IN THE CIRCUIT COURT OF THE TENTH JUDICIAL CIRCUIT

IN AND FOR HARDEE COUNTY, FLORIDA

FELONYDMSION FILED
STA'tt OF FLORIDA,
THIS INSTRUMENT MAR 0 2 2020
Plaintiff, IN COMPUTER't.~ HARDEE COUNTY
CLERK OF COURTS

v. Case No.:

Comes now "ving administrator and rebutts Plaintiff's

TRAVERSE declaring:

1. With the State of Florida's TRAVERSE, the State of Florida admits trespass upon

Defendant's rights and infringement upon Defendant's Trademark, Intellectual Property

and Trade Secrets which does threaten Defendant's lively-hood.

2. Florida Statute ("FS") § 455.201(1) does read in part "[i]t is the intent of the Legislature

that persons desiring to engage in any lawful profession regulated by the department shall

be entitled to do so as a matter of right if otherwise qualified."

3. FS § 474.201 does read in part "[i]t is the legislative intent that veterinarians who are not

normally competent or who otherwise present a danger to the public shall be disciplined

or prohibited from practicing in this state."

4. Therefore, FS § 474.201 determines "minimwn contacts" State of Florida must establish

to obtain personal jurisdiction. minimum contacts = by contract OR by act/action (ie: trespass)

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5. Nowhere in State of Florida's TRAVERSE, did State of Florida produce proof of claim,

nor even allege that Defendant is "not normally competent" nor that Defendant did

"otherwise present a danger to the public" at any time before initiation of any

proceedings.

6. No proof of claim means no right to compel performance.

7. No right to compel performance means it is wrong to compel performance.

8. Force and wrong are the greatest enemies of peace.

9. By failing to meet "minimum contacts" established by Florida Legislature, Defendant

accepts and agrees with all facts stipulated within its TRAVERSE wherein State of

Florida does admit and confess:

a Personal Jurisdiction over Defendant was never properly established.

b. Breach of the Peace.

c. Simulation of Legal Process.

d. Abuse of Process.

e. Instigation of litigation, FS § 877.01, also known as Barratry.

f. Conversion of Defendant's property for personal profit and gain.

g. Violation ofFS § 876.05, Oath of Office.

h. Unlawful search and seizlll'e in adversity with Florida Constitution Article I,

Section 12 and United States Constitution, Fourth Amendment.

1. Unlawful taking in adversity with United States Constitution, Fifth Amendment.

J. Receiving stolen and misappropriated trade secrets and intellectual property.

k. Dealing in Stolen Property. The definition of"Dealing in Stolen Property" is

contained in FS § 812.019.

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 1. Trademark Infringement.

m. Dilution of Trademark.

n. Use of mails and wires with intentto deprive Defendant's intangible right to

receive honest services in adversity with 18 U.S.C., §§ 1346, 1349; and FS §

817.034(1)(a) and (b).

o. Engaging in systematic, ongoing course of conduct with intent to defraud one or

more persons with intent to obtain property from one or more persons by false or

fraudulent pretenses, representations, and willful misrepresentations of a future

act in violation of FS § 817.034(3)(d).

p. Obtaining property in violation ofFS § 817.034(4)(a);

q. Trespass upon Defendant property and rights protected by the Laws and

Constitutions of the State of Florida and United States in adversity with 42

U.S.C., §§ 1983, 1985 and 18 U.S.C., § 242.

r. False claims and false statements before this Court in adversity with Florida Rules

of Judicial Procedure Rule 2.515(a) and Oath of Admissions to the Florida Bar;

18 U.S.C., §§ 287 and 1001; and FS §§ 837.02, and 837.06.

10. Therefore, Florida Department of Business and Professional Regulation and the Board of

Veterinary Medicine, et al. do operate without License, Insurance or Authority and all

acts and actions are ultra vires.

11. With prosecution of this action, State of Florida does cause significant harm and injury to

Defendant's Trademark, Intellectual Property and Trade Secrets which does endanger

and threaten Defendant's lively-hood and reputation.

12. Counsel for Plaintiff knows or reasonably should know that this case:

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a. is travesty ofjustice;

b. should not even be in comt, and;

c. does waste the Court's valuable resources and time.

Florida Jurat; Oath: I, William Houston Lovett, swear under penalties of perjury under
the laws of the United States of America that the ore oin facts are 'e and correct and am
willing to testify in Court.

STATE OF FLORIDA )
COUNTY OF HARDEE )

~nally appeared the

BEFORE ME an of:l\...cer authorized to administer oaths
undersigned livi!J.g adtninistrator who being by me first duly

2. I have read ~ tood the attached foregoing document filed herein, and each
fact a.Qeged therein is true and correct and I am willing to testify in a court of law.
Declared ~r penalties of perjury that the forgoing facts and information are true and
correct and subscribed his autograph by his own hand before me on this A_ day of March
2020.
v personally known. with valid identification.

Witness My Hand and Seal Below,

By:4~f. ~~fL
· Flo Notary ublic
Seal

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...

I, living administratm- do certify that service of the

foregoing was made on Assistant State Attorney John W. Kromholz, on this 2nd day of March
2020, by U.S. Mail to 124 S 9th Ave #100, Wauchula, FL 33873.

CC: Certified U.S.Mail:-----·

Service of Process Unit
Office of the General Counsel D.B.P.R.
2091