IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA JERMAINE CARLOS DIAZ , Plaintiff, CASE NO: v. RAYON SHERWIN PAYNE d/b/a FOLKSALERT APP , Defendant. ________________ __ _____________/ COMPLAINT Plaintiff , JERMAINE CARLOS DIAZ , by and t hrough the undersigned counsel, here by sues Defendant, RAYON SHERWIN PAYNE d/b/a FOLKSALERT APP , and states as follows: PARTIES, VENUE, AND JURISDICTION 1. This is an action for defamation and for damages in excess of $15,000.00, exclusive of attorney’s fees. 2. Plaintiff, JERMAINE CARLOS DIAZ , is an individual who at all times material hereto has and continues to reside in Harris County, Texas 3. Defendant, RAYO N SHERWIN PAYNE , is an individual who at all times material hereto has and continues to re side in Orange County, Florida at the address of 8815 Conroy Windermere Rd., Orlando, FL 32835. 4. Venue is proper in Orange County, Florida pur suant to § 47.011, Fla. Stat . because it is the county where the Defendant resides and it is the county where the cause of action accrued. 5. Jurisdiction of this Court is proper pursuant to § 26.012, Fla. Stat Filing # 91884416 E-Filed 06/28/2019 06:10:47 PM 2 GENERAL ALLEGATIONS 6. Plaintiff, JERMAIN E CARLOS DIAZ (“DIAZ”) , is t hirty - six (36) years old and resides in the Houston, Texas area. 7. In July 1998, when DIAZ was only fourteen (14) years old, he was arrested on charges of transporting a minor, who was one year older than him (15 years old) in interstate commerce for purposes of prostitution, and for aiding and abetting. 8. Despite being only fourteen (14) years old when the incident occurred, DIAZ has spent the past two decades with no further incident as it relates to those charges. DIAZ has never been designated a dangerous sex offender and DIAZ’s lifetime supervision has been terminated. 9. DIAZ was previously enrolled in the Texas Art Institute and majored in interior design. 10. Since finishing school DIAZ has dedicated his life to raising his twelve - year - old son of whom he has full custody. 11. Since 2006 , DIAZ has managed music artists through his successful company Money To Blow Music Group, LLC, and has gained considerable notoriety in doing so. 12. DIAZ maintained an Instagram page, @ lacetheblueprint , where he promoted the music artists he manages and commonly goes by the name of “ Lace the Blue Print ” or “Young Lace.” Through Instagram, DIAZ generated income in the amount of $15,000 to $25,000 per month through appearance booking fees and endorsements. 13. Defendant, RAYON SHERWIN PAYNE (“PAYNE”), works in maintenance at a Central Florida apartment complex and also operates and maintains the FolksAlert App YouTube page at https://www.youtube.com/channel/UCcXVxqGH - WkzUPKzihJAjmQ/featured (“FolksAlert”). 3 PAYNE’S FALSE AND DEFAMATORY STATEMENTS AND HARASSMENT OF DIAZ 14. PAYNE, who commonly goes by t he name of “Keko,” has an unhealthy obsession with DIAZ, despite the two having never met and despite DIAZ wanting absolutely nothing to do with PAYNE . Utilizing FolksAlert, PAYNE routinely harasses DIAZ with an intent to cause DIAZ substantial emotional distress by publishing false and defamatory videos about DIAZ to FolksAlert. 15. In fact, PAYNE’s publication of the numerous false and defamatory videos concerning DIAZ have achieved their desired result of harassing DIAZ and causing DIAZ severe emotional distress. 16. For example, through his Fol k sAlert videos, PAYNE frequently states that DIAZ is a “ dangerous sex offender” and implicates DIAZ as being currently involved in human trafficking . These statements p ublished by PAYNE are false and defamatory, and were published by PAYNE with express malice or reckless disregard for the truth. 17. A timeline of PAYNE’s bizarre publication of false and defamatory statements about DIAZ is as follows. 18. On February 13, 2019, P AYNE published a video to YouTube titled “Dear Young Lace Lets Do Busines s ” https://www.youtube.com/watch?v=d2MwkJYRwp4 In this video, PAYNE brags about his harassment of DIAZ and states , in part: “Carlos @YoungLace, I just deleted your #moneytoblowceo ig page.” 19. On February 16, 2019, PAYNE published a vid eo to FolksAlert’s YouTube chann el titled “Young Lace – The Sex Offender Blue Print ” https://www.youtube.com/watch?v=GMjF - q4KoqA In this video, PAYNE states that “one can arguably say that [DIAZ] is the most successful human trafficker in the United States.” This statement is false and defamatory, and was published with express malice or reckless disregard for the truth. 4 20. On February 18, 2019, PAYNE published a video to FolksAlert’s YouTube channel titled “The Blue Print – A Dangerous Sex Offender (Young Lace) – Trailer 1 ” https://www.youtube.com/watch?v=lM4bg6fs_eQ&t=27s In this video, PAYNE implicates DIAZ as being involved in human trafficking and states that DIAZ is a “dangerous sex offender .” These statement s are false and defamatory, and were published with express malice or reckless disregard for the truth. 21. On February 20, 2019, PAYNE published a video to FolksAlert’s YouTube channel titled “The Blue P rint – A Dangerous Sex Offender (Young Lace) – Trailer 2” https://www.youtube.com/watch?v=3MO7LA3YSBk In this video, PAYNE implicates DIAZ as being involved in human trafficking, states DIAZ is a “dangerous sex offender,” and states and implies that DIAZ is involved with prostitution. The description of the video states: This summer Folksalert presents a documentary about a dangerous sex offender Jermaine Carlos Diaz aka Young Lace and one of his many prostitutes Angelica DiDisiena. (emphasis supplied). 22. These statements are false and defamatory, and were published with express malice or reckless disregard for the truth. 23. On February 21, 2019, PAYNE published a video to FolksAlert’s YouTube channel tilted “Young Lace – The Bold Sex Offender Pimp” https://www.youtube.com/watch?v=e_LBLHMwifU In this video, PAYNE states that DIAZ is a pimp and implicates DIAZ in prostitution. This statement is false and defamatory, and was published with express malice or reckless disregard for the truth. 24. On February 23, 2019, PAYNE published a video to FolksAlert’s YouTube channel titled “The Blue Print – A Dangerous Sex Offender (Young Lace) - Trailer 3” https://www.youtube.com/watch?v=4DHUjkcfXy8&t=33s In this video, PAYNE states that DIAZ is a dangerous sex offender and implies that DIAZ is a human traf ficker, states that DIAZ 5 is a sex trafficker, or involved with human trafficking, implies that DIAZ is involved in prostitution, and states that DIAZ has eight females working for him. These statements are false and defamatory, and were published with expr ess malice or reckless disregard for the truth. 25. On February 27, 2019, PAYNE published a video to FolksAlert’s YouTube channel titled “The Blue Print – A Dangerous Sex Offender (Young Lace) – Trailer 3” https://www.youtube.com/watch?v=rGeDG - hEVPc . In this video, PAYNE states that DIAZ is a dangerous sex offender. This statement is false and defamatory, and was published with express malice or reckl ess disregard for the truth. 26. On March 4, 2019, PAYNE published a video to FolksAlert’s YouTube channel titled “The Blue Print – A Dangerous Sex Offender (Young Lace) Trailer 6” https://www.youtube.com/watch?v=cqfX9027gjQ . In this video, PAYNE implies that DIAZ is involved with human trafficking and sex trafficking and states that DIAZ is a dangerous sex offender. This statement is false and defamatory, and was published with expr ess malice or reckless disregard for the truth. Further, the video depicts a picture of a battered woman and falsely implies that DIAZ beat the wom a n and otherwise harms women. 27. On March 17, 2019, PAYNE published a video to FolksAlert’s YouTube channel tit led “The Blue Print – A Dangerous Sex Offender (Young Lace) – Trailer 7” https://www.youtube.com/watch?v=X5 - m6DzQjcs . In this video, PAYNE implies that that DIAZ is a sex trafficker, states that DIAZ has eight prostitutes, and that DIAZ is a pimp. These statements are false and defamatory, and were published with express malice or reckless disregard for the truth. 28. Also on March 17, 2019, PAYNE published a video to FolksAlert’s YouTube channel titl ed “EP 51: BOLD PIMPING – A Houston Sex Trafficking Operation” https://www.youtube.com/watch?v=DxAyQgX_R6Y . In this video, PAYNE implie s that DIAZ is 6 a sex trafficker, and is involved with sex tra fficking and prostitution This statement is false and defamatory, and was published with express malice or reckless disregard for the truth. 29. On March 18, 2019, PAYNE published a video to FolksAlert’s YouTube channel titled “CLASSIC PIMPING: Johnny Cash an d Young Lace (2012)” https://www.youtube.com/watch?v=Qf8zIxwwdIA . In this video, PAYNE implies that DIAZ is a pimp and involved with prostitution. This statement is false and defamatory, and was p ublished with express malice or reckless disregard for the truth. 30. On March 23, 2019, PAYNE published a video to FolksAlert’s YouTube channel titled “The Blue Print – A Dangerous Sex Offender (Young Lace) – Trailer 8” https://www.youtube.com/watch?v=ZTKnqZIG1Wg . In this video, PAYNE states that DIAZ “is known on social media and around the United States in human trafficking circle s as Young Lace the Pimp.” The video otherwise imp l ies that DIAZ is a sex trafficker or is involved in sex trafficking. These statements are false and defamatory and were published with express malice or reckless disregard for the truth. 31. On April 6, 2019, PAYNE published a video to FolksAlert’s YouTube cha nnel titled “A Trusted Face Young Lace” https://www.youtube.com/watch?v=DpFyBYPqSDo The video implies that DIAZ is a pimp and involved with prostitution. This statement is false and defamatory, a nd was published with express malice or reckless disregard for the truth. 32. On April 16, 2019, PAYNE published a video to the FolksAlert’s YouTube channel titled “Using Algorithm To Stop Sex Offender Jermaine Carlos Diaz” https://www.youtube.com/watch?v=0OLEbi2goQA . In this video, PAYNE implies that DIAZ is dangerous and needs to be stopped from committing crimes. This statement is false and defamatory, and was publi shed with express malice or reckless disregard for the truth. 7 33. On May 6, 2019, PAYNE published a video to FolksA lert’s YouTube channel titled “ The Blue Print – A Dangerous Sex Offender (Young Lace) Trailer 10” https://www.youtube.com/watch?v=XxRW0KDHJtY . In this video, PAYNE implies that DIAZ committed the crime of auto theft. This statement is false and defamatory, and was published with express malice or reckless disregard for the truth. 34. On May 25 , 2019, PAYNE published a video to FolksAlert’s YouTube channel titled “The Young Lace Documentary Coming Summer 2019” https://www.youtube.com/watch?v=1jkbi7 - dl4w . The video threatens and harasses DIAZ with the release of a false and defamatory “documentary” about DIAZ. 35. On June 14, 2019, PAYNE again threatened and harassed DIAZ by publishing a video to FolksAlert’s YouTube channel titled “On 6/17/19 I will have a release date for this Young Lace documentary” https://www.youtube.com/watch?v=N - uWvaOm5uc . The video is a clear threat from PAYNE to DIAZ that PAYNE still intend s to release a so called documentar y, containing false and defamatory statements about DIAZ. 36. Again, on June 15, 2019, PAYNE published another video to the FolksAlert’s YouTube channel titled “Intro: The Blue Print – A Dangerous Sex Offender (Young Lace)” https://www.youtube.com/watch?v=GEefId4 - nag wherein PAYNE is threatening DIAZ with the release of the so called documentary about DIAZ. 37. Then, on June 20, 2019, PAYNE publi shed another video to the FolksAlert’s YouTube channel titled “Registered Sex Offender Carlos Diaz Gets Clowned” https://www.youtube.com/watch?v=Ph3jSvc6Ji0 In this video, PAYNE again harasses DIAZ and brags about PAYNE’s efforts to d elete DIAZ’s and his company’s Instagram pages. 38. PAYNE has also disseminated the aforementioned false and defamatory statements concerning DIAZ to Twitter and Instagram. 8 39. The foregoing statements of fact published by PAYNE about DIAZ charged that DIAZ comm itted an infamous crime and subjected DIAZ to hatred, distrust, ridicule , contempt, or disgrace. 40. PAYNE’s false and defamatory statements concerning DIAZ directly and proximately, and in natural and continuous sequence caused, and continue to cause harm a nd damage to DIAZ, including, without limitation, injury and harm to DIAZ’s reputation, and have caused DIAZ to suffer shame, humiliation, mental anguish and suffering, and hurt feelings experienced in the past and to be experienced in the future such that , but for the publication of the false and defamatory statements, the damage to DIAZ would not have occurred. 41. As a result of PAYNE’s publication of false and defamatory statements concerning DIAZ, DIAZ has also suffered economic damages which are not yet quantified and are ongoing. 42. PAYNE has repeatedly threatened to release a so - called documentary about DIAZ containing blatant false and defamatory statements about DIAZ. 43. PAYNE’s false and defamatory publications serve no legitimate purp o ses. ILLEGAL PHONE CALL RECORDINGS 44. On November 18, 2018, PAYNE illegally recorded a phone call h e had with DIAZ without DIAZ’s c onsent or knowledge, in violation of § 943.03, Fla. Stat https://www.yo utube.com/watch?v=o6aa33BfWbs 45. On or about February 16, 2019, PAYNE illegally recorded a phone call he had with DIAZ, without DIAZ ’ s consent or knowledge, in violation of § 934.03, Fla. Stat https://www.youtube.com/watch?v=sDThsZ - XvY8 46. On April 16, 2019, PAYNE illegally recorded a phone call he had with DIAZ without DIAZ’s consent or knowledge, and in violation of § 943.03, Fla. Stat https://www.youtube.com/watch?v=0OLEbi2goQA 9 47. The aforementioned recordings occurred when DIAZ had a reasonable expectation of privacy. PAYNE’S INTENTIONAL AND DELIBERATE TORTIOUS INTERFERENCE 48. PAYNE’s harassment has not stopped with DIAZ. PAYNE has ev en called DIAZ’s son’s school and harassed DIAZ’s mother. 49. In 2019 , PAYNE took action to cause DIAZ’s personal Instagram page, @lacetheblueprint , DIAZ’s business Instagram page, @moneytoblowmusic group , and DIAZ”s business You Tube channel, “ moneytoblowmusicgroup,” to be deleted or o therwise removed from Instagram and YouTube. PAYNE took such actions without justification and with an intent to damage DIAZ. 50. All conditions precedent to the maintenance of this action have been satisfied, waiv ed or occurred. 51. Plaintiff, DIAZ, has retained the undersigned counsel and has agreed to pay the undersigned a reasonable fee for services rendered. COUNT I - SLANDER 52. This is an action for slander against PAYNE. 53. Plaintiff , DIAZ, realleges and incorporates the allegations set forth in paragraph s 1 through 51 as though fully restated herein. 54. Defendant, PAYNE, made false and defamatory statements concerning DIAZ. 55. Said false and defamatory statements were published to third parties. 56. Plaintiff, DIAZ, has suf fered damages as a result of the Defendant, PAYNE’s, publication of the false and defamatory statements. 10 WHEREFORE, Plaintiff, JERMAINE CARLOS DIAZ, respectfully requests this Court enter judgment in Plaintiff’s favor and against Defendant for all damage s, award costs, and grant such further relief this Court deems just and proper. COUNT II - LIBEL 57. This is an action for libel against PAYNE. 58. Plaintiff, DIAZ, realleges and incorporates the allegations set forth in paragraphs 1 through 51 as though fully restated herein. 59. Defendant, PAYNE, made false and defamatory statements concerning DIAZ by publishing certain written statements to YouTube, Instagram, and Twitter. 60. Said false and defamatory statements were published to third parties. 61. Plaintiff, DIAZ, has suffered damages as a result of Defendant, PAYNE’s, publication of the false and defamatory statements. WHEREFORE, Plaintiff, JERMAINE CARLOS DIAZ, respectfully requests this Court enter judgment in Plaintiff’s favor and against Defe ndant for all damages, award costs, and grant such further relief this Court deems just and proper. COUNT III – SLANDER PER SE 62. This is an action for slander per se against PAYNE. 63. Plaintiff, DIAZ, realleges and incorporates the allegations set forth in p aragraphs 1 through 51 as though fully restated herein. 64. Defendant, PAYNE, made false and defamatory statements concerning DIAZ, which charged that Plaintiff, DIAZ, committed an infamous crime and subjected DIAZ to hatred, distrust, ridicule, contempt, or d isgrace. 65. Said false and defamatory statements were published to third parties. 11 66. Plaintiff, DIAZ, has suffered damages as a result of Defendant, PAYNE’s, publication of the false and defamatory statements. WHEREFORE, Plaintiff, JERMAINE CARLOS DIAZ, respectfully requests this Court enter judgment in Plaintiff’s favor and against Defendant for all damages, award costs, and grant such further relief this Court deems just and proper. COUNT IV – LIBEL PER SE 67. This is an action for libel per se against PAY NE. 68. Plaintiff, DIAZ, realleges and incorporates the allegations set forth in paragraphs 1 through 51 as though fully restated herein. 69. Def endant , PAYNE, made written false and defamatory statements concerning DIAZ, which charged that Plaintiff, DIAZ, commit ted an infamous crime and subjected DIAZ to hatred, distrust, ridicule, contempt, or disgrace. 70. Said false and defamatory statements were published to third parties. 71. Plaintiff, DIAZ, has suffered damages as a result of Defendant, PAYNE’s, publication of th e false and defamatory statements. WHEREFORE, Plaintiff, JERMAINE CARLOS DIAZ, respectfully requests this Court enter judgment in Plaintiff’s favor and against Defendant for all damages, award costs, and grant such further relief this Court deems just and proper. COUNT V – DEFAMATION BY IMPLICATION 72. This is an action for defamation by implication against PAYNE 73. Plaintiff, DIAZ, realleges and incorporates the allegations set forth in paragraphs 1 through 51 as though fully restated herein. 74. Defendant, PAYNE, made certain statement s which either 12 a) Juxtaposed a series of facts so as to imply a defamatory connection between them; or b) Created a defamatory implication by omitting certain facts. 75. Said false and defamatory statements were published to third parties. 76. Plaintiff, DIAZ, has suffered damages as a result of Defendant, PAYNE’s, publication of the false and defamatory statements. WHEREFORE, Plaintiff, JERMAINE CARLOS DIAZ, respectfully requests this Court enter judgment in Plaintiff’s favor and against Defendant for all damages, award costs, and grant such further relief this Court deems just and proper. COUNT VI – INTERCEPTION OF COMMUNICATIONS IN VIOLATION OF FLORID A SECURITY OF COMMUNICATIONS ACT – FLORIDA STATUTE 934.10 77. This is action for violation of § 934.03, Fla. Stat against PAYNE brought pursuant to § 934.10, Fla. Stat 78. Plaintiff, DIAZ , realleges and incorporates the allegations set forth in paragraphs 1 through 51 as though fully restated herein. 79. Defendant, PAYNE, intercepted and recorded oral conversations between PAYNE and DIAZ. 80. Plaintiff, DIAZ, did not consent to and was not aware of any of these interceptions. 81. Plaintiff, did not give his implied co nsent or authorization, express or implied, to allow the interception of these oral communications. 82. The interception and reco r ding of oral communications was Defendant, PAYNE’s, conscious objective. 83. As a direct and proximate result of Defendant, PAYNE’s, actions and conduct, Plaintiff, DIAZ, has suffered and will continue to suffer damages, including economic damages , reputation damages , and damage to his current and prospective business relations. 13 WHEREFORE, Plaintiff, JERMAINE DIAZ, respectfully reques ts this Court enter judgment in Plaintiff’s favor and against Defendant, for Plaintiff’s actual damages but not less than liquidated damages computed at the rate of $100 a day for each date of violation, or $1,000.00, whichever is higher, pursuant to § 934 .10(1)(b), Fla. Stat ., pre - judgment interest, costs including reasonable attorney’s fees pursuant to § 934.10(1)(d), Fla. Stat ., and grant such further relief this Court deems just and proper. COUNT VII – TORTIOUS INTERFERENCE WITH ADVANTAGEOUS BUSINESS RELATIONSHIP 84. This is an action for tortious interference with an advantageous business relationship against PAYNE. 85. Plaintiff, DIAZ, realleges and incorporates the allegations set forth in paragraphs 1 through 51 as though full y restated herein. 86. Plaintiff, DIAZ, maintained advantageous business relationship s with YouTube and Instagram. 87. Defendant, PAYNE, had and has knowledge of the advantageous business relationship. 88. Defendant, PAYNE, intentionally and unjustifiably interfered w ith the advantageous bus iness relationship, by taking action to induce YouTube and Instagram to suspend Plaintiff, DIAZ’s, YouTube and Instagram pages. 89. Plaintiff, DIAZ, has suffered damages as a result of PAYNE’s tortious interference. WHEREFORE, Plaintiff, JERMAINE DIAZ, respectfully requests this Court enter judgment in Plaintiff’s favor and against Defendant for all damages, award costs, and grant such further relief this Court deems just and proper. 14 COUNT VIII – TORTIOUS INTERFERENCE WITH AD VANTAGEOUS BUSINESS RELATIONSHIP 90. This is an action for tortious interference with an advantageous business relationship against PAYNE. 91. Plaintiff, DIAZ, realleges and incorporates the allegations set forth in paragraphs 1 through 51 as though fully restat ed herein 92. Plaintiff, DIAZ, maintained advantageous business relationships with certain companies and entities which directly generated income each month for DIAZ through YouTube and Instagram. 93. Defendant, PAYNE, had and has knowledge of these advantageous b usiness relationships. 94. Defendant, PAYNE, intentionally and unjustifiably interfered with the advantageous business relationships, by taking action to induce YouTube and Instagram to suspend Plaintiff, DIAZ’s, YouTube and Instagram pages, and by continuing to make false and defam atory statements about DIAZ, thereby causing certain companies and entities to discontinue business with DIAZ. 95. Defendant, PAYNE ’ s , intentional and unjustified interference with DIAZ ’ s adv antageous business relationships include, bu t a r e not limited to the publication of the aforementioned YouTube videos, and the following additional videos published to YouTube: a) http://www.youtube.com/watch?v=5pdaPYgwABU ; b) http://www.youtube.com/watch?v=L6U7TAOJJkU ; and c) ht tp://www.youtube.com/watch?v=n2qEUmEx5Ok 96. P laintiff, DIAZ, has suffered damages as a result of PAYNE’s tortious interference, but such damages are incalculable and therefore, DIAZ has an inadequate remedy at law. 15 WHEREFORE, Plaintiff, JERMAINE DIAZ, respectfully requests this Court enter a preliminary and permanent injunction in Plaintiff’s favor and against Defendant enjoining Defend a nt from making any further false and defamatory statements in furtherance of Defnednat ’ s tortious interference and alternatively, a judgment awarding Plaintiff damages, and costs, and grant such further relief this Court deems just and proper. C OUNT IX – INJUNCTION FOR P R OTEC TION AGAINST CYBERSTALKING PURSUANT TO FLORIDA STATUTE 784.0485 97. This is a petition for an injunction against cyberstalking pursuant to Florida Statute 784.0485 against Payne. 98. Plaintiff, DIAZ, realleges and incorporates the allegations set forth in paragraphs 1 through 51 as though fully restated herein. 99. Defendant, PAYNE, is a forty - three (43) year old African American male born November 7, 1975. 100. Defendant, PAYNE ’s , height, weig ht, eye color, and hair color is unknown. 101. Defendant, PAYNE, has cyberstalked Plaintiff, DIAZ, by engaging in a course of conduct to communicate, or cause to be communicated, words, images, or language by or through the use of electronic communication by p ublishing numerous false and defamatory videos directed to DIAZ as described in paragraphs 14 through 43 , and paragraph 95 , supra , thereby causing DIAZ substantial emotional distress and serving no legitimate person. 102. Plaintiff, DIAZ, seeks an injunction against cyberstalking against Defendant, PAYNE, which immediately restrains Defendant from committing any acts of cyberstalking, 16 I HAVE READ EVERY STATEMENT MADE IN THIS PETITON AND EACH STATEMENT IS TRUE AND CORRECT. I UNDERSTAND THAT THE STATEMENTS MADE IN THIS PETITION ARE BEING MADE UNDER THE PENALTY OF PERJURY, PUNISHABLE AS PROVIDED IN SECTION 837.02, FLORIDA STATUTES. Jermaine Carlos Diaz WHEREFORE, Plaintiff, JERMAINE DIAZ, respectfully requests this Court enter a n injunction against Defendant enjoin ing Defendant from cyberstalking pursuant to Chapter 784, Florida Statutes, and grant such further relief this Court deems just and proper. DE MAND FOR JURY TRIAL Plaintiff, JERMAINE DIAZ, demands a jury trial for all issues so triable herein. RESERVATION OF RIGHT TO AMEND Plaintiff reserves his right to amend this Complaint to add claims, including, but not limited to, claims for pun itive damages against Defendant , pursuant to Chapter 768, Florida Statutes. Respectfully submitted this 28th day of June, 2019. /s/ Eric P. LaRue II Eric P. LaRue II, Esquire Florida Bar No.: 97995 The LaRue Firm, PLLC 501 S. New York Avenue Suite 230 Winter Park, FL 32789 Phone: 407 - 455 - 4779 eric@thelaruefirm.com cindy@thelaruefirm.com Counsel for Plaintiff