Friday, November 18, 2022


Our St. Johns County Inspector General is investigating this no-bid contract. 

As Thomas Jefferson said, "I have sworn upon the Altar of Almighty God eternal hostility against every form of tyrannny over the mind of humannkind."S

Some of our misguided Dull Republican St. Johns County Commissioners would like to chill advocacy on their anti-competitive procurement decisions. 

Nevertheless, I have persisted. 

Here is my November 16, 2022 complaint to the St. Johns County Inspector General: 

-----Original Message-----
From: Ed Slavin <>
To: <>; <>; <>; <>
Cc: <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>
Sent: Wed, Nov 16, 2022 12:49 pm

Dear St. Johns County Inspector General Nilsa Arissa:

1. Would you please be so kind as to conduct a thorough criminal, civil and administrative investigation and audit of MOTOROLA SOLUTIONS, INC.; three (3) St. Johns County Commissioners (ISAAC HENRY DEAN, CHRISTIAN WHITEHURST, and SARAH S. ARNOLD); Sheriff ROBERT HARDWICK; Fire-Rescue Chief JEFFREY PREVATT; County Attorney DAVID MICHAEL MIGUT;County Administrator HUNTER SINCLAIR CONRAD; County Office of Management and Budget Director JESSE DUNN; THE FIORENTINO GROUP (TFG) lobbyists,  TFG partner MARK J. PINTO, JR., et al?  

2. Please investigate the County's controversial November 15, 2022 no-bid award of an overpriced, no-bid nearly $15 million contract to MOTOROLA SOLUTIONS, INC. for two-way radios costing $10,000 each,  made in Malaysia and Mexico. inter alia waiving our County's sacred Seventh Amendment right to jury trial, while refusing to wait a week to allow new reform Commissioner Krista Keating-Joseph to vote on it, after she takes office on November 22, 2022.  The lack of competitive bidding, the jury trial waiver, and the lack of comity and courtesy inherent in Commissioners' rude disenfranchisement of Commissioner Keating-Joseph and her constituents cannot be justified.  These are among the potential badges of fraud that require investigation.  

3. Please make findings of facts, conclusions of law, and recommendations to reform County purchasing as we know it. 

4. Please scrutInize the etiology of our County's incurious actions in adopting an unethical unconscionable "contract of adhesion" with a multinational corporate oligopolist that has a history of allegedly overcharging governments. Never again should our County rubber-stamp a take-it-or-leave it contract. Misguided and ill-advised Commissioners ignored the witness testimony, making no changes in the contract, asking few questions and never discussing possible modifications, not even discussing the jury trial waiver and other terms.

5. Please work with FDLE Executive Investigations, DOJ Public Integrity Section and FBI to investigate this contract and any and all possible federal, state or local law violations, fraud, waste, abuse, antitrust, ethics, County ordinance and purchasing violations surrounding the County Commission's apparent illegal contract violation of public policy.

6.  Evidence at the November 15, 2022 Commission meeting featured reasoned and documented expert and other testimony about lack of competitive bidding, unconscionably high prices, foreign sourcing  and potentially subpar equipment.  County employees lack objectivity because of their longtime sweetheart relationship with this oligopolist, one of some seven manufacturers.  The Commission refused to allow competitive bidding, for no principled reason. 

7. Three (3) SJC BoCC Commissioners appeared untethered to facts, but they were rude and relentless in rushing to make a reckless decision, potentially wasting more than $6 million or more above market prices.  

8. They intentionally and disrespectfully refused to wait a week to vote until Open Records requests are answered, or until newly-elected reform Commissioner Krista Keating-Joseph's term begins Tuesday, November 22, 2022.  Their rough rush to judgment is yet another badge of fraud.

9. Please see Item 14 on our November 15, 2022 SJC BoCC agenda:

Presenter: Jesse Dunn, Director, OMB
14. St. Johns County, Florida Special Obligation Revenue Note Series 2022A and Amendment to Master Purchase Agreement with Motorola Solutions, Inc. On October 4, 2022, the St. Johns County Commission directed staff to assemble a finance team to pursue short-term financing to purchase replacement radios for the County’s existing 800 megahertz interoperable radio system. Both the County’s Fire Rescue and Sheriff’s Office require replacement radios and associated computer aided dispatch in order to respond to emergencies, and collaborate with other public agencies for the protection of citizens. The County’s financial advisor received nine responses from their financing solicitation and the financing team recommends the proposal from Truist Bank to provide the County with a five-year term to finance costs of the radio equipment. The November 15, 2022 agenda item provides consideration of a resolution of the Board of County Commissioners, authorizing the issuance of the St. Johns County, Florida Special Obligation Revenue Note, Series 2022A pursuant to such loan agreement in the aggregate principal amount not to exceed $13,000,000; authorizes the repayment of such series 2022A note from a covenant to budget and appropriate legally available non-ad valorem revenues, and provides delegation for the authorization, execution, and delivery of the loan agreement. In addition, staff is requesting the Commission to authorize the County Administrator, or designee, to execute Amendment 2 to the Master Purchase Agreement with Motorola, in the amount of $14,716,774. Here, the Finance Team seeks the Board’s approval of this resolution, which includes the required supplemental documents (attached hereto and incorporated herein as Exhibits A-C. For the Board's convenience in reviewing, each of the exhibits are titled/described below: Exhibit A: General Description of the Project; Exhibit B: Proposal of Truist Bank Exhibit; C: Form of Loan Agreement

10.  Please interview the witnesses, subjects and targets and publish a public investigative report. 

11. Kindly investigate and audit conflicted conflicted TFG and its lobbying for and of our County, including TFG's numerous conflicts of interest in representing both governments and corporations.

12.  Please watch November 15, 2022 SJC BoCC meeting video here: (click on Additions/Deletions to Regular Agenda & Regular Agenda Item 14).

Let justice be done.

Thank you,

With kindest regards, I am,
Sincerely yours,
Ed Slavin
(904) 377-4998

-----Original Message-----
From: Ed Slavin <>
To: <>; <>; <>; <>; <>; <>; <>; <>
Cc: <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>
Sent: Thu, Nov 10, 2022 1:21 pm
Subject: NO-BID MOTOROLA SOLUTIONS, INC. CONTRACT JURY TRIAL WAIVER: St. Johns County Staff's Proposed Illegal Waiver of Our Seventh Amendment Right to Civil Jury Trial Is Indefensible

Dear Chairman Dean, Commissioners Arnold, Whitehurst and Keating-Joseph, and Messrs. Dunn, Conrad and Migut:

1. Why are our St. Johns County Administrator and our St. Johns County Attorney recommending that we waive our Seventh Amendment right to civil jury trial?

2. Commissioners and staff: Don't do that again, please.  Our County, two cities and other local governments have agreed with me that Seventh Amendment waivers of jury trial rights are contrary to the genius of a free people and violate the reasonable expectations of probity.  Most recently, at my request, our mosquito control district deleted such a provision from a vendor's standard form uniform contract. 

3. How many other unauthorized jury trial waivers are being inserted into our St. Johns County contracts?  Please send me a list today,

4. Please correct our staff instanter, and tell them that our Founders intended our Seventh Amendment right to civil jury trial as a "bulwark against oppression," in the immortal words of the late Supreme Court Justice William Rehnquist.  Parklane Hosiery Co. v. Shore, 439 U.S. 322 (1979)(Rehnquist, J., dissenting).  No government should ever waive its right to jury trial. These civil jury trial rights are not negotiable.  No overbearing corporation should be heard to euchre our County into waiving them.

5. It is a stench in the nostrils of our Nation that St. Johns County Attorney DAVID MICHAEL MIGUT and St. Johns County Administrator HUNTER SINCLAIR CONRAD would submit to the County Commission such an "unconscionable contract of adhesion," containing a waiver of our sacred right to jury trial, a fundamental constitutional right.  

6. Generations of American veterans fought for our freedoms.  Many were wounded, suffered and died for our freedoms.  We honor them tomorrow on Veterans Day.  But we dishonor their memories whenever our governments are engines of oppression, as on this occasion.

7. I object to to our County agreeing to waive  our Seventh Amendment rights. 

8. I object to our County Administrator being hired without a job application, without a job posting, without a background investigation, or even meeting the minimum career qualifications for the job.

9. Our misguided County Administrator twice told me during 2021 and 2022 budget meetings that "I don't have to answer your questions. I work for the Board of County Commissioners."  It is beyond time for him to go.  We need a national search for a new County Administrator, one who will see that our rights are respected and not neglected.

10. Our St. Johns County staff's habitual sloth and torpor in the face of oppression must end now. We must restore the Rule of Law. We must restore honor and dignity to the office of the St. Johns County Board of County Commissioners and its staff. Compare, proposed finance contract, Exhibit C, within item 14 of Tuesday, November 15, 2022 agenda, no-bid MOTOROLA SOLUTIONS contract, a violation of public policy, Restatement of Contracts, 2d, Section 178 (see earlier e-mail, below):

SECTION 5.07. WAIVER OF JURY TRIAL. To the extent permitted by applicable law, the County knowingly, voluntarily and intentionally waives any right it may have to a trial by jury in respect of any litigation based on, or arising out of, under or in connection with this Agreement, the Note or any agreement contemplated to be executed in connection therewith, or any course of conduct, course of dealing, statements (whether verbal or written) or actions of the County or the Noteholder.

-----Original Message-----
From: Ed Slavin <>
To: <>; <>; <>
Cc: <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>; <>
Sent: Thu, Nov 10, 2022 11:02 am
Subject: Request No. 2022-182: 800 mhz radio system -- Motorola Solutions no-bid contract, item 14 on November 15, 2022 St. Johns County Commission Agenda

Dear Chairman Dean, Mr. Migut and Ms. Dixon:
1. Would you please be so kind as to vote to remove item 14 from the November 15, 2022 agenda of our St. Johns County Board of County Commissioners, with curative instructions to staff to cease and desist from ever again recommending no-bid or "sweetheart" contracts?
2. Would you and the County staff please be so kind as to send me any County staff research on the market for law enforcement radios, identifying the key competitors?
3. Please send me the list of prospective bidders and any RFP, RFQ or other final or draft solicitations of bids or proposals for the nearly $15 million in County business covered by BoCC agenda item 14, on the November 15, 2022  BoCC agenda (MOTOROLA SOLUTIONS), including $10,000 each for two-way radios.  
4. If no competitive bidding, please provide documentation as to why, and include copies of any legal opinion or research on this contract violation of public policy.  Restatement of Contracts, 2d, Section 178 (Contract Violation of Public Policy).  
5. Please send me copies of any County referrals for civil, criminal administrative investigations to federal or state law enforcement, the Inspector General of St. Johns County, State's Attorney, Sheriff, Statewide Prosecutor, State Attorney General, FTC, DOJ, FBI, or otherwise. 
6. What lawyers and lobbyists have represented MOTOROLA in its dealings with the County and Sheriff?  Please send documents.
7. Please  direct our Sheriff and County staff to comply from this day forward with the fundamental economic policy of our Nation since 1890 -- free and open competition, enshrined in the Sherman Antitrust Act, Federal Trade Commission Act, Clayton Act, Hart-Scott-Rodino Antitrust Improvements Act, et al.  We must reform County purchasing as we know it.
8. In what countries are MOTOROLA radios manufactured?  (Malaysia and Mexico?)  Where are MOTOROLA's competitors headquartered?  Where do they make their radios?
9. What background investigation did our County ever do on MOTOROLA and its corporate history concerning litigation, indictments, grand jury investigations, False Claims Act, fraud, bribery and other allegations of a culture of lawbreaking and excessive prices charged to governments and other customers?  Please send documents.  If no background investigation, why not?
10. It's our money.  Please call me to discuss.
Thank you,
With kindest regards, I am,
Sincerely yours,
Ed Slavin
(904) 377-4998

No comments: