Mark Glass, Commissioner December 18, 2023

Florida Department of Law Enforcement (FDLE)

P.O. Box 1489
Tallahassee, FL 32302-1489

RE: Gov. Ron Desantis’ failure to comply with Florida’s Public Records law

Commissioner Glass:

Please find attached/enclosed the AFFIDAVIT OF NEIL J. GILLESPIE,

Gov. Ron DeSantis’ failure to provide public records, executed August 18, 2023.

On information and belief, Florida Gov. Ron DeSantis failed to comply with Florida’s Public
Records law, Article I, Section 24 of the Florida Constitution, and various statutes, including
Sections 119.07(1) and 286.011, Florida Statutes.

My affidavit states, by paragraph:

BEFORE ME, this day personally appeared NEIL J. GILLESPIE, who upon oath deposes
upon personal knowledge and states:

1. I am over the age of eighteen and competent to testify as to the facts and matters set
forth below. I make this affidavit upon personal knowledge unless otherwise expressly
stated.

2. Ron DeSantis is the governor of Florida.

3. Agent Video Intelligence (Agent Vi)/Irisity AB provides an Artificial Intelligence (AI)

security system for the Marion County Jail located in Ocala, Florida.

4. On May 18, 2023, I made an online public records request to

Desantis.OpenGovernment:

Please provide records of Governor Ron DeSantis' recent trip to Israel, including
an itinerary, and any contacts with Agent Video Intelligence (Agent Vi), and
Irisity AB. Thank you.

5. On May 22, 2023, I got an email response from the Office of Open Government
stating:

Good morning,

The Governor’s Office of Open Government is in receipt of your request for

records as stated in your email below. If there is a fee associated with your
Mark Glass, Commissioner December 18, 2023
Florida Department of Law Enforcement (FDLE)

request, you will be provided with a fee estimate for your review. Thank you for
contacting the Executive Office of the Governor.

Sincerely,
Office of Open Government

6. No records were provided. On June 8, 2023 I emailed a second request for the records:

To: DeSantis Open Government

Second request. This is a Public Records Request, Sections 119.07(1) and

286.011, Florida Statutes, and Article I, Section 24 of the Florida Constitution.
All public records requests shall be acknowledged promptly and in good faith,
F.S. § 119.07(1)(c).

Please provide records of Governor Ron DeSantis' recent trip to Israel, including
an itinerary, and any contacts with Agent Video Intelligence (Agent Vi), and
Irisity AB.

Thank you.
Neil Joseph Gillespie

7. On June 9, 2023, I got an email response from the Office of Open Government stating:

Good morning,

The Governor’s Office of Open Government is in receipt of your request for

records as stated in your email below. If there is a fee associated with your
request, you will be provided with a fee estimate for your review. Thank you for
contacting the Executive Office of the Governor.

Sincerely,
Office of Open Government

8. As of today, Gov. Ron DeSantis’ Office of Open Government has not provided the
records I requested, nor provided any other response. My 3 page public record request
email chain with Gov. Ron DeSantis’ Office of Open Government is attached to this
affidavit.

NOTE: Irisity AB is headquartered in Israel, and owns Agent Video Intelligence (Agent Vi).

On December 13, 2023, Beth Reinhard of the Washington Post published a story “DeSantis
staffers blocked release of travel records, whistleblower says” at the link:
https://www.washingtonpost.com/politics/2023/12/13/desantis-travel-records-florida-officials-
clash-post-lawsuit/

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Mark Glass, Commissioner December 18, 2023
Florida Department of Law Enforcement (FDLE)

The Washington Post is suing to obtain the Florida governor’s records and arguing that a new
law limiting disclosure is unconstitutional.

My request concerns records for Agent Video Intelligence (Agent Vi)/Irisity AB provides an
Artificial Intelligence (AI) security system for the Marion County Jail located in Ocala, Florida.
Irisity AB is headquartered in Israel.

On November 6, 2023, Marion County Sheriff Billy Woods was sued in federal court for the
wrongful death of inmate Cory Merchant, see

Merchant v. Woods, et al, U.S. District Court, Middle District of Florida (Ocala), Case
No. 5:23-cv-00661-JSM-PRL

The lawsuit was filed on behalf of Krysti Merchant as Personal Representative for the estate of
Cory Merchant, against Defendant Billy Woods, Sheriff of Marion County, Florida, in his
official capacity, Defendant Justin Kosinski, Deputy, Defendant Joseph Miller, Deputy, and
Defendant Jerome Dukes, Sergeant.
The Plaintiff is represented by:

James Murray Slater, Slater Legal PLLC, Tallahassee, FL

Bhavani K. Raveendran, Romanucci & Blandin LLC, Chicago, IL
Sam Harton, Romanucci & Blandin, Chicago, IL 60654

On November 27, 2023, Marion County Sheriff Billy Woods was sued in federal court for the
wrongful death of inmate Scott L. Whitley, III, see,

Whitley v. Woods et al, U.S. District Court, Middle District of Florida (Ocala), Case No.
5:23-cv-00684-JSM-PRL

The lawsuit was filed on behalf of Pamela C. Whitley, as Personal Representative of the Estate
of Scott L. Whitley, III, on behalf of the Estate, and Scott L. Whitley, Jr. and Margaret M.
Whitley, survivors. against Defendant Billy Woods, in his official capacity as Sheriff of Marion
County, Florida, and the following Defendants:

Defendant: Robert Andrew Walters, Captain

Defendant: Ashleigh Snodgrass, Sargent
Defendant: Arnault Canelle, Corporal
Defendant: Jordon Ortega, Corporal
Defendant: Carl Holmer, Deputy
Defendant: Christopher Kristensen, Deputy
Defendant: Xavier McMiller, Deputy
Defendant: Demontra Smith, Deputy
Defendant: Sa'Quan Wyman, Deputy

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Mark Glass, Commissioner December 18, 2023
Florida Department of Law Enforcement (FDLE)

The Plaintiff is represented by:

Michael Evan Levine, Stewart, Tilghman, Fox & Bianchi, PA, Miami, FL
James Murray Slater, Slater Legal PLLC, Tallahassee, FL

In the matter of Oren Miller v. State of Florida, Case No. 5D23-0846, LT Case No. 2021-CF-
4602-A, this Court overturned a Jury conviction on November 9, 2023, with instructions that the
trial court enter a judgment of not guilty in favor of Miller.

Oren Miller was quoted in a news story February 5, 2023 by Ryan Grim of The Intercept about
his time in the Marion County Jail, see
https://theintercept.com/2023/02/05/ron-desantis-florida-villages-oren-miller/

The last 74 days had been an ordeal. There are about 1,800 people in the county’s lockup
facility; Miller was in a pod with 80, he said, but there were just 56 seats for meals. On
his first day, a jailmate offered to adopt him and get him a seat at meals in exchange for
some of his food, a bargain he eagerly accepted. On the second day, he said, he won
protection from a gang leader. “Oren Miller, you are protected in here because you’re a
senior citizen,” the man said, according to Miller. “‘But understand, don’t cross any
lines.’ … And so I minded my p’s and q’s.” Violence broke out regularly, Miller
recounted, and he watched two men beaten nearly to death. He moved to try to break up
the first fight, but two men held him back, explaining that if he got involved, he’d be
called later as a witness, and you don’t want to be a witness against somebody who
sleeps in the same open room as you. So he let them fight.

Miller went days without his heart or thyroid medication, and grew weak and dizzy.
Complaining of chest pain, he was eventually given an EKG, which the staff told him
showed no problems. “My EKG hasn’t been good in 15 years,” he said. “I will never
have a good EKG. I’ve got an irregular heartbeat all the time.” He said they gave him
medication despite claiming to detect no heart trouble — the same type of heart
medication he’d been prescribed but hadn’t been getting.

To hold someone in custody means removing their autonomy. The jailer has exclusive control
over the welfare of the person and is therefore exclusively responsible for the conditions in
which the inmate is held. As jailer, Sheriff Woods is responsible for each and every one of the
1,800 or so inmates in the jail.

As Florida Governor, Ron Desantis is responsible for each and every one of the 1,800 or so
inmates in the Marion County Jail.

A paper copy of this complaint will be mailed to you as Commissioner of the FDLE.

Additional court documents related to the Marion County Jail will be served to you as
Commissioner of the FDLE on the Florida Portal.

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Mark Glass, Commissioner December 18, 2023
Florida Department of Law Enforcement (FDLE)

Thank you.

Sincerely,

Neil J. Gillespie
Justice Network
2801 SW College Road, Suite 3
Ocala, Florida 34474
Tel: 352-239-9037 (cell)
Tel: 352-581-2600 (land line)
Email: celticein@yahoo.com
Email: Neil4Justice@yahoo.com

Attachments/enclosures

Mark Glass, Commissioner

Florida Department of Law Enforcement (FDLE)
http://www.fdle.state.fl.us/OGC/Public-Records.aspx
Email: info@fdle.state.fl.us

Mark Glass, Commissioner

Florida Department of Law Enforcement (FDLE)
http://www.fdle.state.fl.us/Contact-Us/More-Contacts
E-mail: agencyclerk@fdle.state.fl.us

Cc: Beth Reinhard, Political investigations

Washington Post, Washington, D.C.
beth.reinhard@washpost.com

Physical Location:
Florida Department of Law Enforcement
2331 Phillips Road
Tallahassee, FL 32308