St. Augustine Beach Mayor UNDINE CELESTE PAWLOWSKI GEORGE FILES COMPLAINTS AGAINST ELECTION OPPONENT TOM REYNOLDS, who withdrew his candidacy.
St. Augustine Beach Mayor UNDINE GEORGE may have violated the First Amendment and Florida's anti-SLAPP law by filing an angry complaint against her opponent, Tom Reynolds with the State's Attorney and Florida Elections Commission for expressing his opinions.
On September 11, 2018, St. Augustine Beach Mayor UNDINE CELESTE PAWLOWSKI GEORGE filed a rambling angry Florida Elections Commission complaint against Tom Reynolds attaching dozens of pages of First Amendment protected activity by Tom Reynolds.
St. Augustine Beach City Hall is a crime scene with New Years Eve "Beach Blast Off!" money missing, an employee quitting the day after her police interview and three successive Mayor-Commissioners abusing criminal law to punish critics.
Voting to silence and dissent, three St. Augustine Beach CityCommissioners voted 3-2 in December 2017 to limit comment on agenda items two minutes, seeking to chill, coerce and intimidate First Amendment protected activity.
Mr. Reynolds withdrew shortly after being served with the complaint, which was also filed with State's Attorney RALPH JOSEPH LARIZZA.
Mayor GEORGE objected to some of Mr. Reynolds' criticism, some of which hit below the belt (sexual orientation) and some of which were spot on (Ms. GEORGE"s alleged behavior in meetings, alleged case-fixing of a Norbert Tuseo code enforcement case).
GEORGE"s husband, EDWARD GEORGE, is a former Mayor of St. Augustine Beach.
In 2016, St. Augustine Beach Mayor RICHARD BURTT O'BRIEN was found to have filed a wrongful stalking injunction in Circuit Court against Mr. Reynolds, dismissed by Circuit Court Judge Howard O. McGillin, Jr. on December 7, 2016 as violating Mr. Reynolds' First Amendment rights to criticize the government.
Undeterred, Mayor UNDINE CELESTE PAWLOWSKI GEORGE has stepped into the mire of St. Augustine Beach corruption, becoming the third mayor in a row to abuse her limited powers to rain retaliation upon critics. The "Devil's Triangle" was referred to in Judge Brett Michael Kavanaugh's 2018 Supreme Court confirmation hearings. Here in St. Johns County, the Devil's Triangle refers to ANDREA SAMUELS, RICHARD BURTT O'BRIEN and UNDINE CELESTE PAWLOWSKI GEORGE, three "mayors" with delusions of adequacy and animus toward First Amendment rights.
Her long, rambling 79 page complaint package is freighted with animus, attempting to criminalize disagreements on issues of corruption and mismanagement with self-serving assertions.
The all-white VIP tent for the annual "Beach Blast Off!" fireworks has been ended, including the free subsidy for Commissioners. Mayor GEORGE stated in her complaint that "the Commissioners' attendance at the VIP area is an incident of the responsibilities of office,not a gift of value."
Like entitled Supreme Court nominee Brett Michael Kavanaugh, Mayor UNDINE GEORGE is thin-skinned and shows unfitness to hold public office.
No response from Mayor GEORGE about her client list, her conflicts of interest, her constitutional law experience and research, her legal drafting process of the complaint, or her anger at Mr. Reynolds in retaliation or blowing the whistle on corruption issues.
Here's the Florida law against SLAPP lawsuits:
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Here's what she filed with the Florida Elections Commission on September 11, 2018:
AFFIDAVIT
§
§
§
BEFORE ME, the undersigned authority duly authorized to administer oaths under the
laws of the State of Florida, personally appeared Undine C. George, on this day,
~. I ( -rt- , 2018, who being by me first duly sworn and says, under oath:
I. My name is Undine C. George and I am submitting this attachment affidavit in support of
the Complaint filed with the Florida Elections Commission and the State Attorney's
Office, by me and against Mr. Thomas Reynolds ("Reynolds"), for violation of
§104.271(2), Fla.Stat.
JURISIDICTIONAL ALLEGATIONS
2. I am, and at all times relevant to these proceedings, have been a candidate seeking reelection
to the St. Augustine Beach City Commission, Seat 3 (the "Seat").
3. I became a qualified candidate to the Seat on June 18, 2018.
4. Mr. Reynolds is, and was at all times relevant to these proceedings, a qualified candidate
to the Seat.
5. According to the St. Johns County Supervisor of Elections website (www.sjcvotes.us),
Reynolds' Statement of Candidate and Appointment of Campaign Treasurer and
Designation of Campaign Depository were stamped received on June 14, 2018 at the St.
Johns County Supervisor of Elections and Reynolds' Statement of Financial Interests,
Candidate Oath, and Acknowledgment of Forms were stamped received on, and he
became qualified to the Seat, on June 22, 2018. (True and correct copies of these five
referenced forms acquired from the St. Johns County Supervisor of Elections website are
attached hereto as composite Exhibit '"A ". ).
6. The Elections Commission has jurisdiction regarding the matters contained within this
Complaint which fall within §§I 04 and 106, Fla. Stat.
Affiant's Initials:~ Page 3 of 79 Page I of 21
FACTS COMMON TO ALL COUNTS
7. I, Undine C. George, am a female person who was born a female and have always
identified as a female.
8. I am married to my husband, Edward S. George, a male person who was born a male and
has always identified as a male.
9. My husband and I are in a very committed, very monogamous, and very happy marriage.
I 0. I am the current Mayor of St. Augustine Beach, FL. I am licensed to practice law in the
State of Florida, and have been since 2005, and am also admitted to practice law in the
United States District Courts for the Northern District of Florida as well as the Middle
District of Florida. I am a small business owner, among them being my law firm,
Anastasia Law, P.L., located in St. Augustine Beach which has been in existence since
2010.
11. My husband is a former Mayor and former member of the City Commission of St.
Augustine Beach, Florida. He is a licensed professional engineer and has owned his
engineering consulting company in St. Johns County, FL since 1998.
12. My husband and I both are respected professionals. We each have a long history of
membership in, and serving on boards of, various non-profit organizations and
community organizations. We look forward to continued service in the community
however the false statements made maliciously by Reynolds as described herein are
purposed by him to prevent our continued success, respect and standing in the
community.
13. The false and malicious statements by Reynolds are purposed to hurt my re-election and
gain himself votes in this year's general election.
14. On information and belief, the herein described action(s) by Reynolds also constitutes a
violation of one or more of the following: §817.569, Fla. Stat.; §836.01 , Fla. Stat.;
§836.04, Fla. Stat.; §836.09, Fla. Stat., §836.11; Fla. Stat.; or, other Florida law.
15. On information and belief, the herein described action(s) by Reynolds constitute(s) a hate
crime because it evidences prejudice based on the sexual orientation of its victim and
should be subject to reclassification pursuant to §775.085, Fla. Stat.
Affiant's Initials:~ Page 4 of 79 Page 2of21
COUNT I
16. This is a Complaint against Reynolds for violation of§ 104.271 (2).
17. It is a violation of Fla. Stat. 104.27 I (2) if "any candidate who, in a primary election or
other election, with actual malice makes or causes to be made any statement about an
opposing candidate which is false."
18. On or around August 23, 2018, Reynolds did make false statement(s) against opposing
candidate, Undine C. George, with actual malice, on the internet, in response to an article
published in the St. Augustine Record (local newspaper) website www.st.augustine.com
(hereinafter shall be the "Record").
I 9. The article Reynolds posted his false and malicious statements to was published by the
Record on August 22, 20 I 8 and was titled "Ethics Complaints Against St. Augustine
Beach Officials Dismissed" (hereinafter the "Record Ethics Article"). See
b.1!Q: //www .staugustine.com/news/20180822/ethics-complaints-against-st-augustinebeach-
officials-dismissed (a true and correct copy of the article and comments posted by
Reynolds are attached as composite Exhibit "B").
20. Separate false statements are identifiable from Reynolds' two separate postings to the
Record Ethics Article. For convenience they are organized in this first count, however I
believe that each separate statement constitutes a separate and distinct violations of the
statute.
21. Among the false statements made with actual malice by Reynolds, on the Record website
in response to the Record Ethics Article, they include:
a. "UNDINE GEORGE COMMITTED TWO FELONIES IN DOING THIS
INTERFERENCE"
1. This statement about me is false and was made with actual malice.
i1. It is false and malicious to refer to me as having committed two felonies
because I have not. I am not a felon. I have never been convicted of a
felony whatsoever.
ui. This statement is per se malicious.
iv. This statement is per se libelous.
1. Reynolds alleges that "COMMISSIONER DID USE HER POSITION TO
INTERFERE WITH TWO CODE ENFORCEMENT COMPLAINTS
Affiant 's Initials:~ Page 5 of 79 Page 3of21
AGAINST TWO PROPERTIES OWNED by NORBERT TUSEO," but
this also is not true. For the duration of my service as commissioner I have
never improperly interfered with any code enforcement complaints; when
I have been made aware of any improper actions relating to code
enforcement I have only ever brought them to the attention of the city
attorney.
b. "Commissioner UNDINE GEORGE LED THE COVER-UP and the WOMAN
SUED THE CITY AND WON!"
1. This statement about me is false and was made with actual malice.
11. I have never participated in any "cover-up" of any sexual assault against a
female employee, in fact I have been an advocate to our city manager to
require sensitivity training of personnel because I personally was a victim
of misogyny perpetrated against me, by the same city employee who is no
longer working at the city, and who is implicated by Reynolds' statement.
11i. Reynolds' reversal of reality is particularly malicious, hateful and
insensitive. To be accusing a fellow victim of being at fault, his"blame the
victim" mentality, is heinous, out dated and, quite frankly, it is perverse.
c. "UNDINE GEORGE ... WILL HAVE TO ANSWER THE TO THEIR
UNETHICAL CORRUPT CONDUCT ... " Reynolds also begins his comments
referring to me and the others as "UNETHICAL ELECTED OFFICIALS [who] .. .
DID ACCEPT a $2,500.00 GIFT FROM THE CITY."
i. This statement about me is false and was made with actual malice.
IL Reynolds knows, because he has been told repeatedly, that there was no
$2,500 gift received by me. (See email sent to Reynolds on June 11 , 2018,
by City Manager Max Royle, wherein at paragraph 6, Royle explains to
Reynolds his inaccuracies and Reynolds responds, verifying receipt of the
emai I. A true and accurate copy of this email correspondence is attached
hereto as Exhibit "B. l ".) Reynolds has extrapolated that, because only
advertising sponsors, who donate a minimum of $2,500 to the city's Beach
Blast Off event, gain access to the "VIP" area, if any one Commissioner
attends the same "VIP" area, then he or she has individually received a
Affiant's Initials:~ Page 6 of 79 Page 4of21
$2,500 gift. But this is simply not true. (See B.1 ). When an advertiser pays
$2,500 to the city it is for advertising, the VIP area access is a bonus. The
city does not sell tickets to the VIP area. Moreover, the Commissioners'
attendance at the VIP area is an incident of the responsibilities of office,
not a gift of value.
u1. Especially since Reynolds has had this explained to him by city officials,
by email and at city commission meetings, and now the Ethics
Commission (see article in Exhibit B), for him to say that my failing to
report my attendance at a city function as a gift is " unethical corrupt
conduct" is a false statement about me made with actual malice.
WHEREFORE, Complainant respectfully requests a ruling that Reynolds is guilty of the
numerous violations of§ I 04.271 (2), Fla. Stat., as identified in the above count, together with a
reclassification as allowed pursuant to §775.085, or as otherwise may be allowed by law, an
award of attorney fees and costs for the prosecution of this action, and any other relief
appropriate and just under the circumstances.
COUNT II
22. This is a Complaint against Reynolds for violation of§ 104.271 (2).
23. It is a violation of Fla. Stat. 104.271(2) if "any candidate who, in a primary election or
other election, with actual malice makes or causes to be made any statement about an
opposing candidate which is false."
24. On or around July 29, 2018, Reynolds did make false statement(s) against opposing
candidate, Undine C. George, with actual malice, on the internet, in response to an article
published in the St. Augustine Record (local newspaper) website www.st.augustine.com
(hereinafter shall be the "Record").
25. The article Reynolds posted his false and malicious statements to was published by the
Record on July 28, 2018 and was titled "St. Augustine Beach Officials Propose Millage
Rate Increase" (hereinafter the "Millage Article"). See
h1!Q:fjwww. sta u gustine. co mlll~-~s/2 0 18 0 72 ~i. st -E.Ä:!R1::1_~t_i.n e-beach-o ffi c i al s-m:QP9..~-~.:
Page 7 of 79 Page 5of21
mi!J .. i:l:g~_:-Jate-incr~i:l:~~ (a true and correct copy of the article and comments posted by
Reynolds are attached as composite Exhibit "C").
26. Separate false statements are identifiable from Reynolds' two separate postings to the
Millage Article. For convenience they are organized in this second count, however I
believe that each separate statement constitutes a separate and distinct violations of the
statute.
27. Among the false statements made with actual malice by Reynolds, on the Record website
in response to the Millage Article, they include:
a. "NOW COMMISSIONER and TOKEN MAYOR UNDINE GEORGE WANTS
HIS and HIS WIFE EDS HEALTH INSURANCE PAID FOR!"
1. This contains false statements made with actual malice
IL It is false and malicious to refer to me as a male person because I am a
female person who was born a female and has always identified as a
female.
BL It is false and malicious to refer to my husband, Edward George, as a wife
or a female person because he is a male person who was born a man and
has always identified as a male.
1v. It is false and malicious to refer to the health insurance that was discussed
in the Millage Article as being desired or introduced by me because it was
introduced by city staff on its own initiative and not by me.
v. Although there may not be anything independently wrong with anyone
identifying with either particular gender, Reynolds is obviously pandering
maliciously to the insidious bigotry, prejudice and hatred that is shared
among some members of the community against non-traditional sexual
orientation persons, trans-gender persons or alternative gender identifier
persons.
b. "LESBIAN TURNED BI-SEXUAL COMISSIONER UNDINE GEORGE
WANTS THE CITY TO PAY $1 ,765.00 A MONTH FOR THE CADILLAC
HEALTH INSURANCE FOR WIFE ED GEORGE and HIMSELF UNDINE E!"
i. This contains false statements made with actual malice.
Affiant's Initials:~ Page 8 of 79 Page 6 of21
11. It is false and malicious to refer to me as a male person because I am a
female person who was born a female and has always identified as a
female.
111. It is false and malicious to refer to my husband, Edward George, as a wife
or a female person because he is a male person who was born male and
has always identified as a male.
1v. It is false and malicious to refer to the health insurance that was discussed
in the Millage Article as being desired or introduced by me because it was
introduced by city staff on its own initiative and not by me. (See Exhibit
B). Moreover, the only time the City of St. Augustine Beach offered
health insurance to city commissioners, my husband and I reimbursed the
city for the cost of my husband's health insurance even though no
employee or commissioner was or is obligated to do so.
v. It is false and malicious to refer to me as a "lesbian turned bi-sexual
commissioner" because sexual orientation has nothing to do with being a
commissioner and saying this is a malicious expression of hate speech.
v1. It is false and malicious to refer to me as a "lesbian turned bi-sexual
commissioner" because I am in a happy and committed monogamous
relationship with my husband.
v11. It is false and malicious to refer to me as a "lesbian turned bi-sexual"
because that is not how I identify my sexuality or sexual orientation.
v111. Although there may not be anything independently wrong with anyone
being a "lesbian turned bi-sexual" Reynolds is obviously maliciously
pandering to the insidious bigotry, prejudice and hatred that is shared
among some members of the community.
1x. Although there may not be anything independently wrong with anyone
identifying with either particular gender, Reynolds is obviously
maliciously pandering to the insidious bigotry, prejudice and hatred that is
shared among some members of the community against non-traditional
sexual orientation persons, trans-gender persons or alternative gender
identifying persons.
Affiant's Initials~ Page 9 of 79 Page 7of2 I
c. "A TEN HOUR A MONTH JOB?"
L It is false and malicious to say that I only work ten hours a month on the
position of Mayor and City Commissioner. In fact, I work much more than
that and some weeks the responsibilities of the Seat take more than thirty
hours per week.
d. "HE RUMOR ALL OVER THIS 1.87 SQUARE MILES BEACH CITY ABOUT
UNDIINE GEORGE and HIS HUSBAND ED GEORGE ARE NOT NORMAL
PERIOD!"
1. This contains false statements made with actual malice.
11. It is false and malicious to refer to me as a male person "HIS" because I
am a female person who was born a female and has always identified as a
female.
ui. It is a false statement to say that there is a rumor across the whole city that
I and my husband are not normal. Although it is couched in the nature of
describing a rumor, read in the context of the entirety of his comments, it
is also clear that he is using this statement as evidence of the other false
statements he has made with actual malice.
lV. Moreover, it is not true that such a rumor is "all over this 1.87 square
miles" other than Reynolds trying to create such a rumor.
v. Although Reynolds is attempting to couch his actual malice and false
statements by using "not normal period" which would typically be
considered vague, or a matter of opinion, in the context of the entire
comments published by Reynolds, it is a patently obvious malicious
statement of hatred, bigotry and prejudice on the basis of sexual
orientation.
e. "UNDINE & ED GEORGE WANT TO BE THE FIRST COUPLE IN THE
UNITED STATE TO BOTH GET SEX CHANGE OPERATIONS! THIS IS
NOT A JOKE!"
i. This contains false and malicious statements.
11. Neither me nor my husband, nor both of us, want to get a sex change
operation.
Affiant' s Initials:~ Page 10 of 79 Page 8of21
ui. In making this false statement, Reynolds is obviously maliciously
pandering to the insidious bigotry, prejudice and hatred that is shared
among some members of the community against non-traditional sexual
orientation persons, trans-gender persons or alternative gender identifying
persons.
1v. Reynolds plainly says that "THIS IS NOT A JOKE!" in all capital font
and with an explanation point. He is making it clear that he is not
expressing an opinion or a theory, but rather a fact. This is quintessentially
what the statute was intended to prohibit. Moreover, in his own words he
proves that these false statements are being made with actual malice. In
particular, the fact that he goes on in the immediately next sentence to
state, "THIS IS CRAZY ON STEROIDS ... " evidences his maliciousness
because it evidences his perspective of hatred against transgender persons.
Therefore, since he admits that he believes it is "crazy on steroids" for a
person to desire a sex change operation, his falsely announcing that my
husband and I desire such an operation, shows that his announcement is
being made to subject us to ridicule.
f. Reynolds signs off saying "THANK YOU, TOM REYNOLDS, a CANDIDATE
FOR ST AUGUSTINE BEACH CITY COMMISSION VOTE TOM
REYNOLDS FOR ST AUGUSTINE BEACH CITY COMMISSIONER
NOVEMBER 2018". In signing off in this way, Reynolds admits that these false
statements are maliciously made against me and my family in hopes that
Reynolds will get additional votes and/or support in the election, and/or that I will
lose votes and/or support in the election.
WHEREFORE, Complainant respectfully requests a ruling that Reynolds is guilty of the
numerous violations of§ 104.271 (2), Fla. Stat., as identified in the above count, together with a
reclassification as allowed pursuant to §775.085, or as otherwise may be allowed by law, an
award of attorney fees and costs for the prosecution of this action, and any other relief
appropriate and just under the circumstances.
Afftant's lnitialsM Page 11 of 79 Page 9of21
/
COUNT III
28. This is a Complaint against Reynolds for violation of§ 104.271 (2).
29. It is a violation of Fla. Stat. 104.271(2) if "any candidate who, in a primary election or
other election, with actual malice makes or causes to be made any statement about an
opposing candidate which is false ."
30. On August 22, 2018, at around 12:58 p.m., and then again at 7:19 p.m., Reynolds did
make false statement(s) against opposing candidate, Undine C. George, with actual
malice, on the internet, in response to an article published by Historic City News (a local
on-line news outlet, available at www.historiccity.com) .
31. The article Reynolds posted his false and malicious statements to was published by
Historic City News on August 22, 2018 and was titled "Ethics Commission finds lack of
legal sufficiency" (hereinafter the "Ethics Article"). See
htt s://historiccit .com/2018/staugustine/news/tlorida/ethics-commission-ftnds-lack-of-legalsufftciency-
72977 however the comments were edited on or around August 23, 2018. The
original and the edited comments are available on the Historic City News website as well
as on Tom Reynold 's Facebook page, at htJQs: //www.facebook.com/tom.rey..D..9lc;is,9-23 .
(A true and correct copy of the article, the original and the edited comments posted by
Reynolds are attached as composite Exhibit "D").
32. Separate false statements are identifiable from Reynolds' posting to the Ethics Article.
For convenience they are organized in this third count, however I believe that each
separate statement constitute separate and distinct violations of the statute.
33. Among the false statements made with actual malice by Reynolds, on the Record website
in response to the Ethics Article, they include:
a. "DON'T FORGET ... UNDINE PAWLOSKI GEORGE IS THE DAUGHTER
OF FELONY VOTER FRAUDSTER MICHELL PAWLOWSKI."
i. This statement about me is false and was made with actual malice.
IL It is false and malicious to refer to me as having a father who is a "Felon
Voter Fraudster" because my father is not a felon. My father has never
been convicted of a felony whatsoever.
ui. This statement is per se malicious.
1v. This statement is per se libelous.
Afftant's Lnitials: ~ Page 12 of 79 Page I 0of21
v. Moreover, my name is not Undine Pawloski George, my name is Undine
Celeste George.
vi. Similarly, spelling my father's name with two L's echoes of the prior false
statements Reynolds has made as described above.
b. "UNDINE E. GEORGE HAS ALSO COMMITTED TWO FELONIES"
1. This statement about me is false and was made with actual malice.
IL It is false and malicious to refer to me as having committed two felonies
because I have not. I am not a felon. I have never been convicted of a
felony whatsoever.
ui. This statement is per se malicious.
1v. This statement is per se libelous.
v. Reynolds goes on to explain with further false statements made for the
purpose of malice and subjecting me to ridicule that the purported felonies
involved, "INTERFERING WITH CODE ENFORCEMENT
COMPLAINTS FOR HER CAMPAIGN DONOR AND CLIENT A NEW
YORK PEDOFILE NAMED NORGERT TUSEO!TUESO OWNS
ILLEGAL RENTAL PROPERTIES IN ST AUGUSTINE BEACH THAT
WERE ILLEGALLY BUILT!"
Affiant' s Initials:~
1. I do not have any clients named Norbert Tuseo or who fit the
description contained in this post.
2. I have no personal knowledge regarding the sexual proclivities of
Mr. Norbert Tuseo but upon information and belief, (after
conducting a registered offender search on the Florida Department
of Law Enforcement website which did not reveal any records to
indicate that Mr. Tueso is sexual offender) Mr. Norbert Tuseo is in
fact NOT a pedophile.
3. Although Mr. Tueso was one of many individuals who did donate
to my campaign in 2010, I did nothing to improperly interfere with
code enforcement complaints for or against him.
Page 13 of 79 Page 11 of 21
4. Reynolds' false statements regarding me associating with or
corruptly aiding a pedophile or criminal were made with actual
malice.
c. "LIKE FELON VOTER FRAUDSTER FATHER LIKE FELON COMMITTING
DAUGHTER/SON aka L TB"
1. This statement about me is false and was made with actual malice.
11. This statement is per se malicious.
u1. This statement is per se libelous.
1v. It is false and malicious to refer to me as having a father who is a "Felon
Voter Fraudster" because my father is not a felon. My father has never
been convicted of a felony whatsoever.
v. It is false and malicious to refer to me as a "felon committing" individual
because I am not and have not. I am not a felon. I have never been
convicted of a felony whatsoever.
v1. It is false and malicious to refer to me as a "son" because I am a female
person who was born a female and has always identified as a female.
VIL It is false and malicious to refer to me as a "L TB," meaning, "lesbian
turned bi-sexual," because this is a malicious expression of hate speech.
vnt. It is false and malicious to refer to me as a "lesbian turned bi-sexual
commissioner" because I am in a happy and committed monogamous
relationship with my husband.
ix. It is false and malicious to refer to me as a "lesbian turned bi-sexual"
because that is not how I identify my sexuality or sexual orientation.
x. Although there may not be anything independently wrong with anyone
being a "lesbian turned bi-sexual" Reynolds is obviously maliciously
pandering to the insidious bigotry, prejudice and hatred that is shared
among some members of the community.
xi. Although there may not be anything independently wrong with anyone
identifying with either particular gender, Reynolds is obviously
maliciously pandering to the insidious bigotry, prejudice and hatred that is
shared among some members of the community against non-traditional
Affiant's Initials:~ Page 14 of 79 Page 12 of 2 1
sexual orientation persons, trans-gender persons or alternative gender
identifying persons.
d. FELONY CONDUCT IS A PAWLOSKI/GEORGE FAMILY VALUE!
1. This statement about me and my family is false and was made with actual
malice.
11. This statement is per se malicious.
111. This statement is per se libelous.
1v. It is false and malicious to refer to my family as celebrating felonious
conduct, or to imply that my relatives are felons because my relatives are
not felons. None of my immediate family members have ever been
convicted of a felony whatsoever. I am unaware of any family members
(distant or close) having ever been convicted of any felony.
v. It is false and malicious to refer to me as celebrating felonious conduct
because I do not. I am not a felon. I have never been convicted of a felony
whatsoever.
e. "THIS COMMENT WAS WRITTEN BY TOM REYNOLDS, a PERSON
RUNNING AGAINST L TB & FELON COMMITTING UNDINE GEORGE ...
for ST AUGUSTINE BEACH CITY COMMISSION" (see original comments
posted twice on 8/22/18, once at 12:58 pm and second time at 7: 19pm, but this
particular statement does not appear in the edited comments)
1. This statement about me is false and was made with actual malice.
11. lt is false and malicious to refer to me as being a "felony committing"
person because I have not. I am not a felon. I have never been convicted of
a felony whatsoever.
ui. This statement is per se malicious.
1v. This statement is per se libelous.
v. It is false and malicious to refer to me as a "LTB", meaning "lesbian
turned bi-sexual" because sexual orientation has nothing to do with being
a candidate for commissioner and saying this is a malicious expression of
hate speech.
Affiant's Initials:~ Page 15 of 79 Page 13 of21
v1. It is false and malicious to refer to me as a "LTB'', meaning "lesbian
turned bi-sexual" because I am in a happy and committed monogamous
relationship with my husband.
v11. It is false and malicious to refer to me as a "lesbian turned bi-sexual"
because that is not how I identify my sexuality or sexual orientation.
v111. Although there may not be anything independently wrong with anyone
being a " lesbian turned bi-sexual" Reynolds is obviously maliciously
pandering to the insidious bigotry, prejudice and hatred that is shared
among some members of the community.
1x. Although there may not be anything independently wrong with anyone
identifying with either particular gender, Reynolds is obviously
maliciously pandering to the insidious bigotry, prejudice and hatred that is
shared among some members of the community against non-traditional
sexual orientation persons, trans-gender persons or alternative gender
identifying persons.
x. In signing off on his comments in this way, Reynolds admits that these
false statements are maliciously made against me and my family because
they are purposed gain Reynolds additional votes and/or support in the
election, and/or to cause me to lose votes and/or support in the election.
WHEREFORE, Complainant respectfully requests a ruling that Reynolds is guilty of the
numerous violations of§ 104.271 (2), Fla. Stat., as identified in the above count, together with a
reclassification as allowed pursuant to §775.085, or as otherwise may be allowed by Jaw, an
award of attorney fees and costs for the prosecution of this action, and any other relief
appropriate and just under the circumstances.
COUNT IV
34. This is a Complaint against Reynolds for violation of§ 104.271 (2).
35. It is a violation of Fla. Stat. 104.271(2) if "any candidate who, in a primary election or
other election, with actual malice makes or causes to be made any statement about an
opposing candidate which is false."
Afftant's Initials:~ Page 16 of 79 Page 14 of21
36. On August 1, 2018, at around 6:43 a.m. , Reynolds did make false statement(s) against
opposing candidate, Undine C. George, with actual malice, on the internet, in response to
an article published in the Record.
37. The article Reynolds posted his false and malicious statements to was published by the
Record on July 31 , 2018 and was titled "St. Augustine Beach Commissioners Approve
Tentative Millage Increase" (hereinafter the "Tentative Millage Article"). See
http://www.staugustine.com/news/2018073 I /st-augustine-beach-comm issioners-approvet~
nt1:1,tiY~:miJl~g~:i!l9.I~i:l.!?.~ however the comments may have been removed and no longer
available on the Record website. (A true and correct copy of the article and comments
posted by Reynolds are attached as composite Exhibit "E").
38. Separate false statements are identifiable from Reynolds' posting to the Tentative Millage
Article. For convenience they are organized in this fourth count, however I believe that
each separate statement constitutes a separate and distinct violations of the statute.
39. Among the false statements made with actual malice by Reynolds, on the Record website
in response to the Tentative Millage Article, they include:
f. "COMMISSIONER GEORGE refused to allow any Public Input aka Public
Comment on the raising of City Residents Taxes."
1. This constitutes a statement made about Reynolds' opposing candidate,
Undine George, that she refused to allow any Public Input during the St.
Augustine Beach City Commission Special Budget Meeting which was
held on July 31, 2018.
IL This statement is false because Undine George, as Mayor, did allow public
comment at that meeting on the raising of City Residents Taxes.
11i. In fact, Mayor George suggested adding public comment to the agenda.
1v. A link to the video of the Special Budget Meeting in question is available
on the City of St. Augustine Beach website (
http: //www.staugbch.com/meetings ) and the video is on youtube at
b.ttQ§_;/f~,YQl:l.1.1::1 b~_,_9-0 m/wat~hl..Y-=:fAQ~S._BJ l 86E&fe!!t!l.Ie~y9g_lli. b~ ) .
v. The video of the meeting is time stamped and public comment began at
7:06pm on July 31 , 2018, approximately 2 hours, and 16.5 minutes into
the video.
Afftant's lnitials: !{).A Page 17 of 79 Page 15of21
v1. The City Commission as a whole addressed and had opportunity to
comment on Mayor George 's suggestion to add public comment to the
agenda, and this can be seen from the video as having occurred at
approximately 5:02 pm, 12 minutes into the video.
g. "YES Commissioner/Token Mayor Undine George, who is a Lesbian turned Bisexual
was showing his Trump Authoritarian MODE last night."
1. This contains false statements made with actual malice.
i1. It is false and malicious to refer to me as a male person because I am a
female person who was born a female and has always identified as a
female.
111. It is false and malicious to refer to me as a "lesbian turned bi-sexual
commissioner" because sexual orientation has nothing to do with being a
commissioner and saying this is a malicious expression of hate speech.
1v. It is false and malicious to refer to me as a "lesbian turned bi-sexual
commissioner" because I am in a happy and committed monogamous
relationship with my husband.
v. It is false and malicious to refer to me as a "lesbian turned bi-sexual"
because that is not how I identify my sexuality or sexual orientation.
v1. Although there may not be anything independently wrong with anyone
being a "lesbian turned bi-sexual" Reynolds is obviously maliciously
pandering to the insidious bigotry, prejudice and hatred that is shared
among some members of the community.
v11. Although there may not be anything independently wrong with anyone
identifying with either particular gender, Reynolds is obviously
maliciously pandering to the insidious bigotry, prejudice and hatred that is
shared among some members of the community against non-traditional
sexual orientation persons, trans-gender persons or alternative gender
identifying persons.
v1u. It is hateful and false to refer to me as having been in a "Trump
authoritarian MODE" during the meeting and that hatefulness fmiher
evidences that all of the false statements were made with malice.
Affiant's Initials:~ Page 18 of 79 Page 16 of2 I
h. "Undine, (Georges Father,the Felon Voter Fraudster Michelle Pawloski, is a big
TRUMP CHUMP)"
1. This statement about me is false and was made with actual malice.
11. It is false and malicious to refer to me as having a father who is a "Felon
Voter Fraudster" because my father is not a felon. My father has never
been convicted of a felony whatsoever.
111. This statement is per se malicious.
1v. This statement is per se libelous.
v. It is false and malicious to refer to me as having a father named "Michelle
Pawloski" because my father is a male who identifies as a man and whose
name is spelled Michelle Pawloski, which spelling is the feminine spelling
intended to imply a woman's name.
v1. Although there may not be anything independently wrong with anyone
identifying with either particular gender, Reynolds is obviously
maliciously pandering to the insidious bigotry, prejudice and hatred that is
shared among some members of the community against non-traditional
sexual orientation persons, trans-gender persons or alternative gender
identifying persons.
v11. Referring to me as having a father who is a "big TRUMP CHUM" is
evidencing Reynolds' intent to subject me to ridicule because the term has
a common meaning of being inherently degrading. The online urban
dictionary defines a "trump chum" as "a person with a monkey brain who
still supports president Trump" and Merriam Webster's online dictionary
defines a "chump" as "a person who is easily tricked : a stupid or foolish
person". Regardless of the fact that my father supports our president, it is a
derogatory term and was stated with malice, intending to harm my
reputation.
1. "HE, (UNDINE), she/he/ or is it a9he/she WANTS TO BE CALLED "HE" OR
'SIR"'
1. This statement about me is false and was made with actual malice.
11. I am a woman and do not want to be called a "he" or a " sir".
Affiant's Initials: 1l Page 19 of 79 Page 17of21
11i. It is false and malicious to refer to me as a "she/he/ or is it a9he/she"
because I am a female person who was born a female and has always
identified as a female.
iv. In making this false statement, Reynolds is obviously maliciously
pandering to the insidious bigotry, prejudice and hatred that is shared
among some members of the community against non-traditional sexual
orientation persons, trans-gender persons or alternative gender identifying
persons.
J. "VOTE OUT THE TAX and SPEND HOTEL DEVELOPER PUPPETS
UNDINE GEORGE"
i. This is a statement made about me, that I am a "hotel developer puppet"
and it is not true. Even to the extent that it could be said to be an opinion,
in the context of the entire comments made it is obviously with malicious
intent and a review of my public record reveals that it is not true.
ii. To the best of my recollection, only three hotel projects have come before
me while on the Commission and prior to that while serving on the
Planning and Zoning Board. They were: the Marriott at St. Augustine
Beach, the Embassy Suites Hotel which came before the Commission this
year for approval of a water park, and a proposed Holiday Inn on the
parcel immediately south of the Marriott. I voted against all three projects.
k. "Tom Reynolds, SAB GOV WATCH ... and a Candidate running against Lesbian
turned Bi-sexual Undine George"
i. This contains false statements made about me with actual malice.
1i. It is false and malicious to refer to me as a male person because I am a
female person who was born a female and has always identified as a
female.
BL It is false and malicious to refer to me as a "lesbian turned bi-sexual
commissioner" because sexual orientation has nothing to do with being a
commissioner and saying this is a malicious expression of hate speech.
Affiant's Initials~ Page 20 of 79 Page 18 of2 l
iv. It is false and malicious to refer to me as a "lesbian turned bi-sexual
commissioner" because I am in a happy and committed monogamous
relationship with my husband.
v. It is false and malicious to refer to me as a "lesbian turned bi-sexual"
because that is not how I identify my sexuality or sexual orientation.
vi. Although there may not be anything independently wrong with anyone
being a " lesbian turned bi-sexual" Reynolds is obviously maliciously
pandering to the insidious bigotry, prejudice and hatred that is shared
among some members of the community.
va. Although there may not be anything independently wrong with anyone
identifying with either particular gender, Reynolds is obviously
maliciously pandering to the insidious bigotry, prejudice and hatred that is
shared among some members of the community against non-traditional
sexual orientation persons, trans-gender persons or alternative gender
identifying persons.
WHEREFORE, Complainant respectfully requests a ruling that Reynolds is guilty of the
numerous violations of§ l 04.271 (2), Fla. Stat., as identified in the above count, together with a
reclassification as allowed pursuant to §775.085, or as otherwise may be allowed by law, an
award of attorney fees and costs for the prosecution of this action, and any other relief
appropriate and just under the circumstances.
COUNTY
40. This is a Complaint against Reynolds for violation of§ 104.271 (2).
41. It is a violation of Fla. Stat. l 04.27 I (2) if "any candidate who, in a primary election or
other election, with actual malice makes or causes to be made any statement about an
opposing candidate which is false."
42. On July 7, 2018 at around 7:40 a.m. and again on July 8, 2018, at around 8:54 a.m.,
Reynolds did make false statement(s) against opposing candidate, Undine C. George,
with actual malice, by email, in response to an invitation to be interviewed, as a candidate
Affiant's Initials:~ Page 21 of 79 Page 19 of2 l
for the Seat, by the St. Johns County Board of Realtors' political action committee. A
true and accurate copy of the emails are attached as composite Exhibit "F".
43. Among the false statements made with actual malice by Reynolds, by email to dozens of
people, they include:
a. "ENDORSE MY OPPONENT, LESBIAN TURNED BI-SEXUAL UNDINE E.
GEORGE! SHE IS THE PERFECT ENDORSEMENT FOR UNETHICAL
ODOM!"
vui. This statement about me is false and was made with actual malice.
ix. It is false and malicious to refer to me as a "lesbian turned bi-sexual"
because sexual orientation has nothing to do with being a candidate for
commissioner and saying this is a malicious expression of hate speech.
x. It is false and malicious to refer to me as a "lesbian turned bi-sexual"
because I am in a happy and committed monogamous relationship with
my husband.
xi. It is false and malicious to refer to me as a "lesbian turned bi-sexual"
because that is not how I identify my sexuality or sexual orientation.
xii. Although there may not be anything independently wrong with anyone
being a "lesbian turned bi-sexual" Reynolds is obviously maliciously
pandering to the insidious bigotry, prejudice and hatred that is shared
among some members of the community.
x11i. Although there may not be anything independently wrong with anyone
identifying with either particular gender, Reynolds is obviously
maliciously pandering to the insidious bigotry, prejudice and hatred that is
shared among some members of the community against non-traditional
sexual orientation persons, trans-gender persons or alternative gender
identifying persons.
xiv. Stating that I am the "perfect endorsement for [someone alleged to be]
unethical" is the equivalent of calling me unethical or supportive of
unethical conduct, which is a false statement made with actual malice as
the full contents of the email evidence.
Aftiant's Initials:~ Page 22 of 79 Page 20of21
WHEREFORE, Complainant respectfully requests a ruling that Reynolds is guilty of the
numerous violations of§ 104.271 (2), Fla. Stat., as identified in the above count, together with a
reclassification as allowed pursuant to §775.085, or as otherwise may be allowed by law, an
award of attorney fees and costs for the prosecution of this action, and any other relief
appropriate and just under the circumstances.
ATTORNEY FEES
Demand is hereby made for an award of reasonable attorney fees and costs for the
prosecution of this action, pursuant to Florida Law.
Respectfully submitted on September 11 , 2018, by:
Sworn to and subscribed before me this Jff!!..day of
Undine C. George, who is personally known to me.
¥m/aJe , 2018, by
~~~
My Commission Expires:
,,,,,,.~~//',, DEANNA LYNN DIXO~
~w.~ State of Florida-Notary Public
~. ·~ Commission # GG 119833
~,16 ~'" My Col"(lmission Expires
'''''"~''' June 28, 2021
Page 23 of 79 Page 21 of 21
1 comment:
Sheeeeeesh!
Smell the gross hypocrisy here.
We have an inciter to violence scum bag president who urges 'grabbing women by the pussy, punching people in the face, knock the crap out of them', etc., etc.,etc.,etc.,etc.,etc., and a rich preppy elite traitor lawyer accused of rape, who is being force fed to the Noble Liar, xtrevilist, corporate pig owned, supreme contort justice bench.
A rich preppy elite traitor lawyer, with a SECRET history of highly immoral legal machinations, who bases many of his specious decisions on a manufactured doctrine of "common accepted usage".
By that common accepted usage presidential measure, Tom Reynolds, is simply being a Great American.
Credentials have become a SLAPP in the face stain of deception...
http://saintaugdog.com/sadissues/issue1/1page1sad.html
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