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distributing any political advertisements in support of the fee paid for with public funds,and ordering Defendants to remove all political advertisements in support of the fee paidfor with pubric funds from the university of Florida campus.

B' A declaratory judgment holding that Defendants unlawfully expended public firnds to payfor political advertisements in support of the proposed student fee, and requiringDefendants to report to the students of the university of Florida the amount of fundswrongfuily expended, including time spent by employees during working hourspromoting the student fee.

c. An order that Defendants pay praintiffs, costs related to this action.Accelerated Hearing

Due to the immanent nature of the election (February 23 and24,2Ll|),plaintiffs requestan immediate hearing on this claim.

Jonathan J. Ossip I30101501 Murphree HallGainesvilie ,FL32612561-289-1577Plaintiff

. 'r i' ,l't':.1.!.,'. i ) I'; t, ^.L.-: i i. vt "-t4 l\" vLy'" LKMarielGraceRffi1190603 Beaty Towers WestGainesville,FL 32612954-803-8301Plaintiff

11020204 Beaty Towers WestGainesville,FL 32612954-534-4270Plaintiff

1202 SW lstAvenue, UnitFGainesville,FL 32601352-682-0004Plaintiff

Graham Clark i-tMic

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Graham CiarkUniversity of Florida Student

(4) Because the election is less t}ran one week away, time is of the essence, soadditionallS please confum to Mr. Jonathan Ossip that the above has been done.Mr. Ossip has a smattphone and therefore can receive calls and emails anywhere.As such, please contact him with this confirmation by phone at 567-289-1577and by email at ossipj@gmail.com.Failure to comply with this request may result in us seeking rmmediate injunctive relief in acourt of competent jutisdiction.Sincerely yorus,

tfl cvuuut ft"clovMadel Grace RectorUniversity of Florida Student

#h.hh^,-

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14. The political advertisements paid for by the Board of Managers with public funds are notlimited to factual information, and therefore are subject to $106.113 Fla. Statutes(Expenditures by local govemments). Section 106.1 13 Fla. Statutes is attached to thisComplaint as Exhibit B.

15. On February 18, 2010, Plaintiffs rendered to Defendant Telles-Irvin, along with otherUniversity of Florida offrcials, a letter outlining $106.113 Fla. Statutes and requesting theUniversity to cease and desist in the expenditure of public funds on politicaladvertisements, to cease and desist in the distribution of political advertisements paid forwith public funds, and to remove all politicat advertisements paid for with public fundsfrom the University of Florida campus, and to respond to such letter with a confirmationof the above-listed actions. This letter is attached to this Complaint as Exhibit C.

16. Defendant Telles-Irvin did not respond to the above-mentioned letter.1.7. OnFebruary Ig,z}I},political advertisements paid for with public funds continued to be

distributed and displayed on the University of Florida campus.18. Defendants have unlawfully converted public funds into campaign funds used to pay for

political advertisements in support of the proposed student fee.19. Defendants'expenditures of public funds to advertise the proposed student fee, and the

dispiay and distribution of these political advertisements, are abusive and unlawful.Relief Sought

WHEREFORE, based upon all the paragraphs stated above, Plaintiffs demand judgmentagainst Defendants as follows:

A. An Order enjoining Defendants from expending any public funds to pay for politicaladvertisements in support of the proposed student fee, enjoining Defendants from

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5.

6.

Defendant J. Bernard Machen is the President of the University of Florida and Agent ofthe University of Florida Board of Trustees.Defendant Patricia Telles-Irvin is the Vice President for Student Affairs of the Universityof Florida.

7. Defendant J. Wayne Reitz Union Board of Managers (hereinafter referred to as "Board ofManagers") is the governing board of the J. Wayne Reitz Union, a subdivision of theDivision of StudentAffairs of the University of Florida, as outlined in University ofFlorida Regulation 6C l -4.005.

FACTS8. The Student Senate of the University of Florida has placed on the ballot for the Spring

2010 Student Govemment election two questions regarding the creation of a new studentfee to fund repairs, renovations, and expansions to the J. Wayne Reitz Union.

9. The elections a.re set to be held on February 23 ard24,2010.10. The Board of Managers, or an agent thereof, has appropriated public frrnds of the

University of Florida in order to print political advertisements regarding the student feeballot questions, converting these funds to campaign funds.

11. These political advertisements instruct electors to vote "Yes and Yes" on the questionsregarding the Reitz Union student fee in the February 23 and24,2010 elections. Anexample of such is attached to this Complaint as ExhibitA.

1,2. Board of Managers is a proponent of the creation of the student fee.13. Board of Managers has converted and spent public funds to propagandize the proponents'

slogan, "Renew Your Reitz."

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JonathanJ. Ossip, Mariel Grace Rector,Graham Clark and Michael Morales,Plaintiffs,vs.J. Bernard Machen, as president of theUniversity of Florida and Agent of theUniversity of Florida Boardlf Trustees,Patricia Telles-Irvin, as Vice president forStudentAffairs of the University of Floridaand the J. Wayne Reitz Union Board ofManagers, Defendants.

IN THE CIRCUIT COURTOF TIIE EIGHTHJUDICIAL CIRCUIT OFF'LORDIA, IN AND FORALACUHA COUNTY

Case No.: (, /'* 1." ( 4 --,1- .: 3Div.: --7-/

COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEFThis is a civil action and' pursuant to chapter 86 Florida Statutes, declaratory relief, This

court has -jurisdiction pursuant to Article v, $5 Florida constitution and 526.012F1a. statutes.PARTIES

1' PlaintiffJonathan J' ossip is a student at the university of Florida and a resident andtaxpayer of Alachua County, Florida.

2' PlaintiffMariel Grace Rector is a student at the university of Florida and a resident andtaxpayer of Aiachua County, Florida.

3' PlaintiffGraham clark is a student at the university of Florida and a resident andtaxpayer of Alachua County, Florida.

4' PlaintiffMichael Morales is a student at the university of Florida and a resident andtaxpay er of Alachua County, Florida.