It's about character and competence. We are all disappointed that St. Johns County Sheriff Robert Hardwick still retains some scoundrels or second-raters, like ethically-challenged Sheriff's General Counsel MATTHEW CLINE. Click here to watch the video of current Sheriff's current General Counsel MATTHEW CLINE lying about the government-owned World Golf Village Convention Center, threatening persecution of First Amendment rights and otherwise being an arrogant apparatchik, inter alia violating the civil rights of veteran Jeffrey Marcus Gray when MATTHEW CLINE was the UnderSheriff under controversial corrupt Sheriff DAVID SHOAR, who legally changed his name from "HOAR" in 1994. Fun fact: author of the Michelle O'Connell homicide coverup, disgraced ex-Sheriff DAVID SHOAR is the Chief Investigator for the WOOLSEY MARCOM law firm.
From WOKV:
St. Johns County Sheriff’s Office, General Counsel and more named in lawsuit disclosing sex crimes.
Jake Stofan, Action News Jax March 31, 2025
ST. JOHNS COUNTY, Fla. — Several St. Johns County leaders are named in a federal lawsuit claiming a sexual battery victim’s information was improperly released.
The federal lawsuit claims it was used for political mudslinging by her opponent.
The victim, identified as Jane Doe, is suing the St. Johns County Sheriff’s Office, Sheriff Rob Hardwick in his official capacity, former Undersheriff turned General Counsel Matthew Cline in his individual capacity, a judge, her husband, and an anti-domestic violence political action committee.
According to the lawsuit, former Undersheriff Cline is accused of starting a rumor that a candidate running for judge in St. Johns County previously reported a false sexual battery claim.
The victim’s attorney Cindy Myers explained her client was sexually battered, but ultimately didn’t pursue charges.
“She did focus on healing. She lost a ton of weight. I mean, she went through dramatic changes because of the emotional fallout from this situation,” said Myers.
The false claim rumor, according to court documents, eventually made it to Joshua and Casey Woolsey.
Casey was the victim’s only opponent in the judicial race.
The complaint claims Joshua Woolsey tried to get her sexual battery police report and was even shown an unredacted copy that contained personal identifying information of the victim that is protected under state law by Cline, who at that point was serving as the SJCSO’s General Counsel.
“There’s no reason for that report to be in that person’s hands unless they intended to use it against her to harass, shame, belittle her in this campaign,” said Myers.
Myers claimed Joshua and Casey Woolsey did just that, publicly accusing the victim of falsifying the sexual battery report during the campaign.
Casey Woolsey won the race, and the victim filed the lawsuit last May.
A recent motion to dismiss the case brought by Woolseys and the Stop Domestic Violence Florida political committee was largely rejected by a court, with the judge going so far as to write the alleged conduct is, “intolerable, atrocious and utterly outrageous”.
Currently, the Woolseys are accused of defaming the victim, while the St. Johns County Sheriff’s Office faces several claims including violations of public records laws and Marcy’s Law.
The sheriff’s office denied all wrongdoing in court filings.
Attorney Scott Thomas, who is representing the Woolseys in the case, issued the following statement to Action News Jax.
“On behalf of Woolsey Law and Casey and Josh Woolsey, we are pleased that the majority of these politically motivated claims have been dismissed at this initial stage. While it remains our belief that the case could and should have been dismissed in its entirety, we understand that in ruling on a motion to dismiss the Court was required to accept the plaintiff’s allegations as true and we respect the Court’s decision,” said Thomas. “To be certain, the Woolseys categorically deny the plaintiff’s false claims and are confident they will be vindicated in this proceeding as in the plaintiff’s prior three efforts.
Myers argued her client was re-traumatized by the release of her sensitive information, and the use of that information against her in the public sphere
“Her major concern is holding them accountable for sexual battery victims in St. Johns County. There has to be accountability for that. I mean, this is an egregious breach of confidentiality,” said Myers.
Depositions in the case are scheduled for next week.
SJCSO declined to comment on the pending litigation.
READ DOCKET HERE
U.S. District Court
Middle District of Florida (Jacksonville)
CIVIL DOCKET FOR CASE #: 3:24-cv-00489-BJD-MCR
Doe v. Hardwick et al Assigned to: Senior Judge Brian J. Davis Referred to: Magistrate Judge Monte C. Richardson Demand: $75,000 Cause: 42:1983 Civil Rights Act | Date Filed: 05/14/2024 Jury Demand: Both Nature of Suit: 440 Civil Rights: Other Jurisdiction: Federal Question |
| Plaintiff | ||
| Jane Doe | represented by | Marie A. Mattox Marie A Mattox PA 203 North Gadsden Street Tallahassee, FL 32301 850-383-4800 Email: marie@mattoxlaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED Cynthia Ann Myers Cynthia A. Myers, PA Cynthia A. Myers, PA PO Box 15011 Tallahassee, FL 32308 850-322-1124 Fax: 850-383-4801 Email: cindy@cindymyerslaw.com ATTORNEY TO BE NOTICED |
V. | ||
| Defendant | ||
| Robert A. Hardwick in his official capacity as Sheriff of St. Johns County Florida | represented by | Gwendolyn Palmer Adkins COPPINS MONROE, P.A. 2316 Killearn Center Boulevard Suite 202 Tallahassee, FL 32309 850-422-2420 Email: gadkins@coppinsmonroe.com LEAD ATTORNEY ATTORNEY TO BE NOTICED William Breen Armistead COPPINS MONROE, P.A. 2316 Killearn Center Blvd. Suite 202 Tallahassee, FL 32309 850-422-2420 Fax: 850-422-2730 Email: warmistead@coppinsmonroe.com ATTORNEY TO BE NOTICED |
| Defendant | ||
| Matthew Cline in his individual capacity | represented by | Gwendolyn Palmer Adkins (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED William Breen Armistead (See above for address) ATTORNEY TO BE NOTICED |
| Defendant | ||
| Joshua Woolsey | represented by | Bruce Michael Trybus Cooney Trybus Law 1600 W. Commercial Boulevard Suite 200 Fort Lauderdale, FL 33309 954-568-6669 Email: btrybus@cooneytrybus.com LEAD ATTORNEY ATTORNEY TO BE NOTICED Milo Scott Thomas Burr & Forman LLP 50 N. Laura Street Suite 3000 Jacksonville, FL 32202 904-232-7233 Fax: 904-232-7201 Email: msthomas@burr.com ATTORNEY TO BE NOTICED Patrick Cade Spivey Burr & Forman LLP 50 North Laura Street Suite 3000 Jacksonville, FL 32202 904-232-7269 Email: cspivey@burr.com ATTORNEY TO BE NOTICED |
| Defendant | ||
| Woolsey Law PLLC with a fictitious name of Woolsey Morcom PLLC | represented by | Cameron Scott Frye Dsk Law 609 W. Horatio Street Tampa, FL 33606 813-254-5825 Email: cfrye@dsklawgroup.com LEAD ATTORNEY ATTORNEY TO BE NOTICED Bart R. Valdes de Beaubien, Simmons, Knight, et al 609 W. Horatio St Tampa, FL 33606 813-251-5825 Fax: 813-254-1063 Email: bvaldes@dsklawgroup.com ATTORNEY TO BE NOTICED Milo Scott Thomas (See above for address) ATTORNEY TO BE NOTICED |
| Defendant | ||
| Casey Woolsey | represented by | Bruce Michael Trybus (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED Milo Scott Thomas (See above for address) ATTORNEY TO BE NOTICED Patrick Cade Spivey (See above for address) ATTORNEY TO BE NOTICED |
| Defendant | ||
| William Lee Owen, III | represented by | James Curtis Rinaman , III Dutton Law Group, P.A. 1054 Kings Avenue Jacksonville, FL 32207 904-421-6900 Fax: 904-421-6910 Email: service.jcr@duttonlawgroup.com LEAD ATTORNEY ATTORNEY TO BE NOTICED Katherine E. McKinley Luks, Santaniello, Petrillo, Cohen & Peterfriend 201 South Orange Ave, Suite 400 Suite 400 Orlando, FL 32801 407-540-9170 Fax: 407-540-9171 Email: kmckinley@insurancedefense.net ATTORNEY TO BE NOTICED |
| Defendant | ||
| Stop Domestic Violence Florida a Political Committee | represented by | Benjamin John Gibson Shutts & Bowen 215 South Monroe Street Suite 804 Tallahassee, FL 32301 850-241-1720 Fax: 850-241-1718 Email: bgibson@shutts.com LEAD ATTORNEY ATTORNEY TO BE NOTICED Denise Harle Shutts & Bowen 215 South Monroe Street Suite 804 Tallahassee, FL 32301 850-241-1727 Email: dharle@shutts.com ATTORNEY TO BE NOTICED Kassandra S. Reardon Shutts & Bowen 215 South Monroe Street Suite 804 Tallahassee, FL 32301 850-241-1724 Fax: 850-241-1716 Email: kreardon@shutts.com ATTORNEY TO BE NOTICED |
| Defendant | ||
| William Masson | ||
| Defendant | ||
| John Doe 1 | ||
| Defendant | ||
| Jane Doe 1 | ||
| Mediator | ||
| Jason Chad O'Steen | represented by | Jason O'Steen O'Steen & O'Steen, P.L. 2900 East Park Ave. Tallahassee, FL 32301 850-877-1028 Email: jason@osteenosteen.com ATTORNEY TO BE NOTICED |
| Date Filed | # | Docket Text |
|---|---|---|
| 05/14/2024 | 1 | COMPLAINT against All Defendants with Jury Demand (Filing fee $405 receipt number AFLMDC-22091910) filed by Jane Doe. (Attachments: # 1Proposed Summons, # 2 Proposed Summons, # 3 Proposed Summons, # 4 Proposed Summons, # 5 Proposed Summons, # 6 Proposed Summons, # 7Proposed Summons, # 8 Proposed Summons, # 9 Civil Cover Sheet )(Mattox, Marie) Modified text on 5/15/2024 (JK). (Entered: 05/14/2024) |
| 05/15/2024 | 2 | NEW CASE ASSIGNED to Senior Judge Brian J. Davis and Magistrate Judge Monte C. Richardson. New case number: 3:24-cv-489-BJD-MCR. (ARL) (Entered: 05/15/2024) |
| 05/15/2024 | 3 | NOTICE TO COUNSEL Cynthia Myers and Marie Mattox of Local Rule 2.02(a), which states, "The first paper filed on behalf of a party must designate only one lead counsel who - unless the party changes the designation - remains lead counsel throughout the action." Counsel must file a Notice of Lead Counsel Designation identifying lead counsel. (Signed by Deputy Clerk). (ARL) (Entered: 05/15/2024) |
| 05/15/2024 | 4 | NOTICE TO COUNSEL Cynthia Ann Myers of Local Rule 2.01(b)(2)(B), which requires members of the Middle District bar to maintain with the clerk a current telephone number, mailing address, and email address. Update your contact information (duplicate firm name) for the Middle District through PACER. (Signed by Deputy Clerk). (JK) (Entered: 05/15/2024) |
| 05/15/2024 | 5 | SUMMONS issued as to Matthew Cline, Robert A. Hardwick, William Lee Owen, III, Stop Domestic Violence Florida, Casey Woolsey, Joshua Woolsey, Woolsey Law PLLC. (JK) (Entered: 05/15/2024) |
| 05/16/2024 | 6 | NOTICE of Local Rule 3.02(a)(2), which requires the parties in every civil proceeding, except those described in subsection (d), to file a case management report (CMR) using the uniform form at www.flmd.uscourts.gov. The CMR must be filed (1) within forty days after any defendant appears in an action originating in this court, (2) within forty days after the docketing of an action removed or transferred to this court, or (3) within seventy days after service on the United States attorney in an action against the United States, its agencies or employees. Judges may have a special CMR form for certain types of cases. These forms can be found at www.flmd.uscourts.gov under the Forms tab for each judge. (Signed by Judicial Assistant). (AMP) (Entered: 05/16/2024) |
| 05/16/2024 | 7 | NOTICE of Lead Counsel Designation by Marie A. Mattox on behalf of Jane Doe. Lead Counsel: Marie A. Mattox. (Mattox, Marie) (Entered: 05/16/2024) |
| 05/17/2024 | 8 | SUMMONS issued as to Division of Risk Management. (JK) (Entered: 05/17/2024) |
| 05/20/2024 | 9 | RETURN of service executed on 05120/2024 by Jane Doe as to William Lee Owen, III. (Mattox, Marie) (Entered: 05/20/2024) |
| 05/24/2024 | 10 | RETURN of service executed on 05/21/2024 by Jane Doe as to Robert A. Hardwick. (Mattox, Marie) (Entered: 05/24/2024) |
| 05/24/2024 | 11 | RETURN of service executed on 05/21/2024 by Jane Doe as to Matthew Cline. (Mattox, Marie) (Entered: 05/24/2024) |
| 05/24/2024 | 12 | RETURN of service executed on 05/22/2024 by Jane Doe as to Division of Risk Management Department of Financial Services. (Mattox, Marie) Modified docket text on 5/28/2024 (JOS). (Entered: 05/24/2024) |
| 05/31/2024 | 13 | NOTICE of Appearance and Waiver of Service of Process Appearance by Milo Scott Thomas on behalf of Casey Woolsey, Joshua Woolsey, Woolsey Law PLLC. (Thomas, Milo) (Entered: 05/31/2024) |
| 06/05/2024 | 14 | NOTICE of Appearance by Benjamin John Gibson on behalf of Stop Domestic Violence Florida (Gibson, Benjamin) (Entered: 06/05/2024) |
| 06/05/2024 | 15 | NOTICE of Appearance by Denise Harle on behalf of Stop Domestic Violence Florida (Harle, Denise) (Entered: 06/05/2024) |
| 06/05/2024 | 16 | NOTICE of Appearance by Kassandra S. Reardon on behalf of Stop Domestic Violence Florida (Reardon, Kassandra) (Entered: 06/05/2024) |
| 06/05/2024 | 17 | RETURN of service executed on 06/03/2024 by Jane Doe as to Stop Domestic Violence Florida. (Mattox, Marie) (Entered: 06/05/2024) |
| 06/06/2024 | 18 | NOTICE of Lead Counsel Designation by Gwendolyn Palmer Adkins on behalf of Matthew Cline, Robert A. Hardwick. Lead Counsel: Gwendolyn P. Adkins. (Adkins, Gwendolyn) (Entered: 06/06/2024) |
| 06/06/2024 | 19 | NOTICE of Appearance by James Curtis Rinaman, III on behalf of William Lee Owen, III (Rinaman, James) (Entered: 06/06/2024) |
| 06/07/2024 | 20 | Unopposed MOTION for Extension of Time to File Answer to Respond to Plaintiff's Complaint by William Lee Owen, III. (Rinaman, James) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 06/07/2024) |
| 06/07/2024 | 21 | NOTICE of Lead Counsel, Designation and Appearance by James Curtis Rinaman, III on behalf of William Lee Owen, III (Rinaman, James) (Entered: 06/07/2024) |
| 06/10/2024 | 22 | ENDORSED ORDER granting 20 Unopposed Motion for Extension of Time to Respond to Plaintiff's Complaint. Defendant William Lee Owen, III's response to the Complaint is due on or before June 30, 2024. Signed by Magistrate Judge Monte C. Richardson on 6/10/2024. (JRM) (Entered: 06/10/2024) |
| 06/10/2024 | 23 | Joint MOTION for Extension of Time to File Answer re 1 Complaint (Unopposed) by Matthew Cline, Robert A. Hardwick. (Adkins, Gwendolyn) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 06/10/2024) |
| 06/11/2024 | 24 | ENDORSED ORDER granting 23 Unopposed Joint Motion for Extension of Time to Respond to Complaint. Defendants Sheriff Hardwick, Matthew Cline, and Stop Domestic Violence Florida's response to the Complaint is due on or before June 30, 2024. Signed by Magistrate Judge Monte C. Richardson on 6/11/2024. (JRM) (Entered: 06/11/2024) |
| 06/14/2024 | 25 | NOTICE of Appearance by Katherine E. McKinley on behalf of William Lee Owen, III (McKinley, Katherine) (Entered: 06/14/2024) |
| 06/20/2024 | 26 | NOTICE Appearance and Lead Counsel Designation by Bruce Michael Trybus on behalf of Casey Woolsey, Joshua Woolsey (Trybus, Bruce) Modified text on 6/21/2024 (AM). (Entered: 06/20/2024) |
| 06/20/2024 | 27 | MOTION for Extension of Time to File Answer to 1 Complaint by Casey Woolsey, Joshua Woolsey. (Trybus, Bruce) Motions referred to Magistrate Judge Monte C. Richardson. Modified text on 6/21/2024 (AM). (Entered: 06/20/2024) |
| 06/21/2024 | 28 | Unopposed MOTION for Extension of Time to File Response to 1 Complaint by Woolsey Law PLLC. (Thomas, Milo) Motions referred to Magistrate Judge Monte C. Richardson. Modified docket text on 6/24/2024 (JOS). (Entered: 06/21/2024) |
| 06/24/2024 | 29 | ENDORSED ORDER granting 28 Unopposed Motion for Extension of Time to file Response. Defendant Woolsey Law PLLC's Response to the Complaint is due on or before June 30, 2024. Signed by Magistrate Judge Monte C. Richardson on 6/24/2024. (JRM) (Entered: 06/24/2024) |
| 06/24/2024 | 30 | ENDORSED ORDER taking under advisement 27 Motion for Extension of Time to Respond to Complaint by Defendants Joshua Woolsey and Casey Woolsey. On or before June 28, 2024, Defendants Joshua Woolsey and Casey Woolsey shall clarify whether Plaintiff opposes the Motion in accordance with Local Rule 3.01(g). Signed by Magistrate Judge Monte C. Richardson on 6/24/2024. (JRM) (Entered: 06/24/2024) |
| 06/26/2024 | 31 | MOTION to Compel Plaintiff to Proceed in Her Own Name by Matthew Cline, Robert A. Hardwick. (Adkins, Gwendolyn) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 06/26/2024) |
| 06/27/2024 | 32 | NOTICE of Appearance by Cameron Scott Frye on behalf of Woolsey Law PLLC (Frye, Cameron) (Entered: 06/27/2024) |
| 06/27/2024 | 33 | NOTICE of Lead Counsel Designation by Cameron Scott Frye on behalf of Woolsey Law PLLC. Lead Counsel: Cameron Frye. (Frye, Cameron) (Entered: 06/27/2024) |
| 06/28/2024 | 34 | JOINDER in motion by Woolsey Law PLLC Defendant Woolsey Law, PLLC's Joinder in Motion to Compel Plaintiff to Proceed in Her Own Name by Sheriff Robert A. Hardwick and Matthew Cline. (Thomas, Milo) (Entered: 06/28/2024) |
| 06/28/2024 | 35 | Unopposed MOTION for Extension of Time to File Answer Complaint by Defendants Joshua Woolsey and Casey Woolsey by Casey Woolsey, Joshua Woolsey. (Trybus, Bruce) Motions referred to Magistrate Judge Monte C. Richardson. Modified on 6/28/2024 (CTR). (Entered: 06/28/2024) |
| 06/30/2024 | 36 | MOTION to Dismiss for Failure to State a Claim by Woolsey Law PLLC. (Frye, Cameron) (Entered: 06/30/2024) |
| 06/30/2024 | 37 | MOTION to Dismiss for Failure to State a Claim by Stop Domestic Violence Florida. (Gibson, Benjamin) (Entered: 06/30/2024) |
| 07/01/2024 | 38 | Second Unopposed MOTION for Extension of Time to File Answer to Respond to Plaintiff's Complaint by William Lee Owen, III. (Rinaman, James) Motions referred to Magistrate Judge Monte C. Richardson. Modified 7/2/2024 as to docket text (ARL) (Entered: 07/01/2024) |
| 07/01/2024 | 39 | ENDORSED ORDER granting 35 Unopposed Motion for Second Extension of Time to Respond to Complaint by Defendants Joshua Woolsey and Casey Woolsey. Defendant shall have until July 10, 2024, to respond to Plaintiff's Complaint. Signed by Magistrate Judge Monte C. Richardson on 7/1/2024. (JRC) Modified on 7/2/2024 to edit docket text and regenerate nef (MDC). (Entered: 07/01/2024) |
| 07/01/2024 | 40 | ANSWER and affirmative defenses to 1 Complaint with Jury Demand by Matthew Cline, Robert A. Hardwick.(Adkins, Gwendolyn) (Entered: 07/01/2024) |
| 07/02/2024 | 41 | ENDORSED ORDER granting 38 Defendant, William Lee Owen, III, Second Unopposed Motion for Extension of Time to Respond to Plaintiff's Complaint. Defendant shall have until July 11, 2024, to respond to Plaintiff's Complaint. Signed by Magistrate Judge Monte C. Richardson on 7/2/2024. (JRC) (Entered: 07/02/2024) |
| 07/02/2024 | 42 | NOTICE of compliance re 36 MOTION to Dismiss for Failure to State a Claim Compliance with Local Rule 3.01(g) by Woolsey Law PLLC (Frye, Cameron) (Entered: 07/02/2024) |
| 07/10/2024 | 43 | MOTION to Dismiss Dismiss Counts VI, VII, VIII and IX of the Complaint by Casey Woolsey, Joshua Woolsey. (Attachments: # 1 Exhibit 1 Woolsey Declaration with Exhibits, # 2 Exhibit 2 Cline Declaration)(Trybus, Bruce) Modified text on 7/11/2024 (KME). (Entered: 07/10/2024) |
| 07/10/2024 | 44 | Unopposed MOTION for Extension of Time to File Response/Reply by Jane Doe. (Mattox, Marie) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 07/10/2024) |
| 07/11/2024 | 45 | MOTION to Dismiss Counts V, VI,VII, VIII and IX of Complaint by William Lee Owen, III. (Rinaman, James) (Entered: 07/11/2024) |
| 07/12/2024 | 46 | ENDORSED ORDER granting 44 Unopposed Motion for Extension of Time to File Response to Pending Motion to Compel. Plaintiff's response is due on or before July 15. Signed by Magistrate Judge Monte C. Richardson on 7/12/2024. (JRM) (Entered: 07/12/2024) |
| 07/12/2024 | 47 | ENDORSED ORDER denying as moot 27 Motion for Extension of Time to File Answer to Complaint by Casey Woolsey and Joshua Woolsey. Signed by Magistrate Judge Monte C. Richardson on 7/12/2024. (JRM) (Entered: 07/12/2024) |
| 07/15/2024 | 48 | SUPPLEMENT re 45 MOTION to Dismiss Counts V, VI,VII, VIII and IX of Complaint by William Lee Owen, III. (Rinaman, James) (Modified on 7/15/2024, to edit text) (BGR). (Entered: 07/15/2024) |
| 07/15/2024 | 49 | RESPONSE in Opposition re 31 MOTION to Compel Plaintiff to Proceed in Her Own Name filed by Jane Doe. (Mattox, Marie) (Entered: 07/15/2024) |
| 07/15/2024 | 50 | AMENDED COMPLAINT against All Defendants with Jury Demand. filed by Jane Doe.(Mattox, Marie) (Entered: 07/15/2024) |
| 07/25/2024 | 51 | MOTION to Dismiss for Failure to State a Claim by Woolsey Law PLLC. (Frye, Cameron) (Entered: 07/25/2024) |
| 07/29/2024 | 52 | MOTION for Extension of Time to Amend Complaint By Defendants Joshua Woolsey & Casey Woolsey by Casey Woolsey, Joshua Woolsey. (Trybus, Bruce) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 07/29/2024) |
| 07/29/2024 | 53 | MOTION to Dismiss Counts V, VI,VII, VIII and IX of Amended Complaint by William Lee Owen, III. (Rinaman, James) (Entered: 07/29/2024) |
| 07/29/2024 | 54 | MOTION to Dismiss Counts V, VIII, and IX of Amended Complaint and Incorporated Memorandum of Law by Stop Domestic Violence Florida. (Gibson, Benjamin) (Entered: 07/29/2024) |
| 07/29/2024 | 55 | RESPONSE re 49 Response in Opposition to Motion to Compel Plaintiff to Proceed in Her Own Name by Matthew Cline, Robert A. Hardwick. (Adkins, Gwendolyn) (Entered: 07/29/2024) |
| 07/29/2024 | 56 | ANSWER and affirmative defenses with Jury Demand to 50 Amended Complaint by Matthew Cline, Robert A. Hardwick.(Adkins, Gwendolyn)(Entered: 07/29/2024) |
| 07/29/2024 | 57 | MEMORANDUM in opposition re 49 Response in Opposition to Motion to Proceed Anonymously filed by Woolsey Law PLLC. (Thomas, Milo) (Entered: 07/29/2024) |
| 07/30/2024 | 58 | SUPPLEMENT to Motion to Dismiss filed 7/29/24 by William Lee Owen, III. (Rinaman, James) (Entered: 07/30/2024) |
| 08/02/2024 | 59 | Supplemental MOTION for Extension of Time to File Answer Amended Complaint by Casey Woolsey, Joshua Woolsey. (Trybus, Bruce) Motions referred to Magistrate Judge Monte C. Richardson. Modified text on 8/2/2024 (GL). (Entered: 08/02/2024) |
| 08/02/2024 | 60 | ENDORSED ORDER granting 52 Motion For Extension Of Time To Respond To Amended Complaint By Defendants Joshua Woolsey And Casey Woolsey, in light of 59 Supplement To Motion For Extension Of Time To Respond To Amended Complaint. On or before August 8, 2024, Defendants Joshua Woolsey and Casey Woolsey shall file their answer to Plaintiff's Complaint. Signed by Magistrate Judge Monte C. Richardson on 8/2/2024. (JRM) (Entered: 08/02/2024) |
| 08/02/2024 | 61 | ORDER directing the parties to SHOW CAUSE on or before August 12, 2024, why sanctions should not be imposed for their failure to file a Case Management Report within the time prescribed by Local Rule 3.02(b)(1). Failure to respond may result in dismissal or sanctions without further notice. Signed by Senior Judge Brian J. Davis on 8/2/2024. (AMP) (Modified on 8/21/2024, DISCHARGED per 77 Order) (BGR). (Entered: 08/02/2024) |
| 08/06/2024 | 62 | CERTIFICATE of counsel re 51 MOTION to Dismiss for Failure to State a Claim by Cameron Scott Frye on behalf of Woolsey Law PLLC (Frye, Cameron) (Entered: 08/06/2024) |
| 08/08/2024 | 63 | MOTION to Dismiss AMENDED COMPLAINT by Casey Woolsey, Joshua Woolsey. (Trybus, Bruce) (Entered: 08/08/2024) |
| 08/08/2024 | 64 | UNOPPOSED MOTION for Extension of Time to File Response/Reply to 51 Motion to Dismiss by Jane Doe. (Mattox, Marie) Motions referred to Magistrate Judge Monte C. Richardson. Modified on 8/9/2024 to edit text (ELM). (Entered: 08/08/2024) |
| 08/12/2024 | 65 | ENDORSED ORDER granting 64 Plaintiff's Unopposed Motion for Extension of Time to File Response to Pending Motion to Dismiss. Plaintiff's response to Defendant's Motion to Dismiss is due on or before August 19, 2024. Signed by Magistrate Judge Monte C. Richardson on 8/9/2024. (JRM) (Entered: 08/12/2024) |
| 08/12/2024 | 66 | CERTIFICATE of interested persons and corporate disclosure statement by Jane Doe. (Mattox, Marie) (Entered: 08/12/2024) |
| 08/12/2024 | 67 | CORPORATE Disclosure Statement by Stop Domestic Violence Florida. (Gibson, Benjamin) (Entered: 08/12/2024) |
| 08/12/2024 | 68 | CASE MANAGEMENT REPORT. (Mattox, Marie) (Entered: 08/12/2024) |
| 08/12/2024 | 69 | RESPONSE TO ORDER TO SHOW CAUSE re 61 Order filed by Jane Doe. (Mattox, Marie) Modified text on 8/13/2024 (MCB). (Entered: 08/12/2024) |
| 08/12/2024 | 70 | RESPONSE in Opposition re 53 MOTION to Dismiss Counts V, VI,VII, VIII and IX of Amended Complaint filed by Jane Doe. (Mattox, Marie) (Entered: 08/12/2024) |
| 08/12/2024 | 71 | RESPONSE in Opposition re 54 MOTION to Dismiss Counts V, VIII, and IX of Amended Complaint and Incorporated Memorandum of Law filed by Jane Doe. (Mattox, Marie) (Entered: 08/12/2024) |
| 08/14/2024 | 72 | Unopposed MOTION to Stay Discovery Pending the Court's Ruling on Defendants' 63 Motion to Dismiss Plaintiff's Amended Complaint by Casey Woolsey, Joshua Woolsey. (Trybus, Bruce) Modified docket text on 8/15/2024 (EVK). (Entered: 08/14/2024) |
| 08/15/2024 | 73 | JOINDER in motion by Woolsey Law PLLC re 72 MOTION to Stay Discovery Pending the Court's Ruling on Defendants' 51 Motion to Dismiss Plaintiff's Amended Complaint filed by Joshua Woolsey, Casey Woolsey . (Frye, Cameron) Modified docket text on 8/15/2024 (EVK). (Entered: 08/15/2024) |
| 08/19/2024 | 74 | ORDER DENYING AS MOOT 36, 37, 43 and 45 Motions to Dismiss which preceded Plaintiff's Amended Complaint; GRANTING 72Defendants' Motion to Stay Discovery Pending the Court's Ruling on Defendants' Motion to Dismiss Plaintiff's Amended Complaint. Discovery as to Joshua Woolsey, Casey Woolsey and Woolsey Law PLLC is STAYED pending a ruling on their Motions to Dismiss. Signed by Senior Judge Brian J. Davis on 8/19/2024. (AMP) (Entered: 08/19/2024) |
| 08/19/2024 | 75 | RESPONSE in Opposition re 51 MOTION to Dismiss for Failure to State a Claim filed by Jane Doe. (Mattox, Marie) (Entered: 08/19/2024) |
| 08/20/2024 | 76 | SECOND NOTICE TO COUNSEL Cynthia Ann Myers of Local Rule 2.01(b)(2)(B), which requires members of the Middle District bar to maintain with the clerk a current telephone number, mailing address, and email address. Update your contact information (duplicate firm name in profile) for the Middle District through PACER. (Signed by Deputy Clerk). (JK) (Entered: 08/20/2024) |
| 08/20/2024 | 77 | ENDORSED ORDER DISCHARGING 61 Order to Show Cause in light of 68 Case Management Report and 69 Response to Order to Show Cause. Signed by Senior Judge Brian J. Davis on 8/20/2024. (AMP) (Entered: 08/20/2024) |
| 08/23/2024 | 78 | MOTION for Extension of Time to File Response; re 63 Motion to Dismiss by Jane Doe. (Mattox, Marie) Motions referred to Magistrate Judge Monte C. Richardson. (Modified on 8/23/2024, to edit text) (BGR). (Entered: 08/23/2024) |
| 08/23/2024 | 79 | AMENDED MOTION for Extension of Time to File Response; re 63 Motion to Dismiss by Jane Doe. (Mattox, Marie) Motions referred to Magistrate Judge Monte C. Richardson. (Modified on 8/23/2024, to edit text) (BGR). (Entered: 08/23/2024) |
| 08/26/2024 | 80 | ENDORSED ORDER granting 79 Plaintiff's Amended Motion for Extension of Time to File Response and denying as moot 78 Plaintiff's Motion for Extension of Time to File Response. Plaintiff's response to Motion to Dismiss Amended Complaint is due on or before August 29, 2024. Signed by Magistrate Judge Monte C. Richardson on 8/26/2024. (JRM) (Entered: 08/26/2024) |
| 08/29/2024 | 81 | CASE MANAGEMENT AND SCHEDULING ORDER: Mediator selection due by 10/31/2024; Conduct mediation hearing by 4/30/2025; Discovery due by 5/30/2025; Dispositive motions due by 6/30/2025; Pretrial statement due by 11/12/2025; Final Pretrial Conference set for 11/19/2025 at 10:00 AM in Jacksonville Courtroom 12 C before Senior Judge Brian J. Davis; Jury Trial set for trial term commencing on 12/1/2025 at 9:00 AM in Jacksonville Courtroom 12 C before Senior Judge Brian J. Davis. Signed by Senior Judge Brian J. Davis on 8/29/2024. (Attachments: # 1 Mediation Report Form, # 2 Docket Sheets)(AMP) (Entered: 08/29/2024) |
| 08/29/2024 | 82 | RESPONSE in Opposition re 63 MOTION to Dismiss AMENDED COMPLAINT filed by Jane Doe. (Attachments: # 1 Exhibit, # 2 Exhibit)(Mattox, Marie) (Entered: 08/29/2024) |
| 08/30/2024 | 83 | MOTION to Stay Discovery Pending the Court's Ruling on Defendant Owen's Motion to Dismiss Plaintiff's Amended Complaint by William Lee Owen, III. (Rinaman, James) (Entered: 08/30/2024) |
| 09/06/2024 | 84 | MOTION for Leave to File Reply by Casey Woolsey, Joshua Woolsey. (Thomas, Milo) (Entered: 09/06/2024) |
| 09/06/2024 | 85 | DISCLOSURE STATEMENT under Rule 7.1, Federal Rules of Civil Procedure, and Local Rule 3.03 by Woolsey Law PLLC. (Frye, Cameron) (Entered: 09/06/2024) |
| 09/06/2024 | 86 | ENDORSED ORDER granting 83 Motion to Stay Discovery. Discovery as to William Owen, III, is STAYED pending a ruling on his 53 Motion to Dismiss. Signed by Senior Judge Brian J. Davis on 9/6/2024. (MCW) (Entered: 09/06/2024) |
| 09/09/2024 | 87 | NOTICE by Joshua Woolsey of his Proposal for Settlement (Trybus, Bruce) (Entered: 09/09/2024) |
| 09/11/2024 | 88 | ENDORSED ORDER: 84 Defendants Joshua Woolsey and Casey Woolsey's Motion for Leave to File Reply is GRANTED. Defendants shall file their reply of no more than five (5) substantive pages on or before September 24, 2024. Signed by Senior Judge Brian J. Davis on 9/10/2024. (AMP) (Entered: 09/11/2024) |
| 09/23/2024 | 89 | ORDER granting 31 Defendants' Motion to Compel Plaintiff to Proceed in Her Own Name. Signed by Magistrate Judge Monte C. Richardson on 9/23/2024. (JRM) (Entered: 09/23/2024) |
| 09/24/2024 | 90 | REPLY to Response to Motion re 63 MOTION to Dismiss AMENDED COMPLAINT filed by Casey Woolsey, Joshua Woolsey. (Thomas, Milo) (Entered: 09/24/2024) |
| 09/27/2024 | 91 | RESPONSE TO ORDER TO SHOW CAUSE filed by Jane Doe. (Mattox, Marie) (Entered: 09/27/2024) |
| 10/07/2024 | 92 | OBJECTION re 89 Order on Motion to Compel . (Mattox, Marie) (Entered: 10/07/2024) |
| 10/16/2024 | 93 | NOTICE of Additional Counsel Designation by William Breen Armistead on behalf of Matthew Cline, Robert A. Hardwick (Armistead, William) (Modified on 10/17/2024, to edit text) (BGR). (Entered: 10/16/2024) |
| 10/16/2024 | 94 | DISCLOSURE STATEMENT under Rule 7.1, Federal Rules of Civil Procedure, and Local Rule 3.03 by Matthew Cline, Robert A. Hardwick. (Armistead, William) (Entered: 10/16/2024) |
| 11/05/2024 | 95 | JOINT Notice of Selection of Jason Chad O'Steen as Mediator by Matthew Cline, Robert A. Hardwick. (Adkins, Gwendolyn) (Modified on 11/6/2024, to edit text) (BGR). (Entered: 11/05/2024) |
| 11/07/2024 | 96 | ORDER Appointing Jason Chad O'Steen, Esq. as mediator in this action. Signed by Senior Judge Brian J. Davis on 11/7/2024. (AMP) (Entered: 11/07/2024) |
| 02/17/2025 | 97 | MOTION for Protective Order, MOTION to Stay Discovery by Jane Doe. (Mattox, Marie) Motions referred to Magistrate Judge Monte C. Richardson. (Entered: 02/17/2025) |
| 02/17/2025 | 98 | AMENDED MOTION for Protective Order , MOTION to Stay Discovery by Jane Doe. (Mattox, Marie) Motions referred to Magistrate Judge Monte C. Richardson. Modified on 2/18/2025 to edit text (ELA). (Entered: 02/17/2025) |
| 03/05/2025 | 99 | RESPONSE in Opposition re 98 AMENDED MOTION for Protective Order MOTION to Stay Discovery filed by Robert A. Hardwick. (Adkins, Gwendolyn) (Entered: 03/05/2025) |
| 03/05/2025 | 100 | MOTION for Protective Order, MOTION to Quash Subpoena for Verizon Records by Jane Doe. (Mattox, Marie) Motions referred to Magistrate Judge Monte C. Richardson. Modified text on 3/6/2025 (JK). (Entered: 03/05/2025) |
| 03/12/2025 | 101 | ORDER taking under advisement 100 Plaintiff's Motion for Protective Order and to Quash Subpoena to Verizon. Plaintiff's filing due by 3/17/25. See Order for details. Signed by Magistrate Judge Monte C. Richardson on 3/12/2025. (TAM) (Entered: 03/12/2025) |
| 03/14/2025 | 102 | NOTICE of compliance with ECF 101 by Jane Doe (Attachments: # 1 Exhibit)(Mattox, Marie) (Entered: 03/14/2025) |
| 03/26/2025 | 103 | ENDORSED ORDER directing Defendant Robert A. Hardwick to respond to 100 Plaintiff's Motion for Protective Order and to Quash Subpoena to Verizon on or before March 28, 2025, or else the Motion will be considered unopposed. Signed by Magistrate Judge Monte C. Richardson on 3/25/2025. (TAM) (Entered: 03/26/2025) |
| 03/26/2025 | 104 | ORDER GRANTING IN PART and DENYING IN PART 51 Defendant Woolsey Law PLLC's Motion to Dismiss for Failure to State a Claim; GRANTING IN PART and DENYING IN PART 53 Defendant William Lee Owen, III's Motion to Dismiss; GRANTING IN PART and DENYING IN PART 54 Stop Domestic Violence Florida's Motion to Dismiss Counts V, VIII and IX; GRANTING IN PART and DENYING IN PART 63Defendants Joshua Woolsey and Casey Woolsey's Motion to Dismiss. See order for details. Signed by Senior Judge Brian J. Davis on 3/26/2025. (AMP) (Entered: 03/26/2025) |
| 03/28/2025 | 105 | RESPONSE in Opposition re 100 MOTION for Protective Order MOTION to Quash Subpoena for Verizon Records filed by Matthew Cline, Robert A. Hardwick. (Armistead, William) (Entered: 03/28/2025) |
| 04/01/2025 | 106 | ORDER denying without prejudice 100 Plaintiff's Motion for Protective Order and to Quash Subpoena to Verizon. See Order for details. Signed by Magistrate Judge Monte C. Richardson on 3/31/2025. (TAM) (Entered: 04/01/2025) |
------ READ FIRST PAGE OF AMENDED COMPLAINT HERE:
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
JACKSONVILLE DIVISION
CASE NO.: 3:24-cv-00489-BJD-MCR
JANE DOE,
Plaintiff,
v.
ROBERT A. HARDWICK, in his official
capacity as SHERIFF, ST. JOHNS COUNTY;
MATTHEW CLINE, in his individual capacity;
JOSHUA WOOLSEY; WOOLSEY LAW PLLC,
with a fictitious name of WOOLSEY MORCOM PLLC;
CASEY WOOLSEY; WILLIAM MASSON, WILLIAM
LEE OWEN, III; JOHN DOE I, AND JANE DOE I
of STOP DOMESTIC VIOLENCE, a Political Committee.
Defendants,
____________________________________/
AMENDED COMPLAINT
Plaintiff, JANE DOE, hereby sues Defendant, ROBERT A. HARDWICK, in
his official capacity as SHERIFF, ST. JOHNS COUNTY; MATTHEW
MATTHEW CLINE, in his individual capacity;
JOSHUA WOOLSEY; WOOLSEY LAW PLLC,
with a fictitious name of WOOLSEY MORCOM PLLC;
CASEY WOOLSEY; WILLIAM MASSON, WILLIAM
LEE OWEN, III; JOHN DOE I, AND JANE DOE I
of STOP DOMESTIC VIOLENCE, a Political Committee.
Defendants,
____________________________________/
NATURE OF THE ACTION
1. This is a civil action seeking monetary damages, declaratory judgment,
and legal, equitable, and injunctive relief against Defendants. This is an action
brought under the United States Constitution, 42 U.S.C. § 1983, the Florida
Constitution, the Florida Statutes, and the common laws of the State of Florida.
2. This is an action involving claims which are, individually, in excess of
Seventy-Five Thousand Dollars ($75,000.00).
PARTIES
3. At all times pertinent hereto, Plaintiff, JANE DOE, has been a resident
of St. Johns County. She is sui juris.
4. At all times pertinent hereto, Defendant, ROBERT A. HARDWICK, in
his official capacity as SHERIFF, ST. JO
No comments:
Post a Comment