirtbags, cry babies, etc.”
In the footnotes of the lawsuit, it states, “Mr. Payton’s life is in danger due to the
outbreak of COVID-19 in the Marion County Jail. The failure of the trial court to
timely enter a final order should not preclude Mr. Payton from proceeding with this
writ of habeas corpus.
Mr. Payton’s attorney was contacted by the trial court on the morning of June 26th
to see if all parties were available for a VOP trial in mid to late July 2020. That
same morning, the Plaintiff advised the court he needed time to check with his
witnesses’ availability. Unfortunately, Mr. Payton was not given an opportunity to
do this and a VOP trial was unilaterally set on June 26, 2020.”
The lawsuit also states, “Mr. Payton is a 74-year-old combat veteran who was
exposed to agent orange in Vietnam. This has caused him to develop many
serious health conditions, to include chronic kidney disease, obstructive sleep
apnea, diabetic neuropathy, chronic lung disease, and colon cancer.”
The jail is aware of Payton’s serious medical conditions.
According to the CDC guidelines, as noted in the lawsuit, Payton’s medical

conditions absolutely put him at greater risk for death if he were to contract
COVID-19.
In addition to the lawsuit filed against Woods, a motion has been filed with the
court to recuse or disqualify Judge Anthony Tatti because of prejudice or bias in
the case, which the lawsuit states would prevent Payton from receiving a fair trial.
The lawsuit states that Judge Tatti, without proper reason or legal explanation,
has denied a petition for Payton’s bail three times.
Currently, there are dozens of inmates being held for misdemeanor violations.
Charges range from Open Container, Misdemeanor Possession of Marijuana (a
charged that has been decriminalized in numerous counties), Driving While License
Suspended, and numerous more.
In a letter, Woods wrote, “The people who are in jail are all in jail for a reason.
Everyone’s reason is unique,
COVID-19 SURVEILLANCE but whatCOVID-19
DASHBOARD they all UPDATES
have in common
FRONT is that there
PAGE MOREisa 
court order of some kind requiring them to be there –to serve a sentence, to be
held until bond is posted, to be held without bail until trial, or to be held until
unpaid child-support is paid.”
COVID-19 has caused hardships for many, even law-abiding citizens who, at no
fault of their own, might have fallen behind on child support. A reasonable person
could conclude that it could happen to anyone and [that] does not make any
particular person a dangerous or hardened criminal.
In dozens of previous cases, attorneys have also said that holding a person for
misdemeanor possession of marijuana is laughable.
According to hundreds who have turned to social media, the public and other
watchdog groups have made it clear that they are not asking for violent criminals
to be released, but that is how the sheriff made it seem in his letter.
In regard to being held without bond, the lawsuit states:
Habeas corpus is the proper remedy to challenge incarceration due to denial of

a request for bond. Seymour v. State, 132 So.3d 300, 303 (Fla. 4th DCA 2014).
COVID-19 Presents a Lethal Threat of Harm to Plaintiff in Violation of

Article I, Section 17 of the Florida Constitution
The Florida Constitution states that “cruel and unusual punishment” is

forbidden.
The lawsuit states that Payton agreed to wear an ankle monitor if a bond was
granted and the court is aware of that fact.
Many have said it is not about getting out of jail…it’s about proper healthcare for a
74-year-old man.
In the justice system, one is supposed to be presumed innocent until proven

guilty. However, in Marion County, most have long felt that it has been the
opposite.
Page 1 of 2
Neil Gillespie

To: "Neil Gillespie" <neilgillespie@mfi.net>; "Patricia Jean Duffy" <duffylaw@gmail.com>
Cc: <bking@sao5.org>; <jgainey@sao5.org>; <asmith@sao5.org>; <Eservicemarion@Sao5.Org>;
"Israel, Jonathon" <jisrael@floridabar.org>; "Courtemanche, Richard"
<RCourtemanche@floridabar.org>
Sent: Friday, July 17, 2020 3:42 AM
Subject: Re: The Florida Bar LRS Referral for COVID-19 legal issue
Patricia Duffy, Attorney at Law

855 E University Ave
Gainesville, FL 32601-5508 14
duffylaw@gmail.com
RE: The Florida Bar LRS Referral for COVID-19 legal issue
Ms. Duffy,
I am not showing a response from you, so I am referring this matter to the Office of the State Attorney
for the Fifth Judicial Circuit, and The Florida Bar.
Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Tel. 352-854-7807

To: Patricia Jean Duffy
Cc: Neil Gillespie
Subject: The Florida Bar LRS Referral for COVID-19 legal issue
Patricia Duffy, Attorney at Law

855 E University Ave
Gainesville, FL 32601-5508
duffylaw@gmail.com
Ms. Duffy,
The Florida Bar LRS refereed me to you. I am a person age 64 with type 2 diabetes and have followed
COVID-19 orders to protect my health since I am in a high risk group. Recently a person age 35 lived
in my home and was openly critical of COVID-19 orders calling the pandemic a hoax. This person
never wears a mask, and travels in and around Marion County just as she did before COVID-19. This
person brought at least three strangers to my home in May 2020 to have sex and/or do drugs. The
person age 35 was a squatter in my home with no lease, and is not a relative, and not in a romantic
7/26/2020
Page 2 of 2
relationship with me. The person vacated my home on May 16, 2020. I have an Unlawful Detainer
complaint filed in Marion County, Case 2020-CA-934. What legal protections do I have to protect
myself from the behavior of this person who violated Governor Ron DeSantis’ COVID-19 Executive
Orders? The local police, the Marion County Sheriff’s Office, does not take the COVID-19 threat
seriously and has ignored my request for assistance. Thank you.
Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Tel. 352-854-7807
7/26/2020
Page 1 of 3
Neil Gillespie
From: "P.Bobby Rumalla, P.A." <PBRLAW@EMBARQMAIL.COM>

To: "'Neil Gillespie'" <neilgillespie@mfi.net>
Subject: RE: [The Florida Bar LRS] Introductions for Neil Gillespie and Pravesh Rumalla
I returned your call but did not receive a reply.

From: Neil Gillespie [mailto:neilgillespie@mfi.net]
To: Neil Gillespie; pbrlaw@embarqmail.com
Cc: bking@sao5.org; jgainey@sao5.org; asmith@sao5.org; Eservicemarion@Sao5.Org; Israel, Jonathon;
Courtemanche, Richard
Subject: Re: [The Florida Bar LRS] Introductions for Neil Gillespie and Pravesh Rumalla
Pravesh Bobby Rumalla, Esq.

2537 SE 17th St
Ocala, FL 34471-5522
Office: 352-369-1777
Cell: 352-369-1777
15
Fax: 352-622-2166
Email: pbrlaw@embarqmail.co
Mr. Rumalla:
I am not showing a response from you, so I am referring this matter to the Office of the State Attorney for
the Fifth Judicial Circuit, and The Florida Bar.
Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Tel. 352-854-7807
To: pbrlaw@embarqmail.com
Cc: Neil Gillespie
Subject: Re: [The Florida Bar LRS] Introductions for Neil Gillespie and Pravesh Rumalla
Pravesh Bobby Rumalla, Esq.

2537 SE 17th St
Ocala, FL 34471-5522
Office: 352-369-1777
Cell: 352-369-1777
7/26/2020
Page 2 of 3
Fax: 352-622-2166
Email: pbrlaw@embarqmail.co
Mr. Rumalla:
The Florida Bar LRS refereed me to you. I am a person age 64 with type 2 diabetes and have followed
COVID-19 orders to protect my health since I am in a high risk group. Recently a person age 35 lived in
my home and was openly critical of COVID-19 orders calling the pandemic a hoax. This person never
wears a mask, and travels in and around Marion County just as she did before COVID-19. This person
brought at least three strangers to my home in May 2020 to have sex and/or do drugs. The person age 35
was a squatter in my home with no lease, and is not a relative, and not in a romantic relationship with me.
The person vacated my home on May 16, 2020, but returned on June 7, 2020 under the guise of removing
her personal property in the garage, but then tried to establish residency during a home invasion where I
was arrested. I have an Unlawful Detainer complaint filed in Marion County, Case 2020-CA-934 and am in
the process of getting it served. What legal protections would I have to protect myself from the behavior of
this person who violated Governor Ron DeSantis’ COVID-19 Executive Orders? The local police, the
Marion County Sheriff’s Office, does not take the COVID-19 threat seriously and has ignored or dismissed
my request for assistance. Thank you.
Sincerely,
/s/
Neil J. Gillespie
8092 SW 115th Loop
Tel. 352-854-7807
From: Legal.io
To: neilgillespie@mfi.net
Subject: [The Florida Bar LRS] Introductions for Neil Gillespie and Pravesh Rumalla
New match: introducing Neil Gillespie to Pravesh Rumalla Pravesh Rumalla, Esq..
Dear Neil,
7/26/2020
Page 3 of 3
You've been matched with Pravesh Rumalla. Please get in contact with Pravesh to
schedule a consultation.
Pravesh Rumalla
Pravesh Rumalla, Esq. · Ocala Florida
Email: pbrlaw@embarqmail.com
Phone: (352) 369-1777
Here are some next steps:
1. Schedule a consultation to discuss this request.
2. Determine whether and, if so, how Pravesh can help.
3. If appropriate, agree on engagement terms and next steps.
This introduction does not create or constitute an attorney-client relationship with Pravesh
Rumalla or The Florida Bar Lawyer Referral Service.
Request Details
COVID-19 threat
Powered by Legal.io | Need help? Get in touch by replying to this email.
7/26/2020
7/13/2020 More Ocala jail inmates test positive for COVID-19 - News - Ocala.com - Ocala, FL
More Ocala jail inmates test

positive for COVID-19
By Austin L. Miller 16
@almillerosb
Posted Jul 10, 2020 at 4:12 PM
The number has gone from 44 to 49 to the current

74. Fifteen jail workers also have tested positive.
The number of inmates at the Marion County Jail who have tested
positive for COVID-19 has increased significantly within the past week,
and the figure could rise as officials receive more test results.
While testifying during a bail modification hearing on Friday,

Dr.Tabitha Downey told the court that as of Thursday, 74 inmates has
tested positive for COVID-19. She said results are pending for 150 more
inmates.
Earlier this week, the number was 49. Last week, it was 44.
In addition, 15 jail workers have tested positive. That number also is on

the rise.
The doctor’s testimony came during a hearing concerning inmate

Dominique Owens, who has tested positive for COVID-19. Owens, who
is awaiting trial and accused of several violent felonies, sought,
unsuccessfully, to have his bail reduced from $85,000.
https://www.ocala.com/news/20200710/more-ocala-jail-inmates-test-positive-for-covid-19?utm_source=SFMC&utm_medium=email&utm_campaign=GHM_Daily… 1/4
Owens had been housed in A Pod, a maximum security wing that houses
the most dangerous and violent offenders, according to the Marion
County Sheriff’s Office, which operates the jail. It appears the virus was
first detected in A Pod.
Downey, a chief medical officer for Heart of Florida, the agency that
provides healthcare for jail inmates, said Owens and others who have
contracted the deadly disease are isolated from other people at the jail.
She said the infected inmates, who are in D Pod, are being treated twice
a day by nurses who wear protective clothing and masks.
With limited available space, the infected group is segregated to one

area, which is recommended by the Centers for Disease Control and
Prevention, according to the doctor.
Downey said medical staff is equipped to provide care for the infected
inmates. If for any reason any patient needs additional treatment, that
inmate would be transported to AdventHealth Ocala or Ocala Regional
Medical Center.
As for Owens specifically: Downey said sometimes the 33-year-old man,

who has been at the jail since Nov. 14, 2018 and was diagnosed with
COVID-19 late last month, has refused treatment. The doctor said
medical staff is aware that Owens has asthma.
Downey said the treatment refusals are concerning. She said medical
personnel has talked with everyone in D Pod about the importance of
being checked twice a day.
Aside from having asthma, which Downey said is being monitored,

Owens is bipolar and experiences depression and anxiety. H has been
given medicine as appropriate. She said Owens sometimes refuses to
take his medications.
Owens’ lawyer, Yvens Pierre-Antoine of Gainesville, is one of the

founders of the Florida Justice Group. During the hearing, the lawyer
asked if inmates with COVID-19 should be housed together. Downey
told the attorney it’s not ideal; however, the jail is abiding by CDC
guidelines.
Downey said so far inmates in D Pod has shown any signs of failing
health. She said those with COVID-19 have been staying in D Pod since
late June.
Pierre-Antoine told the court if his client should be released, pending

resolution of his criminal case, he would live with his aunt, who is a
licensed counselor. He said Owens has no history of absconding and
would agree to an electronic monitoring device.
The lawyer said Owens’ asthma condition is a concern for Owens’ family,
and argued the best thing to do is to allow his to be released so he can
receive proper healthcare.
Assistant State Attorney Lori Cotton said jail officials are keeping the jail
clean and properly caring for the infected population. She said the court
should not ignore Owens’ criminal history, which includes time in
prison.
State records show Owens was released in early 2017 after serving time
for drug possession.
Circuit Judge Anthony Tatti asked Downey if she knew D Pod’s capacity
and whether inmates were housed one or two to a cell. She did not
know the answer to either question. She assured the judge that those
who has COVID-19 are separate from healthy inmates.
After hearing both sides, Tatti said he believes Owens’ bond ($85,000) is
reasonable and that the inmate is being treated properly at the jail. The
judge said he was concerned about Owens refusing treatment.
Although he denied the motion, Tatti told Pierre-Antoine that if

Owens’ health situation changes, then he wants to hear about it.
Court documents show Owens was arrested on Nov. 13, 2018, on a

charge of aggravated domestic battery with a firearm, two counts of
aggravated assault with a deadly weapon and possession of a firearm by a
convicted felon.
Marion County Sheriff’s Office deputies were called to a residence on

Oct. 30, 2018, where Owens reportedly broke into the home and held a
man at gunpoint. He also threatened to kill the man.
While there, Owens choked and put a gun at the head of a woman. He
hit her in the head with the gun, and repeatedly punched her in the
head, according to what deputies were told. Owens fled before deputies
arrived.
In another incident, on Oct. 29, 2018, the woman who was assaulted by
Owens on Oct. 30, told deputies that Owens slapped her face, choked
and bit her forehead. Owens was charged with domestic battery by
strangulation and battery, second offense.
In Owens’ arrest report, it states he was adjudicated guilty in 2011 for

aggravated battery with a deadly weapon.
In the motion for bond reduction, Pierre-Antoine noted that the

victims in each case said they want to drop the charges and that they are
not afraid of Owens.
Contact Austin L. Miller at 867-4118, austin.miller@starbanner.com or

@almillerosb

COVID-19 Complaint To Dept of Health Re Marion County Florida

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COVID-19 Complaint To Dept of Health Re Marion County Florida

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Dr. Scott A.

Rivkees July 26, 2020

1. Timothy McCourt and the Marion County Sheriff’s Office (MCSO)

The Department of Health declared coronavirus is a disease or condition to be reported, see

My email to McCourt appears at Exhibit 1 and states in relevant part:

RE: COVID-19 protections and Sarah Thompson

Yes, she does.

Zachary Glenn Phipps

"Hillsborough County Sheriff Chad Chronister said Rodney Howard-Browne,

RE: COVID-19 Cases

1. Inmates incarcerated at the Marion County Jail

Sgt. Paul Bloom

1. Inmates incarcerated at the Marion County Jail

I have copied Mr. Phipps on this e-mail.

Mr. McCourt: I am not requesting records, I am preparing a complaint to the Department

Lawsuit filed against Marion County Sheriff, Billy Woods

• COVID-19 Presents a Lethal Threat of Harm to Plaintiff in Violation of Article I, Section 17

Criminal Prohibition Petition from Marion County (Court document available)

Lawsuit filed against Marion County Sheriff, Billy Woods

You can read the release here.

The lawsuit was filed on July 1. (Read the lawsuit here)

Woods is being accused of violating the Florida Constitution by allowing inmates

In the lawsuit, it states, “Defendant, Billy Woods, as Sheriff of Marion County,

protections necessary to mitigate the severe threat of COVID-19. This constitutes

A jail staff member, wrote, “Medical treatment is nonexistent here. Inmates

The jail is aware of Payton’s serious medical conditions.

In regard to being held without bond, the lawsuit states:

• Habeas corpus is the proper remedy to challenge incarceration due to denial of a

• The Florida Bar Lawyer Referral Service

Patricia Duffy, Attorney at Law Pravesh Bobby Rumalla, Esq.

• News Reports of COVID-19 in Florida and in Marion County.

COVID-19 Call Center available 24/7 | +1 (866) 779-6121 or email COVID-19@flhealth.gov

Florida Department of Health

Joint Information Center on COVID-19 for the State of Florida

High Risk Populations

From: "COVID-19" <COVID-19@flhealth.gov>

From: Neil Gillespie <neilgillespie@mfi.net>

From: "Neil Gillespie" <neilgillespie@mfi.net>

RE: COVID-19 protections and Sarah Thompson

From: "Neil Gillespie" <neilgillespie@mfi.net>

----- Original Message -----

Subject: RE: COVID-19 protections and Sarah Thompson

RE: COVID-19 protections and Sarah Thompson

(Witness signature) (owner phone number)

(witness printed name)

Billy Woods, Sheriff

8092 SW 115th Loop

DATED this 12th day of January, 2020.

From: "Neil Gillespie" <neilgillespie@mfi.net>

----- Original Message -----

Zachary Glenn Phipps

----- Original Message -----

RE: COVID-19 protections and Sarah Thompson

(Received from inmate by Officer Signature and 10 #) (Oaterrime)

(Response to inmate by Officer Signature and 10 #) (Daterrime)

White Copy - Classification once the response is compiled.

From: "Neil Gillespie" <neilgillespie@mfi.net>

In my view the BOCC ought to immediately close down the jail.

----- Original Message -----

To: Guy Minter ; Neil Gillespie

RE: MCSO and F.S. sec 215.322 Acceptance of credit cards

From: "Neil Gillespie" <neilgillespie@mfi.net>

RE: COVID-19 Cases