Bella Collina resident don juravin filed protective injunction against Randall Greene

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BELLA COLLINA RESIDENT DON JURAVIN FILED PROTECTIVE INJUNCTION AGAINST RANDALL GREENE

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Protective Injunction against Randall F. Greene was filed

IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT,

IN AND FOR LAKE COUNTY, FLORIDA

DON KARL JURAVIN,

Case No.:______________________

Petitioner, Div. No.:______________________

AGAINST

RANDALL GREENE,

Respondent.

______________________________

AMENDED PETITION FOR INJUNCTION FOR PROTECTION AGAINST STALKING

COMES NOW, the Petitioner, DON KARL JURAVIN, by and through the undersigned counsel, files with this Honorable Court this Petition for Injunction for Protection Against Stalking from RANDALL F. GREENE,  pursuant to Florida Statute §784.0485 and Florida Family Law Rule 12.610, and as sufficient grounds would therefore state:

Section I. Petitioner

1. Petitioner, Don Karl Juravin, currently resides at the following address: 15118 Pendio Drive, Montverde, Florida 34756.
2. Mr. Juravin’s attorney in this matter is the undersigned counsel, Glenn A. Reid of The Reid Law Office with the mailing address of PO Box 950554, Lake Mary, Florida 32795, and the telephone number, 386-235-1920.

Section II. Respondent

1. Respondent, Randall Greene currently resides in the community of Bella Collina at 17034 Medici Way, Montverde, Florida 34756 with the telephone number of 561-317-3354 as well as several other anonymous, unregistered mobile telephones commonly referred to as, “burners.”
2. Petitioner has known Respondent since the first individual contact on December 30, 2016.
3. Respondent’s last known place of employment is a convergence of a number of convoluted roles where his place of business is operated from The Club at Bella Collina and/or his residence. 

4. Physical description of Respondent:

Race: Caucasian 

Sex: Male

Date of Birth: 11/18/1965

Height: 5’8”

Weight: unknown 

Eye Color: unknown

Hair Color: Dark with Gray at the Temples

No known distinguishing marks and/or scars.

Vehicle: 2005 Elise Lotus Color: Grey   Tag Number: COPB8T

5. Other names Respondent has used: Terry Wainwright of Monteverde, Florida with the e-mail address of terrywainwright44@gmail.com. 

6. Randall F. Greene is associated with an extensive list of intertwined business entities and there are a number of attorneys known to represent a few of said entities but there are no known attorneys that represent the respondent, individually.

Section III. Case History and Reason For Seeking Petition

1. Petitioner has not sought nor received an injunction for protection against stalking against Respondent in this or any other court.
2. To the knowledge of the Petitioner, Respondent has not received or tried to get an injunction for protection against stalking against Petitioner in this or any other court.
3. Petitioner and Respondent do not have any other pending or closed court cases between these two parties.
4. Petitioner is a victim of stalking because Respondent has: 

1. _X__ Committed stalking;
2. _X__ Previously threatened, harassed, stalked, cyberstalked, or physically abused the Petitioner;
3. _____ Threatened to harm Petitioner or family members or individuals closely associated with Petitioner;
4. _____ Intentionally injured or killed a family pet;
5. _____ Used, or threatened to use, against Petitioner any weapons such as guns or knives;
6. _____ A criminal history involving violence or the threat or violence, if known;
7. _____ Another order of protection issued against him or her previously from another jurisdiction, if known;
8. _____ Destroyed personal property, including, but not limited to, telephones or other communication equipment, clothing, or other items belonging to Petitioner.

5. Below is a description of the specific incidents of stalking or cyberstalking: 

1. Don Karl Juravin, the petitioner,  has endured too long the abusive, threatening and pointless harassment, stalking and cyberstalking by Randall Greene, the respondent, which appears to have originated from Mr. Greene’s obvious displeasure regarding Mr. Juravin’s lawful and constitutionally protected expressions in a public forum his opinions of the community in which Mr. Juravin resides, Bella Collina in Monteverde, Florida.
2.  In retaliation for the audacity to merely publish opinions for which Mr. Greene finds disagreeable, Mr. Juravin has suffered from threats and intimidation made in person, by text message and anonymous internet posts with the sole purpose of causing damage to Mr. Juravin.  
3. Don Karl Juravin is, and at all times relevant to the instant petition, a resident and property owner of the community of Bella Collina in Monteverde of Lake County, Florida. 
4. Bella Collina, hereafter referred to as, “Bella Collina,”  is a deed restricted community within the Bella Collina Property Owners Association and shall hereafter be referred to as, “BCPOA.” 
5. During Mr. Juravin’s residence in the Bella Collina community, he became accustomed to communicating all questions and concerns to the attention of the property manager, Andrew Gorrill. 
6. A letter, dated December 19, 2016, from the law office, Shutts & Bowen, LLP., was sent to Don K. Juravin complaining of and demanding removal of Mr. Juravin’s legally appropriate reviews of the Bella Collina community with a deadline of December 23, 2016. (SEE Exhibit “A”)
7. On December 28, 2016, Mr. Juravin sent a text message to a contact he understood to be Andrew Gorrill, the property manager for the Bella Collina Property Owners’ Association, hereafter referred to as BCPOA, labeled in his mobile telephone as, “Bella Collina,” (SEE Exhibit “W”) reporting a black vehicle, more specifically described as a Range Rover,  speeding through the community and close proximity where his young daughter was riding her bicycle. (SEE Exhibit “B”)
8. A short time later on the same day, Property Manager Gorrill responded by text message that he and his, “boss Randall Greene,” advised to report the event to Lake County and further advised that all communication should be, “lawyer to lawyer.” (SEE Exhibit “C”)
9. Notwithstanding the previously expressed preference of the property manager and his, “boss Randall Greene,” to communicate rudimental details between legal representatives for each party, Mr. Juravin received, again, a text message on December 30, 2016, from Property Manager Andrew Gorrill unreasonably demanding that Mr. Juravin retain a lawyer for the sole purpose of communicating with the property manager for and the property owners’ association of his own community to which Mr. Juravin repeatedly replied with direction to send all communication to his personal email address. (SEE Exhibit “D”)
10. Shortly after and on the same day of the text message conversation between Mr. Juravin and Property Manager Gorrill, Mr. Juravin received an obviously angry text message from the mobile telephone number 561-317-3354 in which said message listed the identification of, “Randall F. Greene.” (SEE Exhibit “E”)
11. The text message from Randall Greene was an aggressive, personal, threatening  and paltry attempt to demean and intimidate Mr. Juravin with mentions of an, “investigator,” and, “litigation,” a full week after the deadline included in the demand letter from Shutts & Bowen. (SEE Exhibit “E”)
12. There were several consistencies between the text messages from Gorrill and Greene which reveals that the, “boss,” and his employee were working closely together responding to Mr. Juravin’s legitimate concerns for his family’s safety from large automobiles speeding through the gated community. 
13.  On January 9, 2017, 17 days after the deadline set by the demand letter sent by Shutts & Bowen on behalf of the BCPOA, another letter was sent by Shutts & Bowen and this time demanding that Mr. Juravin cease filing police reports regarding Mr. Randall Greene, describing Mr. Greene as the president of BCPOA and failed to set a new deadline for compliance or even extend the previous deadline listed by the previous demand letter. (SEE Exhibit “G”)
14. On January 13, 2017, Priscila Cucutta,  a friend of Mr. Juravin, travelled to Bella Collina at the request of Mr. Juravin to check on his house while he was travelling abroad. Ms. Cucutta was immediately detained by private security force and served with a copy of the previously mentioned letter from Shutts & Bowen dated December 19, 2016, with the addition of a green, square, “post-it,” note scrawled with the message, “We take bogus reviews very seriously. This letter is also for you.”  (SEE Exhibit “H”) 
15. Yet another law office, Ryan Law Group of North Palm Beach, Florida, sent a letter that may only be described by the word, coincidently used within the content of said letter, “bizarre,” as this letter finally provides notice of the long threatened demand to cut off all direct communication between Mr. Juravin and, “the Association.”
16. On March 6, 2017, another text message was sent from mobile telephone number 561-317-3354, previously identified as Randall Greene,  to Mr. Juravin acknowledging Mr. Juravin had not responded to unidentified communication.  Mr. Juravin responded demanding that Mr. Greene cease communication and  harassment. (SEE Exhibit “I”) 
17. On March 7, 2016, a distressed and frustrated Mr. Juravin, responded to a stretch of communication received from Mr. Greene, notwithstanding Mr. Greene’s own request of no direct communication, requesting that Mr. Greene cease communication.  (SEE Exhibit “J”) 
18. On March 12, 2017, in a seemingly act of trickery, subsequent to the numerous letters sent expressing the necessity of communicating solely through lawyers and threatening further legal action if Mr. Juravin failed to do so, Randall Greene deceitfully engaged Mr. Jurvain in communication by sending text messages, only for Mr. Juravin to receive a message five days later, from Andrew Gorrill as noted in the signature, on behalf of Bella Collina POA falsely accusing Mr. Juravin of unsolicited communication.  (SEE Exhibit “K”)
19. On March 27, 2017, Mr. Juravin received a hostile text message from 818-252-8159 a telephone number unknown to him that offered unwelcome comments about legal documents filed in litigation involving Mr. Juravin and appeared to revel in a perceived misfortune for Mr. Juravin. (SEE Exhibit “L”)  
20. On April 3, 2017, Randall Green sent an unsolicited text message to Mr. Juravin regarding a presumed business matter, despite Mr. Greene’s own reiteration of “no direct communication” and request to communication through lawyers only.  (SEE Exhibit “M”) 
21. On May 2, 2017, Randall Greene, yet again, sent another unsolicited, threatening, accusatory text message to Mr. Juravin stating, “Another fake police report?? You won’t like the results of this one.”  (SEE Exhibit “M”) 
22. The harassment and stalking was not solely confined to communications via letters and text messages. A series of false, defaming online reviews were published regarding Mr. Juravin and his business, portraying Mr. Juravin in a negative light. The author of these articles is believed to be the same person, and likely is Mr. Greene. (SEE Exhibit “N” through Exhibit “V”) 
23. There are numerous similarities between all of the various writings associated with or identified to be authored by Randall Greene. The similarities between the incidents of this ongoing, relentless stalking and cyberstalking by Randall Greene of Don Juravin includes but is certainly not limited to the repeated misspelling of the word, “Judgement,” the regular use of the word, “bogus,” as well as an endless parade of obvious counterfeit identities that would likely originate from the same mind that would list his education on a professional networking site as, “St. Plegmund III of Canterbury Reform School for Boys,” and drive a Gray Lotus Elise with the vanity license plate, “COPB8T.” (SEE Exhibit “F”)
24. The most recent libelous post regarding Mr. Juravin was published online on the morning of May 31, 2017 and reported with great specificity about three lawsuits filed by, “Bella Collina,” against Mr. Juravin. A contemporaneous review of the Lake County Clerk of Court online records showed that the third lawsuit was not yet available on the site. The third case was not available for review on the clerk’s website until the next day, June 1, 2017. This advanced and inside information about this third case demonstrates that the anonymous poster is Randall Greene or someone working closely and in concert with Randall Greene. (SEE Exhibit “V”)    

6. Petitioner is not aware of whether Respondent owns, has, and/or is known to have guns or other weapons.  

Section IV. Injunction 

1. Petitioner moves the Court to enter a TEMPORARY INJUNCTION for protection against stalking that will be in place from now until the scheduled hearing in this matter, which will immediately restrain Respondent from committing any acts of stalking, and which will provide any terms the Court deems necessary for the protection of a victim of stalking, including any injunctions or directives to law enforcement agencies.
2. Petitioner moves the Court to enter, after a hearing has been held on this petition, a FINAL JUDGMENT for protection against stalking prohibiting Respondent from committing any acts of stalking against Petitioner and:

a. prohibiting Respondent from going to or within 500 feet of any place Petitioner lives, or to any specified place regularly frequented by Petitioner and any named family members or individuals closely associated with Petitioner; Anna Juravin Levia Juravin, Ynes Juravin, and Karin Juravin.

b. prohibiting Respondent from going to or within 500 feet of Petitioner’s place(s) of employment or the school that Petitioner attends;  the address of Petitioner’s place(s) of employment and/or school is: 

c. prohibiting Respondent from contacting Petitioner by telephone, text message, mail, by e-mail, in writing, through another person, or in any other manner;

d. ordering Respondent that he or she shall not have in his or her care, custody, possession, or control any firearm or ammunition;

e. prohibiting Respondent from knowingly and intentionally going to or within 100 feet of Petitioner’s motor vehicle, whether or not that vehicle is occupied;

3. Petitioner moves the Court to enter any other terms it deems necessary to protect Petitioner from stalking by Respondent.

I UNDERSTAND THAT BY FILING THIS PETITION, I AM ASKING THE COURT TO HOLD A HEARING ON THIS PETITION, THAT BOTH THE RESPONDENT AND I WILL BE NOTIFIED OF THE HEARINGS, AND THAT I MUST APPEAR AT THE HEARING. I UNDERSTAND THAT IF EITHER RESPONDENT OR I FAIL TO APPEAR AT THE FINAL HEARING, WE WILL BE BOUND BY THE TERMS OF ANY INJUNCTION OR ORDER ISSUED AT THAT HEARING.

I UNDERSTAND THAT I AM SWEARING OR AFFIRMING UNDER OATH TO THE TRUTHFULNESS OF THE CLAIMS MADE IN THIS PETITION AND THAT THE PUNISHMENT FOR KNOWINGLY MAKING A FALSE STATEMENT INCLUDES FINES AND/OR IMPRISONMENT.

I HAVE READ EVERY STATEMENT MADE IN THIS PETITION AND EACH STATEMENT IS TRUE AND CORRECT. I UNDERSTAND THAT THE STATEMENTS MADE IN THIS PETITION ARE BEING MADE UNDER PENALTY OF PERJURY, PUNISHABLE AS PROVIDED IN SECTION 837.02, FLORIDA STATUTES.

_______  

(initials)  

Dated: ____________________________ ____________________________________

Signature of Petitioner

STATE OF FLORIDA

COUNTY OF ______________________

Sworn to or affirmed and signed before me on __________ by____________________________

____________________________________

NOTARY PUBLIC or DEPUTY CLERK

____________________________________

(Print, type, or stamp commissioned name of notary clerk.)

_____ Personally known

_____ Produced identification

Type of identification produced ________________________

IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT,

IN AND FOR LAKE COUNTY, FLORIDA

DON KARL JURAVIN,

Case No.:______________________

Petitioner, Div. No.:______________________

and

RANDALL GREENE,

Respondent.

______________________________/

NOTICE OF RELATED CASES

1. Petitioner submits this Notice of Related Cases as required by Florida Rule of Judicial Administration 2.545(d). A related case may be an open or closed civil, criminal, guardianship, domestic violence, juvenile delinquency, juvenile dependency, or domestic relations case. A case is “related” to this family law case if it involves any of the same parties, children, or issues and it is pending at the time the party files a family case; if it affects the court’s jurisdiction to proceed; if an order in the related case may conflict with an order on the same issues in the new case; or if an order in the new case may conflict with an order in the earlier litigation.

___ There are no related cases.

_X_ The following are the related cases (add additional pages if necessary):

Related Case No. 1

Case Name(s):_DCS Real Estate Investments v. Don K. Juravin__________________________                         

Plaintiff:__DCS Real Estate Investments_____________________________________________                                                 Defendantt  _Don Karl Juravin___________________________________________________ Case No.: _35-2017-CA-000667__________ Division:  ___________________________   

Type of Proceeding:  [check all that apply]  

____ Dissolution of Marriage ____ Paternity  

____ Custody  ____ Adoption   

____ Child Support ____ Modification/Enforcement/Contempt Proceedings ____ Juvenile Dependency ____ Juvenile Delinquency   

____ Termination of Parental Rights ____ Criminal  

____ Domestic/Sexual/Dating/Repeat ____ Mental Health      

____ Violence or Stalking Injunctions       __X  Other_Defamation Complaint____________

State where case was decided or is pending: __X_ Florida ____ Other: {specify}_____________

Name of Court where case was decided or is pending: _Fifth Circuit Court of Lake County, Florida before Judge Nacke_______________________________________________________  Title of last Court Order/Judgment (if any): ____________None__________________________ Date of Court Order/Judgment (if any): _______________None__________________________

Relationship of cases: 

_X__ pending case involves same parties, children, or issues;

____ may affect court’s jurisdiction;  

_X__ order in related case  may conflict with an order in this  case;  

_X__ order in this case may conflict with previous order in related case.

Statement as to the relationship of the cases:  _The instant case is part and parcel of the constant course of conduct that directs intimidation and harassment toward Mr. Juravin to silence his speech. The lawsuit is a poor attempt to place a legitaimate face on the stalking behavior of Mr. Juravin._______________________________________________________________________

Related Case No. 2

Case Name(s): __Bella Collina Property Owners’ Assocition, Inc., v. Don Karl Juravin_______  Plaintiff: __Bella Collina Property Owners’ Association, Inc._____________________________                                                 Defendant:  __ Don Karl Juravin_________________________________________________ Case No.: __35-2017-CC-001748______________ Division:  ___________________________ 

Type of Proceeding:  [check all that apply]  

____ Dissolution of Marriage ____ Paternity  

____ Custody  ____ Adoption   

____ Child Support ____ Modification/Enforcement/Contempt Proceedings ____ Juvenile Dependency  ____ Juvenile Delinquency  

____ Termination of Parental Rights  ____ Criminal  

____ Domestic/Sexual/Dating/Repeat ____ Mental Health        

____ Violence or Stalking Injunctions __X_Other_Interpleader for Grass Dispute______     

State where case was decided or is pending: _X_ Florida ____ Other: {specify} _____________

Name of Court where case was decided or is pending:_Fifth Circuit County Court Lake County, Florida before Judge Neal_____________________________________________________ Title of last Court Order/Judgment (if any): _______________None_______________________ Date of Court Order/Judgment (if any): _________________None________________________

_X__ pending case involves same parties, children, or issues;

____ may affect court’s jurisdiction;  

_X__ order in related case  may conflict with an order in this  case;  

_X__ order in this case may conflict with previous order in related case.

Statement as to the relationship of the cases:  _The instant case is part and parcel of the constant course of conduct that directs intimidation and harassment toward Mr. Juravin to silence his speech. The lawsuit is a poor attempt to place a legitaimate face on the stalking behavior of Mr. Juravin._______________________________________________________________________

Related Case No. 3

Case Name(s): __Bella Collina Property Owners’ Assocition, Inc., v. Don Karl Juravin_______  Plaintiff: __Bella Collina Property Owners’ Association, Inc._____________________________                                                 Defendant:  __ Don Karl Juravin_________________________________________________ Case No.: __35-2017-CA-000979______________ Division:  ___________________________ 

Type of Proceeding:  [check all that apply]  

____ Dissolution of Marriage ____ Paternity  

____ Custody  ____ Adoption   

____ Child Support ____ Modification/Enforcement/Contempt Proceedings ____ Juvenile Dependency  ____ Juvenile Delinquency  

____ Termination of Parental Rights  ____ Criminal  

____ Domestic/Sexual/Dating/Repeat ____ Mental Health        

____ Violence or Stalking Injunctions __X_Other: Complaint for Injunctive Relief_____     

State where case was decided or is pending: _X_ Florida ____ Other: {specify} _____________

Name of Court where case was decided or is pending:_Fifth Circuit County Lake County, Florida before Judge Briggs_____________________________________________________ Title of last Court Order/Judgment (if any): _______________None_______________________ Date of Court Order/Judgment (if any): _________________None________________________

_X__ pending case involves same parties, children, or issues;

____ may affect court’s jurisdiction;  

_X__ order in related case  may conflict with an order in this case;  

_X__ order in this case may conflict with previous order in related case.

Statement as to the relationship of the cases:  _The instant case is part and parcel of the constant course of conduct that directs intimidation and harassment toward Mr. Juravin to silence his speech. The lawsuit is a poor attempt to place a legitimate face on the stalking behavior of Mr. Juravin._______________________________________________________________________

3. [check all that apply]

__X_  Assignment to one judge   

_  X_  Coordination of existing cases will conserve judicial resources and promote an efficient         

         determination of these cases because the parties and issues are inextricably intertwined. 

4. The Petitioner acknowledges a continuing duty to inform the court of any cases in this or any other state that could affect the current proceeding.

Dated on this the 2nd day of June, 2017.                     

 ________________________________________        Don K. Juravin

15118 Pendio Drive

Montverde, Florida 34756     

Telephone Number: 813-810-5100      

E-mail Address: don@gastric.care 

CERTIFICATE OF SERVICE 

I CERTIFY that I delivered a copy of this Notice of Related Cases to the Lake County Sheriff’s Department and/or a certified process server for service on the Respondent, Randall Greene at 17034 Medici Way, Montverde, Florida 34756,  and a copy to: Electronic Mail and/or  US Postal Service and/or Hand Delivered Honorable Chief Judge Don F. Briggs, Lake County Judicial Center, P.O. Box 7800, 550 W. Main Street, Tavares, FL 32778, Chief Judge for the Fifth Circuit, and who is assigned to Lake County Case Number 2017-CA-000979; Electronic Mail and/or  US Postal Service and/or Hand Delivered to Judge Lawrence J. Semento,  via email at bpettingill@circuit5.org, Administrative and Circuit Judge for Lake County; Electronic Mail and/or  US Postal Service and/or Hand Delivered to Judge Mark Nacke, via email at aarchey@circuit5.org, Lake County Judicial Center, P.O. Box 7800, 550 W. Main Street, Tavares, FL 32778, who is the judge assigned to Lake County Case Number 2017-CA-000667; US Postal Service and/or Hand Delivered to Judge Terry T. Neal, Lake County Judicial Center, P.O. Box 7800, 550 W. Main Street, Tavares, FL 32778,  who is the judge assigned to Lake County Case Number 2017-CC-001748; via US Postal Service to Paul E Simonson, 505 South Flagler Drive, Suite 900, West Palm Beach, FL 33401, a registered agent for the party of the related cases, DCS Real Estate Investments, LLC.;  via US Postal Service to Aegis Community Management Solutions, Inc., 8390 Championsgate Blvd., Suite 304, Championsgate, FL 33896, a registered agent for the party of the related cases, Bella Collina Property Owners’ Association, Inc.; via Electronic Mail to Robert L. Taylor, Esq.,  who is the attorney for Bella Collina Property Owners’ Association, Inc. in Lake County Case Number 2017-CC-001748 at rtaylor@bplegal.com; via Electronic Mail to Michael Crosbie Esq., who is the attorney for DCS Real Estate Investments, LLC in Lake County Case Number 2017-CA-000667 at mcrosbie@shutts.com; via Electronic Mail to  James Ryan, Esq., who is the attorney for Bella Collina Property Owners’ Association, Inc. in Lake County Case Number 2017-CA-000979, at jdr@ryanlawgroup.net,  on June 2, 2017.

______________________________

Glenn A. Reid, Esquire

The Reid Law Office

Florida Bar # 0629898

Post Office Box 950554

Lake Mary, Florida 32795              

Ph: (386) 235-1920

                                                                        glenn@thereidlawoffice.com

                                                                        legal7@gastric.care

Attorney for the Petitioner