ED SLAVIN
P.O. Box 3084
St. Augustine, Florida 32085-3084
(904) 471-7023
October 18, 2006
Honorable Nilgun Tilek
Director, Office of Investigative Assistance (OIA)
Occupational Safety and Health Administration (OSHA)
United States Department of Labor (USDOL)
200 Constitution Avenue, N.W. Room N3119
Washington, D.C. 20210 via fax to 202-693-2369
ED SLAVIN v. WILLIAM B. HARRISS, JAMES PATRICK WILSON, JOSEPH BOLES, SUSAN BURK, DONALD CRICHLOW & ERROL JONES (each of whom is named in their personal, individual and official capacities for compensatory and punitive damages, frontpay, attorney fees and injunctive relief), CITY OF ST. AUGUSTINE , FLORIDA (COSA), MAYOR GEORGE R. GARDNER and PENNY HALYBURTON, SUPERVISOR OF ELECTIONS (named solely for injunctive relief and not monetary damages).
SWORN, VERIFIED CERCLA, TSCA, SWDA, FWCPA WHISTLEBLOWER COMPLAINT
Dear Ms. Tilek:
I hereby file this sworn complaint pursuant to 29 C.F.R. 24.3(c):
1. In retaliation for my April 20, 2006 environmental whistleblower complaint, enclosed, Respondents contrived to keep me off the ballot for St. Augustine City Commissioner, violating the environmental whistleblower laws. As a candidate:
A. I am an applicant for employment and jurisdiction exists under DOL case law; and
B. Respondents are guilty of illegal blacklisting in retaliation for my filing a DOL environmental whistleblower complaint and reporting environmental crimes.
2. I hereby respectfully request that OSHA investigate and order a special election, along with all of the other relief requested in the April 20, 2006, along with punitive damage under TSCA and SdWA, attorney fees and frontpay for the Commissioner's salary, provided that no tax funds are sought and that all damages should be paid by individual Respondents..
3. By September 21 & 25 letters Respondent Election Supervisor PENNY HALYBURTON, in a manner strongly suggesting that it was at the behest of the other Respondents, deprived Complainant of the right to run for City Commissioner.
4. Respondent WILSON abruptly resigned his job on October 12, 2006 and Respondents violated Florida Sunshine laws by an illegal October 13, 2006 meeting. FDLE is investigating.
5. Respondent CRICHLOW and the other Commissioners have been involved in attempting to assert that Complainant is not a City resident, violating Sunshine laws by discussing the asserted need for a survey of our street, for the purpose of violating my environmental whistleblower rights..
My street address is exempt from disclosure pursuant to F.S. 119 and may not be disclosed by DOL to any requester pursuant to FOIA..
6. Election laws have been inconsistently applied and Respondent HALYBURTON has acted in response to ex parte communications from some of the other Respondents.
7. For further details, please see my April 20, 2006 complaint (on appeal to ARB).
8. Further details will be provided to the investigator but are not provided here due to the sensitive nature of the ongoing environmental criminal investigation commenced on February 27, 2006..
9. It is my understanding that my campaign account may remain open pending the outcome of this litigation and that funds may be used to support this litigation.
10. Please assign your best investigator and not one from the Atlanta region, for reasons that I will share with you by telephone.
As the ancient equitable maxim states, :"Let justice be done though the heavens fall.
Respectfully submitted,
ED SLAVIN
COMPLAINANT
Enclosure
c. Mr. William Pence, Esquire (via fax to 407-843-6610)
Mr. Michael Hill, USEPA OIG SAC, Atlanta (via fax)
Respondents (via fax)
STATE OF FLORIDA
COUNTY OF ST. JOHNS
DECLARATION OF ED SLAVIN
I, Ed Slavin, swear and declare pursuant to the penalty of perjury set forth in 18 U.S.C. § 1001 and 28 U.S.C. § 1746 that all of the statements in the foregoing document are true to the best of my knowledge and belief. Today is October 18, 2006. Further affiant saith not.
ED SLAVIN
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