IN THE CIRCUIT COURT OF THE

SECOND JUDICIAL CIRCUIT IN AND

FOR LEON COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION

MARGARET ANN “PEGGY” SCHILLER and

WALTER ROWE ARRINGTON,

Plaintiffs,

vs. 2022

REBEKAH JONES, BOBBY BEASLEY in

his official capacity as the Supervisor of
Elections in Walton County, DAVID H.
STAFFORD in his official capacity as the
Supervisor of Elections in Escambia
County, PAUL LUX in his official
capacity as the Supervisor of Elections
in Okaloosa County, TAPPIE VILLANE
in her official capacity as Supervisor of
Elections in Santa Rosa County and
CORD BYRD, in his official capacity as
Florida Secretary of State.

Defendants.
/

EMERGENCY COMPLAINT FOR DECLARATORY

AND INJUNCTIVE RELIEF
(Temporary Injunction Requested)

The Plaintiffs, MARGARET ANN “PEGGY” SCHILLER (“SCHILLER”) and WALTER

ROWE ARRINGTON (“ARRINGTON”) sue the Defendants, REBEKAH JONES

(“JONES”), BOBBY BEASLEY (“BEASLEY”) in his official capacity as the Supervisor of

Elections in Walton County, DAVID H. STAFFORD (“STAFFORD”) in his official

1
capacity as the Supervisor of Elections in Escambia, PAUL LUX (“LUX”) in his

official capacity as the Supervisor of Elections in Okaloosa County, TAPPIE

VILLANE (“VILLANE”) in her official capacity as Supervisor of Elections in Santa

Rosa County and CORD BYRD (BYRD), in his official capacity as Florida Secretary

of State, and alleges as follows:

1. This action is initiated pursuant to § 86.021, Florida Statutes (F.S.) and

pursuant to the General Equity Jurisdiction of the Court as established in

F.S. §26.012, asking this court to declare that, JONES, who has qualified

to run as a candidate for US Congress in District 1 as a member of the

Democratic Party, has violated § 99.021 of the Florida Statutes which

required her to be a member of the Democratic party for the previous 365

days prior to qualifying for office, as JONES was registered without party

affiliation between June 11, 201 and August 11, 2021.

2. Plaintiff also seeks Injunctive relief to direct the Defendants, BEASLEY,

STAFFORD, LUX AND VILLANE AND BYRD to remove JONES from the list

of qualified Candidates for the August 23, 2022, Democratic Primary

Election for US House District 1 in Florida.

3. Because the candidates for this office qualified with the Secretary of State

in Tallahassee, Florida, venue is proper in Leon County, Florida.

4. The Plaintiff, SCHILLER, is a Democratic candidate for US House, District

1 and is JONES’ opponent in that primary election. [See Exhibit “A”,

qualifying papers of SCHILLER.]

2
5. The Plaintiff, ARRINGTON, is a qualified elector within US House District 1

in Florida, entitled to vote in the Democratic Primary election for US House

District 1 in Florida to be held on August 23, 2022. [See Exhibit “B”, voter

registration information of ARRINGTON]

6. The Defendant, JONES, is a candidate in the Democratic Party Primary for

US House District 1 in Florida. [See Exhibit “C”, qualifying papers of

JONES.]

7. The Defendant, BEASLEY, is the Supervisor of Elections for Walton County,

Florida and is sued in his official capacity as the officer charged with

conducting all elections within Walton County, Florida which portions are

contained within US House District 1 in Florida and is thus an

indispensable party to this action because of the relief requested.

8. The Defendant, STAFFORD, is the Supervisor of Elections for Escambia

County, Florida and is sued in his official capacity as the officer charged

with conducting all elections within Escambia County, Florida which

portions are contained within US House District 1 in Florida and is thus

an indispensable party to this action because of the relief requested.

9. The Defendant, LUX, is the Supervisor of Elections for Okaloosa, Florida and

is sued in his official capacity as the officer charged with conducting all

elections within Okaloosa County, Florida which portions are contained

within US House District 1 in Florida and is thus an indispensable party

to this action because of the relief requested.

3
10. The Defendant, VILLANE, is the Supervisor of Elections for Santa Rosa, Florida

and is sued in her official capacity as the officer charged with conducting

all elections within Santa Rosa County, Florida which portions are

contained within US House District 1 in Florida and is thus an

indispensable party to this action because of the relief requested.

11. The Defendant, BYRD, is the Florida Secretary of State and is sued in his

official capacity as the officer charged with qualifying all candidates for,

and conducting all congressional elections within the State of Florida

where US House District 1 in Florida is located and thus is an

indispensable party to this action because of the relief requested.

FACTS

12. On June 13, 2022, the Defendant, REBEKAH JONES presented paperwork to

the Division of Elections in Tallahassee, Florida in order to file and qualify

to run as a Democratic Party candidate for US House, District 1. [See

Exhibit “C”, paperwork submitted by JONES]

13. In order to qualify to run for Congress, JONES presented to the Division of

Elections, she submitted Division of Elections form DS-DE 300 A, the Federal

Candidate Party Loyalty Oath. [See Exhibit “C”]

14. On her DS-DE 300 A, JONES swore an oath that she had been a registered

member of the Democratic Party for 365 days prior to her qualifying for

office. [See Exhibit “C”]

15. JONES, in fact, had NOT been a member of the Democratic Party for 365

4
 days prior to qualifying to run for Congress, as she had registered to vote

without party affiliation between June 11, 2021, and August 11, 2021.

[See Composite Exhibit “D”, comprehensive voter registration information

of REBEKAH JONES]

DECLARATORY RELEIF

16. Plaintiff reaffirms and realleges paragraphs numbered 1 through 15 as set

forth above.

17. § 99.021(1)(b) of the Florida Statutes states, in relevant part as follows: “In

addition, any person seeking to qualify for nomination as a candidate of any

political party shall, at the time of subscribing to the oath or affirmation, state

in writing: . . . That the person has been a registered member of the political

party for which he or she is seeking nomination as a candidate for 365 days

before the beginning of qualifying preceding the general election for which

the person seeks to qualify…..”

18. JONES spent two months in the prescribed 365-day period, registered as an

unaffiliated voter and was thus NOT a registered member of the political party

for which she is seeking nomination for a period of 365 days before the

beginning of the qualifying process.

19. As JONES does not meet the requirements of 12. § 99.021of the Florida

Statutes, she cannot run for US House District 1 in Florida as a Democrat

and must be removed as a candidate in that election.

20. As a properly qualified candidate for office and as JONES’ opponent in the

5
 Democratic Primary for US House District 1 in Florida, SCHILLER has

standing and the duty to request this Court to declare the candidacy of the

Defendant JONES to be void as it is prohibited by § 99.021 of the Florida

Statutes.

21. As a registered member of the Democratic Party and a qualified elector in

US House District 1 in Florida, ARRINGTON has standing and the duty to

request this Court to declare the candidacy of the Defendant JONES to be

void as it is prohibited by § 99.021 of the Florida Statutes.

22. The Defendants BEASLEY, STAFFORD, LUX AND VILLANE and BYRD are

joined in this action as a necessary and indispensable parties for the

purposes of relief sought. In the absence of a judicial declaration and order

directing Defendants, BEASLEY, STAFFORD, LUX AND VILLANE AND

BYRD, to remove JONES from the list of qualified Candidates for US House

District 1 in Florida, the Plaintiffs and other electors of US House District

1 in Florida will be denied their right to a fair and uniform election and will

be irreparably injured as voters will be mistakenly voting for an individual

who has not been a member of the Democratic Party for 365 days prior to

qualifying for office and is thus not eligible or qualified to run for US House

District 1 in Florida as a member of the Democratic Party.

23. SCHILLER AND ARRINGTON are without an adequate remedy at law. The

Plaintiffs, in the absence of a declaration by this Court accompanied by

supplemental injunctive relief determining that the Defendant JONES is

prevented by Florida Statutes from running for US House District 1 in

6
 Florida and directing the Defendants BEASLEY, STAFFORD, LUX AND

VILLANE AND BYRD to remove JONES’ name from the list of qualified

Democratic candidates for US House District 1 in Florida and prevent her

from appearing on the ballot for the August 23, 2022 Democratic Primary

election, the Plaintiff and the Democratic electors of US House District 1 in

Florida will not only be deprived of the right to a legal, proper and effective

vote but will also be denied the effective enforcement of the law requiring

candidates for partisan office to be members of the party they are running in

for at least a year prior to qualifying for office and thereby will be

irreparably injured.

INJUNCTIVE RELEIF

24. Plaintiff reaffirms and realleges paragraphs numbered 1 through 15 as set

forth above.

25. SCHILLER AND ARRINGTON seek temporary and permanent injunctive

relief from this Court, enjoining JONES from running for US House District

1 in Florida as a member of the Democratic Party and ordering Defendants

BEASLEY, STAFFORD, LUX AND VILLANE and BYRD to remove JONES

from the list of qualified Democratic Candidates for US House District 1 in

Florida in the August 23, 2022 Democratic primary election.

26. SCHILLER AND ARRINGTON meet the standard to seek injunctive relief.

27. “The issuance of a preliminary injunction is an extraordinary remedy

which should be granted sparingly, which must be based upon a showing

of the following criteria: (1) The likelihood of irreparable harm; (2) the
7
 unavailability of an adequate remedy at law; (3) substantial likelihood of

success on the merits; and (4) considerations of the public interest.” City of

Jacksonville v. Naegele Outdoor Advertising Co., 634 So.2d 750 (Fla. 1st

DCA,1994).

28. Should JONES not be enjoined from running for US House District 1 in

Florida as a member of a political party of which she has not been a

member for the past 365 days, the Plaintiffs and the qualified Democratic

electors in US House District 1 in Florida will be damaged and irreparably

harmed by a candidacy of someone who has violated § 99.021 of the

Florida Statutes.

29. JONES has violated her party loyalty oath and is thus attempting to secure

votes from Democratic Party electors in US House District 1 in Florida when

she has not been a member of that party for 365 days prior to qualifying and

is thus materially misconstruing her party loyalty to unsuspecting voters.

30. Without an injunction removing JONES from the ballot, the Plaintiff and the

Democratic voters in US House District 1 in Florida have no other

adequate remedy at law and will suffer damages.

31. Plaintiffs, SCHILLER AND ARRINGTON have a substantial likelihood of

success on the merits as the information is clear that JONES has not been a

member of the Democratic Party for longer than 365 days prior to qualifying

to run for US House District 1 in Florida as a Democrat.

32. The issuance of an injunction will protect the public interest by ensuring that

only candidates that meet the requirement of § 99.021 of the Florida

8
 Statutes appear on the August 23, 2022 Democratic Primary ballot for US

House District 1 in Florida and thus Democratic electors are not deceived

into voting for an individual who was NOT a member of the Democratic Party

for 365 days before qualifying for office.

WHEREFORE, the Court is respectfully requested to assert and assume

jurisdiction and enter judgment declaring that JONES is prevented by § 99.021

of the Florida Statutes from seeking election to the US House for District 1 in

Florida as a member of the Democratic Party of which she HAS NOT been a

member of for the 365 days preceding her qualifying for office and ordering

Defendants BEASLEY, STAFFORD, LUX AND VILLANE AND BYRD remove the

name of the Defendant JONES from the list of qualified Democratic candidates for

US House District 1 in Florida and enjoining JONES from running as a Democratic

Candidate for US House District 1 in Florida in the August 23, 2022 Democratic

primary election as well as granting such other relief as would be just and

equitable.

Respectfully Submitted this 15th day of July 2022 by,

Law Firm of Juan-Carlos Planas, P.A.

2332 Galiano Street, 2nd Floor
Coral Gables, FL 33134
(850) 980-6542
Email: jcplanas@planaslawfirm.com
By: ___s./_J.C. Planas__________
Juan-Carlos Planas, Esq.
Fla. Bar No.: 156167

9
EXHIBIT “A”
7/15/22, 4:11 PM Candidate Tracking system - Florida Division of Elections - Department of State

Candidate Tracking System

       
2022 General Election

United States Representative

District  1

Peggy Schiller

Democrat
 

 
Address

174 Watercolor Way

Suite 103 Number 203

   
Santa Rosa Beach, FL 32459

Phone: (850)312-0707
  Status:Qualified  
  Date Filed:01/14/2022  
  Date Qualified:06/13/2022  
  Method:Petition method  
  Email:PeggyforthePanhandle.com  
 

Federal Campaign Reports

Campaign Documents

Petition Signatures

https://dos.elections.myflorida.com/candidates/CanDetail.asp?account=79920 1/1
EXHIBIT “B”
7/15/22, 4:08 PM Track My Ballot

An official government website Here's how you know 

DAVID H. STAFFORD
ESCAMBIA COUNTY  
SUPERVISOR OF ELECTIONS

TRACK MY BALLOT
You now have a choice when tracking the status of your vote-by-mail ballot:

1. You can sign up for automatic updates to your phone or email address by visiting BallotTrax
at https://escambiavotes.ballottrax.net/voter/

and/or

2. You may use the form below to:

Track the status of your vote-by-mail ballot
Update your registration information
Find sample ballots
If you are not registered to vote, you can find registration information here

WALTER R. Voter Registration

ARRINGTON Number: 128104421

Voter Information
+ Voter Status:
Eligible to vote in Escambia
County. Our office does not currently have an all
elections request on file for this voter. 
Date Registered:
April 11, 2020
Date of Birth:
May 14, 1985

Party Affiliation:
DEM
Precinct:
83
County: Escambia
https://escambiavotes.gov/track-my-ballot 1/4
7/15/22, 4:08 PM Track My Ballot
County:
Escambia

Request Registration Update

View Office Holders

View Precinct Statistics

Contact Information

Residence Address
:
1825 BAINBRIDGE AVE APT D

PENSACOLA, FL 32507

Mailing Address
:
1825 BAINBRIDGE AVE APT D

PENSACOLA, FL 32507

No Address Change information at this time

Current Elections

2022 Primary Election

Voter Status: Our office does not currently have a

NEXT ELECTION
23
AUG 2022
UPCOMING ELECTIONS


LAST ELECTION'S RESULTS

JOIN OUR MAILING LIST TODAY

https://escambiavotes.gov/track-my-ballot 2/4
7/15/22, 4:06 PM District Office Holders

Office Holders

Office Name
Office Holder
Status
Contact Information
District
Precinct

United States Senator - Marco Marco Rubio 284 Russell Senate Office Bldg.
Escambia County County Wide
Rubio (http://www.rubio.senate.gov/public/)
Washington, DC 20510

(REP) Phone: (202) 224-3041

Toll Free (866) 630-7106

FAX: (202) 228-5171

700 S Palafox Street Suite 125

Pensacola, FL 32502

Phone: (850) 433-2603

FAX: (850) 433-2554

Term Expires 01/2023

United States Senator - Rick Rick Scott 716 Hart Senate Office Bldg.
Escambia County County Wide
Scott (http://www.billnelson.senate.gov/)
Washington, D.C. 20510

(REP) Phone: (202) 224-5274

FAX: (202) 228-2183

U.S. Courthouse Annex

111 N. Adams St.

Tallahassee, FL 32301

(850) 942-8415

Term Expires 01/2025

Representative in Congress Matt Gaetz 507 Cannon House Office Bldg

CONGRESS Show
(http://gaetz.house.gov) Washington, D.C. 20515
DISTRICT
(REP) Phone: (202) 225-4136

FAX: (202) 225-3414

4300 Bayou Boulevard, Suite 13

Pensacola, FL 32503

Phone: (850) 479-1183

FAX: (850) 479-9394

Toll Free: (866) 367-1614

Term Expires 01/2021

https://www.voterfocus.com/OfficeHolders/WHOfficesResult.php?county=FL-ESC&Precinct= 83.0 1/9

EXHIBIT “C”
7/15/22, 4:11 PM Candidate Tracking system - Florida Division of Elections - Department of State

Candidate Tracking System

       
2022 General Election

United States Representative

District  1

Rebekah Jones

Democrat
 

 
Address

Post Office Box 1259

  Gulf Breeze, FL 32562  

Phone:  
  Status:Qualified  
  Date Filed:09/29/2021  
  Date Qualified:06/13/2022  
  Method:Petition method  
 

Federal Campaign Reports

Campaign Documents

Petition Signatures

https://dos.elections.myflorida.com/candidates/CanDetail.asp?account=79724 1/1
EXHIBIT “D”