March 9, 2018 Update: Read the angry furious fatwa from SABCA President WILLIAM JONES (below FTC letter), in response to DMCA takedown letter request to St. Johns County.
From: Ed Slavin
Subject: Federal Trade Commission Investigation re: St. Augustine Beach Civic Association, Inc. and Website, www.staugustinebeachpier.com
Dear Chair Ohlhausen, et al.
1. I am writing to request that the United States Federal Trade Commission (FTC) investigate possible unfair and deceptive trade practices by the St. Augustine Beach Civic Association, Inc. (SABCA).
2. SABCA maintains a website, www.staugustinebeachpier.com.
3. The name of the www.staugustinebeachpier.com website conceals its true ownership and its true purpose. SABCA's website contains advertising and sells sponsorships.
4. SABCA is a 501c4, a de facto political action committee, which conceals its finances and obtains both government funds and private donations.
5. The "St. Augustine Beach Pier" is actually owned by St. Johns County, Florida government. It was paid for by a one-year increase in ad valorem property taxes approved by St. Johns County voters in a 1982 referendum. It is officially known as the "St. Johns County Ocean and Fishing Pier." (Pier Park)
6. SABCA blurs the lines between itself, the City of St. Augustine Beach and the St. Johns County, Florida Board of County Commissioners: SABCA bullies public officials for its own political agenda.
7. SABCA has purported to banish, punish or prosecute First Amendment protected activity at the Pier Park, including shooing away an African-American County Commissioner handing out campaign literature. Due to its long train of abuses, St. Johns County County Commission unanimously ended the SABCA-procured "First Amendment Zone" at Pier Park on August 3, 2015. http://www.staugustine.com/article/20150804/NEWS/308049951 8. SABCA claims not to support candidates or causes, but in reality its officers vet, recruit and campaign for St. Augustine Beach City Commission candidates favorable to its agenda.
9. SABCA financially supported, with a $500 contribution, a controversial 2015 St. Johns County Special Election referendum on an 8.66% sales tax increase for school construction, which spared wealthy corporate developers from paying $150,000,000 in impact fees and taxes over ten years -- an ROI of 33,200% on developers' and allies' investment of some $187,000 in campaign contributions.
10. SABCA refuses and denies SABCA memberships to persons who ask questions of it, including current SAB Mayor Undine Celeste Pawloskwi George and her husband, former SAB Mayor Edward George.
11. SABCA has a history of making annual contributions of money and other things of value to the City of St. Augustine Beach.
12. SABCA was until 2017 allowed to hold its meetings in the St. Augustine Beach Commission chamber, where alcohol and food were served, and wine was given to St. Augustine Beach City Manager BRUCE MAX ROYLE.
13. For some eighteen (18) years, SABCA had a no-bid contract with St. Johns County Board of County Commissioners for a lucrative Wednesday Farmer's Market at the Pier Park.
14. For eighteen (18) years, SABCA allegedly discouraged food vendors from accepting SNAP/EBT payment cards, violating the rights of low-income people, including persons with disabilities and senior citizens, discouraging them from attending the Pier Park Farmer's Market.
15. On February 20, 2018, St. Johns County Commissioners decided to issue an RFP for a Farmer's Market. Yet privileged SABCA President William Jones, an employee with the St. Johns County Sheriff, demanded a de facto source procurement instead of competitive RFP.
16. SABCA obtained a no-bid $1/year lease from the City of St. Augustine Beach for a garage, abusing pressure tactics to disrupt City Commission meetings until it got its way.
17. SABCA did not pay for electric power or garbage collection for some ten (10) years for its Farmer's Market at Pier Park, and now only pays some 41 cents per week for collection of trash from dozens of vendors.
19. SABCA has blocked disabled parking spaces at the Pier.
20. SABCA has allegedly retaliated against and sought to prosecute persons raising concerns about disabled parking.
21. SABCA may have undisclosed agreements, understandings and relationships with real estate developers.
22. SABCA has encouraged the City of St. Augustine Beach to seek the transfer or lease of the St. Johns County Ocean and Fishing Pier parking lot and inland facilities, amounting to some six acres, for purpose of leasing it and running it.
22. Miami-baesd Diego Ardid and his family own or control Key International, Inc., which owns or controls the new St. Augustine Beach Embassy Suites Hotel, a massive, gargantuan, structure, which compliant St. Augustine Beach officials allowed to be built in violation of the City's height limit, under pressure from Akerman lawyers. The Embassy Suites Hotel adjoins our six acre St. Johns County Ocean and Fishing Pier property,
23. Several government officials in St. Augustine Beach and St. Johns County have admittedly had secret meetings with the Ardids and Key International concerning Pier Park, with no documents produced in response to Open Records requests filed pursuant to F.S. 119.
24. St. Johns County Administrator MICHAEL DAVID WANCHICK, St. Augustine Beach Commissioner and ex-Mayor RICHARD BURTT O'BRIEN, ex-Mayor and ex-Commissioner ANDREA SAMUELS, and City Manager BRUCE MAX ROYLE claim there are "no documents," and have not answered news media questions candidly about their discussions, agreements and relationships concerning Pier Park.
25. Please investigate SABCA's www.staugustinebeachpier.com website pursuant to Section 5 of the Federal Trade Commission Act of 1914 for unfair and deceptive trade practices: SABCA does not own or control our St. Augustine Beach Pier.
27. Please obtain SABCA's financial records and investigate its sources and uses of funds, including any unfair or deceptive trade practices, conflicts of interest, double-billing, self-dealing or peculation, including use of funds from its website and St. Johns County bed tax funds.
28. Please investigate SABCA's relationship(a) with the Ardids, Key International and the Embassy Suites Hotel.
29. Please send FTC Bureau of Consumer Protection and Bureau of Competition investigators to St. Augustine Beach.
30 Please interview witnesses, obtain documents, and determine whether any violations of the Federal Trade Commission Act, Section 5, or other federal law violations, have occurred here.
With kindest regards, I am,
St. Augustine, Florida 32085-3084
From: Ed Slavin
Sent: Thu, Mar 8, 2018 10:55 pm
Subject: Re: DMCA takedown notice re: St. Augustine Beach Civic Association, Inc. and Website, www.staugustinebeachpier.com