Professional Documents
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Gillespie V Google, Complaint For Replevin, 2024-CA-0209
Gillespie V Google, Complaint For Replevin, 2024-CA-0209
NEIL J. GILLESPIE,
Plaintiff,
2024-CA-0209
Case Number:__________________
vs. JURY TRIAL DEMANDED
Defendants.
______________________________________/
Plaintiff pro se Neil J. Gillespie, a nonlawyer, sues the Defendants, and alleges:
2. The description of the property is: The Plaintiff’s Google Account, neilgillespie@mfi.net,
and the Neil Gillespie YouTube channel: @neilgillespie4184 (Exhibits 5 and 6); telephone no.
352-615-3819; and Plaintiff’s current TracFone account for 352-850-5009. (Exhibits 7 and 8).
3. To the best of Plaintiff’s knowledge, information, and belief, the value of the property is
Gillespie Blogger profile with his blogs, and the Neil Gillespie YouTube channel:
neilgillespie@mfi.net, Neil Gillespie Blooger user profile, including the Neil 2020 blog, the
Justice Network blog, the Music and Video - 2020 Election blog, and the Neil Gillespie
YouTube channel, his intellectual property under the Google Terms of Service (“Google TOS”)
effective January 5, 2022, a copy of the Google TOS being attached at Appendix A, Exhibit A.1.
B. The Plaintiff is entitled to the possession the telephone number 352-615-3819 under a
Retail Installment Contract with Verizon Wireless Services LLC dated November 29, 2022, a
C. The Plaintiff is entitled to the possession of his current Tracfone account for 352-850-
5009 under a Tracfone 1 Year and 400 minutes phone card, a “365-DAY PLAN” activated
November 3, 2023, a copy of the phone card and purchase receipt appearing at Exhibits 7 and 8.
A. Defendant Google LLC came into possession of the property when the Plaintiff
opened his Google Account neilgillespie@mfi.net in 2011. To the Plaintiff’s best knowledge,
information, and belief, Defendant Google LLC detains the property because Google claims it
cannot be sure the Account neilgillespie@mfi.net belongs to the Plaintiff, Neil J. Gillespie.
Separately and in addition, the timing and circumstances of Defendant Google LLC’s wrongful
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detainer of the Plaintiff’s property shows a prior restraint on political speech, and election
interference, under the laws and constitution of Florida, and of the United States. (Appendix C).
Installment Contract with the Plaintiff November 29, 2022, to port his former pre-paid Tracfone
number 352-615-3819 to a new post-paid Moto G Pure Verizon wireless phone. (Appendix B).
The Plaintiff’s phone no. 352-615-3819 is his recovery phone for his Google Account
neilgillespie@mfi.net. TracFone Wireless, Inc. is owned by Verizon, and all Tracfone brands are
now a part of the Verizon family. To the Plaintiff’s best knowledge, information, and belief,
Defendant Verizon Wireless detained his phone number 352-615-3819, then failed to port the
number to a new wireless device for the Plaintiff, preventing him from getting a verification
code from Google sent to 352-615-3819, a verification code needed to access his Google
Account neilgillespie@mfi.net. Without the verification code, the Defendant Google LLC claims
it cannot be sure the Google Account neilgillespie@mfi.net belongs to the Plaintiff, Neil J.
Gillespie.
C. Defendant TracFone Wireless, Inc. has refused the Plaintiff possession of his current
Tracfone account for 352-850-5009 under a Tracfone pre-paid “365-DAY PLAN” activated on
November 3, 2023 (Exhibit 7) and valid to November 2, 2024. The Plaintiff’s Tracfone wireless
device, a Blu View 2 B131DL wireless telephone (Exhibit 8) functions to make and receive texts
and calls, but he cannot log into his account because Tracfone claims “We are unable to validate
the information you provided.” The Plaintiff obtained a Tracfone pre-paid 365-DAY PLAN for
the purpose of managing his online accounts, including Google LLC and its services Gmail,
Blooger and YouTube; and also X (formerly Twitter), Yahoo, Scribd, Facebook, and others.
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6. On August 20, 2023 the Plaintiff got an email from the Defendant Google LLC,
“Updating our Google Account inactivity policy”. (Exhibit 9). The essence of the policy, “This
change starts rolling out today and will apply to any Google Account that’s been inactive,
meaning it has not been signed into or used within a two-year period. An inactive account and
any content in it will be eligible for deletion from December 1, 2023.” The Plaintiff will forever
loose his intellectual property because he cannot sign into or use his Google, Blogger, or
YouTube accounts. The Defendant Google LLC is owned by the Defendant Alphabet, Inc.
7. On August 15, 2023 the Plaintiff got an email from the Defendant Google LLC
announcing Squarespace recently announced that it entered into an agreement to purchase all
domain name registrations and related customer accounts from Google Domains. (Exhibit 10).
The Google Official Site - Google Domains page announced “On September 7, 2023
Squarespace acquired all domain registrations and related customer accounts from Google
Domains”. (Exhibit 11). A Google Domains Help page announced “When you buy and register a
domain through Google Domains, you must be signed in to a Google Account that you’ll use to
manage your domain. (Exhibit 12). The Plaintiff is unable to login to Squarespace because he
cannot sign into his Google Account neilgillespie@mfi.net because Defendant Google LLC
claims it cannot be sure the account belongs to the Plaintiff, Neil J. Gillespie.
8. On January 20, 2024 the Plaintiff got an email from the Verizon Class Action Settlement
Administrator (Exhibit 13) informing him that a proposed settlement has been reached in a class
action lawsuit regarding his prior Verizon post-paid wireless account for 352-239-9037:
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The lawsuit claimed that Cellco Partnership d/b/a Verizon Wireless (“Verizon”) charged a
monthly Administrative Charge and/or Administrative and Telco Recovery Charge (collectively,
“Administrative Charge”) on Verizon post-paid individual consumer wireless accounts that was
unfair and not adequately disclosed. The Settlement Class, including the Plaintiff in this case,
Neil Gillespie, is represented by the law firm DeNittis, Osefchen, Prince, P.C., and the law firm
Hattis & Lukacs. Verizon is represented by the law firm Faegre Drinker Biddle & Reath, and the
law firm Quinn Emanuel Urquhart & Sullivan, LLP. On January 23, 2024, Settlement Class
member Neil Gillespie gave written notice to the Verizon Administrative Charge Settlement
Administrator to opt-out, to be excluded from the Settlement Class in the lawsuit. (Exhibit 14).
9. The property has not been taken for any tax, assessment, or fine pursuant to law.
10. The property has not been taken under an execution or attachment against the Plaintiff’s
property.
11. Therefore, the Plaintiff demands judgment for possession of his property.
THE PARTIES
12. The Plaintiff is Neil J. Gillespie (“Gillespie”), a nonlawyer age 67, individually, and
doing business as Justice Network, a fictitious name. Justice Network was registered with the
Florida Department of State on January 25, 2018 at 8092 SW 115th Loop, Ocala, Florida, 34481.
located at 2801 SW College Rd., STE 3, Ocala, FL 34474. In addition, Gillespie was in the past,
and currently is, a No Party Affiliation (NPA) candidate for U.S. president, see,
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13. Defendant Google LLC (“Google”) is a limited liability company organized and existing
under the laws of the State of Delaware, with its principal place of business in Mountain View,
California. Google is an online company providing internet-related products directly and through
subsidiaries and business units it owns and controls such as Gmail, Blogger and YouTube.
14. Defendant Alphabet Inc. (“Alphabet”) is a publicly traded company incorporated and
existing under the laws of the State of Delaware and headquartered in Mountain View,
California. Alphabet was created as a holding company for Google in late 2015, and Alphabet
controls Google’s day-to-day operations. Virtually all of Alphabet’s revenue comes from
Google. Since December 2019, Alphabet and Google have had the same Chief Executive
Officer, Sundar Pichai. As a result of Alphabet’s operational control, Google is Alphabet’s alter
telecommunications conglomerate incorporated and existing under the laws of the State of
Delaware and headquartered in New York City. (1095 Avenue of the Americas, NY, NY).
16. Defendant Verizon Wireless Services, LLC is an American wireless network operator
limited liability company organized and existing under the laws of the State of Delaware, and a
division of Verizon Communications, Inc., with its principal place of business in Basking Ridge,
New Jersey. This Complaint refers to Verizon Communications, Inc. and Verizon Wireless
mobile phone provider incorporated and existing under the laws of the State of Delaware and
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18. Replevin is governed by Chapter 78 of the Florida Statutes (Fla. Stat.) The Plaintiff has a
right to replevin under Fla. Stat. 78.01, to recover his personal and intellectual property wrongly
taken or detained by the Defendants, and any damages sustained by reason of the wrongful
taking or detention.
19. An action for replevin must be brought in a court of competent jurisdiction based on the
value of the property sought to be replevied. Fla. Stat. 78.03. The Marion County Circuit Court
20. An action for replevin may be brought in any county where the property sought to be
replevied is located, where the contract was signed, where the defendant resides, or where the
cause of action accrued. Fla. Stat. 78.032. The Plaintiff’s property sought to be replevied is
located on his computer located in Marion County, Florida, and is viewable online on the
Internet in Marion County, Florida. The Plaintiff’s contracts with the Defendants were executed
in Marion County, Florida. The cause of action accrued in Marion County, Florida.
21. The Google Terms of Service (“Google TOS”), effective January 5, 2022, appear in
22. The Google TOS define Google’s relationship with the Plaintiff, and how the Plaintiff
23. Under the Google TOS, Google is the Service Provider; Google services are provided by,
24. Under the Google TOS, the Plaintiff, age 67, meets the age requirements to own and
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25. The Google TOS establishes Definitions, including: (Appendix A, Exhibit A.1, page 14)
“consumer” means:
“An individual who uses Google services for personal, non-commercial purposes outside
of their trade, business, craft, or profession. (See business user)”.
“copyright” means:
“A legal right that allows the creator of an original work (such as a blog post, photo, or
video) to decide if and how that original work may be used by others, subject to certain
limitations and exceptions (such as “fair use” and “fair dealing”).
“liability” means:
“Losses from any type of legal claim, whether the claim is based on a contract, tort
(including negligence), or other reason, and whether or not those losses could have been
reasonably anticipated or foreseen.”
“organization” means:
“A legal entity (such as a corporation, non-profit, or school) and not an individual person.”
“services” mean:
“The Google services that are subject to these terms are the products and services listed
at https://policies.google.com/terms/service-specific, including:
• apps and sites (like Search and Maps)
• platforms (like Google Shopping)
• integrated services (likeMaps embedded in other companies’ apps or sites)
• devices and other goods (like Google Nest)
Many of these services also include content that you can stream or interact with.”
“trademark” means:
“Symbols, names, and images used in commerce that are capable of distinguishing the
goods or services of one individual or organization from those of another.”
“warranty” means:
“An assurance that a product or service will perform to a certain standard.”
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“Things that you create, upload, submit, store, send, receive, or share using our services,
such as:
• Docs, Sheets, and Slides you create
• blog posts you upload through Blogger
• reviews you submit through Maps
• videos you store in Drive
• emails you send and receive through Gmail
• pictures you share with friends through Photos
• travel itineraries that you share with Google”
26. Under the Google TOS, Google provides services to the Plaintiff, including a Google
Account, neilgillespie@mfi.net, a Blogger account, the Neil Gillespie Blooger user profile,
27. Under the Google TOS, the Plaintiff has Google’s permission to use Google’s services,
28. Blogger is an American online content management system founded in 1999 which
enables its users to write blogs with time-stamped entries. Pyra Labs developed it before being
acquired by Google in 2003. Google hosts the blogs, which can be accessed through a
29. The Blogger Content Policy appears in Appendix A, at Exhibit A.2, and states in part:
30. YouTube is an American online video sharing and social media platform owned by
Google, and governed by the Google TOS. YouTube is also governed by a separate YouTube
Terms of Service dated December 15, 2023, and appearing in Appendix A at Exhibit A.3.
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31. Under the Google TOS, and YouTube TOS, Google provides services to the Plaintiff,
including a Google Account, neilgillespie@mfi.net, and the Neil Gillespie YouTube account or
LICENSE
32. The Google TOS provides the Plaintiff a “License”, found on page 6 (Appendix A at
License
Your content remains yours, which means that you retain any intellectual property rights
that you have in your content. For example, you have intellectual property rights in the
creative content you make, such as reviews you write. Or you may have the right to share
someone else’s creative content if they’ve given you their permission.
We need your permission if your intellectual property rights restrict our use of your
content. You provide Google with that permission through this license.
What’s covered
This license covers your content if that content is protected by intellectual property
rights.
Scope
This license is:
• worldwide, which means it’s valid anywhere in the world
• non-exclusive, which means you can license your content to others
• royalty-free, which means there are nomonetary fees for this license
Rights
This license allows Google to:
• host, reproduce, distribute, communicate, and use your content — for example, to
save your content on our systems and make it accessible from anywhere you go
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• publish, publicly perform, or publicly display your content, if you’ve made it visible
to others
• modify and create derivative works based on your content, such as reformatting or
translating it
• sublicense these rights to:
• other users to allow the services to work as designed, such as enabling you to
share photos with people you choose
• our contractors who’ve signed agreements with us that are consistent with
these terms, only for the limited purposes described in the Purpose section
below
Purpose
This license is for the limited purpose of:
• operating and improving the services, which means allowing the services to work as
designed and creating new features and functionalities. This includes using automated
systems and algorithms to analyze your content:
• for spam, malware, and illegal content
• to recognize patterns in data, such as determining when to suggest a new
album in Google Photos to keep related photos together
• to customize our services for you, such as providing recommendations and
personalized search results, content, and ads (which you can change or turn
off in Ads Settings)
This analysis occurs as the content is sent, received, and when it is stored.
• using content you’ve shared publicly to promote the services. For example, to
promote a Google app, we might quote a review you wrote. Or to promote Google
Play, we might show a screenshot of the app you offer in the Play Store.
developing new technologies and services for Google consistent with these terms
Duration
This license lasts for as long as your content is protected by intellectual property rights.
If you remove from our services any content that’s covered by this license, then our
systems will stop making that content publicly available in a reasonable amount of time.
There are two exceptions:
• If you already shared your content with others before removing it. For example, if
you shared a photo with a friend who then made a copy of it, or shared it again, then
that photo may continue to appear in your friend’s Google Account even after you
remove it from your Google Account.
• If you make your content available through other companies’ services, it’s possible
that search engines, including Google Search, will continue to find and display your
content as part of their search results.
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33. The Plaintiff has property rights under his Google Account neilgillespie@mfi.net, the
and the Neil Gillespie YouTube account or channel, @neilgillespie4184 (Exhibits 5 and 6);
35. The Plaintiff’s Google Account neilgillespie@mfi.net was formed in February 2011. The
Plaintiff had three active Blogger blogs on January 20, 2021, the date of his last blog post.
The Plaintiff worked an average of 10 hours a week on his blog, amounting to 520 hours
hourly rate of $20 per hour; for a total of $104,000. Justice Network is engaged in
advocacy, education, news gathering & dissemination, and helping people fight injustice.
B. The Plaintiff’s Neil 2020 blog, since September 22, 2019, is valued at $13,800
calculated as follows: The Plaintiff worked approximately 10 hours a week on this blog
through January 20, 2021, amounting to 690 hours worked (10 x 69 weeks); at an hourly
rate of $20 per hour; for a total of $13,800. Neil 2020 is a blog of Neil J Gillespie, a
C. The Plaintiff’s Music and Video - Election 2020 blog, since April 19, 2019, is valued
this blog through January 20, 2021, amounting to 910 hours worked (10 x 91 weeks); at
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an hourly rate of $20 per hour; for a total of $18,200. This blog is a demonstration project
showing relatively inexpensive ways of reaching people and providing political and other
the inherent expectations of big donors. A List of most-viewed YouTube videos is found
on Wikipedia, https://en.wikipedia.org/wiki/List_of_most-viewed_YouTube_videos
No. 16, “Counting Stars” by OneRepublic, shows 3.95 billion views. “Counting Stars” is
D. The Plaintiff’s Neil Gillespie YouTube account or channel with the video, “13th
Circuit JNC Interviews, June 15, 2010, Tampa, FL” is valued at $500 for production cost.
36. Under the Google TOS, Google has provided the Plaintiff a License and warranty, and
given the Plaintiff permission to use Google’s services, for the Plaintiff’s creative content
uploaded and published on Blogger and YouTube, certain rights as a business user under his
37. Google is liable to the Plaintiff for any breach of its License and warranty to him.
38. Presently the Plaintiff cannot access or use his Google Account neilgillespie@mfi.net,
including his Blogger Account and YouTube Account, because Google claims it cannot be sure
39. On January 30, 2024 the Plaintiff attempted to login and access his Google Account
neilgillespie@mfi.net, at his Blogger profile, but Google denied him access, and sent the
Plaintiff a “Critical security alert” email to neilgillespie@mfi.net on January 30, 2024 at 11:00
PM. The “Critical security alert” email Google sent to neilgillespie@mfi.net see Exhibit 15.
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40. Below is the image from Google’s “Critical security alert” sent to neilgillespie@mfi.net.
The original Google image was provided in color; the image appearing below is shown in black
and white because the Florida E-Filing Portal apparently does not function with a color image.
41. The above security alert shows Google is wrongly blocking the Plaintiff’s sign-in.
42. Google is blocking the Plaintiff’s legitimate sign-in attempt to his Google Account
neilgillespie@mfi.net because the Plaintiff cannot get a verification code Google sent to the
Plaintiff’s wireless phone number 352-615-3819; the Defendant Verizon has wrongly detained
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43. The Plaintiff has access to his Google Account email address, neilgillespie@mfi.net, and
clearly used the correct password for his Google Account neilgillespie@mfi.net. In fact,
“Someone just used your password to try to sign in to your account. Google blocked
them, but you should check what happened.”
“Someone” is the Plaintiff. YES, the Plaintiff just used his password to try to sign in to his
account, but Google blocked him. The Plaintiff knows what happened: Google is wrongly
blocking the Plaintiff’s legitimate attempts to sign in to his own Google Account.
Google states “Verify it’s you” and “To help keep your account safe, Google wants to make sure
it’s really you trying to sign in” at neilgillespie@mfi.net and “Confirm you’re not a robot” via a
CAPTCHA. The Plaintiff correctly completed the CAPTCHA and confirmed he is not a robot.
45. Exhibit 17 is a PDF of a Google Blogger “Welcome” page for neilgillespie@mfi.net that
says “enter your password”. The Plaintiff entered his password where indicated on the page.
neilgillespie@mfi.net that says, “To help keep your account safe, Google wants to make sure it’s
really you trying to sign in” to the Plaintiff’s Google Account neilgillespie@mfi.net. Google
says “Get a verification code” and “To get a verification code, first confirm the phone number
you added to your account (•••) •••-••19. Standard rates apply.” The Plaintiff entered the phone
number 352-615-3819 as shown on Exhibit 18, and pushed the send button.
47. Exhibit 19 is a PDF of a Google Blogger Account recovery page that says, “To help keep
your account safe, Google wants to make sure it’s really you trying to sign in” to the Plaintiff’s
Google Account neilgillespie@mfi.net. The Google Blogger Account recovery page also says
“A text message with a 6-digit verification code was just sent to (352) 615-3819.” The page
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provides an input box to “Enter the code”. The page also has another option: “I don’t have my
phone”. The Plaintiff does not have his phone to receive a text at (352) 615-3819, because
Verizon has wrongly detained the phone number (352) 615-3819 that Verizon promised to
provide to the Plaintiff under a Retail Installment Contract with Verizon Wireless Services LLC
dated November 29, 2022, a copy of the Contract being attached. (Appendix B, Exhibit B.2)
48. Exhibit 20 is a PDF of a Google Blogger page “Couldn’t sign you in” to the Plaintiff’s
Google Account neilgillespie@mfi.net. Google says, “You didn’t provide enough info for
Google to be sure this account is really yours. Google asks for this info to keep your account
secure. To recover your account, try again and answer each question shown.” However, as
Exhibit 20 shows, Google has not provided any questions to answer. The only option Google
provides is a link, “More tips to recover your account”. In regard to the Plaintiff’s Google
49. Google does not provide telephone support to resolve issues with the Plaintiff’s Google
The Plaintiff’s letter to Google LLC appears in Appendix A at Exhibit A.4. A UPS Proof of
Delivery shows the letter was delivered to Google on May 12, 2023 at 9:52 AM, tracking
Number 1Z64589F0291957636. Google did not respond to the Plaintiff’s letter that began:
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Subsequently the Plaintiff regained access to his email neilgillespie@mfi.net, descried below.
51. On June 1, 2023, the Plaintiff sent a Notice of Litigation to Alphabet, Inc./Google LLC,
and to its Registered Agent, Corporation Service Company. No response was received.
Exhibit A.5. The Notice was provided by to Alphabet, Inc./Google LLC by U.S. Certified Mail,
Tracking No. 70192970000057339543. Return Receipt Tracking No. 9590 9402 7830 2234 4295
41, and the Return Card, show the Notice was delivered to Alphabet/Google on June 7, 2023.
The Notice to Corporation Service Company was provided by U.S. Certified Mail, Tracking No.
70192970000057339550. Return Receipt Tracking No. 9590 9402 7830 2234 4295 58, and the
Return Card, show the Notice was delivered to Mona Lisa Hart at Corporation Service
Company. The Plaintiff’s Notice of Litigation to Alphabet, Inc./Google LLC states in part:
Google as also failed to respond to my letter May 10, 2023 to Sundar Pichai, CEO,
Google LLC, delivered to him on May 12, 2023, see attached the proof of delivery for
UPS shipment tracking number lZ64589F0291957636.
Unfortunately Google has left me no option other than to litigate. My unanswered letter
to Sundar Pichai, CEO, Google LLC, and Jisha's emails to me, are evidence of Google's
violation of my civil rights. Please be advised that my political campaign is, inter alai, a
federally protected activity under 18 USC 245(b)(1)(a).
52. On October 20, 2023, the Plaintiff served Alphabet/Google on the Florida Portal:
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The above captioned pleading appears in Appendix A at Exhibit A.6. The Plaintiff is the founder
and owner of Justice Network. On Thursday, August 6, 2020, the Plaintiff profiled a story from
the American Civil Liberties Union (ACLU) on his Justice Network blog, entitled “Is a Florida
Chief Judge Taking Cues From a Prosecutor?” The story, by Jacqueline Azis, Staff Attorney,
ACLU of Florida & Somil Trivedi, Senior Staff Attorney, ACLU Criminal Law Reform Project,
is about Brad King, the elected state attorney of Marion County, Florida, and public corruption.
53. On February 4, 2021 the Plaintiff was arrested and ultimately extradited to Florida on a
Governor’s Warrant by Gov. Ron DeSantis, after Marion County Judge Gary Sanders denied
Gillespie’s motion under the Americans With Disabilities Act for a 60 day stay in a political
prosecution so he could get retina surgery, done at Wills Eye Hospital in Philadelphia. The
Plaintiff unsuccessfully challenged the extradition and was incarcerated on no bond for over a
year. During that time the Plaintiff lost his email neilgillespie@mfi.net and his wireless phone
number 352-615-3819. The only response the Plaintiff got from Alphabet/Google was a
Removal From The Service List notice that appears in Appendix A, at Exhibit A.7.
54. On January 13, 2021, the Plaintiff had filed in the USSC a MOTION FOR LEAVE TO
FILE, RULE 17, PROCEDURE IN AN ORIGINAL ACTION, and a Rule 23 Stay for the
Inauguration of Joe Biden and Kamala Harris, directed to Justice Thomas. The Plaintiff made a
post about his USSC filing on his Justice Network Google Blogger blog neilgillespie@mfi.net
on January 20, 2021 that appears in Appendix C at Exhibit C.1. The Plaintiff’s USSC filing
challenged a Federal Election Commission (FEC) letter to him as a candidate. In the U.S.
Supreme Court case Ex parte Garland, 71 U.S. 333 (1866), the USSC held counselors are
officers of the court, not officers of the United States, and that their removal was an exercise of
judicial power, not legislative power. The Plaintiff’s FEC complaint argued that under the
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separation of powers doctrine, Joe Biden and Kamala Harris are not eligible to serve in an
executive branch office such as president/VP because each of them are lawyers and part of the
judicial branch of government. A lawyer admitted to practice is an officer of the court, part of the
judiciary. A lawyer, officer of the court, in the executive branch would usurp the separation of
powers doctrine set forth in the U.S. Constitution, and is part of a seditious conspiracy by the
judicial branch that is a threat to our Republic. See Appendix C, Exhibit C.1 and Exhibit C.2.
55. The Plaintiff contends that his 2021 USSC filing, and the holding in Ex parte Garland, 71
U.S. 333 (1866), is relevant to a case currently before the U.S. Supreme Court:
Pursuant to USSC Rule 37, the Petitioner requested consent of the Parties in USSC 23-719 to file
an amicus curiae brief. The Petitioner’s amicus brief will bring to the attention of the Court
relevant matter that he believes has not already been brought to its attention by the Parties and
56. On December 27, 2023 the Petitioner emailed the Marion County Clerk about filing a
Complaint for Replevin to return his online intellectual property on Google, and on X (formerly
Twitter), and cited story on the American Bar Association (ABA) Journal says the DOJ is used a
writ of replevin against a former White House adviser to recover emails. The Plaintiff provided a
copy of the email to Kenneth H. Yi, Director, Alphabet, Inc./Google LLC, kyi@google.com.
Director Mr. Yi/Alphabet/Google did not respond. See the email in Appendix A, at Exhibit A.8.
57. On January 4, 2024 the Plaintiff regained temporary access to his email address used
with Google and others, neilgillespie@mfi.net. The Plaintiff was then able to recover his account
with X (formerly Twitter), @Justice_Network, appearing at Exhibit 21. The Plaintiff also got
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two spam quarantine reports for neilgillespie@mfi.net, showing the email is active, Exhibit 22
for a spam report January 23, 2023, and Exhibit 23 for a spam report January 25, 2024.
58. On January 17, 2024 the Plaintiff got email at neilgillespie@mfi.net from Lee Rawles of
USSC RULE 17 MOTION FOR LEAVE TO FILE AN ORIGINAL ACTION (Exhibit 24).
Your message
To: Lee Rawles
Subject: USSC RULE 17 MOTION FOR LEAVE TO FILE AN ORIGINAL ACTION.pdf
Sent: Wednesday, January 13, 2021 7:46:06 PM (UTC-06:00) Central Time (US &
Canada) was deleted without being read on Wednesday, January 17, 2024 10:40:05 AM
(UTC-06:00) Central Time (US & Canada).
Lee Rawles is an assistant managing editor for the ABA web, see
https://www.abajournal.com/authors/4765/
59. The foregoing proves the Plaintiff owns his Google Account neilgillespie@mfi.net.
60. Google has wrongly detained the Plaintiff’s Google Account neilgillespie@mfi.net.
61. Therefore the Plaintiff is entitled to recover his Google Account neilgillespie@mfi.net.
62. The Plaintiff is entitled to the possession the telephone number 352-615-3819 under a
Retail Installment Contract with Verizon Wireless Services LLC dated November 29, 2022, a
63. The Plaintiff requires his telephone number 352-615-3819 to get a verification code from
64. Verizon has refused to provide the Plaintiff his property, his telephone no. 352-615-3819.
because the Plaintiff cannot get a verification code Google sent to telephone no. 352-615-3819.
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66. Verizon is cooperating with Google to detain the Plaintiff’s Google Account
neilgillespie@mfi.net
67. Separately, the Verizon Class Action Settlement Administrator (Exhibit 13) notified the
Plaintiff he is owed a settlement in Esposito et al. v. Cellco Partnership d/b/a Verizon Wireless.
68. The Plaintiff gave written notice to the Verizon Administrative Charge Settlement
Administrator to opt-out, to be excluded from the Settlement Class in the lawsuit. (Exhibit 14).
69. The Plaintiff includes his claims in Esposito et al. v. Cellco Partnership d/b/a Verizon
70. Therefore the Plaintiff is entitled to recover his telephone no. 352-615-3819.
DEFENDANT TRACFONE
71. The Plaintiff is entitled to the possession of his current Tracfone account for 352-850-
5009 under a Tracfone 1 Year and 400 minutes phone card, a “365-DAY PLAN” activated
November 3, 2023, a copy of the phone card and purchase receipt appearing at Exhibits 7 and 8.
72. The Plaintiff obtained a Tracfone pre-paid 365-DAY PLAN for the purpose of managing
verification codes for his online accounts, including Google LLC and its services Gmail, Blooger
and YouTube; and also X (formerly Twitter), Yahoo, Scribd, Facebook, and others.
73. Defendant TracFone Wireless, Inc. has refused the Plaintiff possession of his current
Tracfone account for 352-850-5009 under a Tracfone pre-paid “365-DAY PLAN” activated on
November 3, 2023 (Exhibit 7) and valid to November 2, 2024. The Plaintiff’s Tracfone wireless
device, a Blu View 2 B131DL wireless telephone (Exhibit 8) functions to make and receive texts
and calls, but he cannot log into his account because Tracfone claims “We are unable to validate
21
COMLAINT FOR REPLEVIN
74. Without access to his Tracfone account for 352-850-5009 under a Tracfone pre-paid
“365-DAY PLAN” the Plaintiff cannot make updates to his account to assure its proper function
and purpose in managing verification codes for his online accounts, including Google LLC and
its services Gmail, Blooger and YouTube; and also X (formerly Twitter), Yahoo, Scribd,
75. Tracfone is wrongly detaining the Plaintiff’s Tracfone account for 352-850-5009.
76. The Plaintiff is entitled to access his Tracfone account for 352-850-5009 under a “365-
DAY PLAN” activated on November 3, 2023 (Exhibit 7) and valid to November 2, 2024.
77. Therefore the Plaintiff is entitled to recover his Tracfone account for 352-850-5009.
79. Google has contracts with the government of the United States and accepts federal money
under those contracts, and therefore must comply with government free speech requirements and
22
COMLAINT FOR REPLEVIN
deprivation of any rights, privileges, or immunities secured by the Constitution and laws,
shall be liable to the party injured in an action at law, suit in equity, or other proper
proceeding for redress, except that in any action brought against a judicial officer for an
act or omission taken in such officer’s judicial capacity, injunctive relief shall not be
granted unless a declaratory decree was violated or declaratory relief was unavailable.
For the purposes of this section, any Act of Congress applicable exclusively to the
District of Columbia shall be considered to be a statute of the District of Columbia.
80. October 20, 2023 the Plaintiff proffered in his Notice of Conflict With the State
Attorney’s Office (Appendix A, Exhibit A.6, page 5) that his “Blogger/Google account linked to
his MFI.com email address is constitutionally protected speech under the First Amendment of
the U.S. Constitution, and a federally protected activity under 18 U.S.C. 245(b)(1)(a).” and,
18. In addition, because the Defendant cannot access his Blogger, YouTube and Google
accounts associated with his email neilgillespie@mfi.net, he cannot serve his clients.
19. On such client is Ronny Scott Cooper, Inmate ID #0005200, Marion County Jail,
Med B, held without bond since May 1, 2019, case no. 2019-CF-1050, for violation of
section 812.133.2A, Florida Statutes, Carjacking While Armed. Circuit Judge Peter M.
Brigham presiding. The docket shows Mr. Cooper is represented by John Wayne
Witherspoon, Bar ID #1008179, Crim. Conflict & Civ. Reg. Counsel, 5th Circuit.
20. Mr. Cooper filed a pro se motion to dismiss counsel dated October 3, 2023 (DOC
569). Judge Brigham entered a Transport Order on October 3, 2023 (DOC 657) to
transport Mr. Cooper to the Marion County Courthouse for the “purpose of appearing for
a psychological evaluation to be performed by Dr. Tonia Werner at 1:00 pm, October
25,2023, the defendant will be placed in holding cell between courtroom 3A and 3B
courtroom.”.
21. The Defendant has found a private attorney willing to represent Mr. Cooper for
$10,000, but is unable to commence fundraising because the Defendant cannot access his
Blogger, YouTube and Google accounts associated with his email neilgillespie@mfi.net.
80. On June 28, 2022 Google introduced “Google Public Sector” see,
https://cloud.google.com/blog/topics/public-sector/announcing-google-public-sector
Google Cloud has a long history of supporting and working with the governments in
many different parts of the world, including the United States, Europe, Asia Pacific, Latin
America, and Japan. We’ve helped government agencies modernize their core technology
systems; transformed the way in which they deliver services via digital platforms to
citizens; delivered security solutions to help agencies protect themselves from cyber
attacks; provided communication, collaboration, and productivity tools to educational
and healthcare systems; and enabled them to use data to improve financial systems and
23
COMLAINT FOR REPLEVIN
other critical infrastructure. We’ve offered products that address the unique needs of the
public sector; built a dedicated sales force, partner ecosystem, and services organization;
and worked with partners to bring joint solutions to government and educational
institutions.
Today, we’re expanding this commitment in the United States with the creation of
Google Public Sector, a new Google division that will focus on helping U.S. public
sector institutions—including federal, state, and local governments, and educational
institutions—accelerate their digital transformations.
However Google’s announcement of “Google Public Sector” on the Google Cloud blog is not
printable like posts on the Plaintiff’s blog, and is evidence that Google’s intent is contrary First
Amendment speech rights, by creating information that it alone controls and cannot be preserved
81. Verizon has contracts with the government of the United States and accepts federal
money under those contracts, and therefore must comply with government free speech
requirements and federal laws such as 18 U.S.C. 245(b)(1)(A) and 42 U.S.C. § 1983.
Verizon participates in the Affordable Connectivity Program, a $14.2 billion FCC benefit
program that supports eligible low- income households struggling to afford monthly
internet service. This critical program ensures that households have the connections they
need for work, school, healthcare, and more
Unlike Google, the FCC allows the public to print and download information. (Exhibit 25)
83. The Plaintiff makes a claim under Fla. Stat. sec. 768.72(1) for punitive damages against
Defendant Google because there is a reasonable showing by evidence in the record and proffered
by the Plaintiff which would provide a reasonable basis for recovery of such damages.
24
COMLAINT FOR REPLEVIN
(2) A defendant may be held liable for punitive damages only if the trier of fact, based on
clear and convincing evidence, finds that the defendant was personally guilty of
intentional misconduct or gross negligence. As used in this section, the term:
(a) “Intentional misconduct” means that the defendant had actual knowledge of the
wrongfulness of the conduct and the high probability that injury or damage to the
claimant would result and, despite that knowledge, intentionally pursued that course of
conduct, resulting in injury or damage.
(b) “Gross negligence” means that the defendant’s conduct was so reckless or wanting in
care that it constituted a conscious disregard or indifference to the life, safety, or rights of
persons exposed to such conduct.
84. The Plaintiff has shown in this Complaint by evidence in the record and proffered here,
that Sundar Pichai (CEO) Google LLC, and Kenneth H. Yi, Director, Alphabet, Inc./Google
LLC, Legal - Securities, Corporate Governance & Finance, engaged in “Intentional misconduct”
1. Google breached a duty of care to the Plaintiff under the Constitution and laws of
Florida, and of the United States, including the First Amendment;
2. Google breached the Google Terms of Service and License with the Plaintiff;
3. Google is the cause of the breach of care and duty to the Plaintiff;
4. The Plaintiff sustained damages as the result of Google’s intentional misconduct and
gross negligence.
and Google engaged in intentional misconduct and gross negligence with malice aforethought.
85. Pursuant to Rule 1.430(b), of the Florida Rules of Civil Procedure, Demand For Jury
Trial, and Article I, Section 22, of the Florida Constitution, Trial by Jury, the Plaintiff demands a
WHEREFORE, the Plaintiff respectfully requests the Court to enter judgment in its favor
25
COMLAINT FOR REPLEVIN
a. A writ of replevin against Google to recover the Plaintiff’s property being wrongly
detained: The Plaintiff’s Google Account, neilgillespie@mfi.net, the Neil Gillespie Blooger user
and the Neil Gillespie YouTube channel: @neilgillespie4184 (Exhibits 5 and 6);
d. Judgment against Google for the Plaintiff’s costs of suit, including reasonable
e. Judgment against Google for any and all such other relief as the Court may deem
proper.
f. A writ of replevin against Verizon to recover the Plaintiff’s property being wrongly
i. Judgment against Verizon for the Plaintiff’s costs of suit, including reasonable
j. Judgment against Verizon for any and all such other relief as the Court may deem
proper;
26
COMLAINT FOR REPLEVIN
k. A writ of replevin against TracFone to recover the Plaintiff’s property being wrongly
detained: The Plaintiff’s current Tracfone account for 352-850-5009 under a Tracfone 1 Year
and 400 minutes phone card, a “365-DAY PLAN” activated November 3, 2023 and valid to
November 2, 2024;
n. Judgment against TracFone for the Plaintiff’s costs of suit, including reasonable
o. Judgment against TracFone for any and all such other relief as the Court may deem
proper.
CERTIFICATE OF SERVICE
I hereby certify the Complaint for Replevin was served February 1, 2024 on the Florida
27
COMLAINT FOR REPLEVIN
Jeffrey S Jacobson
jeffrey.jacobson@faegredrinker.com
FAEGRE DRINKER BIDDLE & REATH LLP
https://www.faegredrinker.com/en/
Neil J. Gillespie
28
EXHIBIT LIST - COMPLAINT FOR REPLEVIN
Neil J. Gillespie v. Google, et al
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1/29/24, 2:17 PM Email addresses associated with your domain - Google Domains Help
As part of the registration process, you provide a registrant name and email address to list in WHOIS,
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VIA USPS FIRST CLASS PREPAID STAMPED MAIL
I, Neil J. Gillespie, wish to be excluded from the Settlement Class in the lawsuit
Esposito et al. v. Cellco Partnership d/b/a Verizon Wireless
Thank you.
Sincerely,
Neil J. Gillespie
2801 SW College Rd, STE 3
Ocala, FL 34474
Email: CELTICEIN@YAHOO.COM
Telephone: 352-239-9037
14
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~ Affordable Connectivity Program
Helping Households Connect
The Affordable Connectivity Program is a $14.2 billion program that supports eligible low- income households
struggling to afford monthly internet service. This critical program ensures that households have the connections
they need for work, school, healthcare, and more.
Eligible households can also receive a one-time discount of up to $100 to purchase a laptop, desktop computer, or
tablet from participating providers i f they contribute more than $10 and less than $50 toward the purchase price.
The Affordable Connectivity Program is l imited to one monthly service discount and one device discount per
household.
~ˇ
Find more information about the Affordable Connectivity Program at fcc.gov/ACP
Affordable Connectivity ...rogram
Helping Households Connect
•ı Empoweringconsumerst o choose t he service plan t hat best meets t hei r needs (includinga plan they may
already be on);
•ı Ensuringconsumershave access t o supportedbroadbandservices regardlesso f their c redi t status;
•ı Prohibitingprovidersf r o m excludingconsumersw i t h past due balances o r pr i or debt f r o m enrollingin the
program;
•ı Preventingconsumersf r o m being forced i n t o more expensiveo r l o wer quality plans in o r der t o receive the
ACP;
•ı Reducing t he p o ten t ial f o r bill shock o r o t her financial harms;
•ı AllowingACP recipientst o switch providersor broadbandservice offerings;and
•ı Providinga dedicated FCC process f o r ACP complaints.
The agency will c o n t i n uew o r k i n gw i t h federal partners t hat supportedt he EBB, such as the Department o f
Education,HHS, HU D and others. Their d i rec t relationshipsw i t h eligible householdscreate unique opportunitiesf o r
collaborativeoutreach and p r o m o t i o no f t he ACP. Specifically,the FCC has issued a Further Notice o f Proposed
Rulemakingin which i t seeks c o m men t on a p i l o t program t o ensure t hat householdst hat rely on Federal Public
HousingAssistancereceive d i rec t outreach t o encourage t hem t o enroll in the ACP.
The Further Notice also seeks c o m men t on establishinga new grant program f o r ACP outreach partners.The
agency understandst hat local, trusted c o m m u n i t yvoices are often the best positionedto encourageen r o l l men tin
g o ver n men tbenef i t programs, like the ACP. We are currentlyseeking c o m men t on the structureand objectivesf o r
this grant program and on grant-makingbest practicest hat will help t o ensure the program is a success.
NEIL J. GILLESPIE,
Plaintiff,
2024-CA-0209
Case Number:__________________
vs. JURY TRIAL DEMANDED
Exhibit A.1 Google Terms of Service (TOS), effective February 5, 2022 (PDF download)
Exhibit A.2 Blogger Content Policy (1 of 20) saved as a PDF from the link January 30, 2024.
https://www.blogger.com/content-policy?hl=en_US
Note: Google does not make its Blogger Content Policy available in PDF as it
does the Google TOS. Instead, what looks online as a continuous document at the
link appears to be 20 separate topics under the heading “Blogger Content Policy”.
Only the first topic is saved in PDF as Exhibit A.2 (the most relevant topic)
Exhibit A.3 YouTube Terms of Service (TOS) dated December 15, 2023, saved as a PDF
from the link January 29, 2024. https://www.youtube.com/static?template=terms
Note: Google does not make its YouTube TOS available in PDF as it does the
Google TOS. Instead, what looks online as a continuous document at the link was
saved as a 16 page PDF at Exhibit A.3
Exhibit A.4 Gillespie letter May 10, 2023 to Sundar Pichai (CEO), Google LLC
Exhibit A.5 Gillespie letter June 1, 2023 to Kenneth Yi, Director, Alphabet, Inc./Google LLC
Exhibit A.6 Gillespie Notice of Conflict with/SAO Filing # 184402021 E-Filed Oct-20-2023
Exhibit A.7 Kenneth Yi/Alphabet/Google composite exhibit of Removal From Service List
Exhibit A.8 Gillespie email Dec-27-2023 to the Clerk and Kenneth Yi/Alphabet/Google
GOOGL E TERM S OF SERVICE
Archived versions
These Te
T rms of Service reect the way Google’s business works, the laws that apply to our company,
y and
certain things we’ve always believed to be true. As a result, these Te
T rms of Service help dene Google’
es
relationship with you as you interact with our services. For example, these terms include the following topic
headings:
What you can expect from us, which describes how we provide and develop our services
What we expect from you, which establishes certain rules for using our services
Content in Google services, which describes the intellectual property rights to the content you nd in our
services — whether that content belongs to you, Google, or others
In case of problems or disagreements, which describes other legal rights you have, and what to expect
in case someone violates these terms
Understanding these terms is important because, by using our services, you’re agreeing to these terms.
Besides these terms, we also publish a Privacy Policy. We encourage you to read it to better understand how
you can update, manage, export, and delete your information.
Terms
Google LLC
organized under the laws of the State of Delaware, USA, and operating under the laws of the USA
Age requirements
If you’re under the age required to manage your own Google Account, you must have your parent or legal
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and policies.
These terms help dene the relationship between you and Google. Broadly speaking, we give you permission
to use our services if you agree to follow these terms, which reect how Google’s business works and how we
earn money. When we speak of “Google,” “we,” “us,” and “our,r” we mean Google LLC and its aliates.
We provide a broad range of services that are subject to these terms, including:
apps and sites (like Search and Maps)
Many of these services also include content that you can stream or interact with.
Our services are designed to work together,r making it easier for you to move from one activity to the next. For
example, if your Calendar event includes an address, you can click on that address and Maps can show you
how to get there.
We’
e re constantly developing new technologies and features to improve our services. For example, we use
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and block spam and malware. As part of this continual improvement, we sometimes add or remove features
and functionalities, increase or decrease limits to our services, and start offering new services or stop
offering old ones. When a service requires or includes downloadable software, that software sometimes
updates automatically on your device once a new version or feature is available. Some services let you adjust
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If we make material changes that negatively impact your use of our services or if we stop offering a service,
we’
e ll provide you with reasonable advance notice, except in urgent situations such as preventing abuse,
responding to legal requirements, or addressing security and operability issues. We’
e ll also provide you with an
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The permission we give you to use our services continues as long as you comply with:
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requirements
You also agree that our Privacy Policy applies to your use of our services. Additionally,
y we provide resources
like the Copyright Help Center, Safety Center, and descriptions of our technologies from our policies site to
answer common questions and to set expectations about using our services.
Although we give you permission to use our services, we retain any intellectual property rights we have in the
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Respect others
We want to maintain a respectful environment for everyone, which means you must follow these basic rules
of conduct:
comply with applicable laws, including export control, sanctions, and human tracking laws
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fraudulent or deceptive ways, introducing malware, or spamming, hacking, or bypassing our systems or
protective measures. When we index the web to bring you search results, we respect standard usage
restrictions that website owners specify in their websites’ code, so we require the same when others use
our services
Our service-specic additional terms and policies provide additional details about appropriate conduct that
everyone using those services must follow. If you nd that others aren’t following these rules, many of our
services allow you to report abuse. If we act on a report of abuse, we also provide the process described in
the Taking action in case of problems section.
Some of our services are designed to let you upload, submit, store, send, receive, or share your content. You
have no obligation to provide any content to our services and you’re free to choose the content that you want
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License
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make, such as reviews you write. Or you may have the right to share someone else’
e s creative content
if they’ve given you their permission.
We need your permission if your intellectual property rights restrict our use of your content. You
provide Google with that permission through this license.
What’s covered
This license covers your content if that content is protected by intellectual property rights.
This license doesn’t affect your privacy rights — it’s only about your intellectual property rights
feedback that you offer,r such as suggestions to improve our services. Feedback is
covered in the Service-related communications section below.
Scope
Rights
host, reproduce, distribute, communicate, and use your content — for example, to save your
content on our systems and make it accessible from anywhere you go
publish, publicly perform, or publicly display your content, if you’ve made it visible to others
modify and create derivative works based on your content, such as reformatting or translating
it
other users to allow the services to work as designed, such as enabling you to share
photos with people you choose
Purpose
operating and improving the services, which means allowing the services to work as designed
and creating new features and functionalities. This includes using automated systems and
algorithms to analyze your content:
developing new technologies and services for Google consistent with these terms
Duration
This license lasts for as long as your content is protected by intellectual property rights.
If you remove from our services any content that’s covered by this license, then our systems will stop
making that content publicly available in a reasonable amount of time. There are two exceptions:
If you already shared your content with others before removing it. For example, if you shared a
photo with a friend who then made a copy of it, or shared it again, then that photo may
continue to appear in your friend’s Google Account even after you remove it from your Google
Account.
If you make your content available through other companies’ services, it’s possible that search
engines, including Google Search, will continue to nd and display your content as part of their
search results.
You’re responsible for what you do with your Google Account, including taking reasonable steps to keep your
Google Account secure, and we encourage you to regularly use the Security Checkup
Using Google services on behalf of an organization or business
Many organizations, such as businesses, non-prots, and schools, take advantage of our services. To
T use
our services on behalf of an organization:
your organization’s administrator may assign a Google Account to you. That administrator might
require you to follow additional rules and may be able to access or disable your Google Account.
Service-related communications
T provide you with our services, we sometimes send you service announcements and other information. To
To T
learn more about how we communicate with you, see Google’
e s Privacy Policy.
If you choose to give us feedback, such as suggestions to improve our services, we may act on your feedback
without obligation to you.
Your content
Some of our services give you the opportunity to make your content publicly available — for example, you
might post a product or restaurant review that you wrote, or you might upload a blog post that you created.
See the Permission to use your content section for more about your rights in your content, and how
your content is used in our services
See the Removing your content section to learn why and how we might remove user-generated content
from our services
If you think someone is infringing your intellectual property rights, you can send us notice of the infringement
and we’
e ll take appropriate action. For example, we suspend or close the Google Accounts of repeat copyright
infringers as described in our Copyright Help Center.
Google content
Some of our services include content that belongs to Google — for example, many of the visual illustrations
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e s content as allowed by these terms and any service-specic
additional terms, but we retain any intellectual property rights that we have in our content. Don’t remove,
obscure, or alter any of our branding, logos, or legal notices. If you want to use our branding or logos, please
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Other content
Finally,
y some of our services give you access to content that belongs to other people or organizations — for
example, a store owner’s description of their own business, or a newspaper article displayed in Google News.
You may not use this content without that person or organization’s permission, or as otherwise allowed by
law. The views expressed in other people or organizations’ content are theirs, and don’t necessarily reect
Google’
e s views.
Some of our services include downloadable software. We give you permission to use that software as part of
the services.
royalty-free, which means there are no monetary fees for this license
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Some of our services include software that’s offered under open source license terms that we make available
to you. Sometimes there are provisions in the open source license that explicitly override parts of these terms,
so please be sure to read those licenses.
Warranty disclaimer
We built our reputation on providing useful, reliable services like Google Search and Maps, and we’
e re
continuously improving our services to meet your needs. However,r for legal purposes, we offer our services
without warranties unless explicitly stated in our service-specic additional terms. The law requires that we
explain this using specic legal language and that we use capital letters to help make sure you see it, as
follows:
Liabilities
Both the law and these terms try to strike a balance as to what you or Google can claim from the other in
case of problems. That’s why the law allows us to limit certain liabilities — but not others — under these
terms.
These terms only limit our responsibilities as allowed by applicable law. These terms don’t limit liability for
gross negligence or willful misconduct.
T the extent allowed by applicable law:
To
Google is liable only for its breaches of these terms or applicable service-specic additional terms
punitive damages
Google’
e s total liability arising out of or relating to these terms is limited to the greater of (1) $200 or (2)
the fees paid to use the relevant services in the 12 months before the dispute
T the extent allowed by applicable law, you’ll indemnify Google and its directors, ocers, employees,
To
and contractors for any third-party legal proceedings (including actions by government authorities)
arising out of or relating to your unlawful use of the services or violation of these terms or service-
specic additional terms. This indemnity covers any liability or expense arising from claims, losses,
damages, judgments, nes, litigation costs, and legal fees.
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1/29/24, 3:33 AM Terms of Service
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Sundar Pichai (CEO) May 10,2023
Google LLC
1600 Amphitheatre Parkway
Mountain View, California 94043
A.4
Sundar Pichai (CEO) May 10,2023
Google LLC
Justice Network
https:llnosueorg.blogspot.com/
https://www.facebook.com/Justice-Network-150432974991704/
Google's online account recovery services have not worked for me.
Thank you.
Sincerely,
Neil J. Gillespie
d/b/a! Justice Network
2801 SW College Road, Suite 3
Ocala, Florida 34474
Tel: 352-239-9037
Email: celticein@yahoo.com
Email: neil.gillespie.wh8 8@wharton.upenn.edu
Enclosures
2
AFFIDAVIr OF NEIL J. GILLESPIE
Email and cell phone accounts discontinued (corrected)
STATE OF FLORIDA )
) SS.:
COUNTY OF MARION )
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.
3. The notice is attached, and begins, "We are sorry to announce that beginning July 1st,
2021, MF1.net will cease operations and support ofMFl.net email addresses will end."
4. I was held injail from February 4,2021 through April 7,2022, then released ROR.
5. Attached is a Notice olEmail Delivery Failure on Service o/Court Document dated May
10, 2022, for a bounce back on April 22, 2022, for E-Service Delivery Failed for
neilgillespie@mfi.net in my home foreclosure, Marion County Case No. 2013-CA-OI15.
6. While I was held in jail, my prepaid 3G network cell phone service was discontinued by
my service provider Tracfone. This was my phone to receive a text for a verification code.
7. While I was held injail, I could not update my discontinued email address or cell phone
number linked to my Google account, or other online accounts, and I lost access to certain
accounts. I am working to recover my lost accounts, and I did recover my Facebook account.
The foregoing instrument was acknowledged before me, this I d- day ofMay, 2022,
by Neil J. Gillespie, who is personally known to me, or who has produced FL,f)L, 6,Q.l/- (,30 - fC btfl- d
as identification and states that he is the person who made this affidavit and that its contents are
truthful to the best O.fhiSknowl~.IOIEPH /I ~
Neary PublIc tA!e;.,A
SEAL
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My Commission Expires: 1111'1 h-o:;J-5 PrinfName of Notary PUtili-c- -
From: System Administrator
Sent: Thursday, April 8, 202111:44 AM
To: MFI.net Users
Subject: Discontinuation of MFl.net email and end user support
We are sorry to announce that beginning July 1st, 2021, MFl.net wi l l cease operations and support of MFl.net email
addresses will end. At this time we will also discontinue the sale, service, and support of PC's and software to individual
retail customers from DataOne Networks, DataOne will continue to of fer full sales, support, and managed network
services to our business networking clients.
We have enjoyed the privilege of serving you for 26 years, but due to changes in the marketplace, we have decided to
focus our efforts on our web site development, digital marketing, and hosting company, NetSource Technologies. For
those of you looking for a new email provider, we believe that for most users, Google's gmail service is a very good
solution.
If you or your company is looking for a full service Digital Marketing agency to help stand out online, we encourage you
to check out NetSource Technologies. Since 1995, they have received over 70 design awards working with a national
client base. I f you need a business website or help with any of your digital marketing needs, our award-winning team
would love to help you!
•ı Please click here for more information about this announcement. including resources to helD you transition to a
new email provider.
1
5/10/2022 SERVICE OF COURT DOCUMENT - CASE NUMBER 422013CA000115CAAXXX Email Deli\eryFailure - Yahoo Mail
SERVICE OF COURT DOCUMENT - CASE NUMBER 422013CA000115CAAXXX Email Deli Yahoo Mail/O 0 PORTAL 13CA...
very Failure
This is an automatic email message generated by the Florida Courts E-Filing Portal. This email address does not receive email.ı
Thank you,ı
The Florida Courts E-Filing Portalı
https:llmail.yahoo.comlb/folders/140/rnessages/ANTF}Btip91-YmLBVAJ06PzOIZY?src=ym&folderT~USER&offset=O&unblockNo\,l\J=false&action=printMessa... 1/1
5/10/23, 11: 16 AM Blogger: User Profile: Neil Gillespie
E:il illesr)!e
My blogs
Neil 2020
About me
Through myoid website I met folks from around the country. Some
of their stories are profiled there. Many believe that America's
Introduction
justice system is broken.
Reform American courts or avoid them. Your life, health and wealth
is at risk. But don't just take my word, read what the experts say in
stories posted here.
https://W'/INJ.blogger.com/profile/12580744990628852454 1/1
5/10/23,11:17 AM Neil 2020ı
https:/IneiI2020.blogspot.com 1/19
5/10/23, 11:16AM COMMITTEE DETAILS FOR CANDIDATE 10 P60022993
https:lldocquery.fec.gov/cgi-bin/fecimg/?P60022993 1/2
5/10/23,11:16A M COMMITTEE DETAILS FOR CANDIDATE 10 P60022993
Federal Election Commission, 1050 1st Street, NE, Washington, DC 20463 (800) 424-9530 In Washington (202) 694-1000ı
For the hearing impaired, TTY (202) 219-3336 Send comments and suggestions about this site to: webmanager@fecDgov.ı
https:/Idocquery.fec.gov/cgi-bin/fecimg/?P60022993 2/2
5/10/23, 11 :14 AM COMMITTEE DETAILS FOR COMMITTEE 10 C00627810
CANDIDATE:ı
GILLE S PIE, NEIL ID: P 6 0 0 2 2 9 9 3ı
. •• _~.~r~~~ ••
https:/Idocquery.fec.gov/cgi-bin/fecimg/?C00627810 1/2
5/10/23, 11:14AM COMMITTEE DETAILS FOR COMMITTEE 10 C00627810
MISCELLANEOUS
REPORT FROM 04/26/2018 2 201804260300007331 PDF
FEC
-til
• I I
Federal Election Commission, 1050 1st Street, NE, Washington, DC 20463 (800) 424-9530 In Washington (202) 694-1000
For the hearing impaired, TTY (202) 219-3336 Send comments and suggestions about this site to: webmanager@fec.gov.
https:lldocquery.fec.gov/cgi-bin/fecimg/?C0062781 0 2/2
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print dialogue box th at a pp e ars.Note: If your brows erdoe s not s upportthis function, s ele ctPrint from th e File m e nu
to print the label.
2. Fold th e print e d la b el a t th e s olid lin e below. Pla c eth e la b el in a UP S Shipping Pouch.If yo u do not have a
pouch, affix the folded la b el u sing cle ar pla stic shipping ta p e ov e r th e entire label.
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aboutblank 1/1
5/12/23, 3:53 PM Tracking I UPS - United States
Proof of Deliveryı
Dear Customer,ı
This notice serves as proof of delivery for the shipment listed below.ı
Tracking Numberı
1Z64589F0291957636ı
Weightı
1.00 LBS
Service
Shipped / Billed On
05/10/2023
Delivered On
Delivered To
GOGGLE
2690 CASEY AVE
MOUNTAIN VIEW, CA, 94043, US
Received By
DOM
Left At
Dock
Please print for your records as photo and details are only available for a l imited time.
Sincerely,
UPS
Google has also been unable to assist me with my Blogger User Profile for Neil
Gillespie https:llwww.blogger.com/profile/12580744990628852454
and associated Google political campaign account found at
http://neiI2020.blogspot. coml
Google as also failed to respond to my letter May 10, 2023 to Sundar Pichai, CEO,
Google LLC, delivered to him on May 12, 2023, see attached the proof of delivery
for UPS shipment tracking number lZ64589F0291957636.
A.5
Kenneth H. Yi, Director June 1,2023
Alphabet, Inc./Google LLC
Legal - Securities, Corporate Governance & Finance
"Global leaders should be working to reduce "the risk of extinction" from artificial
intelligence technology, a group of industry chiefs and experts warned on Tuesday.
A one-line statement signed by dozens of specialists, including Sam Altman whose
firm OpenAI created the ChatGPT bot, said tackling the risks from AI should be "a
global priority alongside other societal-scale risks such as pandemics and nuclear
war". ChatGPT burst into the spotlight late last year, demonstrating an ability to
generate essays, poems and conversations from the briefest of prompts -- and
sparking billions of dollars of investment into the field. But critics and insiders
have raised the alarm over everything from biased algorithms to the possibility of
massive job losses as AI-powered automation seeps into daily life."
2ı
Kenneth H. Vi, Director June 1,2023
Alphabet, Inc./Google LLC
Legal - Securities, Corporate Governance & Finance
Here in the city of Ocala, Marion County, Florida, AI is behind the failure to
adequately protect inmates in the Marion County Jail through use of innoVi
Genetec Integration, Agent Vi, Comprehensive AI-Powered Video Analytics,
version 30-Nov-2021, which has resulted in at least one inmate death, and a
number of inmate injuries. As currently used, AI my be considered a crime against
humanity. Thank you.
Sincerely,
1#
Neil J. Gillespie
d/b/a! Justice Network
2801 SW College Road, Suite 3
Ocala, Florida 34474
Tel: 352-239-9037
Email: celticein@yahoo.com
Email: neil.gillespie.wh8 8@wharton.upenn.edu
Enclosures
3ı
6/1/23.2:50 PM Yahoo Mail - Re: Google Workspace Support 45187880: Notice of Litigation
D e a rMr. Vi,
aboutblank 1/5
6/1/23, 2:50 PM Yahoo Mail - Re: Google Workspace Support 45187880: Notice of Litigation
nuclear war". ChatGPT burst into the spotlight late last year,
demonstrating an ability to generate essays, poems and conversations
from the briefest of prompts -- and sparking billions of dollars of
investment into the field. But critics and insiders have raised the alarm
over everything from biased algorithms to the possibility of massive job
losses as AI-powered automation seeps into daily life."
Sincerely,
lsi
Neil J. Gillespie
d/blal Justice Network
2801 SW College Road, Suite 3
Ocala, Florida 34474
Tel: 352-239-9037
Email: celticein@yahoo.com
Email: neil.gillespie.wh88@wharton.upenn.edu
On Thursday, June 1, 2023 at 01: 10:57 AM EDT, Google Workspace Support <workspacesupport@google.com>
wrote:
Hello Neill
I sincerely apologize for the inconvenience. As I mentioned earlier if your domain has a google
workspace account only we can assist further! the specialist team has confirmed that your
domain(mfLnet) does not have a google workspace account. If you have a workspace account
for mfi"net please open a new ticket from that domain.
Before cancelling the google workspace subscription plan for any domain, please take a backup
for the drive files.
I will go ahead and close this case for now. However, you do have 30 days to reopen it by simply
replying to this email. I assure you that I will take ownership of your ticket and wm solve the issue
as soon as possible. Also, take into account that my business hours are Monday to Friday from
04.30AM to 12.30AM 1ST.
Sincerely~
Jisha
Google Workspace Support
Foflow @AskWorksQace for regular helpful tips & product updates
aboutblank 4/5
6/1/23, 2:50 PM Yahoo Mail - Re: Google Workspace Support 45187880: Notice of Litigation
GOOGLE LLC.pdfı
4,1kBı
The above named entity submits this statement for the purpose of changing its registered office or registered agent, or both, in the State of Florida.
SIGNATURE:
Electronic Signature of Registered Agent Date
Title S Title AS
Name WALKER, KENT Name YI, KENNETH H
Address 1600 AMPHITHEATRE PKWY Address 1600 AMPHITHEATRE PKWY
I hereby certify that the information indicated on this report or supplemental report is true and accurate and that my electronic signature shall have the same legal effect as if made under
oath; that I am a managing member or manager of the limited liability company or the receiver or trustee empowered to execute this report as required by Chapter 605, Florida Statutes; and
that my name appears above, or on an attachment with all other like empowered.
Remove X
Tracking Number:
70192970000057339543
Copy Add to Informed Delivery (https://informeddelivery.usps.coml)
Latest Update
Your item was delivered to the front desk, reception area, or mail room at 9:31 am on June 7,2023 in
MOUNTAIN VIEW, CA 94043.
Delivered
Delivered, Front Desk/Reception/Mail Room
"
ro
ro
MOUNTAIN VIEW, CA 94043 0
June 7, 2023, 9:31 am cr
OJ
n
7\
See All Tracking History
Product Information v
See Less A
STATE OF FLORIDA,
Plaintiff, CASE NO. 2019-CF-4193
vs. CASE NO. 2020-CF-2417
CASE NO. 2021-CF-0286
NEIL JOSEPH GILLESPIE, CASE NO. 2022-CF-1143
Defendant.
__________________________________/
Defendant NEIL JOSEPH GILLESPIE, a nonlawyer reluctantly appearing pro se, gives
1. The Defendant is the founder and owner of Justice Network, registered with the
Department of State on January 25, 2018. The Registration Number of this Fictitious Name is
dissemination, and helping people fight injustice. A Department of State certification for Justice
2. On Thursday, August 6, 2020, the Defendant profiled a story from the American Civil
Liberties Union (ACLU) on his Justice Network blog, entitled “Is a Florida Chief Judge Taking
Cues From a Prosecutor?” The story, by Jacqueline Azis, Staff Attorney, ACLU of Florida
& Somil Trivedi, Senior Staff Attorney, ACLU Criminal Law Reform Project, is about Brad
King, the elected state attorney of Marion County, Florida, and was published by the ACLU on
September 10, 2018. State Attorney Brad King retired on December 31, 2020.
3. A copy of the Justice Network blog post profiling the ACLU story is attached and states:
Prosecutors are some of the most powerful elected officials in our country. They decide
what charges to file or dismiss, how severe the charges will be, whether to seek cash bail,
and what plea offers are made. Through their lobbying associations, they also shape
criminal statutes to their benefit, often blocking reforms that the community supports.
A.6
DEFENDANT’S NOTICE OF CONFLICT WITH THE STATE ATTORNEY’S OFFICE
But while prosecutors wield immense control over the direction of our criminal justice
system, they certainly can’t handpick the judges who hear their criminal cases.
Or can they?
In Marion County, Florida, Brad King — the elected state attorney and the county’s top
prosecutor — believed he was losing too often in the criminal cases his office was
prosecuting. Instead of upping his game, he managed to shift it in his favor, with the help
of a judge whose job it is to guard the integrity of the judicial process.
On July 12, King sent a scathing letter to the administrative judge of Marion County,
Judge James McCune, complaining about two of McCune’s colleagues, before whom
King and his staff regularly appeared: Judge Robert Landt and Judge Thomas Thompson
III. That letter was obtained by the ACLU of Florida through a public records request,
and is being publicly released in full here for the first time.
King’s complaints were brazenly self-serving. Of Judge Landt, King asserted that his
"rulings on such things as motions to dismiss, motions to suppress evidence, and motions
to set bond, and his sentencings, are consistently more favorable to the defense than other
judges." King threatened to assign fewer prosecutors to Landt’s docket, because "we
expect little in the way of punishment for those defendants." As for Judge Thompson,
King complained that he "grants continuance after continuance to defendants," in
reference to a tool commonly used by judges to postpone proceedings and requested by
both sides to allow proper preparation for trial. In his letter, King also formally demanded
that the number of judges in the Marion County Criminal Court be reduced.
After sending his letter, King claimed that his issues with Landt relate to allegations of
harassment of King’s female attorneys. However, these allegations were investigated and
closed years ago. Moreover, King’s letter makes clear that adverse rulings, not those
claims, are the reason King sought Landt’s removal.
Within days of receiving the letter, Chief Judge Sue Robbins, who oversees Judge
McCune, gave King exactly what he wanted. Without consulting defense attorneys,
whose clients’ cases are directly impacted by these changes, Robbins reduced the
numbers of judges in the Marion County Criminal Court from four to two. Specifically,
she removed Landt and Thompson — the judges King had criticized in his letter.
The two remaining county judges on the criminal docket both used to work as
prosecutors for King. The judges who were removed — Landt and Thompson — were
both up for re-election, with primaries on August 28. Landt ran against a current assistant
state attorney working under King. That candidate proudly posted Landt’s reassignment
letter on his campaign website, boasting that his competitor has been removed from the
criminal bench.
It remains a mystery why a chief judge, who is charged with neutral oversight of a
judicial district the size of Connecticut, took such an action after receiving King’s letter.
2
DEFENDANT’S NOTICE OF CONFLICT WITH THE STATE ATTORNEY’S OFFICE
Ruling for the defense, or not doling out sufficient "punishment," is not legitimate
grounds for removal. This would be true even if the judges were consistently getting it
wrong on the facts or the law — but they weren’t. Florida’s appellate courts regularly
affirmed these judges over King’s objections.
Going forward, how can people who appear in Marion County Criminal Court feel they
are getting a fair hearing or trial — knowing their judges have effectively been selected
by the prosecution, or that they might fear removal if they rule on behalf of the defense?
What State Attorney Brad King did — seeking to influence who is on the criminal bench
by sending a scornful demand letter to judges — is highly irregular, to say the least. On
Robbins’ part, accepting the unreasonable demands of a state attorney is even more
inappropriate. Her decision, shortly following King’s request, gives the appearance, at
the very least, that she is easily pressured and, at worst, that she is biased toward the
prosecution over the accused.
A prosecutor’s grievance should never become policy. Prosecutors aren’t kings and they
don’t get to issue decrees. They — and the judges who oversee their cases — are public
servants, accountable to us all.
4. Brad King’s July 12, 2018 letter to Administrative Judge James McCune is attached.
5. On April 26, 2020, the Villages-News published a story, “Retiring state attorney will be
remembered for cases not pursued in The Villages.” that states in part:
Longtime State Attorney Brad King has announced his retirement and he will likely be
remembered in The Villages for the ones who got away.
King, a former Marion County sheriff’s deputy who was first elected in 1988 to serve as
chief prosecutor for Sumter, Lake, Marion, Hernando and Citrus counties, made the
announcement on Friday. He has indicated he will leave office by Dec. 31. King said he
wanted to spend more time with family.
The Republican had pre-filed to run for another term, but then he had a change of heart.
King quietly greased the path for his successor, his office’s executive director William
McDonald Gladson, to take over the reins. Gladson was the only candidate to qualify for
state attorney for the Fifth Judicial Circuit by Friday’s deadline. That means Gladson will
automatically be elected and will take office in January.
In The Villages, King will be remembered for two prominent cases he chose not to
vigorously pursue:
• Last year, a man who left a woman to die in The Villages after she fell in 2017 from his
golf cart at Brownwood, walked out of a courtroom virtually unpunished thanks to a
3
DEFENDANT’S NOTICE OF CONFLICT WITH THE STATE ATTORNEY’S OFFICE
decision by King’s office. Timothy Jacob Foxworth on May 20 pleaded no contest to two
misdemeanor charges in connection with the July 16, 2017 incident which claimed the
life of 51-year-old Shelly Osterhout. The sentence enraged her family, including her
father, who wrote a letter a letter to the court in which he decried the prosecutor’s
office’s fear of the Foxworth family’s “deep pockets.”
• In 2018, Villagers were stunned when King’s office announced two suspects would not
be prosecuted in the 2016 beating death of 26-year-old Austin Stevens at Spanish Springs
Town Square. A document from the prosecutor’s office indicated that it has been
determined that Stevens was the “initial aggressor” on the night of June 5, 2016. The
original police report said teens who had been in a minivan that had passed by Stevens’
workplace had been taunting the McCall’s Tavern employees. Stevens went to the corner
at TooJay’s to confront the teens. The original report said one of them ran up behind
Stevens and punched Stevens on the side of his head, causing Stevens to fall to the
ground and strike the back of his head on the concrete. While on the ground and
unresponsive, another teen kicked Stevens in the face, the original report said. Stevens
was airlifted to Ocala Regional Medical Center, where he died of injuries suffered during
the beating.
6. The Villages-News story appears online and includes 38 reader comments, mostly
negative for King: https://www.villages-news.com/2020/04/26/retiring-state-attorney-will-be-
remembered-for-cases-not-pursued-in-the-villages/
10. Case No. 2020-CF-2417 was nolle prosequi on April 28, 2022 because the alleged
11. The Defendant was held in jail on no bond from February 4, 2021 through April 7, 2022.
12. During his incarceration, the Defendant’s email address for his Justice Network blog,
NetSource Technologies, Inc./TSC Industries, Inc. 3700 South Pine Ave., Ocala, FL 34471.
4
DEFENDANT’S NOTICE OF CONFLICT WITH THE STATE ATTORNEY’S OFFICE
13. The Defendant’s Justice Network blog is a product of Blogger; owned and hosted by
Google LLC, a subsidiary of Alphabet, Inc. Because Greg Petry canceled the Defendant’s email
14. The Defendant’s YouTube channel is hosted by Google LLC, a subsidiary of Alphabet,
Inc. Because Greg Petry canceled the Defendant’s email address, he cannot access his YouTube
15. During his incarceration, the Defendant’s cell phone ended and the number was lost, so
16. Greg Petry has not responded to the Defendant’s certified mail of August 10, 2023 about
this issue. Google LLC, a subsidiary of Alphabet, Inc., has not responded to the Defendant’s
17. The Defendant believes his Blogger/Google account linked to his MFI.com email
address, is constitutionally protected speech under the First Amendment of the U.S. Constitution,
18. In addition, because the Defendant cannot access his Blogger, YouTube and Google
accounts associated with his email neilgillespie@mfi.net, he cannot serve his clients.
19. On such client is Ronny Scott Cooper, Inmate ID #0005200, Marion County Jail, Med B,
held without bond since May 1, 2019, case no. 2019-CF-1050, for violation of section
812.133.2A, Florida Statutes, Carjacking While Armed. Circuit Judge Peter M. Brigham
presiding. The docket shows Mr. Cooper is represented by John Wayne Witherspoon, Bar ID
20. Mr. Cooper filed a pro se motion to dismiss counsel dated October 3, 2023 (DOC 569).
Judge Brigham entered a Transport Order on October 3, 2023 (DOC 657) to transport Mr.
5
DEFENDANT’S NOTICE OF CONFLICT WITH THE STATE ATTORNEY’S OFFICE
Cooper to the Marion County Courthouse for the “purpose of appearing for a psychological
evaluation to be performed by Dr. Tonia Werner at 1:00 pm, October 25,2023, the defendant will
21. The Defendant has found a private attorney willing to represent Mr. Cooper for $10,000,
but is unable to commence fundraising because the Defendant cannot access his Blogger,
22. Mr. Cooper stated in a jail Emessage to the Defendant on October 19, 2023 that he was
previously examined by Dr. Harry Krop, Ph.D., Clinical Psychologist. Mr. Cooper waived
confidentiality for the Defendant to disclose their Emessages. Mr. Cooper wrote in part:
dr. krop said in 2-video's that he recomends time served and a duel diognosis program
that was years ago he said back then that i had done enough time on this case and nobody
was touched or harmed in any way,the victim got her vehicle back ,nothing was wrong
with it..ive told the attorney jeffery deen to look at both video's and do a deposition on
dr.krop he hasn't done nothing.. dr.krops assistant called my mom years ago after an
evauation with her and told my mom i was coming home,and the case would be
dissmissed or time served, it's on a evaluation video to.... ronny cooper.. thank you..
23. Jeffrey D. Deen is the Regional Counsel, Office of Criminal Conflict and Civil Regional
24. The Florida Bar News reported on September 14, 2023: “Gov. Ron DeSantis September
12 appointed Brad King of Ocala to serve as judge on the Fifth Judicial Circuit Court.”
https://www.floridabar.org/the-florida-bar-news/governor-appoints-brad-king-to-the-bench/
6
DEFENDANT’S NOTICE OF CONFLICT WITH THE STATE ATTORNEY’S OFFICE
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on October 20, 2023 the foregoing Notice was served on the
Florida Portal to:
and to the names on the Florida Portal Notice of Service of Court Documents.
7
State ofFlorida
Department ofState
~z5JY I
Secretllry ofState
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BRAD KING, STATE ATTORNEY
Fifth Judicial Circuit of Florida
Serving Marion, Lake, Citrus, Sumter, Hernando Counties
To: Judge James R. McCune, Administrative County Court Judge of Marion County
and County Court Judges
From: Brad King, State Attorney
As I recently explained to you, the number of cases on the county court dockets of Marion
County have dropped in recent years, while caseloads in other counties have not. For example, each of
you have averaged about 4000 criminal cases per year, while the sole county judge in Sumter County
has about 6000. This has resulted in an imbalance in the workloads of my staff. Because the legislature
provides me only a limited number of positions, I am forced to reassign attorney positions among the 26
courtrooms I must staff in order to better balance the workload on my attorneys.
Based on the caseload data, I am reducing the number of attorneys assigned to the Marion
County Court from 10 to 6. In order to facilitate this, I requested that you reduce the number of dockets
from 4 to 3, like the county court judges have done in Lake County. I was joined in this request by the
Public Defender, who like me, must provide services with a limited number of staff. For reasons about
which I can only speculate, you have refused this request. Keep in mind that in addition to the regular
dockets, we also support eight different county court diversion programs aimed at keeping first
offenders, and sometimes second and third ones, out of the formal court system.
I intend to make this reduction in two steps. First, I will reduce the attorneys assigned to each
Marion County Court docket from two to one and a half. Because I will have two attorneys who must
divide their time between two dockets, I must reduce their caseloads even further. I am implementing
several steps to reduce the caseload on each docket. As the caseloads drop on each docket, I am going
to take the second step to further equalize the workload on my staff, and make better use of the
resources I commit to each docket, by assigning only one attorney to each of two dockets.
I had my staff review each of the Marion County Court dockets to determine if an unequal
assignment of staff would be appropriate due to prosecution results obtained, because of the rulings of
each judge. I have determined that there are two dockets where the results of prosecutions produce
substantially less benefit for the citizens of Marion County. Accordingly, I will further reduce the staff
allocated to those dockets.
I found a different problem on Judge Tommy Thompson’s docket, but with a similar result.
Judge Thompson started with the smallest docket; it was, in fact, zero. Unfortunately, it is now the
largest docket because he grants continuance after continuance to defendants. This results in not just a
delay in justice for the victims in those cases, but in little activity on his docket other than just having an
attorney present while continuances are granted. Accordingly, I will consider further reducing the cases
assigned to his docket, so that I may further reduce the staff assigned to his courtroom and to try to
achieve a more timely resolution for those cases that remain on his docket.
I realize that further reducing the caseload on two dockets, but not on the others, may result in
some disparate treatment of defendants based upon docket assignment. Such disparate treatment
already exists among the dockets due to the proclivities of the two judges set forth above.
After making the final reduction in staff to Judge Landt’s and Judge Thompson’s dockets, I will
evaluate each of the two other dockets to determine if one and a half attorney positions are adequate,
or if I should return the two-attorney arrangement to Judge Ritterhoff-Williams’ and Judge McCune’s
dockets.
I have already begun reassignment of attorneys on each docket. If, in the future, you should be
willing to reconsider redistributing the caseloads, I will be more than happy to revisit this arrangement.
County Court Supervisor Becky Fletcher and Marion County Division Supervisor Toby Hunt will be
responsible for docket assignments as we work through this process.
1/30/24, 4:19 AM Yahoo Mail - Removal from Service List – Case Number 422019CF004193CFAXXX
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1/30/24, 4:38 AM Yahoo Mail - REPLEVIN ACTION AGAINST GOOGLE/ALPHABET
Gregory C. Harrell
Marion County Clerk of Court and Comptroller
gharrell@marioncountyclerk.org
Gentlemen:
to recover my email
address, neilgillespie@mfi.net, that I owned for over 10 years. Without
it I cannot access my online intellectual property on Google, etc. This is
also a prior restraint on speech, and election interference under the laws
and constitution of Florida, and of the United States.
about:blank
A.8 1/3
1/30/24, 4:38 AM Yahoo Mail - REPLEVIN ACTION AGAINST GOOGLE/ALPHABET
Google LLC, et al, accept federal money and must comply with
government free speech requirements and other laws as to
discrimination, etc.
A story on the ABA Journal says the DOJ is used a writ of replevin
against a former White House adviser to recover emails.
https://www.abajournal.com/web/article/what-is-a-writ-of-replevin-its-
being-used-by-the-doj-against-former-white-house-adviser
Please advise if you would like me to efile on the portal. Thank you.
Sincerely,
/s/
Neil J. Gillespie
2801 SW College Rd., STE 3
Ocala, FL 34474
Tel: 352-239-9037 (cell)
Tel. 352-581-2600 (office)
NeilGillespie2024@yahoo.com
Neil4Justice@yahoo.com
celticein@yahoo.com
about:blank 2/3
1/30/24, 4:38 AM Yahoo Mail - REPLEVIN ACTION AGAINST GOOGLE/ALPHABET
about:blank 3/3
Filing # 191081810 E-Filed 02/01/2024 05:34:29 PM
NEIL J. GILLESPIE,
Plaintiff,
2024-CA-0209
Case Number:__________________
vs. JURY TRIAL DEMANDED
Defendants.
______________________________________/
APPENDIX B - VERIZON
Verizon Communications, Inc.
Verizon Wireless Services, LLC
COMPLAINT FOR REPLEVIN
Exhibit B.1 Verizon Receipt of Transaction to port telephone number 352-615-3819 to the
Plaintiff with “Add a Line” to a “Motorola moto g pure 32 GB in DEEP
INDIGO” Agreement number 1593846358, paid $10.50, Order No: 6021092
11/01/2022 @ 01:27 UTC
Exhibit B.2 Retail Installment Contract with Verizon Wireless Services LLC to provide
telephone number 352-615-3819 to the Plaintiff with a “MOTOROLA G
PURE/MOTXT21632 (Device)”, a Truth In Lending Act Agreement (TILA)
dated November 29, 2022
Exhibit B.3 Verizon confirmation email to the Plaintiff November 30, 2022 at 04.41 PM,
“Hi, NEIL | Account number ending in: 6041-00001”
“You’re all set.”
“Thanks for activating your service on 11/29/2022 for line(s) ending in: 3819.”
"
"!
Montly charges Today's charges
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B.1
RETAIL INSTALLMENT CONTRACT
RETAIL INSTALLMENT SALE AGREEMENT / RETAIL INSTALLMENT
OBLIGATION / SECURITY AGREEMENT
SUBJECT TO STATE REGULATION
YOU, meaning the Buyer named above, agree to pay US, the Seller/Creditor named above, the Total Sale Price of the
goods identified above according to the terms of this Retail Installment Sale Agreement/Retail Installment
Obligation/Security Agreement (the Device Payment Agreement).
B.2
1596217838_1391601_776312
Customer Copy - Page 1
DEVICE PAYMENT AGREEMENT TERMS
1. DEVICE PAYMENT AGREEMENT. THIS DEVICE PAYMENT AGREEMENT REQUIRES THAT YOU MAINTAIN
SERVICE WITH VERIZON WIRELESS UNDER YOUR CUSTOMER AGREEMENT. ALTHOUGH YOUR
CUSTOMER AGREEMENT IS A SEPARATE DOCUMENT, EXCEPT AS PROHIBITED BY APPLICABLE LAW,
THE WAIVERS AND LIMITATIONS OF LIABILITY, DISCLAIMER OF WARRANTIES, AND OTHER
PROVISIONS OF YOUR CUSTOMER AGREEMENT ARE INCORPORATED BY THIS REFERENCE IN THIS
AGREEMENT, AND SHALL SURVIVE TERMINATION OF YOUR CUSTOMER AGREEMENT. ADDITIONALLY,
ANY DISPUTES UNDER THIS DEVICE PAYMENT AGREEMENT SHALL BE RESOLVED IN ACCORDANCE
WITH THE DISPUTE RESOLUTION PROVISIONS IN YOUR CUSTOMER AGREEMENT UNDER THE
HEADING: HOW DO I RESOLVE DISPUTES WITH VERIZON WIRELESS, WHICH TERMS ARE
INCORPORATED BY REFERENCE. SPECIFICALLY, YOU AND VERIZON WIRELESS BOTH AGREE TO
RESOLVE ALL DISPUTES UNDER THIS DEVICE PAYMENT AGREEMENT ONLY BY ARBITRATION OR
SMALL CLAIMS COURT AND YOU WAIVE ANY RIGHT TO A JUDGE OR JURY IN ANY ARBITRATION.
2. PAYMENTS. Payment is due as stated on Your bill. IF WE DO NOT RECEIVE PAYMENT WITHIN 15 DAYS OF
THE DUE DATE, WE MAY CHARGE YOU A LATE PAYMENT FEE OF UP TO 5% OF THE UNPAID BALANCE
OF YOUR BILL OR $5, WHICHEVER IS LESS, except where prohibited by law. Your specific payment schedule
is provided on page 1. Returned checks will be subject to a fee of up to $25, except where prohibited by law.
Payments You make will be applied first to balances due under Your Customer Agreement and then to balances
due under this Device Payment Agreement. If You have more than one device financing agreement with Verizon
Wireless on Your account, payments will be applied to the oldest one first, and then to more recent ones in order
of age; if two device financing agreement with Verizon Wireless are entered into on the same day, the one added
to Our system first will be deemed older. Your payment schedule is determined by the date that You accept these
terms and conditions, which allows Us to apply charges to Your bill. If You order a Device that is not available for
shipment at the time of order, We will provide You with a payment schedule based on Our best estimate of when
Your Device will be shipped. Your first payment will not be due until the Device is shipped. For any Device not
available for shipment at the time of order, You agree that We may update the estimated payment schedule when
Your Device is shipped, and We will provide the new payment schedule to You in writing. Additionally, if a delay in
accepting this Device Payment Agreement or activating Your Device results in any charges becoming due on a
date(s) later than the payment schedule, We will provide You with an updated payment schedule on Your bill. If
You do not activate Your Device within 45 days of receipt, it shall be considered an event of Default subject to
Section 6 of this Device Payment Agreement. If Your Device qualifies for an early upgrade offer, visit
verizonwireless.com/upgradeterms for further details, terms and conditions.
3. PREPAYMENT: You may pay the total amount due under this Device Payment Agreement at any time before the
final scheduled payment is due, and You will not have to pay a penalty. If You pay more than the monthly
payment due any excess amount You pay will be credited to Your account, and applied to any future charges
pursuant to Section 2 above.
4. SECURITY INTEREST. You are granting to Us a purchase money security interest (PMSI) in the Device and any
or all cash or non-cash proceeds of the Device (including, as applicable, any substitutions or replacements), to
secure Your payment and performance of Your obligations under this Device Payment Agreement (collectively,
the "Secured Obligations"). The PMSI You are granting to Verizon Wireless is subject to the Uniform
Commercial Code in effect in the state of Your billing address indicated on this Device Payment Agreement at the
time it is signed.
1596217838_1391601_776312
Customer Copy - Page 2
5. RISK OF LOSS: INSURANCE. You bear the entire risk of loss, theft or damage to the Device from any cause
during the term of this Device Payment Agreement. Even if the Device is lost, stolen or damaged, You remain
obligated for the total Amount Financed. We recommend that You obtain property insurance on the Device. You
may obtain property insurance from others for the Device purchased under this Device Payment Agreement.
6. DEFAULT AND REMEDIES. You are in default under this Device Payment Agreement if You fail to make any
required payment when due or within fifteen (15) days of the due date; You terminate Your Customer Agreement;
We terminate Your Customer Agreement for good cause; You breach any covenant, representation or warranty
hereunder which is not cured within ten (10) days after written notice to You; or We terminate Your Service for
breach (each a Default). To the extent permitted by applicable law, upon a Default We have the right to require
You to pay immediately the entire remaining balance in full under this Device Payment Agreement, and to pay Us
actual and reasonable costs of collection. In addition, to the extent permitted by applicable law, upon a Default
We may (a) take possession of the Device, (b) sell, lease or otherwise dispose of the Device, and/or (c) exercise
all other remedies available to a secured party under the Uniform Commercial Code in effect in the state of Your
billing address indicated on this Device Payment Agreement at the time it is signed or other applicable law. We
will give You notice of Our intent to exercise Our rights as required by applicable law.
7. ASSIGNMENT. We may, without Your consent, and without giving You notice, assign or transfer this Device
Payment Agreement or any payment or any other sums due or to become due hereunder. In such event our
assignee will have, to the extent transferred or assigned to it, all Our rights, powers, privileges and remedies
under this Device Payment Agreement. You agree You will not assign this Device Payment Agreement or any
interest in it and will not sell or transfer, or offer to sell or transfer, or enter, or offer to enter, into any lease with
respect to the Device covered by this Device Payment Agreement without Our prior written consent.
8. MILITARY LENDING ACT DISCLOSURE. If You are a member of the active military, or a spouse or dependent of
the active military, the following apply (the federal government requires Us to provide this notice to You even
though we do not assess any of the fees referenced below): Federal law provides important protections to
members of the Armed Forces and their dependents relating to extensions of consumer credit. In general, the
cost of consumer credit to a member of the Armed Forces and his or her dependent may not exceed an annual
percentage rate of 36 percent. This rate must include, as applicable to the credit transaction or account: The
costs associated with credit insurance premiums; fees for ancillary products sold in connection with the credit
transaction; any application fee charged (other than certain application fees for specified credit transactions or
accounts); and any participation fee charged (other than certain participation fees for a credit card account).
Please refer to the Truth In Lending Act disclosures in this Device Payment Agreement for information regarding
Your monthly payments. To hear this statement of rights under the Military Lending Act, please call 800-922-0204
and mention Military Lending Act.
9. ELECTRONIC ACCESS TO DEVICE PAYMENT AGREEMENT/OTHER COMMUNICATIONS. By signing below,
You acknowledge that You have access to Verizon Wireless' Website at www.verizonwireless.com , where a
copy of this Device Payment Agreement and related privacy and other communications will be provided to You.
You also consent to receive account-related communications in an electronic format, such as by email. If You
want a paper copy of this Device Payment Agreement, You may ask Your sales representative to email or print a
copy for You.
1596217838_1391601_776312
Customer Copy - Page 3
10. BUYER'S RIGHT TO CANCEL. If You do not want the Device purchased under this Device Payment Agreement,
You may cancel this Device Payment Agreement by contacting Verizon Wireless by phone, online, or in person
within 45 days of Your acceptance. You must return Your Device pursuant to Verizon Wireless Return Policy
available at www.verizonwireless.com to obtain a refund. If You do not return Your Device within the return
period, You will be charged for the Amount Financed for Your Device.
I agree to all the terms and conditions of the Retail Installment Sale Agreement/Security Agreement (RISA),
including my obligation to make the monthly payments described on page 1 of my RISA, my right to cancel
within forty-five (45) days, and my grant of a security interest to Verizon Wireless in the device.
1596217838_1391601_776312
Version 07/27/2022 Customer Copy - Page 4
11/30/22, 8:45 PM Yahoo Mail - Neil, your service documents are available in My Verizon.
Important details concerning your wireless service and contract term can be
found in My Verizon under Account Management, then go to View My
Documents.
This email was sent to CELTICEIN@YAHOO.COM. We respect your privacy. Please review our privacy policy. If you think this email was sent in error or
you'd like to change how you receive your notifications, click here.
Verizon Wireless, One Verizon Way, Mail Code: 180WVB, Basking Ridge, NJ 07920
B.3
about:blank 1/1
Filing # 191081810 E-Filed 02/01/2024 05:34:29 PM
NEIL J. GILLESPIE,
Plaintiff,
Case Number:__________________
vs. JURY TRIAL DEMANDED
Defendants.
______________________________________/
Exhibit C.1 Petitioner’s Justice Network blog post January 20, 2021:
USSC Rule 23 Stay Inauguration of Joe Biden and Kamala Harris
https://nosueorg.blogspot.com/2021/01/ussc-rule-23-stay-inauguration-of-joe.html
Exhibit C.2 Petitioner’s email to the Parties in Trump v. Anderson, USSC No. 23-719,
requesting consent under USSC Rule 37 to file an amicus curiae brief.
Exhibit C.3 USSC letter to the Petitioner February 8, 2021 returning his petition received
January 19, 2021, with directions to correct and refile.
Exhibit C.6 Transcript of hearing April 28, 2021, Habeas Petition CP-09-MD-319-2021
THE HONORABLE CLYDE W. WAITE presiding, Courtroom 3
In the Court of Common Pleas of Bucks County, Pennsylvania (Criminal Div.)
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C.5
1
1 Lee.
2 THE COURT: That's because this
3 Laurel Lee is an attorney?
4 THE DEFENDANT: Well, she's a
5 member of the Florida bar, she's an
6 officer of the court, and she's still
7 referred to as Judge Lee because she was a
8 judge prior to being appointed to this
9 executive position.
10 THE COURT: But Governor DeSantis
11 is a lawyer; therefore officer of a court;
12 therefore violates the separation of
13 powers; and, therefore, the papers are
14 irregular as to him?
15 THE DEFENDANT: Yes, Your Honor.
16 THE COURT: That Sheriff Woods of
17 Marion County is also a defendant in some
18 litigation that you're involved in, and
19 that his taking custody of you as a result
20 of an extradition is inappropriate because
21 of some private purpose that he's pursuing
22 that resulted in some adverse action with
23 respect to you, is that correct?
24 THE DEFENDANT: Yes. And just to
25 clarify --
16
1 document. However --
2 THE COURT: So the only thing
3 that you're raising is whether or not the
4 Florida papers are in order based on the
5 things that you've just told me about?
6 THE DEFENDANT: Well, there is
7 more than that, Your Honor. But, yes --
8 THE COURT: Well, what else is
9 there? And it has to be something that's
10 relevant because once the Governor of
11 Pennsylvania accepts the warrant and the
12 rendition documents from Florida, the
13 Court here has no authority to look behind
14 those documents.
15 Now you've done plenty of
16 research on this, I can see that based on
17 the paperwork that you filed, the
18 discussions that you're having now. I
19 looked at your petition for writ of
20 certiorari in the Supreme Court, which
21 many lawyers would not have had the
22 capability of preparing, so you're aware
23 of all of these things.
24 THE DEFENDANT: Yes.
25 THE COURT: And I want to make
24
1 issuance.
2 I find that the requisite facts
3 have been stated appropriately to satisfy
4 that requirement.
5 You have been given your
6 opportunity to pursue your petition for
7 habeas corpus. The hearing has been held.
8 The requisite facts have been admitted;
9 namely, that there are criminal charges
10 pending in Florida, that the Governor of
11 the State of Pennsylvania has accepted
12 that and has issued a directive to this
13 Court to have you extradited to Florida.
14 There have been no other issues raised by
15 the defendant that's recognizable here in
16 this Court.
17 THE DEFENDANT: I'm respectfully
18 disagreeing, Your Honor.
19 THE COURT: You may disagree but
20 that is my ruling.
21 And based thereon, the petition
22 for writ of habeas is denied and the
23 defendant shall forthwith be extradited to
24 the State of Florida to face these
25 criminal charges.
33
C E R T I F I C A T E
_________________________
John A. Toronzi, CRR
Official Court Reporter
DATED: __________________
_________________________
Hon. Clyde W. Waite
DATED:_______________
35