UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF FLORIDA

TAMPA DIVISION
RANDALL TOWNSEND,
)
Individual,
)
AND AS NEXT FRIEND AND )
PATERNAL PARENT OF MINOR )
SON, J.D.T.
)
AND AS NEXT FRIEND AND )
PATERNAL PARENT OF MINOR )
DAUGHTER, J.G.T
)
AND AS A DIRECT MEMBER
)
OF THE FIRST BAPTIST
)
CHURCH OF CITRUS PARK AND )
AS NEXT FRIEND OF
)
ALL MINOR CHILDREN
)
OF THE CORPORATION
)
KNOWN AS FIRST BAPTIST
)
CHURCH OF CITRUS PARK
)
AND CITRUS PARK CHRISTIAN )
SCHOOL, INC.
)
Plaintiffs
)

CASE NO:_8:06-CV2050T-30-TGW
JURY TRIAL DEMANDED
REQUEST FOR INJUNCTIONS IN
COUNTSIII and XXX and XXI
and XXXXVI thru XXXXXI.
AND A WRIT OF PROHIBITION
IN COUNT ---XVI.

)
v.

)
)
RONALD L. BECK,
)
(a.k.a. Ron Beck) INDIVIDUALLY, )
REVERAND RONALD L. BECK, )
AS SENIOR PASTOR, OF
)
FIRST BAPTIST CHURCH OF
)
CITRUS PARK,
)
(Hereinafter as FBCCP),
)
ET. AL. AND NOW As per all as
DEFENDANTS Listed Below herein,

AMENDED FEDERAL COMPLAINT

AS FOR CASES CONSOLIDATED AND REMOVED FROM EITHER:
IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
SECOND DISTRICT,
AND
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT,
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
AS STATED BELOW

CIRCUIT CASE NO: 02-03812

RANDALL TOWNSEND,
Individual,
DIVISION: K
AND AS NEXT FRIEND AND
PATERNAL PARENT OF MINOR SON, J.D.T.
AND AS NEXT FRIEND AND
PATERNAL PARENT OF MINOR DAUGHTER, J.G.T
Plaintiffs, or as Appellants
V.
RONALD L. BECK, (a.k.a. Ron Beck) INDIVIDUALLY,
REVERAND RONALD L. BECK, AS SENIOR PASTOR, OF FIRST BAPTIST
CHURCH OF CITRUS PARK, (Hereinafter as FBCCP)
WILLIAM T. BROWN, (a.k.a. Bill Brown), INDIVIDUALLY,
REVERAND WILLIAM T. BROWN, OF FBCCP AS PASTOR OF EDUCATION
AND ADMINISTRATION;
HERMAN MEISTER, INDIVIDUALLY,
REVERAND HERMAN MEISTER, AS PASTOR OF SCHOOL MINISTRIES, OF
FBCCP;
GARY LEATHERMAN, INDIVIDUALLY,
GARY LEATHERMAN, AS TRUSTEE(1997-2005) AND
GARY LEATHERMAN AS MEMBER OF FINANCE COMMITTEE OF FBCCP AND
GARY LEATHERMAN AS MEMBER OF PERSONNEL COMMITTEE, OF FBCCP;
ROBERT GILES, INDIVIDUALLY,
ROBERT GILES, AS MEMBER OF PERSONNEL COMMITTEE, OF FBCCP;
TIM JEFFERS, INDIVIDUALLY,
TIM JEFFERS, AS FINANCE COMMITTEE MEMBER OF FBCCP
TIM JEFFERS, AS FBCCP DEACON
MARK NUNES, INDIVIDUALLY,
MARK NUNES, AS CHAIRMAN OF DEACONS, 1999-2000, OF FBCCP;
MIKE SHUMATE, INDIVIDUALLY,
MIKE SHUMANTE, AS CHAIRMAN OF DEACONS, 2000-2001, OF FBCCP;
JOE HOWLETT, INDIVIDUALLY,
JOE HOWLETT, AS TRUSTEE,(1995-present) OF FBCCP;
GEOFF SMITH, INDIVIDUALLY,
GEOFF SMITH, AS CORPORATION PRESIDENT, AS TRUSTEE (at all times),
GEOFF SMITH AS DEACON OF FBCCP;
DR. LON LYNN, INDIVIDUALLY,
DR. LON LYNN, AS A PROFESSIONAL MEDICAL DOCTOR,
THE SELECT MEMBERS OF THE CORPORATION d/b/a,
FIRST BAPTIST CHURCH OF CITRUS PARK, and CITRUS PARK
CHRISTIAN SCHOOL, (CPCS), A MINISTRY OF FBCCP,
CITRUS PARK CHRISTIAN SCHOOL, A MINISTRY OF FBCCP
___________________________________________________________________
INDEPENDENT ACTION COMPLAINT PER Fla. R. Civ. P. 1.540
DEFENDANTS

CHARLES H. SCRUGGS III.,

CIRCUIT CASE NO. 05-0911
Individually,
DIVISION G
CHARLES H. SCRUGGS, III. ESQUIRE,
APPEALS CASE:2D06-2811
As attorney at law
CHARLES H. SCRUGGS, III, P.A., A Professional Association Law Firm
INDEPENDENT ACTION COMPLAINT PER Fla. R. Civ. P. 1.540
DEFENDANTS
HEATHER M. GRAY, Individually,
CASE NO: 06-6005
HEATHER M. GRAY, ATTORNEY AT LAW,
HEATHER M. GRAY, PROFESSIONAL ASSOCIATION AS A FLORIDA
CORPORATION,
INDEPENDENT ACTION COMPLAINT PER Fla. R. Civ. P. 1.540
DEFENDANTS
KAREN HARROD TOWNSEND, Individually, CASE NO 05-9605 Civil and
02-4974, Family Court
and
APPEALS CASE: 2D06-3469
STEVEN TYLER HARROD, Individually,
DONALD HARROD, Individually,
NORMA HARROD, Individually,
SUPPLEMENTAL AND AMENDED PLEADINGS
FILED HEREIN PER
Fla. R. Civ. P. 1.540 and 1.570 and 1.190
BASED ON NEWLY DISCOVERED EVIDENCE
AND THEREBY
ADDING OR REINSTATING OF DEFENDANTS AND CLAIMS
RON BECK, AS PASTOR /MEMBER OF FBCCP AS OF CPCS SCHOOL BOARD,
HERMAN MEISTER AS CPCS SCHOOL BOARD MEMBER,
KAREN HARROD TOWNSEND AS
EMPLOYEE OF CITRUS PARK CHRISTIAN SCHOOL, (CPCS)
A MINISTRY OF THE FBCCP
ROBERT GILES AS MEMBER OF THE CPCS SCHOOL BOARD,
PAULA POWELL, Individually, PAULA POWELL AS FBCCP FINANCIAL
SECRETARY EMPLOYEE, PAULA POWELL AS CPCS SCHOOL BOARD
MEMBER,
TIM JEFFERS, AS FBCCP TRUSTEE (2005-present)
CARL (BUDDY) RAWLS, Individually, CARL(BUDDY) RAWLS, AS MEMBER OF
THE LONG RANGE PLANNING COMMITTEE FBCCP,
DUANE MILFORD, Individually,
DUANE MILFORD AS LONG RANGE PLANNING COMMITTEE MEMBER
OF FBCCP,
3

KAREN JEFFERS, Individually,

KAREN JEFFERS AS EMPLOYEE AS PRINCIPLE OF CPCS,
GAYLE LYNN, Individually,
GAYLE LYNN, AS EMPLOYEE AS DEAN OF STUDENTS CPCS,
APRIL BECK, Individually,
APRIL BECK, AS EMPLOYEE OF CPCS
APRIL BECK, AS MEMBER OF FBCCP
JIM LEAHY, Individually,
JIM LEAHY AS PERSONNEL COMMITTEE CHAIRMAN OF FBCCP,
JOE KAREAS, Individually,
MICHAEL JOHN CORBIN, Individually,
MICHAEL JOHN CORBIN AS MEMBER OF THE LONG RANGE PLANNING
COMMITTEE FBCCP,
MICHAEL JOHN CORBIN, AS PASCO COUNTY SHERIFF DEPUTY DETECTIVE,
JOYCE MEISTER, Individually,
JOYCE MEISTER, AS EMPLOYEE OF CPCS
JACKIE HOWLETT, Individually,
JACKIE HOWLETT AS CPCS SCHOOL BOARD MEMBER,
JACKIE HOWLETT AS MEMBER OF THE LONG RANGE PLANNING
COMMITTEE FBCCP,
JOE HOWLETT AS HILLSBOROUGH COUNTY SHERIFF DEPUTY,
MIKE SMOAK, AS Individually,
MIKE SMOAK AS CPCS SCHOOL BOARD MEMBER,
MIKE SHAR, Individually,
JOHN A. GRANT, JR. Individually,
JOHN A. GRANT, JR. AS REGISTERED AGENT OF First Baptist Church of Citrus
Park CORPORATION,
UTICA INSURANCE COMPANY OF NEW YORK,
CHARLES DENNY, IV, Individually,
CHARLES DENNY, IV, AS ATTORNEY AT
LAW FOR THE FIRM OF DICKINSON & GIBBONS P.A.,
THE LAW FIRM OF DICKINSON & GIBBONS, P.A. ATTORNEYS AT LAW,
JAMES ROLFES, Individual,
A. JAMES ROLFES, AS ATTORNEY AT LAW,
A. JAMES ROLFES, AS ATTORNEY OF THE LAW FIRM OF DICKINSON &
GIBBONS, P.A. ATTORNEYS AT LAW,
DREW GARDNER, AS Individual,
DREW GARDNER AS ATTORNEY AT LAW FOR THE CHRISTIAN LAW
ASSOCIATION
THE CHRISTIAN LAW ASSOCIATION, A FLORIDA CORPORATION
DAVID GIBBS, III, Individual,
DAVID GIBBS, III, AS ATTORNEY AT LAW, GIBBS LAW FIRM. P.A.
DAVID GIBBS, III AS ATTORNEY AT LAW, OF THE CHRISTIAN LAW
ASSOCIATION
STACEY TURMEL, Individually,
STACEY TURMEL AS ATTORNEY AT LAW, OF STACEY TURMEL, P.A.,

THE LAW FIRM OF STACEY TURMEL, P.A.

THE OFFICE OF THE GOVERNOR OF THE STATE OF FLORIDA UNDER THE
CARE AND SUPERVISION OF JEB BUSH AND CHARLIE CRIST,
MR. CHARLIE CRIST, Individually,
MR. CHARLIE CRIST, AS IN THE OFFICIAL POSITION AS THE ATTORNEY
GENERAL FOR THE STATE OF FLORIDA,
THE OFFICE/DEPARTMENT OF THE ATTORNEY GENERAL FOR THE STATE
OF FLORIDA
Mr. TOM GALLAGHER, Individually,
MR. TOM GALLAGHER, AS IN THE OFFICIAL POSITION AS THE CHIEF
FINANCIAL OFFICER OF THE STATE OF FLORIDA DEPARTMENT OF
FINANCIAL SERVICES, and
THE DEPARTMENT OF FINANCIAL SERVICES,
THE DEPARTMENT OF CHILDREN AND FAMILIES OF THE STATE OF
FLORIDA,
DAVID GEE, AS SHERIFF OF HILLSBOROUGH COUNTY FLORIDA, and
DEPUTY SHERIFF JOE HOWLETT AND
DEPUTY SHERIFF MIKE SMOAK AND
DEPUTY SHERIFF SCOTT WELLINGER, Individually,
SCOTT WELLINGER, AS A HILLSBOROUGH COUNTY SHERIFF DEPUTY
SERGEANT,
DEPUTY SHERIFF LUTHER CORE, Individually,
LUTHER CORE AS HILLSBOROUGH COUNTY SHERIFF DEPUTY DETECTIVE
EXECUTIVE SUPPORT DEPARTMENT INTERNAL AFFAIRS,
DEPUTY SHERIFF PAUL J. GUARINO, Individually,
PAUL J. GUARINO, AS HILLSBOROUGH COUNTY SHERIFF DEPUTY
SERGEANT PROPERTY CRIMES UNIT,
DEPUTY HARRY HOOVER, Individually,
HARRY HOOVER, AS HILLSBOROUGH COUNTY SHERIFF DEPUTY
SERGEANT FOR INTERNAL AFFAIRS,
JAMES (JIM) COATS, AS SHERIFF OF PINELLAS COUNTY FLORIDA,
DEPUTY SHERIFF JOSEPH A. GILLETTEE, SERGENT ADMINISTRATIVE
INVESTIGATIONS DIVISION PINELLAS COUNTY SHERIFF OFFICE
DEPUTY SHERIFF TIM JEFFERS,
THE PINELLAS COUNTY SHERIFFS OFFICE
BOB WHITE, AS SHERIFF OF PASCO COUNTY FLORIDA,
DEPUTY SHERIFF JOHN MICHEAL CORBIN OF PASCO COUNTY FLORIDA,
THE DEPARTMENT OF THE PASCO COUNTY SHERIFF,
THE CHIEF OF POLICE OF TAMPA, FLORIDA, and
POLICE OFFICER JOE KAREAS OF THE CITY OF TAMPA,
THE CITY OF TAMPA
CYNTHIA BARNARD SANZ, Individually,
CYNTHIA BARNARD SANZ AS
SPECIAL AGENT SUPERVISION FOR THE FLORIDA DEPARTMENT OF
LAW ENFORCEMENT,
MR. GUY TUNNELL, COMMISSIONER, FLORIDA DEPARTMENT OF LAW

ENFORCEMENT, NOW AS
MR. GERALD BAILEY COMMISSIONER, FLORIDA DEPARTMENT OF LAW
ENFORCEMENT,
THE FLORIDA DEPARTMENT OF LAW ENFORCEMENT
CURTIS BAUGHMAN, Individually,
NANCY LOPEZ, Individually,
CURTIS BAUGHMAN AND NANCY LOPEZ AS EMPLOYEES OF VICTIMS
ASSISTANCE OF THE STATE ATTORNEY OF FLORIDA,
THE DEPARTMENT OF VICTIMS ASSISTANCE
MARK A. OBER, Individually,
MARK A. OBER AS STATE ATTORNEY OF FLORIDA,
CHIEF JUDGE MANUEL MENENDEZ JR. OF HILLSBOROUGH COUNTY
FLORIDA CIRCUIT CIVIL COURTS,
MANUEL MENENDEZ JR. Individually,
WAYNE TIMMERMAN, Individually,
JUDGE WAYNE TIMMERMAN A CIRCUIT COURT JUDGE OF HILLSBOROUGH
COUNTY FLORIDA,
RAUL PALOMINO, Individually,
JUDGE RAUL PALOMINO, A CIRCUIT COURT JUDGE FOR HILLSBOROUGH
COUNTY FLORIDA,
FRANK GOMEZ, Individually,
JUDGE FRANK GOMEZ A CIRCUIT COURT JUDGE FOR HILLSBOROUGH
COUNTY FLORIDA,
MONICA SIERRA, Individually,
JUDGE MONICA SIERRA, A CIRCUIT COURT JUDGE FOR HILLSBOROUGH
COUNTY FLORIDA,
RALPH STODDARD, Individually,
JUDGE RALPH STODDARD, A CIRCUIT COURT JUDGE FOR HILLSBOROUGH
COUNTY FLORIDA,
GREG HOLDER, Individually,
JUDGE GREG HOLDER, A CIRCUIT COURT JUDGE FOR HILLSBOROUGH
COUNTY FLORIDA,
MARVA CRENSHAW, Individually,
JUDGE MARVA CRENSHAW, A CIRCUIT COURT JUDGE FOR HILLSBOROUGH
COUNTY FLORIDA,
RAQUEL A. RODRIQUEZ, Individually,
RAQUEL A. RODRIQUEZ AS GENERAL COUNSEL TO THE OFFICE OF THE
GOVERNOR OF THE STATE OF FLORIDA
BROOKE S. KENNERLY, Individually,
BROOKE S. KENNERLY AS EXECUTIVE DIRECTOR FOR THE JUDICIAL
QUALIFICATIONS COMMISSION OF THE STATE OF FLORIDA,
THE JUDICIAL QUALIFICATIONS COMMISSION OF THE STATE OF FLORIDA,
THE FLORIDA BAR,
THE FLORIDA BAR OFFICER OF EXECUTIVE DIRECTOR,
THE FLORIDA BAR OFFICER OF TAMPA BRANCH OFFICE
EXECUTIVE/DISCIPLINE DIRECTOR AS BRANCH STAFF COUNSEL,

THE FLORIDA BAR TAMPA INTAKE STAFF COUNSEL EMPLOYEE, MS. DOE
LIEMAN,
MS. DOE LIEMAN, Individually,
THE FLORIDA BAR TAMPA INTAKE STAFF EMPLOYEE MS. JANE CRISTY and
Ms. JANE CRISTY, Individually
THE STATE OF FLORIDA, and
THE SHERIFF OF SANTA ROSA COUNTY, AND
SANTA ROSA COUNTY, OF THE STATE OF FLORIDA
HILLSBOROUGH COUNTY FLORIDA, OF THE STATE OF FLORIDA
KMART CORPORATION also d.b.a. SEARS HOLDING COMPANY
JOE PALKO, Individual,
JOE PALKO, EMPLOYEE AS Vice President (Kmart) SEARS HOLDING COMPANY
RANDY BRIGHT, Individual,
RANDY BRIGHT, (Kmart) EMPLOYEE AS REGIONAL COACH,
KEITH JOHNSON, Individual,
KEITH JOHNSON, (Kmart) EMPLOYEE AS REGIONAL HUMAN RESOURCES
DIRECTOR,
SHANE PEARSON, Individual,
SHANE PEARSON, (Kmart) EMPLOYEE AS LOSS PREVENTION DISTRICT
COACH,
KATHERINE CUNNINGHAM, Individual,
KATHERINE CUNNINGHAM, (Kmart) EMPLOYEE AS DISTRICT
COORDINATOR SECRETARY
DANIEL J. GENTILE, Individual,
DANIEL J. GENTILE, (Kmart) EMPLOYEE AS DISTRICT COACH
DOUG LIVINGSTON, Individual,
DOUG LIVINGSTON, AS KMART EMPLOYEE LOSS PREVENTION COACH,
AT STORE 3092,
ROY ALLEN, Individual,
ROY ALLEN, KMART EMPLOYEE AS ASSISTANT COACH, AT STORE 3092,
DR. LINDA ROWE CAMPBELL, Individual,
DR. LINDA ROWE CAMPBELL, (Kmart) EMPLOYEE AS PHARMACIST AT
STORE 3092
BARBARA BOOTH, Individual,
BARBARA BOOTH, (Kmart) EMPLOYEE AT STORE 3092
THE FIRST BAPTIST CHURCH OF CITRUS PARK BOARD OF DEACONS OF
1999-2000-2001-2002-2003-2004-2005-2006
DON BECK, Individually,
DON BECK, AS DEACON,
JOHN COLLINSON, Individually,
JOHN COLLINSON, AS DEACON,
BILL CRAFT, Individually,
BILL CRAFT, AS DEACON,
ROBERT GILES, AS DEACON,
ED HOPKINS, Individually,
ED HOPKINS, AS DEACON,

JERRY MILLER, Individually,

JERRY MILLER, AS DEACON,
WILSON SMITH, Individually,
WILSON SMITH, AS DEACON
AS DEFENDANTS,
___________________________________________/
UNITED STATES FEDERAL MIDDLE DISTRICT COURT
AMENDED COMPLAINT
AND
DEMAND FOR JURY TRIAL
Plaintiffs, individually and on behalf of all others similarly situated, complain as
follows:
NATURE OF ACTION
COMES NOW PLAINTIFF RANDALL TOWNSEND, PRO SE, AND
ALWAYS AS A NEXT FRIEND AND PROTECTOR FOR THE FIRST BAPTIST
CHURCH OF CITRUS PARK BY-LAWS AND THE CHILDREN MEMBERS OF
THE CORPORATION AND OF HIS OWN CHILDREN SINCE 1994, OR BEFORE
WITHIN PLAINTIFF RANDALL TOWNSENDS (HEREINAFTER AS PLAINTIFF
TOWNSEND) DUTIFUL SERVICES AND STATES TO ALL PERSONS AND
AGENCIES AND OTHERS AS STATED AND ACKNOWLEDGED BY RON
BECK WHO IN WRITTEN RESPONSE ON SEPTEMBER 13, 1999, WROTE,
It hurts when a church member you think you have a decent relationship with
tells other brothers that he thinks the Pastor needs to resign because he isnt the
man of God for this church.
And this letter from Ron Beck(Beck) was follow up to Beck on August 11, 1999, telling
this Plaintiff Townsend to resign all duties because this Plaintiff confronted selfserving pastors with a list of misconduct as violations of the First Baptist Church of
Citrus Park Corporation (FBCCP) BY-LAWS(1993), of State, Federal and IRS Laws and

Randall Townsend acting dutifully per the Corporation BY-LAWS made allegations of
problems, fraudulent inducement and fraud and missing and misuse of Corporation funds,
interference with marital and family relationships and theft of Church Designated
Properties, caused by alleged pastors and others alleged as FBCCP Officers and Trustees.
AND PLAINTIFF TOWNSEND CONTINUES AS PROOF AND STATES HEREIN:
(A) TO STOP ABUSE ON THESE PLAINTIFFS BY ALLEGED CLERGY AND
TRUSTEES OF A CHURCH WHO FOR NOW DURING THIS OVER MANY
YEARS OF LITIGATION, CREATED, EXTENDED AND ALLOWED BY
FRAUDS OF JUDGES AND ATTORNEYS AND EACH DEFENDANT HEREIN
STILL WILLFULLY ALLOWING ALLEGED CLERGY AND TRUSTEES TO
FRAUD AND STEAL FROM A CHURCH AND TERRORIZE PLAINTIFF
FAMILY RIGHTS, CHURCH RIGHTS AND CIVIL RIGHTS OF PLAINTIFFS
EVEN AFTER BEING WARNED BY JUDGE PALOMINO ON NOVEMBER
15, 2001, NOT TO KEEP THIS HONORABLE FATHER FROM SEEING HIS
OWN VICTIMIZED CHILDREN NOW SINCE NOVEMBER 8, 2002, BY
THREATS AND FRAUDS AND FOR THOSE WHOM PLAINTIFF SPEAKS
AND ALL DEFENDANTS CONTINUE TO DO FRAUDS TO THE CHURCH
PLAINTIFFS AND TO MISUSE THE CIRCUIT COURTS, DOMESTIC
VIOLENCE COURT, FAMILY COURTS AND APPEALS COURTS AND
GOVERNMENT OFFICES AND POSITIONS AND
(B) TO CLARIFY PER THIS LAWSUIT GUIDELINES FOR ALL PERSONS IN THIS
STATE OF FLORIDA TO KNOWINGLY LEARN HOW TO OPERATE CIVILLY
WITH PERSONS OR GROUPS OF PERSONS ATTEMPTING TO ACT IN

VIOLATION OF RULES AND BY-LAWS CONTRACT OF A NOT FOR PROFIT

CORPORATION ALLEGING TO ACT UNDER FLORIDA STATUES 617, BUT
INSTEAD DO ODIOUS AND OUTRAGEOUS ILLEGAL CONDUCT ACTING
AS, WITH AND FOR BENEFIT OF CLERGY AS SHOWN HEREIN AND TO
CONCEAL EACH DEFENDANTS ILLEGAL CONDUCT BY GIVING BENEFIT
TO CLERGY AND DOING FRAUD AND VIOLATIONS OF OFFICIAL DUTY
(C) TO PUNISH VIOLATORS OF PLAINTIFFS, THE LAWS, CONTRACTS AND
(D) to make a claim against each individual as Defendant herein under Section 1983 of
TITLE 42 of the United States Code, which provides that any person who, under
apparent authority of state law, deprives another of any rights, privileges, or immunities
secured by the United States Constitution and the laws will be liable to the party injured.
[42 U.S.C.S. 1893], and under TITLE 18 of the United States Code, which states:
CHAPTER 13,
SECTION 241. Conspiracy against rights.
If two or more persons conspire to injure, oppress, threaten, or intimidate any
person in any State, Territory, Commonwealth, Possession, or District in the free exercise
or enjoyment of any right or privilege secured to him by the Constitution or laws of the
United States, or because of his having so exercised the same; or
If two or more persons go in disguise on the highway, or on the premises of
another, with intent to prevent or hinder his free exercise or enjoyment of any right or
privilege so secured- They shall be fined under this title or imprisoned not more than ten
years, or both; and if death results from the acts committed in violation of this section or
if such acts include kidnapping or an attempt to kidnap, they shall be fined under this
title or imprisoned for any term of years or for life, or both, or may be sentenced to
death.
SECTION 242. Deprivation of rights under color of law.
Whoever, under color of any law, statute, ordinance, regulation, or custom,
willfully subjects any person in any State, Territory, Commonwealth, Possession, or
District to the deprivation of any rights, privileges, or immunities secured or protected by
the Constitution or laws of the United States, or to different punishments, pains, or
penalties, on account of such person being an alien, or by reason of his color, or race,
than prescribed for the punishment of citizens, shall be fined under this title or
imprisoned not more than one year, or both; and if bodily injury results from the acts

10

committed in violation of this section or if such acts include the use, attempted use, or
threatened use of a dangerous weapon, explosives, or fire, shall be fined under this title or
imprisoned not more than ten years, or both; and if death results from the acts committed
in violation of this section or if such acts include kidnapping or an attempt to kidnap,
aggravated sexual abuse, or an attempt to commit aggravated sexual abuse, or an attempt
to kill, shall be fined under this title, or imprisoned for any term of years or for life, or
both, or may be sentenced to death.
SECTION 245. Federally protected activities. Stated herein in full.
SECTION 246. Deprivation of relief benefits.
Whoever directly or indirectly deprives, attempts to deprive, or threatens to
deprive any person of any employment, position, work, compensation, or other benefit
provided for or made possible in whole or in part by any Act of Congress appropriating
funds for work relief or relief purposes, on account of political affiliation, race, color,
sex, religion, or national origin, shall be fined under this title, or imprisoned not more
than one year or both.
SECTION 247. Damage to religious property; obstruction of persons in the free
exercise of religious beliefs.
(a) Whoever, in any of the circumstances referred to in subsection (b) of this
section- (2) intentionally obstructs, by force or threat of force, any person in the
enjoyment of that persons free exercise of religious beliefs, or attempts to do so; shall be
punished as provided in subsection (d).
CHAPTER 19,
Section 317. Conspiracy to commit offense or to defraud United States
If two or more persons conspire either to commit any offense against the United
States, or to defraud the United States, or any agency thereof in any manner or for any
purpose, and one or more of such persons do any act to effect the object of the
conspiracy, each shall be fined under this title or imprisoned not more than five years, or
both.
SECTION 373. Solicitation to commit a crime of violence.
(a) Whoever, with intent that another person engage in conduct constituting a
felony that has as an element the use, attempted use, or threatened use of
physical force against property or against the person of another in violation of
the laws of the United States, and under circumstances strongly corroborative
of that intent, solicits, commands, induces, or otherwise endeavors to persuade
such other person to engage in such conduct, shall be imprisoned or
fined; or if the crime solicited is punishable by life imprisonment or death,
shall be imprisoned for not more than twenty years.
(b) It is not a defense to a prosecution under this section that the person solicited
could not be convicted of the crime because he lacked the state of mind
required for its commission, because he was incompetent or irresponsible, or
because he is immune from prosecution or is not subject to prosecution.

11

and per the United States Constitution and the State Of Florida Constitution
stating, NO LAW SHALL IMPEDE THE OBLIGATION OF A CONTRACT and sues
each individual and or person, agent, agency, State of Florida Government Public
Entity, Judge, Attorney, Court Officer and or each Corporation as stated herein, pursuant
to Florida Statues 768.28(6), and Florida Statues 760 as the HUMAN RIGHTS ACT OF
1977 and Florida Statues 617, as each person, agency and Corporation violated Florida
Statues 775.03 and gave unlawful benefit to clergy and the fraud and omissions of
truthful disclosure of alleged clergy allowed alleged clergy with these Attorneys and
Judges and others now defendants do fraud and theft of and to the Florida Statues 617,
Not For Profit Corporation, and to these Plaintiffs Children as Minors as Plaintiff
Townsend alleges suffer from Stockholm Syndrome or the like and are not of the
mental, emotional and physical wellness to represent themselves due to the frauds of
Karen Harrod Townsend, Ron Beck, Herman Meister, Gary Leatherman, Joe Howlett,
Dr. Lon Lynn, Gayle Lynn and Doe as others including School Teachers, Youth
Pastors, Church members and employee and the maternal family members assisted by
illegal actions of attorneys, law enforcement and judges regulating and controlling their
environment and training and for whom Plaintiff Townsend still now for many years still
Speaks and makes the following statements in support of the claim:
GENERAL ALLEGATIONS
1.

This is now consolidated as a Federal Case Action because Circuit Court, Family
Court, Domestic Violence Court and Appeals Court Judges and alleged Law
Enforcement refuse to stop but even assist ongoing violations of law as alleged
herein by Plaintiff TOWNSEND, Pro Se:

12

(A) AS AN INDIVIDUAL, AND

(B) AS NEXT FRIEND AND PATERNAL PARENT OF MINOR SON, J.D.T. AND
(C) AS NEXT FRIEND AND PATERNAL PARENT OF MINOR DAUGHTER,
J.G.T, AND
(D) AS A DIRECT MEMBER of the First Baptist Church of Citrus Park, (FBCCP)
Acting as legally elected as Directly, Indirectly and Derivatively AND
(E) AS NEXT FRIEND FOR AND OF ALL THE MINOR CHILDREN of the
FBCCP/CITRUS PARK CHRISTIAN SCHOOL (CPCS), past, present and future
(F) And as a voting Citizen of Florida continuing to hear political speeches, campaign
advertisements and promises of what elected Government officials have done or will do
and then as Required by their promise or duty as stated herein find these Officials ignore
PLAINTIFF RANDALL TOWNSEND (Plaintiff Townsend) as he has been acting since
1995, to enforce contracts and stop abuse, injury, intimidation, fraud, omission of truthful
disclosure and threats to all Children Plaintiffs for who Plaintiff Townsend now speaks
as victims by ALL Defendants against Plaintiff Townsend as Plaintiffs leader and as a
whistle blower to illegal, unethical and contractual BY-LAWS violations against all
Plaintiffs, and ESPECIALLY THE CHILDREN, by first the collusion of the First Baptist
Church of Citrus Park, and Citrus Park Christian School Corporation Pastors, (BECK,
BROWN, NASWORTHY and MEISTER) as just in 2006, fully revealed and confirmed
by the June/July 2006, Partial Production of Corporation Records demanded in 1999, and
or before, and by court rulings and against now all defendants who knowingly, willingly,
intentionally and negligently violate laws, contracts, legal duties and even their own
alleged ethical, lawful, religious teachings but violating rights of others while at times

13

relevant herein plaintiffs are: (1) citizens of Hillsborough and or surrounding Counties,
of the State of Florida, of these United States of America; (2) and Plaintiff Townsend is
as still a loving and legally acting and protecting parent as of a normal father/child
relationship; (3) protector of the Church and School Children prior, to the intentional
frauds and omissions of truthful disclosure of alleged schism pastors and trustees
now in conspiracy with Thirteenth Circuit Court Judge(s) of Hillsborough County and
attorneys and all other Defendants who knowingly, intentionally, willfully, recklessly and
negligent conspiracy up and through 09/07/06, and beyond by Attorney Denny still
by fraud and violations of legal procedures of the duty of an attorney as acting to conceal
truthful legal DUTY and accurate FBCCP Church and CPCS School Documents from
this dutiful Plaintiff member and other general voting members and with collusion by
Judge Crenshaw to limit the right of Plaintiff to expose and sue all joint tortfeasors who
still threaten and abuse and conduct fraud to conceal ongoing frauds of Clergy as
Beck, Karen Harrod, Meister, Leatherman, Jeffers, Smith, Howlett and others against this
Plaintiff Father as Judge Palomino recognized and admitted in open trial on November
15, 2001, in Case NO: 01-15814, Karen Townsend v. Randall Townsend, Domestic
Violence Division, addressing Attorney Charles Scruggs, III, Curtis Baughman, Karen
Townsend and Randall Townsend stating:
I have a feeling that from what Ive heard here today and just from what Ive
seen and observed that Mr. Townsend is probably going to testify that you dont allow
him to see his children, and this is the only opportunity that he has to see his children.
as these and other Defendants, by under oath confession, stated acts of fraud, extortion,
battery and omissions of truthful disclosure in the trials of Ron Beck v. Randy Townsend
Case NO 01-15813, and Karen Townsend v. Randy Townsend, Case NO 01-15814,

14

against Plaintiff Townsend as a Respondent and these defendants all who still conspire,
damage and even on February 16, 2007, mail a threatening, abusive letter as received
from Attorney former Judge, Charles Scruggs III, to Plaintiff, this former client stating:
You poor crazy sick individual! I received your 40 page Motion and as usual,
I cant make anything out of it any better than the Judges, lawyers, public officials,
pastors and church members that youve included in your Rambling Rubbish. I suggest
that you get down on your knees and pray to our Heavenly Father that he take the heavy
burden off your sholders and give you His peace. The plethora of goo which you spout
has seperated you from reality. As the young People would tell you Get a life! This
litigation is consuming you (not to mention the forrest of trees you are destroying in your
consumption of (coffee-strike) copy paper. Dont you have anything meaningful going
on in your life? It used to be God but in weeding through your written gibberish you
write in you legal papers, it would appear youve lost sight of the cross of Christ.
Let not your heart be troubled Unless youve already gone over the edge, I fear that
you are teetering on the brink of insanity. The whole world is against youright? Do
you honestly believe that any of these people (that youve sued) gives a tinkers damn
about you? Well I do, because (whether you know it or not, you are a brother in Christ
and a Child of God and you matter. May our Lord Clear your mind of the abundance of
Cobwebs therein and give you peace.
and doing acts against the Canons, Lawyer/Client Contracts and legal Ethical rules and
showing now still his animosity, concealment of his personal convictions and frauds
but still being concealed, protected and not allowing Plaintiffs to protect and preserve and
present their rights as Scruggs and pastors and Schism members and others as
Defendants herein ignored the letters even written by the Townsend Children stated
Herein : October 20, 1999
Dad,
Please dont be mad at us! I dont know what other option I/we have. Its
not fair just not 2 C mome either! N- ways well C U soon + well give U a
call later! OK? Take Care of Peaches, Whisper (family cats) + Shaddow
(family dog). Jason needs U 2 set up his bunk-bed in his room, If not well
get it later + set up the dinette set in the kitchen too!
- U ~ C-U Soon
- Jen
and the October 20, 2001, letter of the son, J.D.T trying to regain a relationship by:

15

but continually being harassed by the mother, the maternal family and the Schism and
THIS LETTER OF J.D.T from away at Bible College but sent to this father 10/20/01,
JUST 10 DAYS LATER October 31, 2001RON BECK AND KAREN HARROD
INTENTIONALLY PLACED WORD OF LIFE ON THE AFFIDAVIT FOR
PROTECTIVE ORDER AND GAINED AN INJUNCTION WHICH PREVENTED
THIS FATHER FROM SEEING HIS CHILDREN OR ATTENDING THE WORD OF
LIFE YOUTH RALLY JUST SO BECK DID NOT HAVE TO EXPLAIN HIS FRAUDS
TO THE CHURCH OR WORD OF LIFE EMPLOYEES WHO WERE QUESTIONING
THE ACCUSATIONS BY BECK AND MEISTER AND THE SHERIFF TRUSTEES
AND THIS STRESS OF THE ACCUSATIONS OF THE SCHISM EVEN LEAD TO
J.D.T DROPPING OUT OF THIS BIBLE COLLEGE JUST WEEKS BEFORE
GRADUATION WASTING A FULL YEAR OF CREDITS AND FINANCES
LEADING TO NOW PROVED PHYSICAL, MENTAL AND EMOTIONAL STRESS
and Defendants conspired with the mother/employee/criminal and instigated, concealed
criminal acts, created or still allege that Plaintiff Townsend was/is the Crazy one,
Dangerous and Unstable in violation of RYAN v. RYAN using Irreconcilable
Differences as a scheme to conceal the Schisms, wife and attorneys frauds and
uses these concealments to keep Plaintiff from his children, his Church and proper BYLAWS and COURT process and did actions to divest Plaintiff Townsend of his family,
reputation, employment and still enacted delays, unlawful garnishments, court sanctions,
slander and invasion of privacy as still the alleged honorable courts of Hillsborough
County Family, Circuit Civil and the Second D.C.A. WILLFULLY ACT TO CONCEAL
SCRUGGS, DEFENDANTS, OTHERS AND THEMSELVES:

16

A. In violation of STONE Et.al v. WALL Et. al 734 So2d 1038 (Fla. 1999), June 17,
1999, still Do interference with the fathers custody and seeking to recover damages,
costs, and attorney fees related to the fathers recovery of custody. And in this case these
actions by these alleged clergy, lawyers and others intend to permanently by fraud do
interference until resolved by this Federal Court and as these Defendants conspire and
B. In violation of the SUPREME COURT APPROVED SIMPLIFIED FORMS July
1993, APPENDIX 4INJUNCTION FOR PROTECTION, stating:
Under Florida Law, courts can make orders to protect people from
physical violence of a spouse, former spouse, relative, person living with
you now or in the past or the other parent of your child, whether or not
you have ever been married or lived together. These orders are enforced
by law enforcement agencies.
If you are a victim of any act of violence, or reasonable believe you are
about to become a victim you can ask for protection from this violence.
You still will have the right to this protection after the person moves out of
your residence.
The person asking for the protection is the petitioner/Plaintiff and the
person who must obey the order is the Respondent/Defendant.
WHAT KIND OF ORDERS ARE AVAILABLE TO PREVENT
DOMESTIC VIOLENCE?
1. If there is an immediate danger of violence, the court can issue an
order without notice to the respondent. It will go into effect
immediately when the respondent is served. (A Temporary Injunction
for Protection Against Domestic Violence (Ex Parte) and Notice of
Hearing (Form 16). It lasts until the next court hearing, but no longer
than 30 days. In this order, the judge may:
a. Tell the respondent not to contact, molest, attack, strike, threaten,
sexually assault, batter, telephone, or disturb the peace of the
Petitioner.
b. Order the respondent to move out and not return to your home, and
to take only personal clothing and effects.
c. Tell the respondent to stay away from certain people and places
such as your house or place of employment.
d. Decide who has custody and visitation of children.
e. Make other orders special to your situation to assure your safety.
2. After a notice to the respondent and a hearing, the court may issue an
order effective for up to one year. (Injunction for Protection Against
Domestic Violence (After Notice) (Form 17). It can order the items

17

listed in number 1 and also can order the respondent to pay child
support and enter into counseling.Form 17Injunction for
Protection Against Domestic Violence (After Notice). This is the form
signed by the court following the hearing. It is effective up to one
year, unless the court terminates it earlier or extends it.
The Exparte actions of Scruggs(fired on September 30, 2003, upon receipt of the
ORDER of Judge Crenshaw in Case 02-03812, allowing only a Claim of
Malicious Prosecution against Beck, individual, Beck as pastor, and the FBCCP
Corporation shows her collusion with Timmerman, Gomez, Menendez Jr. and
Sierra and others) with Gray and Stacey Turmel as Attorneys for the efforts of
the Defendants in disregard for the rights of the plaintiffs and or the ruling of the
laws did with the knowingly, intentional, reckless and negligent did conspire with
Judge Timmerman even after on March 25, 2003, Scruggs alleged via a
VERIFIED PETITION TO DISQUALIFY JUDGE TIMMERMAN that
Timmerman was unlawful in all previous alleged court actions and added the
phrases not in the PETITION FOR DISSOLUTION OF MARRIAGE but by
Collusion of now with Turmel to conceal fraud of her clients even written in the
Petition . And supporting affidavits as AFFIDAVIT PURSUANT TO
UNIFORM CHILD CUSTODY JURISDICTION ACT (1) no previous court
actions on custody even though case 01-15813 and 01-15814 were custody
issues and (2) even though no claim to assets in the marital home from the
affidavit of Karen Harrod Townsend of November 14, 2001, filed in case 0115814 verses the fraud of the AMENDED and FINAL JUDGEMENT OF
DISSOLUTION OF MARRIAGE stating as records prove specifically prepared
and presented to the Court after Scruggs termination and without the notice and or

18

authority of this Plaintiff who after September 30, 2003, was PRO SE:
(1) TO THE FRAUD ISSUES OF THE STILL PENDING INJUNCTION --9. The Wife has requested a mutual injunction be entered by this
court restraining either party from molesting, harassing, interfering and or
bothering the other party. It is therefor ORDERED AND ADJUDGED.
Both parties shall be enjoined from harassing, molesting, stalking, and
bothering the party either directly, or indirectly or through any third parties.
This injunction shall remain in effect until further order of this Court.
NO DOMESTIC VIOLENCE, FAMILY, CIRCUIT, OR APPEALS
COURTS NOW WILL OVERTURN THE USE OF THIS DIVORCE
INJUNCTION GAINED BY NOW PURELY CONFESSED FRAUD BY
ACTIONS OF PLAINTIFFS ATTORNEYS, KAREN HARROD TOWNSEND,
MEMBERS OF THE CHURCH SCHISM AND LAW ENFORCEMENT TO
CONCEAL EXPARTE ACTIONS AND MALPRACTICE WITH THESE
COURT JUDGES AND THIS INJUNCTION STILL PROHIBITS THIS
FATHER FROM SEEING HIS CHILDREN NOW ONGOING SINCE
OCTOBER 20, 1999, WHEN THE MOTHER ADMITTED TO ALLEGING
THIS FATHER VIOLATED HIS OWN CHILDREN JUST SO SHE COULD
CONCEAL HER TAX FRAUDS AND FRAUDS EVEN TO THE CHILDREN
AND OTHER FRAUDS OF THESE PASTORS WHO THREATENED TO FIRE
HER AS THEIR CHRISTIAN SCHOOL TEACHER IF SHE DID NOT LIE
TO ASSIST THEIR ALLEGED LEGAL ACTIONS NOW PROVED AS
FRAUDS AND CONSPIRACY TO DEPRIVE PLAINTIFFS WHILE
ALLEGING TO ACT AS CLERGY IN ALL DUTIFUL POSITIONS TO THE
BY-LAWS, AND OTHER LAWS, YET: (1) THE RULINGS OF JUDGES
ARNOLD AND BARTON THROUGH 2006, AND (2) THE PARTIAL

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PRODUCTION OF FBCCP RECORDS OF JUNE/JULY 2006, REVEAL

FRAUDS AND OMISSIONS OF TRUTHFUL DISCLOSURE, AND
MISAPPROPRIATION OF CORPORATE OPPORTUNITY AND
MULTIPLE VIOLATIONS OF LAW BY ALL DEFENDANTS AS STATED
HEREIN, AGAINST INNOCENT GENERAL VOTING MEMBERS AND
PLAINTIFFS BY SCHISM MEMBERS AND OTHERS.
(2)

TO THE ISSUES OF THE MARITAL ASSETS--7. That the parties own the former marital home along with the
Husbands parents, and therefore the Wife owns a 0ne-fourth interest in said
home. The Husband currently resides in said home and has been paying all bills
associated with this home. It is therefor ORDERED AND ADJUDGED
The Wife owns a one-fourth interest in and to the formal marital home
and shall be entitled to receive her interest in a timely manner. The Husband shall
have 90 days to arrange with the other owners to purchase the Wifes one-fourth
interest in the property and have her name removed from responsibility on same.
placed in the DIVORCE ORDER WITH INJUNCTIONS and these phrases
not in the filed February/April 2002, PETITION FOR DISSOLUTION OF
MARRIAGE gained by the now proved frauds and intentional withholding of the
true evidence by Scruggs that violate his personal convictions to not make a
church look bad gave this Defendant Estranged Wife an unjust financial gain of
over $60,000.00 (allowing wifes tax fraud, fraud in the home rights and alimony)
and additional yet fully unknown financial losses and parental/child relationship
time, employment and does conceal until this Federal Court intervenes allowing
lower courts and attorneys to conceal criminal acts and still cause violations of
civil rights, custody, visitation, contact and lead to issues of lost employment and
future violations of rights intentionally by attorney Gray to allege no rights to
appeal any issues in cases 02-4974 and case 02-03812, and did frauds to Plaintiffs

20

and the Second District Court of Appeals and using still and including the threats
made still by deputies and by Attorney Gray threatening Plaintiff Townsend that
if in any way Townsend did or was believed to do a violation of the DIVORCE
INJUNCTION until she had judge Timmerman remove the injunction to fear
arrest even on false charges made as by the still threats of Attorney Rolfes in
November 2006, and now even Attorney Scruggs per the February 16, 2007, letter
And Defendants Karen Harrod Townsend and Steven Harrod even made to Judge
Holder on June 22, 2006, after the known acts of frauds by Defendants in the
hearing on Rules of Civil Procedure 1.540, to reverse and remove the Injunctions
as requested in Count Nine of case 05-9605, even after the estranged wife
revealed in her new affidavit on December 12, 2005, she never claimed the acts
that were used by Scruggs, Denny, Gray, Turmel and Judge Timmerman to cause
the Injunctions is the first place alleging even back to 1999, as Karen Harrod
Townsend in total contrast to her actions then but now states under oath:
I did not assert physical harm, (as the copy of the hearing he presented to
the court as an attachment shows.) I made no further claims, but filed for divorce
and moved to Pensacola at the end of the school year.
The divorce stipulates a mutual restraining order to prevent harassment,
which the deposition proceedings may allow without an attorney or mediator
should be present. I cannot afford to hire an attorney. Additionally, now that the
plaintiff no longer pays alimony since his job was recently terminated, I need to
work more hours to compensate and have little time to negotiate the legal system
on my own. Not only am I not financially able, but also cannot risk loosing my
job by repeatedly taking off from work to deal with extenuated legal issues with
the plaintiff.
4.Unwarranted case. It is a means to reopen issues that have already been
decided in other courts, as I have asserted in my early request.The questions
that have been proposed for deposition are without basis, as no one to my
knowledge has alleged physical abuse, only stalking in the 2001 case #01-15814,
Division G, to which he refers.
Plaintiff alleges that the basis for alleging stalking and denial of these Plaintiffs

21

rights as a parent/members at FBCCP and CPCS functions from September 8,

1999, through current times was procured from the fraud just revealed by the
production of the June/July 2006, Court Ordered released partial records that
shows that as Church/School parents and members that Defendants attempt to
suppress, ban or excommunicate Plaintiff Townsend was attempted and done by
unconstitutional means of the By-laws and State statues and a violation of due
process in now proof of the conspiracy to keep concealed the frauds being done to
the General Voting Members and these Plaintiffs by the alleged lawful acts of
the Clergy, alleged Trustees as alleged honorable Sheriff Deputies and now as
prolonged by the frauds of attorneys and judges and alleged law enforcement
officers all throughout with full knowledge that Plaintiff Townsend has always
been an honorable man and by being honorable this will expose the criminal,
uncivil and unethical acts of the estranged wife, pastors, deputies, attorneys,
judges and others as shown herein by even the Addendum Affidavit of Karen
Harrod Townsend filed for Case NO. 01-15814 in November 2001, now proved
intending to do fraud to the court and to the General Voting Church members in
her 8 page Affidavit by stating as follows:
The Respondent(Randall Townsend) often misreads or misconstrues
what people say or do; He calls us liars, and there was no way to prove
differently to him. He generally feels that people do things intentionally against
him and even plot against him (as with the lawsuits and church pastors.) Since
the move out, this seems to have become worse.
The Respondent also displays a compulsive, obsessive personality.
C. As alleged Law enforcement officers or State Officials by omissions of truthful
disclosure decline to have jurisdiction and refuse to even follow or require the

22

Divorce Injunction to be followed with phone or visitation of Plaintiffs within

themselves as shown:
1. On December 25, 2006, Plaintiff Townsend traveled over 500 miles to Pace
Florida to see his children for Christmas and at other times Santa Rosa County
Sheriff Deputies again as at other previous times refused to assist Plaintiff
Townsend per the INJUNCTION even advising Plaintiff Townsend hed better
Just leave town.
2. In December 2005, Defendants HARRODS and Judge Holder did impede even
Plaintiff Townsend taking the Depositions of J.D.T. and J.G.T and others in Pace,
Florida.
3. In 2004, Defendant Gray, Scruggs, Turmel, the State Attorneys Office, the Judges
Timmerman, Gomez, Sierra, Crenshaw, and Palomino impeded the Divorce
Injunction rights of Plaintiffs as stated in the Injunction, the law, and right to
appeal now proved frauds by defendants.
4. Throughout multiple years of demands, contact, and deposing J.D.T. and J.G.T
and others, and even production from the office of Dr. Lon Lynn the medical
records of J.D.T and J.G.T are denied this Pro Se and Parent Randall Townsend
5. And throughout September 1999, through current times, the frauds and
omissions of truthful disclosure of Karen Harrod Townsend are honored above
the rights of and wishes of Plaintiffs Randall Townsend and J.D.T and J.G.T and
others as the letters and actions as exhibits intentions of October, 1999, through
current times of J.D.T and J.G.T are ignored and convoluted by Defendants even
prohibiting or providing needed immediate medical care for J.G.T., the minor

23

(17), daughter on November 10, 2002, while the Karen Harrod Townsend as the
mother, remained over 500 miles away and by phone impeded law enforcement as
reported in Case 02-495771, City of Tampa, Officer J.W. Guzwa, #522, and this
father, from seeing or assisting in the needed medical care of his daughter, J.G.T,
while she visited in Tampa, on a trip paid for by Randall Townsend and this
further lead to needed medical and hospital care of J.D.T, due to the incompetent
medical attention as directed by the mother, Karen Harrod Townsend, trying to
continue her frauds to law enforcement, the Courts, her employer and
manipulation of these children (JDT & JGT) to their detriment and harm and
D. will still not allow Plaintiff Townsend to follow the standard of the Florida Supreme
Court per 617 F.S. as before an act of clergy is done or alleged protected or shielded
as a First Amendment Act the act or actions in question must follow these tests of the
THRESHOLD INQUIRY as stated in MALICKI v. DOE 814 So2d 347 (Fla. SCt.
2002) in acting under Constitutional Law 84.5(7.1) protections and as this Plaintiff
argued and presented to the Court of Judge Crenshaw in Plaintiffs October 9, 2003,
SUPPORTING MEMORANDUM OF LAW AND MOTION FOR REHEARING
stated as follows then and below and by the NEW EVIDENCE tried to be presented to
the Court of Judge Crenshaw on September 7, 2006, as Plaintiff Townsend had just
received the June/July 2006, ORDERED PRODUCED CHURCH/SCHOOL
CORPORATION RECORDS OF or about 1998-2001, that show the criminal underlying
actions and intentions and malice and motives of all joint tortfeasors to willfully and
recklessly use the Child Protective Injunctions, and Refusal to produce records and to
make false allegations and slander the character of Plaintiff Townsend to continue the

24

concealment of all violations of law and even the collusion of the Judges and Attorneys
as stated herein. The many MEMORANDUM OF LAW AND MOTIONS FOR
REHEARINGS, presented in all the Courts (Domestic Violence, Family, Civil,
Appeals) in each case and MULTIPLE MOTIONS OBJECTING TO SUMMARY
JUDGEMENT was still before the court of Judge Crenshaw as again raised by Plaintiff
Townsend on September 7, 2006, and Judge Crenshaw instead of an order on the Points
per this Memorandum of Law and in concert with the specific words of January 21, 2003,
and agreement by Attorney Denny to Judge Arnold that Plaintiff Townsend could Amend
the Pleading and re-file the cases and then do a request for consolidation of all the cases
Judge Crenshaw continues the stalling, delay, damages and conspiracy and did recuse
herself as to this Plaintiff Townsend an admission of guilt and negligence and fraud of
her helping the Clergy and attorneys and judges and the now former wife and others to
still violate the rights of this Plaintiff Townsend and his children and in violation of the
laws now since 1995, and all acts are still ongoing and still concealed as stated:
ISSUE #1The issue presented in this case is whether the First Amendment
bars a third-party tort action against a religious institution grounded on the alleged
tortuous act by one of its clergy. We conclude that the First Amendment does not
provide a shield behind which a church may avoid liability for harm caused bybattery
by one of its clergy
Plaintiff alleged under the Law these acts shown done by Clergy, the Estranged
Wife, the Sheriff Deputies alleged as Trustees and Attorneys and Judges and Dr. Lon
Lynn and failure by law enforcement or state officials to intervene meets the definition of
Battery on these Plaintiffs and resulted in fear and intimidation and emotional
distress and loss of civil rights of speech, religious practice, family rights practice and
employment as employments were terminated as extortion to further violations of laws

25

and rights and promote the position of to help malfeasance of Scruggs to not make a
church look bad or the exposure of his malfeasance and exparte incrimination of the
courts. Plaintiff incorporate herein in full all points raised in the October 9, 2003,
SUPPORTING MEMORANDUM OF LAW AND MOTION FOR REHEARING as
presented to Judge Crenshaw in case 02-03812 and is never resolved by Judge Crenshaw.
This shows that Plaintiff Townsend and other Plaintiffs rights have been violated
as even understood by Plaintiff Minor J.G.T at age 14 on October 20, 1999, when Schism
put the children under duress, J.G.T and J.D.T had to move from the family home due to
the EXTORTION and THREATS of the SCHISM and the mother and J.G.T wrote:
Dad,
Please dont be mad at us! I dont know what other option I/we have. Its
not fair just not 2 C mome either! N- ways well C U soon + well give U a
call later! OK? Take Care of Peaches, Whisper (family cats) + Shaddow
(family dog). Jason needs U 2 set up his bunk-bed in his room, If not well
get it later + set up the dinette set in the kitchen too!
- U ~ C-U Soon
- Jen
or again 2001,Beck and the Schism filed Criminal Charges claiming Repeat Violence and
Domestic Violence and Stalking just so Beck would not meet Randall Townsend at a
WORD OF LIFE YOUTH RALLY where now J.D.T was attending College and had
begun a new life and starting to regain his son/father relationship as stated by J.D.T but
the Schism needed more time to continue and conceal fraud and misappropriation of
corporate assets and the intentional concealment and violation of DUTY by Grant, Gibbs,
and Scruggs and others that allowed Beck, the mother and the Schism to continue and do
crime and multiple violations of rights of Plaintiffs and of the By-Laws and allowed
Intentionally, willfully, recklessly and knowingly by judges and harming Plaintiffs to:
(A) Practice freely all civil rights with his family or others or due to the intentions of

26

alleged Pastors to lie and give false testimony even under Oath, this father has not been
able to hug his children now since, 1999, for fear of going to jail on false charges by
alleged Clergy, Law Enforcement and Judges working to conceal their own frauds
(B) to speak to or see his own or the Plaintiff children since November 8, 2002, or
before or
(C) reverse fraudulent Court actions and INJUNCTIONS for fear of going to jail on
false charges renewed by pastors and trustees on September 8, 1999, and continued
by these Defendant still today some over 8 years of or with NO PROOF OF
THESE CLAIMS having any truth that Plaintiff Townsend was dangerous and a
liar and abusive and suffering from a stress related breakdown so to cause fear
and frauds to all Plaintiffs even by threats to the Townsend kids so to cause the
Plaintiffs Minor J.D.T and J.G.T to on October 20, 1999, to leave the family home
and safety of the protection of this father and by frauds of the mother and the Schism
kept for over 5 days Townsend from knowing the whereabouts of his Children and
then in June 2002, until January 2004 not legally reporting the new residence or
phone number of the mother and children and by still using the falsely alleged Ruling
of Judge Palomino to law enforcement and Judges and others and then by using Judge
Timmermans signed Divorce Injunctions of 2003, being gained by fraud and being
still used illegally by the Defendant as Former Wife (Karen) and her CoConspirators to even still prevent this Pro Se Plaintiff in December 2005 through
current times with help and assistance of Judges Holder, Stoddard , Arnold, 2DCA,
Crenshaw and Judge Sierra not to allow this Plaintiff Pro Se Father to talk to or even
depose his own children to unravel the injustices still being done to all these plaintiffs

27

herein when Plaintiff Townsend on September 8, 1999, as a FBCCP and CPCS

Member, Parent, Childrens Awana Commander, (AWANA), Church Council
Member, Long Range Planning Committee Chairman, (LRPC), Nominations
Committee member and Phase I Committee Member and Budget Committee
participant and the direct ancestor as nephew of the founding pastor as the uncle of
Plaintiff Randall Townsend and Plaintiff Townsend as a State of Florida Licensed
Class D Security Officer in 1999, and a CIVIC LEADER and as a respected
Business Planner of muliple Construction Projects out of DUTY demanded then
And still of the Courts now of Beck, Meister, Leatherman, Brown and Giles:
(1) show me the money and (2) IF YOU TAKE THESE KEYS YOU ARE
TELLING ME YOU DO NOT WANT THE TRUTH and (3) stated of BECK
PRIDE HATH CLOSED HIS EARS, thinking and being told by the non actions
of attorneys, Judges, Law Enforcement and others, as Plaintiff Townsend for years
had said to members (Sheriff Deputy Howlett and Jeffers) and (GEOFF SMITH,) and
others at before and later times to demand full obedience to the FBCCP BY-LAWS
and State and Federal Laws and to reveal:
(A). over $150,000.00 in building funds not reported by the law(s) from 11/98 through
current record but alleged on the revealed June-July 2006 records to be over $213,000.00
(B). the secret accounts or old closed school accounts or misuse of FBCCP revenue
(C). the secret credit card uses and personal expenses shown to this Plaintiff (after
Demanded in the Complaint filed April 2002 and over 20 additional Motions to
the Courts) for the first time in the June-July 2006 records partly produced still in
violation to the Florida Statue 617 and BY-LAWS stated membership rights

28

show to include fraud, conspiracy, breach of duty, breach of trust, omissions of

truthful disclosure and misappropriation or appropriation of a corporate
opportunity, embezzlement and wasteful philanthropy of needed Corporate assets,
accounts and years of all records are still missing as this Member has the right to
full production of records in order to protect the BY-LAWS Contract rights and
Statue Rights sought herein yet Judge Crenshaw on September 7, 2006, refused to
grant this member his BY-LAWS rights and to ORDER production of all
CHURCH and SCHOOL RECORDS done properly as Judge Crenshaw ruled on
May 10, 2006) and attorney Denny, Rolfes, and Grant as Registered Agent refuse
production of FBCCP Corporation documents and other discovery as required by
Law and the FBCCP Corporation BY-LAWS.
(D). the accountability of all collected funds as offerings and tuition and expenses
(E). the missing $43,400.00 in the ASSET Salary fund reported as $53,498.83 in
December 1998 verses $10,098.02, in January 1999,
(F) that Beck, Meister, Leatherman, Jeffers, Howlett and Smith (the Schism) by fraud
induced the Corporation General Voting members to divest of themselves their
personal assets and the assets received from the Eminent Domain Settlement from the
sell of road frontage property at the 7705 Gunn Highway site and by fraud induced
these General Voting Members to purchase (for $600,000.00) the 18105 Gunn
Highway property as Beck, Meister and Leatherman knew even by their own printed
words in local newspapers, meetings with this Plaintiff Townsend as the LONG
RANGE PLANNING COMMITTEE CHAIRMAN (LRPC) and Community leader
that the VISION Projects presented by Beck and Meister were fraud and a scheme

29

to conceal theft of daily assets and other frauds and illegal activities as shown herein
coercing fraud to attorneys and courts and trustees as sheriff deputies with other law
enforcement by fraud
(G) that Beck with the PERSONNEL COMMITTEE(S) did direct for Becks personal
benefit salary increases, bonuses, entertainment compensations, housing and car
allowances and other tax related benefits at the expense and misappropriation of
FBCCP Corporate Opportunity and at the expense of other FBCCP employees and
associates as members.
(H) That Meister with the PERSONNEL COMMITTEE(S) did direct for Meisters
personal benefit salary increases, bonuses, entertainment compensations, housing and
car allowances and other tax related benefits at the expense and misappropriation of
FBCCP Corporate Opportunity and at the expense of other FBCCP employees and
associates as members.
(I) that Beck directed for his personal benefit the attempt at spending $25,000.$40,000.00 to restore, remodel and enlarge the Earl Home at the 18105 North Gunn
Highway property
(J) that Beck directed for his personal use the felony theft of the Awana Microphone
bought by Plaintiff Townsend with designated Awana funds of Townsend and others.
(K) The negligent care and control of FBCCP property and School/Church equipment
(i.e. Buses) while money was diverted to Beck and Meisters entertainment accounts
(L) Nepotism in hiring and illegal labor law practices against teachers and minors
(M)

To stop the fraudulent alleged pastorial but illegal legal and marriage

advice and fraud of and to Plaintiff, Plaintiffs wife and children and Church

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members and
(N) to tell the truth about the frauds of the Clergy BUILDING AND GROWTH PLAN
and how this Clergy Vision violated their promises in 1996, of the Clergy to the
LRPC and to the Church as to the process, the project and the objectives being done.
Further, as proof, Plaintiff Townsend states Clergy as Beck, Nasworthy, and Meister
consulted amongst and by themselves, prepared and required Long Range Planning
Committee Chairman, this Plaintiff Townsend to present and or be presented as a
participant in fraud to the General Voting Members and
A. Even gave Plaintiff Townsend on January 12, 1996, via a fax a cover letter stating:
On the pages to follow is the information that needs to be reported to the church on
Sunday night in the Business Meeting. The Pastor and I have reviewed this
information and discussed it at length and believe that what you need to do is read
this report as is written. You need to communicate the report verbatim, do not vary
from this report as it is written. Read the report and then we can deal with any
questions which should come from the floor of the meeting.
Please call me as soon as you have read the report.
In Christ,
Elbert Nasworthy
The letter to read to the General Voting Members and the LRPC
Committee Members as report known as Report of the Long Range Planning
Committee First Baptist Church of Citrus Park January 14, 1996 in this nine(9)
point report states courses of past, present and future actions for which Townsend shortly
thereafter alleged was illusive, evasive and misrepresentations of what roles persons
would play in the collection, presentation, and implementation of the COGAN Plan.
B. BECK and the Schism as moderator and alleged honorable clergy in multiple
public General Voting Meetings and Committee Meetings presented that Plaintiff
Townsend was responsible for compiling and presenting data and findings per the

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outline of the COGAN Plan and Contract but then privately impeded and obstructed the
reports, collection of data and FBCCP Contract/BY-LAW duties of Townsend in his
multiple positions of leadership
On or about and at various times, Townsend began consultations per his duty and did:
A. On February 25, 1996, Per the agenda CONDUCT A MEETING AS CHAIRMAN:
To the Long Range Planning Committee (LRPC) OF FIRST BAPTIST CITRUS
PARK,
Members present: Bill Dubas, Clara Claxon, Duane Mildord, Mark Nunes, Randy
Townsend,
Members absent: Herman Meister out of town on school business
Pastor(s) attending; Elbert Nasworthy
Randy Townsend acted as chairman and Clara Claxon as secretary of the meeting.
The Chairman then announced that a quorum of members was present and the
meeting of FEBRUARY 25, 1996, was duly convened.
Mark Nunes was introduced and welcomed as the new chairman of the building and
grounds committee. As chairman of building and grounds the church by-laws
appoints said chairman of building and grounds to the long range planning
committee.
A report was made by the Chairman at the request of the absent Mr. Meister and per
the school steering committee that the long range planning committee (LRPC) not an
approve their need for portables for the school year 1996-1997. Discussion was held
and the Motion was duly made and seconded. Motion was approved. The Long
Range Planning approves the site plan of 2/19/96 by EMK which locate two portables
on south curb of driveway between the Teston buildings and the play areas as drawn.
The LRPC encourages the location of the sports storage room next to the school on
the east side of the north canopy. The LRPC did suggest that the portables be leased
as it appears at this time the buildings will not be needed when the next building
phase as projected at present time is completed.
The Chairman did distribute new planning notebooks containing:
SECTION 1. CORRESPONDENCE
1. A DRAFT letter for the discernment of LRPC members pastors and per
approval of LRPC members and pastors, the letter be revised if necessary and
then forwarded to attorneys Mr. Cary Gaylord and Ms. Lorena Ludovici.
Discussion of points raised in the letter are to be discussed in the 3/10/96 LRPC
meeting.
SECTION 2. COMMITTEE PLANNING GOALS AND OBJECTIVES
2. a. Six year Calendar
b. VISION 2000 ten phase PROPOSED sequence of events.
c. VISION 2000 LRPC CODE OF DUTIES AND GOALS

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d. Site maps (to be provided by Duane Milford) containing measurements of

current specs and projected site planning by EMK.
SECTION 3. RULES OF THUMB BUILDING CODES AND GUIDELINES
a. Ten pages of site planning rules of thumb provided by Church Architecture
SECTION 4. LITIGATION OF WORK STUDIES MATERIALS
SECTION 5. EXPERT AREAS OF WORK STUDIES
SECTION 6. AD HOC AREAS OF WORK STUDIES
The Chairman did motion that the LRPC approve the EXPERT AREAS OF
STUDY in an effort to improve communications and reduce time elements these
studies will require. Motion was seconded and Motion was approved.
The chairman did report that a proposal from CHURCH ARCHITECTURE, the
planning group for the Southern Baptist Convention was received and will be review
in detail at the 3/10/96 meeting.
The Chairman did report that a meeting was held on February 21, 1996, with Mr.
Russell Hughes, from the Church planning department of the Florida Baptist
Convention, Mr. And Mrs. Brewer our legal appraisers, Elbert Nasworthy and Randy
Townsend. The report notes that Mr. Hughes also noted that he will provide
information on the legal matters of the Southside Baptist Church in Jacksonville,
Florida, as that information may be of help in our litigation. Mr. Hughes also noted
that this church should contact with a local architect and building contractor to guide
us through expansion discussions. Mr. Hughes offered to provide additional
information regarding our issues after he has the opportunity to review church records
and data.
At this time Elbert Nasworthy for scheduling reasons requested that he be excused
and that the committee continue for as long as needed. Chairman agreed to bring all
pastors up to date when Pastor Beck returned from a missions trip.
Discussion was held on the RULES OF THUMB and EXPERTS were
encouraged to meet as needed with each other and church members and collect all
data.
ALL COMMITTEE MEMBERS WERE ENCOURAGED TO REMIND
OURSELVES AND ALL CHURCH MEMBERS OF LUKE 14:28-30 (Plan your
work before you begin the foundation) AND THAT THIS DATA COLLECTION
PHASE MAY LAST SEVERAL MONTHS AND SHOULD IN NO WAY
INFLUENCE OUR CHURCH FAMILY THAT THE COMMITTEE IS PURSUING
ANY DIRECTION AT THIS TIME. ONLY THE DATA SUMMARY REPORT
PRESENTED TO THE CHURCH FOR APPROVAL WILL DETERMINE THE
COURSE OF ACTION THAT THIS COMMITTEE WILL PURSUE AFTER A
CHURCH VOTE APPROVING SAID RECOMMENDATIONS.
The committee agreed that on 3/10/96 we would address the following:
*Review of EXPERT AREAS rules of thumb.
Chairman requested that each EXPERT present a brief review (5-10 minutes) of
findings to date. A written summary is suggested from each expert with eight copies
for committee and pastors review.
*Review of WHAT IFS AND WISH LISTS
*Review of all church growth and planning bids and committee use of same.
*Review of PROPOSED DRAFT LETTER from Randy Townsend to attorneys.

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The committee agreed that on 3/31/96 we would address the following:

*Complete reviews of EXPERT AREAS
*Prepare statement to be reviewed by the church at the next available business
meeting.
A motion was made and seconded that this meeting adjourn. All approved.
B. The May 20, 1996, MEETING OF THE LRPC upon looking at immediate needs
at the 7705 Gunn Highway property and the position of Pastors and Finance
Committee members that funds were limited the Committee began considering
expansion at the 7705 Gunn Highway property from a multitude of Expert Data and
Cost Details to cure immediate issues with limited resources.(Minutes available)
C. Met with and received counsel and exchanged letters from Attorney David Gibbs, III,
in and during October 1996, and as the letter of October 15, 1996, shows on
Business Loss Rule and other matters dealing with David Gibbs III and Drew
Gardner as agent of and with David Gibbs, III and the Christian Law Association
(CLA) and the Gibbs Law Firm as follows. (Letters Available)
D. Many times Met with and received counsel and letters from Attorneys Cary Gaylord
and Lorena Ludovici.(Letters Available)
E. Met with and received counsel with Hillsborough County officials and exchanged
letters.(Letters and reports available)
F. Met with and received counsel from Attorney as Registered Agent for the FBCCP,
John A. Grant. Jr. who did give fraudulent legal advice to Plaintiff Townsend.
G. Met with and received counsel with IDLEWILD BAPTIST CHURCH PASTORS,
RENO ZUNZ and CARSON WRIGHT.(Letters Available)
H. Met with and received counsel with several Marriage Counselors (Names Available)
I. Met with and received counsel with Dr. Lazarra, Dr. Lon Lynn, Dr. Hoyos.
J. Consulted by phone with multiple persons as agents for the Attorney Generals office,

34

the State Attorneys office, The Hillsborough County Sheriffs Department, The
Department of Education and various other State Of Florida Agencies and
Departments.
K. July, 2000, Townsend, Consulted with Attorney/former Judge Charles
Scruggs, exposing all issues for his legal direction and counsel.
L. Met with and received consultation and exchanged papers and letters with Attorney
Jeffery Klink, whose office is still located in the same buildings of Attorney Scruggs.
Attorney Klink, advised to hire him at that time was premature and that the legal
obligations of the matters Attorney Scruggs was handling may or could be wasteful of
resources for both attorneys to be hired at the same time so therefore the matters
rested in full with Attorney Scruggs.
M. On Multiple occasions wrote to and met with Hillsborough County Sheriff Deputies
and on April 3, 2002, filed a Incident Report Case No: 02-031385 showing and
proving Contempt of Court by Ronald Beck to Judge Palomino and reported this
filing of said report and obtained services and paid fees to Attorney Scruggs to
address this matter with Judge Palomino not knowing at the time that Attorney
Scruggs and Judge Palomino were acting to conceal frauds and omissions of truthful
disclosure and violation of Law as now shown continuing herein this Complaint.
N. On April 25, 2002, Plaintiff Townsend filed a CIVIL ACTION FOR DAMAGES
COMPLAINT AND DEMAND FOR JURY TRIAL, And FOR production of Corporate
Records and they are still not provided to this MEMBER now /Plaintiff Townsend
per his Offices and Duty sought and still seeks to fully expose fraud and criminal acts of:
(1) hidden and misuse of FBCCP & CPCS MONEY and the Awana Childrens property

35

(2) the BECK Fraudulent Building & Growth Scheme being used as the VISION I
& II by Beck and others now through 2006 as proved fraud by the 2006 Rulings of
Judge Barton and Judge Arnold and other professionals of Hillsborough County and
(3) tort and intentionally illegal marital and employer counseling by clergy, as Beck,
Meister, Leatherman and by judges and attorneys and others to conceal fraud
(4) tort counseling and violations of law by masked Officers Howlett and Jeffers
acting as alleged ethical Sheriff Deputies and ethical Corporation Officers/Trustees
(5) reveal all other violation and torts of the Laws and By-Laws and torts against these
plaintiffs and
still attempting to reveal and expose each Defendant attempting to conceal crimes of the
pastors, trustees, judges, attorneys, deputies and all other defendants and of and with the
alleged clergy and sheriff deputies and lawyers and the now former with and other
FBCCP Corporation employees and members since 1995, to conceal their own tort
actions and others multiple violations of the laws and omission of truthful disclosure
procedures to conceal the malpractice and frauds of a fellow attorneys (Gardner, Gibbs,
III and Grant Jr.) who provided false and fraudulent legal advice and former Circuit
Court Judge (Scruggs) who in and through July 2000 and November 2001, through
January/October 2003 and February 2006 and May 2006 and continued by Gray, Denny,
Turmel, Gomez, Sierra and Crenshaw:
A. Did intentional fraud to the Plaintiffs as Scruggs now former clients stating Plaintiff
Townsend did not have a court case against the pastors due to separation of church
and state and freedom of speech for clergy for fraud or misrepresentations and
B. said Plaintiff could not use the courts to stop the slander by the pastors, trustees, or

36

the other church or school employees even of and by the estranged wife to fraud
Plaintiff Townsends reputation and lost child custody relationship or to get
the FBCCP Corporation Documents, because the statements by religious people
were allegedly protected by free speech and separation of church and state even
demanded by a faxed letter to Scruggs on 11/12/01 as a Respondent in the Domestic
Violence Court cases of 01-15813 and 01-15814 nor in the Divorce Case 02-4974 or
as a defense to the frauds to prove case 02-03812 which now June/July 2006
produced records confirm the Breach of Contracts (BY-LAWS and Marital and
LAWYER/CLIENT) and Violations of Laws as alleged by Plaintiff Townsend to
Church/School members, Attorney Scruggs Judges and others and Law Enforcement.
C. Scruggs said Plaintiff in July 2000, could do nothing but write letters to Doctors
(8/1/00, Certified Mail letter to Dr. Lon Lynn, Ron Beck and Gary Leatherman) and
Corporation members and others requesting they protect his children and the other
children and in the Court of Judge Palomino, Ron Beck alleged these letters were
false, yet Scruggs with full knowledge of these issues did fraud the Court and
Plaintiffs.
D. continues statements of frauds to this former client and to the courts and officers
E. did deliberate omission and fraud to keep secret Scruggs personal convictions
withheld and intentionally not revealed to Plaintiffs until September 30, 2003, stating
my personal convictions do not allow me to make a church look bad and the
February 16, 2007 letter stated here and the testimony by Scruggs to Judge Stoddard
And now the February 16, 2007, letter as stated herein thereby allows the criminal
acts to continue giving unlawful benefit to clergy and became as a joint tortfeasor

37

with the pastors, alleged trustees, attorneys Drew Gardner, David Gibbs III, John
Grant Jr. and Judges and Law enforcement and others and the former wifes acts of:
F. child abuse as physical, emotional, mental and continuing permanent,
G. child neglect,
H. child endangerment,
I. fraud, theft and misuse of church and school funds for pecuniary gain,
J. concealment of church and school designated funds in violation of the FBCCP BYLAWS to report all monies every 90 days and State and Federal laws of reporting
K. fraudulent misrepresentations regarding the building funds and expansion program
called by clergy (Beck, Meister) herein as VISION I and VISION II
L. false reporting to and by law enforcement and negligent reporting to law enforcement
M. false reporting to courts in affidavits, oral and written testimony and other actions
N. obstruction of justice and obstruction of a criminal investigation
O. fraud and false reporting to the general voting members of FBCCP since 1995,
P. multiple other breach of duties required per Florida Statues 617 and Florida Statue
895 and Florida Statue 772
Q. of unlawful abuse and harassment and conspiracy and neglect of duty by Sheriff
Deputies as alleged Trustees for the corporation never lawfully elected to office
R. to extrinsic fraud and fraud on the courts and frauds to superior deputy officers
and Internal Revenue Tax Fraud,
in ongoing violations of laws and contracts and concealment of multiple and ongoing
illegal acts now from 1995 through current times of persons alleged as pastors as Beck,
Meister and Brown and alleged trustees Howlett, Leatherman, Jeffers and Smith and

38

other FBCCP and CPCS Corporation officers and members and employees to continue
and to conceal their frauds and omissions of truthful disclosure and criminal acts in
violation of the Laws and of the FBCCP BY-LAWS and of their duties civil and legal.
As an extortion to conceal to their exposure of fraud and Criminal acts Scruggs,
the wife (Karen Harrod Townsend) and Clergy (Beck, Howlett) did in 2001, fraud and
omissions of truthful disclosure to Judge Palomino and then also continued the omissions
of truthful disclosure and frauds in the Divorce Court of Judge Timmerman in 2003, and
Timmerman and Scruggs and Turmel did Exparte, after Scruggs was terminated (9/03) as
attorney for Plaintiffs and by the accusations and unlawful concealment and omissions of
truthful disclosure of Attorneys Gray and Denny and Turmel then with Judge Gomez
created allegations that Plaintiff Townsend did molest and abuse his own children in
order to still deflect eyes from the illegal actions of pastors and deputies and others and
judges and the attorneys as even employed for as by this Plaintiff directly and indirectly
and then in collusion these attorneys and judges and pastors did impede and dissolve the
marriage contract by Plaintiff Townsend and the now former wife as Defendant Karen
Harrod Townsend as she was a contracted FBCCP/CPCS school employee as a teacher
contracted to obey the directives of the pastors or be fired and the children be kicked
out of the school. Upon the favorable ruling by Judge Palomino on November 15, 2001,
ruling for this Plaintiff Townsend as a Respondent to the Charges of Beck and the
persons for whom he spoke as present at the Court as Joe Howlett and Herman Meister
and others as herein named as Doe and for charges made by the wife who then chose to
intentionally, knowingly and recklessly start fraud of the Judge Palomino November 15,
2001, RULINGS and by the Statements of Attorney Charles Denny in now known

39

violation of his fiduciary duty to these Plaintiffs since the 2006, finally produced FBCCP
Corporation Records showed this Plaintiff Townsend is still and always has remained
since 1993, a legal member of the FBCCP Corporation and the statements of Plaintiff
Townsend were and are within his legal rights per Florida Statues 617, to demand from
the alleged Corporation officers and to quote Attorney Denny on June 24, 2003, in the
Courtroom of Judge Crenshaw stated Some of the allegations are quite frankly a little
bizarre, and its the kind of thing that they would like to have resolved. Attorney Denny
alleged the Courts had no jurisdiction to assist Plaintiff Townsend in his allegations of
Civil and Criminal and Contractual Charges Violations due to the entanglement
doctrine. Denny further stated, Hes (Townsend) is asking the Court to step into a
religious dispute and basically find thatthat the church is not organized properly and
managing itself properly and not dealing properly with Mr. Townsend. As stated on
June 24, 2003, on page 5 of the transcript of said hearing. Attorney Denny then in
continuing of the not dealing properly with Mr. Townsend ignores F.S. 617 and the
BY-LAWS of the FBCCP and in the FIRST AFFIRMATIVE DEFENSE STATED:
FIRST DEFENSE The temporary injunction proceeding against Plaintiff was
initiated with probable cause and was fully justified, as Plaintiff was harassing
and stalking members of the First Baptist Church of Citrus Park. The judge in the
temporary injunction proceeding made no findings whatsoever that the
proceeding was initiated without probable cause. When the judge informed
Defendant that Defendant would have to re-file the injunction proceeding in
criminal court, Defendant decided not to subject Plaintiff to criminal
prosecution.
Further, Attorney Denny promoted the frauds of the alleged Clergy and alleged
Trustees masked as also Sheriff Deputies to fraud the court that in the November 3, 2003,
REQUEST FOR ADMISSIONS, Defendant Denny stated that (A) 2. that Plaintiff

40

posed a threat of unstable conduct and violence toward members of First Baptist Church
of Citrus Park. And (4) That the temporary injunction proceeding described in the
Complaint was not instituted and prosecuted with malice, but was rather a good faith
attempt by Defendant to prevent Plaintiff from posing a further threat of unstable conduct
and violence toward members of First Baptist Church of Citrus Park.
This position of Attorney Denny is not supported by the Ruling of Judge
Palomino on November 15, 2001, per the transcripts presented to the case files of case
02-03812 and Divorce case 02-4974 and fully presented to Judge Crenshaw as Defendant
Beck said to Judge Palomino words as said in the Complaints as point 107, below herein.
Townsend responded to the Court of Judge Crenshaw on June 24, 2003, as
follows not aware that the Court of Judge Crenshaw was being deceived about the proper
legal cases presented by Attorney Denny from the District Courts ( as had been
overturned by the rulings of the Florida State Supreme Court and formed clear and direct
flow from the Federal Case Laws where as the District Courts had ignored Federal Case
law and alleged to give total immunity for any act alleged to be done by "Clergy. Also
Kond v. Mudryk, 769 So2d 1073 (Fla. 4th DCA 2000) but still made sure that he BYLAWS were used in the process of the Church and in compliance to the Florida Statues
617 process. The October 9, 2003, argument to the Court in the MOTION FOR
REHEARING stated, on page 6,:
Stealing money and destroying fathers civil rights are TORTS in both
Federal and State laws and totally independent of whether these acts are
religious or not. PLAINTIFF WOULD ASK THIS COURT TO TAKE
JUDICIAL NOTICE OF TOWNSEND v. TOWNSEND, Case #02-4974,
currently before Judge Timmerman, and with the pleadings and the contents of
the recorded testimony of the wife in the trial note that the extreme outrageous
actions resulted due to the conduct of the counselors upon the family with the

41

intent and malice to harm the family as a distraction to their criminal behaviors
about to be exposed to the shareholders in the fall of 1999.
6. ISSUE #3---The United (States) Supreme Court has explained that the FREE
EXERCISE CLAUSE---embraces two concepts-freedom to believe and
freedom to act. The first is absolute but, in the nature of things, the second
cannot be. Conduct remains subject to regulation for the protection of
society. Thus, The First Amendment has never been interpreted to mean
that when otherwise prohibitable conduct is accompanied by religious
convictions, not only the convictions but the conduct itself must be free from
government regulation. Government regulations include both statutory law
and court action through civil lawsuits.
The Threshold rule must be argued and proved by the defendants to any
court but all judges have ignored Plaintiffs motions and a hearing has been
attempted but each court has denied Plaintiffs legal due process since 2001.
Townsend stated on June 24, 2003, pages 6-7, as follows:

I believe Ive timelyIve been asking for motions for extension. I

also believe it was going to be a conflict of interest for Judge Arnold to hear that
matter. My attorney handling my divorce action, Mr. Charles Scruggs is handling
that . And we went before Judge Timmerman a week after that, and were still
waiting on the final judgment on that divorce matter. Accusations were made by
my wife. I was a formerprobably the fourth or fifth level highest at that church.
And Ive been a member sinceoff and on since the early 60s, and this new
pastorthere are multiple violations against the church that my uncle had
formally started back in the 40s and 50s.
And ethically I could not sit back and continue for them to ask me to help them lie
to the congregation, as me to drive a school bus or a school bus with kids on it
that they knew was faulty, that was not tagged, not insured, and so I spoke out.
I became the spokesperson to the wrongdoing. Thats cost me my family. Thats
cost meI cant walk down the mall without having the pastors daughter still
point fingers on me. Im trying to protect my family, let everybody know what is
the truth and do what is honorable.
Ive been filing motions for extension. Im waiting for Judge Timmermans final
judgment, and then I will approach a lawyer to take this case. I have spoken to
over a dozen trying to comply with Judge Arnolds ruling. I believe Im just
around the corner to get that done.
The issues as recorded Transcript of the January 21, 2003, hearing before Judge Arnold,
case 02-03812, and medical reports (Dr. Hoyos and Dr. Millan) was immediately given to
Scruggs to assist in the presentation of all facts to Judge Timmerman on January 30,

42

2003, and to give a reinforced position to Attorney Scruggs that the claims of Plaintiff
Townsend per the partial ruling of Judge Arnold on January 21, 2003, had merit and by
Judge Arnolds inference that the allegations after being presented in a better form may
then be properly alleged and thus prompt former Judge/Attorney Scruggs to take the case
for all Plaintiffs as Scruggs withholding his personal Convictions in violation of the
Law was alleging the Case as against all Defendants was protected as stated herein
based on his superior experience as a former Judge objecting to the legal position of
Judge Arnold.
The enforcement of the Divorce Judgement by Attorneys was gained and used by frauds
and still does threats of jail and as other abuse to Townsend and do interference of child
custody and the Orders and Rulings from Judges Crenshaw on September 7, 2006, and
Judge Holder, Arnold and Stoddard in 2006, and Judge Sierra in 2004-2005, and Judge
Timmerman in 2003-current, continue the interference with this fathers rights to his
childrens interactions and relations and continues this fathers abuse of rights gained by
the frauds on the courts and the refusal of Judges even Judge Crenshaw on September 7,
2006, of this father as a member of FBCCP to have per Florida Statues 617. 1602,
INSPECTION OF RECORDS BY MEMBERS rights so this Plaintiff can expose past
frauds, ongoing frauds and even present the necessary proofs of the pending Malicious
Prosecution Count in Lawsuit 02-03812, TOWNSEND V. BECK or to supplement the
Complaint after full disclosure of the FBCCP records even by these attorneys being paid
by the Plaintiffs who still act to conceal facts and evidence from opposing counsel as this
Plaintiff, PRO SE. Judge Crenshaw and attorney Denny even up to and including new
actions and statements in the hearing of September 7, 2006, in collusion have knowingly,

43

intentionally, recklessly and negligently violated Discovery Rules with alleged superior
knowledge of the law obstructing this member as the Pro Se Plaintiff with rights to all
records and right to seek injunctions preventing these corporate officers from continuing
criminal acts against these plaintiffs as they(Denny as Plaintiffs attorney and Judge
Crenshaw as allegedly unbiased) refused to ORDER to turn over records or Grant
Plaintiff Motions, still act to conceal criminal acts of themselves and of alleged clergy,
attorneys, judges, deputies and all defendants as stated herein and to prevent Plaintiff
Townsend from presenting this case in full to a jury per Plaintiffs rights to have a day in
court and without production of the full documents one allows Benefit to Clergy and
thereby tolls all statue of limitations by the concealment of all things as demanded per
Florida Statues 617 per the FBCCP BY-LAWS, since 1995 to present by this member.
And per Nagashima v. Busck 541 So2d 783 (Fla. 4th DCA 1989), a factual
misrepresentation combined with a misrepresentation of law may also be the basis of a
tort action for fraud. Per Harrell v. Branson 344 So2d 604 (Fla. 1St DCA 1977),
A false representation may be actionable even if the defendant made no direct
statement to the plaintiff. Instead, it is sufficient that the defendant made the
representation with the intent that it reach the plaintiff for the purpose of inducing the
plaintiff to act in reliance on it.
Attorneys, Judges and Sheriff Deputies and others have made physical threats and
other threats against Plaintiff Townsend who has at yet to knowingly violate any law.
Blocking full discovery places the clergy, deputies, attorneys and judges in a
position of advantage to conceal additional violations to plaintiffs and thereby also allow
prejudiced triers of fact or law to allege that all elements of Plaintiffs case are not fully
pled and additional statements by Judges show prejudice to misuse their alleged positions

44

to make false claims and rulings as Res Judicata or Contempt or as Judge Stoddard
falsely created a defense for his friend Scruggs that plaintiff never hired Scruggs.
Judge Crenshaw with attorney Denny were fully advised during July September
2006, in written letters, Motions and by verbal arguments that the just partially released
Judge Crenshaw Court ORDERED on May 10, 2006, FBCCP Corporation Documents
and Ron Beck Credit Card Statements revealed fraud, and criminal acts still ongoing and
that further production to comply with the May 10, 2006 ORDER was needed and that
further production was needed for this PRO SE and DIRECT MEMBER to prove his
Cases yet in Collusion Judge Crenshaw and Attorney Denny argued and still concealed
production of documents and ignored Plaintiffs Matters of Law and Discovery Rules and
actions required of members and officers of the FBCCP BY-LAWS to fellow members.
Further in 2006, Judges Stoddard, Arnold, Holder, and the Second District Court of
Appeals did ignore, conceal, prevent and continue illegal positions to Plaintiffs as Judges
Crenshaw and Judge Sierra with others had done in 2005 and before as stated herein.
Plaintiffs at times material hereto, are also as Church and School members, were and are
dutifully serving their positions to the Church per a Contract known as the BY-LAWS,
CONSTITUTION, POLICIES of 1993, of the FIRST BAPTIST CHURCH OF CITRUS
PARK, (FBCCP) and CITRUS PARK CHRISTIAN SCHOOL (CPCS) AS A
MINISTRY OF THE FIRST BAPTIST CHURCH OF CITRUS PARK and per the CPCS
Student ENROLMENT CONTRACTS of 1989 2002, and the laws of this United States
and State of Florida until battered by all and each individual and each agency, each
Department, and each Company as stated herein arising from and for all Defendants
participation in and production of unlawful neglect of duty; and Breach of Duty; and

45

knowingly, intentional, reckless and negligence to and of their duty; and from each
Defendants knowing and reckless giving benefit to clergy to these select Defendants
herein as alleging to be pastors (hereinafter as SCHISM I, as of Beck and Meister) and
or church officers as trustees (as Smith, Howlett, Leatherman, Jeffers hereinafter as
SCHISM II as alleged FBCCP TRUSTEES with malice, collusion and enjoined with
SCHISM I, in violation of Florida Statues 775.03, stating, The doctrine of benefit of
clergy shall have no operation in this state and thereby gave and are still giving Benefit
to Clergy; as all defendants allege they are lawfully acting and all pastors and trustees
(SCHISM I and SCHISM II) alleged they are legally voted to the positions as elected
Trustees by the General Members of the First Baptist Church of Citrus Park per the
BY-LAWS CONSTITUTION POLICIES (hereinafter as FBCCP BY-LAWS)
conducting FBCCP Business per their alleged lawful and legal actions authority of and
for and to all the voting members of the Corporation of the FBCCP and participation
and interference with the Constitutional Freedoms and Rights of Plaintiffs, and tort
interference against Plaintiffs assisting themselves and other Defendants with unlawful
pecuniary gain by theft and fraud and injurious falsehoods against the reputation of
this Plaintiff in the public eye in his Duty of Service to the Corporations (per Plaintiff
Townsends proper duty and service per the BY-LAWS as nominated and elected per
the Confirmation of the Nominations Committee Process and by then vote of the General
Voting Member) yet Schisms I & II members allegedly removed Plaintiff Townsend
from all positions of service on September 8, 1999, by the unlawful process of the
collusion and fraud of Beck, Meister, Leatherman, Howlett, Giles, Jeffers and Smith and
others as removed without following the process per the BY-LAWS Article III, Section

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7, (A) (G) and to and by the laws of this State of Florida and the United States of
America and Schism I & II Defendants interference with Plaintiffs various Contracts
(Church BY-LAWS Contract, Marriage, Attorney/client contracts, employment and any
future business contracts) and Unlawful interference and slander of Plaintiff Townsend
good reputation in the public eye and Plaintiffs various Child Custody Rights/Duties
causing Child Neglect, Child Endangerment, Child Abuse and Abuse of the Rights of this
Plaintiff as a Father to practice freely his religious practices and beliefs with and to his
family, Children and others by actions in violations of Florida Statues 775.03, giving
unlawful Benefit to Clergy as it will be proved the alleged Clergy and FBCCP
Corporation alleged officers and the now former wife was acting and continue to act
in violation of various Laws as stated herein per their duty of or as agents or as citizens
and specifically in violation of Florida Statues 617, NOT FOR PROFIT as a veil of
gaining personal pecuniary gain and veil to conduct illegal and unlawful actions against
Section 1983 of TITLE 42 of the United States Code rather than acting in the Duty of the
position to serve the interests of the Corporation Not For Profit per the laws as stated in
FLORIDA STATUES 617 and maintain and keep the standards of the FBCCP and CPCS
Corporation BY-LAWS acting as a CONTRACT AGREEMENT with all conditions as a
binding legal document of the State of Florida and violations of other laws as shown
herein. Further, in an extension of and a result of omissions of truthful disclosure
defendants did fraud and omissions of truthful disclosure and injurious falsehoods to
cause Plaintiff Townsend to lose his employment at Kmart and suffer loss of future rights
and future employment and additional Constitutional Rights as stated herein. Each
Defendant herein did continue the nuisance of violations of Plaintiffs rights and failed

47

to reduce the risk of losses of values and rights due to Plaintiffs and all the children
under the duty and care of Plaintiff by defendants tort violations of laws and contracts.
2.

Defendants still knowingly and recklessly participate in the supply, production, and

resulting damages in the advancement of the injurious falsehoods of the alleged clergy
to advance injurious falsehoods and omitted truthful disclosure and omitted disclosing
that these acts of clergy were violations of Florida Criminal and Civil and Labor and
Domestic Relations and Internal Revenue Tax Code and Law and which Plaintiff as a
Whistle Blower made claims against the alleged clergy and the defendants do
knowingly and recklessly refuse to act per their duties per the laws of this state to assist
with not giving Benefit to Clergy to continue the injurious falsehoods and unlawful
actions against this Plaintiff and his children and the FBCCP Corporation Not For Profit
and FBCCP General voting members and these Plaintiffs being abused, kept ignorant
and deprived of truthful lawful information at their times of required Church membership
votes per the Corporation BY-LAWS and thereby become Joint Tortfeasors.
3. Defendants each as individuals and as agents, Departments and Corporations did/do
fraud and omission of truthful disclosure and or denied they had jurisdiction per the
Florida Statues to a DUTY to pursue, investigate or prosecute the allegations of all
violations involving a Florida Statues 617 NOT FOR PROFIT CORPORATION or
allegations of violations of Officers or Clergy of NOT FOR PROFIT CORPORATIONS
or DUTY to enforce Section 1983 of TITLE 42 of the United States Code. This denial of
jurisdiction allowed Benefit of Clergy and because they are so related to the claim in
the action within such original jurisdiction that they form part of the same case or
controversy, intentionally, knowingly, recklessly and negligently allowing additional

48

violations of Federal and State and County Laws and Labor Laws and Contracts. Each
and all defendants have intentionally avoided exposure of all criminal actions of the
clergy and others and thereby conceal their own frauds and crimes and breach of duty and
thus continue the assault on the Rights of these Plaintiffs now for over 10 years.
JURISDICTION
4. This Court has personal jurisdiction over this litigation under:
A. Section 1983 of TITLE 42 of the United States Code, which provides that
any person who, under apparent authority of state law, deprives another of any
rights, privileges, or immunities secured by the United States Constitution and
the laws will be liable to the party injured. [42 U.S.C.S. 1893]
B. Various Sections in Chapters 7, 12,13, 19, 21, 31, 41, 43,47, 65, 73, 79, 93,
96,110, 110A, 123, of TITLE 18 of the UNITED STATES CODE.
C. ALL FEDERAL HUMAN RIGHTS ACTS and HATE CRIMES ACTS as per
Title VII of the Civil Rights Act of 1964, 704(a) and 706 (f) and 706(g)
And 42 U.S.C.A. 2000e-3(a) and 5(f) and 42 U.S.C.A 2000e-5(g) and per
Florida Statues 760.10.
D. And Plaintiffs also sue each person, agency and State of Florida Government
Public Entity and or each Corporation as stated herein, pursuant to Florida
Statues 768.28(6) and Florida Statues 760 and Florida Statues 772 and Florida
Statues 895 and per Florida Statues 617 and this Court has personal and
supplemental jurisdiction as to the other courts and these Complaints and
counts because they are so related to the claim in the action within such
original jurisdiction that they form part of the same case or controversy.
5. This Court also has Jurisdiction of and for the Unlawful and Negligent retention of
employees after being advised of Breach of Duty and Fraud by Employee within the

49

agency, corporation, court or Department in violation of Respondent Superior and

Vicarious Liability Rules and Regulations upon Plaintiff showing causes of Odious and
Outrageous Infliction of acts in bad faith, malicious purposes and or wanton and
willful disregard of human rights, safety or property. TRACEY v. LUDWIG 604 So.
2d 922 (Fla. 2d DCA 1992) and further these law enforcement officers, state officials,
judges and others may upon retirement collect United States Federal Income and
pensions and payments after knowingly, intentionally, and negligently and fraudulently
violating the duty of service gaining these Federal monies and pensions allegedly earned
in the performance of their dutiful service while allowing Fraud, Omissions of truthful
disclosure, battery and threat to ALL Plaintiffs.
6. This Court also has Jurisdiction over each defendant AGENCY AND COURT AND
CORPORATION FOR FAILURE TO TRAIN AND PER RESPONDEAT SUPERIOR
AND VICARIOUS LIABILITY VIOLATIONS OF LAW TO NEGLIGENTLY
SUPERVISE AND RETAIN AS STATED in MONELL v. NEW YORK CITY DEPT
OF SOCIAL SERVICES 436 U.S. 658, 690 98 S. Ct. 2018, 56 L. Ed. 2d 611 (1978)
and GONZALEZ v. PUBLIC HEALTH TRUST 686 F. Supp. 898, 899, 900 (S.D. Fla.
1988) and violation of GARCIA v. REYES 697 So2d 549 (Fla. 1997), as this as above
and herein has been a violation of the Constitutional Religious Right of this Plaintiff
and his children while each defendant knowingly gave Benefit to Clergy to expunge
unlawfully these Plaintiffs from their Religious Rights to membership at the FBCCP,
prior even to and during and after the arrival of Defendant Ron Beck, who knowingly,
intentionally, recklessly and negligently violated the Constitutions of: The United States
of America; The State of Florida; and The First Baptist Church of Citrus Park, By-Laws

50

Constitution as BY-LAWS process as required to lawfully do acts of Defendants. This

Court also has jurisdiction to enforce the Constitutional Rights of Plaintiff unlawfully
damaged by actions of the employer, employees and courts in violation of Florida Statues
760, and of United States Code: TITLE 18, CRIMES AND CRIMINAL PROCEDURE
for matters of Religious Rights, Race Discrimination, Whistle Blower Retaliations
and unlawful payment practices and discriminatory harassment in the workplace. And as
Judge Marva Crenshaw so ruled on May 10, 2006, and allowed and reinforced NO
LAW SHALL IMPEDE THE OBLIGATION OF A CONTRACT as stated in the
UNITED STATES OF AMERICA CONSTITUTION and the STATE OF FLORIDA
CONSTITUTION and plaintiff alleges all laws, policies and rules of procedure used or
allegedly used to protect defendants from allegedly not protecting or doing or acting per
the Contract duties of the BY-LAWS or Attorney Client Contracts are
UNCONSTITUTIONAL in the act or event they may or shall or will IMPEDE THE
OBLIGATION OF A CONTRACT as the Contract may protect or involve a religious
right of Plaintiffs and these alleged acts and violations are in conflict with:
UNITED STATES CODE: TITLE 18 CRIMES AND CRIMINAL PROCEDURE
SECTIONS: Chapter 7, ASSAULT; Chapter 12, CIVIL DISORDERS; Chapter 13,
CIVIL RIGHTS; Chapter 15, Claims and Services In Matters Affecting Government;
Chapter 19, Conspiracy; Chapter 21, Contempts; Chapter 29, Elections and Political
Activities; Chapter 31, Embezzlements and thefts; Chapter 41, Extortion and Threats;
Chapter 43, False Personation; Chapter 47, Fraud and False Statements; Chapter 57,
Labor; Chapter 65, Malicious Mischief; Chapter 73, Obstruction of Justice; Chapter 79,
Perjury; Chapter 93, Public Officers and Employees; Chapter 95, Racketeering; Chapter

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96, Racketeer Influenced and Corrupt Organizations; Chapter 110, Sexual Exploitation
and Other Abuse of Children; Chapter 110A, Domestic Violence and Stalking; Chapter
121, Stored Wire and Electronic Communications and Transactional Records Access;
Chapter 123, Prohibition On Release And Use of Certain Personal Information From
State Motor Vehicle Records and multiple other sections of this United States Codes as
Discovery of all violations are still ongoing and Plaintiff Townsend states that by the
Collusion, Concealment and Refusal by Circuit Court Judges, Attorneys, and State
Officers and Law Enforcement refusal to grant Plaintiffs Pro Se Ongoing Discovery
Demands of Productions of all Documents that this Creates and prolongs concealment
and damages and obstructions of Justice for this Pro Se Plaintiff to present all facts to the
Federal authorities including the Federal Bureau of Investigations (FBI) and IRS.
7. This Court has Jurisdiction over each Agency and Department of the State Of Florida
per KAISNER v. KOLD 543 So2d 732, 1989 Fla. SCt. 2682, and that the issues of
NEGLIGENCE by the AGENCY OR DEPARTMENT is:
We see no reason why the same analysis should not obtain in a case in which
the zone of risk is created by the police. Further, There is a strong public policy in this
state that, where reasonable men may differ, the question of foreseeability in negligence
cases should be resolved by a jury.
Per VINING. V. AVIS RENT-A-CAR 354 So2d 54 (Fla. 1977), 1977 Fla. SCt. 6600.
Where a defendants conduct creates a foreseeable zone of risk, the law
generally will recognize a duty placed upon the defendant to either to lessen the
risk or see that sufficient precautions are taken to protect others from the harm
that the risk poses.
See STEVENS v. JEFFERSON 436 So2d 33, (Fla. 1983), 1983 Fla. SCt. 5164.
8. This Court has Jurisdiction PER THE TORT CLAIMS ACT which does not require
claims-filing requirements over EACH INDIVUDUAL DEFENDANT FOR ALL

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MATTERS AS STATED HEREIN, PERSUANT TO SMITH v. WADE 461 U.S.

30, 55, 103 S. Ct. 1625, 75 L. 2d 632 (1983) AND
9. TO AWARD PUNITIVE DAMAGES UPON THE FINDING OF A JURY TO
ADJUDICATE AND FAIRLY COMPENSATE PLAINTIFF(S) FOR ALL MATTERS
AS STATED HEREIN.
10. This Court has Jurisdiction per PROSSER, LAW OF TORTS 46 (West 4th ed
1971)
All persons who actively participate in a tortious act, or who aid or encourage
the wrongdoer in furtherance of a common plan or design to commit the tortious act, are
equally liable with the wrongdoer for the act. Those who ratify and adopt the wrong
doers act that are done for their benefit are also equally liable with the wrongdoer for
the act. Traditionally, all such aiders and abettors are joined as defendants in one action
and each is held liable for the entire damage.
Matthew Bender and Company, Inc. Assault and Battery 20.04 Also any court officer
or judge after hearing a matter and once ruling on any matter over and above the ruling of
no jurisdiction becomes a joint tortfeasor for any and all wrongdoer or the act of any
wrongdoer.
11. Other courts retained jurisdiction and held in Life Ins. Co. of Georgia v. Lopez 443
So2d 947, the insurer had a duty to investigate and take steps to present the beneficiary
from harming the insured, by canceling the policy or by warning the beneficiary that no
benefits would be payable to any person who murdered the insured then surely any
person or agency who has ignored the BENEFIT OF CLERGY law and other civil and
legal rights of plaintiffs and the children as victims and a whistle blower of criminal or
reckless conduct is also a aider and abettors to continuation of damages and additional
criminal frauds and torts of the original frauds of Beck, Meister, Brown and the alleged
FBCCP Church Trustees (as alleged Trustees were illegally installed by appointment of

53

Beck and not confirmed vote per the process per BY-LAWS Section Article II. by the
Nomination Committee or by vote of the general congregation at the next general
meeting or every three years as required by the FBCCP BY-LAWS to be followed per
Florida Statue 617) actions as Sheriff Deputies WITHOUT PROBABLE CAUSE other
than conceal their prior criminal acts both as trustees and as sheriff deputies and as
general citizens!
Those who ignore the actions of illegal conduct of law enforcement officers, agents
and agencies, attorneys and other judges and corporations in violation of contracts
or other legal duties then continue the damages and the concealment of the frauds
against this PRO SE who is being greatly deprived of his rights, suffering great
nuisance and damages and is still blocked from seeing and visitation and with
full companionship to and with his children since October 20, 1999, and revealing
all omitted truthful disclosure of the maternal mother and maternal family and
attorneys, pastors, judges and others, or even taking the testimony of his own
children to testify did your father ever molest/abuse you? so the Injunctions
and the continued abuse by the maternal mother and her family and the pastors
schism, the attorneys, judges and others who allow this fraud can be held
responsible for the loss of the invaluable relationship time as the courts warns
should not happen in any parent child case! Those who ignore the illegal conduct
continue using the relationship and omissions of truthful disclosure as extortion
against Plaintiffs. So all Defendants should be held responsible for the continuing
acts of omissions of truthful disclosure to these Plaintiffs thereby continuing the
separation and loss of Constitutional rights to freedoms of speech, religion, life,

54

liberty and the pursuit of Happiness and employment and relationship with all
persons in peaceful society.
12. This Court has Jurisdiction to determine intentional specific behavior and therefore
per Dominguez v. Equitable Life Assurance Society 438 So2d 58 (Fla. 3rd 1983) shows
sufficient proof that emotional distress arose from the act. All judges to protect the
integrity of the court are not to allow fraud in the court by the aggressor who uses the
fraud to the court to abuse the victim. This Court should retain jurisdiction to preserve
the integrity of the Courts, to expose fraud on the courts and by whom fraud was done.
13. This Court has Jurisdiction per EXXON CORP. USA v. DUNN 474 So2d 1269,
Damages for emotional distress may be recovered from a defendant who maintains a
nuisance, regardless of physical injury or impact. Annoyance, discomfort, inconvenience,
and the like are the natural results of a nuisance and are thus compensable, even if the
defendant did not intentionally, maliciously or recklessly create or maintain the
nuisance.
14. This Court has Jurisdiction to determine Compensation for injuries to and to
what extent involve emotional distress may also be recovered through such acts as
torts as false imprisonment, assault and battery, wrongful birth and defamation.
PER FLORIDA TORTS 23.30 as Plaintiff Townsend has plead with each and every
person and agency and tried to get help from these Defendants as they have allowed
Plaintiffs rights with the children to be abused by the then wife/now former wife and
mother as an employee of Ron Beck and Herman Meister and FBCCP Church Trustees
through Sheriff Deputies Howlett and Jeffers for the First Baptist Church of Citrus Park
Corporation who acted outside the LAW and the BY-LAWS and violated Plaintiffs just

55

trying to operate civilly under Constitutional Laws and of the Corporation BY-LAWS as
was and still is the duty. All Defendants who have once they have knowledge of these
issues and lied to Plaintiff and alleged Plaintiffs had no rights, lost Plaintiffs rights, or
had no cause of actions, or could not combine defendants and or causes of actions just to
continue and protect themselves due to statue of limitations violations of due process
have just continued the frauds and torts by the criminal acts of the SCHISM Officers .
CHAMPION v. GRAY 478 So2d 17 (Fla. 1985). Further, in 34 AM JUR. P. 188
Section 231, the author says, Fraudulent concealment of a cause of action from the
one in whom it resides, by the one against whom it lies, constitutes an implied
exception to the statue of limitations. Emphasis added. These abusive actions by
BECK and per MEISTER began against Plaintiff Townsend, when Beck and Meister
made a pack to get rid of this LRPC CHAIRMAN and member so they could pull off
their scheme to fraud (1) to miss use FBCCP Corporation funds and pad their pockets
by fraud and (2) of the Master Building Plan corruption alleged as a VISION and
started frauds and omissions of truthful disclosure and giving illegal legal advice about
Plaintiff to the wife and children and others. Facts are well documented in FBCCP
BUSINESS MEETING MINUTES and Corporation Documents Plaintiff still known as a
Corporation Member just received by Order of the Court in June 2006, and confirmed by
Affidavits from Witnesses to the intentional frauds of FBCCP and CPCS alleged pastors
and officers Beck and Meister and Leatherman and Howlett and Jeffers and others
including various FBCCP members, employees, attorneys, judges and Police officers and
Sheriff Deputies and other state employees. In 1996, Plaintiff Townsend per the Duties
of the Positions of Service this Plaintiff Townsend pledged to uphold, first began to

56

alleged that Corporation monies were not being reported per the BY-LAWS Required
process every 90 days and that alleged closed accounts were being mishandled and
kept secret from the general voting member and this Long Range Planning Committee
Chairman as Plaintiff Randall Townend in violation of the BY-LAWS. Whistle Blower
retaliation acts of the pastors (Beck and Meister and Nasworthy) now just partly learned
began against Plaintiff Townsend and Plaintiffs family as Plaintiffs son, J.D.T was 13
and Plaintiffs daughter, J.G.T., was just 11 years old enrolled as students at Citrus Park
Christian School and attending the FBCCP. Beck at the 03/26/1996, Business Meeting
Minutes states that the proposal of what the Church can do, will come from the LONG
RANGE PLANNING COMMITTEE(LRPC) and as the Plaintiff Townsend as Chairman.
15. This Court has Jurisdiction, Quoting Chapter 67 of Florida Jury Instructions by
Richard B. Badgley, at 67.01[3]Comment,
The Florida Supreme Court has adopted the position set forth in the
Restatement (Second) of Torts 46, which acknowledges the existence of
an independent tort for intentional infliction of emotional distress.1 At the
same time, recovery of damages for emotional distress in a cause of action
for another tort remains viable.2
Damages may be recovered for emotional distress without a showing a
bodily harm resulting from the emotional distress.3 Examples of this
include certain abusive debt collection practices.5
Conduct that is actionable as intentional infliction of emotional distress
may also give rise to liability for malicious infliction of emotional distress,
for which punitive damages may be sought.6
67.02[3] Abuse of real or apparent authority over a plaintiff may also rise
to the level of extreme and outrageous conduct.5 Examples of Florida
cases in this category includeand abuse of position by a police officer.7
Per CITY OF DELAND v. FLORIDA TRANSPORTATION AND
LEASING CORP 293 So2d 800 (Fla. 1st DCA 1974)
16. MT. OLIVE PRIMITIVE BAPTIST ET AL v. HARRIS et al. 860 So2d 520 (Fla.
App 1 DIST. 2003) allows Plaintiffs rights by stating:

57

RELIGIOUS SOCIETIES 31(4) Church representatives complaint

against church and its pastor, asserted by representatives as individuals on
derivative basis on behalf of church, set forth sufficient allegations of ultimate
fact to withstand motion to dismiss for failure to state a cause of action,
17. FLORIDA STATUES 617.0834, Abuse and interference of father/child civil rights
and interference with marital counseling and misuse of Credit Cards and frauds Court
and frauds to the BY-LAWS General Voting Members show acts of Criminal
violations of laws.
Florida Statues 617.0834 infers 1. the violations of Criminal Laws estops that officer
or director from contesting the fact that his or her breach, or failure to perform,
constitutes a violation of the criminal law 2. A transaction from which the officer
or director derived an improper personal benefit, either directly or indirectly or 3.
Recklessness or an act or omission which was committed in bad faith or with
malicious purpose or in a manner exhibiting wanton and willful disregard of human
rights, safety, or property. Are grounds for investigation and potential criminal or
civil charges for violations of Criminal laws or the BY-LAWS.
PER Wests F.S.A. 95.031, LIMITATIONS OF ACTIONS 43
A statue of limitations runs from the time the cause of action accrues
which, in turn, is generally determined by the date when the last element
constituting the cause of action occurs.
The continued concealment of the Corporation Business Records and Credit Card Billing
Statements and the obstruction of Plaintiffs knowledge, civil rights, religious rights,
parental rights from or as any still active memberof the FBCCP Church by frauds
ongoing by the alleged FBCCP clergy, FBCCP alleged Corporation officers, Corporation
Attorneys, Judges, Plaintiffs former attorneys, Plaintiffs current attorneys (Dickinson)
acting allegedly for the Corporation Members and the Corporation to the Courts, and of
the Courts and Judges and State agents and agencies as all defendants as stated herein
and the concealment and interference of the child abuse and child custody since October
1999, by the collusion of the FBCCP clergy and FBCCP alleged trustees acting as
Sheriff Deputies conspiring with false evidence and omissions of truthful disclosure of

58

falsehoods against this Plaintiff as a whistle blower of Defendants known criminal

activity past, present and future to destroy Plaintiffs rights and prevent production of
FBCCP Corporation records that still on September 7, 2006, Judge Marva Crenshaw
refused to require Attorney Denny acting for the defendants to not comply with the May
10, 2006, Court Order of Judge Marva Crenshaw shows continuing concealment and
omissions of truthful disclosure which will overturn all alleged frauds against Plaintiff
and still allowing this innocent plaintiff and his children and those plaintiff Townsend
sought to protect from criminal activity still being damaged by the injurious falsehoods
causing the first frauds of Defendants in September/October 1999, to impede the parental
rights of Plaintiff Townsend to his minor children J.D. T. and J.G.T and endanger the
lives of Plaintiffs Children and other Children of and in the FBCCP and CPCS care and
supervision of Plaintiff Townsend and other FBCCP Officers, alleged officers and
employees and the November 2001, Injunctions tried and heard by Judge Raul Palomino
on November 15, 2001, brought against Plaintiff Townsend as retaliations by the
FBCCP employees and others herein or others as DOE yet unknown until pending
Discovery as the Defendants and attorney Scruggs to conceal known criminal acts of all
Defendants herein and then the ACTION FOR DIVORCEMENT filed by the FBCCP
Corporation Emoployee as the wife now former wife of this Plaintiff Townsend as per the
November, 2003, DIVORCE JUDGEMENT WITH INJUNCTIONS and AMENDED
DIVORCE JUDGEMENT WITH INJUNCTIONS shows the causes of actions last
element is still accruing by fraudulent inducement and extrinsic fraud being done in the
Circuit and Family Courts by the failure of the FBCCP Attorney to produce the
Records still not being produced per the Courts ORDER of May 10, 2006, per Judge

59

Crenshaw and Judge Crenshaw then refusal to rule during September 2006, on the
pending DISCOVERY MOTIONS and other MOTIONS for the protection of Plaintiffs
rights (Corporation and Civil) and of still needed discovery of said FBCCP and CPCS
Corporation records per this Plaintiff members rights under Florida Statue 617.1601
through 617.1623 and all other guaranteed rights of Plaintiff per the Laws of these
United States, the State of Florids and the FBCCP Corporation and CPCS Christian
School as binding contracts as Plaintiff still seeks finding the over $200,000.00 and
knowledge of all other violations of the FBCCP BY-LAWS per Plaintiff Townsends
rights as still a member and as discovery of these facts is necessary for plaintiff
Townsend to present all claims and facts even just under the MALICIOUS
PROSECUTION COUNT in case 02-03812, per the rule to present (1) probable
cause, (2) malice (3) by who or whom who had motive and collusion per the
Pellgerini Rule and (4) Damages. These Lower Courts seeking to block discovery
shows collusion, malice, obstruction of justice and witness tampering by these lower
courts continuing the nusiance and risks to Plaintiffs herein and protects
themselves from being proved accomplishes to the Benefit of Clergy issue and
misuse of color of uniform by law enforcment, attorneys, judges and pastors and
others.
Further Plaintiff alleges his termination of employment at Kmart/Sears was in
direct violation of Plaintiff Townsends Civil rights and retaliation against Plaintiff
Townsend as a whistle blower of known criminal activities of ALL Defendants.
Further the collusion by alleged law enforcement, court officers, attorneys and
Judges to continue the concealment of lawful information, FBCCP and CPCS

60

Corporation records from this member as a Plaintiff in now as a former

Respondent/Defendant turned Plaintiff continues the frauds and violations of
Florida Statues 617 and Rules of Civil Procedure as to disclosure of evidence and
continuation of blocking this Plaintiff/Father from the deposing or contact with his
children as children and as witnesses and block this Pro Se Plaintiff from
discovery rights per the Rules of Civil Procedure and prevent defendants from
being in good standing with any court as they are in violation of court orders for the
production of documents and show obstruction of justice and tampering with
witnesses and blocking this Pro Se from Depositions even of his own children
needed for production of evidence even in the Malicious Prosecution Count.
18. Further this Court has personal jurisdiction and subject matter jurisdiction per
these Florida Statues: 39 F.S.(Proceedings related to Juveniles); s. 61
F.S.(Dissolution of marriage); All Florida Statues relating to duties of Public
Officers; s.117 F.S. (Notaries Public); s. 415 F.S. (Childrens Protection From
Abuse, Neglect and Exploitation); s. 458 F.S.( Medical Malpractice); s.617
F.S.(Not for profit Corporation); s.623 F.S. (Private School); and as employees
for FBCCP and CPCS and members assisting to block Corporations records
disclosure directly assisting the Directors actions in violation of: s. 617.1601
(Reporting of records); s.617.1602, (Inspection of Records); s.617.0834
F.S.(Duty and Violation of Duties); s. 617.0841 (Duty to Follow By-Laws);
s. 617.1605 (60 days end of year reporting requirement or per By-laws) s.617.10
F.S., (members right to be heard before removal in Not For Profit Corporation);
s. 784 F.S. (Assault; Battery; Stalking; Culpable negligence); s.787 F.S.

61

(false imprisonment; custody offenses); s. 772 F.S., Civil Remedies for Criminal
Practices as; s. 812, F.S.(theft and related crimes); s.817, F.S., (assisting
Corporate officers in violation of Fraud and Credit Card crimes); s. 836.05, F.S.,
(extortion); s. 837,F.S. and 914.13(perjury); s. 914.14 (Witness accepting bribe);
914.21 and 914.22 and 914.23 and 914.25 (treatment of witnesses); s. 843 F.S.
(Obstruction of Justice); s. 817.49 F.S. (False report of commission of crimes;
penalty); s. 772.102(4), F.S. (as such actions show a pattern of criminal activity);
s. 775 and specifically 775.085 F.S. (Evidencing prejudice while committing
offense; enhanced penalties); s. 775.089 F.S.(Restitution); s. 402,F.S.(Child Care
facilities); s. 827 F.S. (abuse of Children) ; s. 836 F.S. (Defamation and
Publications to expose person to hatred, contempt, or ridicule prohibited); s.838
F.S.(Bribery; misuse of public office); s. 839, F.S., (Offenses by Public Officers
and Employees); s.843 F.S.(Obstructing Justice) s. 871.01 & 871.02, F.S.
(Disturbing Religious and other assemblies); s.877 F.S. (Hate Crimes); s. 895,
F.S. (R.I.C.O.); 623 741 s. 768 F.S. (Florida Tort Claims Act); s.918 F.S.
(Conduct of Criminal trial [Repeat Violence charges per s. 784 and 18.U.S.C. on
November 15, 2001]); s. 943 F.S.(Department of Law Enforcement) other Florida
Statues and per violations of UNITED STATES CODE violations of TITLE 18,
CRIMES AND CRIMINAL PROCEDURE, Section 241, CONSPIRACY
AGAINST RIGHTS, Section 242, Deprivation of rights under color of
law, Section 245, Federally protected activities, Section 246 Deprivation of
relief benefits, Section 247, Damage to religious property; obstruction of
persons in the free exercise of religious beliefs, Section 373, Solicitation to

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commit a crime of violence, Section 1037, Fraud and related activity in

connection with electronic mail and other Sections of the United States Code
and Sections of Human Rights as stated herein.
19. The United States of America and State of Florida Constitutions provide and allowed
as stated by Judge Crenshaw on May 10, 2006, allowing this statement no law shall
impede the obligation of a contract in the Second Amended Complaint filed as
TOWNSEND v. BECK et. Al Case 02-03812, but then refusing to overturn the
continuing Injunctions and continuing to allow misrepresentation of how the
alleged Legal Injunctions are still misused to damage the parental and children
rights as now able to choose for themselves and know and can know and understand
the frauds of injunctions gained by the knowingly intentional, reckless, and negligent
omissions of truthful disclosure that prohibit Constitutional rights and freedoms of
these Plaintiffs and doing acts and enacting laws or omitting truthful disclosure or
enforcing rules that then impeded the obligation of the FBCCP contracts and marriage
contracts, attorney client contracts and agencies contracts with citizens and no law
shall impede the obligation of a contract and this Court has jurisdiction to enforce
the rights, laws and obligations of a Contract per the rights of the Constitutions as
stated herein. Per the Law the Church BY-LAWS are a contract. And per the actions
of these lower courts, Judge Crenshaw, Judge Stoddard, Judge Holder, Judge Sierra
and the Second District Court of Appeals during the periods of on or about October
2005 through present and before October 2006, all lower courts have enacted laws or
rulings that impeded the obligation of contracts enacted by Plaintiff with these
Defendants and thereby each/all Defendants are vicariously and directly or indirectly

63

liable for the omissions of truthful disclosure and obstruction and extortion of the
actions of these other tortfeasors and themselves in violation of these contracts and
Constitutional laws and rights.
20. At the time of these matters Plaintiff Randall Townsend was a resident of
Hillsborough County and of the State Of Florida, United States Of America and
Defendants operated and acted in their positions with or as individuals and doing
business and jurisdiction of the laws governing in Hillsborough County and of this
State of Florida and of these United States and as a member of FBCCP under the
Contract rights and duties of the FBCCP Corporation Constitution, Policies and ByLaws.
21. Further, this Court has jurisdiction as the matter in controversy exceeds, exclusive
of interest and costs, the sum of over $15, 000.00 specified for the Courts jurisdiction.
THE PARTIES
22. Plaintiff Randall Townsend (Plaintiff Townsend), is the father of son J.D.T and
daughter J.G.T as the persons deprived of their respective rights of the Constitution of
the United States of America and the Statues and Constitution of the State of Florida
and the Constitution and BY-LAWS of the First Baptist Church of Citrus Park as a
Contract with Direct, Indirect and Derivative Rights and as per Plaintiff Randall
Townsends Marital Contract Rights and Plaintiff Townsends post office address is
P.O. BOX 21, ODESSA, FL 33556. Additionally, Plaintiff Randall Townsend, Pro
Se, pleads to speak on behalf of all minor Plaintiffs as FBCCP and CPCS School
Children for whom Randall Townsend served from 1993, through present times even

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during the alleged times Beck and other Defendants alleged the FBCCP Membership
of Randall Townsend had been alleged legally terminated and proved a fraud by the
June/July 2006 produced records and therefore Randall Townsend seeks to still serve
per his direct, indirect and derivative duties as Church Leader in the Offices of
Nominations Committee Member, Long Range Planning Committee Chairman, and
Awana Commander and as special liaison as Usher in the role of service to all
Associates and Members deprived of their General Voting Rights due to frauds and
omissions of truthful disclosure by pastors and trustees and others and Plaintiff
Townsend pleads to speak for all plaintiffs in this matter as a Class Action. All
plaintiffs reside in the State of Florida.
23. Defendant RONALD L. BECK, Individually, and REVERAND RONALD L. BECK,
AS SENIOR PASTOR as the Corporation officer, of the FIRST BAPTIST CHURCH
OF CITRUS PARK, (FBCCP), and CITRUS PARK CHRISTIAN SCHOOL (CPCS),
AND THE CORPORATION OF THE FIRST BAPTIST CHURCH OF CITRUS
PARK are Defendants in lawsuit CASE NO 02-03812, Hillsborough County,
Florida AND PER SUPPLEMENTAL AND AMENDED PLEADING ADDS:
24. Defendants as Associates per 62 ALR3rd 1165, hereinafter as General Members:
WILLIAM T. BROWN, Individually, REVERAND WILLIAM T.
BROWN, (FBCCP) AS PASTOR OF ADMINISTRATION, HERMAN
MEISTER, Individually, HERMAN MEISTER, (FBCCP/CPCS) AS PASTOR
OF CITRUS PARK CHRISTIAN SCHOOLS, (CPCS) HERMAN MEISTER AS
CPCS SCHOOL BOARD MEMBER, GARY LEATHERMAN, Individually,
GARY LEATHERMAN, AS TRUSTEE, AS DEACON, ROBERT GILES,

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Individually, ROBERT GILES, AS MEMBER OF PERSONNEL COMMITTEE,

(FBCCP) ROBERT GILES AS MEMBER OF THE CPCS SCHOOL BOARD,
PAULA POWELL, Individually, PAULA POWELL AS FBCCP FINANCIAL
SECRETARY EMPLOYEE, PAULA POWELL AS CPCS SCHOOL BOARD
MEMBER,TIM JEFFERS, Individually, TIM JEFFERS AS PINELLAS
COUNTY SHERIFF DEPUTY, TIM JEFFERS, AS FINANCE COMMITTEE
MEMBER, MARK NUNES, Individually, MARK NUNES, AS CHAIRMAN OF
DEACONS, 1999-2000 (FBCCP) MIKE SHUMATE, Individually, MIKE
SHUMANTE, AS CHAIRMAN OF DEACONS, 2000-2001, (FBCCP),
CARL(BUDDY) RAWLS, Individually, CARL(BUDDY) RAWLS, AS
MEMBER OF THE LONG RANGE PLANNING COMMITTEE FBCCP,
DUANE MILFORD, Individually, DUANE MILFORD AS LONG RANGE
PLANNING COMMITTEE MEMBER FBCCP, And Deacon.
KAREN JEFFERS, Individually, KAREN JEFFERS AS EMPLOYEE AS
PRINCIPLE OF CITRUS PARK CHRISTIAN SCHOOL, GAYLE LYNN,
Individually, GAYLE LYNN, AS EMPLOYEE DEAN OF STUDENTS CITRUS
PARK CHRISTIAN SCHOOL, APRIL BECK, Individually, JIM LEAHY,
Individually, JIM LEAHY AS PERSONNEL COMMITTEE CHAIRMAN,
JOE KAREAS, Individually, JOE KAREAS, AS CITY OF TAMPA POLICE
OFFICER, MICHEAL JOHN CORBIN, Individually, MICHEAL JOHN
CORBIN AS MEMBER OF THE LONG RANGE PLANNING COMMITTEE
FBCCP, MICHEAL JOHN CORBIN, AS PASCO COUNTY SHERIFF
DEPUTY DETECTIVE, JOYCE MEISTER, Individually, JACKIE HOWLETT,

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Individually, JACKIE HOWLETT AS CPCS SCHOOL BOARD MEMBER,

JACKIE HOWLETT AS MEMBER OF THE LONG RANGE PLANNING
COMMITTEE FBCCP, JOE HOWLETT, Individually, JOE HOWLETT AS
HILLSBOROUGH COUNTY SHERIFF DEPUTY, JOE HOWLETT, AS
TRUSTEE, (FBCCP), LON LYNN, Individually, DR. LON LYNN, AS A
PROFESSIONAL MEDICAL DOCTOR, GEOFF SMITH, Individually, GEOFF
SMITH, AS CORPORATION PRESIDENT, MIKE SMOAK, AS Individually,
MIKE SMOAK AS CPCS SCHOOL BOARD MEMBER, MIKE SMOAK AS
HILLSBOROUGH COUNTY SHERIFF DEPUTY, MIKE SHAR, Individually,
DON BECK, Individually, DON BECK, AS DEACON, JOHN COLLINSON,
Individually, JOHN COLLINSON, AS DEACON, BILL CRAFT, Individually,
BILL CRAFT, AS DEACON, ROBERT GILES, AS DEACON, ED HOPKINS,
Individually, ED HOPKINS, AS DEACON, JERRY MILLER, Individually,
JERRY MILLER, AS DEACON, WILSON SMITH, Individually, WILSON
SMITH, AS DEACON
are of THE MEMBERSHIP AT LARGE AS ASSOCIATES AND
EMPLOYEES OF d/b/a, FIRST BAPTIST CHURCH OF CITRUS
PARK,(FBCCP AND CITRUS PARK CHRISTIAN SCHOOL, (CPCS) AS A
FLORIDA NOT FOR PROFIT CORPORATION and are as individuals, as agents
or of the membership of the Corporation of the First Baptist Church of Citrus Park
and Citrus Park Christian School operating as a ministry of the Corporation know
and d/b/a, The First Baptist Church of Citrus Park (FBCCP) being sued as
Defendants as individuals and associates and in their capacity as agents of the

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Corporation and as members of the Corporation and as the CORPORATION

FBCCP. All Defendants reside and or do business in the State Of Florida.
25. Defendants JOHN A. GRANT, JR.(GRANT) Individually, JOHN A. GRANT,
JR. AS REGISTERED AGENT OF First Baptist Church of Citrus Park
CORPORATION, being sued in his role as an individual, Agent of the FBCCP
CORPORATION and Officer of the State of Florida acting as a licensed
REGISTERED AGENT who knowingly, intentionally, recklessly, and negligently
gave benefit to clergy and willfully and recklessly neglected his DUTY as a
REGISTERED AGENT knowing the CORPORATION OF THE FBCCP and
CORPORATE OFFICERS and MEMBERS were in violations of the Florida
Statues as stated herein. Documents revealed in June 2006, revealed GRANT on
or about 1999, through some yet unknown time, did for pay consult and act on
behalf of the Pastors Schisms to promote the fraudulent VISION and did
knowingly degrade the positions of Townsend as LRPC Chairman alleging frauds
of the VISION and personally refused to require production of the Corporations
financial records demanded in 1997-current times to be seen by this Townsend as
stated herein. GRANT at times material hereto also acted as an elected State of
Florida Congressman. GRANT maintains his office and residence in
Hillsborough County, Florida.
26. DEFENDANTS CHARLES H. SCRUGGS III., (SCRUGGS) Individually,
CHARLES H. SCRUGGS, III. ESQUIRE, As attorney at law, CHARLES H.
SCRUGGS, III, P.A., A Professional Association Law Firm was employed
and retained as Legal Counsel for these Plaintiffs and maintains his

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residence and office and practices law in Hillsborough County, Florida.

SCRUGGS knowingly and intentionally, recklessly and negligently, gave
benefit to clergy over the protection of rights of his own clients and to
protect his personal convictions to not make a church look bad and did
willfully multiple actions of tort and frauds on the courts and willfully
violated his own Clients as the Plaintiffs and is being sued in Hillsborough
County Circuit Court in CASE NO: 05-0911 and 2D06-2811 and as herein.
27. DEFENDANTS HEATHER M. GRAY, (GRAY) Individually, HEATHER
M. GRAY, ATTORNEY AT LAW, HEATHER M. GRAY,
PROFESSIONAL ASSOCIATION AS A FLORIDA CORPORATION,
knowingly and intentionally, recklessly and negligently, gave benefit to
clergy over the protection of rights of her own clients and to protect the
malfeasance and tort actions of the alleged Clergy Ron Beck and of
SCRUGGS to protect his personal convictions to not make a church look
bad and did willfully multiple actions of tort and frauds on the courts and
omissions of truthful disclosure and willfully violated her own Clients these
Plaintiffs and is being sued in Hillsborough County Circuit Court in CASE
NO:06-6005. Gray resides and does business in Hillsborough County, Florida.
28. DEFENDANTS KAREN HARROD TOWNSEND, (KAREN HARROD)
Individually, and as estranged former wife of Plaintiff and mother and former
CPCS school teacher of Plaintiff J.D.T and J.G.T and KAREN HARROD
TOWNSEND AS EMPLOYEE OF CITRUS PARK CHRISTIAN SCHOOL
A MINISTRY OF THE FBCCP and maternal family as STEVEN TYLER

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HARROD, (STEVE HARROD) Individually, DONALD HARROD, (DON

HARROD) Individually, NORMA HARROD, (NORMA HARROD)
Individually and are being sued in Hillsborough County Circuit
Court in case no. 05-9605 with pending Appeals Case 2D06-3469. All
Defendants as Harrod reside in Pace, Florida.
29. UTICA INSURANCE COMPANY OF NEW YORK, (UTICA) AS THE
INSURANCE CARRIER OF AND FOR THE DEFENDANT FBCCP and does
business in the State of Florida and as Insurance Company acted and allowed
agents to act in BAD FAITH and in violations of laws against Plaintiff
Townsend and all Plaintiffs in violations of Duty, Directly, Indirectly and
Derivatively.
30. CHARLES DENNY, IV, Individually, CHARLES DENNY, IV, AS ATTORNEY
AT LAW (Hereinafter as Denny) FOR THE FIRM OF DICKINSON &
GIBBONS P.A., THE LAW FIRM OF DICKINSON & GIBBONS, P.A.
ATTORNEYS AT LAW, (hereinafter as DICKINSON) act jointly and are
doing business at 401 North Cattleman Road, Suite 300, Sarasota, Florida 34232,
and are the attorney for Defendant Ronald L. Beck and Reverend Ronald L. Beck
and the First Baptist Church of Citrus Park. Defendant Charles Denny, IV and the
Firm of Dickinson & Gibbons, as attorneys for the Corporation of the First Baptist
Church of Citrus Park, and by Contract hold a direct and derivative fiduciary duty
to the Plaintiffs at times herein and to Plaintiff Randall Townsend herein as
Plaintiff Randall Townsend is a member of the Congregational Form of
Government as directed by the BY-LAWS of the Corporation of the First Baptist

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Church of Citrus Park and has Duties and Rights as a Member to the Corporation
as defined or stated herein.
Defendants herein this part reside and do business in the State of Florida.
31. DREW GARDNER, AS Individual, DREW GARDNER AS ATTORNEY AT
LAW (Hereinafter as Gardner) FOR THE CHRISTIAN LAW ASSOCIATION
(Hereinafter as CLA) and DAVID GIBBS, III, AS Individual, DAVID GIBBS,
III, AS ATTORNEY AT LAW, THE GIBBS LAW FIRM, and DAVID GIBBS
III, AS ATTORNEY AT LAW for the CLA and per Contract, hold a direct and
derivative fiduciary duty to the Plaintiff Randall Townsend herein as Plaintiff
Randall Townsend is a member of the Congregational Form of Government as
directed by the BY-LAWS of the Corporation of the First Baptist Church of
Citrus Park and with Duties and Rights as a Member to the Corporation as defined
and stated herein and reside in the State of Florida and do business in Florida.
32. STACEY TURMEL, (TURMEL) Individually, STACEY TURMEL ESQUIRE AS
ATTORNEY AT LAW, STACEY TURMEL, P.A. hold a direct and indirect and
derivative fiduciary duty to the Plaintiffs herein and has done by acts in violation
of Duty, done fraud, omissions of truthful disclosure and fraud on the courts.
Defendant Turmel does business and resides in Tampa Florida.
33. MR. CHARLIE CRIST, Individually, MR. CHARLIE CRIST, AS IN THE
OFFICIAL POSITION AS THE ATTORNEY GENERAL FOR THE STATE OF
FLORIDA, and THE OFFICE/DEPARTMENT OF THE ATTORNEY
GENERAL FOR THE STATE OF FLORIDA, and now as Governor of the State
of Florida, held and holds a direct and indirect and derivative fiduciary duty per

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Florida Statues 14.022, 16, 27.36 and 27.37 and 617 and others to the
Plaintiffs herein and has done by acts in violation of Duty, done fraud, omissions
of truthful disclosure and fraud on the courts and has specifically refused directly
to act per Florida Statues 617, 623 and other Statues so required by the
DUTY of the Officer, Individual and/or agent of said Duty. Defendant Crist
resides and does business in and for the State of Florida and refused to act in any
capacity said herein.
34. Mr. TOM GALLAGHER, Individually, MR. TOM GALLAGHER, AS IN THE
OFFICIAL POSITION AS THE CHIEF FINANCIAL OFFICER OF THE
STATE OF FLORIDA DEPARTMENT OF FINANCIAL SERVICES, and THE
DEPARTMENT OF FINANCIAL SERVICES, hold a direct and indirect and
derivative fiduciary duty to the Plaintiffs herein and has done by acts in violation
of Duty, done fraud, omissions of truthful disclosure and fraud on the courts.
Gallagher resides and does business in and for and of the State of Florida.
35. THE DEPARTMENT OF CHILDREN AND FAMILIES OF THE STATE OF
FLORIDA, (DCF) operates and has DUTY within the State of Florida to
investigate and protect all Children of or in this State, and hold a direct and
indirect and derivative fiduciary duty to the Plaintiffs herein and has done by acts
in violation of Duty, done fraud, omissions of truthful disclosure and fraud on the
courts.
36. DAVID GEE, AS SHERIFF OF HILLSBOROUGH COUNTY FLORIDA, and
DEPUTY JOE HOWLETT AND DEPUTY MIKE SMOAK AND DEPUTY
SCOTT WELLINGER, Individually, SCOTT WELLINGER, AS A

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HILLSBOROUGH COUNTY SHERIFF DEPUTY SERGEANT, LUTHER

CORE, Individually, LUTHER CORE AS HILLSBOROUGH COUNTY
SHERIFF DEPUTY DETECTIVE EXECUTIVE SUPPORT DEPARTMENT
INTERNAL AFFAIRS, PAUL J. GUARINO, Individually, PAUL J. GUARINO,
AS HILLSBOROUGH COUNTY SHERIFF DEPUTY SERGEANT
PROPERTY CRIMES UNIT, DEPUTY HARRY HOOVER, Individually,
HARRY HOOVER AS HILLSBOROUGH COUNTY SHERIFF DEPUTY
SERGEANT, AS DEPUTIES OF HILLSBOROUGH COUNTY
SHERIFFS DEPARTMENT AND THE HILLSBOROUGH COUNTY
SHERIFFS DEPARTMENT OF THE STATE OF FLORIDA, and hold a direct
and indirect and derivative fiduciary duty to the Plaintiffs herein and has done by
acts in violation of Duty, done fraud, omissions of truthful disclosure and fraud on
the courts. Defendants herein reside and do business in and of and for the State
Of Florida.
37. JAMES COATS, AS SHERIFF OF PINELLAS COUNTY FLORIDA, and DEPUTY
JOSEPH A. GILLETTEE, SERGENT ADMINISTRATIVE INVESTIGATIONS
DIVISION PINELLAS COUNTY SHERIFFS OFFICE and DEPUTY TIM
JEFFERS and THE PINELLAS COUNTY SHERIFFS DEPARTMENT OF
THE STATE OF FLORIDA, (PSCO), and hold a direct and indirect and
derivative fiduciary duty to the Plaintiffs herein and has done by acts in violation
of Duty, done fraud, omissions of truthful disclosure and fraud on the courts.
Defendants herein reside and do business in and of and for the State Of Florida.
38. BOB WHITE, AS SHERIFF OF PASCO COUNTY FLORIDA, and AS A

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DEPUTY JOHN MICHEAL CORBIN OF PASCO COUNTY FLORIDA and

THE PASCO COUNTY SHERIFFS DEPARTMENT OF THE STATE OF
FLORIDA, (Pasco S.O.) and hold a direct and indirect and derivative fiduciary
duty to the Plaintiffs herein and has done by acts in violation of Duty, done
fraud, omissions of truthful disclosure and fraud on the courts. Defendants herein
reside and do business in and of and for the State Of Florida.
39. THE CHIEF OF POLICE OF TAMPA, FLORIDA, and AS POLICE OFFICER
JOE KAREAS (Kareas) OF THE CITY OF TAMPA, THE CITY OF TAMPA
POLICE DEPARTMENT,(TPD) and hold a direct and indirect and derivative
fiduciary duty to the Plaintiffs herein and has done by acts in violation of Duty,
done fraud, omissions of truthful disclosure and fraud on the courts. Defendants
herein reside and do business in and of and for the State Of Florida.
40. CYNTHIA BARNARD SANZ, Individually, CYNTHIA BARNARD SANZ (Sanz)
AS SPECIAL AGENT SUPERVISION FOR THE FLORIDA DEPARTMENT
OF LAW ENFORCEMENT,(FDLE) hold a direct and indirect and derivative
fiduciary duty to the Plaintiffs herein and has done by acts in violation of Duty,
done fraud, omissions of truthful disclosure and fraud on the courts. Defendants
herein reside and do business in and of and for the State Of Florida.
41. MR. GERALD BAILEY COMMISSIONER, (Bailey), FLORIDA DEPARTMENT
OF LAW ENFORCEMENT, (FDLE) and GUY TUNNELL as Former FDLE
COMMISSIONER and hold a direct and indirect and derivative fiduciary duty to
the Plaintiffs herein and has done by acts in violation of Duty, done fraud,
omissions of truthful disclosure and fraud on the courts. Defendants herein reside

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and do business in and of and for the State Of Florida.

42. CURTIS BAUGHMAN(Baughman) as Individually, NANCY LOPEZ, Individually,
CURTIS BAUGHMAN AND NANCY LOPEZ AS EMPLOYEES OF VICTIMS
ASSISTANCE OF THE STATE ATTORNEY OF FLORIDA,(VA) and hold a
direct and indirect and derivative fiduciary duty to the Plaintiffs herein and has
done by acts in violation of Duty, done fraud, omissions of truthful disclosure and
fraud on the courts. Defendants herein reside and do business in and of and for the
State Of Florida.
43. MARK A. OBER, Individually and MARK A. OBER AS STATE ATTORNEY OF
HILLSBOROUGH COUNTY FLORIDA,(OBER) and hold a direct and indirect
and derivative fiduciary duty to the Plaintiffs herein and has done by acts in
violation of Duty, done fraud, omissions of truthful disclosure and fraud on the
courts.
Defendants herein reside and do business in and of and for the State Of Florida.
44. CHIEF JUDGE MANUEL MENENDEZ JR. OF HILLSBOURGH COUNTY
FLORIDA CIRCUIT CIVIL, MANUEL MENENDEZ JR. Individually, and hold
a direct and indirect and derivative fiduciary duty to the Plaintiffs herein and has
done by acts in violation of Duty, done fraud, omissions of truthful disclosure and
fraud on the courts. Defendants herein reside and do business in and of and for the
State Of Florida.
45. WAYNE TIMMERMAN, Individually, JUDGE WAYNE TIMMERMAN A
CIRCUIT COURT JUDGE OF HILLSBOROUGH COUNTY FLORIDA, and
hold a direct and indirect and derivative fiduciary duty to the Plaintiffs herein

75

and has done by acts in violation of Duty, done fraud, omissions of truthful
disclosure and fraud on the courts. Defendants herein reside and do business in
and of and for the State Of Florida.
46. FRANK GOMEZ, Individually, JUDGE FRANK GOMEZ A CIRCUIT COURT
JUDGE FOR HILLSBOROUGH COUNTY FLORIDA, and hold a direct and
indirect and derivative fiduciary duty to the Plaintiffs herein and has done by acts
in violation of Duty, done fraud, omissions of truthful disclosure and fraud on the
courts. Defendants herein reside and do business in and of and for the State
Of Florida.
47. MONICA SIERRA, Individually, JUDGE MONICA SIERRA, A CIRCUIT COURT
JUDGE FOR HILLSBOROUGH COUNTY FLORIDA, and hold a direct and
indirect and derivative fiduciary duty to the Plaintiffs herein and has done by acts
in violation of Duty, done fraud, omissions of truthful disclosure and fraud on the
courts. Defendants herein reside and do business in and of and for the State
Of Florida.
48. RALPH STODDARD, Individually, JUDGE RALPH STODDARD, A CIRCUIT
COURT JUDGE FOR HILLSBOROUGH COUNTY FLORIDA, and hold a
direct and indirect and derivative fiduciary duty to the Plaintiffs herein and has
done by acts in violation of Duty, done fraud, omissions of truthful disclosure and
fraud on the courts. Defendants herein reside and do business in and of and for the
State Of Florida.
49. GREG HOLDER, Individually, JUDGE GREG HOLDER, A CIRCUIT COURT
JUDGE FOR HILLSBOROUGH COUNTY FLORIDA, and hold a direct and

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indirect and derivative fiduciary duty to the Plaintiffs herein and has done by acts
in violation of Duty, done fraud, omissions of truthful disclosure and fraud on the
courts. Defendants herein reside and do business in and of and for the State
Of Florida.
50. MARVA CRENSHAW, Individually, JUDGE MARVA CRENSHAW, A CIRCUIT
COURT JUDGE FOR HILLSBOROUGH COUNTY FLORIDA, and hold a
direct and indirect and derivative fiduciary duty to the Plaintiffs herein and has
done by acts in violation of Duty, done fraud, omissions of truthful disclosure and
fraud on the courts. Defendants herein reside and do business in and of and for the
State Of Florida.
51. RAUL PALOMINO, Individually, JUDGE RAUL PALOMINO, A CIRCUIT
COURT JUDGE FOR HILLSBOROUGH COUNTY FLORIDA, and hold a
direct and indirect and derivative fiduciary duty to the Plaintiffs herein and has
done by acts in violation of Duty, done fraud, omissions of truthful disclosure and
fraud on the courts as said herein. Defendants herein reside and do business in
and of and for the State Of Florida.
52. RAQUEL A. RODRIQUEZ, Individually, RAQUEL A. RODRIQUEZ AS
GENERAL COUNSEL TO THE OFFICE OF THE GOVERNOR OF THE
STATE OF FLORIDA, and hold a direct and indirect and derivative fiduciary
duty to the Plaintiffs herein and has done by acts in violation of Duty, done
fraud, omissions of truthful disclosure and fraud on the courts as said herein.
And as Counsel to and for the Governor of the State of Florida is to by duty to
properly inform the Governor to and how to investigate or pursue all allegations

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of Criminal acts or violation of laws or policies by any person or persons or of

Corporations or of Law enforcement or of agencies or of Courts of the State of
Florida or doing business in the State of Florida for the safety and well being of
all citizens, especially the children on behalf of whom this Plaintiff speaks.
Defendants herein reside and do business in and of and for the State Of Florida.
53. BROOKE S. KENNERLY, Individually, BROOKE S. KENNERLY AS
EXECUTIVE DIRECTOR FOR THE JUDICIAL QUALIFICATIONS
COMMISSION OF THE STATE OF FLORIDA, and THE JUDICIAL
QUALIFICATIONS COMMISSION OF THE STATE OF FLORIDA, and hold a
direct and indirect and derivative fiduciary duty to the Plaintiffs herein and has
done by acts in violation of Duty, done fraud, omissions of truthful disclosure and
fraud on the courts as said herein.
Defendants herein reside and do business in and of and for the State Of Florida.
54. THE FLORIDA BAR, THE FLORIDA BAR OFFICER OF EXECUTIVE
DIRECTOR, THE FLORIDA BAR OFFICER OF TAMPA BRANCH OFFICE
EXECUTIVE/DISCIPLINE DIRECTOR AS BRANCH STAFF COUNSEL,
THE FLORIDA BAR TAMPA INTAKE STAFF COUNSEL EMPLOYEE,
MS. LIEMAN, MS. DOE LIEMAN, Individually, THE FLORIDA BAR
TAMPA INTAKE STAFF EMPLOYEE MS. JANE CRISTY and Ms. JANE
CRISTY, Individually, and hold a direct and indirect and derivative fiduciary duty
to the Plaintiffs herein and has done by acts in violation of Duty, done fraud,
omissions of truthful disclosure and fraud on the courts as said herein.
Defendants herein reside and do business in and of and for the State Of Florida.

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55. THE STATE OF FLORIDA, and hold a direct and indirect and derivative fiduciary
duty to the Plaintiffs herein and has done by acts in violation of Duty, done
fraud, omissions of truthful disclosure and fraud on the courts as said herein.
56. THE CITY OF TAMPA, and hold a direct and indirect and derivative fiduciary
duty to the Plaintiffs herein and has done by acts in violation of Duty, done
fraud, omissions of truthful disclosure and fraud on the courts as said herein.
57. THE SHERIFF OF SANTA ROSA COUNTY, AND SANTA ROSA COUNTY, OF
THE STATE OF FLORIDA, Deputy Sergeant Wheeler and Detective Ryan
and hold a direct and indirect and derivative fiduciary duty to the Plaintiffs
herein and has done by acts in violation of Duty, done fraud, omissions of truthful
disclosure and fraud on the courts.
55. HILLSBOROUGH COUNTY FLORIDA, OF THE STATE OF FLORIDA, and hold
a direct and indirect and derivative fiduciary duty to the Plaintiffs herein and has
done by acts in violation of Duty, done fraud, omissions of truthful disclosure and
fraud on the courts.
56. KMART CORPORATION also known as and doing business as, SEARS HOLDING
COMPANY, INC is a Corporation doing business in the State of Florida, with a
REGIONAL OFFICE located in Brandon, Florida and the Corporate office at times
material hereto was or is located in the State of Michigan and the State of Illinois, of
these United States Of America and Hereinafter known as (Kmart/Sears).
Kmart/Sears held a duty to Plaintiff as an employee and protections as a whistle
blower from all illegal acts and retaliations due to Plaintiff Townsend acting per
Corporation policies and Laws of this Country, State and County and Plaintiff

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Townsend alleges Kmart/Sears acted in violation of Title VII of the Civil Rights
Act of 1964, and Florida Statues 760.10 and all laws as shown herein by acts of the
Corporation and of the employees in supervision for the Kmart/Sears Corporation and
of other store associates.
57. JOE PALKO, Individual, JOE PALKO, EMPLOYEE AS Vice President (Kmart)
SEARS HOLDING COMPANY, RANDY BRIGHT, Individual, RANDY BRIGHT,
(Kmart) EMPLOYEE AS REGIONAL COACH, KEITH JOHNSON, Individual,
KEITH JOHNSON, (Kmart) EMPLOYEE AS REGIONAL HUMAN RESOURCES
DIRECTOR, SHANE PEARSON, Individual, SHANE PEARSON, (Kmart)
EMPLOYEE AS LOSS PREVENTION DISTRICT COACH, KATHERINE
CUNNINGHAM, Individual, KATHERINE CUNNINGHAM, (Kmart)
EMPLOYEE AS DISTRICT COORDINATOR SECRETARY, DANIEL J.
GENTILE, Individual, DANIEL J. GENTILE, (Kmart) EMPLOYEE AS DISTRICT
COACH, DOUG LIVINGSTON, Individual, DOUG LIVINGSTON, AS KMART
EMPLOYEE LOSS PREVENTION COACH, AT STORE 3092, ROY ALLEN,
Individual, ROY ALLEN, KMART EMPLOYEE AS ASSISTANT COACH, AT
STORE 3092, DR. LINDA ROWE CAMPBELL, Individual, DR. LINDA ROWE
CAMPBELL, (Kmart) EMPLOYEE AS PHARMACIST AT STORE 3092,
BARBARA BOOTH, Individual, BARBARA BOOTH, (Kmart) EMPLOYEE AT
STORE 3092, acted independently, and in conspiracy and intentionally, knowingly,
recklessly and negligently and has done by acts in violation of Duty, done fraud,
omissions of truthful disclosure and done acts in violations of the United States Laws
and State of Florida Laws and Pinellas County Laws and violations of Plaintiff

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Townsends civil rights and subjected Plaintiff Townsend to acts of vandalism and
racial prejudice and fraud and paint the character and image of Plaintiff Townsend in
a bad public light to conspire to conceal the violations of law as advised by Plaintiff
Townsend as a whistle blower and to violate Plaintiff Townsends civil rights.
Defendants reside in the State Of Florida at times material hereto.
FACTUAL ALLEGATIONS
58. PLAINTIFF TOWNSEND INCORPORATES ALL PARAGRAPHS STATED
ABOVE AND BELOW HEREIN AS FACTUAL ALLEGATIONS TO SHOW THIS
COURT AND EACH DEFENDANT TO KNOW THAT THE CAUSE OF THIS
ACTION ARISES FROM A RECKLESS AND INTENTIONAL CONSPIRACY
BY ATTORNEYS, JUDGES OF THE CIRCUIT COURT OF HILLSBOROUGH
COUNTY AND OF THE SECOND DISTRICT COURT OF APPEALS, OF
FLORIDA AND BY EACH INDIVIDUAL, OFFICER IN LAW ENFORCEMENT,
AGENT, AGENCY AND CORPORATION LISTED HEREIN TO CONSPIRE
AND DO BREACH OF DUTY TO CONCEAL PROVED ILLEGAL ACTS OF:
A. RONALD L. BECK as an individual, claiming to act as Clergy of FBCCP and
B. HERMAN MEISTER, an individual, claiming to act as Clergy and BOTH
Who in Breach of Contract, Breach of Trust and other unlawful acts, formed in 1995
a Pastors Schism I to do fraud and omissions of truthful disclosure acting under the
disguise as clergy misusing the Color of Uniform as Clergy and intentionally
knowingly, recklessly and negligently acting with Law enforcement officers acting
as alleged TRUSTEES or various COMMITTEE MEMBERS or Deacons or
as Associate hereinafter as General Members:

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C. JOE HOWLETT, an individual, claiming to act as alleged Trustee and an

Hillsborough County Sheriff Deputy (HCSO) and General Member and
D. TIM JEFFERS, an individual, claiming to act as a Finance Committee Member
and a Pinellas County Sheriff Deputy and TRUSTEE and DEACON and
General member.
E. GEOFF SMITH, an individual, claiming to act as First Baptist Church of Citrus
Park Corporation President/Trustee and as Deacon and as General Member and as
an alleged expert Building Contractor and
F. GARY LEATHERMAN, an individual, claiming to act as First Baptist Church of
Citrus Park Corporation Trustee and as a Deacon and as a General Member and as
an expert in issues of finance and as FINANCE COMMITTEE MEMBER and at
times CHAIRMAN Of the FINANCE COMMITTEE and Member of multiple
Committees at the directive of the Pastor Beck as Plaintiff Townsend alleges Beck
and Leatherman acted with Meister and others to conceal all acts of frauds by the
acting out of the statement made by Herman Meister as School Pastor/Principle in
2002, stating we made a pack to deny and destroy anything you (Randall
Townsend) say and the pack actions provided illusions of security for their act.
G. JOHN MICHAEL CORBIN, an individual, claiming to act as a LONG RANGE
PLANNING COMMITTEE MEMBER and as a Pasco County Sheriff Deputy
and General Member
H. MIKE SMOAK, an individual, claiming to act as a SCHOOL BOARD MEMBER
OF Citrus Park Christian School and as a Hillsborough County Sheriff Deputy as
at the rank of HCSO Detective, and as a General Member and

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I. JOE KAREAS, an individual, claiming to act as a General Member and as a

TAMPA POLICE OFFICER
Or with experts as attorneys, law enforcement, Judges, public Government
officials and others to create a self serving scheme and to violate the
First Baptist Church of Citrus Park Corporation, The General Voting Membership
As these Plaintiffs with vested CONTRACT RIGHTS, DUTIES, OBLIGATIONS
and STANDARDS per the Corporation BY-LAWS, AND AS PASTORS TO
MISUSE THEIR OFFICIAL DUTIES AND COLOR OF UNIFORM OF THE
FIRST BAPTIST CHURCH OF CITRUS PARK FOR UNLAWFUL PRACTICES
AND FRAUDS IN VIOLATION OF FLORIDA STATUES 617 AND DID THE
ACTS OF THE PASTORS SCHISM I with the willful Actions of PASTORS
SCHISM II (as the Pastors with FBCCP ALLEGED Trustees) intending to violate
these Plaintiffs and misuse FBCCP and CPCS and did conspired unlawful ACTIONS
knowingly, intentionally, recklessly and negligently with the Pastors Schisms I & II
to violate the FBCCP CONTRACTUAL BY-LAWS RIGHTS, CPCS ENROLMENT
CONTRACT RIGHTS, THE UNITED STATES OF AMERICA
CONSTITUTIONAL RIGHTS AND THE STATE OF FLORIDA
CONSTITUTIONAL AND STATUES RIGHTS, the MARITAL CONTRACT
AND FAMILY RIGHTS AND due process rights of these Plaintiffs herein.
59. Plaintiffs Duty was/is to per DUTIES OF THE UNITED STATES AND FLORIDA
CONSTITUTION AND CHURCH BY-LAWS and specifically Florida Statues 617 to
Investigate violations of FBCCP BY-LAWS and violations of the Constitutional and
Contract rights of Plaintiffs and other FBCCP members, per Federal and State Statues as

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Florida Statues 895 and who was actually the violator of these Laws for the protection of
the Corporation and know that Plaintiff can prove the case only now with these new facts
to show that every law stated in this document can be proved beyond any shadow of any
doubt to a jury as the trier of facts. The Court Ordered Records, produced in part in
June/July 2006, to Plaintiff for the first time, as FBCCP documents even in part prove all
claims of plaintiffs as when the alleged Schisms I & II, as FBCCP Officers and as Sheriff
Deputies as alleged legal trustees from/about 1996 to present have knowingly,
intentionally, recklessly and negligently conspired and concealed the misuse of funds and
frauds to the Corporation as Proofs of these violations of Criminal laws show Beck and
the Schism and those that concealed Becks frauds and the Schisms members frauds
should get JAIL for the violations of all laws as shown herein as they jointly conspired,
extorted and concealed acts against the rights of this plaintiff Townsend known now as s
still a member of the FBCCP Corporation with all BY-LAWS and Florida Statue
Membership rights and the attempts by alleged Clergy and alleged trustees conspiring
with and by frauds to Plaintiffs, attorneys, Judges and law enforcement led to Plaintiff
Townsend being now since September 8, 1999, being alleged dangerous and a liar
and even threatened with jail on the frauds and collusion of Beck and Leatherman and
Howlett and Jeffers and Karen Harrod Townsend was forced for the safety of the
Townsend Plaintiffs to require Karen Harrod Townsend to leave the marital home or
Plaintiff Townsend be falsely arrested on the now revealed frauds by the Schisms to
conceal the illegal acts of the Schism and others and all Plaintiffs have been damaged due
to the criminal acts, breach of duty and violations specifically of the FBCCP BY-LAWS,
that the disagreement by these alleged clergy and trustee to do illegal acts impeded the

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rights as stated by minor J.G.T. (age 14), on October 20, 1999, in a note left for her father
Plaintiff Townsend when the pastors and deputies and Defendant Karen Harrod
Townsend forced these minor children in the quiet of the night while this father was on
duty as a security officer/supervisor with a Class D license at the Citrus Park Town
Center Mall, to leave the safety of their home in order to promote, conspire with and to
conceal the frauds and omissions of truthful disclosure and criminal acts of the pastors,
deputies, officers and Karen Harrod Townsend and her maternal family as Harrods and
other FBCCP and CPCS employees as stated and incorporated herein to keep Plaintiff
Townsend from his rights as a parent, guardian, church member to speak on behalf of
himself and others as stated herein to expose the frauds stated by alleged Clergy and
Trustees and Karen Harrod Townsend and others.
Dad,
Please dont be mad at us! I dont know what other option I/we have. Its
not fair just not 2 C mome either! N- ways well C U soon + well give U a
call later! OK? Take Care of Peaches, Whisper (family cats) + Shaddow
(family dog). Jason needs U 2 set up his bunk-bed in his room, If not well
get it later + set up the dinette set in the kitchen too!
- U ~ C-U Soon
- Jen
And that the causation of these frauds and omissions of truthful disclosure upon Plaintiffs
were by intentional means of extortion and direct violation of the FBCCP BY-LAWS to
not breach the Duty and Family Rights of any member and Plaintiff Townsend and other
Plaintiffs have been caused to fear for their safety due to fraud by alleged trustees,
pastors miss-using their mask as clergy, lawyers, judges and deputies allegedly acting
within their alleged legal duty or lack of duty or jurisdiction but all for the good of the
Plaintiffs and others, instead while using their masks to perform and conceal criminal
Acts as Plaintiff Townsend alleged on September 8, 1999, now fully confirmed by the

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June/July 2006 FBCCP Produced Documents and shows most if not all statements by
Beck and Karen Harrod Townsend made to each court, attorney and law enforcement
officer to be intentional filing of false reports to law enforcement or courts to tamper with
witnesses and obstruct justice as shown herein in direct violation of FBCCP BY-LAWS
Sections in full and incorporated herein and specifically as stated:
(A) CHURCH POLICIES D. COMMITTEE RESPONSIBILITIES AND POLICIES
10. FINANCE. j) A detailed and comprehensive report of all receipts and
disbursements, balances, etc., of the Church and the Christian School, shall be given
at the quarterly business meeting in writing. Assets and liabilities are to be reported
once a year. k) There shall be an annual audit, under the supervision of the Finance
Committee, of all books pertaining to Church and School funds, and a report made to
the Church each July. l) No purchase shall be made by members of the Church,
Christian school, departments or organizations, except within the limits of the budget
and approved by the Finance Committee or Business Administrator.
Plaintiff Townsend in the positions of Nominations Committee, Awana Commander,
Budget Committee Contributor, Long Range Planning Committee Chairman and
others demanded financial responsibility per the terms of the BY-LAWS, on a daily,
monthly and on a Long Term Plan for the completion of the Monthly expenses to
support budgeted policy and to complete the expected $10,000,000.00 Building and
Growth Plan but experienced continues frauds of the pastors and finance committee
members Leatherman, and Jeffers and others and these partially produced documents
of June/July 2006, per the Court ORDER of May 10, 2006, of Judge Crenshaw
shows the frauds known by the Finance Committee and Pastors as Plaintiff
Townsend alleged in the 1990s through current times as many reports are still being
concealed from this member in defiance even to the courts ORDER to conceal
additional fraud and omission of truthful disclosure and misappropriation of
corporate opportunity especially proved to date by: (1) the fraud in the purchase and

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attempted uses of the new property located at 18105 North Gunn Highway, Tampa
Florida and (2) in the FBCCP Corporation Financial Reports, (3) CREDIT CARD
uses and (4) frauds of non reporting these purchases not within the allowed DUTY of
the Pastor as Ron Beck such as expenses at major and expensive restaurants, trips, or
other charges that were made and not reported which (5) eliminated funds for
purchases of properly approved items and services.
Further, these excessive and unreported credit card charges, misappropriation of
corporate opportunities and other non reported purchases placed the Corporation in a
position to require debt or delay to complete necessary projects or purchases per the
duties of these Officers in protection of the total ministry view to quote from the
September 13, 1999, letter of Beck, writing,
The ministry decisions made have been and will continue to be made with a total
ministry view.
Plaintiff alleged this was pure fraud and omission of truthful disclosure to conceal his
breach and frauds of his self dealing now just revealed by the Credit Card statements
and the theft of the Awana Property and the frauds of why the Church HAD to
purchase the Earl property and home just so the Ron Beck daughters could have
more bathrooms and have a larger parsonage and could live in the country.
Plaintiff Townsend alleges that had these June/July 2006, Records been produced on
September 8, 1999, AS DEMANDED in SHOW ME THE MONEY that the
inducement to fraud the wife Karen Harrod Townsend, the Plaintiff Minor Children
J.D.T and J.G.T and other Church and School members and employees against
Randall Townsend would not have been allowed by honorable family and church

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members and therefore the position of Karen Harrod Townsend on October 10, 1999,
stating how can you be so right and these other six men be so wrong and thereby
calling Randall Townsend a liar in his own kitchen and thereby requiring a marital
turmoil based on fraudulent advice of the alleged honorable pastors and trustees and
finance committee members using the withheld documents to conceal ongoing frauds
enticing false accusations by the nave against this Plaintiff Townsend still to this
day because of fraud of alleged Clergy as Schism being given unlawful Benefit
by the Corporation Registered Agent, Lawyers, Judges and Law Enforce and State
Officials. This turmoil caused by the actions of the alleged Pastors and Trustees
caused the allegations of Irreconcilable Differences leading to and being used in the
Divorce Case filed by Karen Harrod Townsend in April 2002. Upon Service of the
Divorce Action, Plaintiff Townsend did file case 02-03812, to try to expose the
underlying violations of LAWS and BY-LAWS and thereby save his marriage, safety
of the mental, emotional and well being of the wife and children and others and
expose the frauds of the Schism and stated these issues and requested assistance in the
Circuit Court as had been done to the Court of Judge Palomino by filing a
COMPLAINT as per the rules as a short and plain statement Case as 02-30812, as
follows:
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT,

IN AND FOR HILLSBOROUGH COUNTY, FLORIDA

CASE NO._02-03812
RANDALL TOWNSEND,
PLAINTIFF,
v.
RONALD L. BECK, INDIVIDUALLY, REVERAND RONALD L. BECK,
AS SENIOR PASTOR, FIRST BAPTIST CHURCH OF CITRUS PARK,
(FBCCP) WILLIAM T. BROWN, INDIVIDUALLY, REVERAND WILLIAM T.
BROWN, (FBCCP) AS PASTOR OF ADMINISTRATION, HERMAN MEISTER,

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INDIVIDUALLY, REVERAND HERMAN MEISTER, AS PASTOR OF SCHOOL

MINISTRIES (CPCS), GARY LEATHERMAN, INDIVIDUALLY, GARY
LEATHERMAN, AS TRUSTEE, (FBCCP) ROBERT GILES, INDIVIDUALLY,
ROBERT GILES, AS MEMBER OF PERSONNEL COMMITTEE, (FBCCP) TIM
JEFFERS, INDIVIDUALLY, TIM JEFFERS, AS FINANCE COMMITTEE
MEMBER, MARK NUNES, INDIVIDUALLY, MARK NUNES, AS CHAIRMAN OF
DEACONS, 1999-2000 (FBCCP) MIKE SHUMATE, INDIVIDUALLY, MIKE
SHUMANTE, AS CHAIRMAN OF DEACONS, 2000-2001. (FBCCP) JOE
HOWLETT, INDIVIDUALLY, JOE HOWLETT, AS TRUSTEE, (FBCCP), GEOFF
SMITH, INDIVIDUALLY, GEOFF SMITH, AS CORPORATION PRESIDENT,
(FBCCP),THE MEMBERSHIP AT LARGE OF d/b/a,FIRST BAPTIST CHURCH OF
CITRUS PARK,
AS DEFENDANTS,
___________________________________________/
COMPLAINT AND DEMAND FOR JURY TRIAL
COMES NOW, RANDALL TOWNSEND, PRO SE, and sues
RONALD L. BECK, INDIVIDUALLY, REVERAND RONALD L. BECK, AS
SENIOR PASTOR OF THE FIRST BAPTIST CHURCH OF CITRUS PARK,
(HEREINAFTER AS FBCCP, WILLIAM T. BROWN, INDIVIDUALLY,
REVERAND WILLIAM T. BROWN, AS PASTOR OF ADMINISTRATION, FBCCP,
HERMAN MEISTER, INDIVIDUALLY, HERMAN MEISTER AS PASTOR OF
SCHOOL MINISTRIES (CPCS), GARY LEATHERMAN, INDIVIDUALLY, GARY
LEATHERMAN, AS TRUSTEE , DEACON AND MEMBER OF PERSONNEL
COMMITTEE OF FBCCP, ROBERT GILES, INDIVIDUALLY, ROBERT GILES, AS
MEMBER OF PERSONNEL COMMITTEE, DEACON,FBCCP, TIM JEFFERS,
INDIVIDUALLY, TIM JEFFERS, AS FINANCE COMMITTEE MEMBER, DEACON
MARK NUNES, INDIVIDUALLY, MARK NUNES, AS CHAIRMAN OF FBCCP
DEACONS, 1999-2000, MIKE SHUMATE, INDIVIDUALLY, MIKE SHUMANTE,
AS CHAIRMAN OF FBCCP DEACONS, 2000-, JOE HOWLETT, INDIVIDUALLY,
JOE HOWLETT, AS FBCCP TRUSTEE, GEOFF SMITH, INDIVIDUALLY, GEOFF
SMITH, AS FBCCP CORPORATION PRESIDENT, DEACON, DR. LON LYNN,
INDIVIDUALLY, DR. LON LYNN, AS DR LON LYNN M.D., THE MEMBERSHIP
AND DEACONS/OFFICERS, AS d/b/a FIRST BAPTIST CHURCH OF CITRUS
PARK, A FLORIDA CORPORATION, AND CITRUS PARK CHRISTIAN SCHOOL,
AS A MINISTRY OF FIRST BAPTIST CHURCH OF CITRUS PARK and alleges:
GENERAL ALLEGATIONS
1. This is an action for damages in excess of $25,000.00.
2. At times material herein, Plaintiff resides in Hillsborough County, Florida.
3. Defendants, reside principally in Hillsborough County, Florida and d/b/a
FBCCP in Hillsborough, County, Florida.
4. At times material hereto, Defendants were to serve and protect the interests of
this Plaintiff pursuant to the Florida Statues (herein after F.S.) in full and specifically
F.S.607; F.S. 817; F.S. 836; F.S. 772.102 points (16,- F.S. 812, theft, related crimes),
(18,- F.S. 817,fraud and credit card crimes) (22,- F.S. 836.05, extortion) (23, - F.S. 837,
perjury), (25. F.S. 843 obstruction of justice); as such practices show a pattern as per F.S.
772.102(4) (Pattern of Criminal Activity). F.S. 871.01&.02(Disturbing Religious and

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other assemblies) and protecting the granted rights of Plaintiff while as a Church
Member, Per the CONSTITUTION AND BY-LAWS of the FBCCP Corporation, as
attached herein and provide due care in protection of this Plaintiff from harm to his
family, integrity, character and emotional well being of this Plaintiff and Plaintiffs
family
5. At times material hereto, Plaintiff was a member in good standing and had
duties per the FLORIDA STATUES, THE FBCCP CONSTITUTION AND FBCCP BYLAWS TO REPORT VIOLATIONS OF SAID POLICIES AND PROCEEDURES
CONTAINTED THEREIN.
6. At times material hereto, Plaintiff became aware of violations of these peace
protecting governing laws, policies and procedures by the FBCCP SENIOR PASTOR
Reverend RONALD L. BECK and Reverend WILLIAM BROWN III and Reverend
Herman Meister. And Plaintiff did per F.S.607.1603 as member of FBCCP and as Chair
of Long Range Planning Committee requested review of Corporation records when
Plaintiff had reason to believe F.S. 607.1620(1) were violated. Plaintiff also had duty to
report other acts of Negligence and Frauds.
7. Plaintiff was serving as (1). Chairman of the Long Range Planning
Committee, a Church By-Law appointed committee responsible for the growth and
expansion of Church services and ministry projects, (2). Member of the Nominating
Committee, a Church By-Law appointed committee responsible for staffing persons in
leadership roles who did not violate Code of Ethics and Morals as stated in the ByLaws and Statement of Faith and Commitment to Serve and CPCS SCHOOL
HANDBOOK (3). AWANA COMMANDER, a Church By-Law appointed position
responsible for the leadership of Leaders and Children in ministry care, (4). Assistant
Head Usher, A Church appointed position for service to the membership, (5) Fill in
Sunday School Teacher, (6) Parent of two children of the Citrus Park Christian School,
(7) Husband of an Employee teacher in Citrus Park Christian School.
8. Plaintiff alleges acts of Ronald L. Beck were outside of the scope of his
professional duties as Pastor of FBCCP and as a Director of the Said Corporation and
these acts were some if not all retaliations for Plaintiff trying to follow the Florida
Statues and By-Laws and in following said codes my good standing proved his
negligence and violations of same.
9. Defendants acting outside of the scope of enacting Florida Statues and
FBCCP Constitution and By-laws thus requires personable liability for their
actions to cause intentional harm upon this Plaintiff and his family per F.S. 607 & 772
and all other available Florida Statues.
10. Thus upon knowledge of said acts of the FBCCP Leadership, Defendants had
a fiduciary duty to constrain Ronald L. Beck, individually, William Brown III,
individually, Herman Meister, individually, and as Pastors and prevent these actions
from causing and inflicting intentional harm, with malice upon Plaintiff and Plaintiffs
family as Defendant Ronald L. Beck and William Brown III and Herman Meister, and
Gary Leatherman, individually and as Officers of the Corporation and others conspired to
cover up his acts which violated the Florida Statues and FBCCP Policies and Procedures
as stated in FBCCP CONSTITUTION AND BY-LAWS and CPCS Handbook.
11. Plaintiff alleges acts of William Brown III were outside of the scope of his
professional duties as a Pastor of FBCCP and upon knowledge of said acts the Defendant

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Leadership had a fiduciary duty to constrain William Brown III and prevent his actions
from causing and inflicting intentional harm with malice upon Plaintiff and Plaintiffs
family
12. Defendant William Brown III, individually conspired to cover up his acts
which violated the Florida Statues and FBCCP Policies and Procedures as stated
in FBCCP CONSTITUTION and BY-Laws.
13. In coersion Ronald L. Beck, William Brown, III, Herman Meister, Tim
Jeffers, Mike Shumate, Joe Howlett and Gary Leatherman did jointly and independently
conspire to tamper with fact finding and cover up evidence and tamper and
intimidate with witnesses in order to Obstruct Justice.
14. Plaintiff and Defendants observed multiple misstatements of facts by Ron
Beck including:
a.
the unreported special money accounts not included in the Corporation
financial statements
b.
his using deception that the report submitted was true
c.
calling Plaintiff a sower of discord in the April 27, 2000 meeting
before the deacon board
d.
calling Plaintiff a liar in the April 27, 2000 meeting before the
deacon board.
e.
Alleging Plaintiff had a stress related breakdown
f.
Alleging Plaintiff was potentially violent in the meeting on April 27,
2000, before the deacon board
g.
Alleging Plaintiff was sowing discord when Plaintiff pointed out
Ron Beck for his own sole personal betterment stole a microphone from the
Awana Childrens Designated ministry use
h.
Alleging Plaintiff was wrong for speaking up and rebuking a Pastor
who per Pastor allegedly had the right to take property designated when Pastor
said he did not have money to buy his own.
i.
Alleging Plaintiff was sowing discord when Plaintiff alleged that
had all monies been reported, sufficient money was available to buy a new
microphone rather than waste money on having the property rekeyed or
buildings remodeled.
15.
Plaintiff on or about July/August, 1999, observed William Brown III in an
immoral act upon Plaintiffs wife.
16. Plaintiff observed multiple acts of negligence and fraud by William Brown III
, which compromised the safety and wellbeing of minors in the care
of Plaintiff as Awana Commander. Such acts Defendant Brown agreed would be done
prior to the arrival of the Awana children so their safety was not in danger. These agreed
tasks included:
a.
moving a lattice piece of furniture from the Fellowship hall which did in
the Awana meeting in August 1999, fall on a 3 year old child.
b.
Setting up space for the Awana children to meet with proper chairs and
tables free from harmful objects
c.
When said tasks were not completed Defendant Brown did with FRAUD
blame others when the facts later proved Defendant Brown said he forgot to advise
others in his care to perform the duties he had promised to perform for the safety of the

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Awana Children.
17.
When the agreed conduct was not done by Defendant Brown, Brown
determined to commit fraud that he did not keep safe the welfare of the children
and others.
18. On multiple occasions Plaintiff witnessed acts of Defendant Brown which
violated trust and compromised safety of the Awana children to the degree that his
conduct must be stopped in order to protect the children from actual harms and future
harms.
One specific act included requiring approximately 45 Awana children and
adults to ride in a bus that did not have insurance, a proper license tag, and had been
reported to have faulty brakes and clutch. This despite the fact that Defendant Brown and
Defendant Beck had notification for each day of that week that said bus would be used
for the Awana Camping trip.
19. When Plaintiff rebuked Defendant Brown for his violations Defendant Ron
Beck and other Defendants willfully label Plaintiff as sowing discord and willfully
added additional duress on Plaintiff and his family as extortions for Plaintiff to keep quiet
about all the violations by the Pastors.
20. Said acts of extortion and witness tampering include:
a.
Defendant Ron Beck telling a Hillsborough Sheriff Deputy to keep
Plaintiff away from the Property by giving False statements to a Deputy
b.
Defendants from the Church stage will advise the congregation that
Plaintiff is a liar
c.
Defendants institute fear in others who do not know the truth and
Defendants advise others Plaintiff is Potentially Violent and Dangerous to
their safety
d.
Defendants illegally using the Church By-laws voted and did expel
Plaintiff from the membership
e.
Defendants did use fraud to the membership and misused the wording in a
letter written by other pastors in an effort to get Ron Beck from continuing his
abuse to say Plaintiff resigned his membership from the FBCCP
f.
Defendant Ron Beck informed others if Plaintiff was seen on the property
he (Ron Beck as pastor) had to be notified immediately and Defendant Ron Beck
informed Plaintiff if seen on the property he Ron Beck would have Plaintiff
arrested for trespassing.
g.
On or about July, 2001, Defendant received a Church Bulletin as an
SPECIAL INVITATION FROM SEVERAL CHURCH MEMBERS to attend a
Special Business Meeting to discuss the Defendant William Brown III keeping his
leadership position but Defendant Ron Beck wrote to Plaintiff to not speak at said
meeting and advised Plaintiff in said letter that If Plaintiff tried to speak he would
be arrested under Florida Statues 871
h.
When Plaintiff arrived in a civil manner and waited on the public sidewalk
until the meeting was to start, Plaintiff was informed by Defendants Joe Howlett
an HCSO, Tim Jeffers, a PCSO, and Mike Shumate, as Chairman of the Deacons,
Plaintiff was not allowed to enter the property.
i.
Defendants did even taunt Plaintiff to enter knowing instructions were
given in the yet not received letter that entering would allow Joe Howlett as
HCSO to arrest Plaintiff in order to keep Plaintiff from releasing key information

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to the congregation. Defendants also blocked Plaintiff from civil speaking to his
own wife as she exited the meeting.
j.
Said acts as they did happen were later intentionally and with malice
misrepresented to the Honorable Judge Palomino by Defendant Ron Beck in
Plaintiffs trial on Repeated Violence and Stalking Charges brought by
Defendant Ron Beck. Judge Palomino dismissed the charges.
k.
Plaintiff alleges that Defendant Ron Beck has used his wife and daughters
in deceptions in order to assert additional frauds to others unknowing citizens and
including Judge Palomino on November 15, 2001, which represented Plaintiff as
a potentially violent person said daughters should be and are afraid of Plaintiff.
l.
Plaintiff alleges that the acts of Defendant Ron Beck and other Defendants
of warning of trespassing, the warning letter of July 2001, and the Charges of
Repeated Violence and Stalking are EXTORTIONS causing great Duress on
Plaintiff and also are OBSTRUCTIONS OF JUSTICE which deny Plaintiff the
safety and protection his Constitutional rights to Life, Liberty and the pursuit of
Happiness. These acts also allow the violations of Defendants to keep hid and
do not allow Plaintiff to regain his integrity that was stolen and slandered by
Defendants and or allow the Plaintiff to be able to reunite Plaintiff family who
now is faced with Divorce due to the stress of this matter.
m.
Defendants repeatedly making false statements to Plaintiffs wife and
children regarding the conduct of Plaintiff and Plaintiffs account of facts. Said
communications are evidence in letters, tape messages and in the transcript before
Judge Palomino on November 15, 2001
20.
At last , on January 14, 2002, Plaintiff was advised by Principle/Pastor
Herman Meister that Plaintiffs daughter, Jennifer was directed to seek medical
examinations due to her excessively missing school and physical complaints of
migraines and stomach conditions.
21.
Plaintiff alleges that as attending physician for (Wife) Karen and
(Daughter) Jennifer Townsend, also acting as Citrus Park Christian School
recommended Doctor that Dr. Lon Lynn and CPCS were negligent in not acting sooner
upon receipt of Plaintiffs registered letter notifying said parties of Plaintiffs concerns of
physical harms and depression being experienced by wife Karen and child Jennifer
Townsend. Such duress is witnessed by the missing of school concern by Herman
Meister finally addressed in 2002..
22.
Such pain and duress and harm was due to the intentional lying and fraud
coverup by Ron Beck and others listed as they continued to harm Plaintiff and Plaintiffs
family with the shame as stated.
COUNT ONE : INTENTIONAL INFLICTION OF EMOTIONAL DURESS
23.
Plaintiff reaffirms and includes all points above and herein and alleges:
24.
In order to cover up the trail of sins/acts and the exposure of these acts
listed in points above Ron Beck did on September 8, 1999, terminate Plaintiff from all
volunteer positions of his duties to FBCCP and Citrus Park Christian School
25. Such act of termination of duty was to express the power of a Senior
Pastor over the matter in order to Obstruct Justice and Obstruct obedience to the Florida
Statues and Church By-Laws and shame Plaintiff into not being able to report
misconduct.

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COUNT TWO:
DEFEMATION OF CHARACTER
26.
Plaintiff reaffirms and includes all points above and herein and alleges:
27.
Wherefore, Plaintiff contends said acts reported above herein were
malicious and deliberate acts with the intent of the termination to show others
that Plaintiff was unfit for service due to some special powers and special
knowledge as a Pastor, Ron Beck held in confidence and could not repeat due to
his calling which allegedly allows him not to with facts release his secrets.
Plaintiff alleges the acts of Ron Beck individually, were intentionally covered by
the role of Pastor Ron Beck so as to defame the character of Plaintiff so the acts
of Ron Beck, individual and as Pastor Ron Beck would not be told to the Church
Body who may find his services did violate the Florida Statues and Church Bylaws.
28. Plaintiff alleges that said acts were done with intended malice and with the
intent to defame Plaintiff so any and all charges by Plaintiff would be disgraced
as just false accusations of a stressed out member seeking revenge.
Wherefore Plaintiff prays for relief as this court seems just.
COUNT THREE: LIBEL
Plaintiff reaffirms and includes all points above and herein and alleges:
29.
Defendant Ron Beck as Pastor has used letters and multiple verbal
messages that harms the integrity of Plaintiff by stating Plaintiff is not right with
God.
30. Said statement is used by Defendant Ron Beck to again assert some
special knowledge he says his Pastor position gives him but said statement has no
basis for fact of truthfulness.
31. Said statement is for the purpose of continuing the damage to plaintiffs
integrity so acts of Ron Beck will not be exposed.
COUNT FOUR:
SLANDER
32.
Plaintiff reaffirms and includes all points above and herein and alleges
33.
Statement in April 27, 2000, Deacons meeting that Plaintiff was sowing
discord made by Ron Beck was injurious to Plaintiff for the purpose of disproving the
facts trying to be exposed about the illegal conduct of the Defendants, Beck, Meister,
Brown, Leatherman, and Jeffers and intended to make other deacons in the room who had
little or no knowledge of the truth of the previous challenges but drop all suspicions and
discredit Plaintiff.
34. Plaintiff alleges that on April 27, 2000, Defendants did yell out keep your
hands on the table when Plaintiff reached for his Bible which had been placed on the
floor. Said Bible contained Plaintiffs outline of matters that needed to be asked from the
Defendants in front of the Deacons as a Disciplinary Review Board.
COUNT FIVE:
NEGLIGENCE IN CARE OF A MINORS
35.
Plaintiff reaffirms and includes all above points herein and states:
36.
Said act of not removing lattice furniture from Fellowship hall prior to
meeting of Awana Children was agreed to be done by William Brown III, Herman
Meister, and Ron Beck all on the day of the meeting but said act was not
Performed.
37. Said act not being performed was a pattern of acts not performed based on
promises made to keep safe the Children and harm did happen to an innocent little

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girl. Plaintiff was required to take the blame for the act to the little girl and accept
the wrath of the father of the little girl on behalf of the Church. Said act was due
to the intentional negligence and patterns of unkept promises consistently being
broken by the Pastors.
COUNT SIX:
NEGLIGENCE IN CARE OF JENNIFER
TOWNSEND, A MINOR
36.
Plaintiff reaffirms and includes all above points herein and alleges:
37.
Defendants were advised of harm being intentionally done by Ron Beck
causing unnecessary pains and stress on a minor Jennifer, daughter of Plaintiff,
because actions of Ron Beck and Herman Meister were putting her in multiple
shamful and shameful situations because of the false charges being told about her
father this Plaintiff.
38. Plaintiff repeatedly asked for Defendants to do their By-laws and
professional duty to investigate all the facts and then stop the wrongful
abuse on Plaintiff and thus stop the shame on Plaintiff.
39. Plaintiff alleges that Dr. Lon Lynn did delay the proper remedy available
to Jennifer due to his attempting to cover up the acts done by Defendants
wrongfully accusing Plaintiff. Said attempt to just ignore the reported
problems including eating disorders and stress related problems did as
reported by other doctors add to the harm of Jennifer.
COUNT SEVEN: DEFEMATION OF CHARACTER
40.
Plaintiff reaffirms and includes all points above and herein and alleges:
41.
On or about November 2001, Defendant Ron Beck did file and affidavit
with the Court containing fraudulent statement as date known and location of
employment and other statements said in the court which were intended to
charge Plaintiff with REPEATED VIOLENCE and STALKING
42. Said charges were made with malice in order to tamper with the position
of the court against Plaintiff and as to keep Plaintiff from his family rights
43. And as to keep Plaintiff from speaking to other Church or School
members and thus keep the violations of Florida Statues and By-laws from
being exposed.
44. Said attempt at the restraining order was an additional attempt to block the
discovery and pursuit of facts required in protection for this suit at hand.
45. Wherefore, Plaintiff prays this court will allow F. S. 772.104 and F.S. 772.11
and F.S. 772.185 and any and all other remedies available to this court to benefit
Plaintiff as redress for the harms caused by these Defendants.
COUNT EIGHT: INJUNCTIVE RELIEF
46.
Plaintiff re-allege and includes all points herein and alleges;
47. Wherefore, Plaintiff prays for Court ordered support of all discovery of
documents, financial and Business Meeting Minutes being hid by the Defendants
as officers of the Corporation and needed to prove Plaintiffs issues for this Court.
44.
Wherefore, Plaintiff prays that this Honorable Court will immediately
direct all Defendants to stop retaliations against Plaintiffs family since turning
the other cheek now for many years has not stopped these Defendants from their
abuses and misuse of power
45.
Seal this complaint and all issues with a gag order and hold all issues with

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secrecy so no additional damages will be done for all parties involved.

Wherefore, Plaintiff prays this Honorable court will:
a. award Compensatory damages, Punitive damages and Treble damages and
b.
direct the Secretary of State and or Hillsborough County Sheriff to
review the licensees and actions of these Pastors and Defendants for their roles in
obstruction of the Florida Statues.
c. allow a Jury Trial on all issues before this Court
d.
Grant Plaintiff such other relief as this Court seems just and proper.
Respectfully submitted,
Randall C. Townsend, Pro Se
P.O. Box 21,
Odessa, Fl. 33556
813 920-9633
By:_____________
Randall C. Townsend
Certificate of Service
I hereby certify that a copy of the foregoing was provided by U.S. Mail this
__25__ day of April 2002, to First Baptist Church Citrus Park as Corporation and as said
members as Defendants at 7705 Gunn Hwy. Tampa, Florida, 33625.
______signed_________
Randall Townsend
This Complaint in January 2003, was Ruled by Judge Arnold to Amend the
Complaint and did not dismiss the litigation and this Ruling by Judge Arnold was
immediately given to and completely informed attorney Scruggs who was to litigate and
defend Townsend and all persons for whom Townsend spoke in this case and the 024974, Divorce Case on or about during January 2003, to Judge Timmerman and thereby
the ruling of Judge Arnold a new Amended Complaint was filed and Plaintiff Townsend
added a Count for Malicious Prosecution. Based on the fraud of case law by Attorney
Denny, Judge Crenshaw dismissed all counts except the count of Malicious Prosecution.
Judge Crenshaw with her rulings of March 1, 2006 through September 22, 2006, became
aware of her participation and fraud on the Plaintiffs and violations of the rights of these
Plaintiffs to present a case and however recused herself rather than Sanction Defendants
as shown herein and said action was again an extension of the Benefit of Clergy Law.

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(B) PROHIBITS THE SCHISM USING VIOLATIONS OF FAMILY MEMBERS

CONSTITUTIONAL AND STATE RIGHTS AND BY-LAWS RIGHTS IN:
Article III (Membership) Sec. 7. Discipline of a Member.
(A) There shall be a Discipline Committee consisting of the Pastors and the Board
of Deacons. These men shall have sole authority in determining heretical
deviations from the Statements of Faith and violations of the Church Covenant.
If the Pastor or a deacon is subject of a disciplinary matter, he shall not sit as
member of the Discipline Committee. He shall be entitled to the same steps as
other Church members and be subject to the same discipline.
(B) Members are expected to demonstrate special loyalty and concern for one
another. When a member becomes aware of an offense of such magnitude that
it hinders spiritual growth and testimony, he is to go alone to the offending party
and seek to restore his brother. Before he goes, he should first examine himself.
When he goes, he should go with a spirit of humility and have the goal of
restoration.
(C) If reconciliation is not reached, a second member, either a deacon or the Pastor
is to accompany the one seeking to resolve the matter. This second step should
also be preceded by self- examination, and exercised in a spirit of humility with
the goal of restoration.
(D) If the matter is still unresolved after the steps outlined in subsections (B) and
(C) have been taken, the Discipline Committee, as the Church representatives
biblically responsible for putting down murmuring, shall hear the matter. If the
matter is not resolved during the hearing before the Discipline Committee, the
Committee shall recommend to the Church that they, after self-examination,
make an effort personally to go to the offending member and seek that
members restoration.
(E) If the matter is still unresolved after the steps outlined in subsections (B), (C),
and (D) have been taken, such members who refuse to repent and be restored
are to be removed from the membership of the Church upon a majority vote of
the membership present at a meeting called for the purpose of considering
disciplinary action.
(F) No matter may be heard by the Discipline Committee or the Church, unless
steps outlined in subsections (B) and (C) have been taken, except in the case of
a public offense.
(G) If an unrepentant offending party is removed from the Church membership, all
contact with him from that point forward must be for the sake of restoration
(except family members).
Plaintiff Townsend alleges that the Pastors, Trustees and Select Associates and officers
did knowingly, intentionally, willingly and recklessly violate the BY-LAWS Contract
Process and did intentionally ignore the claims of Plaintiff Townsend and did give

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benefit of clergy privilege to the now proved unfounded allegations by the Schism in
order to benefit themselves and did use extortion of the Townsend family members in the
scheme to continue the acts of the schism and violations of their respective Contract(s)
and or Constitutional duties.
Plaintiff Townsend did by verbal and written actions and even sneaking into the January
2000, Business Meeting and did inform and announce:
In tonights sermon you stated many people who in exercising their faith stood
alone. With Regret I have to tonight go public. I must continue to follow through with
the road outlined this summer by Gary Brown in his Sunday School Lessons, How to
Reduce Conflicts. As a leader appointed by the Church to serve I by Gods Grace went
to two Brothers Buddy Rawls and Gary Leatherman about a series of matters that needed
fact finding service, Grace with Salt in my one on one attempts to resolve Church
matters. I followed Scripture. On 9/8 I was accused falsely by Pastors who acted without
the full facts. Since that time Matt 18 has continually been ignored.
Also the matters are not resolved but continue to harm the name of Christ.
Since Pastor Beck says He is too busy to resolve these matters I would appreciate
this Body of Christ guide me to a person or persons to hear the matters per Step 2 of
Matt18.
As this step followed the BY-LAWS and the Moderator of the January 2000, Business
Meeting Ron Beck did allege even multiple frauds and acts and directed Randall
Townsend to bring the matter to the PERSONNEL COMMITTEE (PC) for determination
rather than convene the CHURCH DISCIPLINE COMMITTEE (CDC) to investigate the
Allegations for or against Townsend and further upon review of the actions by the
Personnel Committee(PC). Said members report that Gary Leatherman as member of the
PC did conduct the process and did practice fraud, omissions, concealment with the PC,
admitted by Chairman Jim Leahy and therefore Plaintiff Townsend alleges fraud and
omissions of truthful disclosure and breach of contract from the PC in the reports given to
Plaintiffs, the Townsend family, Deacons, and the General Voting Members and others.
Plaintiff Townsend further alleges that until review of the Business Meeting Minutes of

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April 30, 2000, Townsend could not plead to the Deacons yet at previous times or at the
April 2000, (due to threats and allegations of slander and breach of contract process in the
meeting by Howlett, Jeffers, Giles and Beck), Deacons Discipline Committee Meeting as
even stated on April 30, 2000, by Mike Shumate as Chairman of the Deacons per the
June/July 2006, BUSINESS MEETING RECORDS was not ready to announce findings
to the General Voting Members as due to the fraud and omissions of truthful disclosure
and breach of contract of the Schism even the Deacons were being placed in breach of
Contract and as Townsend could not plead to the Church Discipline Committee all
matters against the Schism and thereby the Schism continued their frauds as reported
herein and specifically in the letter of Ron Beck of June 16, 2000, stating:
Randy:
I was truly grieved to receive your recent response to my letter to notify you of
the Deacons decision to accept your withdrawal from our membership.
In your response you state that the action taken by the deacons to remove you from
membership was invalid.
I sense some real confusion on your part, so please allow me to share with you just how
valid their decision was.
First of all, what you may not understand is that the deacons were not acting simply as a
body of deacons, but as Church Discipline Committee. According to our church
bylaws, page 10, Discipline of a Member: These men(the Discipline Committee) shall
have sole authority in determining heretical deviations from the statement of Faith, and
violations of the Church Covenant. The Church Covenant is found on page 12, and
as an unruly brother you are in multiple violations of that covenant.
Secondly, you yourself sent a letter by a church member to read to the Discipline
Committee requesting your membership be removed. I cannot find anywhere in our
church bylaws where that requires a church vote to be valid.
So, to say that the letter I sent you was invalid, and to say that the Discipline
Committees vote was invalid is incorrect.
You had a right to know that you have been removed from membership and that was the
purpose of the letter.
Therefore, per your request, and the unanimous decision of the Church Discipline
Committee, you are no longer a member of the First Baptist Church of Citrus Park.
Sincerely,
(Signed)
Ron Beck

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Sr. Pastor
P.S. Although I did not give you permission to make copies and distribute my previous
letter, you have my permission to distribute this letter to whomever you like.
Further, upon publication of this letter to the General Voting Members and to the
Deacons said deacons and General Voting Members further gave Benefit to Clergy and
continues the frauds and Breach of Contract and Trust and Omissions of truthful
disclosure and the extortion against the Townsend family and Plaintiffs as stated herein.
(C) Article V, Section 4. BUSINESS MEETINGS (b)Due notice and substance of
the meeting shall be given publicly from the pulpit, the Church Bulletin, or the
Church newsletter (The Focus) at least 7 days preceding the date of the meeting.
Plaintiff Townsend alleges the BY-LAWS ARTICLE III, Process was not followed and
the Pastors and Trustees and Deacons intentionally, knowingly, negligently and
recklessly violated the BY-LAWS and until partial production of documents in June/July
2006, Plaintiffs have not been allowed BY-LAWS rights to know said rights or actions or
to speak to protect from abuse these innocent children or protect their rights because of
car chases and physical treats and even pastors assisting Karen Harrod Townsend in
moving from the marital family residence in secret from Randall Townsend to induce
fear and speculation and slander against Randall Townsend, thus assisting the scheme
of the Schism and this act was and is in no way an act allowed by the BY-LAWS as an
act of restoration but an act of fraud, breach of contract, breach of trust, omissions of
truthful disclosure and seeking an opportunity to deprive persons of the Plaintiffs and of
the FBCCP Corporation while the schism alleged to act honorably.
(D) (d) The government of the Church shall be vested in the hands of the members, and
a majority vote of those present and voting shall be effective to bind the Church
(except in calling a Pastor or Staff Minister, or in effecting a change in the BY Laws,
Constitution or Policies, where a 2/3 majority of those present and voting is needed).
By Townsend being denied/delayed in court, slandered, held hostage, or abused by

100

Deputies Howlett, Jeffers, Smoak, Kieras, Corbin and others and as confirmed by the
under oath testimony of Beck to Judge Palomino on November 15, 2001, Case 01-15813,
and per the Federal Express Package and Letter Sent to Plaintiff Townsend of July 26,
2001, on FBCCP letterhead stating:
Mr. Randy Townsend:
This letter is in response to your fax dated 7/24/01.
We have never excluded anyone from worshipping here at 1st Baptist Citrus Park.
If you desire to attend this Sunday evenings service and worship with the
members here you are more than welcomed to do so.
Let me make some corrections, however, to some of your comments contained
within your fax.
First of all, the business meetings of 1st Baptist Church of Citrus Park are not
PUBLIC Business meetings as you stated in your fax. What this means is that
although visitors are welcomed to attend our business meetings, they will not be
given the floor for discussion in the meeting as that is a privilege reserved for the
membership of the church.
If a visitor attempts to speak, or in any way disrupts the business meeting, they
will be escorted from the building and the property.
Enclosed you will find a statutory law that prohibits the disruption of Church
meetings.
Secondly, as far as walking the aisle and joining the church so that you can speak,
that also is not an option. Randy, you are out of fellowship with this Pastoral
Staff, Deacon body, and Church membership, so taking that action is not possible
either. In addition, your letter of request for removing your membership is on
file, and was approved unanimously by the church body.
I continue to pray for your reconciliation with God and your family. These two
things are much more important than speaking in a business meeting.
Sincerely,
(signed)
Ron Beck
Attachment
Florida Criminal and Vehicle Handbook page 932, published by J.B. Gould,
Printed in the U.S.A @2000,
CHAPTER 871
DISTURBING RELIGIOUS AND OTHER ASSEMBLIES
(Complete Chapter)
This letter revoked again the rights of Plaintiff Townsend and for who Townsend
attempted to speak as on the agenda announced in the Church Bulletin of July 22, 2001,
the announcement stated;

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Quarterly Business Meeting

Sunday, July 29,
After the evening service
Voting on Pastor Bill Brown
Finance will be giving the end of the year report
And Plaintiff had been specifically invited to attend by several people to get in the
public view many issues being concealed and even Buddy Rawls walked across the
street and handed the July 22, 2001, Bulletin to Townsend so he would attend but then
was battered and the wife was battered and the Townsend children and others were
battered as reported 11/01, by Beck in his own words to the court, verbal and affidavits.
As Scruggs did nothing to make the church look bad during the 11/15/01, and then
thereafter did exparte actions with Judge Palomino and other judges as Timmerman with
Stacy Turmel in the Divorce Action filed by Karen Harrod Townsend to conceal truth
from the Courts and his clients now these Plaintiffs as Turmel when confronted by her
frauds to the courts demanded sanctions against Townsend for playing attorney and
allegedly not filing for an ORDER OF REFERRAL TO THE GENERAL MASTER
when this ORDER had been presented to Judge Gomez but for the frauds to conceal the
actions of Timmerman, Scruggs and Gray, Judge Gomez has his Judicial Assistant, Mrs
Gunn, quietly without explanation or ruling of Judge Gomez return the Motion to
Plaintiff Townsend and stated the Judge said he had no jurisdiction because the matter
was in the appeals court. And as further evidence of extrinsic fraud Judge Gomez
recusing himself because of his Exparte actions with Scruggs and frauds on the Court not
to reveal fraud on the Court by his refusal to Apply the ORDER OF REFERRAL TO
THE GENERAL MASTER while the case was passed from Judge Timmerman to Gomez
said in agreement with Attorney Stanford Solomon in the Hearing of August 16, 2004, in

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the Townsend v. Townsend case no 02-4974, stating:

PAGE 7And there is no such thing as a limited appearance; once you are in, you are in.
So, I sent my documents to her as the lawyer for fear that Mr. Townsend would be
concerned or would lodge some complaint to some authority some place, maybe the
Attorney General, maybe the Bar, maybe the Court, maybe with somebody that he was
being contacted directly and he was represented by counsel. Other than that, I dont
know what he is talking about.
Yet at the next hearing 10/12/04, on case 02-4974, Stanford Solomon knowing he
assisted Gray, Scruggs and Harrods in fraud uses the limited appearance argument and
Judge Sierra is negligent in not even have been given the Court files from the Clerks
office but again shows prejudice, bias, fraudulent application of the rule of law and
violation of Civil Rules of Procedure and violation of the rights of Plaintiffs and grants a
complete release for the fraudulent and contempt of and frauds on the courts done by the
actions of Stanford Solomon concealing frauds of himself, and his fellow attorneys and
judges and of his clients, Karen Harrod Townsend as or in all roles (wife, former wife,
mother, FBCCP employee, FBCCP member, Plaintiff, Defendant, as presented in the
action of case 05-9605, ruled as Res Judicata by Judge Holder and again herein this now
Federal Action proving the frauds of Scruggs ran from June/July 2000, to present times
and tainted evidence, attorneys, Judges and the reputation of the entire court system of
Hillsborough County and the 2 DCA, the Florida Bar, the JQC and each State or County
agency or agent for whom Scruggs, Grant, Gibbs, Gardner, Gray, Denny and Rolfes
intentionally acted for or against to oppose the Plaintiffs herein of the rights and
jurisdiction issues even stated by Stanford Solomon to the DUTY of the Florida Bar,
THE JUDICIAL QUALIFICATIONS COMMITTEE, THE ATTORNEY GENERAL
OR ANOTHER COURT or any state agency and even Judge Gomez out of fear of breach

103

of rules of law and under the RULES OF ETHICS recused himself because he was on a
NOTICE OF APPEARANCE and as was also on the same NOTICE OF APPEARANCE,
.
Was served AS:

IN THE CIRCUIT COURT OF THE THIRTEENTH

JUDICIAL CIRCUIT, IN AND FOR HILLSBOROUGH
COUNTY, FLORIDA
CASE NO.__02-4974_
IN RE: THE MARRIAGE OF
KAREN HARROD TOWNSEND,
Petitioner/Wife,
And
RANDALL C. TOWNSEND
Respondent/Husband
___________________________________________/
NOTICE OF HEARING
TO: Charles W. Denny, IV
Ronald L. Beck
1750 Ringling Blvd.
First Baptist Church of Citrus Park
Sarasota, FL 34236
15305 Heathridge Drive, 7705 Gunn Hwy
Tampa, Fl 33625
The Membership At Large
Of the First Baptist Church
Of Citrus Park, Incorporated
7705 Gunn Highway
Tampa, Florida 33625

Stacey Turmel, Esquire

2124 West Kennedy Blvd
Suite A
Tampa, Florida 33060

Stanford R. Solomon, Esquire

Charles Scruggs, Esquire
400 North Ashley Plaza Suite 3000 419 West Platt Street
Tampa, Florida 33602
Tampa, Florida 33606
Heather Gray, Esquire
P.O. Box 2668
Riverview, Florida 33568

Karen Harrod Townsend

3109 Able Avenue
Pace, Florida 32571-9514

District Court of Appeals

P.O. Box 327
Lakeland, Florida 33802

Curtis Baughman Victims Asst.

800 East Twiggs Street
Tampa, Florida 33602

Legal Affairs Office Of

Attorney General
2002 N. Lois Avenue
Tampa, Florida 33602

Mark Ober, Esquire

State Attorneys Office
800 East Twiggs Street
Tampa, Florida 33602

Honorable Judge

Honorable Judge
104

Marva Crenshaw
800 East Twiggs
Room 519
Tampa, Florida 33602

Frank Gomez
800 East Twiggs
Room 429
Tampa, Florida 33602

Honorable Judge
Raul Palomino
800 East Twiggs Street
Tampa, Florida 33602

Honorable Judge
James Arnold
800 East Twiggs Street
Tampa, Florida 33602

Judge Wayne Timmerman

800 East Twiggs Street
Tampa, Florida 33602

Clerk of the Court, Family Law

800 East Twiggs, Fourth floor
Tampa, Florida 33602

PLEASE TAKE NOTICE that the undersigned will call up for hearing:
ISSUE:
Motion for Contempt Of Court And Sanctions
Judge:
Honorable FRANK GOMEZ
Date/Time: August 16, 2004
10: 00 AM
And by this NOTICE OF HEARING AND THE ACTION OF JUDGE GOMEZ TO:
(1) Recuse himself and (2) suggest the RULES OF ETHICS barred him hearing any
matters then the Second District Court of Appeals, Judge Crenshaw, and Judge Arnold
and others were also placed on legal NOTICE sufficient to require their immediate Duty,
response, presence in the Court or Recusal of the Courts but rather Judges of the 2DCA,
even acted on cases 02-4974 as Townsend v. Townsend, 02-03812 as Townsend v. Beck,
and on 05-0911, as Townsend v. Scruggs, to contain, conceal and do frauds on the Courts
as did Judge Crenshaw and Arnold to continue and limit and harm the RIGHTS of
Plaintiffs as stated herein.
Judge Sierra, knowingly, intentionally, recklessly and fraudulently refused the multiple
Motions, Letters, Request for Hearings, Petitions, Pleading of respondent turned Plaintiff
Townsend and refused to get involved in the 02-4974 Case until late 2005, when Judge
Sierra would only Rule for a Mediator to intervene so the Garnishments would be

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stopped as the Garnishment payment per the Ruling of Judge Timmerman for the alleged
owed back child support had been overpaid but Judge Sierra, refused and still refuses to
be involved so as directed by the Clerk of the Family Court and of the Civil Court the
matters were filed in case 05-9605, in Circuit Civil and in blind rotation assigned to
Judge Holder as Judge Crenshaw refused to allow the cases to be enjoined just as Judge
Sierra had refused to enjoin the Cases 02-4974 and 02-03812, as they stemmed from 0115813 and 01-15814 continuing issues and all issues as incorporated and included herein.
Plaintiffs states, this non-membership, stalking or not stalking and rights of a
father/citizen/honorable person role or RIGHT was an element of material fact in
the ruling of Judge Palomino in 2001, and known as Rule of Law by Former
Judge/Attorney Scruggs and withheld as a Right from Townsend by sheriff deputies
posing as Trustees, Attorneys, Judges and others of alleged Law enforcement and State
Agencies and that himself, Denny admitted to Judge Arnold, January 2003, he was there
representing all members being paid by people, agencies, Corporations who also owed
a DUTY to all General Membership one of which is to Plaintiff Townsend and for
those who Plaintiff Townsend speaks to stop the still ongoing Breach of Contract ad
Breach of Trust and misappropriation of their or the Corporate opportunity,
abuse/battery and violations of law and rules of law and as shown and proved now
by transcripts and various other letters provided and filed as EXHIBITS in Complaints
02-03812, 02-4974, 05-911, 05-9605, and 06-6005, by threats of arrest/Jail for attempting
to speak at the Church Business Meeting the fulfillment of the extortion with malice
shows concealment of the rights to expose violations of Laws, By-Laws and contracts as
fully stated herein and thus lead to the damages therefrom by these associates/

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officers. These issues of material facts were not revealed until the June/July 2006,
Production of FBCCP Business Meeting records which reveal truth of the allegations
stated by Plaintiff Townsend since 1995 or before to the FBCCP and to the Courts.
(E) (e) All members of the Church shall be entitled to vote in the Church business
meetings---each member being entitled to one vote. Any member may make
motions, or discuss motions, upon recognition of the Moderator. All motions from
the floor, unless deemed necessary by the Moderator, must be referred to the proper
committee for consideration and presented for action at the next business meeting.
The June/July 2006 partial production of 1995-Present FBCCP Corporation requested
records until revealed to Plaintiff Townsend could not and do not let Plaintiff
Townsend as Individual or in all his positions illegally removed from in violation of
frauds by the Schisms or the estranged wife could not (1) vote, (2) know what to vote
on, (3) Be present to hear Motions of fraud of the Schism, Schism alleged experts
brought in by the Schism for concealment of and or validation of Schism Motions
and or General Others from the Floor to Make Motions or ask questions (4) inform
other how to be informed for their vote from this Plaintiff Townsend as the Officer of
the positions as stated herein and concealment by the Schism is a violation of the BYLAWS and violation of the rights of these plaintiffs as voting members and from the
words of BECK the Moderator of the April 30, 2000, Business Meeting, deprive the
Associate General Members from the reports they came to hear on what Townsend
had allegedly done in violation of civil or criminal law, so to prevent Townsend
from revealing the findings from the allegations made in the January 2000,
Business Meeting and at other times in the faxes, letters, and verbal discussions as
Beck said to Judge Palomino the stack of papers are all lies but now proved
every point is truth.

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Or due to reckless and intentional Breach of Duty, Breach of Contract and

violations of Law, by Attorney John A. Grant Jr. (as FBCCP Register Agent), and
Attorney David Gibbs, III as FBCCP Corporation Attorney, Hillsborough Sheriffs
Deputies, The Florida State Attorneys Offices, The State of Florida Department of
Education, Deacons and/or others herein as DOE giving UNLAWFUL Benefit of
Clergy and not responding to the Allegations by Plaintiff Townsend on or before
April 30, 2000, to be present for the false testimony given to the General Voting
Members by the collusion of Leatherman, Beck , Meister, Howlett, and Jeffers in the
alleged true editing of the statements made by Plaintiff Townsend in the prior January
2000, Quarterly Business Meeting or multiple letters, subsequent statements or to
allow Plaintiff Townsend to defend himself or be present when the attempted acts of
fraud and slander were used by Beck and the Schism to excommunicate or vote
out Plaintiff Townsend from the membership by illegal means in violations of BYLAWS ARTICLE III. Section 7 (A)-(G) and said actions were unlawful per Florida
Statues process and also used as to cause fear and fraud to the General Voting
Members as plaintiffs herein as these Schism members held Plaintiff Townsend
across the street from the meeting in public disgrace and view and in violation of
Plaintiffs rights of Notice of the Meeting and Right to hear the accusations made
against him and confront facts to false pretenses in violation of Fourth Amendment
Rights and 617 F.S. and Civil Rights and BY-LAWS Rights.
Further, in the April 30, 2000, Business Meeting, Schism members did advise the
General Voting Member of parts and information learned from the Janssen & Horgan
C.P.A. auditor findings and that did then prove allegations Plaintiff Townsend

108

could have proved in said meeting as proofs of previous and current allegations and
also addressed the April 30, 2000, knowing, intentional, reckless and negligent of
Schism members in collusion even in said meeting to deprive the General Voting
Members/Associates from illegally divesting themselves and other associates of
designated funds and tuitions previously given to the plans of the Vision I and
now the newly presented Vision III now as a plan to abandon the Sanctuary first
plan as presented April 16, 1996, to now the new plan of Sports Complex for the
School as presented by CPCS Pastor/Principle Herman Meister.
The Schism and others knowing Plaintiff Townsends:
A. Reputation, Integrity, Leadership, Experience and Growing Up in the Keystone Area
since the Early 1960s and reputation of the Townsend Name even as nephew of
the Pastor of the Founding Church Odessa Baptist from back in the 1940s, and
B. prior statements to the Knowledge of Plaintiff Townsend in 1993, as to why these
Deacons, (Bates, Rawls, Smith, Kerns,) and Former Retiring Pastor Dr. Harold
Warner (even admitting to Randall Townsend he felt safe retiring because of Randy
being in the leadership of the transition of the Church) and Officers and Pastor Dr.
John Berry, Pastor Elbert Nasworthy and Pastor Bill Brown all approached,
encouraged and by Church Vote at multiple times from or about 1994-current had
elected Randall Townsend to the positions of leadership as LRPC Member and then
elected Chairman by the LRPC Committee and Awana Commander and Nomination
Committee Member, Sunday School Teacher, Soccer Coach, and multiple other
positions and even as a Community leader and representative of FBCCP at multiple
County Planning and Special Event Meetings being promoted as the Church Expert to

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the General Voting Members, To the LRPC Committee and to the AD HOC
Committee of Pastors Beck, Meister, Nasworthy, and Members Duane Milford,
Robert Giles, Frank Edwards, and alleged Trustees Geoff Smith, Gary Leatherman
and Joe Howlett and to the LRPC Committee and to Jack Bentley as the Realtor,
stating to not buy the Earl Property at 18015 N. Gunn Highway and that the 18105
Gunn Highway property had too many issues and listed these issues as entry
ways, Environmental Radon Testing, Lead Base and Lead Dust and Asbestos and
EPC and SwiftMud, Timing and Costs and Community issues including traffic and
the Keystone Park Civic Association and the Sierra Club and local residents in past
years of fighting Hillsborough County Schools and Business and the State of Florida
Department of Transportation from encroaching into the area and again at that time
not promoting using or developing the 18105 N. Gunn Highway Property but rather
expanding at 7705 Gunn Highway and currently at that time alleged the permitting
would not be allowed as Plaintiff Townsend had previously warned even in the
Fourth Quarter Business Meeting of July 28, 1996, page 6, and in the LONG
RANGE PLANNING COMMITTEE MEETING AGENDA FOR SUNDAY,
JANUARY 5, 1997 AFTER EVENING SERVICE, stating:
We must answer these questions before any steps can be started.
1. How many people do we need to seat in a worship service or school
assembly?
2. How many students do we need to seat in a Sunday School by ages and room
size?
3. BY school classroom?
4. BY Awana sessions?
5. How many people do we need to seat in a fellowship environment?
6. Do we need a gym?
7. With the above seating needs how many parking spaces are required?
8. What offices or management spaces are needed?
9. What spaces are needed for transition and greeting areas?

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Further, This Agenda was repeated by Ron Beck, by his written presentation in the
Hand OUT to the Long Range Planning Committee on the agenda for Tuesday,
October 28, 1997, stated:
Responsibility of this Committee:
This committee is responsible for developing a Church Master Plot Plan and
making necessary recommendations for additional facilities or existing facility
changes.
Lets break this down:
1. Develop a Church Master Plot Plan (should cover the next 3-10 years)
2. Make necessary Recommendations for Additional facilities.
3. Make necessary Recommendations for Existing facility changes.
Further, Beck to called a Church wide special business Meeting to hire Carl
Doozan and the handout stated the following:
Special Called Business Meeting for Sunday March 22, 1998,
Phase I Building Committee will bring a recommendation in our Special Called
Business Meeting to bring Carl Doozan as our Phase I Architect.
The following information is what Carl will be doing for the building project.
1. Programming/Data Gathering- This will be primarily done by the church
through the Long Range Planning Committee; consists of verbal description
for each area of the ministry, space and equipment requirements, priorities,
etc; information is then communicated to the Architect for clarification and
evaluation.
2. Site Analysis-
3. Graphic Interpretation of Program-
4. Schematic Site Studies-
5. Presentation drawing-
Car Doozan Requires a Fee of $7,500.00 for the planning services outlines above.
An initial Payment of $1,000.00 is requested with subsequent payments due as the
work progresses. Printing and reproductions will be reimbursable.
For future budgeting, the architectural fees for design and construction drawings
will range from 4% to 6% of construction costs depending on the scope of
services rendered.
C. And per Pastors Ron Becks, Elbert Nasworthys and Randall Townsends as
Chairman of the Long Range Planning Committee with approval of said and others
statements and questions presented before the General Voting Members the General

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Voting Members with the intentionally planned creation of the Phase One Committee
and the planned and conspired departure of Randall Townsend by the SCHISM, the
Business Meeting Records reveal the frauds, omissions of truthful disclosure, breach
of trust, breach of contract and conspiracy of the Schism in the FBCCP Business
Meetings of:
1. MARCH 24, 1996:
A. Announced in the Church Bulleting as follows:
SPECIAL INFORMATION MEETING
Let me encourage you to be here this evening, not only for the preaching,
but also for a Special Informational meeting we will be having after the
service. The purpose for this meeting will be to inform the Church Family
on two recommendations that will be voted on in a special called business
meeting next Sunday evening, March 31st. Pastor Meister will be bringing
a recommendation from the Steering & Building & Grounds Committees;
and there will be a recommendation from the Long Range Planning
Committee. We will not be conducting business at the meeting tonight,
just giving our the information and taking questions and discussion on
each recommendation. The actual vote will be taken in the Special called
business meeting next Sunday evening, March 31st.
Please be in prayer each day this week as to how God would have you
vote.
Sharing & Caring
Pastor
B. The 18 page, HAND OUT OF THE INTRODUCTION TO COGAN
CONTRACT states in part as follows:
THE COGAN APPROACH
The Cogan Approach is a two-step process in which the following
is to be accomplished:
STEP I
A) A plot study and master plan, if necessary, for maximum land
utilization.
B) Space feasibility studies, as required for Christian education, worship,
or fellowship, including present and future space requirement.
C) Conceptual drawings, including floor plans, elevations and
specifications.
D) Contract governmental agencies regarding current code regulations
pertinent to the development of conceptual drawings for the building.

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E) Financial feasibility study including analysis of historical data,

projection of future needs and capabilities, and estimates of building
budget and total project budget requirements.
F) Assist in presenting the results of the preliminary studies and applying
for approval from hierarchal persons or board.
G) Negotiate arrangements for all necessary surveys describing the
physical characteristics, soil reports and sub-surface investigations,
legal limitations, utility locations, and a legal description; formal site
development plans if required by government authorities. Our fee for
this work will be 10 of each invoice.
H) Provide all necessary construction cost estimating and value
engineering services to price design options to obtain the most cost
efficient structure in the design of an affordable facility.
I) Provide a Firm Price for construction drawings as well as the actual
construction itself.
J) Facilitate the building committee review process.
STEP II
WHAT OUR PHASE I ADDRESSES WITH YOU
I. A. WHAT ARE OUR CURRENT SPATIAL REQUIREMENTS?
B. WHAT IS OUR HISTORICAL EXPERIENCE OF GROWTH?
C. WHERE ARE OUR MISSION/MINISTRY EMPHASES?
D. WHAT IS OUR CURRENT FINANCIAL PICTURE,
SPECIFICALLY?
1. Building Fund
2. Undesignated Savings
3. Designated Cash- on hand
4. Equity in Assets
5. Debt and Liquidation Programs
6. Operating Expense Requirements.
E. IF WE ARE ABLE TO BUILD, SHOULD WE?
F. IF WE DECIDE TO BUILD, HOW MUCH SHOULD IT COST?
II.
A. WHAT IS OUR VISION FOR US IN RELATION TO ITEMS
ABOVE?
III.
A. WHAT IS OUR PROJECTED INCOME POTENTIAL?
FROM WHAT SOURCES?
B. WHAT FUNDING METHODS OR COMBINATIONS WILL
WORK FOR US AND ARE CONSISTENT WITH OUR
MISSION AND PHILOSOPHY?
C. HOW MUCH WILL WE NEED TO RAISE? WHEN?
D. WHAT CAN WE AFFORD TO BUILD?
E. CAN WE ACTUALLY BUILD WHAT WE NEED? WHAT?
WHEN?
F. HOW SOON CAN WE START AND WHEN CAN WE
OCCUPY?
G. WHAT WILL WE BE ABLE TO BUILD?

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1. Land usage.
2. Planning Board Rules.
3. Zoning.
4. Building Codes.
5. Permits
6. Highway/Street Departments.
7. EPA & Health Depts
8. Other Regulatory Agencies
9. Specifications
10. Engineering & Design
11. Assurances
12. Architectural Style
13. Participation by Us.
14. Water Management Agencies.
H. HOW WILL WE PRESENT/CONVINCE?
1. Hierarchy (if any)
2. Congregation
3. Funding Sources.
IV.
DURING THIS PROCESS WE WILL ADDRESS ALL
CONCERNS RELATED TO..
SUMMARY:
These items are addressed as the work is carried out by the Cogan
Team in cooperation with the Church Leadership being served. The
Church may be required to supply land surveys, drawings of existing
buildings, etc. as well as basic financial data. The execution of PART I
represents a commitment on the part of Cogan and the Church to Cogan
Team concept to design and build a facility that meets the ministry needs
of the Church as well as the budget which includes PART II.
Plaintiff Townsend states that the above COGAN Document represents as PROOF for
each General Voting Member (Associate), Pastor, Trustee, or other Officer or of any
School Parent, or Government Agency, or Law Enforcement Officer specific rules,
guidelines, Duties, Knowledge of said Duties, and shows Breach of said Duties by failure
to act, or by tort or negligent of duty or fraud or omissions of truthful disclosure
of said truthful data or facts and or breach of trust by violation of said reckless acts
therein or proof of appropriation or misappropriation of corporate opportunity of said
actions per the Duties listed in the Florida Statues stated herein and specifically of Florida
Statues 617 and shows violations of Government, Government Officials and Agencies,

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Law Enforcement and Courts and Attorneys to assist General Voting Members
(Associates) or these Plaintiffs who desire to be truthful and dutiful to the Constitutions,
State Laws and FBCCP BY-LAWS as stated herein.
2. The transcript of the March 31, 1996, Business Meeting is as follows:
Jerry Miller- Is this going to be a complete study for everything, sanctuary,
education, growing, school?
Pastor Beck- Yes. Everything we can possibly do.
Ruth Gough-Is it still in our plans to buy additional property around the
church?
Pastor Beck- We are always looking, and we have really been praying about
the school across the street. Were praying the will go some place else and
that would be perfect. It was a decision before I came, to keep our eyes on the
lots in the back of the church. We have already gone out and asked out how
much they would sell the property of the Day Care. Brother Windy Bennett,
and a couple of lots next to our soccer field. None of these decisions will be
made without taking to the Body.
Bill Schwab-Were there any other companies or any other way considered of
doing this?
Pastor Nasworthy-Yes. The Long Range Planning Committee contacted the
Florida Baptist Convention and their Architectural Department and had a
meeting with Russell Hughes about a month ago. Randy Townsend had a
meeting with him, and I was in part of that meeting also. We also contacted
the Southern Baptist Convention and there Architectural Department up in
Nashville. In both of those cases they were available to us, but they
recommended a firm such as Cogan to come and to the type of study that
needs to be done. The study part is the key thing right now. Those types of
services are also available and their fees would approximately be the same as
Cogans fee. The reason for Cogan is that they are local and they are at our
disposal at any time. If we were dealing with someone from out of state or
out of town, there could be delays in meeting and things.
Judy Hopkins-Are you saying they will tell us what they feel is best for us to
do, and bring it back, and we may or may not decide to stay here?
Pastor Beck-The idea here is not for them to tell us what they think is best for
us. When they get to the end of Phase One, they will tell us just what the
county can let you do. Lets say they get to Phase One, and lets say, we do
vote to have a sanctuary, to get it back off that four-lane highway, and the
County said I am sorry you are only permitted to build a 600 seat auditorium.
Well, there would not be wisdom in that. We have a 450 seat auditorium.
Unless you build at least twice the size of what you already have, the
authorities (whoever they are) tell us that is not right to do that. They will
come with answers. Can you do it? They want us to do the best thing we can

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do. The majority of those we will be working with are born again Christians
in Cogan. The founder himself is born again Christian and also Dan Maddox.
He and his quartet will be singing at our June 30 Patriotic Rally, loves the
Lord; just a tremendous guy. I feel a confidence when I am working with
Christians.
Gene Priddy - Cogan Industry is building a church over on Casey Road if you
would like to see it.
Tammy Nunes How many phases are there?
Pastor Nasworthy- Two phases. A step one to determine what your need is
and the feasibility of it. Step two is actually developing that need, or that
feasibility, into a building plan and getting it quoted and built.
Tammy Nunes-Adding to Bill Schwabs question, did we look inside the
church for people that do that kind of work?
Pastor Nasworthy- No
Pastor Beck- If there is somebody that does that type of work, please give us a
call this week. We pretty much know most of the people in our church and
dont know of anybody that is in that type of situation
Frank Edwards- Will we be looking at demographics of the area and then
overlaying those demographics against what our current property would hold
and how will that have a bearing.
Pastor Nasworthy- Yes. Demographics will play into this. We can tell you the
Hillsborough County Projection. We are in the fastest growing area of the
County. There is not other area that is growing faster than this.
Len Zyki Are they going to do that study also?
Pastor Nasworthy- They will make us aware of that information. When you
say the word study, it means they are going to go out and actually do
something on the street. They are going to generate the information for us and
make the committee aware of it. If you do Phase One properly, you can
determine from your past and previous years against your current year. You
can start to project out with your demographics. You can project out ,
basically, what you anticipate you basic membership should be-all things
equal, given a certain point of time in the future, and you will be plus or minus
some percentage. They will be able to do that, yes.
Len Zyki- What does Phase One address?
Pastor Nasworthy- Look on you hand out at Roman numeral one and A,B,C
and probably D. Yes, that has been done. The Long Range Planning
Committee through the leadership of Randy Townsend as the chairman has
assigned different areas of responsibility to different members, who have gone
out and asked these questions. (This was done before Cogan was in mind and
will be shared with Cogan.)
Lyn Zyki-?
Pastor Nasworthy-Right now I could not comment on it. Its a work in
progress. There are probable some things that we might say. We all knre
that, and then there might be some other things that we will say, Wow! I
had know idea. But it has not been correlated in one report yet.

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Bill Sherman- So far, is there any other location that would be more favorable
to relocating our ministry?
Pastor Nasworthy- There have been other pieces of property in Citrus Park
area and in this part of the immediate county that have been identified as
property, but knot knowing what our total acreage deed (need) might be, there
is nothing bee homed in on. There is no certain piece of property out there
that is said, that would be a great place to go. We know there is property out
there just as you well know.
Pastor Beck- Some time ago I asked Pastor Nasworthy to touch base with
several places that were for sale that we might get a ballpark figure as to how
much it would be per acre, so he did that like for instance, off Van Dyke Road
and some places off of Hutchinson, so we could have some idea what land
might cost us. We are waiting for June settlement to know where we are
financially and what we need to do.
Jim Kerns-What is the time frame for them to complete Phase One?
Pastor Nasworthy- They will go real rapidly. This process will go probably in
a period of about two-months, may be three at the outside. They will know
pretty quick. The reason they can; this committee has done a good job in
preparing for this type of process with anybody, so they are really ahead of the
game.
Pastor Beck- I asked that question myself and Dan stated, We can go as
quick as the church wants to go, or as slow as they want to go, to get through
Phase One.
Jim Kerns- What kind of answer is that? You pay someone $5,000.00, you
want an answer quick.
Pastor Beck-Sometime working with Church, some of them say, we do not
want you to go too fast. Then they change their mind during mid stream on
they want to do. He said, We do it all. We work with your Committees and
Pastors and facilities. He did not give; if takes one month it takes two
months. We work as fast as we can meet with your people. It depends on
how quick we can get together with him. Like we said, we wish he could
have been here tonight. He had another commitment tonight.
Gene Priddy- I believe it takes an expert opinion, and you pay for that.
Ed Hopkins- I believe we should get an expert opinion, but also I believe we
should put this out to bid, because there is more than one company that can
build a church. And I know you said we are not locked into this. There are
some wonderful church building companies that some of us have experienced
with.
Pastor Beck- Let me encourage you, Brother Ed, If you have some names and
phone numbers that you could give our church office, so that we could contact
those companies. Like we said we are not locked in this Phase Two with
them. We are only contracting them to do Phase One. Somebody has to do
that, and I have confidence that Cogan Industries can do a good job with that
much like Brother Priddy said. And I appreciate him sharing that.
Plaintiff Townsend states that despite this plan presented by Beck and Nasworthy to this

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Plaintiff and to the General Voting Member never at any time was the written Report of
Cogan Industries shown to Plaintiff Townsend as the Chairman of the Long Range
Planning Committee nor was this plan shown to the General Voting Members or to the
Phase One Committee during or up until September 8, 1999.
Plaintiff Townsend alleges that this Phase One Plan of Cogan Industries was held private
by the Pastors and Schism to conceal fraud and omissions of the schism.
3. APRIL 14, 1996, PASTORS, COMMITTEE AND DEPARTMENT HEAD
AND GENERAL MEMBER MEETING WITH DAN MADDOX OF COGAN
INDUSTRIESWHERE (30) PERSONS STATED THOUGHTS.
Pastor Beck- Sanctuary improvements, Improve High School, Nursery, Stay
at Current Site.
Gary Leatherman- Central Office, Better use of space/rooms, High school.
Donnie & Cyndi Beck - Sound Proof Choir, Larger Robe changing rooms,
Welcome area, acoustical choir loft, multipurpose
space 500 seat room.
Joe Gough- other property we have out grown
Jim Bates- Prioritize all wishing, more storage areas, *Double All! Size for
growth. Sound addition for hearing impaired. Pay as we go by
buying surrounding areas. Two multi service rooms.
Jim Kerns- School size stay as is due to traffic in & out. More property- feels
church has plenty of space, school has crowed out space, *Proper
fund raising.
Jim Leahy- All purpose fellowship hall for 500-600, Gym, High school,
Sonshine Patch 1000 square foot room, 500 ft storage in center
room for two audiences
Geoff Smith- *Stay at current site, buy property, *Single story building schools
are hard to build 2-3 story, move sanctuary back.
Buddy Rawls-Natural Wood verses stucco, Shorter pues, Center door verses 2
side aisles in sanctuary, stay on property, school stay at 8th grade,
treat 9-12th with proper dues if we do open if planned correctly,
Pay as we GO, Auditorium 70% capacity now, central office,
covered entryway drive through.
Jackie Howlett- Youth Gym, New water system, carpet on nursery, grow
Fellowship hall, larger pantry
Bill Brown- 4 total open rooms after changes 9/1/96, Larger youth areas
Rick Holbin- Bigger stage in Auditorium, Stage Expansion area, Sound proof

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all childrens rooms, intercom & video close circuit from church to
Sonshine patch & Nursery.
WITH REPEAT OR ADDITIONAL COMMENTS BY Pat Smith, Lynn Zyki,
Matt Powell, Paula Powell, David Powell, Mike Powell, Mary Pyle, Ruth Gough,
Duane Milford, Myra Smith, Fred Rawls, Carolyn Rawls, Edna Shulke, Mark
Nunes, Ed Hopkins, Dean Cockreal, and Randy Townsend, now Plaintiff.
Further, Plaintiff Townsend states that each attendee heard and expressed themselves to
Ron Beck as Senior Pastor and Dan Maddox of Cogan Industries and thereby put the
Clergy and Professional representative on official notice of the direction of the General
Voting Members and as the charge to the plans and directives to the LONG RANGE
PLANNING COMMITTEE, pastors and trustees. Plaintiff Townsend states this is still
the objective of this LRPC Chairman and that the actions of Ron Beck and the Schism
has been to divert to themselves for their misappropriation of corporate opportunity, by
their frauds and omissions of truthful disclosure against Randall Townsend and Plaintiffs
herein.
4. APRIL 15, 1996, LETTER TO RON BECK, FROM RANDY TOWNSEND
(4 pages) ON BEHALF OF THE LONG RANGE PLANNING COMMITTEE
and points 1-7, and is Quoted herein.
1. The LRPC did approve the motion that the church allow us to hire
Cogan for only Phase I.
2.
The LRPC did approve that Duane Milford and Randy Townsend
and Pastors Staff or a representative thereof, if desired, should
review the Cogan Contract as attached, (Exhibit 1) and review the
language of said agreement to determine our position of such an
agreement.
3.
I did inform Pastor Nasworthy of the LRPC motion as stated in
Point 2 and we agreed a meeting woud be set up for us as the
church committee to review these matters and then another

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4.
5.
6.

meeting would be had with Cogan prior to signing any document.

We have not been contacted regarding our observations.
The contract as presented cannot be approved by the LRPC as
printed.
Articles, II, III, IV, IX, XII, XIII, XXII, do not pertain to the scope
of approval our church has agreed to pursue at said time.
Let me detail the parts of this contract that specifically deal with
only phase I, that require our attention. This is so that there will be
reduced communications problems that might occur in regards to
our variations of said agreement and protection of our rights.
Article I.
(a) Total sum of $5,000.00. List of certain studies and
preliminary designs and cost of same.
(b) Who does Cogan report with? It has been presented to us and
the church that Cogan will work with the LRPC and pastors,
however the past trend has excluded the LRPC for all meetings
except one.
(1) LRP Committee has partially completed.
(2) Same as above.
(3) Need to define.
(4) Committee could do this based on our data in hand. The NO
BUILD concept will not require us to formally get an answer
that might be so obvious, without exploring the ideas for
growth that our committee has discussed.
(c) We reserve the rights to all.
(d) Who is this committee or group?
(e) We need to define up front each contract and what group or
committee will oversee these contracts. Dan Maddux on
1/25/96, waived the 10% over bill. We need waiver in writing.
Article V.
Need to clarify points of Art. I. In order to define Art. V.
Should be done in advance of total agreement and payment.
Article VI.
Funds are available now however the account is not
exclusively for this contract and should not be allowed as stated.
Article VII.
These accuracy and completeness issues needed to be
clarified. Again who is to act as owner needs to be defined now.
Article VIII.
The $5,000.00 was it to be paid in advance or as we
reviewed in the 1/25/96, meeting the fee might be split?
Each of these payments need to be defined since we are
only going part way at this time.
Article IX. Same as above in article VIII.
Article X.
Since only phase I is approved this article cannot remain as

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stated.
Article XI.
What if we sub out technical experts of phase I. (Example:
Jeff Smith, Bill Miles and others)
Article XII, XIII, XIV,
Okay.
Article XV.
Perform all provisions need to address and maybe change
to read, perform any.
Article XVI.
Okay.
Article XVII.
Should be in affect during phase I.
Article XVIII, XIX
Should be maintained. Do we have current insurance for
these issues or is additional coverage or riders necessary? If
needed, how much will this cost?
Article XX
Okay with concept, but under new contract only during
phase I.
Article XXI.
Okay.
Article XXII.
Cogan should be liable for work of phase I even if we elect
other participants for phase I process or additional phase II or
others.
Article XXIII.
Wording in principle is okay however we reserve the right
to arbitration if amount of payment is due and we are holding
payment while work is being completed. Cogan should save
harmless OWNER while work is done.
Article XXIV.
Okay.
Article XXV.
If no to article II, what is and how would 8% be defined?
7.
Let me explain that we are only trying to follow the guidelines of
the Church by-laws and do our duty to same. In order to complete
a master plot plan and be responsible to the church for the legal
matters as it has been presented, we must be involved totally in this
process. We cannot be ignored or kept in the dark about the issues
that are involved this process if the church is to believe that we are
accountable to them just as you or the pastors staff members may
be.
We must be working with the same playbook. As noted several times in
the contract, reference is made to the Cogan company gaining information
from the board or church approved committee. We have now for several

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months been trying to compile this information even before we met with
Dan on 1/25/96. I must say that our attempts have not been supported by
staff. Also it has been confusing for me to try to relate what I perceived
had been our game plan from the meetings we have had in your office or
walking the property and then Mr. Meister has a different view from a
staff meeting or other conversations. The LRPC meeting is a time to iron
out those issues but is hard to do when staff has not attended our meetings.
From our position we are to be in this loop of information and to the
church appear to be in the loop. I do not feel we are. I must also state that
we do not have the cart before the horse in our data collection process per
the opinion of many experts I have talked too per the Cogan process as
stated in their contract reference to working with the committee. If we are
to stay on the committee approved Vision 2000 time chart as tentatively
set at our 3/10/96 committee meeting and at our 3/18/96 meeting in your
office, we must be more informed.
Pastor, this letter is not meant to stir strife or discord between us. I am
only trying to do the job that God brings to my attention, and follow the
by-laws. I am also trying to learn from the thousands of experiences that I
have had in twenty years of business in developing conceptual ideas and
seeing them to completion. I am also trying to learn from the many legal
mistakes I have have to deal with. That is what marketing and selling is
all about. If I do not understand whey we are still not in total concert
about this plan it is not because I am not trying to read the play book or
not trying to listen to the counsel from the staff. There are many mixed
signals being sent. I might add that the business or information meetings
have not helped our church bodies perception but only hurt our
committees message to the church body.
As we agreed in your office on March 18, the powers of Satan will do
anything they can to harm this process. I am trying to reduce that division
to divide this body.
At the meeting on April 16, 1996, and by you and I speaking more often,
maybe I can learn what role you really want our committee to play in this
process. I must say that as I try to write the report due for the church
quarterly business meeting, I cant say what I am just told to say. The
report is to be a true perception of the committee. At this time our
committee is really in the dark regarding the strategy of the Cogan process
and the litigation issue.
Please, at your earliest convenience bring me up to date so I can know
how to answer the people per the duties as the Chairman of the Long
Range Planning Committee.
In Christ,
(SIGNED)
Randy Townsend
Exhibit One as attached are the comments of Duane Milford.

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Plaintiff Townsend alleges this letter, highlights and exposes:

A. The separation of the schism from the Long Range Committee
B. The deceptions of the schism to the Long Range Committee
C. The honorable motives of the Long Range Committee and this Chairman
D. The motives of the schism as separate from the Long Range Committee
E. The motives of the schism as separated from the BY-LAWS.
F. The motives of the schism as separated from the RIGHTS of the General
Voting Members as Associates per the Law and as the right to full
disclosure under the Florida States and the BY-LAWS
G. The motives and intention of Randall Townsend on September 8, 1999, to
continue the investigation of alleged pastors and others by the demands
of, Show me the money and if you take these keys you are telling me you
do not want the truth as the Schism had acted to still conceal matters from
Townsend and the General Voting Members and Townsend in his Committee
and Church approved Duties and Elbert Nasworthy was no longer present to
be held as the scape goat of misinformation.
H. The enactment of the Schism SCHEME by the evidence produced in the
June/July 2006, production of documents of the statements and presentations of
the SCHISM MEMBERS on specifically, October 31, 1999 and April 30, 2000,
and at other times as shown herein as to elevate the damages against Plaintiff
Townsend, as confirmed by the Question of Defendant Karen Harrod Townsend
to Judge Palomino, on November 15, 2001, as WHAT DO I TELL THE
PARENTS, these SCHISM members were engaged and entrapped in their own

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scheme and frauds due to the allegations of Plaintiff Townsend being and
appearing true by the ruling in the Hillsborough County Zoning and Permitting
Process and multiple Court Cases as stated herein and the Schism alleged
Plaintiff Townsend was dangerous and a liar yet now after September 8,
1999, till the events using Judge Palomino, Plaintiff Townsend was none of the
slanderous frauds as alleged by the Schism and the participation of Karen
Harrod Townsend and others, even the deceptive actions of Scruggs..
5. MAY 20, 1996, LONG RANGE PLANNING COMMITTEE MEETING
6. JULY 28, 1996, Church QUARTERLY BUSINESS MEETING
Pastor Beck-Any new business?
Buddy Rawls-Any updates with the road project from Long Range Planning
Commmittee.
Pastor Beck- I do not believe these is a report scheduled from them. I do not
know if we have any more information than what we had till this point. Right
now our information we are getting from our attorneys have been dealing with
our mediation meeting and our court meeting that is coming up in the next few
months here. I have not received any new information.
Buddy Rawls- Can we ask the chair of the Long Range Planning Committee?
Pastor Beck-If there is any new information, I would like to know it myself.
Randy Townsend-The last report of information we have had was back in
May with a conversation I had with Lorena Ludovici. Her conversation with
us could basically coincide with what is now forming a Mediation Team.
That Mediation Team being able to dip into the real nuts and bolts, if you will,
of our statement of what the Mediation Team will be preparing in forming our
statement to the County Attorneys, as well as any type of posture that our
Church Body would feel is appropriate in making those statements and being
able to defend those positions. At this point, it is basically in the hands of the
Mediation Team to deal with those areas. As far as Long Range planning, we
have currently completed as many of the projects as we can at this point, and
we are waiting for a couple of reports to get back to us, and then we can look
at other issues that are coming about. We have prepared ourselves to take
what ever direction we can and to this point, as I said, we have finished most
of the reports that we can- other than a couple of internal reports; possibly as
far as taking how many rooms there are on the property and dividing how
many seats, chairs, and tables etc. will be able to be held and possible being
able to put them into a cad system so that at any given moment we will know
what any room can take and then what our total growth could be if we did not

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do anything or if we then looked at what other type of potential this property

could entail.
Pastor Beck-Do we have any questions regarding the Long Range Planning
Report?
Joe Gough-Have you heard anything from the engineering company about
changing the front of the building or anything? Do we know how much
money we will have or will need? Are we just going into this thing trying to
settle on a figure without anything in mind?
Pastor Beck- The architect that is working with our lawyers, have designed, if
we went that route, a new front, and entrance to our building, if I understood
your question. We have heard from them sometime ago. That was presented
sometime ago. There is nothing new. We do not know if that is the wish of
the Body to go that direction . We are not at a point to make a decidion in our
Body to decide if that is the way we want to go or not. Part of what the Long
Range is doing is helping us to come to that conclusion, and the authority we
are going to be giving to the mediation team, but not tonight. If you received
your letter the answer to the second part of your question will be dealt within
that Special Called Business Meeting. If there is a figure or a percentage or
what authority shall we give the mediation team to represent this body. So
rather that me try and answer it at this point , I cannot at this point, really
answer that second part. If you want to see what it would look like to redo the
front of this thing, if that is the route the Body would want to go, those
drawings are already available. They have already been done. They have
been done months ago. That is part of the case being drawn up because they
have to have something to go on. They do not know if we want to redo the
front, or tear down building, or build a new Sanctuary farther back. They do
not know. They just know that they have to have a case by October 28 to go
in defense of our Body. So they went with a total remodeling of the frontchanging our entrances from the front to the sides and all that would entail. I
am sure someone could give you a glimpse of those. Many in our Body have
had a glimpse of those before. We have had the attorneys out here before,
and we will be having them out here again, but, as you can see, we are trying
to keep you as informed as we are about what is going on out here. Right now
our direction obviously is mediation. That is where our emphasis needs to be
right now and our prayers. What does God really want us to do?
Marie Wells-I do not understand. Didnt several months ago we hire someone
to do a study?
Pastor Beck Cogan Industries.
Marie Wells- Is this who we are eluding to when you are explaining to him
about
Pastor Beck-No. Totally different entities. These are architects that are
working with our lawyers who has to have some type of picture of what we
suggest they might do after settlement, and they have to go with some type of
idea or thought. Whether we do it or not is immaterial. The court does not
care.
Marie Wells- What about the study?

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Pastor Beck-Cogun Industries is on-going. They are working on that. The

preliminary the feasibility study, on what we can do on this property, I have
not received a recent report from them, but that is a different thing from this.
Marie Wells-I remember we voted about four months ago.
Pastor Beck I am not sure. It was several months ago. It was June when we
hired them. That is what Brother Nasworthy tells me.
Marie Wells- We must have voted at our last Business Meeting to hire the.
Pastor Beck-To hire them? Oh yes, that was voted on a passed by the Body.
It was voted on before we actually engaged them. We actually engaged them
in June, and they came and had a meeting, open to anybody to share what they
do in Phase One.
Marie Wells-I was just trying to get it straight in my mind which subject we
were talking about.
Pastor Beck- They have not brought us a report. When they do we will share
it with our Body.
(GAP IN TAPE and Townsend was told by Pastors tape was damaged.)
Randy Townsend-There are two pots going on right now; 1. What is the
County saying? 2. What is our attorney countering what the County is saying.
That is operation number one. You can put if into perspective that there is
another segment going on here. That is what we are doing with Cogan
Industries. What we want to be able to do is to see where these two expert
opinions will coincide with each other. What we are also prepared to say is
they will not coincide, and the Church may have a whole different idea. Right
now we as a committee and the Mediation Team, will really get into the find
detail of what is the Countys position? What is our attorneys counter to the
Countys position? The second issue, of what will matter is what Cogan
Industries will come back and tell us, is irrelevant to what the Countys
statement and attorneys positions will be. What we will do then is, before
any step is taken, make sure that this Church Body gets full information
on plans A, B, C, D, or how many other plans it entails. When I last talked
to Dan Maddux, he understood that the County was taking their position and
our attorneys were taking their position based on that expert data. We as a
Long Range Committee have spoke with Lorena Ludovici. They agreed that
they would share that expert data with us from that perspective. Then what
we would be able to do is take what Dan Maddux will give to us. What we
are then able to say is when Dan Maddux does his report he using totally
independent thinking and creating in what he feels is best for this property.
What we are not trying to do in this situation is second guess or out guess or
push any particular direction on any particular person on trying to give us this
information. Again, what we are trying to do with the form created was
adding a collection report. That is we want everybodys input. This is not a
matter that one or two or three people need to choose what course of direction
is for this case. To answer the question, it is still very premature to know that
Dan Maddux can finish his report, because at this point the County has not
finished with what is going to happen out here in front of Gunn Highway, and
there are still counters to fall there.

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Pastor Beck- Does that help you out a little bit? It is not all real easy, but we
certainly want to have the mind of Christ to continue here.
(GAP IN TAPE- Townsend was told by Pastors Tape was damaged.)
7. THIS JULY 28, 1996, BUSINESS MEETING REPORT ALSO SHOWS
FINANCIAL DATA THAT AS YET THIS PLAINTIFF TOWNSEND HAS
TO RECEIVE ANSWERS AS TO SHOW ME THE MONEY? AS
REQUIRED FOR THE INVESTIGATION BY TOWNSEND WITH BYLAW DUTIES AS A GENERAL MEMBER, CHAIRMAN OF THE LRPC
CONDUCTING THE COGAN REPORT PROCESS AND AS A
NOMINATIONS COMMITTEE MEMBER REVIEWING ALL ETHICS!
A. AS REPORTED ON THE JULY 1996-SEPT 1996 FIRST QUARTER
REPORT:
(1) PAGE 12-15: FIRST BAPTIST CHURCH OF CITRUS PARK
FINANCIAL STATEMENT JULY 1996-SEPT 1996 FIRST
QUARTER
BUDGET RECEIPTS
REGULAR OFFERINGS
80,448.49
Miscellaneous Income
0.00
TOTAL BUDGET RECEIPTS
80.448.49
MISSION PERCENTAGE RECEIPTS
17, 517.69
MISSIONS
2,392.36
TOTAL MISSIONS
9,933.51
TOTAL SALARIES
62,907.64
PASTORAL MINISTRY
Pastor Working Fund
79.50
Pastor Supply
192.72
Pastor Convention
182.56
Pastor Continuing Education
545.00
TOTAL PASTORAL MINISTRY
999.78
TOTAL ASSOC. PASTOR MINISTRY
297.49
TOTAL INSURANCE
2,161,82
TOTAL MUSIC MINISTRY
1,140.12
TOTAL YOUTH MINISTRY
1,947.32
TOTAL EDUCATION & OUTREACH
2,751.55
SUPPORT MINISTRY
Travel Expense
0.00
Casual Labor Office
0.00

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Nursery Workers
0.00
Vehicle Lease
893.94
Other Expenses
0.03
TOTAL SUPPORT MINISTRY
5,821.06
(2) PAGE 16-18:
CITRUS PARK CHRISTIAN SCHOOL
BALANCE SHEET SEPTEMBER 1996:
PETTY CASH:
200.00
CHECKING ACCOUNT
79.959.15
REGISTRATION 1996-97
60,959.50
BOOK FEES 1996-97
27,750.00
TUITION 1996-1997
4,739.43
BALANCE 1995-96
74,522.10
BALANCE 1994-95
16,626.59
SAVING INTEREST
30,102.12
$294,858.89
TEACHER SUMMER SALARY
$15,000.00

This Report By Townsend from the position of LRPC Chairman was to address
the concerns of the LRPC, Milford and Rawls that Pastors were denying Chair as
Townsend and the LRPC from the Mediation Team Process and to reinforce that
the Pastors were not involved per their duty of all necessary functions to the
BY-LAWS and Church operations. The LRPC and the Pastors and the Attorneys
had reviewed the March 15, 1996, letter of Randy Townsend to the attorneys of
Mr. Gaylord and Mrs. Ludovici and to attorney David Gibbs, III, announcing the
position of the LRPC and of the Plaintiffs herein and these issues and supporting
Case Laws were necessary information for, during and to secure the rights of the
Plaintiffs herein in the course for any eminent domain action or settlement of said
action.
8. THE POINTS OF THE MARCH 15, 1996, LETTER ARE AS FOLLOWS:
POINT I.IMPACT OF NOISE AND VIBRATIONS TO
SANCTUARY FOR WORSHIP

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POINT II.PROPERTY VALUES

POINT III.ISSUES OF WHEN DAMAGES BEGAN AND HOW TO
CALCULATE.
POINT IV.LINE OF SIGHT
POINT V.SAFETY WALL AND TRAFFIC ACCIDENTS
POINT VI- FUTURE DAMAGES DURING FIND RAISING
Further these questions and actions were made by Buddy Rawls as a member of the
Long Range Planning Committee so to show the General Voting Members the
dissolutions of the Pastors to the Long Range Planning Committee and even by
actions of Beck to not include Randy Townsend as the LRPC Chairman to the
Mediation Team as the LRPC had intended from their recommendation to the Pastors.
Further, it was the intentions of Plaintiff Townsend, Rawls, Bates and others that
required that the Together We Build (TWB) Monies begin being reported weekly in
the Church Bulletin and not just Quarter or when ever the Church Office remembered
to report said funds, so on or about late 1996, TWB or the changed name to
Challenge to Build (CTB) was reported weekly in the Bulletin and these numbers
showed a pattern of non reported funds from the past.
Further, it was the intentions of Beck and Meister at later times to blame Elbert
Nasworthy as Pastor Of Administration for failure to communicate to the LRPC but
now known the infighting of the Pastors as Church verses School issues were at the
root of keeping the LRPC and this CHAIRMAN of LRPC ignorant of what actions
were produced in the April 30, 2000, Business Meeting to build the sports area
even to the point of proceeding without permits or zoning approval as defiance
by Meister and the CPCS School Board as quoted by Meister in the 2000 Business
Meeting Minutes and by actions shown throughout 2006-2007, by the School
Activities of Basketball, Volley Ball and other school functions using the MAC

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Building at the 18105 Gunn Highway property despite in March 2006, being Denied
in their Permit by Judge Barton and at previous times intending to violate the law,
until they got caught as Meister alleged and as showing his lack of integrity, breach of
contract, breach of trust and omissions of truthful disclosure and frauds in teaching
the Children Plaintiffs to violate the law or that violating the law is okay until you get
caught and then create new frauds to keep your violations ongoing and concealed.
Further, in said Mediation Meeting, Beck and the Schism, did advise Townsend he
was only a guest in said meetings and therefore his positions and questions did not
have authority of the Mediation Team as Townsend was added to the Mediation
Team after the Church had previously voted on the Mediation Team by a now proved
A fraudulent act of the Schism even at that time starting the plan to devalue and
misinform the LRPC Committee and misuse the LRPC in the scheme of frauds by the
Schism.
Further, in signing the Mediation Agreement, Townsend pointed out a loss to the
FBCCP Corporation of $27,479.00, due to the haste and negligent actions of
Pastors and Trustees signing the Mediation Agreement before the Contract was
reviewed verses the Mediation Funds accepted at the Mediation Conference. When
Townsend addressed this matter to the Pastors and Trustees and Attorneys, during the
first 30 days which protected rights of appeal, the Pastors and Trustees refused to
pursue the obligations as stated by the LRPC and their Chairman, Plaintiff Townsend.
Further, the CITRUS PARK CHRISTIAN SCHOOL, NEWSLETTERS CONTAIN
EVIDENCE OF PROOF OF ALL ALLEGATIONS OF PLAINTIFF TOWNSEND

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SINCE 1996, DEFENDING THE FBCCP BY-LAWS AND CPCS MANUALS AND
CORPORATION AND ASSOCIATE/MEMBER INTERESTS AND STATE:
A. SEPTEMBER 27, 2005, Contains and states:
LAND USE HEARING
Please be in prayer concerning our request for a Special Use permit on our
MAC building. A new hearing date has been set for Friday, October 7th. The
judge has remanded it back to the Land Use Appeals Board (LUAB) for further
review and determination. This is very critical because a new LUAB will be
hearing the case and they may view it completely different than the previous one.
We have retained a Land Use attorney to represent us at this hearing. We
encourage you to contact our county commissioner, Jim Norman at (813) 2725725 to notify him of the decision reversals we have received over the last 4
years.
DEDICATION SERVICE
You are cordially invited to join us for a special dedication service for our new
MAC building Sunday, October 9th at 6:00PM. Pastor Ron Beck will be bring a
message and dedicate the MAC center to the Lord. If you havent had an
opportunity to visit, we invite you to join us on this celebratory occasion.
B. NOVEMBER 15, 2005
SPECIAL USE PERMIT UPDATE
First Baptist Church of Citrus Park voted to appeal the decision of the Land Use
Appeals Board and will take the County to court on the advice of our attorney.
The church has agreed not to exceed $40,000.00 for this expense. Any
contributions to this need would be helpful.
C. MARCH 14, 2006,

TRAFFIC CONTROL
For the past three weeks the sheriffs office has been monitoring our
dismissal procedures due to the numerous complaints by those in the
neighborhood. The sheriffs office required a meeting with the
administration and gave them their findings and possible solutions. From
this time forward, violators may be ticketed for obstructing a right of way.
Also, please do NOT park across the street and walk your child in or let them
cross the street by themselves; this presents a very dangerous situation. ALL
parents MUST follow our prescribed procedure for unloading and loading
students.
D. APRIL 25, 2006,
A LETTER FROM OUR PASTOR
Dear Parents,
I want to thank all of you who have been praying for the property issues we have
been going through as a ministry. On March 28, 2006, Judge Barton issued an order
denying our request for a Special Use Permit for our new property. Although we

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were disappointed in his decision we are comforted that God is in control. Our
church family will be meeting to discuss the options that we have. The options we
see at this point are as follows:
1. We could appeal the decision, but this would be difficult and costly.
2. We could re-apply for a Special Use Permit.
3. We could continue to operate on both campuses holding our classes on this
campus and developing our school sports programs and other church
ministries on the new property.
We appreciate you prayer for wisdom as our church family considers these options.
Whichever path we take, I want you to know as a school family that we are
committed to continuing our school ministry, Teaching Every Subject in the Light of
Gods Word. We are very excited about what God has for us in the upcoming
school year here at CPCS.
Sharing & Caring
Pastor Beck
Further these records of Credit Card Statements of Beck and Church Business
Meetings of June/July 2006, show:
A. Conspiracy, Breach of Duty, Breach of Trust, Fraud and Omissions of Truthful
Disclosure and misappropriation of corporate opportunity by the Schism.
B. Conspiracy and Fraud to allege that the violations of the BY-LAWS and of the
COGAN plan was due to the incompetence or failure of Elbert Nasworthy
allegedly acting alone as the Pastor of Administration, but shows collusion and
frauds and omissions of truthful disclosure by the Schism desiring to make
Nasworthy the scapegoat and allowing the Schism to continue the mask on
their true actions and intended plan as shown herein.
C. Show and prove why Plaintiff Townsend was required to object to the violations of
law and BY-LAWS and of the Cogan Plan.
D. Show and prove why Beck and the Schism began the Phase One Committee to
override and breach the duty of the LRPC and this CHAIRMAN now Plaintiff
Townsend and to appoint Geoff Smith as Chair of the AD HOC. Phase One

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Committee which side stepped the Rules and INTENT of the BY-LAWS and
concealed actions of the Schism buying time by blaming Nasworthy as these same
issues continue and occurred during the tenure of Bill Brown as Pastor of
Administration and Townsend sought to confront these issues on September 8,
1999, through current times and Gary Leatherman alleged he was being
deceived by Pastors of the secret accounts and therefore needed his time to
investigate with Townsend.
E. Show and prove why Plaintiff Townsend was required to be excommunicated
slandered and violated of his Constitution and Contract RIGHTS and the deviant plan
of the Schism and others to violate the laws and BY-LAWS and rights of Plaintiffs as
stated herein.
Further the letters from Beck placed as exhibits in the case files show violations of
duty and fraud and omissions of truthful disclosure by Beck and others verses the
actions as done in the April 30, 2000, and other Business Meetings.
(F) (f) All business meetings shall follow an agenda. All committee reports at the
quarterly meetings shall be in written form in addition to the oral reports. All new
business for consideration will appear on the agenda of the business reports.
The June/July 2006, partially produced documents confirm violations of said point
(f), as written reports are missing and new business is not reported legally to this
Plaintiff so to address all matters per Plaintiffs duty as defined in 1993- to 1999, in
his official roles until the omissions of truthful disclosures of the estranged with and
pastors and deputies as trustees began and then is continued and assisted by
attorneys Gardner, Gibbs, Grant, Scruggs, Gray, Denny, Turmel, and judges still
refusing to grant Discovery and by others.

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(G) Article VI Sec. 4. Amendments, This Constitution may be altered provided that
proper notice has been givenand provided also that such proposed changes have
been submittedbut final action is subject to the vote of the Church.
And Plaintiff Townsend states that the partial production of the June/July 2006,
confirm violations of this clause herein and violations of Plaintiff Townsends and
others rights to knowledge, and thought and vote were done illegally and as breach.
(H) Article II, Sec. 2., When any member of the Board of Directors (Trustee) is unable
to carry out the business to which the church has called him, he shall be replaced by
temporary appointment by the pastor. A replacement shall be elected at the next
regular business meeting and he shall serve until the end of the three year term.
Plaintiff alleges upon review of the partial June/July 2006, FBCCP Documents that
this Section 2., has been violated by intentional, negligent, reckless and knowingly
conspiring actions of the pastor acting as alleged Clergy and alleged trustees
unlawfully masked as Officers acting per the duties of FBCCP BY-LAWS and F.S.
617, and of Sheriff Deputies and violating the rights of members as these Plaintiffs to
know, address and vote per the BY-LAWS to confirm the true Trustee Officers timely
upon knowledge in September 1999, of all prior and still ongoing frauds and
omissions of truthful disclosure by actions of these alleged pastors and trustees and
attorneys and judges and others in agencies as all defendants herein to obstruct the
rights of Plaintiff Townsend to require all Pastors and trustees to carry our the
business to which the church has called him or then be elected upon revelation to
the voting members of truthful conduct or violations of breach of conduct of the BYLAWS, Contracts and Laws by whom and for whom they allegedly serve only to
protect the frauds and omissions of truthful disclosure of pastors and themselves.
(I) Article II, Sec. 3. The Board of Directors shall hold its election of officers
(president, vice-president, secretary) immediately following the business meeting in
which the members were elected.

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Plaintiff Townsend alleges that no produced documents show that elections of these
Trustees were done and that this Plaintiff has been denied his right to vote or his
right to oppose the appointment of any Trustee and thereby no actions by the trustees
are within the BY-LAWS or STATE LAWS and Violate the Contract of the BYLAWS and therefore any and all actions of the TRUSTEEs are violations of the BYLAWS, BREACH OF DUTY, and FRAUDS TO THE CORPORATION MEMBERS
and thereby all joint tortfeasor to assisting the frauds and breach of the TRUSTEEs
hold a duty to make whole or reimburse these Plaintiffs due to the collusion,
fraud and omissions of truthful disclosure and violations against these Plaintiffs and
Plaintiffs have been damaged by these violations of these alleged Trustees and
pastors and others doing illegal actions as of Section 4, Article II and others as
ARTICLE I, SECTION 4. And ARTICLE III, SECTION 7, (A)-(G), has been
intentionally, knowingly, recklessly and negligently done in order for pastors and
trustees to continue their fraudulent acts against plaintiffs assisted by others including
actions specifically against ARTICLE III, SECTION 7, (G), to violate family
members. As tools of the alleged trustees and pastors and others illegal acts as said
herein to conceal frauds against plaintiffs and prevented Plaintiff Townsend from his
right to MOTIONS per section ARTICLE IV Sec. 1. The PastorTermination may
be either at the pleasure of the Pastor or the Church but actions by sheriff deputies
acting as illegal trustees in violations of Article IV. Section 4. TRUSTEES upon
officially recorded instructions of the Church in conference prevent still this
Plaintiff Townsend from attending any meeting and voicing and voting his rights or
the rights of these minor plaintiffs.

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(J) Per CHURCH POLICIES I. DENOMINATIONAL POLICY section C. it

states:
At no time shall this Church be under the control or jurisdiction of any separate
organization or body, ecclesiastical or otherwise, but shall remain completely
independent and autonomous in the government of its own affairs. The extent of
support and to and cooperation with any organization outside this local Church shall
be at the will and pleasure of this Church.
Plaintiff Townsend states that by the willful acts of Beck, Meister, Howlett and Karen
Harrod Townsend as members, and in their alleged official honorable dutiful positions
herein acting by their now proved fraudulent acts and Beck and Karen Harrod
Townsends own testimony made under oath now proved fraudulent written affidavits
and under oath now proved fraudulent verbal testimony to the Courts that these showed:
(1) a willful breach of contract and breach of trust (FBCCP BY-LAWS and Marriage)
violations and the willful and pleasure of the Church BY-LAWS clause intentions
and got by fraud approval to involve by fraud and omissions of truthful disclosure and
false slander and unlawful allegations against Randall Townsend just so he could not
be present at Business Meetings or Daily School and Church functions or be in the
daily lives of Plaintiffs Children to rebuke these now proved false accusations
(2) and to involve Sheriff Deputies, State Officials, and these Courts in the Church and
School matters by frauds and bar this Plaintiff Townsend as first charged dangerous/
RESPONDENT to civil and criminal charges and by other allegations demanded
from his paid and contractual attorneys full disclosure and still respectfully requests
full disclosure per the legal process as first started by Schism members and attorneys
and judges, this continues the Schisms frauds and denies the General Voting Member
their BY-LAWS Rights to full and fair, honest reporting of all matters while, before

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or during discussion and voting of all matters of Church and School Business. And
thereby withholding the truthful and honest opinions, reports and advise that this
Nominations Committee Member, Awana Commander, Long Range Planning
Committee Member, Usher and multiple other positions General Voting Member and
Officer Randall Townsend intended to be told to the General Voting Member prior to
a VOTE then these actions impede the obligation of the BY-LAWS as a contract.
(K) ARTICLE IV (Organization) Sec. 2. Other staff members Specific duties (Job
Description) of all paid staff members shall be kept on file in the Church office and
available to all Church members upon request.
Plaintiff Townsend even September 7, 2006, has made multiple request of employee
records that have since the 1990s has been denied. Especially necessary now when
the issues of August-October 1999, and thereafter from the just produced June/July
2006 records shows additional self dealing, frauds and embezzlement by Officers.
(L) ARTICLE IV (Organization) Sec. 3. DeaconsThe Deacons are charged to
constantly seek out men who may meet the New Testament qualifications for
Deacon and present those who do to the Nominating Committee for Church
approval.
Plaintiff Townsend alleges that this process was avoided at multiple times in the
process of electing Deacons so the Schism could find men that solely met their
objectives and this bypassed the Nomination Committee already attending to and
aware of the prejudice being created by the Pastors bypassing the BY-Law system.
60. Plaintiff states per Florida Statue 617.0834 the following actions remove the Civil
Immunity liability of any officer or director of the NOT FOR PROFIT Corporation
and can be used to show BREACH OF DUTY per:
A. 617.0834(1)(a) stating, The officer or director breached or failed to perform his or
her duties as an officer or director; and

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B. 617.0834 (1)(b)1. The Violations of Standards of Criminal Law or Civil Law

can be used to show BREACH OF DUTY per violation of:
C. the Internal Revenue Tax Law Violations can be grounds for Breach
D. Labor Law Violations can be grounds for Breach
E. Acts of Negligence and Intentional Misconduct can be grounds for Breach
F. Fraud and Omissions of Truthful Disclosure can be grounds for Breach
G. False Testimony in an Affidavit or Court and Perjury can be Grounds for Breach
H. Proof of Child Neglect or Child Abuse or Interference with Child Custody, or Child
Endangerment can be Grounds for Breach
I. Proof of violations of FBCCP BY-LAWS of appointments and illegal voting of
FBCCP Corporation officers and FBCCP Trustees not being confirmed by election of
the Nominations Committee or confirmed by the vote every three years per the
FBCCP BY-LAWS and these illegal acts of FBCCP Trustees actions in violations of
the FBCCP BY-LAWS and Sheriff Deputies Policies and practices in conspiracy to
give Benefit to Clergy actions in violations of the FBCCP BY-LAWS and Laws of
these UNITED STATES, STATE OF FLORIDA, HILLSBOROUGH COUNTY
CIVIC LAWS, CRIMINAL LAWS, LABOR LAWS, BUILDING CODE LAWS and
FRAUDS AND OMISSIONS OF TRUTHFUL DISCLOSURE TO THE GENERAL
VOTING MEMBER can be Breach of the FBCCP and Constitutional Law.
J. Proof of Credit Card theft and misuse of designated funds can be as Breach
K. Proof of any and all violations of Florida Statues 895, as this Statue is also within
the Duty of the Attorney General and State Law Enforcement (FDLE) to
investigate and prosecute violators for the protection of all citizens.

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L. Proof of NOT ACTING IN GOOD FAITH per 617.0830(3) stating, A director is not
acting in good faith if he or she has knowledge concerning the matter in question that
makes reliance otherwise permitted by subsection (2) unwarranted. Subsection (2)
states, In discharging his or her duties, a director may rely on information, opinions,
reports, or statements, including financial statements and other financial data if prepared
or presented by: (a) One or more officers or employees of the corporation whom the
director reasonably believes to be reliable and competent in the matters presented;
Plaintiff Townsend presented the Pastors Schism and the LRPC and the Corporation
Attorneys, Eminent Domain Consultants, County Planners and select General Members
and the Consultants hired by the Corporation as CARL DOOZAN of Carl Doozan and
Associates and DAN MADDOX of COGAN Industries with reports that conflicted with
the VISION II of the Pastors Schism and thus this required the Pastors Schism II to
show bad faith actions and create deceptive frauds and omissions of truthful disclosure
in order to carry out the VISION II plan that still after over 9 years and several Court
rulings by Judges Arnold and Judge Barton show that the RULINGS by Plaintiff
Townsend were reasonable and good faith Dutiful actions as should have been done
by the Pastors Schism II rather than the Pastors Schism II continuing to hire hired
GUNS as consultants, lawyers or themselves to do frauds to the General Voting
Members, the Hillsborough County Zoning Department, the Community within which
they planned to live and operate as a TRUTHFUL HONORABLE CHURCH or to the
Courts but still continue the frauds by the COERCION and DECEPTIONS of Attorney
Denny as JUST ANOTHER HIRED GUN OF THE PASTORS SCHISMS keeping
this General Member from practicing Plaintiffs RIGHTS and DUTY per Florida

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Statues, s. 617.1601 (Reporting of records); s.617.1602, (Inspection of Records);

s.617.0834 F.S.(Duty and Violation of Duties); s. 617.0841 (Duty to Follow ByLaws); s. 617.1605 (60 days end of year reporting requirement or per By-laws)
s.617.10 F.S., (members right to be heard before removal in Not For Profit Corporation);
M. Proof of Negligence and injurious actions violations of duties by the employees
themselves as individuals or by respondent superior making the pastors or trustees
and or corporation vicarious liable and can be grounds for Breach as per cases cited
in MALICKI v. DOE 814 So2d 347 (Fla. SCt. SC01-179) March 14, 2002, and
multiple other cases as stated herein.
N. Proof of Incompetent, or False, or Bad Faith Reports from Experts, (Legal or
Architects) used by the Pastors Schism as Officers to conduct the Deceptions of the
Courts and Deceptions of the GENERAL VOTING CONGREGATIONAL MEMBER
can be proof for Breach of Duty and proof of damages and restitution for said damages.
The Use of the overruled D.C.A. MALICKI case by Attorney Denny in violation of the
standards required by the Duties of an attorney practicing in the Second District Court of
Appeals per the FLORIDA APPELLATE PRACTICE AND ADVOCACY Book 3rd
Edition, affirms that the duty of the attorney is to cite proper case law and should the
cited law change it is the duty and good faith of the attorney to act and inform the court
and Plaintiff states that Judge Marva Crenshaw knowingly, intentionally, recklessly and
negligently omitted truthful disclosure and participated in the misuse of the MALICKI
DCA case in opposition to the Florida State Supreme Court Rulings overturning the DCA
MALICKI standards and process to aid and assist and conspire with Attorney Denny and
Defendants herein to conceal all actions of Defendants by her ORDERS as show herein.

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Plaintiff states that Attorney Denny since before presenting the MALICKI DCA case to
the Courts in January 2003, was aware or should have been aware that his argument and
position to the court was of the D.C.A. opinion reported in Florida Law Weekly and had
been overruled by the Florida Supreme Court in March 2002, also reported in Florida
Law Weekly and any proper search of legal systems shows the Supreme Court Case was
fully published prior to all arguments by Denny in January 2003, or by the admission of
Judge Crenshaw in her ORDER of September 2003. Plaintiff Townsend alleges that
Denny was completely knowledgeable of his acts and even the Honorable Judge Arnold
on January 21, 2003, objected in part to the argument of Attorney Denny, but Attorney
Denny with knowledge that the Case was overruled proceeded to misinform the court and
the Honorable Marva Crenshaw trying to allege protections of the D.C.A. Court ruling to
EXCLUDE these FBCCP BY-LAWS in full. The MALICKI cases both D.C.A and
Florida Supreme Court however still show the BY-LAWS were used as the tool of the
court to determine the alleged tortious conduct of the Church Defendants. And the
Court specifically held that To hold otherwise and immunize the Church Defendants
from suit could risk placing religious institutions in a preferred position over secular
institutions, a concept both foreign and hostile to the First Amendment. Pages 364-365.
By attorney Denny intentionally, knowingly, recklessly and negligently continuing fraud
upon the court and this Plaintiff Pro Se Randall Townsend know just known per the
production of the COURT ORDERED FBCCP Corporation Records in June 2006,
delaying omissions of truthful disclosure and conducting frauds against the court and his
own client this Plaintiff as a General Member, all statue of limitations have yet to expire
due to the continuation of the concealment of facts from this General Member still on

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September 7, 2006, showing to court of Judge Crenshaw by MOTIONS and verbal

testimony that discovery of FBCCP records is still needed for this Plaintiff and General
Member with rights of discovery of all FBCCP documents.
O. Further, the Misuse of the DOE v. EVANS 718 So2d 286 (Fla. 4th DCA 1998)
continued and allowed and promoted the injurious falsehoods by the pastors schisms to
the General Voting Members and to the Courts and Plaintiffs, Plaintiffs family, and all
Defendants relied on the intentionally false and deceptive position of attorney Gardner,
Gibbs III, Grant Jr., Denny, Scruggs and Gray and or other attorneys not yet known to
this Plaintiff who attempted fraud during the Zoning or Ordinance Hearing and trials and
Appeals regarding the 18105 Gunn Highway site in conspiracy to do fraud to protect their
own tort acts of malfeasance and breach of duty and continued and promoted the frauds
of Beck, Meister, Howlett, Jeffers and others of the FBCCP membership and others.
61. Plaintiff states per Florida Statues 617.0206 Changes in the By-Laws were not
done per the BY-LAWS DUE PROCESS as now known from the Production of
the BUSINESS MEETING MINUTES of July 2, 2000, and show intent to conceal
activities already done for the protection of the offenders as Plaintiff was reporting
issues that these Pastor Schism members used to fake the appearance of no
Wrongdoing. Plaintiff states that the intentional acts by the Schism were illegal
and violations of the BY-LAWS to block this Plaintiff from speaking to the issues
before the General Congregation VOTE to approve these Revisions and denying
Plaintiff the RIGHT TO VOTE on these BY-LAWS and as per Florida Statue laws
and ASSOCIATIONS AND NON PROFIT CORPORATIONS RULES 71
A. Florida Statue 617.0304(3) states:

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In a members proceeding under paragraph (2)(a) to enjoin an

unauthorized corporate act, the court may enjoin or set aside the act, if
equitable and if all affected persons are parties to the proceeding, and
may award damages for loss (other than anticipated profits) suffered by
the corporation or another party because of enjoining the unauthorized
act.
Therefore any agent or agency who has assisted these violations of the schism is
joint tortfeasor to those who violated their Duty to the Corporation either under the
law or under the Contract Code of the BY-LAWS.
1. 71:30 ChecklistMatters to be considered in actions involving
Churches or religious societies generally
2. ROSS v. GERUNG (1954, Fla.) 69 So2d 650 Actions by or against
religious societies with members so numerous that it would be impracticable
to bring all of its members before the court may be brought as class action.
3. 71:30 Should review (1) Status of Church (2) Facts showing liability
of church (3) Facts showing liability of church leaders or members
4. Per 617.0601 state that notice of meetings and activities of the
members must be set forth in the articles of incorporation or in the ByLaws.
5. 71:2 SUIT v. Gilbert (1941) 148 Fla. 31, 3 So2d 729, states The
constitution and by-laws of an association govern the rights, duties and
liabilities of the members and when subscribed or assented to by the members
become a contract between each member and the association
6. 71:2 Surf Club v. Long(1975, Fla App D3) 325 So2d 66 An
organization may not amend its by-laws or constitution so as to impair a
members contractual rights.
The events of the Changes to the First Baptist Church of Citrus Park Corporation
Constitution, and Policies and BY-LAWS in July 2000, were illegal, intended to
divest this members rights, not properly announced to this member who was being
chased by Trustees as Sheriff Deputies in the Sheriff Deputy issued vehicles and at
times even using the lights or by Ron Beck, Individual, with visiting Evangelists in
town in the vehicle with Ron Beck so to present Plaintiff Townsend as an alleged
crazy person and stalker to this visiting Evangelist and others including Pastors

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at other Churches, to keep Plaintiff Townsend away from the FBCCP or CPCS
public meetings or functions even as a parent of CPCS students with rights, not
properly or timely reviewed prior to vote for or by the General Voting Members
and intended to evade illegal and Reckless conduct of schism officers
frauds the still nave General Voting Members. Concealment still of FBCCP
Corporation Records properly requested per the ruling of the court of Judge Marva
Crenshaw was continued and concealed still by the unlawful Oral ruling of
September 7, 2006, of Judge Crenshaw done on the hearings for Discovery in the
September 7, 2006, Case Management Conference in case 02-03812.
7. 71:3 To expel or involuntarily terminate a member from a private
associationa member need only be given notice and a hearing before
expulsionbut it (the hearing) must comport with applicable bylaws or
regulations of the association
The production of BUSINESS MEETING MINUTES of June 2006, of the
Corporation meeting of April 30, 2000, show that the NOTICE and Hearing and
Vote was done illegally of this members rights and all the while this member by
fraud was being asked to wait across the street in his automobile for over 2 hours
while the Pastors and Trustees and Sheriff Deputies made Randall Townsend to
appear as a criminal, stalker and to J.D.T. even to witness his father being
subjected to this humiliation and slanderous injurious falsehoods by Beck, Howlett,
Shumate and Leatherman on the front steps of the Church. Transcript testimony,
Notes, and Letters to Beck and from Beck and only now to compare to the Business
Meeting minutes to confirm events show the conduct violated the process or
expulsion of this member Plaintiff Townsend was unlawful per the BY-LAWS
ARTICLE III Section 7, (A)-(G).

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8. 71:4 & 71.13--Liability of members---Individual members of an

association can be held personally liable for tortious acts, whether
negligent or intentional, which the member committee or participated in
or which the member authorized, assented to or ratified. A member may
also be liable for failure to act. A member may be liable if that member
sets proceedings in motion or agrees to a course of action that culminates
in wrongful conduct. Mere membership does not make all members
liable for the acts of others done without their knowledge or approval.
GUYTON v. HOWARD 525 So2d (1988 Fla App D1)
9. MEIER v. Johnston 110 Fla. 374, For it is conceivable that in a property
case even a single party as Representative of the whole membership may sue
or defend for the whole.
10. 617.0503(6) Lists rules of law enforcement investigative conducts for
both civil and criminal investigations by the Attorney Generals Office,
Legal Affairs or law enforcement agency. Thus the Church or the
officers or the members have never been immune as Defendants Denny,
Scruggs, Gray or Judge Crenshaw and others listed in the Complaint as
Defendant individuals, or agencies herein have tried fraud and omissions
of truthful disclosure and per PELLEGRINI v. Winter 476 So2d 1363
(Fla. 5th DCA 1985) and per WILLIS v. FOWLER 102 Fla. 35, 136 So.
358 (1931) this is cause for an action based on fraud as Defendant
misrepresented facts to validate his or her opinion when this attorney and
Judge held a position of superior knowledge and fiduciary or confidential
capacity has the duty to make a good-faith full disclosure and Defendants
by trick or artifice prevented plaintiff from making inquiry into facts per
Travelodge Intern. Inc. v. Eastern Inn 382 So2d 789 (Fla. 1st DCA 1980)
and this misrepresentation caused additional damages as lost precious
relations and financial damages as stated herein and shows proof that all

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Defendants have been joint tortfeasor to the continuing damages of the

Malicious Prosecution and now for years not allow plaintiffs to defend
themselves due to frauds of attorneys and judges allegedly advising truth
and not using fraud as false evidence as in the case of Lloyd v. Hines
474 So2d 376 (Fla. 1st DCA 1985).
62. Plaintiff states that PER THE FLORIDA STATUES ALL Plaintiff had or ever
had TO PROVE TO THE GENERAL MEMBERSHIP VOTERS OF THE
CHURCH TO HAVE HAD BECK AND OTHERS REMOVED WAS
RECKLESSNESS OF DUTY and this is even the standards of proof for in the
civil cases and the multiple hired guns used as manuevers by the Clergy and alleged
officially voted in trustees masked as Sheriff Deputies and lawyers reinforcing the
continuing frauds show recklessness of duty and intentional conspiracy to defraud
Plaintiffs as Plaintiff incorporates herein all MOTIONS of 2006, presented to the
Court of Judge Marva Crenshaw in case 02-03812, to present facts to block the
MOTIONS FOR SUMMARY JUDGEMENT attempted by the Court to continue the
concealment of criminal acts and frauds and joint tortfeasors violations of Plaintiffs.
63. Plaintiff alleges that the Pastors Schism I & II knew Plaintiff could have proved
Recklessness of Duty and Breach of Duty and Frauds On September 8, 1999,
if Howlett was not as a Rambo Trustee/Sheriff Deputy covering his own criminal,
recklessness breach of duty to both uniforms as violated that day by the Schisms.
64. Plaintiff alleges that the actions and frauds of CHARLES SCRUGGS, III AS
AN ATTORNEY AND A FORMER JUDGE OF THIS HILLSBOROUGH
COUNTY WORKING EXPARTE WITH ATTORNEYS AND JUDGES AND

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ALLEGED LAW ENFORCEMENT TO CONNIVE AT THE DEFEAT OF

THESE PLAINTIFFS AS HIS CLIENTS TRYING TO PROTECT SCRUGGS,
as an individual violating his DUTIES and color of uniform as an Attorney and
Officer of the Courts to protect and conceal his PERSONAL CONVICTIONS
NOT TO MAKE A CHURCH LOOK BAD BUT BY GIVING BENEFIT TO
CLERGY AND CONCEALMENT OF THE FRAUDS OF RON BECK,
HIMSELF AND OTHERS ACTING OUTSIDE THE LAWS OF THIS STATE
THE COVER UP AND MAKES THE FRAUDS, OMISSIONS OF TRUTHFUL
DISCLOSURE AND DAMAGES BY THE PASTORS SCHISM GREATER
AND LONGER.
65. THESE ACTIONS ALSO DERIVE FROM THE INTENTIONAL, RECKLESS,
UNLAWFUL ACTS OF GARDNER, GIBBS III, GRANT, JR. AND DENNY, IV, AS
FIRM ATTORNEYS FOR DEFENDANT RON BECK, Individual, RON BECK AS
PASTOR KNOWINGLY, INTENTIONALLY, RECKLESSLY AND NEGLIGENTLY
ALLOWING UNLAWFUL BENEFIT OF CLERGY AND MISREPRESENTATIONS
OF LAW TO DEFENDANT DENNYS OTHER CLIENTS INCLUDING THIS
PLAINTIFF THAT THE COURT HAS NO JURISDICTION TO ENFORCE THE BYLAWS CONTRACTUAL RIGHTS OF THE FBCCP CORPORATION AND DID
WITH THE PASTORS SCHISMS I & II CONSPIRE, CONCEAL AND OMIT
TRUTHFUL DISCLOSURE AND USE THE UNLAWFUL INTERFERENCE
WITH THE CHILDREN OF THIS PLAINTIFF AS THE TOOL OF THE
EXTORTION AND PLAINTIFFS CONSTITUTIONAL RIGHTS AS A FATHER
HAVE BEEN VIOLATED AS A WHISTLE BLOWER TRYING TO PROTECT

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HIS AND THE RIGHTS OF HIS MINOR CHIDREN AND OTHERS RELIGIOUS
CONSTITUTIONAL RIGHTS BUT WERE DEPRIVED OF THESE RIGHTS BY
FRAUD AND CONSPIRACY OF EACH DEFENDANT NAMED HEREIN.
66. Plaintiff Townsend alleges Defendant Karen Harrod Townsend on or about October
10, 1999, in the kitchen of the marital residence at 18005 Lindawoods Street, did state to
Plaintiff Townsend, How can you be so right and these six men be so wrong? as a
direct cause and affect of the influence of the pastorial counseling, employer counseling,
and marital counseling received from Defendants Beck, Meister, Leatherman and Brown
and as the counseling was fraud, omissions of truthful disclosure, illegal legal advice and
counseling and tort interference with a marital contract and a breach of duty and a breach
of privacy done intentionally, knowingly, willingly, recklessly and negligently to induce
the Defendant Karen Harrod Townsend to act in extortion and conspiracy to conceal the
fraud, embezzlement and conspiracy of FBCCP pastors and alleged trustees and as
Deputies and as individuals and with this influence Defendant Karen Harrod Townsend
did allege and state that Plaintiff Townsend was a liar and thereby pledged her
allegiance, support, cooperation and actions to her employer and her supervisors in
opposition to Plaintiff Townsend acting per his duty to the Marriage Contract, the
FBCCP BY-LAWS and to the Laws of this State of Florida and the United States.
67. Each individual by their training or by their own personal decision to breach their
DUTY to honor the obligations and rights of the United States Constitution, State of
Florida Constitution, and breach the rights and obligations to a Binding Legal
Contract(s) or violate and breach their duty to their employer or Duty as a member of
FBCCP to intentionally, knowingly and recklessly and negligently violate the FBCCP

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Constitution and BY-LAWS or Constitutions or Marriage Contract as stated herein

become joint tortfeasors with and to the actions of the Pastors Schism and give
benefit to clergy to knowingly, intentionally, recklessly and negligently violate the
Constitutions and Rights of these Plaintiffs.
68. Plaintiffs alleges that all actions by Defendants as Pastors Schism I & II, caused
on September 8, 1999, and still continuing in 2006, were and are intentional malicious
retaliations against all Plaintiffs to give Benefit to Clergy to prevent Plaintiff Randall
Townsend per his DUTY to the Corporation and to his family from exposing unlawful
violations by the Pastors Schism I & II, and the estranged wife of the FBCCP
Corporation BY-LAWS, CRIMINAL LAWS, CIVIL LAWS, LABOR LAWS AND
INTERNAL REVENUE LAWS AND FRAUDS OF MISUSE OF CORPORATION
ASSETS AND FRAUD ABOUT THE MASTER BUILDING PROGRAM AND
FRAUD AND OMISSIONS OF TRUTHFUL DISCLOSURE OF THE ACTIONS BY
RON BECK, INDIVIDUAL, OF THEFT OF CORPORATION FUNDS ON HIS
CORPORATION CREDIT CARD AND THEFT OF THE AWANA CHILDREN
MICROPHONE AND ACTIONS OF TORTS AND NEGLIGENCE AND ABUSE OF
CHILDREN AND OTHERS IN THE CARE AND MANAGEMENT OF THE
PASTORS AND THE TRUSTEES AND THAT EXPOSURE OF: (1) The Master
Building Plan Vision II &III frauds was for a personal benefit started only for the
personal gain for benefit of Clergy Ron Beck, as individual, as Beck was presented
with sufficient facts during the Eminent Domain taking of the 7705 Gunn Highway
frontage road property at the site of the Original Citrus Park Baptist Church since the
1940s, to know the power and dominance of opponents to expanding Northern Gunn

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Highway. Beck and the Pastors knew Groups and agencies like Keystone Park Civic
Association, Sierra Club, Pinellas County, Swiftmud, EPC and the master Hillsborough
County Plan all showed that Northwest Hillsborough County was on the radar of
concerns by all the above to protect growth into the Brooker Creek watershed area. Beck
and Meister knew the 18105 Gunn Highway property is the middle of the watershed and
Beck wanted a new parsonage for his family and more bathroom space due to his three
daughters and is fully knowing per the warning of Plaintiff Townsend prior to the
purchase of the new 18105 North Gunn Highway property the problems of the project
and that purchasing the new property would delay other necessary projects needed for the
immediate needs of the ministry as a whole but Beck created the AD HOC Committee as
Schism Plan II to divest rights and warnings of the LRPC and this LRPC Chairman as
this Plaintiff. Beck refused Plaintiff Randall Townsends reasoning to sit face to face
with the community and county leaders and other interested parties and get their approval
for the full project before FBCCP bought the land just so Beck could gain control of a
new parsonage as the Earl Home at 18105 North Gunn Highway just so his daughters
could have more bathroom space and he (Ron Beck) always wanted to live in the
country and thereby intentionally created in 1997 the VISION II and allegedly per the
Plea of Herman Meister in the Special Called Business Meeting to obtain the vote to buy
the property used all the Designated Building Fund Moneys gained from the Eminent
Domain Settlement and old school closed accounts and ignored this LRPC Chairman
and LRPC Committee Rights and the 1996 Rights even Ron Beck as Pastor willingly
granted to the General Voting Members that they would have Final Voting Rights after
being legally presented with ALL Findings and Proposed OPTIONS of this LRPC

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Chairman as stated in the Corporation Business Meeting Minutes in 1996 but then
removed by misuse of the BY-LAWS and knowingly, intentionally, recklessly and
negligently doing frauds and omissions of truthful disclosure by the violations of Process
by the Pastors Schism I & II in breach of the good faith duty ignoring issues as
reported in verbal coaching and as a letter from Plaintiff Townsend to Hillsborough
County Administrator Mr. Daniel A. Kleman, in 1995, shows with copies sent to
Hillsborough County Commissioners.
69. Plaintiff Townsend alleges from 1996-1999, Plaintiff Townsend as LRPC Chairman
gave Ron Beck plenty of chances to not lie to the people but he is what he is and will
not change as even his father, Jr. Beck, in tears cried on Plaintiffs shoulder at the Citrus
Park Mall the last time Plaintiff Townsend saw Junior Beck before he died, at what he
knew his son Ron Beck intentionally did to my family just to get his abusive way by the
nave church members who to this day are still nave by the actions of the pastors
schism using Schism hired guns as attorneys and accountants and others doing fraud
70. Plaintiff Townsend grew up on Lake Keystone off of Wayne Road, since the mid
1960s and advised the Long Range Planning Committee and the pastors of my over 30
years personal knowledge of the intensity by these groups to oppose an intensity
growth project as the Master Growth Plan our Church sought to serve the interests of
what would be planned to be the largest private school in Northwest Hillsborough
County. Also as the Northdale Soccer Club Board of Director member as Developmental
Coach Coordinator and Registrar, and Founder and Coordinator of a Multi County
League of Florida Youth Soccer, all volunteer, and as Florida Youth Soccer Association
Volunteer of the Year in 1995, Plaintiff worked with the Florida Youth Soccer and the

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Hillsborough County Parks Department on several projects to explore Parks

development, including Keystone Park and the South Mobley Road Complex and the
Northwest Nature Trail/Bike Routes. Plaintiff had discussions with County Planners to
have the County as options of the FBCCP LRPC study of a MASTER PLAN purchase
the 7705 Gunn Highway site and develop a Citrus Park Community Center as the
Keystone Park Community Center is designed as this would compensate for the crowded
Citrus Park Little League. Plaintiff Townsend even advised Church Pastors and LRPC
and other members that the new property 18105 Gunn Highway residents in the 1990s
opposed developing the Sports Complex at the existing Keystone Park and or even
adding additional banks of lights on existing poles due to the complaints of local
residents and that the Citrus Park Christian School and FBCCP proposed sports complex
would be an unsuccessful attempt on the 18105 Gunn Highway property and that before
purchase of the property a letter of intent and approval of permits should be accomplished
with the County and the Community as a reasonable duty of Corporation planning.
71. Plaintiff Townsend alleges that Beck and the pastors were fully aware of the
problems in the 18105 Gunn Highway site in trying to: A. encroach on the One house per
five acres rule; B. the Brooker Creek water shed rights issues; C. and the Intensity of the
crowded roads; D. even moving the first plat plan of the Veteran Expressway farther east
away from the Keystone Park area; E. Protection of the rural scenic Gunn Highway
Corridor north towards the Pasco County line from South Mobley Road and Plaintiff
alleges that the pastors schism I showed no interest or concerns to these reasonable
issues of Plaintiff Townsend as the LRPC Chairman. Plaintiff Townsend now alleges
that the intentional recklessness to this reasonable concern by this Plaintiff as the LRPC

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Chairman and the 10 years of actions by the Pastors Schism I, shows the intent of the
Pastors Schism I, was not for the FIDUCIARY GOOD of the Corporation but done for
job security and pecuniary gain at the expense of the Corporation, and these Plaintiffs.
72. Plaintiff alleges that Beck and the pastor schism has sought to kill Plaintiff and my
family every way he can to kill the messenger of this message so we could not expose or
embarrass his ego as his plan exposed the failures as everyone now sees by the March 28,
2006 Ruling of Judge Barton confirming what Plaintiff said for over 10 years As Judge
Arnold and Margaret Tussing of Hillsborough County Planning and Zoning ruled but
even these pastors refuse to acknowledge as even Herman Miester stated the Clergy False
Plan by saying in the St. Petersburg Times Newspaper on May 28, 2004, I believe once
we get out there and get settled, most of the criticism will go away, ignoring his own
previous statements of the same community issues and concerns stated by even himself in
the St. Petersburg Times on September 13, 1996, saying, It is bumper-to-bumper,
Meister said. I would say that we average an accident a week at Ehrlich and Gunn. I just
dont think that theyve considered the safety of the children and the people in this area.
Yet making these statements about the 7705 Gunn Highway property these Clergy
intentionally ignored that these same issues were the basis not even about one year later
to not purchase the 18105 North Gunn Highway property as the issues of traffic
congestion, density, environmental damage and safety of the children and the people in
this area and ignoring the watershed issues and density traffic issues and other issues
were additional reasons not to buy the 18105 Property but Beck had to have the
Earl Home as his new parsonage and therefore ignored the betterment of the FBCCP.
73. Plaintiff alleges that the most logical position with now after knowing Ron Beck

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since high school in the 1970s and even having his father (Junior Beck) as one of
Plaintiff Townsends best friends until he passed was Beck had to deceive and help
the estranged wife as his employee to destroy the family in order to get all Townsends
out of his way to try to kill the messenger as the opposition to the frauds of Ron Becks
Vision despite this VISION being in direct conflict with the words of Beck himself.
74. Plaintiff Townsend alleges Plaintiffs father and mother pled to Beck and the Schism
many times for help not destroying their Grandkids and the marriage but Beck lied to
them and did fraud with the others to allege the actions were proper as a pastor or as a
Schism.
75. Plaintiff alleges further that (2) THESE FINANCIAL RECORDS AS JUST
PRODUCED PER THE MAY 10, 2006, ORDER, and RECORDS STILL NOT
PRODUCED WILL SHOW AND PROVE THESE ALLEGED OFFICERS OF THE
CORPORATION WERE AND ARE IN VIOLATION OF THEIR DUTIES AS
OFFICERS AND IN VIOLATIONS OF CRIMINAL LAWS now these many years as
THE GENERAL VOTING CONGREGATION AS VESTED MEMBERS and Trustee J.
Kerns, several now departed members and this Plaintiff, in 1995, said for the officers
to do A full review of the Corporation per the By-LAWS and to be as pure as the
driven snow to the Laws and for an IRS Audit and this was intentionally and
negligently not done by Gary Leatherman, Tim Jeffers and Ron Beck and Herman
Meister and these Trustees and Officers should be liable to and by the General Voting
Congregation as Plaintiff Randall Townsend has been trying and is now attempting to do
on behalf of himself and for the minor plaintiff members for whom Plaintiff Townsend
represents by his arguments since 1994, and by attempts since 1995, to gain the proofs of

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the alleged frauds and do per the process the law in 1999, by going to Grant, Gibbs,
Scruggs and Gray and others in law enforcement for the violations of law as Corporate
Officers. The Audit was an addition promotion of fraud as now proved by these facts
and Plaintiff Townsend again on September 7, 2006, in DISCOVERY MOTIONS to the
Court of Judge Marva Crenshaw has been denied by the delays of Judge Marva Crenshaw
and Attorney Denny and Attorney Rolfes present in the Courtroom on September 7,
2006, to get the AUDIT and Reports done allegedly by accountants JANSSEN &
HORGAN on or about October 27, 1999, and not learned of by Plaintiff until the partial
production of documents on June 10, 2006 yet this member has full 617, Florida Statues
rights to this full report and said report is needed for presentation of Plaintiffs full case to
the courts and to the jury. Plaintiffs still seek all DISCOVERY of records still concealed.
76. Plaintiff alleges it was true in 1995, and more true now that Plaintiff as member get
the chance to see the clearer picture of the frauds in and by the June 12, 2006,
Documents and Credit Card Bills as these Credit Card abusive purchases are not
even reported in these EXPENSED items reports given to the Corporation every
90 Days or Yearly as required by Law and Plaintiff all this time by the Pastors
Schism I & II and Attorneys Scruggs and Attorney Denny was required to appear
to be removed from ALL Plaintiffs positions of Duty and rights as an honorable
member of the Nominations Committee and honorable rights and duties as a
general member to investigate unethical, unlawful and or uncivil actions by
Pastors, or Officers or members of the Corporation and Defendants as Pastors
Schism I & II, violated the process of the FBCCP Corporation Constitution and
BY-LAWS and began frauds and Omissions of truthful disclosure.

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77. Plaintiff alleges these frauds of fraudulent Corporation Business Audits and
omissions of truthful disclosure did on October 10, 1999, lead to and cause this Plaintiff
as father and member and husband out of fear of being arrested and put in jail as per
Simpson v. City Of Miami 700 So2d 87, per 741.30(9)(b) a person who violates a
domestic violence injunction must be held in custody until brought before the courtas all
allegations of abuse from Beck, Meister, Howlett, Jeffers and others grew greater for the
injurious falsehoods allegations being told by the Pastors Schism I & II, and the
omissions of truthful disclosures of the now former wife, Karen Harrod Townsend
stating, how can you be so right and these other six men be so wrong and thereby
caused this Plaintiff to require for his safety and the safety from additional infliction of
emotional distress to the marital children and try to keep the home a safe dwelling
required the estranged wife upon choosing to believe the frauds and omissions of truthful
disclosure allegations by the Pastors Schisms I & II, and fearing the Actions and threats
of Trustees Howlett as a Sheriff Deputy to arrest this Plaintiff even in his own home due
to the allegations of ABUSE made by the Pastors Schism I and Pastors Schism II to the
Awana and CPCS Teachers and Employees, September 8-9, 1999, and the omissions of
truthful disclosure and silence of the estranged wife and mother and then these Attorneys,
Judges and Law Enforcement officers do violate the rights of this Plaintiff and all the
Children and do conceal frauds of themselves and of the unlawful Benefit of Clergy.
Plaintiffs were also due to frauds and omissions of truthful disclosures of Clergy and
Deputies and Karen Harrod Townsend subjected to fear and abuse on other public
properties and religious properties in Clay County, Pinellas County and Pasco County as
well as Hillsborough County, Florida, due to the actions of Beck, Brown and Meister to

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allege criminal conduct of Plaintiff Townsend per the scheme to fraud from September 8,
1999, to present using false statements and the INJUNCTIONS of November 2001 and
the 2003, Divorce Injunctions known to have been gained by intentional fraud of courts.
78. Plaintiff Randall Townsend alleges that these Produced Corporation records of June
12, 2006, BUSINESS MEETING MINUTES AND REPORTS, Confirm that on
September 8, 1999, that over $200,000.00 had not been properly reported per the BYLAWS during the BUSINESS MEETING REPORTS OF the 2nd, 3rd or 4th Quarter as
from January 1999-September 1999, and Plaintiff was advised that these designated
Building Funds and Corporation funds were none of your business by Gary
Leatherman, Tim Jeffers, Ron Beck, Herman Meister, Joe Howlett and William Brown
during May 1999- through January 23, 2000 as on January 23, 2000, this Plaintiff had to
quietly sneak into the balcony of the Church during the Business Meeting to get a right to
try to address all matters to the General Voting Members of the FBCCP Corporation as
Plaintiff had been barred from the Property during the October 31, 1999, Business
Meeting and from the property at 7705 Gunn Highway at other times as a member and as
a school/church parent of Plaintiffs J.D.T. and J.G.T as students at FBCCP and CPCS.
79. Plaintiff Randall Townsend alleges that these Produced Corporation records of July
10, 2006, as the Corporation Credit Card Billings FOR RON BECK, revealed for the first
time proof of violations of the Corporation by Ron Beck as these purchases were not By
law reported in the FBCCP Business Meeting Reports, not reported properly as required
by detailed line item and show patterns of pecuniary gain and secret accounts at the
expense of the Corporation and that during the July September 1999, period Ron Beck
spent over $2,700.00 on his Credit Card that was (1) not reported and (2) caused William

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Brown as Pastor of Administration to tell this Plaintiff as Awana Commander to hold off
buying the needed start up Awana materials and supplies because the Church is out of
money and didnt you see the pastors pen message about the offerings in the bulletin?
(3) show misuse of the privilege of the Credit Card by philanthropic purchases and (4) by
concealing these Benefits of Clergy from the General Voting Member per the BYLAWS REPORTING POLICIES as stated in Plaintiff alleges that had these Awana
Workers and Awana parents and the General Voting Members known of the theft of the
Awana microphone and the misuse of this Corporation Credit card causing these Awana
Material not to be purchased and the additional frauds of Ron Beck individual and of the
Trustees and other pastors that these Corporation Officers (5) authorized designated
funds to purchase sound equipment for the personal benefit of Ron Beck again at the
expense of the Awana Children and shows the alleged FBCCP officers would have been
fired and Plaintiff would have pursued Criminal Charges at that time in 1999 had Plaintiff
Randall Townsend not been presented as dangerous and abuser and suffering from a
stress related breakdown and a liar and leading to the allegation of a stalker by repeat
violence and stalker and Domestically Violent and to the allegation as a child
molester so that April 30, 2000, the Schisms could and did call a Special Business
Meeting and to remove this Plaintiff from the General Voting Membership by the frauds
as state herein rather than face jail should Plaintiff ever be allowed to fully speak upon
production of all Corporation Records. Plaintiff Townsend also alleged the FBCCP
vehicles as the Church Bus and Vans were unsafe and dangerous and even illegally used
for the transportation of the children and placed the Corporation and Children at risk
yet these alleged trustees as Sheriff Deputies violated the uniforms of trustees and

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deputies and ignored the violations uses of FBCCP vehicles and safety of the children.
80. Plaintiff alleges that the Financial Audit done by the Firm of Janssen & Horgan
C.P.A.S, P.A.(JANSSEN) per the letter dated October 27, 1999, with no attachments or
follow up reports as inferred would be prepared as We have discussed several ideas with
the finance committee, administrative pastor, and financial secretary. In the near future, a
written management letter will be provided that will outline those and other suggested
improvements. are an incomplete attempt at fraud by the Pastors Schism to omit truthful
disclosure to this Plaintiff and the General Voting Member and that the finding of this
JANSSEN was brought about to console and connive the General Voting Member that
the allegations of this Plaintiff were fraud at that time. Plaintiff alleges that this AUDIT
was not conclusive to all issues raised by this Plaintiff and does not reveal all frauds.
81. Plaintiff Randall Townsend alleges that each FINANCE COMMITTEE REPORT
from 1996 through those presently produced on June 12, 2006, are in violation to
Florida Statue 617.1601 Corporate Records keeping guidelines and other sections
and violation of the FBCCP BY-LAWS ARTICLE III. D. (10). (j-l), and that Florida
Statue 617.1602, Inspections of records by members, rights have been violated against
this member and against the General Voting Member through fraud and deceptions by the
intentional, willing, reckless and negligent actions with malice and for personal gain by
the Pastors Schism I & II, and by Attorneys Grant, Gibbs, Gardner, Denny, Rolfes,
Scruggs and Gray acting with Judges Palomino, Timmerman, Gomez, Sierra, Menendez,
Holder, Stoddard, Arnold and Judges of the 2 DCA with Judge Crenshaw even on
returning from her recess to collect her thoughts from the recap of facts stating
MARCH 1, 2006:

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PAGE 30, Line 3,

THE COURT: Mr. Townsend, I am going to take a moment and see if I can put
this case into perspective that it must be put in.
Without question you have obviously been hurt by the breakup of your family, by
you inability to see your kids on what youre telling me some significant period of time,
by the now separation from what ever employment you had, by what you believe has
been a betrayal of your trust by your former attorney, Mr. Scruggs.
Notwithstanding those things, not withstanding your statements to me on a
number of prior occasions as to what you believe the church members, the deacons and
the pastor, have misrepresented at various proceedings throughout their appearances in
this court system, I am constrained by the requirements of the law; meaning, I can only
address legal issues and rule in accordance with the dictates of the law. That is my
responsibility.
PAGE 31, Line 6,
It is clear from what youre saying youve got a number of other cases. Perhaps
parts of your family law case are still ongoing. You cannot continue to bring those things
into this case in a improper format. If they are related, and in life everything is related at
some point, but unless those matters are related in a legal sense, I cant permit you to
continue to present them in the fashion that youre presenting them.
So why did I go through that exercise. At the outset, at least once if not twice, I
interrupted you to try to get you to focus on the legal motions. Superimposed on
everything that this Court does is fundamental due process, the rule of law. The Court
must rule on legal motions: for example, the most straightforward was the motion for
contempt. Under no scenario can I say you either laid out, presented or stated a basis for
finding any kind of contempt.
Plaintiff Townsend states that Judge Crenshaw was with and by her own words revealing
her own prejudice and bias and incriminating herself by intentionally still limiting the
presentation of the fundamental due process, the rule of law of Plaintiff and protecting
any and all attorneys and judges from being proved doing intrinsic or extrinsic or
fraud on the court even attorney former Judge/Colleague Scruggs and thereby also
Denny (with attorney Client duties to Townsend as a General Member per the By-laws)
and others and on or after the Arguments of September 7, 2006, through her RECUSAL
ORDER of September 22, 2006, finally reading all of the Written evidence presented to
the COURTS by Respondent/Plaintiff Townsend even going back to the evidence put in
the 02-03812 case files back in the ORIGINAL CASE FILED ON APRIL 25, 2002, and

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from the Case files of these underlying matters of Case file 01-15813 and 01-15814, back
to Judge Palomino and used fraudulently by Attorney Scruggs who by law had the same
Contractual duties as: (1) Attorney Client and (2) as Judge/Attorney to follow all the law
that did also include Denny, Rolfes, Gibbs, Grant, Gardner, and all Judges Palomino,
Arnold, Timmerman, Gomez, Menendez, Sierra, Holder, Stoddard and the 2 DCA and
that Judge Crenshaw had to knowingly now include herself, other Judges and Attorneys
and each Defendant as stated now herein this Federal Case and as she said, on:
PAGE 36, Line 12, Okay. But thats former Judge Scruggs. The defendant in
this case is Ronald Beck and the church.
As sufficient facts to obtain Sanctions against Attorney Denny, Rolfes and the Firm of
Dickinson & Gibbons were laid out, presented or stated a bases for any kind of
contempt by stating:
PAGE 8, Line 22, Mr. Townsend: Yes, Your Honor, my position on that point
alone would be that prior to the hearing before Judge Arnold on January the 21st , 2003, I
instructed Mr. Denny to shepardize his cases, that he was about to present fraudulent
cases to the Court of Judge Arnold. He refused to do so. Those actual cases, Your Honor,
are exactly what this Court used in understanding the ruling of KOND, and which was
later quashed the subcase under KOND being DOE v. EVANS.
In 2002, March 14th, those cases that they relied on called DOE v. Malicki.
PAGE 19, Line 22, Your Honor, I also the last time we were before the Court
mentioned that Mr. Denny was in a conflict of interest representing Mr. Beck
individually and also then representing the church, you see, because I think those are two
distinct issues when we go back and look at other cases like Fritovich (phonetic) which is
598 So.2d. 265, and other cases
PAGE 28, Line 12,Ive protected every one of my statues of limitations. Ive
protected every one of my rights and show where Mr. Denny has only been covering for
his clients lies all the way back to the first piece of paper he produced where it showed a
case DOE. V. EVANS, Your Honor, when he used 25 Florida Law Weekly cases, when
week 27, was already published. He already knew DOE v. EVANS was overturned by
the Florida State Supreme Court in their later ruling. He already knew Malicki v. Doe
was overturned. He already had that knowledge. I gave him that knowledge, Your
Honor, and also in documents I presented to the Court showing the new cite numbers, the
814 on March 22, I believe, 2002, was the actual dates of those, Your Honor, where hes
still going and using cases that were a year old intentionally to convince the Court that

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they had no standing against the church because we might get into Ecclesiastical
matters It has only been a fraud and a continual practice by the attorneys to fraud the
truth
Plaintiff had presented over 25 requests for the production of records of the Corporation
and Beck and others and still Judge Crenshaw refused to sanction, reprimand or award
any full requests of this Pro Se but Judge Crenshaw continues to reprimand and duress
the attempts of Plaintiff to follow the RULES of LAW she claims to honor.
Even on May 10, 2006, in Reading the elements of Malicious Prosecution to knowingly
continue a litigation is also proof of continuing Malicious Prosecution and by the agreed
actions that Judge Crenshaw acknowledged were Malpractice and damages by Scruggs
she also was showing Denny, Grant, Gibbs, Gardner, Gray, herself, Timmerman,
Palomino, Holder, Sierra, Gomez, Stoddard and the 2DCA as part of the frauds and
Malicious Prosecution and showing this proves the frauds of any other attorney or Judge
that reads these pleadings and continues to divest and damage these Plaintiffs.
This conflict of representation is especially true when the Concealed Corporation
Documents are produced in 2006, and Townsend is proved to still be a Corporation
Member never removed legally from his Church membership and positions and DENNY
by the concealment of these facts was concealing and breaching his DUTY and CODE
OF ETHICS to Plaintiff Townsend and for whom Plaintiff Townsend speaks and all
innocent and frauded church members and Omega Insurance with knowledge of these
facts delayed Settlement and Denny and others willfully extend the damages done to
Plaintiffs.
Also the fact that any Court action was extended by Denny is now showing cause
for Sanctions and even the reimbursement of Townsends $924.00, paid to get

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interrogatories answered while Townsend was alleged a non member but now that
membership is proved all COURT ACTIONS per Florida Statues 617 are due to be
reimbursed to Townsend and paid by the Corporation or this gives Benefit of Clergy
and continues to keep this Plaintiff as a victim of the injurious falsehoods of the
alleged righteous Corporation officers and this is giving unlawful benefit to clergy as
even critical Corporate Records ordered to be produced in the May 10, 2006, ORDER of
this Court has been ignored by the Pastors Schism I & II and the intentional actions of
Attorney Charles Denny still to fully conceal the actions of the Pastors Schism I & II,
from this General Voting Member, Plaintiff and father trying to regain his relationship
with his Children not unlawfully interfered with for 10 years by the Pastors Schism.
82. Plaintiff Alleges that the just produced June 12, 2006 copies of the fraudulently hid
April 30, 2000, Special Called Business Meeting was in violation of the BY-LAWS and
IN VIOLATION OF THE SPECIFIC RIGHTS OF THIS MEMBER NOT TO BE
PRESENT TO REPRESENT HIMSELF FROM THE INJURIOUS FALSEHOODS
ALLEGED BY THE PASTORS SCHISM IN DIRECT VIOLATION OF BY-LAWS
ARTICLE V. SECTION 4 (e), and ARTICLE III. SECTION 7 (A-G). Plaintiff offers this
is further proof of the accrual of conspiracy issues by the Defendants as Pastors Schism
and the hired guns and other Defendants of agencies and individuals who allowed the
Constitutional, Civil and Criminal Restitution Rights and BY-LAWS Contractual rights
of these Plaintiffs to be violated now 1999 or before by the Conspiracy of the Pastors
Schism I & II and negligence of other defendants. At many multiple times these partially
produced records reveal the Schism members illegally acquired hired guns as expert
Maneuvers in collusion to convey frauds and omissions of truthful disclosure of the

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Schism to install misrepresentation, false hope and false confidence in the allegations of
the Schism members and others as attorneys to conceal malpractice to the general voting
members as these Plaintiffs herein and even these maneuver experts were used to
convey marital counseling and false counseling to Plaintiff Townsends children J.D.T
and J.G.T, which still to this day prevents these children to understand truth this Plaintiff
Father is trying to prove through the courts being blocked by judges and attorneys so
Each Plaintiff can restore lost relationships.
83. Plaintiff alleges Sections quoted below are from cases and or WESTS FLORIDA
STATUES ANNOTATED CHAPTER 617 CORPORATIONS NOT FOR PROFIT.
THE BY-LAWS and or CORPORATION CONSTITUTION shall be used to show
DUTY and the willful misconduct or violation of a duty of the BY-LAWS Contract:
A. McALISTER v. SHAVER 633 So2d 494(Fla. App 5 Dist. 1994)
CONSTITUTIONAL LAW 82(10) Parent has constitutionally protected inherent right
to meaningful relationship with children.
Pastors schism frauds cost the lost rights intentionally to conceal the just revealed
June/July 2006 produced FBCCP documents showing criminal acts of Schism
members in coercion with the frauds of Defendant Karen Harrod Townsend and
others.
PARENT AND CHILD 2(3.1) Only limitation on natural legal right of parent to enjoy
custody, fellowship and companionship of children is that, between parent and child,
ultimate welfare of child must be controlling.
PARENT AND CHILD 2(17) Visitation with child should never be denied as long as
visiting parent conducts himself or herself, while in presence of child, in manner which
will not adversely affect childs morals or welfare.
Pastors schism frauds cost my rights with the children now since September 8, 1999.
Plaintiff with the production of the June 12, 2006, Documents alleges these Church

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officers and Sheriff Deputies (Pastors Schism) wearing the hat of Church officers and
Sheriff Deputies used the fraud and extortion on the wife and mother of the family
children and as an employee of a Florida Statue 623 Private School in violation of the
State Statues and BY-LAWS to conduct her criminal frauds and omissions of truthful
disclosure to Judges, Attorneys and the General Voting Congregation. These schism
members acting under the fraudulent legal advice of Attorney Gardner used frauds
(to the wife/employee and to the allegedly independent SCHOOL BOARD and to
Plaintiff) as Employer and Trustees as Deputies and lawyers from September 8, 1999,
confirmed by the April 30, 2000, Special Called Meeting, then used the frauds and
extortion of other employees of the Florida Statues 617 & 623 Private School and
members as Gayle Lynn as Dean of Students and Dr. Lon Lynn as the family medical
doctor to continue and conceal the severe abuse of the marital children in violation of
Florida Statues 415 and 827 as confirmed by the Doctor reports of Dr. Hoyos and Dr.
Millan. These School Employees and Doctor know these Abusive extreme acts they
were doing was harming the family and the children causing great emotional and mental
and physical symptoms as reported by Dr. Millan but these Pastors and Teachers
continued to prevent this father access to his own children due to the injurious false
allegations now proved as frauds by these new affidavits of the employee estranged
Karen Harrod Townsend. These Pastors and Trustee/ Sheriff Deputies used AD HOC
voting rights and frauds to their own wives as School Board Members to fraud and abuse
As advised to Charles Scruggs in April 2002 by the letters and as Plaintiff as Client had
pled and warned in July 2000 and in the April 2002, (02-03812) Complaint to the Court
and in the Divorce case of 2003, all the abuse being done to my children was by everyone

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but not Plaintiff Townsend but Scruggs used that to keep Plaintiff from the children so
Plaintiff could not report Scruggs torts of frauds and negligence and unethical misconduct
in July 2000, when he should have called DCF and turned in the Mother and the pastors
schism, Dr. Lon Lynn, Grant, Gibbs and others. Attorneys Denny and Stacey Turmel
and Stanford Solomon intentionally promoted known fraud to and with Judge
Timmerman, Gomez, Sierra, Palomino, Crenshaw, Stoddard, Holder, 2DCA and
others and these deceptions were continued by Attorneys Gray, Denny, and others.
B. BOARD OF COUNTY COMMISSIONERS v. SCRUGGS 545 So2d 910,
1989, states several practices of the courts and thereby Charles Scruggs as an alleged
trained and skilled attorney and as a former Judge was to be working for the father as
Townsend and the minor children and had a knowledge and duty under the laws even in
cases he prosecuted to protect the parental rights of Randall Townsend and protect the
welfare of the mental and emotional and physical well being and MORALS and
WELFARE of the children and now years of abuse is present and provable in court.
84. Plaintiff Townsend alleges that these recent productions of document prove Beck and
Meister as Pastor Schism I began their two part plan to remove Plaintiff from all his
positions by frauds and injurious falsehoods and part one was to use the marriage
counseling of Beck and Meister starting in 1996, of the employee/estranged wife starting
their pastors scheme tied to the Actions of the APRIL 14, 1996, COGAN
INDUSTRIES MEETING and the FACT FINDING OF THE $10,000,000.00 PROJECT
that caused the PASTORS SCHISM I to lie to the wife to tell the wife in counseling to lie
to her husband about the family finances causing tax frauds to and by her CPA and that
my personal business lawsuits were not Biblical, but then Beck turns around years later

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and sues Plaintiff on false charges and that shows when this trail of BECK started frauds
when there is proof that she needed to be Baker Acted then that lead to the additional
frauds on all children and Plaintiff and then to other employees and then to the courts and
PART TWO, to misrepresent to the Deacons the Pastors Schism I allegations of the
BY-LAWS that the LRPC Chairman had to allegedly roll off the LRPC Committee at
the end of a three year term as this Plaintiff Townsends first term would have expired in
1996-1997, but the Deacons refused the Positions of the Pastors Schism I and therefore
the Pastors Schism I using the AD HOC PROVISION OF THE BY-LAWS formed
the new PHASE ONE Committee and removed by fraud the duties committed to the
GENERAL VOTING MEMBERS by Beck in January March 1996, Business Meetings.
85. Plaintiff alleges On August 11, 1999, these pastors schism as reported in the
Church Issues Journal of September/October 1999, page 41, confirms the pastors
counseling and frauds that Beck and Meister then intentionally knowingly, recklessly and
negligently even violating the specific Contract rules of the BY-LAWS page 9, at
Article III, Section 7(G), used her mental confusion to cover up their frauds on the
Corporation and this father that now in the courts of 2006 has been proved full circle.
Beck told this father/church member/leader/ state security officer now plaintiff on August
11, 1999, to resign all church positions and Plaintiff refused and confronted him
on the Master Building Plan Frauds the Missing Money and the Awana Issues and
other negligence acts as violations of ethical conduct per the BY-LAWS that still haunted
my versions of facts verses his FRAUDS AND LIES as now proved 10 years later, he
was guilty then and more so now as proved by the Production of partial Corporation
Records now in 2006, demanded to Beck and other FBCCP officers in 1999 to date by

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this FBCCP member and the Deacons, School Board, and Schism supporters knowingly,
intentionally, recklessly and negligently continued violation of the BY-LAWS and
Contracts and Due Process by doing fraud to and with alleged experts as Grant, Gibbs,
Gardner, Denny, Dr. Lon Lynn and others as DOE attorneys hired during the Permit
phases of litigation and by acts of Denny and Rolfes and others to be revealed upon
review of all Corporation Records not yet produced to these litigant Plaintiff members.
86. Plaintiff Alleges then Gary Leatherman and Dr. Lon Lynn with Howlett and Meister
and Jeffers and Smith, and others, knowingly intentionally and recklessly and negligently
included themselves in the frauds as confirmed by the letters including the Certified
Letter of August 1, 2000, sent after my consultation with Attorney Scruggs, to Beck, Dr.
Lynn and Gary Leatherman. Defendants started the extortion and frauds and now all
defendants are joint tortfeasors to the fact that Karen Harrod Townsend lies and uses all
to abuse and destroy plaintiffs children J.D.T. and J.G.T and still today helped by judges
using the torts and frauds of Scruggs and Turmel and Judge Timmerman and all judges
of the Thirteenth Circuit after hearing the facts continuing the endangerment through the
DIVORCE JUDGEMENT WITH INJUNCTIONS and the schism.
87. Plaintiffs allege the estranged wifes brother (Steve Harrod) and Karen Harrod
Townsend even advised the court of Judge Holder and Anchor Court Reporting
associates in December 2005, that Plaintiff Townsend as this father was under a COURT
ORDER that does not allow Plaintiff to contact his children and thus conceal criminal
acts of Ron Beck, Herman Meister from September 8, 1999, and before and the others of
the Pastors Schism as Gary Leatherman and Lon and Gayle Lynn, and themselves for
over 10 years and their mother and the violence of the maternal grandfather Don Harrod

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as witnessed by Attorneys Heather Gray and Stanford Solomon on March 29, 2004,
outside the court of Judge Gomez and is proof these children are scared and nave.
88. Plaintiff alleges PER Wests F.S.A. 95.031, LIMITATIONS OF ACTIONS 43
A statue of limitations runs from the time the cause of action accrues which, in
turn, is generally determined by the date when the last element constituting the
cause of action occurs.
89. Plaintiff Townsend alleges that Defendant Karen Harrod Townsend as the Employee
and Member of FBCCP and CPCS has since October 1999, said AS SHE REPORTED
IN TRANSCRIPTS AS RESPONDANT SUPERIOR AND VICARIOUS LIABILITY
CASES SHOW TO JUDGES PALOMINO AND JUDGES TIMMERMAN AS HER
EXCUSES AND REASONS TO GET THE STILL VERY INJURIOUS FALSEHOOD
INJUNCTION USING THIS IN January 2006, to Anchor Court Reporting, my talking
about the frauds of the pastors schism is why she told Judge Palomino she will not
allow me to see my children and then to continue the frauds of the pastors schism
and Joe Howlett as the Sheriff Deputy to cover up his criminal acts as the deputy with
Jeffers and Trustees goes TWO YEARS LATER to Curtis Baughman in November
2001, and files criminal charges against Plaintiff and then Attorney Scruggs continues the
frauds of Howlett, Beck and the Former Wife Harrod, in the Court of Judge Palomino in
November 15, 2001 Now in the court of Judges Timmerman, Gomez, Sierra, Stoddard
and Holder as Plaintiffs now have the June/July 2006 FBCCP Documents to prove the
pastors Schisms frauds and theft in 1998-1999 and since as proved by Judge Barton,
March 28, 2006 and these documents of June 12, 2006 and Credit Card bills and with the
frauds of Denny alleging the now recanted First Affirmative Defense and concealing
Townsend with membership rights and still concealing FBCCP & CPCS Records that

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this is Continuation CONVERSION Liability and the principle of CONSCIOUS

PARALLELISM and of Compounding a felony by all defendants against Plaintiffs.
90. Plaintiff alleges The FOURTH AMENDMENT protects Plaintiffs legal rights and
those of all my children to unreasonable search and seizures and when Beck, Howlett,
Meister, and the Wife and SCRUGGS BY HIS OMISSIONS OF TRUTHFUL
DISCLOSURE AS THIS CONCEALED HIS NON REPORTING OF THEIR
CRIMINAL ACTS REPORTED TO HIM IN JULY 2000, attempted to get the stalking
orders to seize rights as a parent of my children from Judge Palomino as per the rule of
an order from an INDEPENDENT MAGISTRATE, THEY LOST, yet the facts show
they did exactly opposite what Judge Palomino ORDERED and WARNED TO STOP
as the transcript shows Judge Palomino cautioned Defendants on interference with child
custody issues and even giving Scruggs an approval to let Townsend testify as to how or
all that was being done to prevent Plaintiff Townsend and the Plaintiff Children from
having a normal relationship as the letters from Minors J.D.T and J.G.T show were being
impeded by the collusion of the mother, Beck, Scruggs, Meister, Leatherman, Howlett
and others of the Corporation as School Employees, Church Members and Parents and
others as Associates who as even reported in the transcript of 01-15814, testimony by
Karen Harrod Townsend to Judge Palomino, What do I tell the parents yet Defendants
removal of Plaintiff Townsends children got worse as is proved by the Dr. HOYOS and
DR. MILLAN REPORTS! Thus ALL have been in violation of the Judge Palomino
ORDER, since 2001 and this includes SCRUGGS, GRAY, TIMMERMAN, GOMEZ,
SIERRA, DENNY, CRENSHAW, HOLDER, STODDARD, MENENDEZ, AND ALL
OTHERS AS DEFENDANTS SHOWING NEGLECT OF DUTY TO HONOR THE

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COURT ORDER OF JUDGE PALOMINO AND MISS USING FRAUD OF IT TO

AND WITH all agents and departments and others blocking my rights as a free
parent/protector to all children! Even as a PRO SE, Plaintiff should have the right to
interview his own children so to clear reputations from these false charges by
the former wife, the pastors schism and the fraud silence by Scruggs and Gray and
frauds of other Defendants as stated herein. The falsehoods of Plaintiff Townsends
reputation led to and did cause termination of employment and impedes future
employment due to being label per the charges of alleged clergy and other
defendants and the failure to do duty of same.
91. Plaintiff alleges the frauds of are allowing the maternal family(HARRODS) and
pastors schism to still try to put Plaintiff in Jail as the estranged former wife and Beck
have violated the Plaintiff and the children now for 10 years and law enforcement does
nothing. Defendant (Steve Harrod) allegedly called the Santa Rosa County Sheriff on
Plaintiff in 2002, the last time Plaintiff tried to see daughter J.G.T. (a minor with me with
full custody at the time) and they will do it again as they know the actions of Attorney
Scruggs and Judge Timmerman and Beck and others will show me as a child molester
in the AMENDED FINAL JUDGMENT FOR DIVORCE WITH INJUNCTIONS as
they still brainwash and abuse these mentally and emotionally and physically under
nourished children to conceal their years of Child Abuse by the maternal family and
Citrus Park Pastors and employees. Also again on December 25, 2006, Plaintiff
Townsend did travel to Pace, Florida driving over 500 miles one way to see his children
on Christmas Day, and was denied visiting or any contact rights by Defendants Karen
Harrod Townsend, Norma Harrod, Donald Harrod, Steven Harrod and by Deputy

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Sergeant Wheeler who refused to assist in the enforcement of the injunction and did
nothing more than issue an incident number and strongly advised Plaintiff Townsend to
return to Tampa as previous attempts to involve the Santa Rosa Sheriff per the law has
been violated in their failure of duties.
92. Plaintiff Townsend as this father has said truthfully at every opportunity, it was frauds
of Scruggs, Joe Howlett, Ron Beck, Herman Meister, Judge Timmerman, Judge Gomez
and Judge Sierra, Attorney Heather Gray, Gary Leatherman, Tim Jeffers, Geoff Smith
and attorneys for the Church/School Gibbs, Gardner and Denny, ROlfes and attorney for
the wife Stacey Turmel, to conspire and make up false charges as alleged to Judge
Palomino and Curtis Baughman of Victims Assistance (as Curtis Baughman stated in
March 2006, it was Joe Howlett in November 2001 who filed to him the falsely charged
report about Plaintiff and this brought Baughman to the Court of Judge Palomino on
November 15, 2001). This proves that the charges made by Ron Beck(1999) by fraud of
the BY-LAWS and the Florida Statues and the Criminal Injurious Falsehoods to remove
Townsend from the Church/School duties in violation of FBCCP BY-LAWS operating
under F.S.617, ignored my DIRECT, INDIRECT and DIRIVATIVE RIGHTS per the
617 Laws and Plaintiffs rights as a Civil Person to be with my children at all times. This
proves the interference with Child Custody frauds because on September 8, 1999, when
Ron Beck, Herman Meister, Gary Leatherman, Joe Howlett and Tim Jeffers started the
frauds of child abuse or or dangerous or potentially violent they then waited until
November 2001, to have Joe Howlett as a Trustee and Sheriff Deputy Contact the proper
authorities that should have investigated the allegations of Ron Beck and Herman Meister
and Gary Leatherman and Joe Howlett and Tim Jeffers in 1999, if there really had been a

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criminal acts that they truly could allege that Townsend was or had done. INSTEAD
SINCE PLAINTIFFS CHARGES IN AUGUST 1999, TO SHOW ME THE MONEY
these men (Trustees and Deacons and Pastors) without lawful rights have destroyed
Townsends family and children as extortion for their cover up of over $200,000.00
missing money and them in August 1999, refusing to allow Townsend to see the
corporation records to conspire to deceive now as the Records in part in June/July 2006
show beyond doubt criminal frauds and actions.
93. Plaintiff Townsend alleges BECK and his co-defendants CHARGED Plaintiff
Townsend UNDER THE CRIMINAL CODES --FLORIDA STATUES 784.046 and
18 U.S.C.2265 by his INJUNCTION on November 2, 2001, signed at 10:20 A.M.
charging as a Defendant of Criminal Acts Beck and others could not prove even by the
failure of Scruggs to present Plaintiff Townsend side of the facts in the slightest and
reasons to keep the childrens mother, Brown, Beck, Meister and Howlett and the nave
members away from the children who were lying to the children and the people and now
the courts as their conniving grew to cover up their first frauds as these Production of
Document just gained now in June/July 2006, or the 2006, Judge Barton Ruling, PROVE:
(1)

With the COURT ORDER OF JUDGE PALOMINO on November 15,

2001, the DUTY OF THE COURTS AND THESE OFFICERS OF THE

COURTS AND THESE STATE LAW ENFORCEMENT OFFICERS DUTY TO
TOWNSEND TO ENFORCE THE ORDER OF THE COURT that my
rights were violated as Malicious Prosecution, Abuse of Process and Fraud and
False statements to the Courts and this was a confirmed act by the words of Judge
Palomino that he ruled he thought the rights as a father was being illegally

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Impeded and with Plaintiff Townsends OCTOBER, 2003, MOTION FOR

REHEARING presented to Judge Timmerman and all subsequent Complaints,
Motions, Affidavits, Letters and Verbal Testimony and Exhibits presented to
attorneys, law enforcement and to the Courts all Defendants have been informed
and put on Notice of the frauds and omissions of truthful disclosure and
misrepresentations of defendants verses the words and exhibits and affidavits used
in the hearings before Judge Palomino on November 15, 2001, by defendants to
do and continue frauds on the courts and use abuse of process and as the letter of
Drew Gardner on behalf of the School Board in April 2002, agreed and
acknowledged relevant matters and instead of doing Duty to the Corporation
and the innocent and nave Associates Gardner and Gibbs continue the fraud.
(2)

Had the true intentions of Trustee/Sheriff Deputy Howlett and Beck and

others as concerned persons of FBCCP truly sensed responsibility or present

danger as alleged since September 8, 1999, and at all other various times the
actions of reporting the events to Curtis Baughman in November 2001, showed
breach of duty to report Child Abuse, Negligence and apathy to meet the duty
alleged and further show malicious intent to do damage to the reputation of this
Plaintiff unduly not as stated to protect themselves or anyone from fear or
physical harm as per the transcript testimony to Judge Palomino on November 15,
2001, by Ron Beck on behalf of the FBCCP and himself. Instead this shows
proof of the conspiracy to use the employee estranged wife to promote the
allegations of Domestic Violence or attempt to show this plaintiff was mentally
ill and abusive to cause the injurious falsehood to Judge Palomino in the need

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to secure a permanent injunction not obtained but by frauds even later reported by
Attorney Denny and the estranged wife via the attorneys to Judge Timmerman,
Defendants did willfully and recklessly interfere with child custody and did inflict
emotional distress and cause abuse of the children as reported by Dr. Hoyos and
Dr. Millan. Further proof that outside the Pastors Schism all unbiased judges and
other fully informed persons align with the positions of this Plaintiff as being the
true victim with his children and these other Plaintiffs who suffered without the
presence of this Plaintiff Townsend attempting to daily know of all other abuse of
the children as the building and growth expectations on the new 18105 North
Gunn Highway obtained by frauds of Clergy and Illegally retained FBCCP
trustees was to serve the interests of the children of the Church and School but for
the frauds of the pastors, alleged trustees, deputies, attorneys, judges, state
officials and public entities.
(3)

Had he had a true presentation of the partial CHURCH RECORDS JUST

RECEIVED then Charles Scruggs should have stopped Beck, the wife and the
SCHISM and other frauds and even his had he got the Subpoena as the faxed
letter to him on November 12, 2001, had demanded for him to do! Scruggs didnt
because he in July 2000, had not reported the Child abuse, battery and money
fraud then to the Courts to protect the FBCCP members and Contracts rights and
as Scruggs sought not to reveal or violate his concealed superior knowledge of his
personal convictions as not revealed until September 30, 2003, and by his letter
above herein of February 16, 2007, proving his Ethical, Attorney/Client and total
disregard for the rights of the Courts, Church members, Plaintiff and others for

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whom Scruggs has taken an Oath to Obey the Rules of Law and Serve and
PROTECT thereby.
(4)

Florida Statues 617 clearly leaves intervention controls for stoppage of

any and all Corrupt or Criminal Schemes as stated in:

617.0301Corporations may be organized under this act for any lawful
purpose or purposes not for pecuniary profit and not specifically prohibited to
corporations under other laws of this state. Emphasis added for any lawful
purpose!
94. Plaintiffs alleges all Unlawful actions must be stopped and the violators in the
Corporation and/or the Corporation stopped when it is a front for unlawful purposes
and Plaintiff states, Where did Beck and the SCHISM get the rights to take away my
marital and father/parenting rights just so they could conceal the criminal acts with the
hired guns or the breach of duty and apathy of the Defendants as stated herein.
95. Plaintiff Townsend alleges that Florida Statues 617.0503-- allows your agency as
the State Law enforcement agency and the Department of Legal Affairs and the Attorney
General and the Sheriff and the Courts all have Jurisdiction to insure that all law is
followed within Hillsborough County, Florida. AND 617.0830(3)A director is not
acting in good faith if he or she has knowledge concerning the matter in question that
makes reliance otherwise permitted by subsection (2) unwarranted. These officers and
Trustees have done fraud by false reporting crimes to Deputies and these Courts and to
the Citizens of Hillsborough County as reported herein and by negligence to the Duties of
this Statue each individual and agency and Corporation and Department herein is an
accomplice to the criminal actions of all Defendants.
96. Plaintiff alleges the May 5, 2000, June 16, 2000, and July 26, 2001, letters by

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Defendant Beck, and all affidavits, court transcripts and other letters and exhibits as
presented to the Circuit and Appeals Courts and attorneys and law officers, knowingly,
intentionally, recklessly, and negligently was used by each Defendant to allege that the
BY-LAWS were properly followed and that the Plaintiff Townsend was in Breach of the
BY-LAWS and other State and Federal Laws and Rules of Civil and Criminal Procedure
and therefore by frauds and improper use of the BY-LAWS using Sheriff Deputies
(Howlett and Jefffers and Smoak and Corbin) and TPD officer Kieras, lawyers, Judges,
others in law enforcement, state offices and agencies and others have intentionally and
falsely slandered this Plaintiff and interfered with his Constitutional, and Contract ByLaws and legal rights and an each defendant herein is responsible for damages incurred
by these Plaintiffs as stated herein and only until the production of these April 30, 2000,
and other CHURCH BUSINESS MEETING MINUTES and the Ruling of this Court on
May 10, 2006, to Produce these Records could Plaintiff unveil the Conspiracy by all
Defendants assisting Benefit of Clergy of all illegal activities as stated herein.
97. Plaintiff Townsend alleges that the unlawful and illegal marriage and legal counseling
given to Defendant Karen Harrod Townsend by Pastors, alleged FBCCP Trustees, law
enforcement, lawyers and judges(Palomino, Timmerman, Gomez, Sierra, Holder,
Crenshaw, Stoddard) by their own rulings or by omissions of truthful disclosure of
Sheriff Deputies and Lawyers and Defendant Steven Tyler Harrod and others did
cause Defendant Karen Harrod Townsend to do frauds and filings of false reports to the
Sheriffs, Courts, Certified Public Accountants and United States Internal Revenue
Service and these actions did inflict duress and financial frauds and damages against
Plaintiff Townsend as the collusion and concealment by Defendants did allow fraudulent

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advancement of IRS Innocent Spouse protections and gained by illegal claiming of the
home mortgage interest and children as dependants and other frauds inflicted on Plaintiff
Townsend by the omissions of truthful disclosure of income and these false tax filings by
Defendant Karen Harrod Townsend as yet to be fully discovered and the concealment
and advancement of these frauds is continued by the 2006 Rulings in the Courts of Judge
Holder, Stoddard, and Judge Crenshaw and the Second District Court of Appeals.
98. Plaintiffs request this Federal court take Judicial Notice of all cases stated herein and
incorporates all claims, claims for damages and all remedies for claims and new claim for
damages as alleged and requested by Plaintiffs in all Plaintiffs cases as stated herein and
plaintiffs pleas for all judgements of this court as so requested or demanded in all lower
courts as stated in each Complaint, Amended Complaint, Motion or Appeal and Requests
for Discovery and Requests for Injunctions and any and all new requests as required upon
production of all discovery records as required for justice to be solved in these cases.
99. Plaintiff alleges per the unstricken portions of Paragraphs, as below herein
per the specific ruling by Judge Crenshaw as to the allegations and duty of Members
and violations of those members of said duty, apply, expand and include each defendant
herein who also hold and violated the like duty to this Plaintiff who also obstruct this
Plaintiff from his rights and to voice said rights to a jury and thereby Judge Crenshaws
own rulings allowing the points to stand the Matters of Law have and are ready to be
presented against all defendants to the jury as per matters of facts and damages.
Plaintiff Townsend alleges that the Complaints, AMENDED COMPLAINTS and
Appeals filed as TOWNSEND v. BECK et al. As case 02-03812, and TOWNSEND v.
Scruggs et. Al Case 05-0911 and as 2D06-2811 and TOWNSEND v. GRAY et. Al,

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Case 06-6005, and TOWNSEND v. TOWNSEND et al. Case 05-9605, 02-4974 and
2D06-3469, be included herein FROM LOWER COURTS AND SECOND DISTRICT
COURT OF APPEALS and be incorporated herein this Complaint and for jurisdiction of
this UNITED STATES FEDERAL COURT MIDDLE DISTRICT, TAMPA FLORIDA.
Further Point 100, is omitted herein and point 101 resumes the Complaint
per the ORDER of the Judge Marva Crenshaw per the May 10, 2006, 02-3812, CASE
MANAGEMENT CONFERENCE after plaintiff receiving the PRODUCTION OF
CORPORATION RECORDS AS DEMANDED SINCE 1996 BUT WAS CONCEALED
BY THE FRAUDS OF THE PASTORS SCHISM AND BY ATTORNEYS AND
JUDGE CRENSHAW IN THE SEPTEMBER 7, 2006, VERBAL RULINGS PRIOR TO
HER SELF RECUSAL BASED ON THE MOTION OF THIS PLAINTIFF AND BY
OTHERS AS DEFENDANTS SHOWN HEREIN AND THUS ALL ACTS OF
CONCEALMENT PER LAW PREVENT THE ACCRUAL OF THESE PENDING
ISSUES BEFORE THIS COURT AS STATED HEREIN AGAINST THESE
DEFENDANTS. Any or all reference to stricken paragraphs do not apply to the
paragraphs as numbered herein but refer back to the Second Amended Complaint of
April 19, 2004, in the number as shown therein.
TOWNSEND V. BECK et. Al
CASE 02-03812
SECONDED AMENDED CIVIL ACTION FOR DAMAGES COMPLAINT
AND
DEMAND FOR JURY TRIAL
COUNT VIMALICIOUS PROSECUTION
AGAINST RON BECK, Individually, Reverend Ronald L. Beck, as
Senior Pastor, and The Corporation of the First Baptist Church of
Citrus Park, Inc., A Florida NOT FOR PROFIT CORPORATON
COMES NOW, RANDALL TOWNSEND, PRO SE, and sues

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RONALD L. BECK, INDIVIDUALLY; REVERAND RONALD L. BECK, AS

SENIOR PASTOR OF THE FIRST BAPTIST CHURCH OF CITRUS PARK;
(HEREINAFTER AS FBCCP); FIRST BAPTIST CHURCH OF CITRUS PARK, A
FLORIDA CORPORATION and alleges:
GENERAL ALLEGATIONS
101.

This is an action for damages in excess of $25,000.00.

102.At times material herein, Plaintiff resides in Hillsborough County, Florida.

103.Defendants, reside principally in Hillsborough County, Florida and d/b/a
FBCCP in Hillsborough, County, Florida.
4.-5. STRIKE
106.

THESE MEMBERS AT LARGE OF THE CORPORATION THEN

WHO THEN VIOLATED KEEPING TO THEIR FIDUCIARY DUTIES TO

ALLOW PLAINTIFF TO REVEAL HIS KNOWLEDGE OF THE SECRET
FUNDS AND OTHER FLORIDA STATUE VIOLATIONS BY THE
OFFICERS THESE MEMBERS AT LARGE THEN BECAME COCONSPIRATORS AND DID DAMAGE THE CHARACTER AND
REPUTATION OF THIS PLAINTIFF BY ALLOWING, AND BY GIVING
THEIR VOTE OF APPROVAL FOR AND THEN BY PAYING FOR THE
CHARGES TO BE FILED AND BY BEING WILLING TO OFFERING
TESTIMONY IN SAID CASE OF MALICIOUS PROSECUTION AS ACTED
OUT BY RON BECK AS INDIVIDUAL AND AS PER HIS OWN
TESTIMONY TO JUDGE PALOMINO ON NOVEMBER 15, 2001, SAYING
WELL, FIRST, YOUR HONOR, ID LIKE TO TELL YOU ITS THE FIRST

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TIME IVE HAD TO DO SOMETHING LIKE THIS TO A PERSON BEFORE.

AS A PASTOR I DONT REALLY GO FOR THIS KIND OF STUFF, BUT
OVER THE PAST TWO YEARS SINCE 99AND I HAVE BROUGHT
WITH ME A STACK OF SLANDEROUS AND FALSE MATERIALS THIS
MAN HAS CONTINUED TO MAIL AND FAX TO ME AND TO MY STAFF
AND TO OUR CHURCH MEMBERS. YOUR HONOR, I WOULD LIKE TO
GIVE YOU A LETTER THAT HE WROTE HIMSELF ASKING THAT HIS
MEMBERSHIP BE REMOVED FROM MY CHURCH, IF I MAY. THE
COURT REPLYS, ALL RIGHT. WELL, IN THIS LETTER DOES HE
THREATEN PHYSICAL HARM TO YOU? MR. BECK REPLYS, NO SIR.
ITS JUST A POINT I WANT TO MAKE THAT HE HAS VOLUNTARILY
WITHDRAWN HIS MEMBERSHIP FROM OUR CHURCH, BUT HE WONT
LEAVE OUR CHURCH ALONE. MR. BECK LATER CONTINUES,
VOLUNTARILY REMOVING HIS MEMBERSHIP FROM OUR CHURCH.
AND AFTER THAT LETTERBY THE WAY , IN THE LETTER HE SAYS
THIS ACTION I PRAY WILL BRING CLOSURE TO OUR CURRENT
DISPUTE AND PROTECT MY WIFE, CHILDREN AND CHURCH BODY
FROM ANY FURTHER ACTION ON THIS MATTER.
107.MR. BECK FURTHER ADVISES JUDGE PALOMINO, YOUR HONOR,
ALL I WANT OUT OF THIS WHOLE THING IS FOR THIS MAN TO LEAVE
THE CHURCH BODY ALONE. TO DISCONTINUE STALKING ME AS
HES BEEN DOING ON A REGULAR BASIS, AND TO BETO
DISCONTINUE SLANDEROUS MATERIALS MAILING OR FAXING OR e-

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MAILING TO ME AND OUR CHURCH MEMBERS. I HAVE GOT A PILE

HERE OF STUFF THAT WOULD WASTE YOUR TIME READING, BUT
ITS SLANDEROUS AND UNTRUE AND--. AND MR. BECK ALSO
STATED, NO, ONCE AGAIN, THIS IS NOT AN INTENT BECAUSE OF
HIM CHALLENGING PHYSICAL HARM, BUT RATHER FEAR,
INTIMIDATION, BECK THEN CREATED A FRAUDULENT
DESCRIPTION OF AN EVENT TO EXCITE THE JUDGE TO ORDER THE
RESTRAINING ORDER AS NEEDED AND DID NOT SAY PLAINTIFF WAS
INVITED TO BE AT THIS BUSINESS MEETING BY OTHER MEMBERS SO
THE TRUTH COULD BE TOLD, AND MR BECK CONTINUED,
THREATENING TO BUST INTO A CHURCH SERVICE.
AND HE HAS COME ON THE PROPERTY AND WAS STOPPED BY
SEVERAL USHERS BECAUSE HE WAS GOING TO BUST INTO THE
SERVICE. IN ADDITION MR. BECK INFERS THAT HE IS THERE IN THE
COURT OF JUDGE PALOMINO ON BEHALF OF THE MEMBERSHIP AT
LARGE BECAUSE OF SAYING, LIKE I SAID, WED (emphasis added),
LIKE TO SEE THIS CONTINUE BECAUSE FOR THE PAST TWO
WEEKS THERES BEEN A REAL PEACE AROUND THE CHURCH
PROPERTY WITHOUT THIS THING CONTINUING AND WITHOUT
GETTING THESE SLANDEROUS THINGS LIKE ON THE E-MAIL,
AND MY MEMBERSHIP ALSO GETTING THEM AND ALSO TURNING
THEM IN TO ME AND WONDERING ABOUT THEM AS WELL SO--.
8.--10. STRIKE

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111.Plaintiff also had duty as described above and herein and was asked by others
to investigate and to report other acts of Negligence and Frauds and Conspiracy
and Conspiracy to Defraud when Pastors and Pastors with Finance Committee
members and trustees sought to defraud the Membership, Government Agencies
and individuals, including Plaintiffs wife and minor children and Parents and
even now the Courts when Defendants continue to try to allege Plaintiff is a
Liar, Sower of Discord, Dangerous due to a Stress related breakdown
and a Stalker or a VIOLENT MAN. All accusations are pure frauds by
Defendants to cover up their illegal conduct and violations of the BY-LAWS in
an effort to allow Defendants to conceal their frauds to the membership and to the
courts and government agencies including the false reports to the sheriffs
department..
112.-26 STRIKE
127.PLAINTIFF ALLEGES THAT THESE MEMBERS AT LARGE OF THE
CORPORATION AS A WHOLE WHEN LEARNING IN JANUARY 2000, AT
THE BUSINESS MEETING THAT PLAINTIFF WAS TRUTHRUL IN THAT
UNREPORTED MONEY SHOWED UP IN THE FORM OF CERTIFICATE OF
DEPOSITS AND THAT IN SAID BUSINESS MEETING RON BECK TOLD
SEVERAL FRAUDS THAT WERE EXPOSED AS FRAUDS THESE
MEMBERS THEN CONTINUES TO EMPLOY RON BECK, WHO
CONTINUE THEIR ABUSE OF THIS PLAINTIFF EVEN BY THE WORDS
SAID AND THESE DEFENDANTS KNOW THAT THEIR ENTIRE
ACCUSATIONS THAT THEY BELIEVE PLAINTIFF WAS A DANGEROUS

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PERSON OR POTENTIONALLY DANGEROUS WAS A CREATED FRAUD BY

THE PASTOR.
127.29 STRIKE
130. Thus upon knowledge of said acts of the FBCCP PASTOR, acting
Individually, and acting as Officer of the Corporation of FBCCP, he had an
individual FIDUCIARY and a CONTRACTUAL DUTY created by the
Contract language of the FBCCP BY-LAWS to constrain themselves and
Ronald L. Beck, individual, and as Pastor of the Corporation and prevent actions
from Still causing and inflicting intentional harm, with malice upon Plaintiff and
Plaintiffs family as Defendant Ronald L. Beck conspired to cover up the acts
Plaintiff tries to report acts which violated the Florida Statues and FBCCP
Policies and Procedures as stated in FBCCP BY-LAWS and Citrus Park
Christian School Handbook and Plaintiff is still being violated by the FALSE
ACCUSATIONS CREATED by the PASTOR AND OTHERS as they still try to
discredit and harm the integrity of Plaintiff as Plaintiff tries to still expose their
ongoing un-civil acts and violations of law and violations of Plaintiffs CIVIL
RIGHTS AS THESE DEFENDANT CONTINUE TO PRACTICE HATE
CRIMES AND VIOLATE THE UNITED STATES OF AMERICA
CONSTITUTION AND OF THE CONSTITUTION OF THE STATE OF
FLORIDA AS THEY PRACTICE THESE HATE CRIMES KEEPING
PLAINTIFF FROM HIS CHILDREN BY THEIR FRAUDS AND LIES AND
AS THEY VIOLATE THE CONSTITUTIONS THAT CLEARLY STATE
THEY CANNOT USE OR HIDE BEHIND LAWS THAT TRY TO PROTECT

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THEM BECAUSE THE CONSTIUTIONS CLEARLY STATE NO LAWS

SHALL IMPEDE THE OBLIGATION OF A CONTRACT AND THESE
DEFENDANTS WERE OBLIGATED TO THIS PLAINTIFF TO NOT
SLANDER HIS GOOD NAME AND HARM HIS FAMILY BY THEIR
ACTIONS AS THEY ASSISTED THE SENIOR PASTOR TO VIOLATE THE
RIGHTS OF THIS PLAINTIFF BY FRAUDS.
131.

In COERSION, claiming superior exclusive knowledge he gained from his

hired experts Ronald L. Beck, using only the manipulated tainted information he
wanted to reveal to the investigators in order to get their findings to reinforce him,
inspired his wife, April Beck, and daughters Julianna Beck, Darla Beck, and
other pastors William Brown, III, Herman Meister, and other members of
FBCCP, Tim Jeffers, Karen Jeffers, Mike Shumate, Joe Howlett, Jackie Howlett,
Robert Giles, and Gary Leatherman, Geoff Smith, Jim Bates, Carl W. (Buddy)
Rawls, John Michael Corbin, Joe Kieras, Jim Leahy, Paula Powell, Tammy
Nunes, Mark Nunes, Craig Tucker, Dr. Lon Lynn, Gayle Lynn, Shawn Hopkins,
Jerry Miller and others, as individuals and collectively AS MEMBERS AT
LARGE AS THE FBCCP CORPORATION did and continue jointly
and independently conspire to tamper with fact finding and cover up of
evidence and tamper with and intimidate witnesses in order to Obstruct Justice
and continue frauds and create Frauds against Planitiff in order to discredit the
facts Plaintiff was trying to expose per Plaintiffs DUTIES to the Corporation per
the FBCCP BY-LAWS, CONSTITUTION, POLICIES and FLORIDA
STATUES and these individuals continue to harass Plaintiff and Plaintiffs family

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and continue to ruin and try to ruin Plaintiffs integrity and Plaintiffs
relationships with Plaintiffs family and friends despite the revelations in the Land
Use Hearings regarding Petition File Number SU 00-1203-KE and appeal number
01-1023 and the Circuit Court Case Number 01CA8320, as Gills Et al. V
Hillsborough County and the findings thereof confirming the positions Plaintiff as
CHAIRMAN OF THE LONG RANGE PLANNING COMMITTEE, tried to
warn of and advise of to the Corporation however Ron Beck named Plaintiff as a
liar and a controller and worrier and potentially violent due to a stress
related breakdown to the points that this became THE DISTRACTION BECK
AND THE PASTORS AND FINANCE COMMITTEE AND TRUSTEES
NEEDED TO REMOVE THE INVESTIGATION OF THEIR ACTS and as
planned TO GET THE DESIRED CONSEQUENCES OF KEEPING
PLAINTIFF QUIET ABOUT THE VIOLATIONS BY THESE DEFENDANTS
BY BECK AND MEISTER AND BROWN AND LEATHERMAN AND
HOWLETT AND JEFFERS AND NUNES AND RAWLS AND DR. LYNN this
threatened the Security anyone including Plaintiffs family might have from
trusting any advice that Plaintiff might provide for stating these warnings and
findings IN THESE ATTACHMENTS HEREIN AND NOW ALSO
Confirmed by the legal process. Plaintiff alleges that there are patterns as
examples that show Ron Beck when he does not get what he wants will use
deceptive practices and destruction of the opponents integrity in order to
manipulate his partly nave subordinates to the point that if they do not agree with
him he will turn on them and degrade them as well, not allowing them to defend

186

themselves from his attacks and these members knowingly allow these acts.
132.In coercion, Ron Beck and his pastors claiming in their pastoral roles to have
superior knowledge instigated marriage problems in Plaintiffs marriage while
they allegedly were trying to help and then used this created deceptions in order to
discredit Plaintiff from being of a moral standard to be in leadership or a
competent father or husband when BECK, MEISTER, BROWN AND
LEATHERMAN AND GILES ON SEPTEMBER 8, 1999, BY FRAUDS
removed Plaintiff from leadership so Plaintiff could not continue to prove out the
deceptions about the money trail and the building scheme and theft of the
childrens microphone and other frauds and acts of criminal negligence of Ron
Beck and the pastors, that Plaintiff became aware of as in Plaintiffs roles of
leadership as per POINT (12) herein and is trying to reveal to the membership by
Plaintiff doing his duty to the CORPORATION to reveal the frauds by the
Pastors.
133.{STRIKE ALL}33-43.
144. DEFENDANTS MEMBERS AT LARGE WERE NOTIFIED BY
MULTIPLE LETTERS AND EVEN THE MINUTES FROM THE
CORPORATION BUSINESS MEETINGS OF THE FRAUDS BY THE
CORPORATION OFFICERS AND ARE, BY THE GILS LAWSUIT AND
THIS LAWSUIT, BEING INFORMED OF THE BETRAYAL OF THE
INVESTIGATION OF THE CORPORATE OFFICERS FINANCIAL
REPORTING AND FRAUD BY DEFENDANT GARY LEATHERMAN TO
THIS PLAINTIFF AND TO THE CORPORATION YET DEFENDANTS AS

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MEMBERS AT LARGE STILL PRACTICED MULTIPLE HATE CRIMES OF

EXTORTION AGAINST THIS PLAINTIFF INCLUDING TELLING
PLAINTIFF TO LEAVE PUBLIC STREETS OR PUBLIC PROPERTY AS
PLAINTIFF TRIED TO REACH TO HIS KIDS AS A CONCERNED PARENT
AND INCLUDING ALLOWING THE FILING BY DEFENDANT BECK OF
THE CHARGES OF AS A STALKER WHEN PLAINTIFF HAD NEVER
BEEN LEGALLY DEPRIVED OF HIS CONSTITUTIONAL PARENT RIGHTS
THESE MEMBERS AT LARGE PUT THEMSELVES ABOVE THE LAW
AND PRACTICED HATE CRIMES AGAINST THIS PLAINTIFF
INCLUDING ATTEMPTED FALSE CHARGES TO LAW ENFORCEMENT
OFFICERS IN ORDER TO HAVE PLAINTIFF ARRESTED AND THESE
ACTS DID CAUSE PLAINTIFF TO BE HARRASSED BY A SHERIFF
DEPUTY ON MULTIPLE OCASSIONS WHEN PLAINTIFF WAS
INVESTIGATED ON THESE ALLEGED AND FALSE CHARGES
REPEATEDLY CREATED BY VARIOUS MEMBERS AT LARGE AS THEY
WILLINGLY PARTICIPATED IN THE CONSPIRACY TO KEEP PLAINTIFF
FROM BEING FOUND TRUTHFUL AS THE CHAIRMAN OF THE LONG
RANGE PLANNING COMMITTEE DUTIES REQUIRED PLAINTIFF
TELLING THE TRUTH NOW BEING REVEALED IN THIS LAWSUIT AS
PLAINTIFF WAS FOUND TO BE TRUTHFUL IN THE CASE BEFORE
JUDGE ARNOLD IN GILS V. HILLSBOROUGH COUNTY STOPPED THE
CORPORATION FROM BUILDING ON THE NEW PROPERTY AS
PLAINTIFF ADVISED THE MEMBERSHIP AT LARGE AND THIS

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MEMBERSHIP AT LARGE ACTED WILLFULLY TO TAMPER AND MAKE

FALSE ACCUSTIONS AGAINST THIS PLAINTIFF BECAUSE THIS
PLAINTIFF WAS OBEYING THE LAWS THIS MEMBERSHIP AT LARGE
WAS TRYING TO VIOLATE BUT NOW STOPPED BY THE COURT
RULING OF JUDGE ARNOLD.
145.At all times herein mentioned, Defendants Ron Beck, was the agent or
employee or both of Defendant First Baptist Church of Citrus Park, and in doing
the things herein alleged was acting within the course and scope of such agency
and with permission and consent of his codefendant and with the authority for the
Defendant First Baptist Church of Citrus Park as membership at large.
146.{STRIKE}46-49.
150.Defendant Ron Beck speaking as the moderator of the meeting and as the
Senior Pastor and as a member of the Committee answered: Pastor Beck- No we
have not checked. We will check with legal matter so see if we would have any
problems.
151.{STRIKE}
152.Defendant Ron Beck speaking as the moderator of the meeting and as Senior
Pastor and as a member of the Committee answered: Pastor Beck- Brother Joe,
as chair, can I recommend that and pass that recommendation to our Chairman of
the Finance Committee and have him dig into that and find and get information
for you.
153.At the time defendants made the above representations to Plaintiff, all
Defendants were aware but did not inform Plaintiff that they were not

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reporting in full all monies for many QUARTERLY REPORTS , A detailed and
comprehensive report of all receipts and disbursements, balances, etc., of the
Church and the Christian School, but implied that all reported information was
truthful and complete so no Audit would be necessary because their alleged selfrighteous motives to be as pure as the driven snow would satisfy. Defendants
much later admitted to Plaintiff that the Senior Pastor did not believe in reporting
the fact that the Corporation had several bank accounts so this committee making
a statement that that is when each and every check was written out of the church
and the school for the entire year ending June 30, 1995, was looked at by at least
one of the five Finance Committee members., may or may not have been true if
the Total Committee was not privileged to know about unreported bank accounts.
154-57-STRIKE
158.At the time Defendant made the representations herein alleged Defendant had
superior and exclusive knowledge of these unreported funds because the Senior
Pastor Ron Beck intended to keep secret accounts for use in the special projects
and not report these accounts being used by deceptions.
159-61-STRIKE
162.At all times herein mentioned, defendant RONALD L. BECK, was the agent
of Defendant First Baptist Church of Citrus Park, and in doing the things herein
alleged was acting within the course and scope of such agency and with
permission and consent of his codefendants and with the authority for the
Defendant First Baptist Church of Citrus Park and Membership.
163.On or about January 23, 2000, defendant Ronald L. Beck, falsely and

190

fraudulently represented to Plaintiff that the FBCCP BY-LAWS stated First of

all our bylaws state that every motion of active business to be conducted in any
regular scheduled business meeting must be in writing.
64.-70. {STRICKEN}
COUNT VI
MALICIOUS PROSECUTION
171.

Plaintiff, Randall Townsend, Pro Se, sues the Defendant, RONALD L.

BECK, individually, and in his Official capacity as REVERAND RONALD L. BECK,

SENIOR PASTOR OF FBCCP, and sues DEFENDANTS AS MEMBERS AT LARGE
OF FBCCP AS NOTED HERIN AND OTHER TO BE NAMED AS DISCOVERY IS
JUST STARTING AND WILL CONTINUE IN capacities as stated above herein in the
Corporation known as First Baptist Church of Citrus Park and Plaintiff sues THE
CORPORATION KNOW AS First Baptist Church Of Citrus Park.
172.This is an action for damages that exceed $25,000.00.
173.Plaintiff is a citizen and resident of Hillsborough County, at all times material
hereto, and resides in Hillsborough County. These Defendants all reside in the
State of Florida and held positions of Officers of Defendant First Baptist Church
of Citrus Park. Defendant First Baptist Church of Citrus Park is a Florida
Corporation, duly licensed and organized under the laws of Florida, whose main
office and doing business at 7705 Gunn Highway, Tampa Florida.
174.Plaintiff re-alleges all above points herein as proof of OUTRAGEOUS AND
ODIOUS ACTIONS BY THESE DEFENDANTS DONE WITH MALICIOUS
INTENT TO ALLOW THESE DEFENDANTS TO CONDUCT THEIR

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FRAUDS TO THIS PLAINTIFF, PLAINTIFFS FAMILY, THE COURTS AND

TO THESE CITIZENS OF HILLSBOROUGH COUNTY.
175.On or about NOVEMBER 2, 2001, the Defendant RONALD L. BECK
INDIVIDUAL AND AS IN HIS OFFICERS POSITION AS SENIOR PASTOR
OF THE FBCCP AND AS THEIR ELECTED REPRESENTATIVE BY HIS
OWN STATEMENTS PRESENTED BY HIS OWN WORDS TO JUDGE
PALOMINO commenced civil preceding against the Plaintiff by filing with the
Clerk of this Honorable Court, a Complaint, with Exhibits attached, a copy of
which is attached hereto and made a part of hereof by reference as EXHIBIT FOUR.
176.A summons was also duly issued by the Clerk of this Honorable Court, and
was served, together with a copy of the Complaint and Exhibits thereto, on the
Plaintiff and the Defendants in this present action. Moreover, that litigation was
prosecuted to its conclusion in this Court by the Order as attached Exhibit FIVE.
177.On November 2, 2001, when the Complaint referred to in the paragraph above
was filed, the Defendant RONALD L. BECK individually, and in his capacity as
SENIOR PASTOR OF THE CORPORATION OF FBCCP AND DEFENDANTS
AT LARGE OF THE FBCCP AS THEY AGREED TO SUPPORT
DEFENDANT BECK IN HIS ACTION AS INDIVIDUAL AND SPOKE FOR
THEIR CAUSE INTENTIONALLY CREATED herein knew that the allegations
contained in the Complaint were false and untrue; that the action was brought
without probable cause; and further, that the action was instituted and prosecuted
with malice and without any reasonable probability of success. Furthermore, the
actions by Defendant was an attempt to fraud the Court with granting a Stalking

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Order so to bar Plaintiff from investigation process and exposing facts to other
FBCCP Corporation members and to the other churches and to the general public
that exposed the Deceptions by Defendant Ron Beck individual and other Church
officers and their own personal attacks against this plaintiff and his family acted
against as hate crimes. Defendant Ron Beck in the Complaint
did write two fraudulent facts to the Judge to induce a TEMPORARY
INJUNCTION FOR PROTECTION AGAINST REPEAT VIOLENCE case
file # 01-15183, Hillsborough County, Florida. However, notwithstanding
these facts, the Defendant signed this Complaint and caused it to be filed with the
Clerk of this Court and served on this Plaintiff in this present action. These acts
were performed by the Defendants with the intent to injure the Plaintiff, and to
bring his good name into public disgrace and disrepute, and with the further intent
to with the Stalking Order prevent Plaintiff from coming to the FBCCP
Corporation and exposing to the members the frauds and deceptions of Ron Beck,
Defendant and the others named above herein and continue his frauds to
Plaintiffs wife that Plaintiff was dangerous, that the action was filed with the
specific and malicious intent on the part of the Defendant to coerce the Court
with fraud from his testimony and from witnesses Ron Beck tried to call who
intended based on subsequent testimony intended to give false information to the
Honorable Judge Palomino to induce him to grant a stalking order and to
further keep Plaintiff from speaking to the FBCCP Corporation where Plaintiff
was a member in good standing and holding the offices as in POINT (12) above
herein until the Fraudulent statements and Fraudulent actions were started by this

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Defendant when Plaintiff was attempting to report to the Members the false
business statements and other misrepresentations by Reverend Ron Beck and
others herein. NOTICE of the issues of his improper actions are contained above
herein and incorporated herein this count.
178.The civil proceedings filed by Ronald L. Beck and for FBCCP commenced on
November 15, and terminated with the entry of this summary final judgment in
favor of the Defendant therein, the Plaintiff here, a true copy of which is attached
here to as Exhibit SIX and it incorporated herein by reference.
179.The Plaintiff thereby contends that, in light of all facts as itemized and
confirmed above, the original action brought against the Plaintiff here was (1)
brought by the party that is the Defendant(s) here; (2) found to be without
probable cause; (3) instituted with malice; (4) terminated in favor of the Plaintiff;
and (5) found to be the action for which the Plaintiff has suffered injuries and
damages.
180.Moreover, the Defendants here is unable to establish that the original
proceeding was instituted and prosecuted on the good faith reliance of legal
counsel; or, that the proceeding was instituted pursuant to an independent
investigation by a responsible attorney of law, licensed to practice in the state; or
that the Defendant is or represents, or is and agent of, a public entity or state
agency that is immune from liability for causes of action in tort.
181.The circumstances under which the above-described acts were committed by
Defendants constitute a wanton and reckless disregard for the Plaintiffs legally
protected rights and interests, and a willful attempt to injure the Plaintiff.

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182.By reason of both the false Complaint executed and filed with malice, and
attempted extortion and frauds, and a direct intent to injure the Plaintiff as noted
above, the Plaintiffs reputation to his family and in the community where he lives
and worked and served in many civic functions has been irretrievably damaged,
and the Plaintiff has been humiliated, frightened by his coercion with Sheriff
Deputies on multiple occasions including the April 27, 2000, Deacons meeting
where defendants Beck, Leatherman and Howlett alleged Plaintiff was a violent
man and a liar, shamed, and intimidated, and again in July 2001, and by multiple
traffic stops by Deputy Joe Howlett when Plaintiff was not in violation of any
laws and followed on two occasions and abused even at toll booths and at the
public mall and at the public post office and restaurants and has suffered great
duress in watching William Brown multiple times put at risk the health of many
minor children and in July, 1999, violate by an immoral act upon Plaintiffs now
former wife, yet Plaintiff was called the liar for reporting such act and Plaintiff
has suffered great mental pain thereby as Plaintiff was forced now for many years
to watch the pain and suffering these officers and members at large as Doctor
Lynn and these Sheriff Deputies Howlett and Jeffers professional actions were
allegedly a cover for their own criminal acts as these conspirators do daily to
destroy this family and the lives of these people and this plaintiff as they still
conspire to put more people at risk who do not follow the wishes of Ron Beck and
his pastors. PLAINTIFF BECAUSE OF THE LIES STARTED BY RON BECK
HAS NOW NOT BEEN ABLE TO SEE OR SPEAK TO HIS KIDS SINCE
LATE 2002, BECAUSE OF THE LIE THAT PLAINTIFF IS VIOLENT AS THE

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ACTION FILIED BY RONALD L. BECK FOR HIMSELF AND THE

CHURCH WAS USED EVEN OUT OF CONTEXT BY ATTORNEY FOR THE
WIFE IN THE DIVORCE CASE TO JUDGE TIMMERMAN WHO RATHER
THAT SHOW PROPER JUDICIAL PROCESS INSTEAD TOOK THE LIES OF
STACEY TURMEL AND DID USE HER POSITIONS ON THE BECK
ACTIONS AS A WAY TO ALL THE MORE HARM AND DAMAGE THIS
PLAINTIFF/HUSBAND/FATHER.
Moreover, the expense of defending against the lawsuit, both in this Court and in
the District Court of Appeal, has been incurred on behalf of this Plaintiff, and the
health of this Plaintiff and of the Plaintiffs spouse, children and parents and
family and others has been damaged and the future expenses of trying to repair
the mental duress by professional counselors that will be needed to restore this
families relationships destroyed by the years of frauds by these alleged pastors.
183. WHEREFORE, the Plaintiff demands trial by jury on all issues so triable and prays
this Court will award damages against Defendants, Ronald L. Beck, individually,
Reverend Ronald L. Beck as senior pastor of First Baptist Church of Citrus Park
and First Baptist Church of Citrus Park, Inc. including court costs, and any other
further relief as the Court may deem proper.
184. Plaintiff Townsend alleges that by Defendants Beck, Meister, Karen Harrod
Townsend, Leatherman, Jeffers, Howlett, Geoff Smith, Corbin, Schumate, Bates, Rawls,
Brown, Grant, Gibbs, Gardner, Scruggs, Gray, Denny, Rolfes, Deacons, Trustees, School
Board Members, Long Range Planning Members, Finance Members and other deceptions
of attorneys listed herein and as DOE and Judges named herein knowingly using

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intentional, negligent, and recklessness to miss use State Laws, Federal Laws, Rules of
Law per Judge Crenshaw, as done by Turmel, Solomon and each Judge Named above
herein and failure to Honor the FBCCP Contract known as the BY-LAWS that the Plea
of Plaintiff Townsend to show me the money and Stop the Schism building scheme
frauds has been delayed and allowed allegations by Townsend to be ignored, and
recklessly and negligently handled by all Defendants as named above and herein despite
that Townsend has followed the RULES OF the BY-LAWS and RULES OF LAW and
CASE LAW in trying to OBTAIN DISCLOSURE, PROTECTION, AND A STOPPAGE
OF DAMAGES BY EACH DEFENDANTS RECKLESSNESS AND TORTS and each
Defendant has been duly noticed, warned and advised on True By-Laws and Legal
Process and however continue their torts against these Plaintiffs still being damaged to
this day and thereby became a joint tortfeasor violating the Rights of Plaintiffs herein.
185.Plaintiff Townsend alleges that Defendants JOE PALKO, Individual, JOE PALKO,
EMPLOYEE AS Vice President (Kmart) SEARS HOLDING COMPANY, RANDY
BRIGHT, Individual, RANDY BRIGHT, (Kmart) EMPLOYEE AS REGIONAL
COACH, KEITH JOHNSON, Individual, KEITH JOHNSON, (Kmart) EMPLOYEE AS
REGIONAL HUMAN RESOURCES DIRECTOR, SHANE PEARSON, Individual,
SHANE PEARSON, (Kmart) EMPLOYEE AS LOSS PREVENTION DISTRICT
COACH, KATHERINE CUNNINGHAM, Individual, KATHERINE CUNNINGHAM,
(Kmart) EMPLOYEE AS DISTRICT COORDINATOR SECRETARY, DANIEL J.
GENTILE, Individual, DANIEL J. GENTILE, (Kmart) EMPLOYEE AS DISTRICT
COACH, DOUG LIVINGSTON, Individual, DOUG LIVINGSTON, AS KMART
EMPLOYEE LOSS PREVENTION COACH, AT STORE 3092, ROY ALLEN,

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Individual, ROY ALLEN, KMART EMPLOYEE AS ASSISTANT COACH, AT

STORE 3092, DR. LINDA ROWE CAMPBELL, Individual, DR. LINDA ROWE
CAMPBELL, (Kmart) EMPLOYEE AS PHARMACIST AT STORE 3092
BARBARA BOOTH, Individual, BARBARA BOOTH, (Kmart) EMPLOYEE AT
STORE 3092, as individuals and as Kmart/Sears employees, agents and supervision and
knowingly, intentionally, recklessly and negligently did frauds and omissions of truthful
disclosure in violations to this Plaintiff Townsend as an employee of KMART/SEARS
Holding as retaliations of Plaintiff Townsend as a Whistle Blower of illegal activities
of these individuals and of the Corporations and as violators of Plaintiffs religious rights
and freedoms and civil rights and freedoms violations including race, religion and other
civil rights and thereby the Corporation of KMART/SEARS HOLDING INC. is
vicariously and directly responsible and liable under the law for all actions of all
Defendants as retaliations against Plaintiff Townsend and responsible for damages
incurred by Plaintiff Townsend as stated herein and per all laws for the protection of this
Plaintiff Townsend and those who Plaintiff Townsend attempts to represent and serve.
186. Plaintiff Townsend states that Defendant Roy Allen on or about October 6, 2005,
did admit and apologize to Plaintiff Townsend that he never meant for his plan with
Defendant Dan Gentile to get Roy Allen his own store would lead to sabotage and the
termination of Plaintiff Townsend but that Dan Gentile had betrayed him also but it was
too late to change things as Roy Allen with Doug Livingston, Barbara Booth and others
had knowingly, intentionally, recklessly and negligently given false statements and
omitted truthful disclosure against this Plaintiff Townsend.
187. Plaintiff Townsend also alleges that Pearson and Gentile, Livingston, Allen,

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Booth, Rowe-Campbell and Bright and did knowingly, intentionally, recklessly and
negligently conspire and omit truthful disclosure of Plaintiff Townsend to management in
verbal reports, written reports and store condition visit reports and of Plaintiff Townsend
decisions and management style and skills being done for the showing of Reasonable
Duty to the KMART SEARS CORPORATION as a disguise of frauds and negligence
and tort conduct of Pearson, Gentile, Livingston, Allen, Booth, Rowe and Rick Gould
and others and at times the directives of Pearson and Gentile were illegal, intentionally
conspired fraud, extortion and breach of KMART SEARS CORPORATE POLICIES and
violations of federal and state and county and city laws and policies these intentional
actions by Pearson and Gentile caused violations of civil rights of Plaintiff Townsend and
his termination of employment and damages to Plaintiff Townsend reputation, character
and opportunities for future employment and well being as stated herein.
COUNT I
BREACH OF DUTY FRAUD BASED ON PROMISE MADE WITHOUT
INTENT TO PERFORMAGAINST DEFENDANT RONALD BECK,
Individually, and in his Corporation officer capacities as in the Corporation known
as the First Baptist Church of Citrus Park and against the Corporation d/b/a the
First Baptist Church of Citrus Park
188.Plaintiffs re-allege all points above and below and incorporates them herein.
189.Comes Now Plaintiff Randall Townsend and sues Defendants Beck, individually,
Beck as Senior Pastor and Beck as Officer of the Corporation(as Beck) and states:
190.On or about August 1999, Defendants Beck falsely and fraudulently represented
that he was concerned about the Plaintiff being in leadership due to the
allegations he had allegedly learned from his employee, Karen, the wife of Plaintiff
Townsend. Defendant Beck stated that he intended to be our marriage counselor

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while we worked through our problems Also he said he intended to get us together
to meet with him after he returned from his vacation to Jeckyl Island, Georgia on or
about the next week.
191.The above representations made by Beck were in fact false. The true facts were:
Ronald Beck later in September 1999, said he forgot he made the promise to set up
the appointment when he returned from his vacation and Ronald Beck later said he
never intended to mediate any marriage problems. Ronald L. Beck than later said
he was too busy to keep an appointment he arranged with Plaintiff and Plaintiffs
wife now separated due to his repeated threats and false charges against Plaintiff,
because he had to go on another vacation(a cruise) and was too busy with his family
at the holidays to keep the appointment he claimed he tried so hard to arrange so all
parties could allegedly sit down and clear up all these little misunderstandings.
Further, upon full disclosure of the FBCCP and Corporation Credit Card Statements
of Ronald Beck as Plaintiff Townsend demanded so to clear up the marital extortion
used by the Schism that the facts reveal that exposure of the frauds contained in said
documents now revealed until June/July 2006, as shown herein, Plaintiff alleges
would not and then could not have been used to continue the extortion, conspiring,
deception and control over the alleged irreconcilable differences of the marriage
and thereby the Scheme of the Schism Beck controlled would have been exposed
thus not allowing Beck and the others of the Corporation alleging to be Honorable
Officers to not continue their frauds and omissions of truthful disclosure to all.
192.Defendant Beck made these representations knowing them to be false and with the
intent to defraud and deceive this plaintiff and plaintiffs wife and Church Members

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of the Corporation into thinking he had a pastorial superior perspective view that he
was not able to reveal to the Corporation of Members, the any and all details of
Plaintiffs in his view allegedly integrity issues which caused Beck to remove
Plaintiff from all positions of leadership on September 8, 1999. This false reliance
was his cover of darkness to induce deceptions to Plaintiff and Plaintiffs wife and
children and to allow deception to the Corporation members to be fearful of
Plaintiff that Plaintiff was dangerous to anyone. And Defendant Beck, until his
letter of July 26, 2001, and filing his petition to the Court of Judge Palomino had
only revealed to Plaintiff that if Plaintiff Came to the Church or School property
and tried to tell people the truth that Defendant Beck said he would have Plaintiff
arrested on whatever charges he could create so people could not hear Plaintiffs
side of the two way street. Therefore, Plaintiff feared arrest even just trying to
pick up his minor children from school or church if Defendant Ron Beck desired
additional retaliations to assist him keeping his frauds and deceptions ongoing or
needed another episode with which to distract members from the facts.
193.Plaintiff, at the time up until September 8, 1999, defendant made the above
misrepresentations and at the time Plaintiff took the actions herein alleged, was
ignorant of the full falsity of defendants misrepresentations that he was innocent of
trying to intentionally destroy Plaintiff and believed them to be true. In reliance on
these representations, plaintiff was induced to and did underestimate the level of
corruption of corporation funds not being reported and did underestimate the schism
as persons involved in helping Defendant Beck to manipulate the reporting of
Corporation assets and collecting of funds and of other frauds to the Corporation

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and Plaintiff did underestimate the extent that proving Defendant Beck and the
others were guilty in their schemes would have on the destruction of Plaintiff s
good name and on the destruction on the marriage of Plaintiff and the separation
and destruction of the relationship Plaintiff would have with his own children.
Plaintiffs reliance on defendants representations was justified because of the
concealments and previous representations by Defendants that the errors of the
Business Meetings were unintentional errors or mistakes and due to the fact the full
coercion of pastors, finance committee members and trustees had not yet been
exposed and due to the fact that this Defendant represents himself to a highest
standard as a Pastor and thereby the Defendant FBCCP Corporation, extended,
supported, approved and did not conduct themselves per the 617 Florida Statues
nor per the FBCCP BY-LAWS and did intentionally, knowingly and recklessly and
willingly give Benefit to Clergy in violation of the BY-LAWS.
194.As a direct and proximate result of defendants fraud and deceit, plaintiff has
sustained financial, emotional, damages to his reputation, loss of his family and has
now not had a relationship with or seen his children for many years due to the
frauds of Beck allegedly as a Clergy and suffered battery and multiple other
damages yet to be fully determined.
195.Wherefore, plaintiff demands judgment against Defendant Ronald Beck, individual,
Ronald Beck as Senior Pastor and the Membership at Large of the FBCCP and the
FBCCP Corporation.
A. For General Damages
B. For the following special damages for emotional distress and
C. For the pain and suffering of loosing Plaintiffs relationship with Plaintiffs wife

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and children due to the frauds specifically told by Defendant Ron Beck
representing himself as a marriage counselor and
D. For the damages to Plaintiffs good name and reputation.
E. For the costs of suit incurred in this action.
F. For the loss of Plaintiff Odessa Florida Home
G. For Compensatory Damages
H. For the loss of Plaintiff Townsends employment and loss of earning opportunity
I. For Punitive Damages
J. For any and all legal and attorney fees.
K. For such and other further relief as the Court may deem proper.
COUNT II
BREACH OF DUTYFRAUD BASED ON PROMISE MADE WITHOUT
INTENT TO PERFORMAGAINST DEFENDANT GARY LEATHERMAN,
Individually and in ALL his Corporation Officers capacities and First Baptist
Church of Citrus Park as the Corporation of the First Baptist Church of Citrus
Park and Membership at Large and of the First Baptist Church of Citrus Park as a
Corporation.
196. Plaintiffs re-allege all points above and below and incorporates them herein.
197.Comes Now Plaintiff Randall Townsend and sues Defendants Gary
Leatherman,(Leatherman) individually, and Leatherman as Officer of the
Corporation in all positions as stated herein (as Leatherman) and First Baptist
Church of Citrus Park as the Corporation of the First Baptist Church of Citrus Park
and Membership at Large states:
198.At all times herein mentioned defendant Leatherman was the agent of Defendant
First Baptist Church of Citrus Park and in doing the things herein alleged was
acting within the course and scope of such agency and with permission and consent
of his co-defendant and with the authority for the Defendant First Baptist Church of
Citrus Park and Membership at Large.
199.On or about July 28, 1996, quoting from a FOURTH QUARTER BUSINESS
MEETING, member Jim Bates speaking collectively for several members including
this Plaintiff asked: Are there any changes that came out of this review that could

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be recommended by the Finance Committee in the way we are presently doing

business in our Church finances.
200.Defendant Gary Leatherman, individual, and speaking in his Official capacity as
Chairman of the Finance Committee, speaking for the Committee and the Pastors as
members of said committee said:
Yes sir, there were many that had come up. Some were adopted. Some
were rejected, and some were still under discussion. That one that comes
to mind right now; the things we want to do differently on casual labor, on
how we count for casual labor. We are showing up some of the record
keeping of that because we want to make sure that we are pure as the
driven show in the eyes of the IRS. In that area we made some changes.
In others we were still discussing on different ways of doing things. We
know it will take a while before we come to a conclusion on just what is
the optimum way. We do not want to burden the staff, but we also want to
make sure that in the eyes of any body outside that is looking at our
congregation, that is looking for reasons to not let us keep our tax-exempt
status, that we are pure as the driven snow.
201.At the time the defendant made the above representation to plaintiff, defendant was
aware but did not inform plaintiff that his motives were not come as clean as pure
as the driven snow nor did Defendant intend to fully report all funds in a detailed
and comprehensive report of all receipts and disbursement, balances, etc. based on
the guidelines and timelines in the FBCCP BY-LAWS but later actions by
Defendant showed he was a participant in the non-disclosure of the true full
financial records and that Gary Leatherman assist others to conceal rather that
reveal the true total financial records as the BY-LAWS required. This concealment
of facts lead to conspiracy by Beck, Brown, Leatherman, Jeffers and Meister to
deceive the Corporation (church/school) members into additional fraudulent
actions.

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202.The suppression of the fact that Defendant Gary Leatherman was willing to hide
key financial information was likely to mislead plaintiff and did in fact mislead
plaintiff in the light of the other representations by defendant concerning later
discovered miss-uses of the funds by the Pastors and that Gary Leatherman later
alleged he also was road-blocked victim by the Pastors and thus could not report
correctly the true financial records of the Corporation.
203.Defendants suppress this information with the intent to induce Plaintiff to confide in
his leadership implying he wanted to align with Plaintiff to induce the proper
information being allegedly withheld by the Pastors solely not only from the
Corporation but also from the men on the Finance Committee. This suppression
gave false information to this Plaintiff and thus created a false trust and then
allowed Defendant Gary Leatherman to allegedly claim he was able to be an
unbiased participant in the Personal Committee who was assigned in January 2000,
by Ron Beck to assist Plaintiff investigate the charges of Plaintiff. This suppression
of key information is a basis for proof of a conspiracy to continue to keep the true
financial misuses not just of the Pastors not exposed to the Plaintiff and the
Corporation but to keep one from learning that the Finance Committee was also part
of keeping the entire funds from the Corporation members from being revealed so
to escalate their giving to the general fund and to the Building Project in order to
keep other members from even listening to the allegations of this Plaintiff.
204.Plaintiff, at the time these failures to disclose and suppression of facts occurred and
at the time plaintiff took the action herein alleged, was ignorant of the existence of
the facts that defendant suppressed and failed to disclose. Had plaintiff been aware

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that Defendant Gary Leatherman had not disclosed to the Corporation in the
Business Meeting that he was also not truly part of the conspiracy to not report
Quarterly all of the Corporation funds held in secret, and or the acts of misuse of
funds by the Pastors, Plaintiff would not have agreed to communicate private
information to defendant Gary Leatherman to his repeated commitment to be as
pure as the driven show and allow Gary Leatherman to have any contact as a
mediator to Plaintiffs family or any other member of the Corporation as he
allegedly was speaking 100% the total words of the Plaintiff.
205.At the time Defendant made these representations herein alleged, a confidential
relationship existed between Plaintiff and Defendant because Plaintiff understood
that the process in the FBCCP CONSTITUTION AND BY-LAWS to Plaintiffs as a
fellow member and Defendant agreed to assist Plaintiff in a proper investigation of
the violations by the Pastors.
206.At the time Defendant made the representations herein alleged, Defendant had
superior knowledge that he was an active participant in keeping information hid
from Plaintiff and from the Corporation that the financial records presented to the
Plaintiff and Corporation were in fact not complete for years as part of a scheme to
raise more funds for the building program and other fund raising ventures and or be
dipped into without getting approval from a specific governing committee and missapplying of designated funds.
207.Because of the Defendants superior and contractual relationship and Defendants
superior knowledge, Defendant had a DUTY to make a full disclosure to Plaintiff of
all facts material herein due to Plaintiff trusting Defendant was to be true to his

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words to always be as pure as the driven snow in keeping safe the Plaintiffs
family from the fraudulent attacks by the Pastors while Plaintiff tried with the help
of Defendant Gary Leatherman to allegedly investigate the violations by the Pastors
for the Congregation and Defendant had a duty to disclose the fact that he was
actually not willing to enforce the CONSTITUTION and BY-LAWS and produce
the full financial records for the Congregation and as to how he had contributed to
the frauds. PLAINTIFF would then not have trusted Gary Leatherman during
the very delicate time of August 1999, to April 2000 and not have been shocked
and surprised by the betrayals by Defendant Gary Leatherman when he
turned publicly against Plaintiff Townsend in April 2000, and would not have
allowed Defendant to be a trusted confidant between Plaintiff and Plaintiffs
family and other friends or other members of FBCCP and or the Corporation
allegedly acting as an honorable Church and School thereby the Defendant
FBCCP Corporation, extended, supported, approved and did not conduct
themselves per the 617 Florida Statues nor per the FBCCP BY-LAWS and
did intentionally, knowingly and recklessly and willingly give Benefit to
Clergy in violation of the BY-LAWS and other State and Federal Laws stated
herein all paragraphs and now incorporated herein.
208.As a direct and proximate result of Defendants fraud and deceit, Plaintiff has
suffered loss of Plaintiffs family and marriage, financial damages, emotional
distress, slander, defamation to Plaintiffs character and tremendous abuse to
Plaintiffs integrity and battery and possibly un-repairable without vindication
through this lawsuit.

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209.WHEREFORE, plaintiff Townsend demands judgement against Gary Leatherman,

individual, and the First Baptist Church of Citrus Park Membership at Large and as
members named in this full complaint and the Corporation of the First Baptist
Church of Citrus Park as follows:
a. For General Damages
b. For special damages due to the loss of Plaintiffs family relations and damages
to plaintiff Townsends reputation and good standing in the community and in
Plaintiffs emotional pain and suffering due to these losses
c. For Compensatory damages
d. For cost of this suit incurred in this action
e. For such other and further relief as the Court may deem proper.
COUNT III
BREACH OF DUTY FRAUD BASED ON PROMISE MADE WITHOUT
INTENT TO PERFORMAGAINST RON BECK; WILLIAM BROWN;
HERMAN MEISTER; GARY LEATHERMAN;TIM JEFFERS; JOE HOWLETT;
MIKE SHUMATE; MARK NUNES; ROBERT GILES; GEOFF SMITH;
individually and in their Corporation Officers capacities as stated and the
CORPORATION OF THE FIRST BAPTIST CHURCH OF CITRUS PARK
210. Plaintiffs re-allege all points above and below and incorporates them herein.
Comes Now Plaintiff Randall Townsend and sues Defendants RON BECK; WILLIAM
BROWN; HERMAN MEISTER; GARY LEATHERMAN; TIM JEFFERS; JOE
HOWLETT; MIKE SHUMATE; MARK NUNES; ROBERT GILES; GEOFF SMITH;
individually and in their Corporation Officers capacities as stated and the
CORPORATION OF THE FIRST BAPTIST CHURCH OF CITRUS PARK
and states:
211.On or about at various times, Defendants falsely and fraudulently represented that
all Corporation assets and funds and income and expenses were being properly
reported per the Florida Statutes and Church By-Laws legal duty and process.
212.On or about at various times, Defendants falsely and fraudulently omitted truthful

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disclosure as to the General Accounting Process of the Officers of the Corporation

and themselves and presented their superior knowledge with intent to induce
Plaintiff to blindly trust their alleged pure as the driven snow honesty and
integrity in all matters of their leadership and thus Plaintiff would not need to
investigate any allegations of mishandling of funds or misappropriation of corporate
opportunity.
213.On or about at various times Defendants empowered and retained the services of
themselves and allegedly outside C.P.A companies or other attorneys and hired
experts to investigate and advise the uses of all Corporation Funds but the Records
production of June/July 2006, revealed multiple years of frauds, mishandling of
Corporate opportunities, intentional frauds to the General Voting Members wrongly
conveying and then applying the alleged findings of these outside financial experts
causing Plaintiffs to incur loss from these false reports and false schemes to
defraud.
214.Plaintiffs allege that these inducements and actions were frauds and omissions of
truthful disclosure an as a result Plaintiffs were damaged thereby as reported and
alleged herein.
215.As a direct and proximate result of defendants frauds, deceit, and omissions of
truthful disclosure, plaintiffs has sustained financial damages and battery thereby.
216.WHEREFORE, Plaintiff Townsend demands an Immediate Injunction be granted
barring Beck, Meister, Smith, Howlett, Jeffers from any and all illegal violations of
law and that an independent accountant be immediately assigned to review all
FBCCP and CPCS Corporation Records and all private and personal records of all

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employees named herein this full complaint and judgement against Defendants and
each of them as follows:
A. For General Damages
B. For Special Damages for the loss of Plaintiffs relationships with his wife and
children and slander of reputation and defamation of character
C. For the cost of suit incurred in this action
D. For such other and further relief as the Court may deem proper.
E. For restitution of all lost assets of Plaintiffs and loss of employment and loss of
employment opportunities
F. For Punitive, Compensatory, Nominal damages
G. For any and all attorneys fees and court costs.
COUNT IV
INTENTIONAL MISREPRESENTATION OF FACTAGAINST RON BECK,
individually, and as Corporation Officer as stated above herein and the
CORPORATION OF THE FIRST BAPTIST CHURCH OF CITRUS PARK
217.Plaintiffs re-allege all points above and below and incorporates them herein.
218.Comes Now Plaintiff Randall Townsend and sues Defendants Beck, individually,
Beck as Senior Pastor and Beck as Officer of the Corporation(as Beck) and states:
219.On or about January 23, 2003, Defendants Beck falsely and fraudulently
represented the contents of the FBCCP BY-LAWS and stated:
Okay. I am bound by the bylaws of this church to tell you first of all that
we in no way can take action on your motion this evening. First of all our
bylaws state that every motion of active business to be conducted in any
regular business meeting must be in writing, So as your pastor, I would
encourage you, as a member of this Church to put in writing what you just
shared and I would encourage you to make it submitted to the Personnel
Committee. This is obviously a personnel problem.
220.Moderator Beck went on to say, If the pastor or the pastoral staff have accused you
falsely and can no longer help you then it is a matter that they as a body need to
review.
221.The above representations made by defendant Beck herein were in fact false. The

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true facts were: the BY-LAWS herein make no requirement that all motions be in
writing and per the,
BY-LAWS ARTICLE V. SEC 4. BUSINESS MEETINGS (e) All
members of the Church shall be entitled to vote in the Church business
meetingeach member being entitle to one vote. Any member may make
motions, or discuss motions, upon recognition of the Moderator. All
motions from the floor, unless deemed necessary by the Moderator, must be
referred to the proper committee for consideration and presented for action
at the next business meeting.
222.The above representation made by defendant Beck herein was to prevent Plaintiff
Townsend making an immediate motion that Beck and others immediately resign as
for all reasons as stated and invoked herein this complete complaint in all
paragraphs and Beck and the Schism knowingly, intentionally, recklessly and
negligently giving the alleged pastors Benefit of Clergy and violation of the BYLAWS as a means to continue the frauds of Beck and the Schism and that by
further revealing of the FBCCP Corporation records, Beck intended fraud by this
action knowingly and intentionally allowing Gary Leatherman to continue
manipulations and frauds to the Personnel Committee as admitted by Committee
Chairman Jim Leahy, Deacons as admitted by Chairman Mike Shumate, Finance
Committee as revealed by the produced Business Meeting and Credit Card
Statements in June/July 2006, School Board as revealed by the failure to obtain the
Special Use permits for the 18105 North Gunn Highway property and to the
General Voting Members by the full reports of the Business Meeting Minutes Of
Quarterly and Annual Reports revealed and these still concealed and these Plaintiffs
Herein still being deceived of misappropriation of corporate opportunity and frauds
and omissions of truthful reporting of all corporation assets as required by the By-

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Laws and Florida Statues and by the false allegations filed against Plaintiff Randall
Townsend in the General Church Meetings and the Special Called Business
Meeting of April 30, 2000, and by the false and fraudulent Criminal Charges filed
and pled before Judge Palomino on November 15, 2001.
223.Defendant made these presentations knowing them to be false and with the intent to
defraud and deceive plaintiffs and to induce plaintiffs to shut up at the time and to
act in the manner alleged herein in order to continue Becks and others as Pastors
and Leatherman and Trustees conspiracy to those who he would name to be on the
alleged investigation committee against other nave members of the Corporation
allowing those in the conspiracy to keep illegal acts from being discovered as
Plaintiff Townsend had been blocked and deprived from attending the previous
Quarterly Meeting and nor receiving the Quarterly Meeting Reports and Handouts
which just revealed in June/July 2006, in partial production of records per the Court
ORDER of Marva Crenshaw, which now reveal and prove the Corporation Officers
thefts, frauds and Breach of Duty and Contract violation and violations of Civil and
Criminal and IRS LAWS and therefore the MOTION for RESIGNATION or
CHURCH GENERAL MEMBERS VOTE COULD HAVE BEEN DEMANDED
ON JANUARY 23, 2003 as Beck and Other Officers as alleged Officers of the
Corporation feared from the honorable truth seeking member in official duty as the
NOMINATIONS COMMITTEE MEMBER and LONG RANGE PLANNING
COMMITTEE CHAIRMAN AND AWANA COMMANDER would have the
authority and power per the BY-LAWS to Demand a VOTE of RECALL or
TERMINATION due to the financial mismanagement in addition to the frauds and

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abuse to the Plaintiffs children and other children and the frauds of the buying and
allegedly moving the Church and School to the new 18105 North Gunn Highway
property which these pastors were told in 1997, by this Plaintiff Townsend not to
buy the property until we had approvals and permits for the total project.
224.In further point to the deceptive practices of Defendant Beck and his ability to fraud
over the facts, as Plaintiff Townsend had been promoting that the Business
Meeting financial reporting had been flawed and Gary Leatherman had just noted
for the record in January 23, 2000, that there had been flawed information reported
in the previous October 1999, Business Meeting which was in concert with
Plaintiffs tracked ongoing investigation and inquisition of the Administrator
William Brown having had reported to Plaintiff that he still had secret accounts in
August 1999. Yet Defendant Gary Leatherman and Defendant Ron Beck and did
not address the why of the reporting error but instead using his deception refused
to let Plaintiff continue to ask questions and put Plaintiff in fear of being arrested
for asking questions the Moderator Ron Beck may think put him on the spot or
might trap him as an accomplice to the deceptions and keeping secret funds as
approved by Defendant Ron Beck and as further shown in actions of conspiracy,
fraud, extortion and omissions of truthful disclosure and misappropriation of
corporate opportunity by the April 30, 2000, Business Meeting Report as stated
herein this full complaint and with discovery materials not yet produced.
225.At the time Defendant made the false representations alleged in this complaint, a
fiduciary relationship existed between Plaintiff and Defendant because Defendant
was acting as Pastor and Chief Executive Officer per the By-Laws, moderator of the

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Business meetings allegedly to be Orderly and truthful regarding all facts and per
Roberts Rules of Order and By-Laws. Defendant owed Plaintiff a duty not to
misrepresent his opinion of the contents of the BY-LAWS procedures and not
misrepresent that a proper investigation would take the proper course ethically as
had been advised. Now since the charges made in 1999 and thereafter have been
proved by the Court to be in favor of this Plaintiff, this Plaintiff can only pursue this
lawsuit as a means for redress of the false charges against him made by the Pastors
and Finance Committee who in the same meeting of January 23, 2000, admitted
mistaken information was provided in the 2nd quarter of 2000, financial reports as
Plaintiff investigated at that time.
226.At the time Defendant made the false representations herein alleged, Defendant had
a greater superior knowledge of the Business Meeting guidelines and the BYLAWS rules of order and the intended promise to allow the investigation to be
performed without conspiring to destroy the investigation or tamper with the fact
finding process by the assigning the matter to the PERSONNEL COMMITTEE and
acting in concert with said members who also were persons on the Financial
Committee who had reported misinformation on the 2nd quarter of 2000 Business
records.
227.Plaintiff at the time defendant made the above misrepresentations and at the time
plaintiff took the actions herein, was ignorant of all the falsity of defendants
misrepresentations and believed them as partly true because Plaintiff had not been
allowed in the previous October 1999, Business Meeting and did not know that this
stipulation may have been required and that this Pastor would make such an

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intentional calculated obvious misstatement on the record. In reliance on the

Statement of January 23, 2000, business meeting to motions must be in writing
from BY-LAWS and that the committee would investigate, Plaintiff was again
damaged by obstructing of justice of producing the facts necessary to clear the
reputation of this Plaintiff that all of his investigation and quest for truthful
information was proper per his duties by the BY-LAWS and as a State Officer with
a D License so the membership as a whole was not deceived and battered by
alleged trustees as sheriff deputies and others of law enforcement and attorneys and
judges and other nave but connived general members and employees and school
parents and students who underestimated the ability of Beck and the Schism to
conspire and do frauds and damaged further by the acts of the pastors and a select
few concealing the actions of the schism and Karen Harrod Townsend.
228.This attempt by Plaintiff to attend Business Meetings and get factual information
became the MOTIVE by Defendants Beck, Meister, Brown, Jeffers, Howlett,
Leatherman and others became the collective motive for the conspiracy to have
Plaintiff Townsend removed from a position of DUTY as a Member who could ask
a question and was the motive the Defendant Beck sent the July 26, 2001, letter
advising Plaintiff as now a non member he had no right to speak in the Business
meeting or risk being arrested. In coercion, Ron Beck advised Joe Howlett, Mike
Shumate and Tim Jeffers to meet Plaintiff from the front steps of the Church in
July, 2001 and prohibit Plaintiff from coming into the Business Meeting solely
being the one from the crowd to reveal the Emperor had no clothes Defendants
had already intimidated other witnesses and pointed out in the January 23, 2000,

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Business Meeting when others did not ask questions but let Plaintiff stand alone as
they Betrayed Plaintiff and became cowards to speak out.
229.As a direct and proximate result of defendants fraud and deceit, plaintiff suffered
financial damages and emotional duress and pain and suffering and battery.
230.WHEREFORE, plaintiff demands judgement against Defendant Ronald Beck,
individually, and Ronald Beck as Senior Pastor and the FBCCP Membership at
Large and the Corporation of FBCCP as follows:
A. FOR General Damages
B. For the following special damages and the loss of Plaintiffs reputation by their
conspiracy in the Defamation of Plaintiffs character so to allow them to
maintain their alleged innocence to Plaintiffs investigation per his duties and
for the loss of relationship with Plaintiffs wife and children and battery by law
enforcement and attorneys and judges
C. For the costs of suit incurred in this action.
D. For emotional stress by the slander and frauds and loss of family, employment
and opportunity for employment opportunities
E. Loss of his house, home and ability to incur lost money from SunBelt
Equipment Sales per the State Attorney to be at 1,000,000.00.
F. For punitive, compensatory and nominal damages and attorneys fees and costs
G. For such other and further relief as the Court may deem proper.
COUNT V
INTENTIONAL RECKLESS INFLICTION OF EMOTIONAL DISTRESS
AGAINST HERMAN MEISTER, individually and HERMAN MEISTER PASTOR
OF SCHOOL MINISTRIES OF FBCCP and the CORPORATION OF THE FIRST
BAPTIST CHURCH OF CITRUS PARK (FBCCP) and CITRUS PARK
CHRISTIAN SCHOOL (CPCS)
231.Plaintiffs re-allege all points above and below and incorporates them herein.
232.Comes Now Plaintiff Randall Townsend and sues Defendants Herman Meister,
individually, Meister as Pastor of School Ministries and Meister as Officer of the
Corporation(as Meister) and the Corporation of the FBCCP and CPCS and states:
233.Defendant Herman Meister, individually, is employed as Pastor of School
Ministries for FBCCP of CPCS, and the agent of the Defendant FBCCP.

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234.At all times stated herein, Defendant Herman Meister (Meister) was the agent and
employee of Defendant FBCCP and CPCS and in doing the things herein alleged
was acting within the course and scope of such agency and with permission and
consent of his codefendant.
235.On or about August 1999 through January 2002, Herman Meister promised
Townsend that he would keep safe Plaintiff and Plaintiffs minor daughter per the
written contracts noted in the FBCCP BY-LAWS 1992-1993 and per the CPCS
HANDBOOK and obey and follow all of the rules and procedures as stated therein
and Herman Meister alleged and presented himself not to be a part of the ongoing
frauds and misrepresentations by Ron Beck and others against Plaintiff Townsend.
236.At the time Defendant Meister made the promise with the intent to induce Plaintiff
to believe Defendant Herman Meister was an honorable man and being truthful as
per the stipulations of conduct expected of the Principle/Pastor of the Christian
School and Church and thereby gaining trust that Meister would keep safe Plaintiff
and Plaintiffs minor daughter J.G.T and Plaintiffs wife as a teacher in the same
school under his Direct Employment and supervision.
237.Plaintiff, at the time defendant made the above promise to keep safe as an honorable
Principle/Pastor as directed by the Contracts of the FBCCP BY-LAWS and the
CPCS Handbook and at the time Plaintiff took the actions herein alleged, was
ignorant of Defendants intention not to perform. In reliance on Defendants
promise as stated herein. Plaintiff allowed enrollment of his minor student in
CPCS. Had Plaintiff known of Defendants actual intention, plaintiff would not
have taken such action of trust of Meister in his fraud and omissions of truthful

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disclosure and could not be aware of the scheme and conspiracy by Meister until
the revealing of the April 30, 2000, Business Meeting Records not revealed until
June/July 2006 as stated in full in this Complaint in all paragraphs incorporated now
herein.
238.Defendant failed to abide by his promise and instead used this deception, fraud and
omission of truthful disclosure as extortion that if Plaintiff refused to drop his
investigation of the proper reporting of the funds and the improper releasing of
information regarding the building plans for growth of the ministry to the new
property, from the pastors of the Church and School that Defendant Meister would
assist and did help the Senior Pastor Beck and Pastor of Administration William
Brown and the Finance Committee and Trustee Gary Leatherman, Tim Jeffers and
Joe Howlett to use extortion and abuse of process and harassment as they were
trying to ruin the integrity and character of plaintiff Townsend and used trickery
and frauds against Plaintiff and Plaintiffs wife and Minors J.D.T and J.G.T. and
others confirmed by Meister in a conversation of rage and yelled out at Plaintiff
Townsend in January 2002, WE MADE A PACK TO DENY AND TO
DESTROY ANYTHING YOU SAY!
239.Further, Defendant Herman Meister as Pastor/Principle of the school did ignore the
physical trauma endured by minor daughter J.G.T and the mental anguish and the
destruction of Plaintiffs family and family lifestyle as stated in the CPCS handbook
as the goal of CPCS Family values and Plaintiffs reputation at the hand of his
extortion schemes as the now produced in June/July 2006, FBCCP and CPCS
Business Records just revealed multiple motives and acts of criminal, civil, labor,

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and IRS violations by Meister as a fraud and omission of truthful disclosure to his
intended purpose to deceive and cause infliction of emotional distress as a practice
to induce Plaintiff Townsend to stop his pursuit of the violators of Plaintiffs rights
and Meister did use his role as the employer, Pastor of School Ministries and
School Board Member and Member of the LRPC Committee to promote fraud,
omissions of truthful disclosure, misappropriation of corporate opportunity,
extortion, conspiracy and emotional stress on all Plaintiffs and on Defendants under
his employment to enable additional damages and emotional, physical, mental and
financial damages by engaging by his actions Gayle Lynn, Dr. Lon Lynn and even
the Mother Karen Harrod Townsend to conceal, fraud, battery and damage Plaintiff
Townsend, and Plaintiff J.D.T and Plaintiff J.G.T and all minor plaintiffs for whom
Plaintiff Townsend speaks.
240.As a direct and proximate result of Meisters frauds and omissions of truthful
disclosure and extortion and infliction of extreme emotional distress, plaintiff
Townsend and all plaintiffs has sustained financial damages, and the loss of
Plaintiffs family relations with his wife and his children and the loss of his standing
in the community and suffered extreme emotional and mental distress.
241.Wherefore Plaintiff Townsend demands judgement against Defendant Meister
individually, Meister as Pastor of FBCCP AND CPCS and the Corporation of
FBCCP/CPCS as follows:
A. For general damages
B. For the following special damages including medical bills past, present and
future incurred from the treatments due to the mental anguish suffered by
Plaintiffs and any and all other relief as deemed proper by the Court.

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C. For costs incurred in this suit and in costs from defending against all trials
including cases 01-15813 and 1-15814 and other suits to overturn the resulting
Injunctions flowing from the frauds and omissions of truthful disclosure of
Defendants.
D. For punitive damages.
E. For such other and further relief as the Court may deem proper.
COUNT VII
CLAIM FOR PROFESSIONAL MALPRACTICE BREACH OF
DUTY AGAINST DR. LON LYNN M.D. Individually, DR. LON LYNN AS
MEMBER OF FBCCP and DR. LON LYNN, Medical Doctor for INTENTIONAL
NEGLIGENT CARE AND CAUSING INTENTIONAL INFLICTION OF
EMOTIONAL DISTRESS AND BATTERY
242.Plaintiffs re-allege all points above and below and incorporates them herein.
243.Comes Now Plaintiff Randall Townsend Plaintiff RANDALL TOWNSEND, Pro
Se, AS AN INDIVIDUAL, AND AS NEXT FRIEND AND PATERNAL PARENT
OF MINOR SON, J.D.T. ANDAS NEXT FRIEND AND PATERNAL PARENT OF
MINOR DAUGHTER, J.G.T, AND AS A DIRECT MEMBER of the First Baptist
Church of Citrus Park, (FBCCP) Acting Directly, Indirectly and Derivatively AND AS
NEXT FRIEND FOR AND OF ALL THE MINOR CHILDREN of the FBCCP and
CITRUS PARK CHRISTIAN SCHOOL (CPCS), and sues Defendants DR. LON LYNN,
individually, and DR. LON LYNN AS MEMBER OF FBCCP and DR. LON LYNN,
Medical Doctor for NEGLIGENT CARE CAUSING INTENTIONAL INFLICTION OF
EMOTIONAL DISTRESS and Battery and states:
244.At all times material hereto, Defendant Lon Lynn individual was the agent and
employee of defendant Dr. Lon Lynn M.D. and in doing the things alleged herein
was acting within the course and scope and authority of such agency and with the
permission and consent of his co-defendants.
245.On or about September 1999, Defendants became aware of conflicts and disorders

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of minor J.D.T and Minor J.G.T and Defendant Mother Karen Harrod Townsend as joint
members of FBCCP and as employee and students of CPCS.
246.On or About July 31, 2000, via a phone conversation and via a personal meeting
Plaintiff Townsend did also inform Defendants of special issues needed in the proper care
of Minor J.D.T. and Minor J.G.T and Defendant Karen Harrod Townsend resulting from
stress related circumstances caused by FBCCP and CPCS issues as stated herein and Dr.
Lon Lynn personally and directly related to this Plaintiff as Parent of J.G.T and J.D. T.
that he would see that the proper medical care would be given to Plaintiffs in view of the
stress related symptoms he was aware of in their lives due to the FBCCP/CPCS issues.
247.On or about August 2000, after consultation with Defendant Scruggs, Plaintiff
Townsend sent by Certified Mail as conditions precedent a letter advising all Defendants
as Dr. LON LYNN, M.D of special needs and circumstances with issues relative or
related to the care of Dr. Lon Lynns fellow FBCCP and CPCS members and as patients
J.D.T and J.G.T and the mother Karen Harrod Townsend and advised Dr. Lon Lynn of
the falsely and fraudulently represented frauds and omissions of truthful disclosures that
the problems of FBCCP and CPCS were causing Plaintiff J.D.T and J.G.T and others.
Dr. Lon Lynn also revealed that from his wife, Gayle Lynn, as the CPCS school
counselor and from his personal knowledge as a member of FBCCP and CPCS parent
that he was aware of the issues and claims made by Plaintiff Townsend against
Defendants Pastors and Trustees and Dr. Lon Lynn advised he was aware of the claims of
the Pastors and Trustees as Deputies made about and damages to Plaintiff Townsend.
248.Plaintiff Townsend alleges that Dr. Lon Lynn from his medical training and from
his alleged respected position as a Medical Doctor and with knowledge gained from the

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FBCCP and CPCS HANDBOOK and personal discussions and observations with all
parties that Dr. Lon Lynn, had a knowledge of the desired care and expectations required
to keep safe Plaintiffs and Dr. Lon Lynn because of his training and superior knowledge
had a duty to exercise his position of leadership and as member to assist and resolve and
present facts and prevent damages to all Plaintiffs within his medical and leadership care.
249.Plaintiff Townsend alleges that Dr. Lon Lynn intentionally, willingly, knowingly
and recklessly failed to exercise proper medical, and membership of FBCCP and CPCS
DUTIES and intentionally, willfully, knowingly and recklessly desired rather to Give
Benefit to Clergy to protect the employment of his wife Gayle Lynn as the CPCS school
counselor and protect his position of FBCCP and CPCS roles and leadership positions
rather than suffer loss of income, loss of clients and loss of rapport with Pastors and
alleged Trustees and other members despite Dr. Lon Lynn being fully aware of the truth
of the allegations and resulting damages as reported to him by Plaintiff Townsend.
250.At the time defendants made the promise with the intent to induce plaintiff
Townsend to trust his wisdom and medical care as a medical professional and as a man in
the community and in the FBCCP and CPCS family as member of integrity and honor
and to let Dr. Lon Lynn have time to perform the proper medical treatments and to assist
Plaintiff in getting his patients to counseling for their symptoms both said were evident,
defendant had no intention of performing per his agreed services of care or assistance to
get the facts and truth of the FBCCP and CPCS exposed and extended battery all on
Plaintiffs to continue his and others concealment of frauds and benefit of clergy to
continue his opportunity for financial gain and unjust enrichment for himself individually
and for his Medical practice and Business and to provide unjust enrichment for his wife

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as employee of CPCS/FBCCP.
251.Defendants Dr. Lon Lynn, individual and Medical Doctor and FBCCP and CPCS
member made the promise with the intent to induce Plaintiff to keep quiet and stall and
delay to let Dr. Lon Lynns part in the scheme to cover up the activities and allegations of
the leadership at FBCCP and CPCS continue the harms and battery against Plaintiffs.
252.Plaintiffs at the time defendants made the above promise and at the time plaintiff
took the actions alleged herein, was ignorant of defendants intention not to perform. In
reliance on defendants promise to assist Plaintiff to getting the Plaintiffs the truthful
disclosure of allegations of the issues of the FBCCP and CPCS and the proper medical
care and relief from the emotional and mental anguish and stress as victims of frauds and
omissions of truthful disclosure and fears and loss of family and paternal relations,
plaintiffs did suffer thereby and incurred damages and did wait and them was betrayed by
Dr. Lon Lynn, when he selected and refused to discuss, and perform his intended
promises to provide information and care and refused to discuss the matter further with
this parent in violation of this parents right to intervention and custody and control of the
medical care of the Plaintiffs as at no time during the medical care by Defendants did any
court remove or restrict the permanent rights of Plaintiffs except only during the period of
November 2- 15, 2001, until the Injunction by Judge Palomino was removed. As a
further result Plaintiffs were damaged and thus created additional symptoms and mental
anguish in the family relationships due to the betrayal of Dr. Lon Lynn as he watched the
leadership at FBCCP and CPCS create additional frauds and omissions of truthful
disclosure and infliction of emotional distress, battery and shame and duress on Plaintiffs.
253.In further negligence of medical care, Defendants did delay the referral of his

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patients to other medical professionals as a means of keeping quiet and suppressed the
anguish and duress on his patients and fellow FBCCP and CPCS members created by the
issues at the hand of employees and members of FBCCP and CPCS.
254.Had Plaintiffs known of defendants actual intention, plaintiffs would not have taken
such action in confidence to the alleged promise of the duty to care for Plaintiffs and
would not have taken the excuses for delay and would have sought immediate care by
patients original medical professional as was done by Dr. Santiago Hoyos.
255.Plaintiff Alleges Dr. Santiago Hoyos immediately alleged wrongdoing and
negligent care by Dr. Lon Lynn and sought proper medical care from his own services
and from the services of Dr. Ernesto Millan as reported in the medical summary reports
as letters supplied as evidence in this matter to Defendants and to these lower courts.
256.Defendants failed to abide by his promise and instead got quiet and thereby did
even refuse to speak to Plaintiff and thus complicated the image of Plaintiffs in the public
eye to defame this Plaintiff Townsend and cause and incur additional stress on Plaintiffs
due to the malicious actions of Plaintiffs FBCCP and CPCS members and peer pressure
on Plaintiffs and by his non cooperation took a position to others that Plaintiff was a
danger to those involved rather that as a proper parent acting with the utmost desire of
love, affection and proper care for and of his family.
257.As a direct and proximate result of defendants frauds and omissions of truthful
disclosure and lack of medical care, Plaintiffs suffered infliction of emotional stress,
mental anguish, physical damages, pain and suffering, loss of relationships and financial
damages and shame and humiliations and debt to the Corporation which failed to build
the new school allegedly to serve the interests of these Plaintiffs and Dr. Lon Lynn as a

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FBCCP and CPCS leader had a duty to prevent and stop the financial losses and frauds
and embezzlements of the Pastors and Trustees of FBCCP and of his Medical Practice.
258.Wherefore, plaintiff demands judgement against Defendants and each of them as
follows:
A. For general damages
B. For the following special damages including, medical bills, loss of plaintiffs
relationships, loss of plaintiffs integrity and reputation caused by defendants
participation in the scheme of fraud and omission of truthful disclosure.
C. Damages for infliction of emotional distress and battery and malpractice
D. For the costs incurred in this suit.
E. For unjust enrichment of his Medical Practice and of himself and his wife
individually
F. For attorneys fees
G. For reimbursement for all FBCCP Corporation debt
H. For punitive damages
I. For an award against Dr. Lon Lynn M.D. and as a Corporation for negligent
supervision and retention of Dr. Lon Lynn M.D. and knowingly, intentionally
and recklessly and negligently allowing the actions of Dr. Lon Lynn, Individual
and doing his actions of negligence in the mask as a Medical Doctor.
J. For such other and further relief as the court may deem proper.
COUNT VIII
NEGLIGENT SUPERVISION--AGAINST ALL MEMBERS AT LARGE OF THE FBCCP AND CPCS AND THE
CORPORATION OF THE FIRST BAPTIST CHURCH OF CITRUS PARK AND
THE MEMBERS OF THE PERSONNEL COMMITTEE AND DEACONS AND
AS THE CPCS SCHOOL BOARD MEMBERS AS DEFENDANTS IN THEIR
INDIVIDUAL AND IN ALL CORPORATE OFFICES AND POSITIONS AND AS
ASSOCIATE GENERAL MEMBERS WITH DUTIES PER THE BY-LAWS
259. Plaintiffs re-allege all points above and below and incorporates them herein.
260.Comes Now Plaintiff Randall Townsend Plaintiff RANDALL TOWNSEND, Pro
Se, AS AN INDIVIDUAL, AND AS NEXT FRIEND AND PATERNAL PARENT
OF MINOR SON, J.D.T. AND AS NEXT FRIEND AND PATERNAL PARENT OF
MINOR DAUGHTER, J.G.T, AND AS A DIRECT MEMBER of the First Baptist
Church of Citrus Park, (FBCCP) Acting Directly, Indirectly and Derivatively AND AS
NEXT FRIEND FOR AND OF ALL THE MINOR CHILDREN of the FBCCP and

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CITRUS PARK CHRISTIAN SCHOOL (CPCS), and sues ALL MEMBERS AT

LARGE OF THE FBCCP AND CPCS AND THE CORPORATION OF THE FIRST
BAPTIST CHURCH OF CITRUS PARK AND THE MEMBERS OF THE
PERSONNEL COMMITTEE AND DEACONS AND AS THE CPCS SCHOOL
BOARD MEMBERS AS DEFENDANTS IN THEIR POSITIONS AS
OFFICERS/AGENTS OF THE CORPORATION AND AS INDIVIDUALS for
Negligent Supervision of employees Ron Beck, Herman Meister, William Brown, III and
Karen Harrod Townsend and Gayle Lynn, and Paula Powell, and Tammy Nunes and
April Beck and Joyce Meister and Karen Jeffers as individuals and in their official
positions as individuals and employees and Associate members of FBCCP and CPCS and
states:
261.At all times material to herein mentioned, Defendants Ron Beck, William Brown,
Herman Meister, Karen Harrod Townsend, Gayle Lynn, Paula Powell, April Beck, Joyce
Meister, Tammy Nunes and Karen Jeffers were the agents employed of Defendant First
Baptist Church of Citrus Park(FBCCP) and or Citrus Park Christian School (CPCS) and
in doing the things herein alleged was acting within the course and scope of such agency
and with permission and consent of his codefendants and with the authority of the
Defendant Corporation of FBCCP and all General Voting Members as the Membership at
Large.
262.Plaintiffs allege ALL MEMBERS AT LARGE OF THE FBCCP AND CPCS AND
THE CORPORATION OF THE FIRST BAPTIST CHURCH OF CITRUS PARK AND
THE MEMBERS OF THE PERSONNEL COMMITTEE AND DEACONS AND AS
THE CPCS SCHOOL BOARD MEMBERS were intentionally, knowingly, negligent and

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reckless in the Supervision and training of each employee per the duties and standards of
care and of the performance of services as stated in the FBCCP BY-LAWS, and CPCS
ENROLLMENT CONTRACTS and CPCS STUDENT HANDBOOKS DUTIES AND
SERVICES as stated above and below herein.
263.Plaintiff Townsend alleges that defendants were properly advised of their
intentional, knowingly, reckless and negligent care and supervision by the participation
of Plaintiff Townsend at the January 23, 2000, Business Meeting and by the production
of multiple letters and verbal communications to advise of the negligent actions and
violations of the Corporation BY-LAWS and CPCS Agreements and Contracts.
264.As an approximate and resulting cause of the negligent actions by Defendants as
stated and incorporated herein Plaintiffs did suffer damages and Plaintiff alleges the
Defendants had reason to know of misconduct and did nothing to prevent reasonably
foreseeable harm from being inflicted on the parishioners as these Plaintiffs and as all
defendants knowingly, intentionally, recklessly and negligently chose to give benefit to
clergy in violation to Florida Statue 617 and did intentionally batter and allow and assist
Defendants Beck, Meister, Karen Harrod Townsend, William Brown III, Gayle Lynn and
April Beck and Paula Powell and other employees to violate these Plaintiffs as stated.
265.WHEREFORE Plaintiffs demand judgement against each defendant as follows:
A. For General Damages
B. For Special Damages due to Plaintiffs loss of relations, integrity, good name
C. For costs incurred in this action
D. For attorneys fees
E. For any and all mortgages and debts of the Corporation for failure to provide
these children the proper standard of care and use of the new school as promised
by the pastors and others.
F. For unjust enrichment
G. For Punitive Damages
H. For such other and further relief as the Court may deem proper.

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COUNT IX
NEGLIGENT RETENTION--AGAINST ALL MEMBERS AT LARGE OF THE FBCCP AND CPCS AND THE
CORPORATION OF THE FIRST BAPTIST CHURCH OF CITRUS PARK AND
THE MEMBERS OF THE PERSONNEL COMMITTEE AND DEACONS AND
AS THE CPCS SCHOOL BOARD MEMBERS AS DEFENDANTS IN THEIR
INDIVIDUAL AND IN ALL CORPORATE OFFICES AND POSITIONS AND AS
ASSOCIATE GENERAL MEMBERS WITH DUTIES PER THE BY-LAWS
266. Plaintiffs re-allege all points above and below and incorporates them herein.
267.Comes Now Plaintiff Randall Townsend Plaintiff RANDALL TOWNSEND, Pro
Se, AS AN INDIVIDUAL, AND AS NEXT FRIEND AND PATERNAL PARENT
OF MINOR SON, J.D.T. AND AS NEXT FRIEND AND PATERNAL PARENT OF
MINOR DAUGHTER, J.G.T, AND AS A DIRECT MEMBER of the First Baptist
Church of Citrus Park, (FBCCP) Acting Directly, Indirectly and Derivatively AND AS
NEXT FRIEND FOR AND OF ALL THE MINOR CHILDREN of the FBCCP and
CITRUS PARK CHRISTIAN SCHOOL (CPCS), and sues ALL MEMBERS AT
LARGE OF THE FBCCP AND CPCS AND THE CORPORATION OF THE FIRST
BAPTIST CHURCH OF CITRUS PARK AND THE MEMBERS OF THE
PERSONNEL COMMITTEE AND DEACONS AND AS THE CPCS SCHOOL
BOARD MEMBERS AS DEFENDANTS for Negligent Supervision of employees Ron
Beck, Herman Meister, William Brown, III and Karen Harrod Townsend and Gayle
Lynn, Paula Powell, April Beck and Joyce Meister and Karen Jeffers as individuals and
in their official positions as individuals and employees of FBCCP and CPCS and states:
268.At all times material to herein mentioned, Defendants Ron Beck, William Brown,
Herman Meister, Karen Harrod Townsend, Gayle Lynn, Paula Powell, April Beck, Joyce
Meister and Karen Jeffers were the agents employed of Defendant First Baptist Church of

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Citrus Park(FBCCP) and or Citrus Park Christian School (CPCS) and in doing the things
herein alleged was acting within the course and scope of such agency and with
permission and consent of his codefendants and with the authority of the Defendant
Corporation of FBCCP and all General Voting Members as the Membership at Large.
269.Plaintiffs allege ALL MEMBERS AT LARGE OF THE FBCCP AND CPCS AND
THE CORPORATION OF THE FIRST BAPTIST CHURCH OF CITRUS PARK AND
THE MEMBERS OF THE PERSONNEL COMMITTEE AND DEACONS AND AS
THE CPCS SCHOOL BOARD MEMBERS were intentionally, knowingly, negligent and
reckless in the RETENTION and employment of each employee per the duties and
standards of care and of the performance of services as stated in the FBCCP BY-LAWS,
and CPCS ENROLLMENT CONTRACTS and CPCS STUDENT HANDBOOKS
DUTIES AND SERVICES as stated above and below herein.
270.Plaintiff Townsend alleges that defendants were properly advised of their
intentional, knowingly, reckless and negligent care and RETENTION by the participation
of Plaintiff Townsend at the January 23, 2000, Business Meeting and by the production
of multiple letters and verbal communications to advise of the negligent actions and
violations of the Corporation BY-LAWS and CPCS Agreements and Contracts.
271.As an approximate and resulting cause of the negligent actions by Defendants as
stated and incorporated herein Plaintiffs did suffer damages and Plaintiff alleges the
Defendants had reason to know of misconduct and did nothing to prevent reasonably
foreseeable harm from being inflicted on the parishioners as these Plaintiffs and as all
defendants knowingly, intentionally, recklessly and negligently chose to give benefit to
clergy in violation to 617, 775.03 F. S. and By-Laws, and did intend, allow and assist

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Defendants Beck, Meister, Karen Harrod Townsend, William Brown III, Gayle Lynn and
April Beck and Paula Powell and other employees to violate these Plaintiffs and do
battery against these Plaintiffs as stated.
272.WHEREFORE Plaintiffs demand judgement against each defendant as follows:
A. For General Damages
B. For Special Damages due to Plaintiffs loss of relations, integrity, good name
C. For costs incurred in this action
D. For attorneys fees
E. For any and all mortgages and debts of the Corporation for failure to provide
these children the proper standard of care and use of the new school as promised
by the pastors and others.
F. For unjust enrichment
G. For infliction of emotional distress.
H. For such other and further relief as the Court may deem proper.
COUNT X
COMMON LAW FRAUDAGAINST ALL DEFENDANTS
273.Plaintiffs re-alleges all points above and below and incorporates them herein.
274.COMES NOW PLAINTIFF RANDALL TOWNSEND AND STATES TO ALL
PERSONS AND AGENCIES AND OTHERS AS STATED ABOVE AND
HEREIN:
and makes a claim against each individual as Defendant herein under Section 1983 of
TITLE 42 of the United States Code, which provides that any person who, under
apparent authority of state law, deprives another of any rights, privileges, or immunities
secured by the United States Constitution and the laws will be liable to the party injured.
[42 U.S.C.S. 1893], and sues each agency and State of Florida Government Public
Entity and or each Corporation as stated herein, pursuant to Florida Statues 768.28(6),
And further sues under the TORT CLAIMS ACT and makes the following statements in
support of the claim:
275.Defendants intentionally, knowingly, recklessly or negligently concealed or

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omitted material facts as to the true Duty of each person and agency and other entity that
they did not have jurisdiction or cause to act and defendants intended plaintiffs rely
upon their alleged professional and expert position of their superior knowledge of their
DUTY NOT TO ACT or take the duty of care actions of supervision, investigative,
probative actions or duty to prosecute under the law to avoid the nuisance and risks
damages and all damages incurred by Plaintiffs.
276.Plaintiffs reasonably relied on defendants representations and omissions of
truthful disclosure and as a proximate result thereof was deceived, battered and damaged.
279.WHEREFORE, the Plaintiff demands trial by jury on all issues so triable and prays
this Court will award damages against Defendants, including court costs, compensatory
damages, nominal damages and punitive damages and any other further relief as the
Court may deem proper.
COUNT XI
NEGLIGENCEAGAINST FIRST BAPTIST CHURCH OF CITRUS
PARK CORPORATION Inc. AND Corporation OFFICERS/TRUSTEE and
Individuals asBECK, GEOFF SMITHHERMAN MEISTERGARY
LEATHERMANTIM JEFFERSWILLIAM BROWN AND JOE HOWLETT
280. Plaintiffs reallege all paragraphs above and below and incorporates all herein.
281.At all relevant times defendants FIRST BAPTIST CHURCH OF CITRUS PARK
CORPORATION Inc. AND Corporation OFFICERS/TRUSTEE and as individuals as
RON BECK, GEOFF SMITH, HERMAN MEISTER, GARY LEATHERMAN, TIM
JEFFERS, WILLIAM BROWN AND JOE HOWLETT owed a duty to plaintiffs and to
use reasonable care in their duties per the obligations, Rights and Standards of the
FBCCP Corporation BY-LAWS, as recognized in the State of Florida as a living Contract
per 617, F.S.

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282.Defendants breach their duty by failing to properly report all financial records, by
falsely reporting financial records, by concealing secret accounts, by concealing Credit
Card Billings, by concealing the frauds of the building and growth false plan called the
VISIONS, by negligently supervising their conduct and the conduct of other
employees to operate to the standards of the Corporation BY-LAWS, Criminal Laws,
Civil Laws, Domestic Relations Laws, Labor Laws, Internal Revenue Service Laws and
negligent care of the Awana Children by improper maintaining of the Fellowship Hall
and Sonshine Patch and other facilities and property and vehicles and by failing to
disclose the fraudulent actions and slanders and injurious falsehoods about Plaintiff of
the Pastors Schisms to convey falsehoods about the Master Building Plan to the General
Membership and by omissions of truthful disclosure that this Plaintiff Townsend was
honorable to the true duties and obligations at all times to the BY-LAWS and State
Statues and Defendants were negligent in interference with child custody of this father
and did cause Battery and abuse of process and Malicious Prosecution and fraud on
Plaintiffs Townsend and J.D.T and J.G.T and minor plaintiffs for who Townsend speaks.
283.At all times relevant Defendants owed a duty to plaintiffs to take reasonable and
adequate steps to investigate and report truthfully all allegations of frauds, deceptions,
misappropriations of funds and false reporting of the Master Building Plan and violation
of FBCCP property and theft from these Children and protection of all Plaintiffs rights.
284.At all times relevant Defendants owed a duty to plaintiffs to follow all practices as
described in the BY-LAWS to prevent undue harm, battery and loss of reputation, loss of
family and family harmony and relations and an harmonious spirit in resolving all issues
but Defendants breached these duties intentionally, willfully, knowingly, recklessly and

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negligently in conspiracy to conceal their own individual and collective unjust

enrichment and unlawful acts and violations of the employee contracts and BY-LAWS.
285.Defendants breached its duty to plaintiffs by failing to take reasonable and
adequate steps to communicate and to ensure that all members to whom it managed and
protected followed all procedures of the BY-LAWS and State Statues and Federal Laws.
286.Defendants breach proximately caused damage to plaintiffs as stated herein.
287.WHEREFORE, the Plaintiff demands trial by jury on all issues so triable and
prays this Court will award damages against Defendants, including court costs, and any
other further relief as the Court may deem proper and for infliction of emotional distress
for frauds for battery and for loss of employment and loss of economic opportunities and
unjust enrichment.
COUNT XII
FRAUDAGAINST FIRST BAPTIST CHURCH OF CITRUS PARK
CORPORATION AND OFFICERS/TRUSTEERON BECK, GEOFF SMITH
HERMAN MEISTERGARY LEATHERMANTIM JEFFERSWILLIAM
BROWN AND JOE HOWLETT AND MIKE SHUMATEMARK NUNES
ROBERT GILESIndividually and in their CORPORATION OFFICERS
Capacities as stated above herein
197.

Plaintiffs reallege all paragraphs above and below and incorporates herein.

198. Defendants herein intentionally, knowingly, recklessly or negligently concealed or

omitted material facts and omitted truthful disclosures as to the true intentions, reports,
allegations and conduct of Plaintiff Townsend as Plaintiff Townsend did his DUTY as a
General Voting Member and a persons of several leadership positions, namely LRPC
Chairman, Awana Commander and Nominations Committee Member and various other
titles and Defendants fraudulent did injurious falsehoods to and about this Plaintiff
Townsend with malicious to inflict emotional distress to require and coerce and by

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extortion attempt to require Plaintiff Townsend to stop his alleged false allegations now
all proved to be true as to the motives and intentionally injurious breach of duties by
these Officers and Trustees regarding now proving the missing funds, secret accounts,
Credit Card misuse, frauds about the Master Building Program, fraud that the 7705 Gunn
Highway property could hold a K-12th grade and each and all now proved true allegation
as told in each letter or testimony to these Courts, labor violations, Vehicles violations.
199.Plaintiffs reasonably relied on defendants representations and omissions and as a
proximate result thereof was deceived, battered and damaged.
200.WHEREFORE, the Plaintiff demands trial by jury on all issues so triable and
prays this Court will award damages against Defendants, including court costs, and
punitive damages and any other further relief as the Court may deem proper.

COUNT XIII
ABUSE OF PROCESS BY ASSAULT AND FRAUD AGAINST DEFENDANTS
THE OFFICE OF THE GOVERNOR OF THE STATE OF FLORIDA FOR ACTS
OF JEB BUSH AND CHARLIE CRIST AND DEPUTY JOE HOWLETT,
DEPUTY TIM JEFFERS, DEPUTY JOHN MICHEAL CORBIN, DEPUTY MIKE
SMOAK, TAMPA POLICE OFFICER JOE KAREAS AND OFFICER MIKE
SAHR AND ATTORNEYS AND JUDGES AND FDLE AGENTS AND THE
AGENCY AND THE DEPARTMENT OF CHILDREN AND FAMILIES AND
THE DEPARTMENT OF THE ATTORNEY GENERAL AND THE
DEPARTMENT OF THE STATE ATTORNEYS OFFICE AND AGENTS AND
FLORIDA BAR AGENTS AND AGENCY OF THE FLORIDA BAR AND FOR
JUDICIAL QUALIFICATION AGENTS AND AGENCIES FOR ACTS AGAINST
PLAINTIFF RANDALL TOWNSEND

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201.Comes Now Plaintiff, Randall Townsend individual, and sues Defendants FOR
ABUSE OF PROCESS BY ASSAULT AND FRAUD AGAINST DEFENDANTS THE
OFFICE OF THE GOVERNOR OF THE STATE OF FLORIDA FOR ACTS OF JEB
BUSH AND CHARLIE CRIST AS GOVERNOR AND CHARLIE CRIST AS
ATTORNEY GENERAL AND AS INDIVIDUALS AND DEPUTY JOE HOWLETT,
DEPUTY TIM JEFFERS, DEPUTY JOHN MICHEAL CORBIN, DEPUTY MIKE
SMOAK, TAMPA POLICE OFFICER JOE KAREAS AND OFFICER MIKE SAHR
AND ATTORNEYS AND JUDGES AND FDLE AGENTS AND THE AGENCY AND
THE DEPARTMENT OF CHILDREN AND FAMILIES AND THE DEPARTMENT
OF THE ATTORNEY GENERAL AND THE DEPARTMENT OF THE STATE
ATTORNEYS OFFICE AND AGENTS AND FLORIDA BAR AGENTS AND
AGENCY OF THE FLORIDA BAR AND FOR JUDICIAL QUALIFICATION
AGENTS AND AGENCIES FOR ACTS AGAINST PLAINTIFF RANDALL
TOWNSEND as individuals and as Law Enforcement, Sheriff Deputies and Police
officers and General Members of FBCCP and as FBCCP Officers and Agents and
Citizens of the State Of Florida and Plaintiffs reallege all paragraphs above and below
and incorporates herein and alleges:
202. Plaintiff, Randall Townsend, is an individual residing at relevant times in
Hillsborough, Sarasota and Pinellas Countys of Florida within the jurisdiction of
the UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA and
with rights as a citizen and FBCCP member now not able to be fully known until the
production of FBCCP Business Records in June/July 2006, to have Constitutional and
BY-LAWS rights to Speech, Assembly, No Child interference with his fathers rights, and

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Religious freedoms and for life, liberty and pursuit of happiness but to conceal the frauds
And battery of pastors and sheriff deputies as masked trustees these defendants did use
their Law Enforcement uniforms as masks that all activities of themselves and these
clergy and attorneys and judges were lawful and now proved fraud, and collusion as
stated herein.
203. Defendants Joe Howlett, Tim Jeffers, John Micheal Corbin, Mike Smoak, Joe

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Kareas and Mike Shar are individuals residing within the Counties of Hillsborough and
Pasco of, Florida and working or were working at their times of actions or were on
duty or off duty and or now retired as law enforcement within the Counties of
Hillsborough, Pasco and Pinellas of Florida and within the jurisdiction of the State of
Florida and of this UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF
FLORIDA.
204. Plaintiff Townsend restates all paragraphs of Number 4-20 as above herein that
show that action is proper within the venue and Jurisdiction of this UNITED STATES
DISTRICT COURT MIDDLE DISTRICT OF FLORIDA and Because each Defendant
is a resident or was doing or was alleging to do official duties, on duty and off duty
as law enforcement or as officers of the courts or as Officers of the State and this court
is a proper venue for this action as stated above herein.
205. This is an action for damages in excess of $ 25,000.00 and is within the jurisdiction
of this court.
206. On or about September 8, 1999, and still through current times and at all other times
as stated above and herein at the First Baptist Church of Citrus Park at 7705 Gunn
Highway, Tampa Florida, and at 18105 Gunn Highway, Tampa Florida and at the Court
Room of Judge Raul Palomino of Hillsborough County on November 15, 2001, by
individual and as Deputy Joe Howlett(Howlett) and by Howlett at Citrus Park Town
Center Mall on numerous occasions and by Mike Sahr at Kmart in Sarasota, Florida and
by each Defendant in Count XIII, herein and on surrounding roads at or about Gunn
Highway at or around the Citrus Park Baptist Church Defendant assaulted Plaintiff in that
Defendants Howlett and Smoak did use their Deputy Crusiers at times with lights

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flashing to impede the peaceful operation of Plaintiff Townsend in or out side of his
vehicle to deter, inflict battery, shame and harassment and abuse and Deputy Howlett
even on occasions would attempt to coerce Plaintiff Townsend to retaliate with resistance
so Deputy Howlett could arrest Plaintiff Townsend and per the verbal under oath
testimony of Defendant Ron Beck on November 15, 2001, under oath to Judge Raul
Palomino Beck did attempt to use the alleged needed actions of Howlett and Jeffers and
Smoak to allege that Plaintiff Townsend without lawful duty or cause had to be restrained
or blocked from alleged illegal or unlawful conduct at the steps of the Church despite
Plaintiff Townsend being a member and fully and completely can prove that Plaintiff
Townsend was invited by several members to address in open forum business meeting
process per the BY-LAWS duty the issues of frauds and corruption of these Pastors and
these same deputies as alleged Trustees. Plaintiff states that each deputy and officer at
all times herein and in all paragraphs above and below appeared to each plaintiff to be
acting in their official mask or uniform as an officer of the law and that all deputies and
officers acted to appear to be within their official roles in order to inflict conspired
control, restraint and protection of Plaintiff Townsend to others. Plaintiff Townsend
alleges that even Corbin did publicly yell and abuse Plaintiff Townsend to make a public
scene for the alleged protection of others despite Corbin as a member of the LRPC
Committee fully knowing the pure motives of Plaintiff Townsend. Defendants, while
arguing at Plaintiff over Church issues and pastor and others criminal actions and frauds,
would yell publicly, chase plaintiff on foot, chase plaintiff in official vehicles and
attempted to at times even in uniform cause or Ordered Plaintiff Townsend from his car
so Deputies could show alleged protection to others and possible entice Plaintiff

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Townsend to resist the harassment and abuse. Defendant Jeffers even did Touch the
Wife of Plaintiff Townsend on the steps of the Church and led her away from talking to
Plaintiff Townsend so to make appear that persons were in danger. Defendant Howlett at
times stood in front of Plaintiff, who was in his car, blocking him in his seat. Defendant
then threatened to arrest Plaintiff and raised his hand to his gun belt as if to need against
Plaintiff, all the while standing over Plaintiff and leaving Plaintiff no avenue of escape.
207. Defendant intended to cause apprehension of imminent harm in Plaintiff in that
Defendant Beck had advised Plaintiff Townsend show that defendant's acts were intended
as Defendant Beck stated he would file charges if Plaintiff tried to speak in Church
meetings or attend Church or School services and business meetings or school functions
and as told to judge Palomino on November 15, 2001, by Defendant Ron Beck and
Defendant Employee Karen Harrod Townsend. Defendant approached Plaintiff, who was
seated many times in his car, with no intent to harm anyone would be approached and
engaged by Defendants threatening to cause violent physical injury by arrest, and then
use police type car chases, traffic stops with lights flashing, intervention at the Church
Steps prohibiting Plaintiff now fully known to have always been a member of the
Corporations with rights not restricted by the Courts but only on November 2-15, 2001,
and by Deputy Howlett making false allegations to Curtis Baughman and attending the
Court of Judge Palomino stating willingly to give false testimony and , thereby causing
Plaintiff to feel threatened with imminent bodily injury and place him in apprehension for
his safety and fear of going to prison. Furthermore, Defendant's acts were substantially
certain to result in apprehension of imminent harm in Plaintiff.
208. Because Defendant Howlett made intentional threats to Plaintiff, in the April 2000

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meeting to get your hands on the table and at times in traffic stops would require
Plaintiff to flee the property while just sitting waiting for his children or be chased by
Deputy Howlett, Deputy Smoaks and being yelled at and repeatedly chased by Defendant
Ron Beck in his vehicle even at one time with a visiting evangelist willing to verbally
communicate the threats and chase to pastors at Idlewild Baptist Church and was not
restrained in his movements as Plaintiff was, Defendant had the apparent present ability
to harm Plaintiff as he was threatening to do and as a direct and proximate result, Plaintiff
reasonably feared that Defendant would imminently inflict bodily harm on or put Plaintiff
in jail. Plaintiff Townsend at multiple times did inform, plead and request intervention
by The Office of the Governor and of Jeb Bush and Charlie Crist to no avail in violation
of the Duties and Office of the Governor per the Florida Statues as stated herein and by
the failure of the Governor and Attorney Generals Office to conduct their duty all
Defendants failed to do Duty of their Office and Civic Duty to control and detain the
actions of alleged law enforcement and attorneys and Judges as stated herein and
Plaintiffs state that Jeb Bush and Charlie Crist had personal and individual self-serving
for personal gain motives and thereby refused the reasonable pleading of Plaintiff Randall
Townsend for himself and for those whom he speaks and thereby the individual interests
of Jeb Bush and Charlie Crist caused a breach of their Official Duties as Governor and as
Attorney General and as Commissioner of Education being duly notified by Plaintiff.
209. As a direct and proximate result of Defendant's conduct, Plaintiff was injured in that
Plaintiffs were frightened and excited, resulting in a mental and nervous injury that has
caused Plaintiff great emotional pain and suffering and loss of his family and loss of his
relationship now freely per his civil rights with his children since October 20, 1999, and

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now having not been able to see his children now since November 8, 2002 and reputation
and employment and loss of future ability to earn income and reduction in ability to earn
income and defamation and battery and slander.
210.

As a further direct and proximate result of Defendant's conduct, Plaintiff has been

damaged in the yet undetermined amount of financial damages for the cost of medical
bills, and for lost earnings and the ability to create employment and earnings.
WHEREFORE, Plaintiff demands judgment as follows:
A. For general damages.
B. For punitive damages.

C. For intentional infliction of emotional distress and battery

D. For costs of suit incurred in this action.
E. FOR UNJUST ENRICHMENT
F. For other and further relief as the Court may deem proper.
COUNT XIV
ABUSE OF PROCESS BY TORT INTERFERENCE OF CONTRACT KNOWN
AS THE FBCCP BY-LAWS AND MARRIAGE CONTRACTAGAINST
DEFENDANTS-- Defendant RONALD L. BECK, Individually, REVERAND RONALD
L. BECK, AS SENIOR PASTOR as the Corporation officer, of the FIRST BAPTIST
CHURCH OF CITRUS PARK, (FBCCP), and CITRUS PARK CHRISTIAN SCHOOL
(CPCS), AND THE CORPORATION OF THE FIRST BAPTIST CHURCH OF
CITRUS PARK, WILLIAM T. BROWN, Individually, REVERAND WILLIAM T.
BROWN, (FBCCP) AS PASTOR OF ADMINISTRATION, HERMAN MEISTER,
Individually, HERMAN MEISTER, (FBCCP/CPCS) AS PASTOR OF CITRUS PARK
CHRISTIAN SCHOOLS, (CPCS) HERMAN MEISTER AS CPCS SCHOOL BOARD
MEMBER, GARY LEATHERMAN, Individually, GARY LEATHERMAN, AS
TRUSTEE, (FBCCP) ROBERT GILES, Individually, ROBERT GILES, AS MEMBER
OF PERSONNEL COMMITTEE, (FBCCP) ROBERT GILES AS MEMBER OF THE
CPCS SCHOOL BOARD,PAULA POWELL, Individually, PAULA POWELL AS
FBCCP FINANCIAL SECRETARY EMPLOYEE, PAULA POWELL AS CPCS
SCHOOL BOARD MEMBER,TIM JEFFERS, Individually, TIM JEFFERS AS
PINELLAS COUNTY SHERIFF DEPUTY, TIM JEFFERS, AS FINANCE
COMMITTEE MEMBER, MARK NUNES, Individually, MARK NUNES, AS
CHAIRMAN OF DEACONS, 1999-2000 (FBCCP) MIKE SHUMATE, Individually,
MIKE SHUMANTE, AS CHAIRMAN OF DEACONS, 2000-2001, (FBCCP),
CARL(BUDDY) RAWLS, Individually, CARL(BUDDY) RAWLS, AS
MEMBER OF THE LONG RANGE PLANNING COMMITTEE FBCCP,
DUANE MILFORD, Individually, DUANE MILFORD AS LONG RANGE
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PLANNING COMMITTEE MEMBER FBCCP, KAREN JEFFERS, Individually,

KAREN JEFFERS AS EMPLOYEE AS PRINCIPLE OF CITRUS PARK CHRISTIAN
SCHOOL, GAYLE LYNN, Individually, GAYLE LYNN, AS EMPLOYEE DEAN OF
STUDENTS CITRUS PARK CHRISTIAN SCHOOL, APRIL BECK, Individually, JIM
LEAHY, Individually, JIM LEAHY AS PERSONNEL COMMITTEE CHAIRMAN,
JOE KAREAS, Individually, JOE KAREAS, AS CITY OF TAMPA POLICE
OFFICER, MICHEAL JOHN CORBIN, Individually, MICHEAL JOHN
CORBIN AS MEMBER OF THE LONG RANGE PLANNING COMMITTEE
FBCCP, MICHEAL JOHN CORBIN, AS PASCO COUNTY SHERIFF
DEPUTY DETECTIVE, JOYCE MEISTER, Individually, JACKIE HOWLETT,
Individually, JACKIE HOWLETT AS CPCS SCHOOL BOARD MEMBER,
JACKIE HOWLETT AS MEMBER OF THE LONG RANGE PLANNING
COMMITTEE FBCCP, JOE HOWLETT, Individually, JOE HOWLETT AS
HILLSBOROUGH COUNTY SHERIFF DEPUTY, JOE HOWLETT, AS
TRUSTEE, (FBCCP), LON LYNN, Individually, DR. LON LYNN, AS A
PROFESSIONAL MEDICAL DOCTOR, GEOFF SMITH, Individually, GEOFF
SMITH, AS CORPORATION PRESIDENT, MIKE SMOAK, AS Individually,
MIKE SMOAK AS CPCS SCHOOL BOARD MEMBER, MIKE SMOAK AS
HILLSBOROUGH COUNTY SHERIFF DEPUTY, MIKE SHAR, Individually,
are of THE MEMBERSHIP AT LARGE AND EMPLOYEES OF d/b/a, FIRST
BAPTIST CHURCH OF CITRUS PARK,(FBCCP AND CITRUS PARK
CHRISTIAN SCHOOL, (CPCS) AS A FLORIDA NOT FOR PROFIT
CORPORATION and are as individuals, as agents or of the membership of the
Corporation of the First Baptist Church of Citrus Park and Citrus Park Christian
School operating as a ministry of the Corporation know and d/b/a, The First
Baptist Church of Citrus Park (FBCCP) being sued as Defendants as individuals
and in their capacity as agents of the Corporation and as members of the
Corporation and as the CORPORATION FBCCP. Defendants JOHN A. GRANT,
JR.(GRANT) Individually, JOHN A. GRANT, JR. AS REGISTERED AGENT OF First
Baptist Church of Citrus Park CORPORATION, being sued in his role as an individual,
Agent of the FBCCP CORPORATION and Officer of the State of Florida acting as a
licensed REGISTERED AGENT who knowingly, intentionally, recklessly, and
negligently gave benefit to clergy and willfully and recklessly neglected his DUTY as a
REGISTERED AGENT knowing the CORPORATION OF THE FBCCP and
CORPORATE OFFICERS and MEMBERS were in violations of the Florida
Statues as stated herein. GRANT maintains his office and residence in
Hillsborough County, Florida. DEFENDANTS KAREN HARROD TOWNSEND,
Individually, as estranged former wife of Plaintiff and mother and former
CPCS school teacher of Plaintiff J.D.T and J.G.T and KAREN HARROD
TOWNSEND AS EMPLOYEE OF CITRUS PARK CHRISTIAN SCHOOL
A MINISTRY OF THE FBCCP and maternal family as STEVEN TYLER
HARROD, (STEVE HARROD) Individually, DONALD HARROD,(DON HARROD)
Individually, NORMA HARROD, (NORMA HARROD) Individually and CHARLES H.
SCRUGGS III., Individually, CHARLES H. SCRUGGS, III. ESQUIRE, As attorney at
law, and CHARLES H. SCRUGGS, III, P.A., A Professional Association Law Firm and

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HEATHER M. GRAY, Individually, HEATHER M. GRAY, ATTORNEY AT LAW,

HEATHER M. GRAY, PROFESSIONAL ASSOCIATION AS A FLORIDA
CORPORATION,
210. COMES NOW Plaintiff Randall Townsend (Plaintiff Townsend), is the father of son
J.D.T and daughter J.G.T as the persons deprived of their respective rights of the
Constitution of the United States of America and the Statues and Constitution of the
State of Florida and the Constitution and BY-LAWS of the First Baptist Church of Citrus
Park and Plaintiff Townsends post office address is P.O. BOX 21, ODESSA, FL 33556.
211. Defendant RONALD L. BECK, Individually, REVERAND RONALD L. BECK,
AS SENIOR PASTOR as the Corporation officer, of the FIRST BAPTIST CHURCH
OF CITRUS PARK, (FBCCP), and CITRUS PARK CHRISTIAN SCHOOL (CPCS),
AND THE CORPORATION OF THE FIRST BAPTIST CHURCH OF CITRUS
PARK, WILLIAM T. BROWN, Individually, REVERAND WILLIAM T.
BROWN, (FBCCP) AS PASTOR OF ADMINISTRATION, HERMAN
MEISTER, Individually, HERMAN MEISTER, (FBCCP/CPCS) AS PASTOR
OF CITRUS PARK CHRISTIAN SCHOOLS, (CPCS) HERMAN MEISTER AS
CPCS SCHOOL BOARD MEMBER, GARY LEATHERMAN, Individually,
GARY LEATHERMAN, AS TRUSTEE, (FBCCP) ROBERT GILES,
Individually, ROBERT GILES, AS MEMBER OF PERSONNEL COMMITTEE,
(FBCCP) ROBERT GILES AS MEMBER OF THE CPCS SCHOOL BOARD,
PAULA POWELL, Individually, PAULA POWELL AS FBCCP FINANCIAL
SECRETARY EMPLOYEE, PAULA POWELL AS CPCS SCHOOL BOARD
MEMBER,TIM JEFFERS, Individually, TIM JEFFERS AS PINELLAS
COUNTY SHERIFF DEPUTY, TIM JEFFERS, AS FINANCE COMMITTEE

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MEMBER, MARK NUNES, Individually, MARK NUNES, AS CHAIRMAN OF

DEACONS, 1999-2000 (FBCCP) MIKE SHUMATE, Individually, MIKE
SHUMANTE, AS CHAIRMAN OF DEACONS, 2000-2001, (FBCCP),
CARL(BUDDY) RAWLS, Individually, CARL(BUDDY) RAWLS, AS
MEMBER OF THE LONG RANGE PLANNING COMMITTEE FBCCP,
DUANE MILFORD, Individually, DUANE MILFORD AS LONG RANGE
PLANNING COMMITTEE MEMBER FBCCP, KAREN JEFFERS, Individually,
KAREN JEFFERS AS EMPLOYEE AS PRINCIPLE OF CITRUS PARK CHRISTIAN
SCHOOL, GAYLE LYNN, Individually, GAYLE LYNN, AS EMPLOYEE DEAN OF
STUDENTS CITRUS PARK CHRISTIAN SCHOOL, APRIL BECK, Individually, JIM
LEAHY, Individually, JIM LEAHY AS PERSONNEL COMMITTEE CHAIRMAN,
JOE KAREAS, Individually, JOE KAREAS, AS CITY OF TAMPA POLICE
OFFICER, MICHEAL JOHN CORBIN, Individually, MICHEAL JOHN
CORBIN AS MEMBER OF THE LONG RANGE PLANNING COMMITTEE
FBCCP, MICHEAL JOHN CORBIN, AS PASCO COUNTY SHERIFF
DEPUTY DETECTIVE, JOYCE MEISTER, Individually, JACKIE HOWLETT,
Individually, JACKIE HOWLETT AS CPCS SCHOOL BOARD MEMBER,
JACKIE HOWLETT AS MEMBER OF THE LONG RANGE PLANNING
COMMITTEE FBCCP, JOE HOWLETT, Individually, JOE HOWLETT AS
HILLSBOROUGH COUNTY SHERIFF DEPUTY, JOE HOWLETT, AS
TRUSTEE, (FBCCP), LON LYNN, Individually, DR. LON LYNN, AS A
PROFESSIONAL MEDICAL DOCTOR, GEOFF SMITH, Individually, GEOFF
SMITH, AS CORPORATION PRESIDENT, MIKE SMOAK, AS Individually,

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MIKE SMOAK AS CPCS SCHOOL BOARD MEMBER, MIKE SMOAK AS

HILLSBOROUGH COUNTY SHERIFF DEPUTY, MIKE SHAR, Individually,
are of THE MEMBERSHIP AT LARGE AND EMPLOYEES OF d/b/a, FIRST
BAPTIST CHURCH OF CITRUS PARK,(FBCCP AND CITRUS PARK
CHRISTIAN SCHOOL, (CPCS) AS A FLORIDA NOT FOR PROFIT
CORPORATION and are as individuals, as agents or of the membership of the
Corporation of the First Baptist Church of Citrus Park and Citrus Park Christian
School operating as a ministry of the Corporation know and d/b/a, The First
Baptist Church of Citrus Park (FBCCP) being sued as Defendants as individuals
and in their capacity as agents of the Corporation and as members of the
Corporation and as the CORPORATION FBCCP. Defendants JOHN A. GRANT,
JR.(GRANT) Individually, JOHN A. GRANT, JR. AS REGISTERED AGENT OF First
Baptist Church of Citrus Park CORPORATION, being sued in his role as an individual,
Agent of the FBCCP CORPORATION and Officer of the State of Florida acting as a
licensed REGISTERED AGENT who knowingly, intentionally, recklessly, and
negligently gave benefit to clergy and willfully and recklessly neglected his DUTY as a
REGISTERED AGENT knowing the CORPORATION OF THE FBCCP and
CORPORATE OFFICERS and MEMBERS were in violations of the Florida
Statues as stated herein. GRANT maintains his office and residence in
Hillsborough County, Florida. DEFENDANTS KAREN HARROD TOWNSEND,
Individually, as estranged former wife of Plaintiff and mother and former
CPCS school teacher of Plaintiff J.D.T and J.G.T and KAREN HARROD
TOWNSEND AS EMPLOYEE OF CITRUS PARK CHRISTIAN SCHOOL

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A MINISTRY OF THE FBCCP and maternal family as STEVEN TYLER

HARROD, (STEVE HARROD) Individually, DONALD HARROD,(DON
HARROD) Individually, NORMA HARROD, (NORMA HARROD) Individually,
CHARLES H. SCRUGGS III., Individually, CHARLES H. SCRUGGS, III. ESQUIRE,
As attorney at law, and CHARLES H. SCRUGGS, III, P.A., A Professional Association
Law Firm.
212. Plaintiff alleges all paragraphs above and inclusive herein.
213.Plaintiff at all time material hereto is a resident of the State of Florida, with a mailing
address at P.O. Box 21, Odessa, FL 33556.
214.This is an action for damages in excess of the minimum jurisdiction of this Court.
215.On or about November 2001, Plaintiff was jointly served Cases 01-15813, Beck et al
v. Townsend and Case No: 01-15814, Townsend v. Townsend, alleging Criminal
Charges of Repeat Violence and Stalking and Domestic Violence and Stalking and other
verbal accusations allege in the affidavits and court of Judge Raul Palomino during the
Affidavits of October 31, 2001, by Ron Beck et al. And by Karen Harrod Townsend in
Affidavits of November 2, and November 14, 2001. These said affidavits lead to
INJUNCTIONS being duly served and honored during the period of November 2, 2001
until being QUASHED by Judge Palomino ruling these Injunctions were without cause
and gave detailed warnings to Defendants herein of violations of rights of this Plaintiff
herein. These warnings were ignored by Defendants as stated herein. And stated in all
cases as shown herein for which Plaintiff asks this Court to take judicial notice of all
cases relating back to cases 01-15813 & 01-15814.
216.On or about April 2002, Plaintiff was served Case 02-4974, a COMPLAINT FOR

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DIVORCEMENT and Petition for Child Custody resulting from Defendants intentional,
knowingly, recklessly and negligently conspiring to conceal and restrain the attempt by
this Plaintiff Townsend to per his duty to the State Of Florida, the First Baptist Church of
Citrus Park Corporation, the Nave General Voting Members and the Children in the Care
and Management of the Plaintiff Townsend and the Marital Children J.D.T and J.G.T to
restrain and abuse Plaintiff and inflict emotional distress and ruin the public image of this
Plaintiff so Plaintiff would or could not reveal the Criminal, Civil, Domestic Violations
of Law, Child Abuse and Negligent Care of Children and Labor Law Violations and
Internal Revenue Service violations and frauds and omissions of truthful disclosure and
tampering with witnesses, obstruction of justice and perjury, Defendants through FBCCP
Employee Karen Harrod Townsend filed suit for DIVORCEMENT and Child Custody.
217.Plaintiff alleges that this Suit for DIVORCEMENT and CHILD CUSTODY was not
based on irreconcilable differences but was tort and Abuse of Process to conceal and do
fraud on the courts and on law enforcement and other nave persons in the public eye
with the intentional conspired purpose doing battery as extortion and of damaging the
reputation and public image of Plaintiff Randall Townsend and these actions were
violations and fraud on the court as stated in RYAN v. RYAN 277 So2d 266. (Fla. Sct.
1973) for the unjust enrichment of themselves and others.
218.Plaintiff alleges that the SUIT was brought intentionally to conceal from this Plaintiff
his children J.D.T and J.G.T and prevent this father from getting these marital children
proper medical care as reported was needed by Dr. Santiago Hoyos and Dr. Ernesto
Millan in written findings of January 18, 2002, and February 12, 2002 for Minor J.G.T.
and for various medical reports for Minor J.D.T.

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219.Plaintiff alleges that this Suit for Divorcement was an continuation of conspiracy
assisted by the false representations of Sheriff Deputy Joe Howlett as alleged Trustee of
FBCCP with other Schism Officers and other employees and members of the Corporation
and Defendant Karen Harrod Townsend and with all Harrods (Don, Norma, Steve) and
Scruggs to conceal their unjust enrichment and coercion and frauds falsely alleged
against this plaintiff.
220.Plaintiff alleges that this Suit for Divorcement was a continuation of the allegations
of cases 01-15813 and 01-15814, to continue the concealment of all actions of tort and
negligence as shown and incorporated all paragraphs herein and caused Plaintiff and
others to be deceived and Plaintiff suffered damages thereby including an DIVORCE
JUDGMENT WITH INJUNCTIONS that still damage this Plaintiff with injurious
falsehoods and prevents this father from seeing his children now since November 8, 2002
by the unlawful interference and abuse of process and interference with Constitutional,
and BY-LAW rights to family and protection of civil and religious beliefs of plaintiffs.
221. WHEREFORE, the Plaintiff demands trial by jury on all issues so triable and prays
this Court will award damages against Defendants, including court costs, and any other
further relief as the Court may deem proper.
COUNT XV
BREACH OF CONTRACTUAL FIDUCIARY DUTYAGAINST
DEFENDANTS CHARLES H. SCRUGGS III, INDIVIDUALLY, CHARLES H.
SCRUGGS III, ATTORNEY AT LAW, CHARLES H. SCRUGGS P.A., ATTORNEY
CHARLES DENNY, IV, Individually and as Attorney at law, A. JAMES ROLFES,
Individually and As Attorney At Law and DICKINSON & GIBBONS, P.A., Drew
Gardner, Individually, and Drew Gardner, Attorney At Law and David Gibbs, III,
Individually, and David Gibbs, III, Attorney At Law, and The GIBBS LAW FIRM, and
the CHRISTIAN LAW ASSOCIATION, Ronald L. Beck, individual, Ronald L. Beck as
Corporation Senior Pastor, Geoff Smith, Individual, Geoff Smith, Corporation
Trustee/President, Joe Howlett, Individual, Joe Howlett, Corporation Trustee, Gary
Leatherman, Individual, Gary Leatherman, Corporation Trustee and Tim Jeffers,

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Individual, and Tim Jeffers Corporation Trustee and Herman Meister, Individual, and
Herman Meister as Pastor of School Ministries CPCS. JOHN A. GRANT, JR.
Individually, JOHN A. GRANT, JR. AS REGISTERED AGENT OF First Baptist
Church of Citrus Park CORPORATION, UTICA INSURANCE COMPANY OF NEW
YORK, STACEY TURMEL, Individually, STACEY TURMEL AS ATTORNEY AT
LAW, OF STACEY TURMEL, P.A., THE LAW FIRM OF STACEY TURMEL, P.A.
MR. CHARLIE CRIST, Individually, MR. CHARLIE CRIST, AS IN THE OFFICIAL
POSITION AS THE ATTORNEY GENERAL FOR THE STATE OF FLORIDA,
THE OFFICE/DEPARTMENT OF THE ATTORNEY GENERAL FOR THE STATE
OF FLORIDA, Mr. TOM GALLAGHER, Individually, MR. TOM GALLAGHER, AS
IN THE OFFICIAL POSITION AS THE CHIEF FINANCIAL OFFICER OF THE
STATE OF FLORIDA DEPARTMENT OF FINANCIAL SERVICES, and
THE DEPARTMENT OF FINANCIAL SERVICES, THE DEPARTMENT OF

CHILDREN AND FAMILIES OF THE STATE OF FLORIDA,

DAVID GEE, AS SHERIFF OF HILLSBOROUGH COUNTY FLORIDA, and
DEPUTY SHERIFF JOE HOWLETT AND DEPUTY SHERIFF MIKE SMOAK AND
DEPUTY SHERIFF SCOTT WELLINGER, Individually, SCOTT WELLINGER, AS A
HILLSBOROUGH COUNTY SHERIFF DEPUTY SERGEANT,
DEPUTY SHERIFF LUTHER CORE, Individually, LUTHER CORE AS
HILLSBOROUGH COUNTY SHERIFF DEPUTY DETECTIVE EXECUTIVE
SUPPORT DEPARTMENT INTERNAL AFFAIRS, DEPUTY SHERIFF PAUL J.
GUARINO, Individually, PAUL J. GUARINO, AS HILLSBOROUGH COUNTY
SHERIFF DEPUTY SERGEANT PROPERTY CRIMES UNIT, DEPUTY HARRY
HOOVER, Individually,HARRY HOOVER, AS HILLSBOROUGH COUNTY
SHERIFF DEPUTY SERGEANT FOR INTERNAL AFFAIRS, JIM COATS, AS
SHERIFF OF PINELLAS COUNTY FLORIDA, DEPUTY SHERIFF JOSEPH A.
GILLETTEE, SERGENT ADMINISTRATIVE INVESTIGATIONS DIVISION
PINELLAS COUNTY SHERIFF OFFICE, DEPUTY SHERIFF TIM JEFFERS,
THE PINELLAS COUNTY SHERIFFS OFFICE, BOB WHITE, AS SHERIFF OF
PASCO COUNTY FLORIDA, DEPUTY SHERIFF JOHN MICHEAL CORBIN OF
PASCO COUNTY FLORIDA, THE DEPARTMENT OF THE PASCO COUNTY
SHERIFF, THE CHIEF OF POLICE OF TAMPA, FLORIDA, and POLICE OFFICER
JOE KAREAS OF THE CITY OF TAMPA, THE CITY OF TAMPA, CYNTHIA
BARNARD SANZ, Individually, CYNTHIA BARNARD SANZ AS SPECIAL AGENT
SUPERVISION FOR THE FLORIDA DEPARTMENT OF LAW ENFORCEMENT,
MR. GERALD BAILEY COMMISSIONER, FLORIDA DEPARTMENT OF LAW
ENFORCEMENT, THE FLORIDA DEPARTMENT OF LAW ENFORCEMENT
CURTIS BAUGHMAN, Individually, NANCY LOPEZ, Individually,
CURTIS BAUGHMAN AND NANCY LOPEZ AS EMPLOYEES OF VICTIMS
ASSISTANCE OF THE STATE ATTORNEY OF FLORIDA, THE DEPARTMENT OF
VICTIMS ASSISTANCE, MARK A. OBER, Individually, MARK A. OBER AS STATE
ATTORNEY OF FLORIDA, CHIEF JUDGE MANUEL MENENDEZ JR. OF
HILLSBOROUGH COUNTY FLORIDA CIRCUIT CIVIL COURTS, MANUEL
MENENDEZ JR. Individually, WAYNE TIMMERMAN, Individually, JUDGE
WAYNE TIMMERMAN A CIRCUIT COURT JUDGE OF HILLSBOROUGH

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COUNTY FLORIDA, RAUL PALOMINO, Individually, JUDGE RAUL PALOMINO,

A CIRCUIT COURT JUDGE FOR HILLSBOROUGH COUNTY FLORIDA,
FRANK GOMEZ, Individually, JUDGE FRANK GOMEZ A CIRCUIT COURT JUDGE
FOR HILLSBOROUGH COUNTY FLORIDA, MONICA SIERRA, Individually,
JUDGE MONICA SIERRA, A CIRCUIT COURT JUDGE FOR HILLSBOROUGH
COUNTY FLORIDA, RALPH STODDARD, Individually, JUDGE RALPH
STODDARD, A CIRCUIT COURT JUDGE FOR HILLSBOROUGH COUNTY
FLORIDA, GREG HOLDER, Individually, JUDGE GREG HOLDER, A CIRCUIT
COURT JUDGE FOR HILLSBOROUGH COUNTY FLORIDA, MARVA
CRENSHAW, Individually, JUDGE MARVA CRENSHAW, A CIRCUIT COURT
JUDGE FOR HILLSBOROUGH COUNTY FLORIDA, RAQUEL A. RODRIQUEZ,
Individually, RAQUEL A. RODRIQUEZ AS GENERAL COUNSEL TO THE OFFICE
OF THE GOVERNOR OF THE STATE OF FLORIDA, BROOKE S. KENNERLY,
Individually, BROOKE S. KENNERLY AS EXECUTIVE DIRECTOR FOR THE
JUDICIAL QUALIFICATIONS COMMISSION OF THE STATE OF FLORIDA,
THE JUDICIAL QUALIFICATIONS COMMISSION OF THE STATE OF FLORIDA,
THE FLORIDA BAR, THE FLORIDA BAR OFFICER OF EXECUTIVE DIRECTOR,
THE FLORIDA BAR OFFICER OF TAMPA BRANCH OFFICE
EXECUTIVE/DISCIPLINE DIRECTOR AS BRANCH STAFF COUNSEL,
THE FLORIDA BAR TAMPA INTAKE STAFF COUNSEL EMPLOYEE, MS. DOE
LIEMAN, MS. DOE LIEMAN, Individually, THE FLORIDA BAR TAMPA
INTAKE STAFF EMPLOYEE MS. JANE CRISTY and Ms. JANE CRISTY,
Individually, THE STATE OF FLORIDA, and
222.Comes now Plaintiff Randall Townsend and Sues Defendants
ATTORNEY CHARLES H. SCRUGGS, III, and CHARLES H. SCRUGGS, III,
ATTORNEY and CHARLES H. SCRUGGS, P.A. and CHARLES DENNY, IV,
Individually and as ATTORNEY AT LAW and A. JAMES
ROLFES, Individually and as ATTORNEY AT LAW and the DICKINSON &
GIBBONS, P.A., LAW FIRM, DREW GARDNER, Individually, and DREW
GARDNER, ATTORNEY AT LAW and DAVID GIBBS, III, Individually, and DAVID
GIBBS, III, ATTORNEY AT LAW, and The GIBBS LAW FIRM, and the CHRISTIAN
LAW ASSOCIATION, RONALD L. BECK, individual, Ronald L. Beck as FBCCP
Corporation Senior Pastor, Geoff Smith, Individual, Geoff Smith, Corporation
Trustee/President, Joe Howlett, Individual, Joe Howlett, Corporation Trustee, Gary

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Leatherman, Individual, Gary Leatherman, Corporation Trustee and Tim Jeffers,

Individual, and Tim Jeffers Corporation Trustee and Herman Meister, Individual, and
Herman Meister as Pastor of School Ministries CPCS, and each Defendant listed in this
Count herein and alleges:
223.Plaintiff re alleges all paragraphs above and below and incorporates them herein.
224.This cause of action is for damages within the jurisdiction of this Court and for
damages yet fully known without Court Ordered Discovery of Documents being
concealed by Defendants herein from this Member as Plaintiff Townsend.
225.Plaintiffs alleges as a member of the First Baptist Church of Citrus Park Plaintiffs
are granted per the Contract Rights of the BY-LAWS ARTICLE I. Sec. 2 The members
of the corporation shall consist of the members of the First Baptist Church of Citrus
Park. Sec. 4. The membership present at any regular or special called business meeting
shall constitute a quorum for the conduct of the business of the church, when due notice
has been given. Article II. Section 4. No deed or mortgage of the corporations
property shall be executed except upon resolution adopted at a meeting of the members of
the corporation.
226.Plaintiff Townsend alleges that due to the fraudulent position, advice, legal actions,
and false misrepresentations as to material facts or knowingly concealment of all or part
of material information from this Plaintiff by first Sheriff Deputy Joe Howlett and Jeffers
intentionally, knowingly, recklessly and negligently violating the Fourth Amendment
rights and BY-LAWS rights of this Plaintiff and misusing his color of uniform
intending to inflict emotional fear and danger of Plaintiffs and others and doing gross
negligent and great indifference to persons, property and the rights of others but acting to

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protect his personal interests as a trustee and as a employee of the Hillsborough County
Sheriffs Department and his co-conspirators and that the exposure of the allegations by
Plaintiff Townsend would lead to his loss of employment, pension, and possible
incarceration and loss of reputation and then the continued fraud of Attorney Denny
giving Benefit to Clergy as Defendants in Breach of the Duties of the Contract BYLAWS over the Dutiful Rights of or to this Plaintiff and to the Courts and to the General
Voting Members by not allowing this now newly discovered rights of this Plaintiff
Townsend as still a member being fraudulently concealed by the coercion and fraudulent
and knowingly, intentionally, recklessly and negligently actions to conceal these
Corporations Business Meeting Records just produced on June 12, 2006, that this
Plaintiff as a member of the Corporation was denied his total rights to know of meetings,
attend meetings, speak at meetings, ask questions at meetings, lead as the Chairman of
the LRPC, participate as Awana Commander to protect the interests of the over 200,
children and workers and continue his investigation of the unlawful and violations of the
BY-LAWS of these Officers and to continually questions these OFFICERS of the
Corporation per the BY-LAWS and the Florida Statues to attend, speak, or ask questions
and vote to protect his membership rights as Granted per the BY-LAWS ARTICLE III.
Section 7, and that the DUE PROCESS Right was violated by the Pastors Schisms I &
II, through frauds to this member, his family and the General Voting Members causing
deceptions and damages.
227.Plaintiff alleges that the January 2003, BUSINESS MEETING MOTION for a full
and complete investigation of the officers of the Corporation was Quashed, fraudulently
manipulated and falsely reported per the April 3, 2000, REPORT OF THE PERSONNEL

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COMMITTEE and the testimony of the Trustee Gary Leatherman acting on the Personnel
Committee blocked the Committee from fact finding regarding his self interests of the
reporting of missing accounts and actions to conceal the missing monies just reported to
this Plaintiff in June and July 2006 and reports show the General Voting members still
are deceived about these secret accounts and misappropriation of funds by the Schisms.
228.Plaintiff alleges that as the Long Range Planning Committee Chairman being
unduly removed from this position by the Fraudulent unlawful deceptions and violations
of the BY-LAWS due process that the Corporation of the First Baptist Church and this
Plaintiff have been deceived and suffered damages even incurring DEBT due to the
Coercion and Benefit of Clergy.
229.Plaintiff alleges that all financial debt of the Corporation would not have occurred
but for the Benefit of Clergy and frauds by Attorney Denny with the pastors Schism I
& II trying to suppress and omit the truthful disclosure of the truth of this Plaintiff to the
General Voting Members prior to any vote of said members.
230. Plaintiff allege that therefore all the VOTES of the GENERAL VOTING
MEMBERSHP have been gained by FRAUDULENT BUSINESS PRACTICES AND
OMISSIONS OF TRUTHFUL DISCLOSURE, since September 8, 1999, are invalid and
specifically the votes of the July 2, 2000, REVISED BY-LAWS and the vote or votes of
Mortgages for any building projects were denied by the Coercion of Attorney Denny in
violation of his Fiduciary duty to be truthful to the Clients of the Corporation vested with
rights per the By-laws and that the Actions of attorney Denny and the firm of Dickinson
& Gibbons, did show Benefit to clergy and thereby granted superior rights of speaking
or voting by fraudulent actions and omissions of truthful disclosure in Breach of

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Fiduciary Duty by the Corporation Trustees and Officers as Pastors knowing that the
Voting to revise the BY-LAWS was being done to remove rights from the General
Voting Member and give undue privileges to the Corporation Officers.
231.Plaintiff further alleges that Attorney Denny denying the Rights of this Plaintiff
Townsend per the By-Laws, did give BENEFIT TO CLERGY to extend the fraudulent
business practices now revealed by the production of the Corporation Credit card billings
of the uses allegedly approved by Ron Beck but reveal concealed pecuniary gain and
unlawful loans to an officer of the Corporation in violation of the rights of the General
Voting Members to have knowledge of or approve these unrevealed secret accounts
and the concealment thereby causes and allows misappropriation of corporate opportunity
incurring liability on Plaintiff herein and provides Defendants unjust enrichment.
232.Plaintiff Townsend further alleges that the Firm Of DICKINSON & GIBBONS upon
being duly informed by Plaintiff Townsend conspired and negligently managed and
approved the malfeasance of Attorney Denny to this plaintiff and to the Courts and to the
General Voting Membership and did not take sufficient or reasonable cause or care to
rightfully undo these actions to properly notify or protect the rights due to these clients
and thereby become vicariously liable by their conduct or lack thereof.
233. Plaintiff Townsend further alleges that Pastors Schisms I & II, jointly conspired with
Attorney Denny and greatly benefited thereby to do financial damage and loss to the
General Voting Members by the deception and damages illegally obtained from the
General Voting Members and this Plaintiff and by fraudulent practices did set in motion
actions of others with malicious intent to fraud and damage this Plaintiff Townsend in the
Publics eye and in his places of Employment and thereby caused loss of employment

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and damages.
234.Plaintiff alleges per DEMETREE v. STATE 89 So2d 498 (Fla. 1956) that each
defendant herein intentionally, knowingly, recklessly and negligently violated the rulings
of Judge Palomino in cases 01-15813, and 01-15814, jointly releasing any and all
INJUNCTIONS on November 15, 2001, against this Plaintiff, and even advising
Defendants of violations of the rights of this Plaintiff but by fraud Defendants conspired
and omitted truthful disclosure of the Rulings of the Honorable Judge Palomino and
instead continued and increased the limitations of Plaintiffs RIGHTS TO AND WITH
HIS CHILDREN and Access on Public Property and potential opportunity to restore his
family rights and conveyed fraud in the statements to the Courts as recorded in the FIRST
AFFIRMATIVE DEFENSES with malicious intent to continue and cause additional
fraud and damages to this Plaintiff including the DIVORCE AND INJUNCTIONS
rulings gained by Attorney Scruggs with Judge Timmerman in November 2003, which
still damage this father to not be able to see his children now since November 8, 2002.
235.Plaintiff therefore alleges that the Corporation and this Plaintiff should be made
whole and debt free including all principle sums and interests of any and all
mortgages but for the losses incurred by the deceptions of the Defendants herein as the
Directive Rights of the General Voting Members to this Chairman of the LRPC before
Plaintiff Townsend was removed September 8, 1999, by the frauds of the pastors
schisms was to proceed with all projects but remain debt free and therefore the demand
of show me the money and the fraudulent attempts and deceptions of the now newly
discovered over $214,000.00 unreported in periods 2nd, 3rd, 4th, Quarterly Business
Meetings and Yearly Business Meeting as required by the BY-LAWS did lead to the

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damages incurred. Each Business Meeting shows proof of conspiracy to defraud and by
Plaintiff being banned from each meeting the conspiracy of the Pastors Schism I & II
and with Attorney Denny and his firm these Defendants have prospered thereby at the
suffering of this Plaintiff and the General Voting Members and others.
236.Plaintiff further alleges that each and every one of the representations set forth in the
preceding paragraphs concerned material facts for the reason that Plaintiff would not
have been barred from his family, his children, his Voting Rights, his Positions of
Leadership, his honored reputation, and his employment and future employment(s).
237.Further, Plaintiff and others relied on each and every one of the defendants
representations that resulted in Plaintiffs substantial injury and damages as described
more fully below. In this connection, Plaintiff and Plaintiffs Friends the Minor General
Voting Members further alleges that Defendants purported to have and did have superior
knowledge concerning the subject matter of the transactions described above, and
Plaintiff justifiably relied on Defendant' superior knowledge.
238.By reason of Plaintiffs reliance on Defendants representations and fraudulent
concealment of material facts and injurious falsehoods as described above, Plaintiff has
been damaged in an amount far in excess of the minimum jurisdictional limits of this
Court. Plaintiff alleges that Plaintiff paid over $10,000.00 in legal fees, costs and court
reporter fees, lost equity in the marital home, lost profits of fair market value in the
marital home in excess of $100,000.00, lost over $60,000.00 of unpaid employment
commissions from SunBelt Equipment Company, lost the opportunity per the State
Attorney to Sue SunBelt for defamation and lost income in a suit in excess of
$1,000,000.00, lost marital rights, lost child society rights and custody, lost an honorable

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reputation, lost employment at Kmart as a Level II store manager, lost profit sharing and
lost insurance and lost retirement income and incurred debt in an still unknown amount
and further lost valuable time in a relationship and incurred lack of use of the assets of
the corporation members embezzled by the fraud of the pastors, trustees and adult voting
members as shown and named herein and lost use of the building and expansion program
but for the fraud and fault of negligent and tort intentional, reckless and malfeasance of
officers, alleged trustees, pastors and other general voting members knowingly acting in
negligent breach of the FBCCP BY-LAWS.
239. WHEREFORE, the Plaintiff demands trial by jury on all issues so triable and
prays this Court will award a judgement and award damages including:
A. The offset of all FBCCP Corporation indebtedness due to the fraudulent
voting and other actions of the Schism to deceive this Plaintiff and the Minor
General Voting Membership against Defendants, Ronald L. Beck, individually,
Rev. Ronald L. Beck as senior pastor of First Baptist Church of Citrus Park and
Trustee Geoff Smith, Trustee Joe Howlett, Trustee Gary Leatherman and Trustee
Tim Jeffers and Pastor Herman Meister and Defendant Charles Denny, IV,
individually, Charles Denny, IV. Attorney at Law, A. James Rolfes, Individually
and A. James Rolfes, Attorney at Law and DICKINSON & GIBBONS, P.A.,
B. For General Damages, according to proof.
C. For an award of damages per 57.105(3) for its reasonable expenses incurred
in obtaining an order, which may include attorneys fees and other loss
resulting from the improper delay.
D. For an award of Sanctions against Attorneys per 57.105(4) and 57.105(5).
E. For the Following Special Damages:
F. For approximately $10,000.00 in legal fees, costs, and court reporter fees,
G. Lost of equity in the marital home, lost profits of fair market value in the
marital home in excess of $100,000.00,
H. Lost of over $60,000.00 of unpaid employment commissions from SunBelt
Equipment Company.
I. Loss of the opportunity per the State Attorney to Sue SunBelt for defamation
and lost income in a suit in excess of $1,000,000.00 due to the allegations of
defendants herein during the statue of limitation periods
J. Loss of marital rights,
K. Loss child society rights and custody,
L. Loss of an honorable reputation,

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M. Loss of employment at Kmart as a Level II store manager, and lost profit

sharing and lost insurance and lost retirement income and incurred debt in an
still unknown amount and lost ability to earn future income
N. For costs of suit incurred in this action.
O. For intentional infliction of emotional distress and battery and slander
P. For intentional infliction of child custody and visitation in Society. As this
father was and is prohibited from his children as the Injunctions are still being
enforced by frauds.
Q. For Punitive Damages
R. For other and further relief as the court may deem proper.
COUNT XVI
FRAUDAGAINST DEFENDANTS ATTORNEY CHARLES DENNY, IV,
Individually and as Attorney at law, A. JAMES ROLFES, Individually and As Attorney
At Law and DICKINSON & GIBBONS, P.A., Drew Gardner, Individually, and Drew
Gardner, Attorney At Law and David Gibbs, III, Individually, and David Gibbs, III,
Attorney At Law, and The GIBBS LAW FIRM, and the CHRISTIAN LAW
ASSOCIATION, Ronald L. Beck, individual, Ronald L. Beck as Corporation Senior
Pastor, Geoff Smith, Individual, Geoff Smith, Corporation Trustee/President, Joe
Howlett, Individual, Joe Howlett, Corporation Trustee, Gary Leatherman, Individual,
Gary Leatherman, Corporation Trustee and Tim Jeffers, Individual, and Tim Jeffers
Corporation Trustee and Herman Meister, Individual, and Herman Meister as Pastor of
School Ministries CPCS. JOHN A. GRANT, JR. Individually, JOHN A. GRANT, JR.
AS REGISTERED AGENT OF First Baptist Church of Citrus Park CORPORATION,
UTICA INSURANCE COMPANY OF NEW YORK, STACEY TURMEL, Individually,
STACEY TURMEL AS ATTORNEY AT LAW, OF STACEY TURMEL, P.A., THE
LAW FIRM OF STACEY TURMEL, P.A., MR. CHARLIE CRIST, Individually, MR.
CHARLIE CRIST, AS GOVERNOR OF THE STATE OF FLORIDA, MR. CHARLIE
CRIST, AS IN THE OFFICIAL POSITION AS THE ATTORNEY GENERAL FOR
THE STATE OF FLORIDA, THE OFFICE/DEPARTMENT OF THE ATTORNEY
GENERAL FOR THE STATE OF FLORIDA, Mr. TOM GALLAGHER, Individually,
MR. TOM GALLAGHER, AS IN THE OFFICIAL POSITION AS THE CHIEF
FINANCIAL OFFICER OF THE STATE OF FLORIDA DEPARTMENT OF
FINANCIAL SERVICES, and THE DEPARTMENT OF FINANCIAL SERVICES,
THE DEPARTMENT OF CHILDREN AND FAMILIES OF THE STATE OF
FLORIDA, DAVID GEE, AS SHERIFF OF HILLSBOROUGH COUNTY FLORIDA,
and DEPUTY SHERIFF JOE HOWLETT AND DEPUTY SHERIFF MIKE SMOAK
AND DEPUTY SHERIFF SCOTT WELLINGER, Individually, SCOTT WELLINGER,
AS A HILLSBOROUGH COUNTY SHERIFF DEPUTY SERGEANT,
DEPUTY SHERIFF LUTHER CORE, Individually, LUTHER CORE AS
HILLSBOROUGH COUNTY SHERIFF DEPUTY DETECTIVE EXECUTIVE
SUPPORT DEPARTMENT INTERNAL AFFAIRS, DEPUTY SHERIFF PAUL J.
GUARINO, Individually, PAUL J. GUARINO, AS HILLSBOROUGH COUNTY
SHERIFF DEPUTY SERGEANT PROPERTY CRIMES UNIT, DEPUTY HARRY
HOOVER, Individually,HARRY HOOVER, AS HILLSBOROUGH COUNTY
SHERIFF DEPUTY SERGEANT FOR INTERNAL AFFAIRS, JIM COATS, AS

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SHERIFF OF PINELLAS COUNTY FLORIDA, DEPUTY SHERIFF JOSEPH A.

GILLETTEE, SERGENT ADMINISTRATIVE INVESTIGATIONS DIVISION
PINELLAS COUNTY SHERIFF OFFICE, DEPUTY SHERIFF TIM JEFFERS,
THE PINELLAS COUNTY SHERIFFS OFFICE, BOB WHITE, AS SHERIFF OF
PASCO COUNTY FLORIDA, DEPUTY SHERIFF JOHN MICHEAL CORBIN OF
PASCO COUNTY FLORIDA, THE DEPARTMENT OF THE PASCO COUNTY
SHERIFF, THE CHIEF OF POLICE OF TAMPA, FLORIDA, and POLICE OFFICER
JOE KAREAS OF THE CITY OF TAMPA, THE CITY OF TAMPA, CYNTHIA
BARNARD SANZ, Individually, CYNTHIA BARNARD SANZ AS SPECIAL AGENT
SUPERVISION FOR THE FLORIDA DEPARTMENT OF LAW ENFORCEMENT,
MR. GERALD BAILEY COMMISSIONER, FLORIDA DEPARTMENT OF LAW
ENFORCEMENT, THE FLORIDA DEPARTMENT OF LAW ENFORCEMENT
CURTIS BAUGHMAN, Individually, NANCY LOPEZ, Individually,
CURTIS BAUGHMAN AND NANCY LOPEZ AS EMPLOYEES OF VICTIMS
ASSISTANCE OF THE STATE ATTORNEY OF FLORIDA, THE DEPARTMENT OF
VICTIMS ASSISTANCE MARK A. OBER, Individually, MARK A. OBER AS STATE
ATTORNEY OF FLORIDA, CHIEF JUDGE MANUEL MENENDEZ JR. OF
HILLSBOROUGH COUNTY FLORIDA CIRCUIT CIVIL COURTS,
MANUEL MENENDEZ JR. Individually, WAYNE TIMMERMAN, Individually,
JUDGE WAYNE TIMMERMAN A CIRCUIT COURT JUDGE OF HILLSBOROUGH
COUNTY FLORIDA, RAUL PALOMINO, Individually, JUDGE RAUL PALOMINO,
A CIRCUIT COURT JUDGE FOR HILLSBOROUGH COUNTY FLORIDA,
FRANK GOMEZ, Individually, JUDGE FRANK GOMEZ A CIRCUIT COURT JUDGE
FOR HILLSBOROUGH COUNTY FLORIDA, MONICA SIERRA, Individually,
JUDGE MONICA SIERRA, A CIRCUIT COURT JUDGE FOR HILLSBOROUGH
COUNTY FLORIDA, RALPH STODDARD, Individually, JUDGE RALPH
STODDARD, A CIRCUIT COURT JUDGE FOR HILLSBOROUGH COUNTY
FLORIDA, GREG HOLDER, Individually, JUDGE GREG HOLDER, A CIRCUIT
COURT JUDGE FOR HILLSBOROUGH COUNTY FLORIDA, MARVA
CRENSHAW, Individually, JUDGE MARVA CRENSHAW, A CIRCUIT COURT
JUDGE FOR HILLSBOROUGH COUNTY FLORIDA, RAQUEL A. RODRIQUEZ,
Individually, RAQUEL A. RODRIQUEZ AS GENERAL COUNSEL TO THE OFFICE
OF THE GOVERNOR OF THE STATE OF FLORIDA, BROOKE S. KENNERLY,
Individually, BROOKE S. KENNERLY AS EXECUTIVE DIRECTOR FOR THE
JUDICIAL QUALIFICATIONS COMMISSION OF THE STATE OF FLORIDA,
THE JUDICIAL QUALIFICATIONS COMMISSION OF THE STATE OF FLORIDA,
THE FLORIDA BAR, THE FLORIDA BAR OFFICER OF EXECUTIVE DIRECTOR,
THE FLORIDA BAR OFFICER OF TAMPA BRANCH OFFICE
EXECUTIVE/DISCIPLINE DIRECTOR AS BRANCH STAFF COUNSEL,
THE FLORIDA BAR TAMPA INTAKE STAFF COUNSEL EMPLOYEE, MS. DOE
LIEMAN, MS. DOE LIEMAN, Individually, THE FLORIDA BAR TAMPA
INTAKE STAFF EMPLOYEE MS. JANE CRISTY and Ms. JANE CRISTY,
Individually, THE STATE OF FLORIDA, CHARLES H. SCRUGGS III, Individually,
CHARLES H. SCRUGGS, III as Attorney and CHARLES H. SCRUGGS P.A. Heather
Gray, Individually and Heather Gray, Attorney and Heather Gray P.A and

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240.Comes now Plaintiff Randall Townsend and Sues Defendants CHARLES H.

SCRUGGS, INDIVIDUALLY, ATTORNEY CHARLES H. SCRUGGS, III,
CHARLES H. SCRUGGS P.A and CHARLES DENNY, IV, Individually and as
Attorney at law, A. JAMES ROLFES, Individually and As Attorney At Law and
DICKINSON & GIBBONS, P.A., Drew Gardner, Individually, and Drew Gardner,
Attorney At Law and David Gibbs, III, Individually, and David Gibbs, III, Attorney At
Law, and The GIBBS LAW FIRM, and the CHRISTIAN LAW ASSOCIATION, Ronald
Beck, individual, Ronald L. Beck as Corporation Senior Pastor, Geoff Smith,
Individual, Geoff Smith, Corporation Trustee/President, Joe Howlett, Individual, Joe
Howlett, Corporation Trustee, Gary Leatherman, Individual, Gary Leatherman,
Corporation Trustee and Tim Jeffers, Individual, and Tim Jeffers Corporation Trustee
and Herman Meister, Individual, and Herman Meister as Pastor of School Ministries
CPCS. JOHN A. GRANT, JR. Individually, JOHN A. GRANT, JR. AS REGISTERED
AGENT OF First Baptist Church of Citrus Park CORPORATION, UTICA
INSURANCE COMPANY OF NEW YORK, STACEY TURMEL, Individually,
STACEY TURMEL AS ATTORNEY AT LAW, OF STACEY TURMEL, P.A., THE
LAW FIRM OF STACEY TURMEL, P.A., MR. CHARLIE CRIST, Individually, MR.
CHARLIE CRIST, AS GOVERNOR OF THE STATE OF FLORIDA, MR. CHARLIE
CRIST, AS IN THE OFFICIAL POSITION AS THE ATTORNEY GENERAL FOR
THE STATE OF FLORIDA, THE OFFICE/DEPARTMENT OF THE ATTORNEY
GENERAL FOR THE STATE OF FLORIDA, Mr. TOM GALLAGHER, Individually,
MR. TOM GALLAGHER, AS IN THE OFFICIAL POSITION AS THE CHIEF
FINANCIAL OFFICER OF THE STATE OF FLORIDA DEPARTMENT OF

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FINANCIAL SERVICES, and THE DEPARTMENT OF FINANCIAL SERVICES,

THE DEPARTMENT OF CHILDREN AND FAMILIES OF THE STATE OF
FLORIDA, DAVID GEE, AS SHERIFF OF HILLSBOROUGH COUNTY FLORIDA,
and DEPUTY SHERIFF JOE HOWLETT AND DEPUTY SHERIFF MIKE SMOAK
AND DEPUTY SHERIFF SCOTT WELLINGER, Individually, SCOTT WELLINGER,
AS A HILLSBOROUGH COUNTY SHERIFF DEPUTY SERGEANT,
DEPUTY SHERIFF LUTHER CORE, Individually, LUTHER CORE AS
HILLSBOROUGH COUNTY SHERIFF DEPUTY DETECTIVE EXECUTIVE
SUPPORT DEPARTMENT INTERNAL AFFAIRS, DEPUTY SHERIFF PAUL J.
GUARINO, Individually, PAUL J. GUARINO, AS HILLSBOROUGH COUNTY
SHERIFF DEPUTY SERGEANT PROPERTY CRIMES UNIT, DEPUTY HARRY
HOOVER, Individually,HARRY HOOVER, AS HILLSBOROUGH COUNTY
SHERIFF DEPUTY SERGEANT FOR INTERNAL AFFAIRS, JIM COATS, AS
SHERIFF OF PINELLAS COUNTY FLORIDA, DEPUTY SHERIFF JOSEPH A.
GILLETTEE, SERGENT ADMINISTRATIVE INVESTIGATIONS DIVISION
PINELLAS COUNTY SHERIFF OFFICE, DEPUTY SHERIFF TIM JEFFERS,
THE PINELLAS COUNTY SHERIFFS OFFICE, BOB WHITE, AS SHERIFF OF
PASCO COUNTY FLORIDA, DEPUTY SHERIFF JOHN MICHEAL CORBIN OF
PASCO COUNTY FLORIDA, THE DEPARTMENT OF THE PASCO COUNTY
SHERIFF, THE CHIEF OF POLICE OF TAMPA, FLORIDA, and POLICE OFFICER
JOE KAREAS OF THE CITY OF TAMPA, THE CITY OF TAMPA, CYNTHIA
BARNARD SANZ, Individually, CYNTHIA BARNARD SANZ AS SPECIAL AGENT
SUPERVISION FOR THE FLORIDA DEPARTMENT OF LAW ENFORCEMENT,

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MR. GERALD BAILEY COMMISSIONER, FLORIDA DEPARTMENT OF LAW

ENFORCEMENT, THE FLORIDA DEPARTMENT OF LAW ENFORCEMENT
CURTIS BAUGHMAN, Individually, NANCY LOPEZ, Individually,
CURTIS BAUGHMAN AND NANCY LOPEZ AS EMPLOYEES OF VICTIMS
ASSISTANCE OF THE STATE ATTORNEY OF FLORIDA, THE DEPARTMENT OF
VICTIMS ASSISTANCE MARK A. OBER, Individually, MARK A. OBER AS STATE
ATTORNEY OF FLORIDA, CHIEF JUDGE MANUEL MENENDEZ JR. OF
HILLSBOROUGH COUNTY FLORIDA CIRCUIT CIVIL COURTS,
MANUEL MENENDEZ JR. Individually, WAYNE TIMMERMAN, Individually,
JUDGE WAYNE TIMMERMAN A CIRCUIT COURT JUDGE OF HILLSBOROUGH
COUNTY FLORIDA, RAUL PALOMINO, Individually, JUDGE RAUL PALOMINO,
A CIRCUIT COURT JUDGE FOR HILLSBOROUGH COUNTY FLORIDA,
FRANK GOMEZ, Individually, JUDGE FRANK GOMEZ A CIRCUIT COURT JUDGE
FOR HILLSBOROUGH COUNTY FLORIDA, MONICA SIERRA, Individually,
JUDGE MONICA SIERRA, A CIRCUIT COURT JUDGE FOR HILLSBOROUGH
COUNTY FLORIDA, RALPH STODDARD, Individually, JUDGE RALPH
STODDARD, A CIRCUIT COURT JUDGE FOR HILLSBOROUGH COUNTY
FLORIDA, GREG HOLDER, Individually, JUDGE GREG HOLDER, A CIRCUIT
COURT JUDGE FOR HILLSBOROUGH COUNTY FLORIDA, MARVA
CRENSHAW, Individually, JUDGE MARVA CRENSHAW, A CIRCUIT COURT
JUDGE FOR HILLSBOROUGH COUNTY FLORIDA, RAQUEL A. RODRIQUEZ,
Individually, RAQUEL A. RODRIQUEZ AS GENERAL COUNSEL TO THE OFFICE
OF THE GOVERNOR OF THE STATE OF FLORIDA, BROOKE S. KENNERLY,

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Individually, BROOKE S. KENNERLY AS EXECUTIVE DIRECTOR FOR THE

JUDICIAL QUALIFICATIONS COMMISSION OF THE STATE OF FLORIDA,
THE JUDICIAL QUALIFICATIONS COMMISSION OF THE STATE OF FLORIDA,
THE FLORIDA BAR, THE FLORIDA BAR OFFICER OF EXECUTIVE DIRECTOR,
THE FLORIDA BAR OFFICER OF TAMPA BRANCH OFFICE
EXECUTIVE/DISCIPLINE DIRECTOR AS BRANCH STAFF COUNSEL,
THE FLORIDA BAR TAMPA INTAKE STAFF COUNSEL EMPLOYEE, MS. DOE
LIEMAN, MS. DOE LIEMAN, Individually, THE FLORIDA BAR TAMPA
INTAKE STAFF EMPLOYEE MS. JANE CRISTY and Ms. JANE CRISTY,
Individually, THE STATE OF FLORIDA, Heather Gray, Individually, Heather Gray
Attorney and Heather Gray P.A. and alleges:
241.Plaintiff re alleges all paragraphs above and below and incorporates them herein.
242. This cause of action is for damages within the jurisdiction of this Court and for
damages yet fully known without Court Ordered Discovery of Documents being
concealed by Defendants herein from this Member as Plaintiff Townsend.
243. Plaintiffs alleges as a member of the First Baptist Church of Citrus Park Plaintiffs
are granted per the Contract Rights of the BY-LAWS ARTICLE I. Sec. 2 The members
of the corporation shall consist of the members of the First Baptist Church of Citrus
Park. Sec. 4. The membership present at any regular or special called business meeting
shall constitute a quorum for the conduct of the business of the church, when due notice
has been given. Article II. Section 4. No deed or mortgage of the corporations
property shall be executed except upon resolution adopted at a meeting of the members of
the corporation.

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244.Plaintiff Townsend alleges that due to the fraudulent position, advice, legal actions,
and false misrepresentations as to material facts or knowingly concealment of all or part
of material information from this Plaintiff by first Sheriff Deputy Joe Howlett and Jeffers
intentionally, knowingly, recklessly and negligently violating the Fourth Amendment
rights and BY-LAWS rights of this Plaintiff and misusing his color of uniform
intending to inflict emotional fear and danger of Plaintiffs and others and doing gross
negligent and great indifference to persons, property and the rights of others but acting to
protect his personal interests as a trustee and as a employee of the Hillsborough County
Sheriffs Department and his co-conspirators and that the exposure of the allegations by
Plaintiff Townsend would lead to his loss of employment, pension, and possible
incarceration and loss of reputation and then the continued fraud of Attorney Denny
giving Benefit to Clergy as Defendants in Breach of the Duties of the Contract BYLAWS over the Dutiful Rights of or to this Plaintiff and to the Courts and to the General
Voting Members by not allowing this now newly discovered rights of this Plaintiff
Townsend as still a member being fraudulently concealed by the coercion and fraudulent
and knowingly, intentionally, recklessly and negligently actions to conceal these
Corporations Business Meeting Records just produced on June 12, 2006, that this
Plaintiff as a member of the Corporation was denied his total rights to know of meetings,
attend meetings, speak at meetings, ask questions at meetings, lead as the Chairman of
the LRPC, participate as Awana Commander to protect the interests of the over 200,
children and workers and continue his investigation of the unlawful and violations of the
BY-LAWS of these Officers and to continually questions these OFFICERS of the
Corporation per the BY-LAWS and the Florida Statues to attend, speak, or ask questions

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and vote to protect his membership rights as Granted per the BY-LAWS ARTICLE III.
Section 7, and that the DUE PROCESS Right was violated by the Pastors Schisms I &
II, through frauds to this member, his family and the General Voting Members causing
deceptions and damages.
245.Plaintiff alleges that the January 2003, BUSINESS MEETING MOTION for a full
and complete investigation of the officers of the Corporation was Quashed, fraudulently
manipulated and falsely reported per the April 3, 2000, REPORT OF THE PERSONNEL
COMMITTEE and the testimony of the Trustee Gary Leatherman acting on the Personnel
Committee blocked the Committee from fact finding regarding his self interests of the
reporting of missing accounts and actions to conceal the missing monies just reported to
this Plaintiff in June and July 2006 and reports show the General Voting members still
are deceived about these secret accounts and misappropriation of funds by the Schisms.
246.Plaintiff alleges that as the Long Range Planning Committee Chairman being
unduly removed from this position by the Fraudulent unlawful deceptions and violations
of the BY-LAWS due process that the Corporation of the First Baptist Church and this
Plaintiff have been deceived and suffered damages even incurring DEBT due to the
Coercion and Benefit of Clergy.
247.Plaintiff alleges that all financial debt of the Corporation would not have occurred
but for the Benefit of Clergy and frauds by Grant, Gibbs, Gardner, Scruggs, Gray,
Rolfes, Denny of themselves as individuals and as attorneys and as their or of their Law
Firms ignoring their legal and Constitutional Duties in fraud with the pastors Schism I
& II trying to suppress and omit the truthful disclosure of the truth of this Plaintiff to the
General Voting Members prior to any vote of said members and each Judge, Agent,

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Agency, Department, Corporation and State Office and all Defendants negligently,
recklessly, knowingly and intentionally allowed the damages to these Plaintiffs.
248. Plaintiff allege that therefore all the VOTES of the GENERAL VOTING
MEMBERSHP have been gained by FRAUDULENT BUSINESS PRACTICES AND
OMISSIONS OF TRUTHFUL DISCLOSURE, since September 8, 1999, are invalid and
specifically the votes of the July 2, 2000, REVISED BY-LAWS and the vote or votes of
Mortgages for any building projects were denied by the Coercion of Attorney Denny in
violation of his Fiduciary duty to be truthful to the Clients of the Corporation vested with
rights per the By-laws and that the Actions of attorney Denny and the firm of Dickinson
& Gibbons, did show Benefit to clergy and thereby granted superior rights of speaking
or voting by fraudulent actions and omissions of truthful disclosure in Breach of
Fiduciary Duty by the Corporation Trustees and Officers as Pastors knowing that the
Voting to revise the BY-LAWS was being done to remove rights from the General
Voting Member and give undue privileges to the Corporation Officers.
249.Plaintiff further alleges that Attorney Denny denying the Rights of this Plaintiff
Townsend per the By-Laws, did give BENEFIT TO CLERGY to extend the fraudulent
business practices now revealed by the production of the Corporation Credit card billings
of the uses allegedly approved by Ron Beck but reveal concealed pecuniary gain and
unlawful loans to an officer of the Corporation in violation of the rights of the General
Voting Members to have knowledge of or approve these unrevealed secret accounts.
250.Plaintiff Townsend further alleges that the Firm Of DICKINSON & GIBBONS upon
being duly informed by Plaintiff Townsend conspired and negligently managed and
approved the malfeasance of Attorney Denny to this plaintiff and to the Courts and to the

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General Voting Membership and did not take sufficient or reasonable cause or care to
rightfully undo these actions to properly notify or protect the rights due to these clients
and thereby become vicariously liable by their conduct or lack thereof.
251. Plaintiff Townsend further alleges that Pastors Schisms I & II, jointly conspired with
Attorney Denny and greatly benefited thereby to do financial damage and loss to the
General Voting Members by the deception and damages illegally obtained from the
General Voting Members and this Plaintiff and by fraudulent practices did set in motion
actions of others with malicious intent to fraud and damage this Plaintiff Townsend in the
Publics eye and in his places of Employment and thereby caused loss of employment
and damages.
252.Plaintiff alleges per DEMETREE v. STATE 89 So2d 498 (Fla. 1956) that each
defendant herein intentionally, knowingly, recklessly and negligently violated the rulings
of Judge Palomino in cases 01-15813, and 01-15814, jointly releasing any and all
INJUNCTIONS on November 15, 2001, against this Plaintiff, and even advising
Defendants of violations of the rights of this Plaintiff but by fraud Defendants conspired
and omitted truthful disclosure of the Rulings of the Honorable Judge Palomino and
instead continued and increased the limitations of Plaintiffs RIGHTS TO AND WITH
HIS CHILDREN and Access on Public Property and potential opportunity to restore his
family rights and conveyed fraud in the statements to the Courts as recorded in the FIRST
AFFIRMATIVE DEFENSES with malicious intent to continue and cause additional
fraud and damages to this Plaintiff including the DIVORCE AND INJUNCTIONS
rulings gained by Attorney Scruggs with Judge Timmerman in November 2003, which
still damage this father to not be able to see his children now since November 8, 2002.

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253.Plaintiff therefore alleges that the Corporation and this Plaintiff should be made
whole and debt free including all principle sums and interests of any and all
mortgages but for the losses incurred by the deceptions of the Defendants herein as the
Directive Rights of the General Voting Members to this Chairman of the LRPC before
Plaintiff Townsend was removed September 8, 1999, by the frauds of the pastors
schisms was to proceed with all projects but remain debt free and therefore the demand
of show me the money and the fraudulent attempts and deceptions of the now newly
discovered over $214,000.00 unreported in periods 2nd, 3rd, 4th, Quarterly Business
Meetings and Yearly Business Meeting as required by the BY-LAWS did lead to the
damages incurred. Each Business Meeting shows proof of conspiracy to defraud and by
Plaintiff being banned from each meeting the conspiracy of the Pastors Schism I & II
and with Attorney Denny and his firm these Defendants have prospered thereby at the
suffering of this Plaintiff and the General Voting Members and others.
254.Plaintiff further alleges that each and every one of the representations set forth in the
preceding paragraphs concerned material facts for the reason that Plaintiff would not
have been barred from his family, his children, his Voting Rights, his Positions of
Leadership, his honored reputation, and his employment and future employment(s).
255.Further, Plaintiff and others relied on each and every one of the defendants
representations that resulted in Plaintiffs substantial injury and damages as described
more fully below. In this connection, Plaintiff and Plaintiffs Friends the Minor General
Voting Members further alleges that Defendants purported to have and did have superior
knowledge concerning the subject matter of the transactions described above, and
Plaintiff justifiably relied on Defendant' superior knowledge.

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256.By reason of Plaintiffs reliance on Defendants representations and fraudulent

concealment of material facts and injurious falsehoods as described above, Plaintiff has
been damaged in an amount far in excess of the minimum jurisdictional limits of this
Court. Plaintiff alleges that Plaintiff paid over $10,000.00 in legal fees, costs and court
reporter fees, lost equity in the marital home, lost profits of fair market value in the
marital home in excess of $100,000.00, lost over $60,000.00 of unpaid employment
commissions from SunBelt Equipment Company, lost the opportunity per the State
Attorney to Sue SunBelt for defamation and lost income in a suit in excess of
$1,000,000.00, lost marital rights, lost child society rights and custody, lost an honorable
reputation, lost employment at Kmart as a Level II store manager, lost profit sharing and
lost insurance and lost retirement income and incurred debt in an still unknown amount
and further lost valuable time in a relationship and incurred lack of use of the assets of
the corporation members embezzled by the fraud of the pastors, trustees and adult voting
members as shown and named herein and lost use of the building and expansion program
but for the fraud and fault of negligent and tort intentional, reckless and malfeasance of
officers, alleged trustees, pastors and other general voting members knowingly acting in
negligent breach of the FBCCP BY-LAWS.
257. WHEREFORE, the Plaintiff demands trial by jury on all issues so triable and
prays this Court will award an Immediate WRIT OF PROHIBITION against all
defendants herein stopping their violations of laws and award a judgement and
award damages including:
A. The offset of all FBCCP Corporation indebtedness due to the fraudulent
voting and other actions of the Schism to deceive this Plaintiff and the Minor
General Voting Membership against Defendants, Ronald L. Beck, individually,
Rev. Ronald L. Beck as senior pastor of First Baptist Church of Citrus Park and

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Trustee Geoff Smith, Trustee Joe Howlett, Trustee Gary Leatherman and Trustee
Tim Jeffers and Pastor Herman Meister and Defendant Charles Denny, IV,
individually, Charles Denny, IV. Attorney at Law, A. James Rolfes, Individually
and A. James Rolfes, Attorney at Law and DICKINSON & GIBBONS, P.A., and
each attorney as DOE as Individual and as Attorney and Attorney Firm for
assisting the frauds of Clergy and Alleged trustees and others
B. For General Damages, according to proof.
C. For an award of damages per 57.105(3) for its reasonable expenses incurred
in obtaining an order, which may include attorneys fees and other loss
resulting from the improper delay.
D. For an award of Sanctions against Attorneys per 57.105(4) and 57.105(5).
E. For the Following Special Damages:
F. For approximately $10,000.00 in legal fees, costs, and court reporter fees,
G. Lost of equity in the marital home, lost profits of fair market value in the
marital home in excess of $100,000.00,
H. Lost of over $60,000.00 of unpaid employment commissions from SunBelt
Equipment Company.
I. Loss of the opportunity per the State Attorney to Sue SunBelt for defamation
and lost income in a suit in excess of $1,000,000.00 due to the allegations of
defendants herein during the statue of limitation periods
J. Loss of marital rights,
K. Loss child society rights and custody,
L. For Battery
M. Loss of an honorable reputation,
N. Loss of employment at Kmart as a Level II store manager, and lost profit
sharing and lost insurance and lost retirement income and incurred debt in an
still unknown amount and lost ability to earn future income
O. For costs of suit incurred in this action.
P. For intentional infliction of emotional distress and
Q. For intentional infliction of child custody and visitation in Society. As this
father was and is prohibited from his children as the Injunctions are still being
enforced by frauds.
R. For other and further relief as the court may deem proper.
COUNT XVII
NEGLIGENCE--AGAINST ALL AGENCIES AND DEPARTMENTS AND
STATE ORGANIZATIONS AND CIRCUIT COURTS OF THE THIRTEENTH
CIRCUIT OF THE STATE OF FLORIDA--. THE OFFICE OF THE GOVERNOR
OF THE STATE OF FLORIDA UNDER THE CARE AND SUPERVISION OF JEB
BUSH AND CHARLIE CRIST; THE DEPARTMENT OF THE ATTORNEY
GENERAL FOR THE STATE OF FLORIDA; THE DEPARTMENT OF FINANCIAL
SERVICES; THE DEPARTMENT OF CHILDREN AND FAMILIES OF THE STATE
OF FLORIDA; THE HILLSBOROUGH COUNTY SHERIFFS DEPARTMENT OF
THE STATE OF FLORIDA; THE PINELLAS COUNTY SHERIFFS DEPARTMENT
OF THE STATE OF FLORIDA; THE PASCO COUNTY SHERIFFS DEPARTMENT
OF THE STATE OF FLORIDA; THE CITY OF TAMPA POLICE DEPARTMENT;

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FLORIDA DEPARTMENT OF LAW ENFORCEMENT; MARK A. OBER AS STATE

ATTORNEY OF HILLSBOROUGH COUNTY FLORIDA; CHIEF JUDGE MANUEL
MENENDEZ JR. OF HILLSBOURGH COUNTY FLORIDA CIRCUIT CIVIL; THE
THIRTEENTH CIRCUIT COURTS OF JUDGES RAUL PALOMINO, WAYNE
TIMMERMAN, FRANK GOMEZ, MONICA SIERRA, MARVA CRENSHAW, GREG
HOLDER, RALPH STODDARD,
THE OFFICE OF THE GENERAL COUNSEL TO THE OFFICE OF THE
GOVERNOR OF THE STATE OF FLORIDA; THE JUDICIAL QUALIFICATIONS
COMMISSION OF THE STATE OF FLORIDA; THE FLORIDA BAR; THE STATE
OF FLORIDA; THE CITY OF TAMPA; HILLSBOROUGH COUNTY FLORIDA, OF
THE STATE OF FLORIDA.
257.COMES NOW Plaintiff Randall Townsend sues Defendants THE OFFICE OF
THE GOVERNOR OF THE STATE OF FLORIDA UNDER THE CARE AND
SUPERVISION OF JEB BUSH AND CHARLIE CRIST; THE DEPARTMENT
OF THE ATTORNEY GENERAL FOR THE STATE OF FLORIDA; THE
DEPARTMENT OF FINANCIAL SERVICES; THE DEPARTMENT OF CHILDREN
AND FAMILIES OF THE STATE OF FLORIDA; THE HILLSBOROUGH COUNTY
SHERIFFS DEPARTMENT OF THE STATE OF FLORIDA; THE PINELLAS
COUNTY SHERIFFS DEPARTMENT OF THE STATE OF FLORIDA; THE PASCO
COUNTY SHERIFFS DEPARTMENT OF THE STATE OF FLORIDA; THE CITY
OF TAMPA POLICE DEPARTMENT; FLORIDA DEPARTMENT OF LAW
ENFORCEMENT; MARK A. OBER AS STATE ATTORNEY OF HILLSBOROUGH
COUNTY FLORIDA; CHIEF JUDGE MANUEL MENENDEZ JR. OF
HILLSBOURGH COUNTY FLORIDA CIRCUIT CIVIL; THE COURTS OF THE
THIRTEENTH JUDICIAL CIRCUIT AS STATED HEREIN, THE OFFICE OF THE
GENERAL COUNSEL TO THE OFFICE OF THE GOVERNOR OF THE STATE OF
FLORIDA; THE JUDICIAL QUALIFICATIONS COMMISSION OF THE STATE OF
FLORIDA; THE FLORIDA BAR; THE STATE OF FLORIDA; THE CITY OF

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TAMPA; HILLSBOROUGH COUNTY FLORIDA, OF THE STATE OF FLORIDA.

258.Plaintiff Randall Townsend is an individual at P.O. Box 21, Odessa, Fl, 33556, in
Hillsborough County Florida and Plaintiffs full restate all paragraphs above and
below and incorporate herein this Count granting full rights to Plaintiffs to sue:
259.Defendants are agencies of the State of Florida. Plaintiff presented a claim in writing
to Defendants and the Department of Financial Services, in compliance with Section
768.28 of the Florida Statues, on or about August 2006, and at various previous times
by written and verbal requests for each agency to assist Plaintiff reveal and recover from
all losses as stated herein. Defendants below are being sued for negligent training of
employees and agents performing negligent actions per their alleged duty and thereby per
Respondeat Superior each agency violated Florida Statues 775.03 and gave unlawful
Benefit to Clergy and thereby became joint tortfeasors to and with all unlawful actions
of Defendants as Clergy and deprived this Plaintiff his Constitutional RIGHTS AND
FREEDOMS AND PRACTICE OF HIS RELIGION and BY-LAWS RIGHTS as stated
herein because by NON ACTIONS OF PROTECTIONS OF THIS PLAINTIFF EACH
DEFENDANT ALLOWS FRAUDS BY A PERSON OR GROUP OF PERSONS WHO
ALLEGE TO BE CLERGICAL BUT VIOLATE CRIMINAL, CIVIL LAWS AND
STATUES. Each agent on behalf of the Department or Agency made a deliberate
decision of the government official to deprive a person of life, liberty, or property per
CROCKER v. PLEASANT 778 So2d 978 (Fla. 2001). The Florida Supreme Court
identified the RISK of creating a superior position in MALICKI v. DOE 814 So2d
347 (Fla. SCt. SC01-179) March 14, 2002. ALLEN v. PORT EVERGLADES
AUTHORITY 553 So2d 1341 (Fla. 4th DCA 1989) set the standard at once a public

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entity knows or should have known the danger it created, the entity has the duty to warn
of that danger. This Claim has been verbally denied by each agent on behalf of the
Department or Agency and or was formally denied or is pending as shown below herein:
A. THE OFFICE OF THE GOVERNOR OF THE STATE OF FLORIDA AS UNDER
THE CARE AND SUPERVISION JEB BUSH AND CHARLIE CRIST.
B. THE OFFICE/DEPARTMENT OF THE ATTORNEY GENERAL FOR THE
STATE OF FLORIDA, being sued under Florida Statues 16 and others and verbally
denied any claims.
B. THE DEPARTMENT OF FINANCIAL SERVICES, being sued under Florida
Statues 18 and others and verbally denied any claims.
C. THE DEPARTMENT OF CHILDREN AND FAMILIES OF THE STATE OF
FLORIDA and is a department of the executive branch of the government of the
State of Florida created by Florida Statues Section 20.19 and others and verbally
denied any claims.
D. THE HILLSBOROUGH COUNTY SHERIFFS DEPARTMENT OF THE STATE
OF FLORIDA, being sued under Florida Statues 30 and others and verbally denied
any claims.
E. THE PINELLAS COUNTY SHERIFFS DEPARTMENT OF THE STATE OF
FLORIDA being sued under Florida Statues 30 and others and verbally and in
writing denied any claims.
F. THE PASCO COUNTY SHERIFFS DEPARTMENT OF THE STATE OF
FLORIDA, being sued under Florida Statues 30 and others and verbally denied
any claims.

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G. THE CITY OF TAMPA POLICE DEPARTMENT, being sued under Florida Statues
166.021 and others and verbally denied any claims.
H. FLORIDA DEPARTMENT OF LAW ENFORCEMENT, being sued under Florida
Statues 20.201 and others and verbally denied any claims.
I.

MARK A. OBER AS STATE ATTORNEY OF HILLSBOROUGH COUNTY

FLORIDA, being sued under Florida Statues 16 and others and verbally denied
any claims.

J. CHIEF JUDGE MANUEL MENENDEZ JR. OF HILLSBOURGH COUNTY

FLORIDA CIRCUIT CIVIL, AND CIRCUIT CIVIL COURT JUDGES RAUL
PALOMINO, WAYNE TIMMERMAN, FRANK GOMEZ, MONICA SIERRA,
MARVA CRENSHAW, GREG HOLDER, RALPH STODDARD,
ARE being sued under Florida Statues 26 and others.
K. RAQUEL A. RODRIQUEZ AS GENERAL COUNSEL TO THE OFFICE OF THE
GOVERNOR OF THE STATE OF FLORIDA, being sued under Florida Statues 16
and others and verbally and in writing denied any claims.
L. THE JUDICIAL QUALIFICATIONS COMMISSION OF THE STATE OF
FLORIDA, being sued under Florida Statues 25 and others and verbally and in
writing denied any claims.
M. THE FLORIDA BAR, being sued under Florida Statues 25 and others and verbally
denied any claims and reportedly by Ms. Lieman did throw in the trash the
complaint received and signed for by Jane Christy via certified mail on November 21,
2005. Complaint was filed per the directives of Ted Littlewood of the FLA. Bar.
N. THE STATE OF FLORIDA, being sued under Florida Statues 2, 6, and others and

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verbally and in writing denied any claims.

O. THE CITY OF TAMPA, is a municipal corporation in the State of Florida and may
be sued as such pursuant to Florida Statues Section 166.021 and others and 125.15.
Claim pending.
P. HILLSBOROUGH COUNTY FLORIDA, OF THE STATE OF FLORIDA, is a
political subdivision of the State of Florida and may be sued as such pursuant to
Florida Statues Section 125.15. Claim Pending.
GENERAL ALLEGATIONS
260. Plaintiff allege all previous allegations and paragraphs stated above herein.
261.Plaintiff alleges that by the appearance of Sheriff Deputy Howlett and Sheriff Deputy
Tim Jeffers Color of Uniform and intentional use of the Color of Uniform to serve
their own pecuniary purpose wearing the Uniform of a Deputy both on duty and off
duty to the General Public and General Voting Member, the Agencies and Departments
herein have failed to warn this Plaintiff and the Minor General Voting Members of these
appearing to be security guards who at will place their personal interests over the rights
of the Corporation they allegedly serve and the Minor General Voting Members of this
Corporation whose members must be fully informed and allowed to vote after being fully
informed but said deputies as acting allegedly lawfully per the BY-LAWS as properly
elected and voted to serve as trustees by the BY-LAWS process As of ARTICLE II, as
these unlawfully appointed TRUSTEES have knowingly concealed breach of duty of
themselves and of the clergy and of other officers, law enforcement, employees and
others to the Corporation, General Voting Member, the general public and to the BADGE
they swore to protect under the Constitution of the United States, the State of Florida or

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to their Department or to the FBCCP BY-LAWS they allege to protect. Per PITTS v.
METROPOLITAN DADE COUNTY 374 So2d (Fla. 3 DCA 1978) and CUTLER v.
CITY OF JACKSONVILLE BEACH 489 So2d 126 (Fla. 1st DCA 1986) a false
security and lack of risk is presented by the coercion of Deputies Howlett and Jeffers
and thus a veil of frauds and deceptions and damages resulting to this Plaintiff, the
FBCCP Corporation and the General Voting Members. These agencies refusing to
supervise or investigate their own required this action to enjoin these Defendants as
Joint tortfeasors due to the failure to train, supervise, control and warn to prevent the
Risk of Operational decisions made by the coercion of these Deputies and their intent
for personal protection and private gain thereby and negligence and breach of duties and
damages caused from the deception and resulting damages. Further, The failure of the
Judicial Qualification Commission, The Florida Bar, The FDLE, The Attorney General
and the State Attorney of Hillsborough County by failing the Duty to train, manage,
supervise and investigate and prosecute violates their duty per the Florida States and
Federal Statues as stated in all paragraphs in this Complaint and has allowed the
violations of laws as stated herein by attorneys, judges and law enforcement.
262.PER U.S. v. Leisure, C.A.8 (MO.) 1988, 844 F.2d 1347, stating,
It is only necessary for defendant to have believed that witness might give
information to federal officials, and to have prevented that communication, to violate
statue governing obstruction of criminal investigations.
263.Plaintiff has met his duty to warn the Hillsborough County Sheriffs Department
Deputies of D-#3 District Office to multiple Sergeants and Detectives since September
1999, and to FDLE, the State Attorney, the Attorney Generals Office, Courts and other
agencies at multiple other times and these Agencies continue(d) the Negligent hiring and
retention and supervision of these Howlett, Jeffers, Smoak, Corbin, Sanz, Core, and all

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judges and attorneys and law enforcement and state officers/agents and others
as stated herein acting to violate the rights of this Plaintiff and prevent this plaintiff from
seeing his children now partly since October 20, 1999, and permanently now since
November 8, 2002, by their actions to give benefit to clergy and prevented Plaintiff
Townsend from his civil rights of religion, speech and as a father. Each Agency is
Vicariously Liable to this Plaintiff for the Risk they allows these agents to perform by
acts of deceptions and frauds. Per DEPARTMENT OF HEALTH AND REHAB.
SERV. V. YAMUNI 529 So2d 258 (Fla. 1988) each agency is responsible and liable
for negligence in the investigation and protection of an abused child from further child
abuse. Plaintiff alleges the statutory duty of care to protect a child from further abuse
once it has been notified that abuse has occurred, Sovereign Immunity is waived for a
negligent breach of that duty. And that all agencies, law enforcement, courts and judges
and attorneys have the duty of care to protect a child. The Principles of the TORT
CLAIMS ACT not allegedly applying to Agencies for Operational Decisions then is in
Violation of 1863 and coercion when all agents in collusion refuse to act.
264. Further per Florida Statue 39.205, Failure to report or act on violations of law is a
violation and breach of duty and per the August 2004, exchange in the hearing
between Attorney Stanford Solomon and Judge Gomez as to the responsibilities of
attorneys and judges, once your in your in and Judge Gomez agreed that the
attorneys and courts had a duty to report and represent the full issues of the cases as
shown herein wherein therefore Judge Gomez did recuse himself, however having
already ruled in these matters and concealed these matters did incriminate himself by
the exparte actions with Attorney Scruggs as stated in the Transcripts in the court of

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Judge Gomez and thereby continuing the veil of deceptions continues the frauds as
other courts (Hillsborough Circuit Civil) judges (Sierra, Timmerman, Crenshaw,
Palomino, Holder, Stoddard, Arnold, Menendez Jr.) and Appeals Court Second
District Judges Villanti, Wallace and Larose per the ORDER of the Second District
Court in Appeals Case TOWNSEND v. Scruggs et al. 2D06-2811 to continue to do
concealment of torts and frauds and knowingly and recklessly allowing Benefit of
Clergy and actions of the employee Karen Harrod Townsend and deputies Howlett
and Jeffers and others under the direct and indirect responsibility of attorneys Denny,
Scruggs and Gray to still prevent the rights and continue the damages of plaintiffs as
stated herein by the induced fraudulent INJUNCTIONS and omissions of truthful
disclosure carried forth by attorneys Denny, Scruggs, Gray, Turmel, Rolfes and the
Judges so stated of the Thirteenth Circuit Court Timmerman, Gomez, Sierra, Holder,
Stoddard, Crenshaw even after Plaintiff Townsend has from October 2003, to present
filed over FIFTY MOTIONS, PETITIONS and COMPLAINTS showing these
Injunctions and Court orders were gained by frauds of Alleged Clergy Beck and
frauds of Howlett, the former wife Karen Harrod Townsend and the intentional
extrinsic fraud of Attorney Scruggs, Gray, and Denny and others and further to
continue to allow the weekly frauds and embezzlement and extortion of rights of
these Plaintiffs as members of the Corporation being intentionally misinformed of
breach of duties and frauds of the alleged pastors and alleged trustees and Grant as
the Registered Agent and Denny and Rolfes and Gibbs and Gardner allegedly
honorably serving the interests of the voting members but for the lack of intervention
of these courts the injustice and frauds continue in violation of Florida Statues 617.

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265.This is an action in negligence, with Plaintiff seeking damages in excess of the

jurisdictional minimum of this Honorable Court.
266.At approximately September 8, 1999, Plaintiff was per his duty to the Corporation
of the First Baptist Church of Citrus Park and the General Voting Member and to his
children was required to confront Officers of the Corporation for various actions alleged
as fraud, negligence, breach of duty. Plaintiff at the Show me the money demand
meeting became the victim of retribution by Sheriff Deputy Joe Howlett and Sheriff
Deputy Tim Jeffers using their positions as COLOR OF UNIFORM sheriff deputies
and their dual role as alleged Officers of FBCCP to allege that Plaintiff had become
violent, abusive, potentially dangerous, suffering from a stress related
breakdown, a liar and leading to the allegations of molesting his own children and
marital abuse. Deputies Howlett and Jeffers and Smoak, at times did unlawful car
chases and unlawful stops using their Department issued vehicles, and created scenes
throughout the community, the church, the private Christian school, at the mall, in the
Court of Judge Raul Palomino and told fraud to Curtis Baughman of Victims Assistance,
and at other places, to create the injurious falsehoods and conceal the frauds of Deputies
Howlett, Jeffers, Smoak, Corbin and others as officers, Kaeras to create fear and
infliction of emotional distress to persons and to this plaintiff and plaintiffs family and
children to protect the Deputies unlawful acts to Benefit Clergy to continue violations
of this Plaintiff, his children, the FBCCP and CPCS Minors, the Corporation and others.
267.As a direct and proximate result of this activity, Plaintiff was abused against his
FOURTH AMENDMENT RIGHTS, Abused in the public eye, incurred unlawful
interference with and of lost Child Custody and Society privileges, loss of employment,

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loss of future earning capacity due to abused reputation and defamation, loss of medical,
dental insurance and retirement benefits, loss of his home, loss of consortium, loss of
emotional and physical and mental well being and incurred financial debt and financial
loss and incurred multiple lawsuits and is still severely injured as more particularly
described throughout in this Complaint and all facts and damages are incorporated herein.
268.Plaintiff alleges that each agency is directly and proximately the cause of Plaintiffs
injuries by the failure and breach of duty to train, supervise, investigate, advise of risk,
protect from risk, warn of new dangers, despite being advised of criminal activities by
these Deputies since 1999 and each agency has had sufficient warning of the existence of
the hazardous conditions and of numerous similar incidents that had been caused by the
breach of duties at multiple times by these alleged now TRUSTEES of the FBCCP
Corporation and nonetheless the Department, and Agencies herein failed to act. Florida
Statues required the office of the Attorney General and STATE LAW ENFORCMENT to
supervise, investigate and enforce the Corporations operating under Florida Statue 617.
269. This action is maintained according to the principles of law as stated in this
Complaint, a governmental entity is not protected by sovereign immunity when it is
performing such operational level functions as proper duty of officers and agents to obey
all criminal and civil laws at all times rather than use the Color of Uniform in the
operation of a breach of duties as shown above herein and Defendants cannot claim
sovereign immunity.
270.As a direct and proximate result of Defendants actions and omissions, as alleged
and itemized above, Plaintiff Suffered and Continues to Suffer all losses as stated herein.
Plaintiffs injuries are so severe and so complicated in nature that Plaintiffs recovery will

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be extensive, and Plaintiffs has suffered and will continue to suffer great mental anxiety
and battery and distress in addition to severe and chronic physical pain and suffering, for
the indefinite future.
271. Wherefore, Plaintiff demands judgement as follows:
A. For General Damages.
B. For Nominal Damages
C. For Punitive Damages
D. For All Special Damages as proved herein in the amount still to be determined upon
discovery but known to exceed all jurisdictional minimums.
E. For costs of suit incurred in this action.
F. For other and further relief as the Court may deem proper.
COUNT XVIII
INTERFERENCE WITH EMPLOYER-EMPLOYEE RELATIONSHIP
RESULTING IN DISCHARGE OF EMPLOYEE
AGAINST ALL DEFENDANTS
Plaintiff Randall Townsend alleges:
272.Plaintiff is a resident of Hillsborough, Sarasota and Pinellas County, Florida at
times material hereto and restates herein all paragraphs above and below herein.
273.Defendant Kmart Management Corporation of 3100 West Big Beaver Road, Troy,
Michigan, 48084, and now doing business as SEARS HOLDING COMPANY with a
REGIONAL OFFICE LOCATION AT 1602 West Brandon Blvd, Brandon, Florida.
274.All Defendants as stated in paragraphs 23-55 and 57 are incorporated herein.
275.This is an action in excess of the jurisdictional minimum and limits of the court.
276.On or about December 16, 1999, Plaintiff Townsend entered into a employment
contract whereby Plaintiff was hired as Defendant Kmarts employee. Specifically,
Plaintiff was hired as Pantry Manager and at various times hereto did receive
advancement and promotions resulting in the position of Level II Store Manager
until Plaintiff Townsend was terminated on or about October 6, 2005.

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277.Each Defendant through verbal communications, letters, affidavits, court testimony

or by personal encounters and by joint tortfeasor actions knew and should have
known of Plaintiff Townsends employment and in the Affidavit of Ron Beck of
October 31, 2001, Defendant Beck states in the Affidavit as a record of public
document that Plaintiff Townsend is employed at KMART and at various times
Defendants visited or shopped at Plaintiff Townsends place of employment.
277.Each Defendant by allowing benefit of clergy who by fraud and omissions of
truthful disclosure to conceal and conspire to continue frauds and other criminal
acts alleging Plaintiff Townsend was dangerous, a liar, suffering from a
mental and stress related breakdown, a molester, an abuser or of any improper
character to paint this Plaintiff in a bad public eye did and does contribute to cause
slander and disgrace of Plaintiff Townsend as unbecoming of a Store Manager
expected quality and character in the public eye. Such painting Plaintiff Townsend
in a bad public eye by fraudulent means induced others to fear, use for their own
interests and abuse this Plaintiff to serve their own interests which lead to false
accusations, slander and false grounds for termination or discharge from
employment that if the conduct alleged had come from clergy or attorneys or
judges it must be true and show as a pattern of character to further damage those
under the management of Plaintiff Townsend.
278.Each Defendant did knowingly, willfully, intentionally and recklessly intend to
willfully and wantonly injure or suppress maliciously Plaintiff Townsend and
thereby induce Defendant Kmart /Sears to discharge Plaintiff Townsend and is joint
tortfeasor to unlawfully giving benefit to clergy using false allegations to conceal

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criminal actions of clergy as stated herein.

279.Plaintiff Townsend was additionally retaliated at by Kmart/Sears Management due
to the religious beliefs of Plaintiff Townsend to not commit frauds or lies or
violations of Federal and State and Local laws as Management ordered at multiple
times Plaintiff Townsend to knowingly violate a Company policy, Federal and State
and Local Law and plaintiff alleges his discharge was to conspire to conceal his
intent to report illegal acts of Dan Gentile, Shane Pearson, Dr. Linda RoweCampbell and Rick Gould and others and Plaintiff Townsend was subjected to
racial harassment by actions of employees of Kmart/Sears.
280.As a result of the discharge of employment Plaintiff Townsend has been slandered,
humiliated, emotionally suffered, mentally anguished and been deprived of gainful
employment in the amount of his 2005, salary of $63,500.00 annually and of all lost
benefits to insurance, profit sharing and retirement and potential for bonus and
potential for advancement and increase salary and been deprived of gainful
employment at other equal or comparable or alternate employers due to the painting
of a bad public image of Plaintiff by all defendants fraud and omissions of truthful
disclosure.
281.WHEREFORE, Plaintiff demands judgment as follows:
A. For General Damages.
B. For special damages including lost earnings in the amount of $63,500.00 per year
until Plaintiff is gainfully compensated.
C. For loss of earning capacity and battery
D. For Punitive Damages since the facts arise to the level of actual malice, willful
and wanton intentional interference sought to injure Plaintiff as retaliations
against Plaintiff as shown in all paragraphs throughout the Complaint herein.
E. For any and all other further relief as the Court may deem proper.

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COUNT XIX
CONSPIRACY TO INTERFERE WITH LIVEHOOD
AGAINST ALL DEFENDANTS
282.Plaintiffs reallege all paragraphs all preliminary allegations and subsequent
allegations as stated herein and incorporate these allegations herein by reference.
283.Plaintiff alleges that as a proximate and direct cause of the intentional, knowing and
reckless and negligence by Defendants to not properly represent and intentionally inform
as a reasonable care for services as an attorney not using all available causes of actions
and advocating the rights of Plaintiff Townsend that Plaintiff Townsend was abused and
presented as an unfit candidate of the employer KMART as a Level II store manager and
was discharged as a result of allegations against this Plaintiff Townsend that Defendants
had a reasonable duty they ignored and did damage to cause fear of the employer to stop
Plaintiff Townsend from employment and that this interference was damaging to the
advantageous business relationship that Plaintiff Townsend had with his employer and
future employers as Defendants conspired to conceal all the allegations known by
Defendants as false that were causing damage and was leading to additional allegations
that would cause additional fears and damages to the advantageous relationship by
prolonged and unsettled legal allegations not clearing the slandered reputation of Plaintiff
Townsend.
284.As a proximate and direct cause of Defendant interference to Plaintiffs advantageous
business relationships, Plaintiff has been unemployed since October 2005, and has yet to
find equal employment after many attempts to regain employment due to the lack of
reasonable and proximate care expected by Defendants to protect the reputation and
allegations made against Plaintiff Townsend deemed to be fit for employment had these

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allegations been proved untrue as stated had Defendant not conspired with Attorney
Scruggs and Karen Harrod Townsend and others not yet fully known in their true names
in this matter as Defendants designated as Defendants DOE, to withhold proper care for
her client as Plaintiff believes and was informed based on information and belief alleges
that each of these defendants negligently or otherwise legally responsible for the events
and happenings referred to in this complaint and negligently or otherwise unlawfully
caused the injuries and damages to plaintiff Townsend alleged in this Complaint as Karen
Harrod Townsend admitted in Affidavits that she contacted the employer of Plaintiff
Townsend on numerous occasions in violation of the Final Divorce Judgement,
Injunctions that Attorney Scruggs and Gray was to reverse and or clarify in the Appeal.
285.As a direct and proximate result of Defendants actions and interference with
Plaintiffs advantageous business relationships Plaintiff has experienced termination,
mental and physical duress such as sleeplessness, tenseness, nervousness, weight loss and
other symptoms related to this stress and infliction of emotional distress, debt and
additional loss of time with Plaintiffs children as Karen Harrod Townsend and her
maternal family continue to use economic reasons to desecrate the reputation of Plaintiff
Townsend and these acts were willfully and maliciously done to destroy the reputation of
Plaintiff Townsend by the conspiracy and frauds and therefore constitute a claim for
Punitive Damages and other recovery of loss of employment as Plaintiff Townsend lost
his $63,500.00 a year salary and bonus opportunity paying job and lost 30 year excellent
reputation.
286.WHEREFORE PLAINTIFF REQUESTS ALL RELIEF FOR DAMAGES AS
STATED BELOW HEREIN AND ANY OTHER RELIEF AS THIS COURT DEEMS

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PROPER.
COUNT XX
INFLICTION OF EMOTIONAL DURESS-AGAINST ALL DEFENDANTS
287. Plaintiffs reallege all paragraphs all preliminary allegations and subsequent
allegations as stated herein and incorporate these allegations herein by reference in
this count.
288.Plaintiffs reallege all conditions precedent have been performed or have occurred.
289.Plaintiffs allege Defendants conduct as stated throughout herein allowed Karen
Harrod Townsend and Ronald Beck and others as stated herein to state to fellow
members at FBCCP, fellow co-workers at CPCS and pastors, doctors and attorneys
and Judges of allegations against Plaintiff Townsend as husband and father just to
conceal her malfeasance and acts of tort and abuse on these Plaintiffs herein was
extreme and outrageous for any citizen and even more so extreme and outrageous for
a mother who professed to be of a higher standard as an alleged Christian mother and
Christian School teacher allegedly living per the Code of Conduct displayed in her
employment contract of CPCS as a Christian School Teacher.(Karen Harrod
Townsend hereinafter as Harrod and Ron Beck as BECK and Herman Meister.
290.Plaintiffs allege Defendants allowed Harrods conduct as intentional, reckless and
negligent and with malice and intent to fraud and omit truthful disclosure to cause
emotional distress as extortion on her just and innocent husband and father of the
marital children and a respected leader in the community and that Defendants
knew or should have known that such emotional distress and pain would follow from
Harrods actions starting in the home in the 1990s and through these current times
as that Harrod still continues her frauds and extortion and abusive conduct as

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stated herein keeping this father from a clean and free reputation in the public eye
and having freedom in his relationships with the marital children as NEXT
FRIENDS as stated herein and that Harrod intentionally did take away the parental
rights of this father in 1999 through current by Harrods frauds and abusive
omissions of truthful disclosure and other malfeasance acts as stated herein keeping
this father from the many years of lost time with these marital children this father
sought and still seeks to protect from the malfeasance acts of this alleged honorable
mother and her co conspirators.
291.Plaintiff alleges that Florida Statues s. 768.35 Continuing Domestic Violence,
states A victim as defined in s. 741.28, who has suffered repeated physical or
psychological injuries over an extended period of time as a result of continuing
domestic violence has cause of action against perpetrator responsible for the
violence and Plaintiff alleges that the acts of Harrod were intentional and
abusive acts intended to cause this emotional distress and violence towards this
Plaintiff and these children as NEXT FRIENDS from these intentional actions by
Harrod to destroy the loving home setting just to conceal her acts as stated herein.
292.The true facts is that the transcripts in exhibits herein from the court of Judge
Palomino prove this Plaintiff as reported herein has been truthful, loving, caring,
honest and has not done one act of alleged violent or physically abusive conduct
towards any person but Harrods and others allegations have been pure fraud in an
attempt to harm and abuse and conceal malfeasance of her and her co workers and co
conspirators as this Harrod, in December 2005, in MOTIONS to Judge Holder in
case 05-9605 attempts to recant her allegations began in 1996, and continues with

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the help and assistance and knowledge of herself, co conspirators as stated herein.
293.Defendants, and each of them, knew and have known the representations concerning
the integrity, character, conduct and public image and public actions of this Plaintiff
Townsend that the representations were false; and defendants, and each of them,
made the representations with the intent to induce Plaintiff and others as stated herein
to rely on these representations and do conduct as stated herein to conceal defendant
and her co conspirators actions and procure the Injunction by Judge Timmerman still
to harm these Plaintiffs herein and continue the frauds of defendants and her co
conspirators.
294.Defendants and each of them, knew when they presented the false testimony and
accusations and allegations against this Plaintiff as stated herein and in each exhibit
that these allegations by Defendants and her co conspirators was fraud and presented
to induce abuse and humiliation against Plaintiff Townsend with the intent to induce
others as stated herein and specifically and other points incorporated fully herein to
act to humiliate and abuse this Plaintiff and to thus conceal the actions of defendants
and the co conspirators as stated specifically and incorporated fully herein.
295.Plaintiffs, in fact, did believe the representations of Harrod and others claims
and did in fact seek professional counseling and advice from Doctors, pastors,
professional authors, lawyers, judges and multiple advisors in attempts to refute and
understand charges by Harrod and Beck as proof of truthful facts and to correct the
light of the public eyes as to the truthful facts as alleged herein. Plaintiffs have not
been able to get relief or yet know the full amount of defamation and destruction of
the public image of Plaintiffs and financial damages and losses from the frauds and

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misrepresentations and omissions of truthful disclosure by Defendants to each person

as stated herein and other letters and proof had Plaintiffs and others not relied
on the truthfulness of the alleged allegations by Defendants and each of them.
296.As a proximate result of the false and fraudulent misrepresentations and actions of
the defendants, Plaintiffs have incurred expenses, humiliations and abuse to their
persons and reputations in the public eye and this would not have been required had
the representations of and reports of and presented information of defendants been
true and accurate.
297.As a further proximate result of the false and fraudulent misrepresentations and
actions as reported herein of the defendants, plaintiffs incurred valuable lost time and
relationships to each other as father and children to parent father and expenses for the
litigation and satisfaction of the injunctions and orders gained by the frauds of
defendants not being truthful causing harm to these plaintiffs
298.In making the representations and performing the acts alleged, defendants and each
of them, acted intentionally with fraud and malice; and plaintiffs are entitled to
punitive damages in the sum yet fully unknown to the full extent the laws of Florida
allow to the maximum of these Florida Statues violated by Defendants but estimated
at $2,000,000.00 or more.
COUNT XXI
NEGLIGENCE AND ABUSE OF CHILDREN and REQUEST FOR
IMMEDIATE INJUNCTION- AGAINST KAREN HARROD; STEVEN
HARROD; NORMA HARROD; DONALD HARROD
299. Plaintiffs reallege all paragraphs all preliminary allegations and subsequent
allegations as stated herein and incorporate these allegations herein by reference.
300.Plaintiffs reallege all conditions precedent have been performed or have occurred.

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301.Plaintiffs allege that Defendants herein this count and as her co- conspirators
HARRODS, (as Karen, Steve, Norma, Don) did intentionally conspire and fraud
to jointly abuse and harm Plaintiff and Next Friends of Plaintiff these Children
J.D.T. and J.G.T and violate these marital children as evidence in these exhibits
herein of doctors reports and in the transcripts testimony of the mother and others
in violation of s. 827.04, Florida Statues, ABUSE OF CHILDREN, which states,
Whoever, willfully or by culpable negligence, deprives a child of, or allows a
child to be deprived of,, or medical treatment, or who knowingly or by culpable
negligence, inflicts or permits the infliction of physical or mental injury to a child
and in so doing causes great bodily harm shall be guilty of a felony of the third
degree, punishable as provided in s. 775. 082, s.775.083, or s. 775.084. And per
s. 827.05 Florida Statues, Negligent treatment of children, which states,
Whoever, though financially able, negligently deprives a child or allows a child
to be deprived of,, or medical treatment or permits a child to live in an
environment, which such deprivation or environment causes the childs physical
or emotional health to be significantly impaired or to be in danger of being
significantly impaired shall be guilty of a misdemeanor of the second degree,
punishable as provided in s. 775.082, s.775.083, or s. 775. 084.by doing the acts
against the will of this paternal father as alleged herein and by these specific acts:
A. Of harming these children physically and mentally and emotionally by the
verbal and physical conduct of FBCCP, CPCS, and Karen Harrod Townsend
advised by Attorney Scruggs the August 1, 2000, Certified Letter to Dr. Lon
Lynn demanding by this father that these patients be treated as directed in this

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letter however resulted in deprived and below standard of care as reported by

Dr. Santiago Hoyos and other professionals willing to testify to the courts.
B. Of harming these children mentally and emotionally by repeatedly verbally
abusing this father and these children
C. Of harming these children by keeping them in an hostile school and church
environment at CPCS and FBCCP, being subjected to daily verbal and
emotional embarrassment and abuse by fellow students, parents, lawyers,
administration, pastors and church members and sheriff deputies due to the
frauds told by Defendants about the actions and alleged actions of Plaintiff
Townsend and by the intentional abusive actions reported herein by Pastors
and Sheriff Deputies as Church Leadership practicing extortion and abuse on
these children as extortion to get this Plaintiff Townsend as Father and Church
Leader to drop his allegations of money fraud and building plan fraud and
other tort acts of abusive and outrageous conduct by these in leadership
D. Of harming these children by giving to these children medical prescription
drugs gained by fraud of maternal grandmother Norma Harrod to her medical
doctors and then mailed and then administered by Harrod, the
mother to these children.
E. Of harming these children by administering to these children at times larger
that normal doses of Over the Counter Medicines to these minor children.
F. Of harming these children removing them from the medical supervision of the
honorable Dr. Santiago Hoyos, to the abusive and below standard care of Dr.
Lon Lynn, in order to conspire and abuse these children from knowing these

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extortion acts done by the membership of FBCCP and CPCS and these
others as co-conspirators on these minor children
G. Of harming these children by omitting truthful disclosure and concealing the
mental, physical and emotional abusive conduct done by Harrod and
members of FBCCP and CPCS and pastors, counselors, teachers and Dr. Lon
Lynn, as reported herein by this Plaintiff Townsend as concerned and loving
father herein to Pastors, Doctors, Attorneys, Judges and Curtis Baughman of
Victims Assistance.
H. Of abusive anger and rage by this Mother Karen Harrod and Donald
Harrod as witnessed by Attorneys Heather Gray and Stanford Solomon
outside the court of Judge Gomez on March 29, 2004, and refusing to allow
this father to contact and intervene in the care of these minor children.
302.Plaintiff alleges this Court should immediately intervene and demand this Plaintiff as
NEXT FRIEND be advised of all medical doctors names and addresses and phone
numbers of the J.D.T and J.G.T so this father can properly inform these medical
professionals of all conditions precedent regarding J.D.T. and J.G.T as conditions
past prove these Defendants have and are intentionally abusing these NEXT
FRIENDS to suppress the acts done to these children as reported herein.
303.

Plaintiff Townsend herein as NEXT FRIEND alleges that these current medical
physical, mental and emotional conditions of J.D.T. and J.G.T are from acts from
all Defendants herein and can be confirmed by competent medical professionals
after testimony by this Plaintiff Father who defendants have sought to suppress
from the medical treatment of these children now since 1999, when these children

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were removed from the medical care of Dr. Santiago Hoyos, who knew and
still respects the position of this concerned and loving, Plaintiff Father.
304. Plaintiff alleges this Court should Order that a deposition and or consultation of
J.D.T and J.G.T be done by Plaintiff Townsend, the father and as NEXT
FRIEND or with Plaintiff Townsend allowed to be present to determine the care
and safety of J.D.T and J.G.T.
305. Plaintiff alleges this Court should order payment and restitution per all available
Florida Statues, for these NEXT FRIEND Children from these defendants for
all necessary future medical expenses and medical care needed for mental and
emotional counseling and award any and all special damages award for the
treatment of these medical issues caused by these Defendants to these children.
COUNT XXII
(COMMON LAW FRAUD)- AGAINST ALL DEFENDANTS TO JUDGE
RAUL PALOMINO AND JUDGE WAYNE TIMMERMAN AND JUDGE
JAMES ARNOLD AND JUDGE MARVA CRENSHAW AND JUDGE
GREG HOLDER AND JUDGE JAMES BARTON AND JUDGE RALPH
STODDARD AND JUDGE MONICA SIERRA AND JUDGE FRANK
GOMEZ AND TO THE SECOND DISTRICT COURT OF APPEALS and
CONCEALMENT OF FRAUD ON THE COURTS
306.Plaintiffs reallege all paragraphs all preliminary allegations and subsequent
allegations as stated herein and incorporate these allegations herein by reference.
Plaintiffs reallege all conditions precedent have been performed or have occurred.
307.At all times mentioned in this Complaint, Karen Harrod, was the wife or
former wife of Plaintiff Townsend and mother of Plaintiffs J.D.T and J.G.T and at
all times mentioned in this Complaint, was acting with and for her co conspirators in
the actions and in making the representations alleged in this Complaint and with their

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knowledge and consent including attorneys and judges and agents as stated herein.
308.On or about 2003, through current times herein the State of Florida and Hillsborough
County, Plaintiff Randall Townsend both verbally and in writing within his
knowledge of facts at that time did attempt to truthfully advise Defendants truthful
facts and allegations with out admission of truthful disclosure all matters as reported
herein to provide per the duty of a father, husband and truthful citizen as stated the
facts and allegations herein.
309.On or about 2003, through current times with proof as shown herein by the use of the
injunctions gained by Harrod and BECK by frauds still humiliates and abuses and
misrepresents the need and frauds used by the injunction from the order of Judge
Timmerman herein the State of Florida and Hillsborough and Santa Rosa Counties,
to abuse and harass and humiliate Plaintiffs and Defendants falsely and knowingly
and fraudulently stated to Plaintiffs and others as stated herein that matters and
issues as stated herein was as per Defendants allegations as truthful and not
omissions of truthful disclosures as to the character, integrity, mental status, factual
status and of a caring and loving husband, father and peaceful citizen but defendants
did fraud to conceal and promote the alleged status of Harrod as victims being
afraid of alleged misconduct and abuse by Plaintiff Townsend as stated herein, as
and for repeated attempts to defame reputation of Plaintiff in the public eye.
310.On or about 1996, through current times herein the State of Florida, Harrod and Beck
presented Plaintiff in disgrace and unfavorable and untruthful positions and light in
the public eye and to persons as stated herein this Complaint in all points herein and
Specifically to each action stated herein. The reports of statements by Harrod are

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recorded herein in affidavits, transcripts, letters, Motions, and INJUNCTIONS, as

noted for these records herein and additional statements will and can be provided
upon the approval by this court in trial to allow discovery as has been prevented by
Defendants and attorneys and judges as stated herein by the Orders, Injunctions and
Extrinsic fraud as reported herein or CASES 05-911, 05-9605, and 02-03812.
311.The true facts is that this Plaintiff as reported herein has been truthful, loving, caring,
honest and has not done one act of alleged violent or physically abusive conduct
towards any person but Defendants allegations have been pure fraud in an attempt to
harm and abuse and conceal malfeasance of her and her co defendants and co
conspirators as Harrod as employee and mother, in December 2005, in MOTIONS to
the court attempts to recant Harrods allegations began in 1996, and continues with
the help and assistance and knowledge of herself, co conspirators and Defendants
as stated herein and these other cases as Plaintiff Townsend requests the Court take
Judicial notice of all cases.
312..Defendants, and each of them, knew when they made the representations concerning
the integrity, character, conduct and public image and public actions of this Plaintiff
Townsend that the representations were false; and defendants, and each of them,
made the representations with the intent to induce Plaintiff and others as stated herein
to rely on these representations and do conduct as stated herein to conceal defendant
and her co conspirators actions and procure the Injunction by Judge Timmerman still
to harm these Plaintiffs herein and continue the frauds of defendants and her co
conspirators and or to the court of Judge Arnold and Judge Barton promote known
fraud with regards to the Building and Growth Plan on moving the FBCCP

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Corporation entirely to the new property at 18105 North Gunn Highway as

specifically said by Plaintiff Townsend in 1997, would not happen but Clergy and
alleged trustees and the estranged wife did fraud, omissions of truthful disclosure and
conspired to fraud to promote these frauds and conceal all other violation of laws as
reported herein knowingly with the help of all hired guns by these attorneys and
judges.
313. Defendants and each of them, knew when they presented the false testimony and
accusations and allegations against this Plaintiff as stated herein and in each exhibit
that these allegations by Defendants and her co conspirators was fraud and presented
to induce abuse and humiliation against Plaintiff Townsend with the intent to induce
others as stated in actions specifically and other points incorporated fully herein to
act to humiliate and abuse this Plaintiff and to thus conceal the actions of defendants
and the co conspirators as stated specifically and incorporated fully herein.
314. Harrod with others did frauds and misrepresentation in the testimony as stated above
and incorporated herein intentionally to induce Judge Timmerman to anger and to
inflict the wrath of Judge Timmerman on Plaintiff and to induce the full actions
alleged above herein to get the injunction and the order of financial gain in
alimony and control of the marital home and to induce Judge Timmerman to see
alleged Harrod and the marital children as victims at the alleged evil
hand of this Plaintiff and or that Attorney Scruggs was caused to not be prepared
by the hand of alleged acts of this Plaintiff now proved as fraud of Scruggs.
315. Plaintiffs, in fact, did believe the representations concerning the defendants claims
and did in fact seek professional counseling and advice from Doctors, pastors,

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professional authors, lawyers, judges and multiple advisors in attempts to refute and
understand the allegations by Defendants as proof of truthful facts and to correct the
light of the public eyes as to the truthful facts as alleged herein. Plaintiffs have not
been able to get relief or yet know the full amount of defamation and destruction of
the public image of Plaintiffs and financial damages and losses from the frauds and
misrepresentations and omissions of truthful disclosure by Defendants to each person
as stated in paragraphs and other points herein had Plaintiffs and others not relied
on the truthfulness of the alleged allegations by Defendants and each of them.
316. As a proximate result of the false and fraudulent misrepresentations and actions of
the defendants, Plaintiffs have incurred expenses, humiliations and abuse to their
persons and reputations in the public eye and this would not have been required had
the representations of and reports of and presented information of defendants been
true and accurate.
317.

As a further proximate result of the false and fraudulent misrepresentations and

actions as reported herein of the defendants, plaintiffs incurred valuable lost time and
relationships to each other as father and children to parent father and expenses for the
litigation and satisfaction of the injunctions and orders gained by the frauds of
defendants not being truthful causing harm to these plaintiffs
318. In making the representations and performing the acts alleged, defendants and each
of them, acted intentionally with fraud and malice; and plaintiffs are entitled to
damages in the sum yet fully unknown to the full extent the laws of Florida
allow to the maximum of these Florida Statues violated by Defendants but estimated
at $2,000,000.00 or more.

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319. Further Plaintiffs state s. 817.03, Florida Statues;

Making false statement to obtain property or credit.Any person who
shall make or cause to be made any false statement, in writing, relating to his
financial condition, assets or liabilities, ,with fraudulent intent of obtaining
credit, goods, money or other property, and shall by false statement obtain credit,
goods, money or other property shall be guilty of a misdemeanor of the first
degree, punishable as provided in s. 775.082 or s.775.083.
Wherefore, Plaintiff prays for relief from any and all injunctions and financial
restitution from the unjust enrichment of all defendants as stated herein each of
these paragraphs and punitive damages.
COUNT XXIII
CLAIM FOR MEDICAL EXPENSES AGAINST ALL DEFENDANTS
320.Plaintiffs reallege all paragraphs all preliminary allegations and subsequent
allegations as stated herein and incorporate these allegations herein by reference.
321.Plaintiffs reallege all conditions precedent have been performed or have occurred.
322.As a further proximate result of the defendants negligent conduct, plaintiff has
incurred expenses for medical care and attention, including physicians fees in the
amount yet fully unknown; medical supplies and medications in the amount yet
fully unknown; and transportation to and from the physicians offices in the
amount yet fully unknown. These expenses are incurred for the necessary care
and treatment of plaintiffs injuries resulting from the negligent action of
defendant as described herein. Plaintiffs medical expenses are reasonable and
represent the customary charges for such services and supplies in Hillsborough
County, Florida.
COUNT XXIV
CLAIM FOR DIMINISHED EARNING CAPACITY AGAINST ALL
DEFENDANTS
323.Plaintiffs reallege all paragraphs all preliminary allegations and subsequent

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allegations as stated herein and incorporate these allegations herein by reference.

324.Plaintiffs reallege all conditions precedent have been performed or have occurred.
325.As a further proximate result of defendants negligent conduct, plaintiff Townsends
capacity to earn a livelihood was severely impaired, and in all reasonable probability will
continue to be impaired for an indefinite period, if not for the rest of Plaintiff Townsends
life. Plaintiff Townsend seeks damages for losses due to the impairment to his earning
capacity in the amount in excess of $1,000,000.00 to be determined by the jury.
COUNT XXV
CLAIM FOR PAIN AND SUFFERING TO INJURED PARTIES AGAINST
ALL DEFENDANTS
326.Plaintiffs reallege all paragraphs all preliminary allegations and subsequent
allegations as stated herein and incorporate these allegations herein by reference.
327.Plaintiffs reallege all conditions precedent have been performed or have occurred.
328.As a further proximate result of defendants negligent conduct, each plaintiff has
suffered great physical, mental, and emotional pain and suffering and humiliation
and in all reasonable probability will continue to suffer severe mental and
emotional pain and suffering and humiliation for the rest of their lives.
COUNT XXVI
CLAIM FOR FUTURE MEDICAL CARE AGAINST ALL DEFENDANTS
329. Plaintiffs reallege all paragraphs all preliminary allegations and subsequent
allegations as stated herein and incorporate these allegations herein by reference.
330. Plaintiffs reallege all conditions precedent have been performed or have occurred.
331. As further proximate result of defendants negligent conduct, a reasonable
probability exist that each Plaintiff will incur future medical expenses. The full

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amount of plaintiffs future medical expenses is not known to plaintiff at this time,
and plaintiff will move to amend this complaint to state the amount at the time the
amount is known.
COUNT XXVII
CLAIM FOR DAMAGES FOR FRAUD CAUSING REDUCTION OF
MARKET VALUE AND LOST PROFITS OF PERSONAL PROPERTY
AGAINST ALL DEFENDANTS
332. Plaintiffs reallege all paragraphs all preliminary allegations and subsequent
allegations as stated herein and incorporate these allegations herein by reference.
333. Plaintiffs reallege all conditions precedent have been performed or have occurred.
334. As a proximate result of the defendants negligent conduct by fraud to Judge
Gomez and the Appeals Court that Harrod had: (1) to leave her teaching job at CPCS at
the hand of the alleged acts of Plaintiff Townsend without cause and move out of town
and could not teach again so to incur alimony and education and rehabilitation expenses
of $500.00 a month for four years and (2) any ownership remaining in the marital home
and the fraud that she had stated no money rights to the affidavit presented to the court of
Judge Palomino but in trial before Judge Timmerman alleged a 25% ownership knowing
she had been voted out of any ownership rights (3) no marital debt as setoffs to any
possible assets in the marital home (4) required the home to incur lack of upkeep due to
the excessive garnishments calculated to destroy the financial ability of this Plaintiff to
pay all bills for the home and all other expenses in addition to the excessive garnishment
(5) required the home to be sold per the AMENDED JUDGEMENT that had not been
litigated as per the transcript of January 30, 2003, nor ordered after proper notification to
this Pro Se Plaintiff Townsend and had not been argued but in first hearing in January 30,
2003, in which home issue was to remain under the control of Plaintiff but for the fraud

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of Defendants and these attorneys but was done secretly by Harrod with Defendant and
attorneys Scruggs and Turmel in conspiracy with Defendant, that this caused the home to
loose value due to needed care and the requirement of the court to sell the home this did
cause damage and loss to the Plaintiff in the amount of $100,000.00 from the demise and
sell of the home at below market value do to the forced sale by Harrod and Defendants.
COUNT XXVIII
CLAIM FOR ATTORNEYS FEES AGAINST ALL DEFENDANTS
335.

Plaintiffs reallege all paragraphs all preliminary allegations and subsequent

allegations as stated herein and incorporate these allegations herein by reference.

336. Plaintiffs reallege all conditions precedent have been performed or have occurred.
337.Plaintiff Pleads for Entitlement For any and all attorneys fees as Plaintiff Randall
Townsend, had retained the Attorneys Firms of CHARLES H. SCRUGGS, P.A and
HEATHER M. GRAY to represent these Plaintiffs in these actions and agreed to pay
Attorneys Charles H. Scruggs, P.A. and Heather M. Gray a reasonable attorney fee
And plaintiff retained other attorneys and paid attorneys reasonable fees yet
Undetermined Plaintiff Randall Townsend is entitled to attorneys fees pursuant to
Florida Statue, 451 and Florida Statues 768 and others, as prevailing party,
all reasonable attorneys fees incurred in bringing this suit to prosecute Plaintiffs
rights under the law. Plaintiff is entitled to recover attorneys fees because of the
frauds and omissions of truthful disclosure enumerated herein to attempt to restore the
integrity and family rights of these Plaintiffs as breached by these defendants as
alleged herein and Plaintiff has been compelled to employ counsel to enforce
Plaintiffs rights under the law as alleged herein and plaintiff has paid court fees and

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court reporter fees and additional fees and costs yet undertermined.
338.Plaintiffs allege and affirm that the documents attached herein as Exhibits and others
as papers, affidavits, pleadings, transcripts and Judgements and Orders was issued
or the act done in compliance with the law and request this court to take judicial
notice of all cases mentioned herein.
COUNT XXIX
COMPLAINT FOR VICARIOUS LIABILITY OF
PROFESSIONAL CORPORATION FOR MALPRACTICE OF MEMBER
ATTORNEY and VIOLATIONS OF RESPONDENT SUPERIOR---AGAINST
DEFENDANTS HEATHER GRAY ATTORNEY AND HEATHER GRAY
ATTORNEY AT LAW, P.A. AS OF HEATHER GRAY INDIVIDUAL
339. Plaintiffs reallege all paragraphs all preliminary allegations and subsequent
allegations as stated herein and incorporate these allegations herein by reference.
340. Plaintiff state that the acts as stated herein of Attorney Heather Gray and Heather
Gray, Individual were practices in violations of laws and Rules of Civil Procedure and
Rules of Judicial Procedure and that HEATHER GRAY ATTORNEY AT LAW, P.A.
knowingly, intentionally, recklessly and negligently participated in the deceptions,
frauds, omissions of truthful disclosures and acts as stated herein to these clients and to
the courts and law enforcement officers.
341.Plaintiffs as Clients reasonably relied on defendants representations and omissions
and as a proximate result thereof were deceived as to file causes of actions and promote
causes of available actions and protections from violations continuing of the Florida
Statues as stated in Section 5 above herein and was damaged and is continued to be
damaged and separated as a father and child now since NOVEMBER 8, 2002, by the
frauds and CONCEALMENTS and OMISSIONS OF TRUTHFUL DISCLOSURES
since Defendants became advocates for clients in February 2003, with knowledge and

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duty to disclose attorney Scruggs and Scruggs P.A for their violations of these clients and
frauds on the courts.
342.Plaintiffs allege by the omissions of truthful disclosure and frauds against Plaintiffs
that Plaintiffs did not contribute to the damages caused by Defendants.
343.WHEREFORE, PLAINTIFFS REQUEST ALL RELIEF FOR DAMAGES AS
STATED BELOW HEREIN AND ANY OTHER RELIEF AS THIS COURT DEEMS
PROPER.
COUNT XXX
COMPLAINT FOR MALPRACTICE OF MEMBER ATTORNEY AS
VIOLATIONS BY THEORY OF RESPONDENT SUPERIOR---AGAINST
DEFENDANTS HEATHER GRAY ATTORNEY AND HEATHER GRAY
ATTORNEY AT LAW, P.A. AS OF HEATHER GRAY INDIVIDUAL
344. Plaintiffs reallege all paragraphs all preliminary allegations and subsequent
allegations as stated herein and incorporate these allegations herein by reference.
345.Plaintiff state that the acts as stated herein of Attorney Heather Gray and Heather
Gray, Individual were practices in violations of laws and Rules of Civil Procedure and
Rules of Judicial Procedure and that HEATHER GRAY ATTORNEY AT LAW, P.A.
knowingly, intentionally, recklessly and negligently participated in the deceptions,
frauds, omissions of truthful disclosures and acts as stated herein to these clients and to
the courts and law enforcement officers.
346.Plaintiffs as Clients reasonably relied on defendants representations and omissions
and as a proximate result thereof were deceived as to file causes of actions and promote
causes of available actions and protections from violations continuing of the Florida
Statues as stated in Section 5 above herein and was damaged and is continued to be
damaged and separated as a father and child now since NOVEMBER 8, 2002, by the

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frauds and CONCEALMENTS and OMISSIONS OF TRUTHFUL DISCLOSURES

since Defendants became advocates for clients in February 2003, with knowledge and
duty to disclose attorney Scruggs and Scruggs P.A for their violations of these clients and
frauds on the courts.
347.Plaintiffs allege by the omissions of truthful disclosure and frauds against Plaintiffs
that Plaintiffs did not contribute to the damages caused by Defendants.
348. WHEREFORE, PLAINTIFFS REQUEST ALL RELIEF FOR DAMAGES AS
STATED HEREIN AND ANY OTHER RELIEF AS THIS COURT DEEMS PROPER.
WHEREFORE, plaintiff prays for judgment and relief against defendants and
each of them as follows:
A. A Declaration that each Defendants conduct violated the law as alleged in each cause
of action;
B. A Declaration to abolish the injunction section from the Court of Judge
Timmerman, limiting the rights of this Plaintiff Townsend as father to his now adult
children, J.D.T and J.G.T and restoration of all full rights and expunge all records of
these injunctions caused by fraud of the defendants to the court as revealed by Karen
Harrod Townend in December 2005, Motion to this Honorable Court no threat of
abuse molesting or any vile act exists or ever existed;
C. preliminary and permanent injunctions preventing defendants and her co-conspirators
from any future acts of abuse and slander and harassment to Plaintiffs per s. 741 F.S.
and all other Florida Statues and set severe penalties to warn Defendants and her coconspirators of future abuse to the peace of these Plaintiffs;
D. Judgement for the Plaintiff for general and compensatory damages sustained as a
result of defendants unlawful conduct;
E. For the following special damages to be awarded according to complete discovery of
all proof to the limits allowed by law:
1. For physical Pain and suffering incurred while Defendants used fraud and
2. For the Loss of parental rights by Plaintiff Randall Townsend to J.D.T and to
J.G.T and
3. For Emotional Duress and Mental Duress incurred for Defendants use of abuse
and fraud
4. For Loss of honorable reputation of Plaintiff having to endure the slander and
defamation and frauds and malice and abuse of process and malicious prosecution
and all actions per each count shown herein without counter defense by
Defendants to off set the malicious charges incurring all special and general
damages as stated herein and

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5. For all general, compensatory and nominal damages resulting from each
Defendants conspiracy and fraud and duress and extortion with Beck and Harrods
employer, FBCCP and CPCS and by the extortion and abuse and conspiracy with
individuals and co-employees at the place of employment as listed below as these
litigants falsely charging this Plaintiff with crimes in order to hide their criminal
acts on Plaintiff Randall Townsend and on Minor J.D.T and Minor J.G.T and
Defendants conspiracy with:
A. Ron Beck, individually, and as FBCCP Corporation Member and
Officer
B. Herman Meister, individually, and as FBCCP Corporation Member
and Officer
C. Gary Leatherman, individually, and as Corporation Member and
Officer
D. Joe Howlett, individually, and as Corporation Member and HCSO
Deputy
E. Tim Jeffers, individually, and as Corporation Member and as PCSO
Deputy
F. The FBCCP Corporation
G. The Citrus Park Christian School, employees and School Board
H. And from the FBCCP Corporation members at Large
I. From the abusive conduct practiced on these Pro Se Plaintiffs by
Defendants attorneys causing duress and fraud on these Plaintiffs by
the frauds of Defendants to attorneys, David Gibbs, III; Drew Gardner;
Charles Denny, IV; Stacey Turmel; Charles H. Scruggs, III; Heather
Gray and Stanford Solomon;
J. For Special Damages in loss of reputation and loss of employment by
Plaintiff Randall Townsend in October 2005, flowing from the
fraudulent actions by Defendants
K. .For Special Damages in loss of reputation and loss of monies owed
this Plaintiff Townsend, from SunBelt Equipment Corporation, as
damages of Defendants barred litigation as advised by the State
Attorney for defamation and slander and lost earnings were at
$1,000,000.00
6. For damages resulting from Defendants violation of the injunction set by Judge
Timmerman and the admitted contact by Harrod with Plaintiffs employer up until
October, 2005, and these injunctions in 2001 and 2003-current, and allegations
and contacts by these defendants did attribute to Harrods and others and thereby
defendants willful negligence and abuse, infliction of emotional duress and
harassment in the workplace and loss of employment and loss of earnings and all
future earnings because of the frauds and acts of Defendants and the contacts to
abuse this Plaintiff to this employer.
7. For Loss of Earning capacity from the damaged reputation and integrity caused by
the attacks and injunctions of Defendants to defame Plaintiff Townsend in the
public eye
8. For lost profits of the home equity valued at $100,000.00.

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9. For any and all future medical fees and costs and expenses for future medical
attention for emotional, physical and mental restoration for these Plaintiffs well
being of a future relationship as parent to children and children to this Plaintiff.
10. For the cost incurred with this action
11. For legal costs and fees in all court cases
12. For any and all attorneys fees as Plaintiff Randall Townsend, had retained the
Attorneys Firms of CHARLES H. SCRUGGS, P.A and HEATHER M. GRAY to
represent these Plaintiffs in these actions and agreed to pay Attorneys Charles H.
Scruggs, P.A. and Heather M. Gray a reasonable attorney fee which should be
returned with interest.
13. For such and further relief as this court may deem proper
14. For any and all other Compensatory Damages
15. For CONSEQUENTIAL DAMAGES
16. Plaintiff request leave to amend pleading to request Punitive damages at time that
is just and proper per these pleadings.
17. FOR EXEMPLARY DAMAGES
18. FOR ALL NOMINAL DAMAGES
19. FOR TREBLE DAMAGES
20. AND For any and all additional sanctions, awards and retributions, this court
seems just to allow.
21. FOR A JURY TRIAL ON ALL ISSUES TRIABLE OF RIGHT BY JURY.
COUNT XXXI
FRAUD AGAINST THE FLORIDA BAR AND THE JUDICIAL
QUALIFICATIONS COMMISSION AND THE SECOND DISTRICT COURT OF
APPEALS AND CHIEF JUDGE MANUEL MENENDEZ JR. OF
HILLSBOROUGH COUNTY FLORIDA CIRCUIT CIVIL COURTS,
HILLSBOROUGH COUNTY, FLORIDA AND THE STATE OF FLORIDA
349. Plaintiffs re-allege all points above and below and incorporates them herein
350. Plaintiff allege that each Defendant herein alleges to hold, protect, enforce and
prosecute violation and violators of the United States Constitution, State of Florida
Constitution and U.S. Codes and State and Local Statues and Ordinances for the civil and
peaceful protections and guarantees of all rights as citizens within their jurisdictions.
351. Plaintiffs allege that each defendant herein knowingly, intentionally, willfully and
recklessly refused to do their dutiful service as stated upon acceptance to the position or
job they allege to perform and hold for protection of these Plaintiffs they allege to serve.
352. Plaintiffs allege that by these Defendants intentional, willful and knowingly

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reckless performance of duty that Plaintiffs have been damaged as a result of their willful
and intentional negligence and tort conspiracy not to perform the services they allege to
do and thereby not performing do perform a fraud that they are performing to protect all
Constitutional rights as stated herein.
353. Wherefore Plaintiffs demand judgement for all compensation and damages so
allowed under the law against each defendant and prosecution against each defendant as
this Federal court may so rule.
COUNT XXXII
CLAIM OF CONSPIRACY AGAINST THE FLORIDA BAR AND THE
JUDICIAL QUALIFICATIONS COMMISSION AND THE SECOND DISTRICT
COURT OF APPEALS AND CHIEF JUDGE MANUEL MENENDEZ JR. OF
HILLSBOROUGH COUNTY FLORIDA CIRCUIT CIVIL COURTS, FAMILY
COURTS, DOMESTIC VIOLENCE COURTS OF HILLSBOROUGH COUNTY,
FLORIDA AND THE STATE OF FLORIDA
Plaintiffs re-allege all points above and below and incorporates them herein
354. Plaintiff allege that each Defendant herein alleges to hold, protect, enforce and
prosecute violation and violators of the United States Constitution, State of Florida
Constitution and U.S. Codes and State and Local Statues and Ordinances for the civil and
peaceful protections and guarantees of all rights as citizens within their jurisdictions.
355. Plaintiffs allege that each defendant herein knowingly, intentionally, willfully and
recklessly since first advised starting in 1999, and through filing of this complaint have
refused to do their dutiful service as stated upon acceptance to the position or job that
they allege to perform and hold for the protection of these Plaintiffs they allege to serve.
356. Plaintiffs allege that by these Defendants intentional, willful and knowingly
reckless performance of duty that Plaintiffs have been damaged as a result of their willful
and intentional negligence and tort conspiracy not to perform the services they allege to

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do and thereby not performing do perform a fraud that they are performing to protect all
Constitutional rights as stated herein but instead choose and conspire to give unlawful
Benefit to Clergy and attorneys and judges and others in alleged law enforcement.
357. Wherefore Plaintiffs demand judgement for all compensation and damages so
allowed under the law against each defendant and prosecution against each defendant as
this Federal court may so rule as each defendant did Conspiracy to hold responsibility but
did refuse to act to perform and protect. Plaintiff Townsend also seeks punitive damages.
COUNT XXXIII
VICARIOUS LIABILITY AGAINST THE FLORIDA BAR AND
THE JUDICIAL QUALIFICATIONS COMMISSION AND THE SECOND
DISTRICT COURT OF APPEALS AND CHIEF JUDGE MANUEL MENENDEZ
JR. OF HILLSBOROUGH COUNTY FLORIDA CIRCUIT CIVIL COURTS,
HILLSBOROUGH COUNTY, FLORIDA AND THE STATE OF FLORIDA, THE
OFFICE OF THE ATTORNEY GENERAL AND THE OFFICE OF THE
FLORIDA DEPARTMENT OF LAW ENFORCMENT AND THE
HILLSBOROUGH COUNTY SHERIFF DEPARTMENT AND HILLSBOROUGH
COUNTY OF THE STATE OF FLORIDA AND THE PINELLAS SHERIFF
DEPARTMENT AND THE PASCO SHERIFF DEPARTMENT AND THE CITY
OF TAMPA
Plaintiffs re-allege all points above and below and incorporates them herein
358. Plaintiff allege that each Defendant herein alleges to hold, protect, enforce and
prosecute violation and violators of the United States Constitution, State of Florida
Constitution and U.S. Codes and State and Local Statues and Ordinances for the civil and
peaceful protections and guarantees of all rights as citizens within their jurisdictions.
359. Plaintiffs allege that each defendant herein knowingly, intentionally, willfully and
recklessly since first advised starting in 1999, of the violations of laws by the actions of
alleged Clergy and alleged Trustees as Sheriff Deputies and officers have willfully and
knowingly and intentionally chose and assisted Benefit of Clergy in the advance of

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frauds and omissions of truthful disclosure and through filing of this complaint have
refused to do their dutiful service as stated upon acceptance to the position or job that
they allege to perform and hold for the protection of these Plaintiffs they allege to serve
in violation of NORFOLK MONUMENT CO. v. MEMORIAL GARDENS 394 U.S.
700, 89 S.Ct 1391, 22 L. Ed. 2d 658, 662 (1969) stating:
No formal agreement between the parties is necessary to constitute an unlawful
conspiracy. Nor is it essential that a coconspirator participate in any particular phase of
the conspiracy such as its planning, inception, or conclusion; a conspiracy may be found
if the co conspirator was aware of the scheme and assisted it in some phase of its
perpetration. Per DONOFRIO v. MATASSINI 503 So2d 1278, 1281(Fla. 2d DCA
1987).
360. Plaintiffs allege that by these Defendants intentional, willful and knowingly
reckless performance of duty that Plaintiffs have been damaged as a result of their willful
and intentional negligence and tort conspiracy not to perform the services they allege to
do and thereby not performing do perform a fraud that they are performing to protect all
Constitutional rights and violations of Florida Statues 542.18, 542.19, 772.103(4) and
772.104 and others as 42. U.S.C. 1985, as stated herein.
361. Wherefore Plaintiffs demand judgement for all compensation and damages and a
claim of punitive damages so allowed under the law against each defendant and
prosecution against each defendant as this Federal court may so rule as each defendant
did Conspiracy to hold responsibility but did refuse to act to perform and protect.
COUNT XXXIV
CLAIM FOR BAD FAITH AGAINST
UTICA INSURANCE COMPANY OF NEW YORK
Plaintiffs re-allege all points above and below and incorporates them herein
362. Plaintiff allege that each Defendant herein alleges to hold, protect, enforce and
Protect for violation and violators of the United States Constitution, State of Florida

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Constitution and U.S. Codes and State and Local Statues and Ordinances for the civil and
peaceful protections and guarantees of all rights as citizens within their jurisdictions of
the policies they contract to and with their clients.
363. Plaintiffs allege that defendant herein knowingly, intentionally, willfully and
recklessly refused to do their dutiful service as stated upon acceptance to the position or
job that they allege to perform and hold for the protection of these Plaintiffs they allege to
serve upon entering into the Contract for services with the First Baptist Church of Citrus
Park and for payments of legal services to the law firm of DICKINSON & GIBBONS
and that by allowing the FIRM OF DICKINSON & GIBBONS and its lawyers as agents
to represent in conflict of interest and violations of attorney client rules this Insurance
agency has violated its duty to these Plaintiffs and advanced the frauds of Ron Beck,
Herman Meister, Gary Leatherman, Joe Howlett, Tim Jeffers, Dr. Lon Lynn, Karen
Harrod Townsend and Charles Denny as individuals in violations of rights of these
Plaintiffs who sought protections for themselves and the Corporation who they freely and
religiously attempt to serve and protect but for the frauds, omissions of truthful disclosure
and conspiracy and bad faith actions of Ron Beck, Herman Meister, Gary Leatherman,
Joe Howlett, Tim Jeffers, Dr. Lon Lynn, Karen Harrod Townsend and Charles Denny
being allowed to act and fail to act while serving the interests of Defendants and as
UTICA INSURANCE COMPANY OF NEW YORK.
364. Plaintiffs allege that by these Defendants intentional, willful and knowingly
reckless performance of duty that Plaintiffs have been damaged as a result of their willful
and intentional negligence and tort conspiracy not to perform the services they allege to
do and thereby not performing do perform a fraud that they are performing to protect all

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Constitutional rights as stated herein and also by not attempting to settle the claim of this
Plaintiff but have promoted frauds and incompetent offers of judgments based on the
intensity and damages known and stated in this Complaint.
365. Wherefore Plaintiffs demand judgement for all compensation and damages so
allowed under the law against each defendant and prosecution against each defendant as
this Federal court may so rule as each defendant did Conspiracy to hold responsibility but
did refuse to act to perform and protect. Plaintiffs also seek punitive damages.
COUNT XXXV
CLAIM FOR MISSAPPROPRIATION OF CORPORATE OPPORTUNITY
AGAINST DEFENDANTS RON BECK, individually, Ron Beck as Pastor,
Herman Meister, Individually, Herman Meister as Pastor of School Ministries,
April Beck, Individually, April Beck as Employee of FBCCP/CPCS, Joyce Meister,
Individually, Joyce Meister as Employee of FBCCP/CPCS, Gary Leatherman,
Individually, Gary Leatherman an Officer of the FBCCP Corporation, Tim Jeffers,
Individually, Tim Jeffers as an Officer of the FBCCP Corporation, Karen Jeffers,
Individually, Karen Jeffers as an Employee of FBCCP/CPCS and other Defendants
as DOE until full production of Corporation Records.
Plaintiffs re-allege all points above and below and incorporates them herein
366. Per Uvanile v. Denoff 495 So2d 1177 (Fla. 4th, DCA 1986) and Head v. Lane 495
So2d 821 (Fla. 4th DCA, 1986) and Tinwood N.V. v. Sun Banks 570 So2d 955 (Fla. 5th
DCA 1990, stating An officer or director is precluded from making any secret profit or
deriving any personal advantage at the expense of the corporation.
367. On or about 1995 present Defendants named herein did deprive, conceal, omit
truthful disclosure from the General Voting Members and this Plaintiff the
misappropriation of Corporate opportunities and assets as full disclosure is required by
the Florida Statues and by the FBCCP Corporation BY-LAWS as stated above and below
in each paragraph herein this full complaint and did receive unjust enrichment thereby.

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368. Plaintiffs demands full and complete restitution, punitive, compensatory damages
and what ever relief this court deems proper because of the actions of defendants named
herein acting individually, and jointly.
COUNT XXXVI
ABUSE OF PROCESS AGAINST DEFENDANTS DEPUTY JOE HOWLETT,
DEPUTY TIM JEFFERS, DEPUTY JOHN MICHEAL CORBIN, DEPUTY MIKE
SMOAK, TAMPA POLICE OFFICER JOE KAREAS AND OFFICER MIKE
SHAR FOR ACTS AGAINST PLAINTIFFS AS ALL MINOR CHILDREN AS
MEMBERS OF FBCCP AND CPCS
369.

Comes Now Plaintiff, Randall Townsend individual, and sues Defendants Joe

Howlett, Tim Jeffers, John Micheal Corbin, Mike Smoak, Joe Kareas and Mike Shar as
individuals and as Law Enforcement, Sheriff Deputies and Police officers and for all
Minor Plaintiffs and reallege all paragraphs above and below and incorporates herein and
alleges:
370. Plaintiff, Randall Townsend, is an individual residing at relevant times in
Hillsborough, Sarasota and Pinellas Countys of Florida within the jurisdiction of
the UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA and
with rights as a citizen and FBCCP member now not able to be fully known until the
production of FBCCP Business Records in June/July 2006, to have Constitutional and
BY-LAWS rights to Speech, Assembly, No Child interference with his fathers rights, and
Religious freedoms and for life, liberty and pursuit of happiness but to conceal the frauds
of pastors and sheriff deputies as masked trustees these defendants did use their Law
Enforcement uniforms as masks that all activities of themselves and these clergy and
attorneys and judges were lawful and now proved fraud, and collusion as stated herein.
371. Defendants Joe Howlett, Tim Jeffers, John Micheal Corbin, Mike Smoak, Joe

312

Kareas and Mike Shar are individuals residing within the Counties of Hillsborough and
Pasco of, Florida and working or were working at their times of actions or were on
duty or off duty and or now retired as law enforcement within the Counties of
Hillsborough, Pasco and Pinellas of Florida and within the jurisdiction of the State of
Florida and of this UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF
FLORIDA.
372. Plaintiff Townsend restates all paragraphs of Number 4-20 as above herein that
show that action is proper within the venue and Jurisdiction of this UNITED STATES
DISTRICT COURT MIDDLE DISTRICT OF FLORIDA and Because each Defendant
is a resident or was doing or was alleging to do official duties, on duty and off duty
as law enforcement or as officers of the courts and this court is a proper venue for this
action as stated above herein.
373. This is an action for damages in excess of $ 25,000.00 and is within the jurisdiction
of this court.
374. On or about September 8, 1999, and still through current times and at all other times
as stated above and herein at the First Baptist Church of Citrus Park at 7705 Gunn
Highway, Tampa Florida, and at 18105 Gunn Highway, Tampa Florida and at the Court
Room of Judge Raul Palomino of Hillsborough County on November 15, 2001, by
individual and as Deputy Joe Howlett(Howlett) and by Howlett at Citrus Park Town
Center Mall on numerous occasions and by Mike Shar at Kmart in Sarasota, Florida and
by each Defendant in Count XIII, herein and on surrounding roads at or about Gunn
Highway at or around the Citrus Park Baptist Church Defendant assaulted Plaintiff in that
Defendants Howlett and Smoak did use their Deputy Crusiers at times with lights

313

flashing to impede the peaceful operation of Plaintiff Townsend in or out side of his
vehicle to deter, inflict shame and harassment and abuse and Deputy Howlett even on
occasions would attempt to coerce Plaintiff Townsend to retaliate with resistance so
Deputy Howlett could arrest Plaintiff Townsend and per the verbal under oath testimony
of Defendant Ron Beck on November 15, 2001, under oath to Judge Raul Palomino Beck
did attempt to use the alleged needed actions of Howlett and Jeffers and Smoak to allege
that Plaintiff Townsend without lawful duty or cause had to be restrained or blocked from
alleged illegal or unlawful conduct at the steps of the Church despite Plaintiff Townsend
being a member and fully and completely can prove that Plaintiff Townsend was invited
by several members to address in open forum business meeting process per the BYLAWS duty the issues of frauds and corruption of these Pastors and these same deputies
as alleged Trustees. Plaintiff states that each deputy and officer at all times herein and in
all paragraphs above and below appeared to each plaintiff to be acting in their official
mask or uniform as an officer of the law and that all deputies and officers acted to
appear to be within their official roles in order to inflict conspired control, restraint and
protection of Plaintiff Townsend to others. Plaintiff Townsend alleges that even Corbin
did publicly yell and abuse Plaintiff Townsend to make a public scene for the alleged
protection of others despite Corbin as a member of the LRPC Committee fully knowing
the pure motives of Plaintiff Townsend. Defendants, while arguing at Plaintiff over
Church issues and pastor and others criminal actions and frauds, would yell publicly,
chase plaintiff Townsend on foot and in official vehicles and attempted to at times even
in uniform cause or Ordered Plaintiff Townsend from his car so Deputies could show
alleged protection and deceptions and frauds and omissions of truthful disclosure and

314

misappropriation of their vested Corporation and Citizens rights to others as these Minor
Plaintiffs herein and possibly entice Plaintiff Townsend to resist the harassment and
abuse so to cause additional emotional distress to the Minor Plaintiffs herein. Defendant
Jeffers even did Touch the Wife of Plaintiff Townsend on the steps of the Church and led
her away from talking to Plaintiff Townsend so to make appear that persons were in
danger. Defendant Howlett at times stood in front of Plaintiff, who was in his car,
blocking him in his seat. Defendant then threatened to arrest Plaintiff and raised his hand
to his gun belt as if to need against Plaintiff, all the while standing over Plaintiff and
leaving Plaintiff no avenue of escape.
375. Defendant intended to cause apprehension of imminent harm in Plaintiffs in that
Defendant Beck had advised Plaintiff Townsend show that defendant's acts were intended
as Defendant Beck stated he would file charges if Plaintiff tried to speak in Church
meetings or attend Church or School services and business meetings or school functions
and as told to judge Palomino on November 15, 2001, by Defendant Ron Beck and
Defendant Employee Karen Harrod Townsend. Defendant approached Plaintiff, who was
seated many times in his car, with no intent to harm anyone would be approached and
engaged by Defendants threatening to cause violent physical injury by arrest, and then
use police type car chases, traffic stops with lights flashing, intervention at the Church
Steps prohibiting Plaintiff now fully known to have always been a member of the
Corporations with rights not restricted by the Courts but only on November 2-15, 2001,
and by Deputy Howlett making false allegations to Curtis Baughman and attending the
Court of Judge Palomino stating willingly to give false testimony and , thereby causing
Plaintiff to feel threatened with imminent bodily injury and place him in apprehension for

315

his safety and fear of going to prison. Furthermore, Defendant's acts were substantially
certain to result in apprehension of imminent harm in Plaintiff.
376. Because Defendant Howlett made intentional threats to Plaintiff, on April 27, 2000
to get your hands on the table, prohibited discovery of FBCCP Materials, prohibited
Townsend from the April 30, 2000,Business Meeting and in traffic stops would require
Plaintiff to flee the property while just sitting waiting for his children or be chased by
Deputy Howlett, Deputy Smoaks and being yelled at and repeatedly chased by Defendant
Ron Beck in his vehicle even at one time with a visiting evangelist willing to verbally
communicate the threats and chase to pastors at Idlewild Baptist Church and was not
restrained in his movements as Plaintiff was, Defendant had the apparent present ability
to harm Plaintiff as he was threatening to do and as a direct and proximate result, Plaintiff
reasonably feared that Defendant would imminently inflict bodily harm on or put Plaintiff
in jail.
377. As a direct and proximate result of Defendant's conduct, Plaintiff was injured in that
Plaintiffs were frightened and excited, resulting in a mental and nervous injury that has
caused Plaintiff great emotional pain and suffering and loss of his family and loss of his
relationship now freely per his civil rights with his children since October 20, 1999, and
now having not been able to see his children now since November 8, 2002 and reputation
and employment and loss of future ability to earn income and reduction in ability to earn
income and defamation and slander.
378.

As a further direct and proximate result of Defendant's conduct, Plaintiff has been

damaged in the yet undetermined amount of financial damages for the cost of medical

316

bills, and for lost earnings and the ability to create employment and earnings.
WHEREFORE, Plaintiff demands judgment as follows:
A. For general damages.
B. For punitive damages.
C. For intentional infliction of emotional distress
D. For costs of suit incurred in this action.
E. For other and further relief as the Court may deem proper.
COUNT XXXVII
FOR BATTERY AGAINST DEFENDANTS DEPUTY JOE HOWLETT, DEPUTY
TIM JEFFERS, DEPUTY JOHN MICHEAL CORBIN, DEPUTY MIKE SMOAK,
TAMPA POLICE OFFICER JOE KAREAS AND OFFICER MIKE SHAR FOR
ACTS AGAINST PLAINTIFFS AS ALL MINOR CHILDREN AS MEMBERS OF
FBCCP AND CPCS
379.

Comes Now Plaintiff, Randall Townsend individual, and sues Defendants Joe

Howlett, Tim Jeffers, John Micheal Corbin, Mike Smoak, Joe Kareas and Mike Shar as
individuals and as Law Enforcement, Sheriff Deputies and Police officers and for all
Minor Plaintiffs and reallege all paragraphs above and below and incorporates herein and
alleges:
380. Plaintiff, Randall Townsend, is an individual residing at relevant times in
Hillsborough, Sarasota and Pinellas Countys of Florida within the jurisdiction of
the UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA and
with rights as a citizen and FBCCP member now not able to be fully known until the
production of FBCCP Business Records in June/July 2006, to have Constitutional and
BY-LAWS rights to Speech, Assembly, No Child interference with his fathers rights, and
Religious freedoms and for life, liberty and pursuit of happiness but to conceal the frauds
of pastors and sheriff deputies as masked trustees these defendants did use their Law
Enforcement uniforms as masks that all activities of themselves and these clergy and
attorneys and judges were lawful and now proved fraud, and collusion as stated herein.

317

381.Defendants Joe Howlett, Tim Jeffers, John Micheal Corbin, Mike Smoak, Joe
Kareas and Mike Shar are individuals residing within the Counties of Hillsborough and
Pasco of, Florida and working or were working at their times of actions or were on
duty or off duty and or now retired as law enforcement within the Counties of
Hillsborough, Pasco and Pinellas of Florida and within the jurisdiction of the State of
Florida and of this UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF
FLORIDA.
382. Plaintiff Townsend restates all paragraphs of Number 4-20 as above herein that
show that action is proper within the venue and Jurisdiction of this UNITED STATES
DISTRICT COURT MIDDLE DISTRICT OF FLORIDA and Because each Defendant
is a resident or was doing or was alleging to do official duties, on duty and off duty
as law enforcement or as officers of the courts and this court is a proper venue for this
action as stated above herein.
383. This is an action for damages in excess of $ 25,000.00 and is within the jurisdiction
of this court.
384. On or about September 8, 1999, and still through current times and at all other times
as stated above and herein at the First Baptist Church of Citrus Park at 7705 Gunn
Highway, Tampa Florida, and at 18105 Gunn Highway, Tampa Florida and at the Court
Room of Judge Raul Palomino of Hillsborough County on November 15, 2001, by
individual and as Deputy Joe Howlett(Howlett) and by Howlett at Citrus Park Town
Center Mall on numerous occasions and by Mike Shar at Kmart in Sarasota, Florida and
by each Defendant in Count XIII, herein and on surrounding roads at or about Gunn
Highway at or around the Citrus Park Baptist Church Defendant assaulted Plaintiff in that

318

Defendants Howlett and Smoak did use their Deputy Crusiers at times with lights
flashing to impede the peaceful operation of Plaintiff Townsend in or out side of his
vehicle to deter, inflict shame and harassment and abuse and Deputy Howlett even on
occasions would attempt to coerce Plaintiff Townsend to retaliate with resistance so
Deputy Howlett could arrest Plaintiff Townsend and per the verbal under oath testimony
of Defendant Ron Beck on November 15, 2001, under oath to Judge Raul Palomino Beck
did attempt to use the alleged needed actions of Howlett and Jeffers and Smoak to allege
that Plaintiff Townsend without lawful duty or cause had to be restrained or blocked from
alleged illegal or unlawful conduct at the steps of the Church despite Plaintiff Townsend
being a member and fully and completely can prove that Plaintiff Townsend was invited
by several members to address in open forum business meeting process per the BYLAWS duty the issues of frauds and corruption of these Pastors and these same deputies
as alleged Trustees. Plaintiff states that each deputy and officer at all times herein and in
all paragraphs above and below appeared to each plaintiff to be acting in their official
mask or uniform as an officer of the law and that all deputies and officers acted to
appear to be within their official roles in order to inflict conspired control, restraint and
protection of Plaintiff Townsend to others. Plaintiff Townsend alleges that even Corbin
did publicly yell and abuse Plaintiff Townsend to make a public scene for the alleged
protection of others despite Corbin as a member of the LRPC Committee fully knowing
the pure motives of Plaintiff Townsend. Defendants, while arguing at Plaintiff over
Church issues and pastor and others criminal actions and frauds, would yell publicly,
chase plaintiff Townsend on foot and in official vehicles and attempted to at times even
in uniform cause or Ordered Plaintiff Townsend from his car so Deputies could show

319

alleged protection and deceptions and frauds and omissions of truthful disclosure and
misappropriation of their vested Corporation and Citizens rights to others as these Minor
Plaintiffs herein and possibly entice Plaintiff Townsend to resist the harassment and
abuse so to cause additional emotional distress to the Minor Plaintiffs herein. Defendant
Jeffers even did Touch the Wife of Plaintiff Townsend on the steps of the Church and led
her away from talking to Plaintiff Townsend so to make appear that persons were in
danger. Defendant Howlett at times stood in front of Plaintiff, who was in his car,
blocking him in his seat. Defendant then threatened to arrest Plaintiff and raised his hand
to his gun belt as if to need against Plaintiff, all the while standing over Plaintiff and
leaving Plaintiff no avenue of escape.
385. Defendant intended to cause apprehension of imminent harm in Plaintiffs in that
Defendant Beck had advised Plaintiff Townsend show that defendant's acts were intended
as Defendant Beck stated he would file charges if Plaintiff tried to speak in Church
meetings or attend Church or School services and business meetings or school functions
and as told to judge Palomino on November 15, 2001, by Defendant Ron Beck and
Defendant Employee Karen Harrod Townsend. Defendant approached Plaintiff, who was
seated many times in his car, with no intent to harm anyone would be approached and
engaged by Defendants threatening to cause violent physical injury by arrest, and then
use police type car chases, traffic stops with lights flashing, intervention at the Church
Steps prohibiting Plaintiff now fully known to have always been a member of the
Corporations with rights not restricted by the Courts but only on November 2-15, 2001,
and by Deputy Howlett making false allegations to Curtis Baughman and attending the
Court of Judge Palomino stating willingly to give false testimony and , thereby causing

320

Plaintiff to feel threatened with imminent bodily injury and place him in apprehension for
his safety and fear of going to prison. Furthermore, Defendant's acts were substantially
certain to result in apprehension of imminent harm in Plaintiff.
386. Because Defendant Howlett made intentional threats to Plaintiff, on April 27, 2000
to get your hands on the table, prohibited discovery of FBCCP Materials, prohibited
Townsend from the April 30, 2000,Business Meeting and in traffic stops would require
Plaintiff to flee the property while just sitting waiting for his children or be chased by
Deputy Howlett, Deputy Smoaks and being yelled at and repeatedly chased by Defendant
Ron Beck in his vehicle even at one time with a visiting evangelist willing to verbally
communicate the threats and chase to pastors at Idlewild Baptist Church and was not
restrained in his movements as Plaintiff was, Defendant had the apparent present ability
to harm Plaintiff as he was threatening to do and as a direct and proximate result, Plaintiff
reasonably feared that Defendant would imminently inflict bodily harm on or put Plaintiff
in jail.
387. As a direct and proximate result of Defendant's conduct, Plaintiff was injured in that
Plaintiffs were frightened and excited, resulting in a mental and nervous injury that has
caused Plaintiff great emotional pain and suffering and loss of his family and loss of his
relationship now freely per his civil rights with his children since October 20, 1999, and
now having not been able to see his children now since November 8, 2002 and reputation
and employment and loss of future ability to earn income and reduction in ability to earn
income and defamation and slander.
388. As a further direct and proximate result of Defendant's conduct, Plaintiff has been
damaged in the yet undetermined amount of financial damages for the cost of medical

321

bills, and for lost earnings and the ability to create employment and earnings.
WHEREFORE, Plaintiff demands judgment as follows:
A. For general damages.
B. For punitive damages.
C. For intentional infliction of emotional distress

D. For costs of suit incurred in this action.

E. For other and further relief as the Court may deem proper.
COUNT XXXVIII
FRAUD AGAINST DEFENDANTS DEPUTY JOE HOWLETT, DEPUTY TIM
JEFFERS, DEPUTY JOHN MICHEAL CORBIN, DEPUTY MIKE SMOAK,
TAMPA POLICE OFFICER JOE KAREAS AND OFFICER MIKE SHAR FOR
ACTS AGAINST PLAINTIFFS AS ALL MINOR CHILDREN AS MEMBERS OF
FBCCP AND CPCS
389. Comes Now Plaintiff, Randall Townsend individual, and sues Defendants Joe
Howlett, Tim Jeffers, John Micheal Corbin, Mike Smoak, Joe Kareas and Mike Shar as
individuals and as Law Enforcement, Sheriff Deputies and Police officers and for all
Minor Plaintiffs and reallege all paragraphs above and below and incorporates herein and
alleges:
390. Plaintiff, Randall Townsend, is an individual residing at relevant times in
Hillsborough, Sarasota and Pinellas Countys of Florida within the jurisdiction of
the UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA and
with rights as a citizen and FBCCP member now not able to be fully known until the
production of FBCCP Business Records in June/July 2006, to have Constitutional and
BY-LAWS rights to Speech, Assembly, No Child interference with his fathers rights, and
Religious freedoms and for life, liberty and pursuit of happiness but to conceal the frauds
of pastors and sheriff deputies as masked trustees these defendants did use their Law
Enforcement uniforms as masks that all activities of themselves and these clergy and
attorneys and judges were lawful and now proved fraud, and collusion as stated herein.
322

391.Defendants Joe Howlett, Tim Jeffers, John Micheal Corbin, Mike Smoak, Joe
Kareas and Mike Shar are individuals residing within the Counties of Hillsborough and
Pasco of, Florida and working or were working at their times of actions or were on
duty or off duty and or now retired as law enforcement within the Counties of
Hillsborough, Pasco and Pinellas of Florida and within the jurisdiction of the State of
Florida and of this UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF
FLORIDA.
392. Plaintiff Townsend restates all paragraphs of Number 4-20 as above herein that
show that action is proper within the venue and Jurisdiction of this UNITED STATES
DISTRICT COURT MIDDLE DISTRICT OF FLORIDA and Because each Defendant
is a resident or was doing or was alleging to do official duties, on duty and off duty
as law enforcement or as officers of the courts and this court is a proper venue for this
action as stated above herein.
393. This is an action for damages in excess of $ 25,000.00 and is within the jurisdiction
of this court.
394. On or about September 8, 1999, and still through current times and at all other times
as stated above and herein at the First Baptist Church of Citrus Park at 7705 Gunn
Highway, Tampa Florida, and at 18105 Gunn Highway, Tampa Florida and at the Court
Room of Judge Raul Palomino of Hillsborough County on November 15, 2001, by
individual and as Deputy Joe Howlett(Howlett) and by Howlett at Citrus Park Town
Center Mall on numerous occasions and by Mike Shar at Kmart in Sarasota, Florida and
by each Defendant in Count XIII, herein and on surrounding roads at or about Gunn
Highway at or around the Citrus Park Baptist Church Defendant assaulted Plaintiff in that

323

Defendants Howlett and Smoak did use their Deputy Crusiers at times with lights
flashing to impede the peaceful operation of Plaintiff Townsend in or out side of his
vehicle to deter, inflict shame and harassment and abuse and Deputy Howlett even on
occasions would attempt to coerce Plaintiff Townsend to retaliate with resistance so
Deputy Howlett could arrest Plaintiff Townsend and per the verbal under oath testimony
of Defendant Ron Beck on November 15, 2001, under oath to Judge Raul Palomino Beck
did attempt to use the alleged needed actions of Howlett and Jeffers and Smoak to allege
that Plaintiff Townsend without lawful duty or cause had to be restrained or blocked from
alleged illegal or unlawful conduct at the steps of the Church despite Plaintiff Townsend
being a member and fully and completely can prove that Plaintiff Townsend was invited
by several members to address in open forum business meeting process per the BYLAWS duty the issues of frauds and corruption of these Pastors and these same deputies
as alleged Trustees. Plaintiff states that each deputy and officer at all times herein and in
all paragraphs above and below appeared to each plaintiff to be acting in their official
mask or uniform as an officer of the law and that all deputies and officers acted to
appear to be within their official roles in order to inflict conspired control, restraint and
protection of Plaintiff Townsend to others. Plaintiff Townsend alleges that even Corbin
did publicly yell and abuse Plaintiff Townsend to make a public scene for the alleged
protection of others despite Corbin as a member of the LRPC Committee fully knowing
the pure motives of Plaintiff Townsend. Defendants, while arguing at Plaintiff over
Church issues and pastor and others criminal actions and frauds, would yell publicly,
chase plaintiff Townsend on foot and in official vehicles and attempted to at times even
in uniform cause or Ordered Plaintiff Townsend from his car so Deputies could show

324

alleged protection and deceptions and frauds and omissions of truthful disclosure and
misappropriation of their vested Corporation and Citizens rights to others as these Minor
Plaintiffs herein and possibly entice Plaintiff Townsend to resist the harassment and
abuse so to cause additional emotional distress to the Minor Plaintiffs herein. Defendant
Jeffers even did Touch the Wife of Plaintiff Townsend on the steps of the Church and led
her away from talking to Plaintiff Townsend so to make appear that persons were in
danger. Defendant Howlett at times stood in front of Plaintiff, who was in his car,
blocking him in his seat. Defendant then threatened to arrest Plaintiff and raised his hand
to his gun belt as if to need against Plaintiff, all the while standing over Plaintiff and
leaving Plaintiff no avenue of escape.
395. Defendant intended to cause apprehension of imminent harm in Plaintiffs in that
Defendant Beck had advised Plaintiff Townsend show that defendant's acts were intended
as Defendant Beck stated he would file charges if Plaintiff tried to speak in Church
meetings or attend Church or School services and business meetings or school functions
and as told to judge Palomino on November 15, 2001, by Defendant Ron Beck and
Defendant Employee Karen Harrod Townsend. Defendant approached Plaintiff, who was
seated many times in his car, with no intent to harm anyone would be approached and
engaged by Defendants threatening to cause violent physical injury by arrest, and then
use police type car chases, traffic stops with lights flashing, intervention at the Church
Steps prohibiting Plaintiff now fully known to have always been a member of the
Corporations with rights not restricted by the Courts but only on November 2-15, 2001,
and by Deputy Howlett making false allegations to Curtis Baughman and attending the
Court of Judge Palomino stating willingly to give false testimony and , thereby causing

325

Plaintiff to feel threatened with imminent bodily injury and place him in apprehension for
his safety and fear of going to prison. Furthermore, Defendant's acts were substantially
certain to result in apprehension of imminent harm in Plaintiff.
396. Because Defendant Howlett made intentional threats to Plaintiff, on April 27, 2000
to get your hands on the table, prohibited discovery of FBCCP Materials, prohibited
Townsend from the April 30, 2000,Business Meeting and in traffic stops would require
Plaintiff to flee the property while just sitting waiting for his children or be chased by
Deputy Howlett, Deputy Smoaks and being yelled at and repeatedly chased by Defendant
Ron Beck in his vehicle even at one time with a visiting evangelist willing to verbally
communicate the threats and chase to pastors at Idlewild Baptist Church and was not
restrained in his movements as Plaintiff was, Defendant had the apparent present ability
to harm Plaintiff as he was threatening to do and as a direct and proximate result, Plaintiff
reasonably feared that Defendant would imminently inflict bodily harm on or put Plaintiff
in jail.
397. As a direct and proximate result of Defendant's conduct, Plaintiff was injured in that
Plaintiffs were frightened and excited, resulting in a mental and nervous injury that has
caused Plaintiff great emotional pain and suffering and loss of his family and loss of his
relationship now freely per his civil rights with his children since October 20, 1999, and
now having not been able to see his children now since November 8, 2002 and reputation
and employment and loss of future ability to earn income and reduction in ability to earn
income and defamation and slander.
398.

As a further direct and proximate result of Defendant's conduct, Plaintiff has been

damaged in the yet undetermined amount of financial damages for the cost of medical

326

bills, and for lost earnings and the ability to create employment and earnings.
WHEREFORE, Plaintiff demands judgment as follows:
A. For general damages.
B. For punitive damages.
C. For intentional infliction of emotional distress
D. For costs of suit incurred in this action.

E. For other and further relief as the Court may deem proper.
COUNT XXXIX
FOR BATTERY AGAINST DEFENDANTS DEPUTY JOE HOWLETT, DEPUTY
TIM JEFFERS, DEPUTY JOHN MICHEAL CORBIN, DEPUTY MIKE SMOAK,
TAMPA POLICE OFFICER JOE KAREAS AND OFFICER MIKE SHAR FOR
ACTS AGAINST PLAINTIFF RANDALL TOWNSEND
399.

Comes Now Plaintiff, Randall Townsend individual, and sues Defendants Joe

Howlett, Tim Jeffers, John Micheal Corbin, Mike Smoak, Joe Kareas and Mike Shar as
individuals and as Law Enforcement, Sheriff Deputies and Police officers and for all
Minor Plaintiffs and reallege all paragraphs above and below and incorporates herein and
alleges:
400. Plaintiff, Randall Townsend, is an individual residing at relevant times in
Hillsborough, Sarasota and Pinellas Countys of Florida within the jurisdiction of
the UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA and
with rights as a citizen and FBCCP member now not able to be fully known until the
production of FBCCP Business Records in June/July 2006, to have Constitutional and
BY-LAWS rights to Speech, Assembly, No Child interference with his fathers rights, and
Religious freedoms and for life, liberty and pursuit of happiness but to conceal the frauds
of pastors and sheriff deputies as masked trustees these defendants did use their Law
Enforcement uniforms as masks that all activities of themselves and these clergy and
attorneys and judges were lawful and now proved fraud, and collusion as stated herein.

327

401. Defendants Joe Howlett, Tim Jeffers, John Micheal Corbin, Mike Smoak, Joe
Kareas and Mike Shar are individuals residing within the Counties of Hillsborough and
Pasco of, Florida and working or were working at their times of actions or were on
duty or off duty and or now retired as law enforcement within the Counties of
Hillsborough, Pasco and Pinellas of Florida and within the jurisdiction of the State of
Florida and of this UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF
FLORIDA.
402. Plaintiff Townsend restates all paragraphs of Number 4-20 as above herein that
show that action is proper within the venue and Jurisdiction of this UNITED STATES
DISTRICT COURT MIDDLE DISTRICT OF FLORIDA and Because each Defendant
is a resident or was doing or was alleging to do official duties, on duty and off duty
as law enforcement or as officers of the courts and this court is a proper venue for this
action as stated above herein.
403. This is an action for damages in excess of $ 25,000.00 and is within the jurisdiction
of this court.
404. On or about September 8, 1999, and still through current times and at all other times
as stated above and herein at the First Baptist Church of Citrus Park at 7705 Gunn
Highway, Tampa Florida, and at 18105 Gunn Highway, Tampa Florida and at the Court
Room of Judge Raul Palomino of Hillsborough County on November 15, 2001, by
individual and as Deputy Joe Howlett(Howlett) and by Howlett at Citrus Park Town
Center Mall on numerous occasions and by Mike Shar at Kmart in Sarasota, Florida and
by each Defendant in Count XIII, herein and on surrounding roads at or about Gunn
Highway at or around the Citrus Park Baptist Church Defendant assaulted Plaintiff in that

328

Defendants Howlett and Smoak did use their Deputy Crusiers at times with lights
flashing to impede the peaceful operation of Plaintiff Townsend in or out side of his
vehicle to deter, inflict shame and harassment and abuse and Deputy Howlett even on
occasions would attempt to coerce Plaintiff Townsend to retaliate with resistance so
Deputy Howlett could arrest Plaintiff Townsend and per the verbal under oath testimony
of Defendant Ron Beck on November 15, 2001, under oath to Judge Raul Palomino Beck
did attempt to use the alleged needed actions of Howlett and Jeffers and Smoak to allege
that Plaintiff Townsend without lawful duty or cause had to be restrained or blocked from
alleged illegal or unlawful conduct at the steps of the Church despite Plaintiff Townsend
being a member and fully and completely can prove that Plaintiff Townsend was invited
by several members to address in open forum business meeting process per the BYLAWS duty the issues of frauds and corruption of these Pastors and these same deputies
as alleged Trustees. Plaintiff states that each deputy and officer at all times herein and in
all paragraphs above and below appeared to each plaintiff to be acting in their official
mask or uniform as an officer of the law and that all deputies and officers acted to
appear to be within their official roles in order to inflict conspired control, restraint and
protection of Plaintiff Townsend to others. Plaintiff Townsend alleges that even Corbin
did publicly yell and abuse Plaintiff Townsend to make a public scene for the alleged
protection of others despite Corbin as a member of the LRPC Committee fully knowing
the pure motives of Plaintiff Townsend. Defendants, while arguing at Plaintiff over
Church issues and pastor and others criminal actions and frauds, would yell publicly,
chase plaintiff Townsend on foot and in official vehicles and attempted to at times even
in uniform cause or Ordered Plaintiff Townsend from his car so Deputies could show

329

alleged protection and deceptions and frauds and omissions of truthful disclosure and
misappropriation of their vested Corporation and Citizens rights to others as these Minor
Plaintiffs herein and possibly entice Plaintiff Townsend to resist the harassment and
abuse so to cause additional emotional distress to the Minor Plaintiffs herein. Defendant
Jeffers even did Touch the Wife of Plaintiff Townsend on the steps of the Church and led
her away from talking to Plaintiff Townsend so to make appear that persons were in
danger. Defendant Howlett at times stood in front of Plaintiff, who was in his car,
blocking him in his seat. Defendant then threatened to arrest Plaintiff and raised his hand
to his gun belt as if to need against Plaintiff, all the while standing over Plaintiff and
leaving Plaintiff no avenue of escape.
405. Defendant intended to cause apprehension of imminent harm in Plaintiffs in that
Defendant Beck had advised Plaintiff Townsend show that defendant's acts were intended
as Defendant Beck stated he would file charges if Plaintiff tried to speak in Church
meetings or attend Church or School services and business meetings or school functions
and as told to judge Palomino on November 15, 2001, by Defendant Ron Beck and
Defendant Employee Karen Harrod Townsend. Defendant approached Plaintiff, who was
seated many times in his car, with no intent to harm anyone would be approached and
engaged by Defendants threatening to cause violent physical injury by arrest, and then
use police type car chases, traffic stops with lights flashing, intervention at the Church
Steps prohibiting Plaintiff now fully known to have always been a member of the
Corporations with rights not restricted by the Courts but only on November 2-15, 2001,
and by Deputy Howlett making false allegations to Curtis Baughman and attending the
Court of Judge Palomino stating willingly to give false testimony and , thereby causing

330

Plaintiff to feel threatened with imminent bodily injury and place him in apprehension for
his safety and fear of going to prison. Furthermore, Defendant's acts were substantially
certain to result in apprehension of imminent harm in Plaintiff.
406. Because Defendant Howlett made intentional threats to Plaintiff, on April 27, 2000
to get your hands on the table, prohibited discovery of FBCCP Materials, prohibited
Townsend from the April 30, 2000,Business Meeting and in traffic stops would require
Plaintiff to flee the property while just sitting waiting for his children or be chased by
Deputy Howlett, Deputy Smoaks and being yelled at and repeatedly chased by Defendant
Ron Beck in his vehicle even at one time with a visiting evangelist willing to verbally
communicate the threats and chase to pastors at Idlewild Baptist Church and was not
restrained in his movements as Plaintiff was, Defendant had the apparent present ability
to harm Plaintiff as he was threatening to do and as a direct and proximate result, Plaintiff
reasonably feared that Defendant would imminently inflict bodily harm on or put Plaintiff
in jail.
407. As a direct and proximate result of Defendant's conduct, Plaintiff was injured in that
Plaintiffs were frightened and excited, resulting in a mental and nervous injury that has
caused Plaintiff great emotional pain and suffering and loss of his family and loss of his
relationship now freely per his civil rights with his children since October 20, 1999, and
now having not been able to see his children now since November 8, 2002 and reputation
and employment and loss of future ability to earn income and reduction in ability to earn
income and defamation and slander.
408. As a further direct and proximate result of Defendant's conduct, Plaintiff has been
damaged in the yet undetermined amount of financial damages for the cost of medical

331

bills, and for lost earnings and the ability to create employment and earnings.
WHEREFORE, Plaintiff demands judgment as follows:
A. For general damages.
B. For punitive damages.
C. For intentional infliction of emotional distress

D. For costs of suit incurred in this action.

E. For other and further relief as the Court may deem proper.
COUNT XXXX
FRAUD AGAINST DEFENDANTS DEPUTY JOE HOWLETT, DEPUTY TIM
JEFFERS, DEPUTY JOHN MICHEAL CORBIN, DEPUTY MIKE SMOAK,
TAMPA POLICE OFFICER JOE KAREAS AND OFFICER MIKE SHAR FOR
ACTS AGAINST PLAINTIFF RANDALL TOWNSEND
409.

Comes Now Plaintiff, Randall Townsend individual, and sues Defendants Joe

Howlett, Tim Jeffers, John Micheal Corbin, Mike Smoak, Joe Kareas and Mike Shar as
individuals and as Law Enforcement, Sheriff Deputies and Police officers and for all
Minor Plaintiffs and reallege all paragraphs above and below and incorporates herein and
alleges:
410. Plaintiff, Randall Townsend, is an individual residing at relevant times in
Hillsborough, Sarasota and Pinellas Countys of Florida within the jurisdiction of
the UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA and
with rights as a citizen and FBCCP member now not able to be fully known until the
production of FBCCP Business Records in June/July 2006, to have Constitutional and
BY-LAWS rights to Speech, Assembly, No Child interference with his fathers rights, and
Religious freedoms and for life, liberty and pursuit of happiness but to conceal the frauds
of pastors and sheriff deputies as masked trustees these defendants did use their Law
Enforcement uniforms as masks that all activities of themselves and these clergy and
attorneys and judges were lawful and now proved fraud, and collusion as stated herein.

332

411.Defendants Joe Howlett, Tim Jeffers, John Micheal Corbin, Mike Smoak, Joe
Kareas and Mike Shar are individuals residing within the Counties of Hillsborough and
Pasco of, Florida and working or were working at their times of actions or were on
duty or off duty and or now retired as law enforcement within the Counties of
Hillsborough, Pasco and Pinellas of Florida and within the jurisdiction of the State of
Florida and of this UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF
FLORIDA.
412. Plaintiff Townsend restates all paragraphs of Number 4-20 as above herein that
show that action is proper within the venue and Jurisdiction of this UNITED STATES
DISTRICT COURT MIDDLE DISTRICT OF FLORIDA and Because each Defendant
is a resident or was doing or was alleging to do official duties, on duty and off duty
as law enforcement or as officers of the courts and this court is a proper venue for this
action as stated above herein.
413. This is an action for damages in excess of $ 25,000.00 and is within the jurisdiction
of this court.
414. On or about September 8, 1999, and still through current times and at all other times
as stated above and herein at the First Baptist Church of Citrus Park at 7705 Gunn
Highway, Tampa Florida, and at 18105 Gunn Highway, Tampa Florida and at the Court
Room of Judge Raul Palomino of Hillsborough County on November 15, 2001, by
individual and as Deputy Joe Howlett(Howlett) and by Howlett at Citrus Park Town
Center Mall on numerous occasions and by Mike Shar at Kmart in Sarasota, Florida and
by each Defendant in Count XIII, herein and on surrounding roads at or about Gunn
Highway at or around the Citrus Park Baptist Church Defendant assaulted Plaintiff in that

333

Defendants Howlett and Smoak did use their Deputy Crusiers at times with lights
flashing to impede the peaceful operation of Plaintiff Townsend in or out side of his
vehicle to deter, inflict shame and harassment and abuse and Deputy Howlett even on
occasions would attempt to coerce Plaintiff Townsend to retaliate with resistance so
Deputy Howlett could arrest Plaintiff Townsend and per the verbal under oath testimony
of Defendant Ron Beck on November 15, 2001, under oath to Judge Raul Palomino Beck
did attempt to use the alleged needed actions of Howlett and Jeffers and Smoak to allege
that Plaintiff Townsend without lawful duty or cause had to be restrained or blocked from
alleged illegal or unlawful conduct at the steps of the Church despite Plaintiff Townsend
being a member and fully and completely can prove that Plaintiff Townsend was invited
by several members to address in open forum business meeting process per the BYLAWS duty the issues of frauds and corruption of these Pastors and these same deputies
as alleged Trustees. Plaintiff states that each deputy and officer at all times herein and in
all paragraphs above and below appeared to each plaintiff to be acting in their official
mask or uniform as an officer of the law and that all deputies and officers acted to
appear to be within their official roles in order to inflict conspired control, restraint and
protection of Plaintiff Townsend to others. Plaintiff Townsend alleges that even Corbin
did publicly yell and abuse Plaintiff Townsend to make a public scene for the alleged
protection of others despite Corbin as a member of the LRPC Committee fully knowing
the pure motives of Plaintiff Townsend. Defendants, while arguing at Plaintiff over
Church issues and pastor and others criminal actions and frauds, would yell publicly,
chase plaintiff Townsend on foot and in official vehicles and attempted to at times even
in uniform cause or Ordered Plaintiff Townsend from his car so Deputies could show

334

alleged protection and deceptions and frauds and omissions of truthful disclosure and
misappropriation of their vested Corporation and Citizens rights to others as these Minor
Plaintiffs herein and possibly entice Plaintiff Townsend to resist the harassment and
abuse so to cause additional emotional distress to the Minor Plaintiffs herein. Defendant
Jeffers even did Touch the Wife of Plaintiff Townsend on the steps of the Church and led
her away from talking to Plaintiff Townsend so to make appear that persons were in
danger. Defendant Howlett at times stood in front of Plaintiff, who was in his car,
blocking him in his seat. Defendant then threatened to arrest Plaintiff and raised his hand
to his gun belt as if to need against Plaintiff, all the while standing over Plaintiff and
leaving Plaintiff no avenue of escape.
415. Defendant intended to cause apprehension of imminent harm in Plaintiffs in that
Defendant Beck had advised Plaintiff Townsend show that defendant's acts were intended
as Defendant Beck stated he would file charges if Plaintiff tried to speak in Church
meetings or attend Church or School services and business meetings or school functions
and as told to judge Palomino on November 15, 2001, by Defendant Ron Beck and
Defendant Employee Karen Harrod Townsend. Defendant approached Plaintiff, who was
seated many times in his car, with no intent to harm anyone would be approached and
engaged by Defendants threatening to cause violent physical injury by arrest, and then
use police type car chases, traffic stops with lights flashing, intervention at the Church
Steps prohibiting Plaintiff now fully known to have always been a member of the
Corporations with rights not restricted by the Courts but only on November 2-15, 2001,
and by Deputy Howlett making false allegations to Curtis Baughman and attending the
Court of Judge Palomino stating willingly to give false testimony and , thereby causing

335

Plaintiff to feel threatened with imminent bodily injury and place him in apprehension for
his safety and fear of going to prison. Furthermore, Defendant's acts were substantially
certain to result in apprehension of imminent harm in Plaintiff.
416. Because Defendant Howlett made intentional threats to Plaintiff, on April 27, 2000
to get your hands on the table, prohibited discovery of FBCCP Materials, prohibited
Townsend from the April 30, 2000,Business Meeting and in traffic stops would require
Plaintiff to flee the property while just sitting waiting for his children or be chased by
Deputy Howlett, Deputy Smoaks and being yelled at and repeatedly chased by Defendant
Ron Beck in his vehicle even at one time with a visiting evangelist willing to verbally
communicate the threats and chase to pastors at Idlewild Baptist Church and was not
restrained in his movements as Plaintiff was, Defendant had the apparent present ability
to harm Plaintiff as he was threatening to do and as a direct and proximate result, Plaintiff
reasonably feared that Defendant would imminently inflict bodily harm on or put Plaintiff
in jail.
417. As a direct and proximate result of Defendant's conduct, Plaintiff was injured in that
Plaintiffs were frightened and excited, resulting in a mental and nervous injury that has
caused Plaintiff great emotional pain and suffering and loss of his family and loss of his
relationship now freely per his civil rights with his children since October 20, 1999, and
now having not been able to see his children now since November 8, 2002 and reputation
and employment and loss of future ability to earn income and reduction in ability to earn
income and defamation and slander.
418.

As a further direct and proximate result of Defendant's conduct, Plaintiff has been

damaged in the yet undetermined amount of financial damages for the cost of medical

336

bills, and for lost earnings and the ability to create employment and earnings.
WHEREFORE, Plaintiff demands judgment as follows:
A. For general damages.
B. For punitive damages.
C. For intentional infliction of emotional distress
D. For costs of suit incurred in this action.

E. For other and further relief as the Court may deem proper.
COUNT XXXXI
ABUSE OF PROCESS AGAINST DEFENDANTS DEFENDANTS THE OFFICE
OF THE GOVERNOR OF THE STATE OF FLORIDA FOR ACTS OF JEB BUSH
AND CHARLIE CRIST AND DEFENDANTS THE OFFICE OF THE
ATTORNEY GENERAL FOR ACTS OF CHARLIE CRIST AND THE OFFICE
OF THE DEPARTMENT OF FINANCIAL SERVICES FOR THE ACTS OF TOM
GALLAGHER AND THE OFFICE OF THE STATE ATTORNEY FOR THE
ACTS OF MARK A. OBER AND THE ACTS OF CURTIS BAUGHMAN AND
THE SANTA ROSA SHERIFF DEPARTMENT FOR THE ACTS OF DEPUTY
WHEELER AND HILLSBOROUGH SHERIFF DEPARTMENT AND PASCO
SHERIFF DEPARTMENT AND PINELLAS SHERIFF DEPARTMENT AND
FOR THE CITY OF TAMPA POLICE DEPARTMENT DEPUTY JOE
HOWLETT, DEPUTY TIM JEFFERS, DEPUTY JOHN MICHEAL CORBIN,
DEPUTY MIKE SMOAK, TAMPA POLICE OFFICER JOE KAREAS AND
OFFICER MIKE SHAR AND FDLE FOR ACTS OF AGENTS CINDY SANZ
AND GERALD BAILEY AND THE JUDICIAL QUALIFICATIONS
COMMISSION FOR ACTS OF BROOK S. KENNERLY AND THE FLORIDA
BAR FOR ACTS OF THE EXECUTIVE DIRECTOR AND THE OFFICER OF
THE TAMPA BRANCH AND FOR MS. LIEMAN AND FOR JANE CRISTY AND
THE DEPARTMENT OF CHILDREN AND FAMILIES FOR THE ACTS OF
EXECUTIVE DIRECTOR FOR ACTS AGAINST PLAINTIFF RANDALL
TOWNSEND AND AS ALL MINOR CHILDREN AS MEMBERS OF FBCCP
AND CPCS
419. Comes Now Plaintiff, Randall Townsend individual, and sues DEFENDANTS
THE OFFICE OF THE GOVERNOR OF THE STATE OF FLORIDA FOR ACTS OF
JEB BUSH AND CHARLIE CRIST AND DEFENDANTS THE OFFICE OF THE
ATTORNEY GENERAL FOR ACTS OF CHARLIE CRIST AND THE OFFICE OF
THE DEPARTMENT OF FINANCIAL SERVICES FOR THE ACTS OF TOM

337

GALLAGHER AND THE OFFICE OF THE STATE ATTORNEY FOR THE ACTS OF
MARK A. OBER AND THE ACTS OF CURTIS BAUGHMAN AND THE SANTA
ROSA SHERIFF DEPARTMENT FOR THE ACTS OF DEPUTY WHEELER AND
HILLSBOROUGH SHERIFF DEPARTMENT AND PASCO SHERIFF
DEPARTMENT AND PINELLAS SHERIFF DEPARTMENT AND FOR THE CITY
OF TAMPA POLICE DEPARTMENT DEPUTY JOE HOWLETT, DEPUTY TIM
JEFFERS, DEPUTY JOHN MICHEAL CORBIN, DEPUTY MIKE SMOAK, TAMPA
POLICE OFFICER JOE KAREAS AND OFFICER MIKE SHAR AND FDLE FOR
ACTS OF AGENTS CINDY SANZ AND GERALD BAILEY AND THE JUDICIAL
QUALIFICATIONS COMMISSION FOR ACTS OF BROOK S. KENNERLY AND
THE FLORIDA BAR FOR ACTS OF THE EXECUTIVE DIRECTOR AND THE
OFFICER OF THE TAMPA BRANCH AND FOR MS. LIEMAN AND FOR JANE
CRISTY AND THE DEPARTMENT OF CHILDREN AND FAMILIES FOR THE
ACTS OF EXECUTIVE DIRECTOR FOR ACTS AGAINST PLAINTIFF RANDALL
TOWNSEND AND AS ALL MINOR CHILDREN AS MEMBERS OF FBCCP AND
CPCS and reallege all paragraphs above and below and incorporates herein and alleges:
420. Plaintiffs Townsend, and minor plaintiffs are individual residing at relevant times in
Hillsborough, Sarasota and Pinellas Countys of Florida within the jurisdiction of
the UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA and
with rights as a citizen and FBCCP member now not able to be fully known until the
production of FBCCP Business Records in June/July 2006, to have Constitutional and
BY-LAWS rights to Speech, Assembly, No Child interference with his fathers rights, and
Religious freedoms and for life, liberty and pursuit of happiness but to conceal the frauds

338

of pastors and sheriff deputies as masked trustees these defendants did use their Law
Enforcement uniforms as masks that all activities of themselves and these clergy and
attorneys and judges were lawful and now proved fraud, and collusion as stated herein.
421. Defendants Joe Howlett, Tim Jeffers, John Micheal Corbin, Mike Smoak, Joe

339

Kareas and Mike Shar are individuals residing within the Counties of Hillsborough and
Pasco of, Florida and working or were working at their times of actions or were on
duty or off duty and or now retired as law enforcement within the Counties of
Hillsborough, Pasco and Pinellas of Florida and within the jurisdiction of the State of
Florida and of this UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF
FLORIDA, Plaintiffs allege each defendant herein owed a Federal and State
Constitutional Duty to Act for these Plaintiffs and refused to act as fully stated herein this
full complaint and now incorporated herein.
422. Plaintiff Townsend restates all paragraphs of Number 4-20 as above herein that
show that action is proper within the venue and Jurisdiction of this UNITED STATES
DISTRICT COURT MIDDLE DISTRICT OF FLORIDA and Because each Defendant
is a resident or was doing or was alleging to do official duties, on duty and off duty
as law enforcement or as officers of the courts and this court is a proper venue for this
action as stated above herein.
423. This is an action for damages in excess of $ 25,000.00 and is within the jurisdiction
of this court.
424. On or about September 8, 1999, and still through current times and at all other times
as stated above and herein at the First Baptist Church of Citrus Park at 7705 Gunn
Highway, Tampa Florida, and at 18105 Gunn Highway, Tampa Florida and at the Court
Room of Judge Raul Palomino of Hillsborough County on November 15, 2001, by
individual and as Deputy Joe Howlett(Howlett) and by Howlett at Citrus Park Town
Center Mall on numerous occasions and by Mike Shar at Kmart in Sarasota, Florida and
by each Defendant in Count XIII, herein and on surrounding roads at or about Gunn

340

Highway at or around the Citrus Park Baptist Church Defendant assaulted Plaintiff in that
Defendants Howlett and Smoak did use their Deputy Crusiers at times with lights
flashing to impede the peaceful operation of Plaintiff Townsend in or out side of his
vehicle to deter, inflict shame and harassment and abuse and Deputy Howlett even on
occasions would attempt to coerce Plaintiff Townsend to retaliate with resistance so
Deputy Howlett could arrest Plaintiff Townsend and per the verbal under oath testimony
of Defendant Ron Beck on November 15, 2001, under oath to Judge Raul Palomino Beck
did attempt to use the alleged needed actions of Howlett and Jeffers and Smoak to allege
that Plaintiff Townsend without lawful duty or cause had to be restrained or blocked from
alleged illegal or unlawful conduct at the steps of the Church despite Plaintiff Townsend
being a member and fully and completely can prove that Plaintiff Townsend was invited
by several members to address in open forum business meeting process per the BYLAWS duty the issues of frauds and corruption of these Pastors and these same deputies
as alleged Trustees. Plaintiff states that each deputy and officer at all times herein and in
all paragraphs above and below appeared to each plaintiff to be acting in their official
mask or uniform as an officer of the law and that all deputies and officers acted to
appear to be within their official roles in order to inflict conspired control, restraint and
protection of Plaintiff Townsend to others. Plaintiff Townsend alleges that even Corbin
did publicly yell and abuse Plaintiff Townsend to make a public scene for the alleged
protection of others despite Corbin as a member of the LRPC Committee fully knowing
the pure motives of Plaintiff Townsend. Defendants, while arguing at Plaintiff over
Church issues and pastor and others criminal actions and frauds, would yell publicly,
chase plaintiff Townsend on foot and in official vehicles and attempted to at times even

341

in uniform cause or Ordered Plaintiff Townsend from his car so Deputies could show
alleged protection and deceptions and frauds and omissions of truthful disclosure and
misappropriation of their vested Corporation and Citizens rights to others as these Minor
Plaintiffs herein and possibly entice Plaintiff Townsend to resist the harassment and
abuse so to cause additional emotional distress to the Minor Plaintiffs herein. Defendant
Jeffers even did Touch the Wife of Plaintiff Townsend on the steps of the Church and led
her away from talking to Plaintiff Townsend so to make appear that persons were in
danger. Defendant Howlett at times stood in front of Plaintiff, who was in his car,
blocking him in his seat. Defendant then threatened to arrest Plaintiff and raised his hand
to his gun belt as if to need against Plaintiff, all the while standing over Plaintiff and
leaving Plaintiff no avenue of escape.
425. Defendant intended to cause apprehension of imminent harm in Plaintiffs in that
Defendant Beck had advised Plaintiff Townsend show that defendant's acts were intended
as Defendant Beck stated he would file charges if Plaintiff tried to speak in Church
meetings or attend Church or School services and business meetings or school functions
and as told to judge Palomino on November 15, 2001, by Defendant Ron Beck and
Defendant Employee Karen Harrod Townsend. Defendant approached Plaintiff, who was
seated many times in his car, with no intent to harm anyone would be approached and
engaged by Defendants threatening to cause violent physical injury by arrest, and then
use police type car chases, traffic stops with lights flashing, intervention at the Church
Steps prohibiting Plaintiff now fully known to have always been a member of the
Corporations with rights not restricted by the Courts but only on November 2-15, 2001,
and by Deputy Howlett making false allegations to Curtis Baughman and attending the

342

Court of Judge Palomino stating willingly to give false testimony and , thereby causing
Plaintiff to feel threatened with imminent bodily injury and place him in apprehension for
his safety and fear of going to prison. Furthermore, Defendant's acts were substantially
certain to result in apprehension of imminent harm in Plaintiff.
426. Because Defendant Howlett made intentional threats to Plaintiff, on April 27, 2000
to get your hands on the table, prohibited discovery of FBCCP Materials, prohibited
Townsend from the April 30, 2000,Business Meeting and in traffic stops would require
Plaintiff to flee the property while just sitting waiting for his children or be chased by
Deputy Howlett, Deputy Smoaks and being yelled at and repeatedly chased by Defendant
Ron Beck in his vehicle even at one time with a visiting evangelist willing to verbally
communicate the threats and chase to pastors at Idlewild Baptist Church and was not
restrained in his movements as Plaintiff was, Defendant had the apparent present ability
to harm Plaintiff as he was threatening to do and as a direct and proximate result, Plaintiff
reasonably feared that Defendant would imminently inflict bodily harm on or put Plaintiff
Townsend in jail so Plaintiff Townsend could not protect and serve per his Duties.
427. Defendants did each knowingly intentionally and recklessly refuse to act to prohibit
frauds and deceptions in the FBCCP Corporation, (CHURCH & SCHOOL), Courts and
in the Surrounding Communities that each Officer, Agent, Agency, Department is sworn
by Law to protect and serve per the Florida Statues as stated and incorporated herein but
each has refused to doe their duty and refused to act and refused to accept jurisdiction and
thus allow frauds and crimes to continue that still damage these Plaintiffs herein and each
continues and refuses to act even after contacts within a reasonable time as required as
conditions precedent to the filing of this Amended Complaint.

343

428. As a direct and proximate result of Defendant's conduct, Plaintiffs are injured in that
Plaintiffs were frightened and excited, resulting in a mental and nervous injury that has
caused Plaintiffs great emotional pain and suffering and loss of family and loss of their
relationship now freely per civil rights with his children since October 20, 1999, and
now having not been able to see his children now since November 8, 2002 and reputation
and employment and loss of future ability to earn income and reduction in ability to earn
income and defamation and slander or to protect the Corporation assets so to provide
benefits, education and training so all citizens may continue in a productive life, liberty
and pursuit of happiness without the duress of these Defendants as violators of the law.
429.

As a further direct and proximate result of Defendant's conduct, Plaintiff has been

damaged in the yet undetermined amount of financial damages for the cost of medical
bills, and for lost earnings and the ability to create employment and earnings.
WHEREFORE, Plaintiff demands judgment as follows:
A. For general damages.
B. For punitive damages.
C. For intentional infliction of emotional distress
D. For costs of suit incurred in this action.
E. For other and further relief as the Court may deem proper.
COUNT XXXXII
CLAIM FOR NEGLIGENT SUPERVISION AGAINST DEFENDANTS
HILLSBOROUGH SHERIFF DEPARTMENT AND PASCO SHERIFF
DEPARTMENT AND PINELLAS SHERIFF DEPARTMENT AND FOR THE
CITY OF TAMPA POLICE DEPARTMENT FOR ACTIONS OF DEPUTY JOE
HOWLETT, DEPUTY TIM JEFFERS, DEPUTY JOHN MICHEAL CORBIN,
DEPUTY MIKE SMOAK, TAMPA POLICE OFFICER JOE KAREAS AND
OFFICER MIKE SHAR FOR ACTS AGAINST PLAINTIFFS AS ALL MINOR
CHILDREN AS MEMBERS OF FBCCP AND CPCS AND AGAINST PLAINTIFF
RANDALL TOWNSEND
430. Comes Now Plaintiff, Randall Townsend individual, and sues DEFENDANTS

344

HILLSBOROUGH SHERIFF DEPARTMENT AND PASCO SHERIFF

DEPARTMENT AND PINELLAS SHERIFF DEPARTMENT AND FOR THE CITY
OF TAMPA POLICE DEPARTMENT FOR NEGLIGENT SUPERVISION OF AND
OF TRAINING OF Defendants Joe Howlett, Tim Jeffers, John Micheal Corbin, Mike
Smoak, Joe Kareas and Mike Shar as individuals and as Law Enforcement, Sheriff
Deputies and Police officers and for all Minor Plaintiffs AND AGAINST PLAINTIFF
RANDALL TOWNSEND and reallege all paragraphs above and below and incorporates
herein and alleges:
431. Plaintiff, Randall Townsend, is an individual residing at relevant times in
Hillsborough, Sarasota and Pinellas Countys of Florida within the jurisdiction of
the UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA and
with rights as a citizen and FBCCP member now not able to be fully known until the
production of FBCCP Business Records in June/July 2006, to have Constitutional and
BY-LAWS rights to Speech, Assembly, No Child interference with his fathers rights, and
Religious freedoms and for life, liberty and pursuit of happiness but to conceal the frauds
of pastors and sheriff deputies as masked trustees these defendants did use their Law
Enforcement uniforms as masks that all activities of themselves and these clergy and
attorneys and judges were lawful and now proved fraud, and collusion as stated herein.
433. Defendants Joe Howlett, Tim Jeffers, John Micheal Corbin, Mike Smoak, Joe

345

Kareas and Mike Shar are individuals residing within the Counties of Hillsborough and
Pasco of, Florida and working or were working at their times of actions or were on
duty or off duty and or now retired as law enforcement within the Counties of
Hillsborough, Pasco and Pinellas of Florida and within the jurisdiction of the State of
Florida and of this UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF
FLORIDA.
444. Plaintiff Townsend restates all paragraphs of Number 4-20 as above herein that
show that action is proper within the venue and Jurisdiction of this UNITED STATES
DISTRICT COURT MIDDLE DISTRICT OF FLORIDA and Because each Defendant
is a resident or was doing or was alleging to do official duties, on duty and off duty
as law enforcement or as officers of the courts and this court is a proper venue for this
action as stated above herein.
445. This is an action for damages in excess of $ 25,000.00 and is within the jurisdiction
of this court.
446. On or about September 8, 1999, and still through current times and at all other times
as stated above and herein at the First Baptist Church of Citrus Park at 7705 Gunn
Highway, Tampa Florida, and at 18105 Gunn Highway, Tampa Florida and at the Court
Room of Judge Raul Palomino of Hillsborough County on November 15, 2001, by
individual and as Deputy Joe Howlett(Howlett) and by Howlett at Citrus Park Town
Center Mall on numerous occasions and by Mike Shar at Kmart in Sarasota, Florida and
by each Defendant in Count XIII, herein and on surrounding roads at or about Gunn
Highway at or around the Citrus Park Baptist Church Defendant assaulted Plaintiff in that
Defendants Howlett and Smoak did use their Deputy Crusiers at times with lights

346

flashing to impede the peaceful operation of Plaintiff Townsend in or out side of his
vehicle to deter, inflict shame and harassment and abuse and Deputy Howlett even on
occasions would attempt to coerce Plaintiff Townsend to retaliate with resistance so
Deputy Howlett could arrest Plaintiff Townsend and per the verbal under oath testimony
of Defendant Ron Beck on November 15, 2001, under oath to Judge Raul Palomino Beck
did attempt to use the alleged needed actions of Howlett and Jeffers and Smoak to allege
that Plaintiff Townsend without lawful duty or cause had to be restrained or blocked from
alleged illegal or unlawful conduct at the steps of the Church despite Plaintiff Townsend
being a member and fully and completely can prove that Plaintiff Townsend was invited
by several members to address in open forum business meeting process per the BYLAWS duty the issues of frauds and corruption of these Pastors and these same deputies
as alleged Trustees. Plaintiff states that each deputy and officer at all times herein and in
all paragraphs above and below appeared to each plaintiff to be acting in their official
mask or uniform as an officer of the law and that all deputies and officers acted to
appear to be within their official roles in order to inflict conspired control, restraint and
protection of Plaintiff Townsend to others. Plaintiff Townsend alleges that even Corbin
did publicly yell and abuse Plaintiff Townsend to make a public scene for the alleged
protection of others despite Corbin as a member of the LRPC Committee fully knowing
the pure motives of Plaintiff Townsend. Defendants, while arguing at Plaintiff over
Church issues and pastor and others criminal actions and frauds, would yell publicly,
chase plaintiff Townsend on foot and in official vehicles and attempted to at times even
in uniform cause or Ordered Plaintiff Townsend from his car so Deputies could show
alleged protection and deceptions and frauds and omissions of truthful disclosure and

347

misappropriation of their vested Corporation and Citizens rights to others as these Minor
Plaintiffs herein and possibly entice Plaintiff Townsend to resist the harassment and
abuse so to cause additional emotional distress to the Minor Plaintiffs herein. Defendant
Jeffers even did Touch the Wife of Plaintiff Townsend on the steps of the Church and led
her away from talking to Plaintiff Townsend so to make appear that persons were in
danger. Defendant Howlett at times stood in front of Plaintiff, who was in his car,
blocking him in his seat. Defendant then threatened to arrest Plaintiff and raised his hand
to his gun belt as if to need against Plaintiff, all the while standing over Plaintiff and
leaving Plaintiff no avenue of escape.
447. Defendant intended to cause apprehension of imminent harm in Plaintiffs in that
Defendant Beck had advised Plaintiff Townsend show that defendant's acts were intended
as Defendant Beck stated he would file charges if Plaintiff tried to speak in Church
meetings or attend Church or School services and business meetings or school functions
and as told to judge Palomino on November 15, 2001, by Defendant Ron Beck and
Defendant Employee Karen Harrod Townsend. Defendant approached Plaintiff, who was
seated many times in his car, with no intent to harm anyone would be approached and
engaged by Defendants threatening to cause violent physical injury by arrest, and then
use police type car chases, traffic stops with lights flashing, intervention at the Church
Steps prohibiting Plaintiff now fully known to have always been a member of the
Corporations with rights not restricted by the Courts but only on November 2-15, 2001,
and by Deputy Howlett making false allegations to Curtis Baughman and attending the
Court of Judge Palomino stating willingly to give false testimony and , thereby causing
Plaintiff to feel threatened with imminent bodily injury and place him in apprehension for

348

his safety and fear of going to prison. Furthermore, Defendant's acts were substantially
certain to result in apprehension of imminent harm in Plaintiff.
448. Because Defendant Howlett made intentional threats to Plaintiff, on April 27, 2000
to get your hands on the table, prohibited discovery of FBCCP Materials, prohibited
Townsend from the April 30, 2000,Business Meeting and in traffic stops would require
Plaintiff to flee the property while just sitting waiting for his children or be chased by
Deputy Howlett, Deputy Smoaks and being yelled at and repeatedly chased by Defendant
Ron Beck in his vehicle even at one time with a visiting evangelist willing to verbally
communicate the threats and chase to pastors at Idlewild Baptist Church and was not
restrained in his movements as Plaintiff was, Defendant had the apparent present ability
to harm Plaintiff as he was threatening to do and as a direct and proximate result, Plaintiff
reasonably feared that Defendant would imminently inflict bodily harm on or put Plaintiff
in jail.
449. As a direct and proximate result of Defendant's conduct, Plaintiff was injured in that
Plaintiffs were frightened and excited, resulting in a mental and nervous injury that has
caused Plaintiff great emotional pain and suffering and loss of his family and loss of his
relationship now freely per his civil rights with his children since October 20, 1999, and
now having not been able to see his children now since November 8, 2002 and reputation
and employment and loss of future ability to earn income and reduction in ability to earn
income and defamation and slander.
450.

As a further direct and proximate result of Defendant's conduct, Plaintiff has been

damaged in the yet undetermined amount of financial damages for the cost of medical

349

bills, and for lost earnings and the ability to create employment and earnings.
WHEREFORE, Plaintiff demands judgment as follows:
A. For general damages.
B. For punitive damages.
C. For intentional infliction of emotional distress
D. For costs of suit incurred in this action.

E. For other and further relief as the Court may deem proper.
COUNT XXXXIII
COMPLAINT FOR VICARIOUS LIABILITY OF
PROFESSIONAL CORPORATION FOR MALPRACTICE OF MEMBER
ATTORNEY and VIOLATIONS OF RESPONDENT SUPERIOR--AGAINST DEFENDANTS JOHN A. GRANT JR. ATTORNEY AND JOHN A
GRANT, JR ATTORNEY AT LAW AND JOHN A GRANT, JR. REGISTERED
AGENT AS OF JOHN A GRANT, JR. INDIVIDUAL
451. Plaintiffs reallege all paragraphs all preliminary allegations and subsequent
allegations as stated herein and incorporate these allegations herein by reference.
452. Plaintiff state that the acts as stated herein of Attorney John A. Grant Jr. and John A.
Grant, Jr. Individual and John A Grant, JR. Registered Agent were practices in violations
of laws and Rules of Civil Procedure and Rules of Judicial Procedure and that JOHN A
GRANT JR. ATTORNEY AT LAW, P.A. knowingly, intentionally, recklessly and
negligently participated in the deceptions, frauds, omissions of truthful disclosures and
acts as stated herein to these clients and to the courts and law enforcement officers.
453.Plaintiffs as Clients reasonably relied on defendants representations and omissions
and as a proximate result thereof were deceived as to file causes of actions and promote
causes of available actions and protections from violations continuing of the Florida
Statues as stated in Section 5 above herein and was damaged and is continued to be
damaged and separated as a father and child now since NOVEMBER 8, 2002, by the
frauds and CONCEALMENTS and OMISSIONS OF TRUTHFUL DISCLOSURES

350

since Defendants became advocates for clients in February 2003, with knowledge and
duty to disclose attorneys, judges, pastors, law enforcement and other defendants for their
violations of these clients and frauds on the courts.
454.Plaintiffs allege by the omissions of truthful disclosure and frauds against Plaintiffs
that Plaintiffs did not contribute to the damages caused by Defendants.
455.WHEREFORE, PLAINTIFFS REQUEST ALL RELIEF FOR DAMAGES AS
STATED BELOW HEREIN AND ANY OTHER RELIEF AS THIS COURT DEEMS
PROPER.
COUNT XXXXIV
COMPLAINT FOR MALPRACTICE OF MEMBER ATTORNEY AS
VIOLATIONS BY THEORY OF RESPONDENT SUPERIOR---AGAINST
DEFENDANTS JOHN A. GRANT JR. ATTORNEY AND JOHN A GRANT, JR
ATTORNEY AT LAW AND JOHN A GRANT, JR. REGISTERED AGENT AS OF
JOHN A GRANT, JR. INDIVIDUAL
456. Plaintiffs reallege all paragraphs all preliminary allegations and subsequent
allegations as stated herein and incorporate these allegations herein by reference.
457. Plaintiff state that the acts as stated herein of Attorney John A. Grant Jr. and John A.
Grant, Jr. Individual and John A Grant, JR. Registered Agent were practices in violations
of laws and Rules of Civil Procedure and Rules of Judicial Procedure and that JOHN A
GRANT JR. ATTORNEY AT LAW, P.A. knowingly, intentionally, recklessly and
negligently participated in the deceptions, frauds, omissions of truthful disclosures and
acts as stated herein to these clients and to the courts and law enforcement officers.
458. Plaintiffs as Clients reasonably relied on defendants representations and omissions
and as a proximate result thereof were deceived as to file causes of actions and promote
causes of available actions and protections from violations continuing of the Florida
Statues as stated in Section 5 above herein and was damaged and is continued to be

351

damaged and separated as a father and child now since NOVEMBER 8, 2002, by the
frauds and CONCEALMENTS and OMISSIONS OF TRUTHFUL DISCLOSURES
since Defendants became advocates for clients in February 2003, with knowledge and
duty to disclose attorneys, judges, law enforcement, pastors and others for their violations
of these clients and frauds on the courts.
459. Plaintiffs allege by the omissions of truthful disclosure and frauds against Plaintiffs
that Plaintiffs did not contribute to the damages caused by Defendants.
460. WHEREFORE, PLAINTIFFS REQUEST ALL RELIEF FOR DAMAGES AS
STATED HEREIN AND ANY OTHER RELIEF AS THIS COURT DEEMS PROPER.
WHEREFORE, plaintiff prays for judgment and relief against defendants and
each of them as follows:
A. A Declaration that each Defendants conduct violated the law as alleged in each cause
of action;
B. A Declaration to abolish the injunction section from the Court of Judge
Timmerman, limiting the rights of this Plaintiff Townsend as father to his now adult
children, J.D.T and J.G.T and restoration of all full rights and expunge all records of
these injunctions caused by fraud of the defendants to the court as revealed by Karen
Harrod Townend in December 2005, Motion to this Honorable Court no threat of
abuse molesting or any vile act exists or ever existed;
C. preliminary and permanent injunctions preventing defendants and her co-conspirators
from any future acts of abuse and slander and harassment to Plaintiffs per s. 741 F.S.
and all other Florida Statues and set severe penalties to warn Defendants and her coconspirators of future abuse to the peace of these Plaintiffs;
D. Judgement for the Plaintiff for general and compensatory damages sustained as a
result of defendants unlawful conduct;
E. For the following special damages to be awarded according to complete discovery of
all proof to the limits allowed by law:
1. For physical Pain and suffering incurred while Defendants used fraud and
2. For the Loss of parental rights by Plaintiff Randall Townsend to J.D.T and to
J.G.T and
3. For Emotional Duress and Mental Duress incurred for Defendants use of abuse
and fraud
4. For Loss of honorable reputation of Plaintiff having to endure the slander and
defamation and frauds and malice and abuse of process and malicious prosecution
and all actions per each count shown herein without counter defense by

352

Defendants to off set the malicious charges incurring all special and general
damages as stated herein and
5. For all general, compensatory and nominal damages resulting from each
Defendants conspiracy and fraud and duress and extortion with Beck and Harrods
employer, FBCCP and CPCS and by the extortion and abuse and conspiracy with
individuals and co-employees at the place of employment as listed below as these
litigants falsely charging this Plaintiff with crimes in order to hide their criminal
acts on Plaintiff Randall Townsend and on Minor J.D.T and Minor J.G.T and
Defendants conspiracy with:
a. Ron Beck, individually, and as FBCCP Corporation Member and
Officer
b. Herman Meister, individually, and as FBCCP Corporation Member and
Officer
c. Gary Leatherman, individually, and as Corporation Member and Officer
d. Joe Howlett, individually, and as Corporation Member and HCSO Deputy
e. Tim Jeffers, individually, and as Corporation Member and as PCSO Deputy
f. The FBCCP Corporation
g. The Citrus Park Christian School, employees and School Board
h. And from the FBCCP Corporation members at Large
i. From the abusive conduct practiced on these Pro Se Plaintiffs by Defendants
attorneys causing duress and fraud on these Plaintiffs by the frauds of
Defendants to attorneys, David Gibbs, III; Drew Gardner; Charles Denny, IV;
Stacey Turmel; Charles H. Scruggs, III; Heather Gray and Stanford Solomon;
j. For Special Damages in loss of reputation and loss of employment by
Plaintiff Randall Townsend in October 2005, flowing from the fraudulent
actions by Defendants
k. .For Special Damages in loss of reputation and loss of monies owed this
Plaintiff Townsend, from SunBelt Equipment Corporation, as damages of
Defendants barred litigation as advised by the State Attorney for defamation
and slander and lost earnings were at $1,000,000.00
6. For damages resulting from Defendants violation of the injunction set by Judge
Timmerman and the admitted contact by Harrod with Plaintiffs employer up until
October, 2005, and these injunctions in 2001 and 2003-current, and allegations
and contacts by these defendants did attribute to Harrods and others and thereby
defendants willful negligence and abuse, infliction of emotional duress and
harassment in the workplace and loss of employment and loss of earnings and all
future earnings because of the frauds and acts of Defendants and the contacts to
abuse this Plaintiff to this employer.
7. For Loss of Earning capacity from the damaged reputation and integrity caused by
the attacks and injunctions of Defendants to defame Plaintiff Townsend in the
public eye
8. For lost profits of the home equity valued at $100,000.00.
9. For any and all future medical fees and costs and expenses for future medical
attention for emotional, physical and mental restoration for these Plaintiffs well
being of a future relationship as parent to children and children to this Plaintiff.
10. For the cost incurred with this action

353

11. For legal costs and fees in all court cases

12. For any and all attorneys fees as Plaintiff Randall Townsend, had retained the
Attorneys Firms of CHARLES H. SCRUGGS, P.A and HEATHER M. GRAY to
represent these Plaintiffs in these actions and agreed to pay Attorneys Charles H.
Scruggs, P.A. and Heather M. Gray a reasonable attorney fee which should be
returned with interest.
13. For such and further relief as this court may deem proper
14. For any and all other Compensatory Damages
15. For CONSEQUENTIAL DAMAGES
16. Plaintiff request leave to amend pleading to request Punitive damages at time that
is just and proper per these pleadings.
17. FOR EXEMPLARY DAMAGES
18. FOR ALL NOMINAL DAMAGES
19. FOR TREBLE DAMAGES
20. AND For any and all additional sanctions, awards and retributions, this court
seems just to allow.
21. FOR A JURY TRIAL ON ALL ISSUES TRIABLE OF RIGHT BY JURY.
COUNT XXXXV
COMPLAINT FOR VICARIOUS LIABILITY OF
PROFESSIONAL CORPORATION FOR MALPRACTICE OF MEMBER
ATTORNEY and VIOLATIONS OF RESPONDENT SUPERIOR---AGAINST
DEFENDANTS DAVID GIBBS III ATTORNEY AND DREW GARDNER
ATTORNEY AND AS THE GIBBS LAW FIRM AND OR THE CHRISTIAN LAW
ASSOCIATION AS OF DAVID GIBBS III, INDIVIDUAL AND DREW
GARDNER INDIVIDUAL 461. Plaintiffs reallege all paragraphs all preliminary allegations and subsequent
allegations as stated herein and incorporate these allegations herein by reference.
462. Plaintiff state that the acts as stated herein of Attorney David Gibbs, III and David
Gibbs, III, Individual and Attorney Drew Gardner and Drew Gardner, Individual were
practices in violations of laws and Rules of Civil Procedure and Rules of Judicial
Procedure and that THE GIBBS LAW FIRM AND OR THE CHRISTIAN LAW
ASSOCIATION knowingly, intentionally, recklessly and negligently participated in the
deceptions, frauds, omissions of truthful disclosures and acts as stated herein to these
clients and to the courts and law enforcement officers.

354

463.Plaintiffs as Clients reasonably relied on defendants representations and omissions

and as a proximate result thereof were deceived as to file causes of actions and promote
causes of available actions and protections from violations continuing of the Florida
Statues as stated in Section 5 above herein and was damaged and is continued to be
damaged and separated as a father and child now since NOVEMBER 8, 2002, by the
frauds and CONCEALMENTS and OMISSIONS OF TRUTHFUL DISCLOSURES
since Defendants became advocates for clients in February 2003, with knowledge and
duty to disclose attorneys, judges, law enforcement, and other defendants for their
violations of these clients and frauds on the courts.
464. Plaintiffs allege by the omissions of truthful disclosure and frauds against Plaintiffs
that Plaintiffs did not contribute to the damages caused by Defendants.
465.WHEREFORE, PLAINTIFFS REQUEST ALL RELIEF FOR DAMAGES AS
STATED BELOW HEREIN AND ANY OTHER RELIEF AS THIS COURT DEEMS
PROPER.
COUNT XXXXVI
COMPLAINT FOR MALPRACTICE OF MEMBER ATTORNEY AS
VIOLATIONS BY THEORY OF RESPONDENT SUPERIOR---AGAINST
DEFENDANTS DAVID GIBBS III ATTORNEY AND DREW GARDNER
ATTORNEY AND AS THE GIBBS LAW FIRM AND OR AS THE CHRISTIAN
LAW ASSOCIATION AS OF DAVID GIBBS III, INDIVIDUAL AND DREW
GARDNER INDIVIDUAL
466. Plaintiffs reallege all paragraphs all preliminary allegations and subsequent
allegations as stated herein and incorporate these allegations herein by reference.
467. Plaintiff state that the acts as stated herein of Attorney David Gibbs, III and David
Gibbs, III, Individual and Attorney Drew Gardner and Drew Gardner, Individual were
practices in violations of laws and Rules of Civil Procedure and Rules of Judicial
Procedure and that THE GIBBS LAW FIRM AND OR THE CHRISTIAN LAW

355

ASSOCIATION knowingly, intentionally, recklessly and negligently participated in the

deceptions, frauds, omissions of truthful disclosures and acts as stated herein to these
clients and to the courts and law enforcement officers.
468. Plaintiffs as Clients reasonably relied on defendants representations and omissions
and as a proximate result thereof were deceived as to file causes of actions and promote
causes of available actions and protections from violations continuing of the Florida
Statues as stated in Section 5 above herein and was damaged and is continued to be
damaged and separated as a father and child now since NOVEMBER 8, 2002, by the
frauds and CONCEALMENTS and OMISSIONS OF TRUTHFUL DISCLOSURES
since Defendants became advocates for clients in February 2003, with knowledge and
duty to disclose attorneys, judges, pastors, law enforcement and other defendants for their
violations of these clients and frauds on the courts.
469. Plaintiffs allege by the omissions of truthful disclosure and frauds against Plaintiffs
that Plaintiffs did not contribute to the damages caused by Defendants.
470. WHEREFORE, PLAINTIFFS REQUEST ALL RELIEF FOR DAMAGES AS
STATED HEREIN AND ANY OTHER RELIEF AS THIS COURT DEEMS PROPER.
WHEREFORE, plaintiff prays for judgment and relief against defendants and
each of them as follows:
A. A Declaration that each Defendants conduct violated the law as alleged in each cause
of action;
B. A Declaration to abolish the injunction section from the Court of Judge
Timmerman, limiting the rights of this Plaintiff Townsend as father to his now adult
children, J.D.T and J.G.T and restoration of all full rights and expunge all records of
these injunctions caused by fraud of the defendants to the court as revealed by Karen
Harrod Townend in December 2005, Motion to this Honorable Court no threat of
abuse molesting or any vile act exists or ever existed;

356

C. preliminary and permanent injunctions preventing defendants and her co-conspirators

from any future acts of abuse and slander and harassment to Plaintiffs per s. 741 F.S.
and all other Florida Statues and set severe penalties to warn Defendants and her coconspirators of future abuse to the peace of these Plaintiffs;
D. Judgement for the Plaintiff for general and compensatory damages sustained as a
result of defendants unlawful conduct;
E. For the following special damages to be awarded according to complete discovery of
all proof to the limits allowed by law:
F. For physical Pain and suffering incurred while Defendants used fraud and
G. For the Loss of parental rights by Plaintiff Randall Townsend to J.D.T and to J.G.T
and
H. For Emotional Duress and Mental Duress incurred for Defendants use of abuse and
fraud
I. For Loss of honorable reputation of Plaintiff having to endure the slander and
defamation and frauds and malice and abuse of process and malicious prosecution
and all actions per each count shown herein without counter defense by Defendants to
off set the malicious charges incurring all special and general damages as stated
herein and
J. For all general, compensatory and nominal damages resulting from each Defendants
conspiracy and fraud and duress and extortion with Beck and Harrods employer,
FBCCP and CPCS and by the extortion and abuse and conspiracy with individuals
and co-employees at the place of employment as listed below as these litigants falsely
charging this Plaintiff with crimes in order to hide their criminal acts on Plaintiff
Randall Townsend and on Minor J.D.T and Minor J.G.T and Defendants conspiracy
with:
1. Ron Beck, individually, and as FBCCP Corporation Member and Officer
2. Herman Meister, individually, and as FBCCP Corporation Member and
Officer
3. Gary Leatherman, individually, and as Corporation Member and Officer
4. Joe Howlett, individually, and as Corporation Member and HCSO Deputy
5. Tim Jeffers, individually, and as Corporation Member and as PCSO Deputy
6. The FBCCP Corporation
7. The Citrus Park Christian School, employees and School Board
8. And from the FBCCP Corporation members at Large
9. From the abusive conduct practiced on these Pro Se Plaintiffs by Defendants
attorneys causing duress and fraud on these Plaintiffs by the frauds of
Defendants to attorneys, David Gibbs, III; Drew Gardner; Charles Denny, IV;
Stacey Turmel; Charles H. Scruggs, III; Heather Gray and Stanford Solomon;
K. For Special Damages in loss of reputation and loss of employment by Plaintiff
Randall Townsend in October 2005, flowing from the fraudulent actions by
Defendants
L. .For Special Damages in loss of reputation and loss of monies owed this Plaintiff
Townsend, from SunBelt Equipment Corporation, as damages of Defendants barred
litigation as advised by the State Attorney for defamation and slander and lost
earnings were at $1,000,000.00

357

M. For damages resulting from Defendants violation of the injunction set by Judge
Timmerman and the admitted contact by Harrod with Plaintiffs employer up until
October, 2005, and these injunctions in 2001 and 2003-current, and allegations and
contacts by these defendants did attribute to Harrods and others and thereby
defendants willful negligence and abuse, infliction of emotional duress and
harassment in the workplace and loss of employment and loss of earnings and all
future earnings because of the frauds and acts of Defendants and the contacts to abuse
this Plaintiff to this employer.
N. For Loss of Earning capacity from the damaged reputation and integrity caused by the
attacks and injunctions of Defendants to defame Plaintiff Townsend in the public eye
O. For lost profits of the home equity valued at $100,000.00.
P. For any and all future medical fees and costs and expenses for future medical
attention for emotional, physical and mental restoration for these Plaintiffs well being
of a future relationship as parent to children and children to this Plaintiff.
Q. For the cost incurred with this action
R. For legal costs and fees in all court cases
S. For any and all attorneys fees as Plaintiff Randall Townsend, had retained the
Attorneys Firms of CHARLES H. SCRUGGS, P.A and HEATHER M. GRAY to
represent these Plaintiffs in these actions and agreed to pay Attorneys Charles H.
Scruggs, P.A. and Heather M. Gray a reasonable attorney fee which should be
returned with interest.
T. For such and further relief as this court may deem proper
U. For any and all other Compensatory Damages
V. For CONSEQUENTIAL DAMAGES
W. Plaintiff request leave to amend pleading to request Punitive damages at time that is
just and proper per these pleadings.
X. FOR EXEMPLARY DAMAGES
Y. FOR ALL NOMINAL DAMAGES
Z. FOR TREBLE DAMAGES
AA. AND For any and all additional sanctions, awards and retributions, this court
seems just to allow.
BB. FOR A JURY TRIAL ON ALL ISSUES TRIABLE OF RIGHT BY JURY.
COUNT XXXXVII
COMPLAINT FOR VICARIOUS LIABILITY OF
PROFESSIONAL CORPORATION FOR MALPRACTICE OF MEMBER
ATTORNEY and VIOLATIONS OF RESPONDENT SUPERIOR--- AGAINST
DEFENDANTS CHARLES H. SCRUGGS, III ATTORNEY AND CHARLES H.
SCRUGGS III, P.A. AS OF CHARLES H. SCRUGGS III, INDIVIDUAL
471. Plaintiffs reallege all paragraphs all preliminary allegations and subsequent
allegations as stated herein and incorporate these allegations herein by reference.
472. Plaintiff state that the acts as stated herein of Attorney Charles H. Scruggs, III and

358

Charles H. Scruggs, Individual were practices in violations of laws and Rules of Civil
Procedure and Rules of Judicial Procedure and that HEATHER GRAY ATTORNEY AT
LAW, P.A.knowingly, intentionally, recklessly and negligently participated in the
deceptions, frauds, omissions of truthful disclosures and acts as stated herein to these
clients and to the courts and law enforcement officers.
473.Plaintiffs as Clients reasonably relied on defendants representations and omissions
and as a proximate result thereof were deceived as to file causes of actions and promote
causes of available actions and protections from violations continuing of the Florida
Statues as stated in Section 5 above herein and was damaged and is continued to be
damaged and separated as a father and child now since NOVEMBER 8, 2002, by the
frauds and CONCEALMENTS and OMISSIONS OF TRUTHFUL DISCLOSURES
since Defendants became advocates for clients in February 2003, with knowledge and
duty to disclose attorneys, judges, law enforcement, pastors and other defendants for their
violations of these clients and frauds on the courts.
474.Plaintiffs allege by the omissions of truthful disclosure and frauds against Plaintiffs
that Plaintiffs did not contribute to the damages caused by Defendants.
475.WHEREFORE, PLAINTIFFS REQUEST ALL RELIEF FOR DAMAGES AS
STATED BELOW HEREIN AND ANY OTHER RELIEF AS THIS COURT DEEMS
PROPER.
COUNT XXXXVIII
COMPLAINT FOR MALPRACTICE OF MEMBER ATTORNEY AS
VIOLATIONS BY THEORY OF RESPONDENT SUPERIOR---AGAINST
DEFENDANTS CHARLES H. SCRUGGS, III ATTORNEY AND CHARLES H.
SCRUGGS III, P.A. AS OF CHARLES H. SCRUGGS III, INDIVIDUAL
476. Plaintiffs reallege all paragraphs all preliminary allegations and subsequent
allegations as stated herein and incorporate these allegations herein by reference.

359

477. Plaintiff state that the acts as stated herein of Attorney Charles H. Scruggs, III and
Charles H. Scruggs III, Individual were practices in violations of laws and Rules of Civil
Procedure and Rules of Judicial Procedure and that CHARLES SCRUGGS,P.A.
knowingly, intentionally, recklessly and negligently participated in the deceptions,
frauds, omissions of truthful disclosures and acts as stated herein to these clients and to
the courts and law enforcement officers.
478. Plaintiffs as Clients reasonably relied on defendants representations and omissions
and as a proximate result thereof were deceived as to file causes of actions and promote
causes of available actions and protections from violations continuing of the Florida
Statues as stated in Section 5 above herein and was damaged and is continued to be
damaged and separated as a father and child now since NOVEMBER 8, 2002, by the
frauds and CONCEALMENTS and OMISSIONS OF TRUTHFUL DISCLOSURES
since Defendants became advocates for clients in February 2003, with knowledge and
duty to disclose attorneys, judges, pastors, law enforcement and other defendants for their
violations of these clients and frauds on the courts.
479. Plaintiffs allege by the omissions of truthful disclosure and frauds against Plaintiffs
that Plaintiffs did not contribute to the damages caused by Defendants.
480. WHEREFORE, PLAINTIFFS REQUEST ALL RELIEF FOR DAMAGES AS
STATED HEREIN AND ANY OTHER RELIEF AS THIS COURT DEEMS PROPER.
WHEREFORE, plaintiff prays for judgment and relief against defendants and
each of them as follows:
A. A Declaration that each Defendants conduct violated the law as alleged in each cause
of action;

360

B. A Declaration to abolish the injunction section from the Court of Judge

Timmerman, limiting the rights of this Plaintiff Townsend as father to his now adult
children, J.D.T and J.G.T and restoration of all full rights and expunge all records of
these injunctions caused by fraud of the defendants to the court as revealed by Karen
Harrod Townend in December 2005, Motion to this Honorable Court no threat of
abuse molesting or any vile act exists or ever existed;
C. preliminary and permanent injunctions preventing defendants and her co-conspirators
from any future acts of abuse and slander and harassment to Plaintiffs per s. 741 F.S.
and all other Florida Statues and set severe penalties to warn Defendants and her coconspirators of future abuse to the peace of these Plaintiffs;
D. Judgement for the Plaintiff for general and compensatory damages sustained as a
result of defendants unlawful conduct;
E. For the following special damages to be awarded according to complete discovery of
all proof to the limits allowed by law:
F. For physical Pain and suffering incurred while Defendants used fraud and
G. For the Loss of parental rights by Plaintiff Randall Townsend to J.D.T and to J.G.T
and
H. For Emotional Duress and Mental Duress incurred for Defendants use of abuse and
fraud
I. For Loss of honorable reputation of Plaintiff having to endure the slander and
defamation and frauds and malice and abuse of process and malicious prosecution
and all actions per each count shown herein without counter defense by Defendants to
off set the malicious charges incurring all special and general damages as stated
herein and
J. For all general, compensatory and nominal damages resulting from each Defendants
conspiracy and fraud and duress and extortion with Beck and Harrods employer,
FBCCP and CPCS and by the extortion and abuse and conspiracy with individuals
and co-employees at the place of employment as listed below as these litigants falsely
charging this Plaintiff with crimes in order to hide their criminal acts on Plaintiff
Randall Townsend and on Minor J.D.T and Minor J.G.T and Defendants conspiracy
with:
1. Ron Beck, individually, and as FBCCP Corporation Member and Officer
2. Herman Meister, individually, and as FBCCP Corporation Member and
Officer
3. Gary Leatherman, individually, and as Corporation Member and Officer
4. Joe Howlett, individually, and as Corporation Member and HCSO Deputy
5. Tim Jeffers, individually, and as Corporation Member and as PCSO Deputy
6. The FBCCP Corporation
7. The Citrus Park Christian School, employees and School Board
8. And from the FBCCP Corporation members at Large
9. From the abusive conduct practiced on these Pro Se Plaintiffs by Defendants
attorneys causing duress and fraud on these Plaintiffs by the frauds of
Defendants to attorneys, David Gibbs, III; Drew Gardner; Charles Denny, IV;
Stacey Turmel; Charles H. Scruggs, III; Heather Gray and Stanford Solomon;

361

K. For Special Damages in loss of reputation and loss of employment by Plaintiff

Randall Townsend in October 2005, flowing from the fraudulent actions by
Defendants
L. .For Special Damages in loss of reputation and loss of monies owed this Plaintiff
Townsend, from SunBelt Equipment Corporation, as damages of Defendants barred
litigation as advised by the State Attorney for defamation and slander and lost
earnings were at $1,000,000.00
M. For damages resulting from Defendants violation of the injunction set by Judge
Timmerman and the admitted contact by Harrod with Plaintiffs employer up until
October, 2005, and these injunctions in 2001 and 2003-current, and allegations and
contacts by these defendants did attribute to Harrods and others and thereby
defendants willful negligence and abuse, infliction of emotional duress and
harassment in the workplace and loss of employment and loss of earnings and all
future earnings because of the frauds and acts of Defendants and the contacts to abuse
this Plaintiff to this employer.
N. For Loss of Earning capacity from the damaged reputation and integrity caused by the
attacks and injunctions of Defendants to defame Plaintiff Townsend in the public eye
O. For lost profits of the home equity valued at $100,000.00.
P. For any and all future medical fees and costs and expenses for future medical
attention for emotional, physical and mental restoration for these Plaintiffs well being
of a future relationship as parent to children and children to this Plaintiff.
Q. For the cost incurred with this action
R. For legal costs and fees in all court cases
S. For any and all attorneys fees as Plaintiff Randall Townsend, had retained the
Attorneys Firms of CHARLES H. SCRUGGS, P.A and HEATHER M. GRAY to
represent these Plaintiffs in these actions and agreed to pay Attorneys Charles H.
Scruggs, P.A. and Heather M. Gray a reasonable attorney fee which should be
returned with interest.
T. For such and further relief as this court may deem proper
U. For any and all other Compensatory Damages
V. For CONSEQUENTIAL DAMAGES
W. Plaintiff request leave to amend pleading to request Punitive damages at time that is
just and proper per these pleadings.
X. FOR EXEMPLARY DAMAGES
Y. FOR ALL NOMINAL DAMAGES
Z. FOR TREBLE DAMAGES
AA. AND For any and all additional sanctions, awards and retributions, this court
seems just to allow.
BB. FOR A JURY TRIAL ON ALL ISSUES TRIABLE OF RIGHT BY JURY.
COUNT XXXXIX
COMPLAINT FOR VICARIOUS LIABILITY OF
PROFESSIONAL CORPORATION FOR MALPRACTICE OF MEMBER
ATTORNEY and VIOLATIONS OF RESPONDENT SUPERIOR---AGAINST
DEFENDANTS CHARLES DENNY IV ATTORNEY AND CHARLES DENNY IV
ATTORNEY AT LAW AND JAMES ROLFES ATTORNEY AND JAMES

362

ROLFES ATTORNEY AT LAW AND THE FIRM OF DICKINSON & GIBBONS

AS OF CHARLES DENNY INDIVIDUAL AND JAMES ROLFES INDIVIDUAL
480. Plaintiffs reallege all paragraphs all preliminary allegations and subsequent
allegations as stated herein and incorporate these allegations herein by reference.
481. Plaintiff state that the acts as stated herein of Attorney Charles Denny, IV and
Charles Denny IV Individual and Attorney James Rolfes and James Rolfes Individual
were practices in violations of laws and Rules of Civil Procedure and Rules of Judicial
Procedure and that DICKINSON & GIBBONS P.A. knowingly, intentionally, recklessly
and negligently participated in the deceptions, frauds, omissions of truthful disclosures
and acts as stated herein to these clients and to the courts and law enforcement officers.
482. Plaintiffs as Clients reasonably relied on defendants representations and omissions
and as a proximate result thereof were deceived as to file causes of actions and promote
causes of available actions and protections from violations continuing of the Florida
Statues as stated in Section 5 above herein and was damaged and is continued to be
damaged and separated as a father and child now since NOVEMBER 8, 2002, by the
frauds and CONCEALMENTS and OMISSIONS OF TRUTHFUL DISCLOSURES
since Defendants became advocates for clients in February 2003, with knowledge and
duty to disclose attorneys, judges, law enforcement, pastors and other defendants for their
violations of these clients and frauds on the courts.
483.Plaintiffs allege by the omissions of truthful disclosure and frauds against Plaintiffs
that Plaintiffs did not contribute to the damages caused by Defendants.
484.WHEREFORE, PLAINTIFFS REQUEST ALL RELIEF FOR DAMAGES AS
STATED BELOW HEREIN AND ANY OTHER RELIEF AS THIS COURT DEEMS
PROPER.

363

COUNT XXXXX
COMPLAINT FOR MALPRACTICE OF MEMBER ATTORNEY AS
VIOLATIONS BY THEORY OF RESPONDENT SUPERIOR---AGAINST
DEFENDANTS CHARLES DENNY IV ATTORNEY AND CHARLES DENNY IV
ATTORNEY AT LAW AND JAMES ROLFES ATTORNEY AND JAMES
ROLFES ATTORNEY AT LAW AND THE FIRM OF DICKINSON & GIBBONS
AS OF CHARLES DENNY INDIVIDUAL AND JAMES ROLFES INDIVIDUAL
485. Plaintiffs reallege all paragraphs all preliminary allegations and subsequent
allegations as stated herein and incorporate these allegations herein by reference.
486. Plaintiff state that the acts as stated herein of Attorney Charles Denny, IV and
Charles Denny IV Individual and Attorney James Rolfes and James Rolfes Individual
were practices in violations of laws and Rules of Civil Procedure and Rules of Judicial
Procedure and that DICKINSON & GIBBONS P.A., knowingly, intentionally, recklessly
and negligently participated in the deceptions, frauds, omissions of truthful disclosures
and acts as stated herein to these clients and to the courts and law enforcement officers.
487. Plaintiffs as Clients reasonably relied on defendants representations and omissions
and as a proximate result thereof were deceived as to file causes of actions and promote
causes of available actions and protections from violations continuing of the Florida
Statues as stated in Section 5 above herein and was damaged and is continued to be
damaged and separated as a father and child now since NOVEMBER 8, 2002, by the
frauds and CONCEALMENTS and OMISSIONS OF TRUTHFUL DISCLOSURES
since Defendants became advocates for clients in February 2003, with knowledge and
duty to disclose attorneys, judges, law enforcement, pastors and other defendants for their
violations of these clients and frauds on the courts.
488. Plaintiffs allege by the omissions of truthful disclosure and frauds against Plaintiffs
that Plaintiffs did not contribute to the damages caused by Defendants.

364

489. WHEREFORE, PLAINTIFFS REQUEST ALL RELIEF FOR DAMAGES AS

STATED HEREIN AND ANY OTHER RELIEF AS THIS COURT DEEMS PROPER.
WHEREFORE, plaintiff prays for judgment and relief against defendants and
each of them as follows:
A. A Declaration that each Defendants conduct violated the law as alleged in each cause
of action;
B. A Declaration to abolish the injunction section from the Court of Judge
Timmerman, limiting the rights of this Plaintiff Townsend as father to his now adult
children, J.D.T and J.G.T and restoration of all full rights and expunge all records of
these injunctions caused by fraud of the defendants to the court as revealed by Karen
Harrod Townend in December 2005, Motion to this Honorable Court no threat of
abuse molesting or any vile act exists or ever existed;
C. preliminary and permanent injunctions preventing defendants and her co-conspirators
from any future acts of abuse and slander and harassment to Plaintiffs per s. 741 F.S.
and all other Florida Statues and set severe penalties to warn Defendants and her coconspirators of future abuse to the peace of these Plaintiffs;
D. Judgement for the Plaintiff for general and compensatory damages sustained as a
result of defendants unlawful conduct;
E. For the following special damages to be awarded according to complete discovery of
all proof to the limits allowed by law:
F. For physical Pain and suffering incurred while Defendants used fraud and
G. For the Loss of parental rights by Plaintiff Randall Townsend to J.D.T and to J.G.T
and
H. For Emotional Duress and Mental Duress incurred for Defendants use of abuse and
fraud
I. For Loss of honorable reputation of Plaintiff having to endure the slander and
defamation and frauds and malice and abuse of process and malicious prosecution
and all actions per each count shown herein without counter defense by Defendants to
off set the malicious charges incurring all special and general damages as stated
herein and
J. For all general, compensatory and nominal damages resulting from each Defendants
conspiracy and fraud and duress and extortion with Beck and Harrods employer,
FBCCP and CPCS and by the extortion and abuse and conspiracy with individuals
and co-employees at the place of employment as listed below as these litigants falsely
charging this Plaintiff with crimes in order to hide their criminal acts on Plaintiff
Randall Townsend and on Minor J.D.T and Minor J.G.T and Defendants conspiracy
with:
1. Ron Beck, individually, and as FBCCP Corporation Member and Officer
2.Herman Meister, individually, and as FBCCP Corporation Member and Officer
3.Gary Leatherman, individually, and as Corporation Member and Officer
4.Joe Howlett, individually, and as Corporation Member and HCSO Deputy
5.Tim Jeffers, individually, and as Corporation Member and as PCSO Deputy
6. The FBCCP Corporation

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7. The Citrus Park Christian School, employees and School Board

8. And from the FBCCP Corporation members at Large
K. From the abusive conduct practiced on these Pro Se Plaintiffs by Defendants
attorneys causing duress and fraud on these Plaintiffs by the frauds of Defendants to
attorneys, David Gibbs, III; Drew Gardner; Charles Denny, IV; Stacey Turmel;
Charles H. Scruggs, III; Heather Gray and Stanford Solomon;
L. For Special Damages in loss of reputation and loss of employment by Plaintiff
Randall Townsend in October 2005, flowing from the fraudulent actions by
Defendants
M. .For Special Damages in loss of reputation and loss of monies owed this Plaintiff
Townsend, from SunBelt Equipment Corporation, as damages of Defendants barred
litigation as advised by the State Attorney for defamation and slander and lost
earnings were at $1,000,000.00
N. For damages resulting from Defendants violation of the injunction set by Judge
Timmerman and the admitted contact by Harrod with Plaintiffs employer up until
October, 2005, and these injunctions in 2001 and 2003-current, and allegations and
contacts by these defendants did attribute to Harrods and others and thereby
defendants willful negligence and abuse, infliction of emotional duress and
harassment in the workplace and loss of employment and loss of earnings and all
future earnings because of the frauds and acts of Defendants and the contacts to abuse
this Plaintiff to this employer.
O. For Loss of Earning capacity from the damaged reputation and integrity caused by the
attacks and injunctions of Defendants to defame Plaintiff Townsend in the public eye
P. For lost profits of the home equity valued at $100,000.00.
Q. For any and all future medical fees and costs and expenses for future medical
attention for emotional, physical and mental restoration for these Plaintiffs well being
of a future relationship as parent to children and children to this Plaintiff.
R. For the cost incurred with this action
S. For legal costs and fees in all court cases
T. For any and all attorneys fees as Plaintiff Randall Townsend, had retained the
Attorneys Firms of CHARLES H. SCRUGGS, P.A and HEATHER M. GRAY to
represent these Plaintiffs in these actions and agreed to pay Attorneys Charles H.
Scruggs, P.A. and Heather M. Gray a reasonable attorney fee which should be
returned with interest.
U. For such and further relief as this court may deem proper
V. For any and all other Compensatory Damages
W. For CONSEQUENTIAL DAMAGES
X. Plaintiff request leave to amend pleading to request Punitive damages at time that is
just and proper per these pleadings.
Y. FOR EXEMPLARY DAMAGES
Z. FOR ALL NOMINAL DAMAGES
AA. FOR TREBLE DAMAGES
BB. AND For any and all additional sanctions, awards and retributions, this court
seems just to allow.
CC. FOR A JURY TRIAL ON ALL ISSUES TRIABLE OF RIGHT BY JURY.
COUNT XXXXXI

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CLAIM FOR TORT INTERFERENCE WITH CHILD CUSTODY

AGAINST ALL DEFENDANTS
COMES NOW PLAINTIFF RANDALL TOWNSEND, PRO SE, AND AS
FATHER OF J.D.T and J.G.T who at the start of these litigation issues was 15 and 14,
respectively and states:
490.

Plaintiffs herein restate all paragraphs above and below and incorporate herein
and sues all defendants named above and incorporates herein.

491.

Per STONE V. WALL 734 So2d 1038(Fla.1999), the elements of a cause of

action for Intentional Interference with parent-child relationship are:(1) that plaintiff has
a superior custody right to the child, and (2) that defendant intentionally interfered with
such right, (3) without consent of the parent and the basis for this position of law is on the
sanctity of the parent-child relationship, not on the loss of services.
492.

Plaintiff Townsend as the father alleges that at any custody case hearing if held on

September 8, 1999, as the day this Father/Church elected leader/honorable citizen would
have gained full legal custody of J.D.T and J.G.T but for the fraud and collusion of the
mother, Karen Harrod Townsend intentionally, knowingly, willingly and recklessly
refusing to not conspire with her employers as alleged pastors, clergy, but self-dealing
criminals in violation of the FBCCP BY-LAWS and Federal, State, and Labor Laws who
were intentionally, knowingly, willingly and recklessly hiding and masked as clergy
but using their mask for unlawful purposes. This father states that he had to address these
employer clergy due to the abuse, battery, and unlawful acts against the wife and others
as teacher/employees and for the daily violations against the children as stated in this
Complaint and to show other violations when or if ever any court of true law obeys Rules
of Law and allows this Elected Investigative Member and Childrens Awana Commander

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to get the Church Financial Records exposed now even after over 50 Court Demands and
10 years of preparation of legal alignment of the Corporation to the Law.
493.

Plaintiff Townsend states that had not these alleged Clergy, trustees as sheriff

deputies, attorneys ie Grant, Gibbs, Gardner On September 8, 1999, Followed the

Rules of Law as stated by Judge Crenshaw in May 10, 2006, and September 7, 2006, and
Scruggs and Gray and Denny and Judges not conspired to give unlawful Benefit to
Clergy in violation of 775.03 F.S. and followed 617 F.S.
494.

On September 8, 1999, the interference with the Custody rights would have easily

been given to this Father due to the mental, physical, emotional, criminal and financial
incompetent, derelict and abusive state and actions of the mother Karen Harrod
Townsend, if ever evaluated by true professionals not conspiring with Dr. Lon Lynn with
ulterior and biased motives. Plaintiff Townsend states that the collusion by alleged
employer clergy and sheriff deputies as allegedly trustees conspiring and willfully
working together with Dr. Lon Lynn allowed tort interference with child custody to
become the extortion to kidnap the rights of these Plaintiffs from these Plaintiffs so to
conceal, continue, and procrastinate the revealing of the criminal facts that the clergy,
trustees and Dr. Lynn knew would all send them to jail at that time and lead to their
reputation ruin but as a band they intentionally, knowingly, recklessly continue their tort
battery and violations of the By-Laws and continued interference with labor laws, child
parent rights, misappropriation of corporate (a Church) opportunity in order to for
themselves continue criminal acts.
495.

Plaintiff Townsend states that now the exposed true personal convictions and

demented mental state of former Judge now unknowingly how after reading the February

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16, 2007, letter of any person allegedly as a skilled legal advocate as still an attorney
Charles Scruggs is revealed, the facts show his demented legal advice, exparte actions
and conspiracy with all Judges to continue to do extrinsic, intrinsic and fraud on the court
and with the full cooperation of Judges as shown in the voluminous case files even that
Scruggs could not reveal to Judge Palomino or to Judge Timmerman or any Judge full
custody rights of his clients Randall Townsend or J.D.T. or J.G.T or any other minor
child as this would violate his at that time unreported concealed personal convictions
and intentional acts to violate the RULES of LAW as reported in 2006, by Judge
Crenshaw who then recused herself as an accomplice per Pellgerini. As a participant in
the now 10 years of Malicious Prosecution against this Father/Elected Investigative
Church Leader trying to live peacefully with all Civil Rights as the Constitutions of these
United States and State of Florida Allow and protect.
496.

Plaintiffs state that by the actions of all Defendants, Plaintiffs have been damaged,

stressed, prohibited a child/parent relationship and had to endure every crime as reported
above and now included herein as per the May 10, 2006, words of Judge Crenshaw
reading the elements of malicious prosecution while Plaintiff Townsend tries to
implement 607.1603 as stated in Complaint 02-03812 and on page 27, after hearing this
point in the complaint Judge Crenshaw extends the damages and multiple times tells
Plaintiff Townsend to be quiet during presentation of legal points of now proved true
laws of attorneys and Judges and all Defendants and Judge Crenshaw states on page 57,
Line 13, Lack of probable cause in instituting or continuing a criminal or civil
proceeding against another if the circumstances are not sufficient to cause a reasonably
cautious person to believe that the person accused is guilty of the offense charged or the

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claim made is justified and Continuing a proceeding in this case has only been
allowed by defendants giving unlawful Benefit to Clergy and still to themselves and
do not produce documents or other requested testimony that will allow Plaintiff to
present a case still to a jury because of the malicious and illegal alleged Rules of Law
Acts now discredited by the words of Judge Crenshaw on May 10, 2006, Page 57,:
One acts maliciously in instituting or continuing a criminal/civil proceeding
against another if he does so for the primary purpose of injuring the other or recklessly
and without regard to whether the proceeding is justified or for any purpose except to
bring the offender to justice or to establish what he considers a meritorious claim.
But Judges and Attorneys still withhold production of truth from this Plaintiff/Father as
living his life now as a convicted criminal since the frauds of alleged Clergy because of
Frauds and Collusions of alleged Clergy/Trustees/the criminals including the now
former wife/mother". Even Denny still protest discovery of the elements of the Divorce
Case and production (1/07) of the records of the employer of the brother of Karen Harrod
Townsend as this will show incompetence of the now former wife, but Denny knows will
prove his acts since the start are to run up costs and do violations of RULES OF LAW.
497.

WHEREFORE PLAINTIFFS DEMAND :

A. REMOVAL OF THE FRAUDULENTLY GAINED DIVORCE
INJUNCTION OF JUDGE TIMMERMAN OF 2003, still active.
B. Restore WHOLE the rights and wellbeing of these Plaintiffs due to the
violations of Contract Law and Tort Actions by ALL defendants.
C. Grant any and all damages as allowed by RULES OF LAW.
D. Legally bring charges to a Grand Jury and Prosecute all offenders of the Law
E. Grant any and all relief allowed by the courts of LAW.
F. Grant a Jury Trial on all issues.

COUNT XXXXXII
CLAIM FOR TORT INTERFERENCE BY MALICIOUS PROSECUTION
AGAINST ALL DEFENDANTS
COMES NOW PLAINTIFF RANDALL TOWNSEND, PRO SE, AND AS

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FATHER OF J.D.T and J.G.T who at the start of these litigation issues was 15 and 14,
respectively and states:
498.

Plaintiffs herein restate all paragraphs above and below and incorporate herein
and sues all defendants named above and incorporates herein.

499.

Plaintiff Townsend specifically herein repeats all paragraphs of:

COUNT XXXXXI and COUNT VI as Ruled Complete! by Judge Crenshaw.

500.

Plaintiff therefore have been damaged by the knowingly, intentionally, recklessly

and negligent Malicious Prosecution of Plaintiff Townsend in violation of each
Right as listed above herein and for each claim as stated herein.

501.

WHEREFORE, PLAINTIFFS make a full claim for any and all relief per the
RULES OF LAW to be made Whole and Complete but for the reckless
violations of RULES OF LAW and Dutiful Conduct as fully stated by Defendants
herein and seeks any and all recoverable damages including punitive,
compensatory, legal fees and costs and any further relief this court is allowed.
CLAIM FOR CLASS ACTION

WHEREFORE, PLAINTIFF REQUEST THIS COURT RULE ON THE ACTION

HEREIN AS A CLASS ACTION CASE FOR THE BENEFIT OF ALL
ALLEGATIONS STATED HEREIN AS PLAINTIFF PLEADS, INDIVIDUALLY AND
ON BEHALF OF OTHERS SIMILARLY SITUATED.
RESPECTFULLY SUBMITTED:

_______________
Randall C. Townsend, Pro Se
P.O. BOX 21, ODESSA, FL 33556
Phone 941 350-2677
Jfyrt59@hotmail.com
www.Judgeoneforyourself.com
Judgeoneforyourself@yahoo.com
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