TEBO’S REPLY BRIEF, NOT EDITED…

IN THE UNITED STATES COURT OF APPEALS

FOR THE ELEVENTH CIRCUIT

CASE NO. 18-13819-AA

STACY TEBO,

Appellant,

v.

CITY OF DEBARY, FLORIDA, and

LEO DANIEL PARROTT, in his Official

and Individual capacities,

Appellees.

ON APPEAL FROM

THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF FLORIDA

ORLANDO DIVISION

CASE NO. 6:16-cv-01599-31-DCI

REPLY BRIEF OF APPELLANT STACY TEBO

Martha Ann Chapman, Florida Bar No. 4464

MARTHA A. CHAPMAN, P.A.

1219 E. Livingston Street

Orlando, Florida 32803

407-896-4835

Counsel for Appellant Stacy Tebo

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CERTIFICATE OF INTERESTED PERSONS AND

CORPORATE DISCLOSURE STATEMENT

Pursuant to FRAP 26.1 and Eleventh Circuit Rule 26.1, the undersigned

counsel of record verifies that those persons or entities listed below have or may

have an interest in the outcome of this case:

Bell & Roper, P.A. – Counsel for Appellees

Bowling, Michael Harrison – Counsel for Appellees

Chapman, Martha A. – Counsel for Appellant

City of DeBary – Appellee / Defendant below

Irick, Daniel C. – Magistrate Judge, United District Court

Martha A. Chapman, P.A. – Counsel for Appellant

Parrott, Leo Daniel – Appellee / Defendant below

Presnell, Gregory A. – Judge, United States District Court

Tebo, Stacy – Appellant / Plaintiff below

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TABLE OF CONTENTS

Page

CERTIFICATE OF INTERESTED PERSONS AND CORPORATE

DISCLOSURE STATEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-1

TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i

TABLE OF CITATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii

ARGUMENT AND CITATIONS OF AUTHORITY . . . . . . . . . . . . . . . . . . . . . 1

  1. The District Court Erred in Dismissing Tebo’s Sex

Discrimination Claims . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

  1. The District Court Erred in Dismissing Tebo’s

Retaliation Claims . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

III. Summary Judgment on Tebo’s Section 1983 Claims Should Be

Reversed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

CERTIFICATE OF COMPLIANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

CERTIFICATE OF SERVICE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

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TABLE OF CITATIONS

CASES

Bass v. Bd. County Comm’rs, 256 F.3d 1095 (11th Cir. 2001) . . . . . . . . . . . . . . . . 3

Brown v. City of Huntsville, Ala., 608 F.3d 724 (11th Cir. 2010) . . . . . . . . . . . . 13

EEOC v. Crown Zellerbach Corp., 720 F.2d 1008 (9th Cir.1983) . . . . . . . . . . . . 8

Goldsmith v. Bagby Elevator Co., 513 F.3d 1261 (11th Cir.2008) . . . . . . . . . 2, 12

Holifield v. Reno, 115 F.3d 1555 (11th Cir.1997) . . . . . . . . . . . . . . . . . . . . . . . . . 2

Holland v. Gee, 677 F.3d 1047 (11th Cir. 2012) . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Hurlbert v. St. Mary’s Health Care Sys., Inc., 439 F.3d 1286 (11th Cir. 2006) . . . 3

Kragor v. Takeda Pharm. Am., Inc., 702 F.3d 1304 (11th Cir.2012) . . . . . . . . . . 4

Llampallas v. Mini-Circuits, Lab., Inc., 163 F.3d 1236 (11th Cir. 1998) . . . . . . . 9

Ortiz v. Werner Enterprises, Inc., 834 F. 3d 760 (7th Cir. 2016) . . . . . . . . . . . . . . 3

Rollins v. State of Fla. Dept. of Law Enf, 868 F. 2d 397 (11th Cir. 1989) . . . . 8, 11

Smith v. Lockheed Martin Corp., 644 F. 3d 1321 (11th Cir. 2011) . . . . . . . . . . . . . 2

STATUTES, RULES AND REGULATIONS

42 U.S.C. § 1983 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12, 13

Fed.R.Evid. 404(b) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

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  1. THE DISTRICT COURT ERRED IN DISMISSING TEBO’S SEX

DISCRIMINATION CLAIMS

The decision to terminate Tebo was not just tainted with the discriminatory

and retaliatory animus of a biased decisionmaker. Immediately after City Manager

Parrott became aware that Tebo sent a letter to the EEOC complaining that Parrott

had engaged in sexually discriminatory conduct, Parrott zealously engaged in a

campaign to find and even manufacture bases to support terminating Tebo’s

employment. Having been accused of sex discrimination both by Tebo and the

Assistant City Manager Blissett, Parrott was personally motivated to end Tebo’s

employment – just as he had done just days earlier with the Assistant City

Manager, immediately after he became aware that she filed her informal complaint

to the EEOC. It is undisputed that Parrott alone was the decisionmaker and a jury

could reasonably infer that Parrott, the biased decisionmaker, took the opportunity

to act on his bias.

A jury could reasonably conclude that each of the purported reasons Parrott

claims as the bases for his decision to terminate Tebo’s employment was imbued

with his discriminatory or retaliatory motive. Parrott’s layoff of the female

Assistant City Manager immediately after she filed a charge of sex discrimination

is relevant to the inquiry of Parrott’s discriminatory or retaliatory motive in

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terminating Tebo’s employment. Other acts of discrimination from around the

same time can be probative of discriminatory intent. Goldsmith v. Bagby Elevator

Co., 513 F.3d 1261, 1286 (11th Cir.2008) (finding evidence of other acts of

discrimination by the same decisionmaker against other employees in the plaintiff’s

protected group to be admissible under Fed.R.Evid. 404(b) because that evidence is

probative of the decisionmaker’s discriminatory intent) and Smith v. Lockheed

Martin Corp., 644 F. 3d 1321, 1341 (11th Cir. 2011). Accordingly, those facts

support a reasonable conclusion that Parrott’s decision to terminate Tebo’s

employment was an intentionally discriminatory or retaliatory act.

“[T]he plaintiff will always survive summary judgment if [s]he presents

circumstantial evidence that creates a triable issue concerning the employer’s

discriminatory intent.” Smith v. Lockheed, 644 F. 3d at 1328, citing Holifield v.

Reno, 115 F.3d 1555, 1562 (11th Cir.1997). A plaintiff must show that the

evidence, “when viewed as a whole, `yields the reasonable inference that the

employer engaged in the alleged discrimination.'” Holland v. Gee, 677 F.3d 1047,

1056 (11th Cir. 2012).1 /

1/This Circuit has also applied the convincing mosaic as another approach to

determine if sufficient evidence exists to show discriminatory or retaliatory motive

of an employer. Interestingly, the Seventh Circuit, where this approach began, has

retreated from it as not being a separate theory of proof, and now applies a more

simple statement that “All evidence should be considered together to understand

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In addition to the termination of employment of Blissett, Parrott’s

discriminatory intent can be shown through how he treated Tebo after learning she

had sent a letter to the EEOC complaining about his sexually discriminatory

conduct. Within days, he took away one of her major job duties – responding to

public records requests – and gave it to a male who did not meet even the basic

training required to fulfill those responsibilities and in violation of the City’s own

policies. (Doc 35-5 – Pg 2). When an employee who is unqualified by the

employer’s own criteria is chosen over a qualified employee, an inference of

discrimination is supported and contributes to a showing of pretext. Bass v. Bd.

County Comm’rs, 256 F.3d 1095, 1108 (11th Cir. 2001) (a failure to promote case).

See also, Hurlbert v. St. Mary’s Health Care System, Inc., 439 F.3d 1286, 1299

(11th Cir. 2006) (“An employer’s deviation from its own standard procedures may

serve as evidence of pretext.” ). Similarly here, the transfer of Tebo’s public

records duties to a lesser qualified male can raise an inference of discrimination

and pretext. In the email to Tebo informing her of the removal of these duties,

Parrott specifically cited that this decision was made because she and Blissett had

the pattern it reveals.” Ortiz v. Werner Enterprises, Inc., 834 F. 3d 760, 765 (7th

Cir. 2016). While not invoking the words “convincing mosaic” before the district

court, Tebo did argue that, viewing the evidence as a whole, a jury could

reasonably conclude that Tebo was terminated from her employment due to her

gender or in retaliation for her protected act. She did not waive the issue.

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filed charges of discrimination with the EEOC. (Doc 35-5 – Pg 1).

The City argues that Tebo must disprove all of the reasons stated for Parrott

for her termination and that Tebo failed to do so. (Brief pp 21-22) However, it

was the City in its summary judgment motion to the district court that

characterized the reasons for discharge as “In general terms, Tebo was fired as a

result of a number of incidents of insubordination and acts of disloyalty.” Doc 29 –

  1. Contrary to the City’s assertion now that these incidents are not “so interwound

that evidence of pretext as to one ground undermines all other articulated reasons”

(City Brief 22), Tebo has articulated why each reason is pretextual and the City’s

response to each is essentially that it does not matter if Tebo has a different set of

facts, all that matters is whether Parrott “believed” the reasons he states are true.

This is absurd, in light of Parrott’s position as the biased decisonmaker. See,

Kragor v. Takeda Pharm. Am., Inc., 702 F.3d 1304, 1307 (11th Cir.2012) (“[A]

contradiction of the employer’s proffered reason for the termination of an employee

is sometimes enough, when combined with other evidence, to allow a jury to find

that the firing was the result of unlawful discrimination.”).

To the extent that each of the reasons given by Parrott for Tebo’s discharge

need to be further addressed individually, when Tebo had trouble responding to a

citizen’s Public Records request due to the volume of the records sought, Parrott

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started an investigation into how she handled it and falsely accused her of

intentionally not forwarding to him all of her responses and to wrongly claim she

used an unauthorized method to send the documents to the citizen. Parrott failed to

retain the documents he purports supported his allegations against Tebo. The City

claims it does not matter if Parrott was factually wrong about whether Tebo sent

him everything she sent the citizen; all that matters, according to the City, is

whether he “honestly believed” that Tebo failed to do what he told her to do.

[City’s Brief, p. 22] Tebo testified that she did indeed provide Parrott with all of

what she sent to the citizen. A jury could infer from the missing records that they

would not have supported the City’s contention that Tebo failed to provide all of

the records to Parrott, or they would have been retained. Viewed in the light most

favorable to Tebo, evidence not only of Parrott’s bias against women, but also that

his bias motivated his decision to terminate Tebo’s employment when she

complained to the EEOC regarding his conduct. This evidence is sufficient to tie

generalized discriminatory behavior to the specific employment decision at issue.

The City also gravely mischaracterizes Tebo’s testimony regarding her

complaints about Parrott to City Council members when it states “she nonetheless

continued to complain to City Council members about his performance as City

Manager” after Parrott told her not to in November of 2014 and that “[i]n any

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event, by her own testimony, she continued to complain about Parrott to at least

one Council member into May of 2014.” (Response Brief – Pgs. 4 & 5). May of

2014 is about six months prior to the warning so it clearly cannot be held against

Tebo as a violation of that warning – no matter what Parrott claims to believe. 2/

The City has argued that the temporal proximity of Tebo’s EEOC complaint

is overcome by “intervening” reasons for discharge. However, the list of reasons

given by Parrott for Tebo’s termination, and the subsequent additions to the list,

also show discriminatory and retaliatory intent. The sheer number of reasons

given and the details involved show he was focused on finding as many reasons as

possible to try to justify terminating Tebo’s employment. Parrott included a

number of reasons which are from prior timeframes that preceded favorable

employment reviews. Some of the reasons cited involve issues related to this

dissatisfaction with her prior involvement in other female employees’

2/The deposition testimony immediately following the reference cited by the

City on p. 4 explicitly denies that accusation and indeed points out that she had

spoken to them for about six months prior to receiving the warning:

Q And even after that conversation, you continued to complain to city

council members about Dan Parrott?

  • · · A No. Actually, I had not even spoken to Chris Carson about anything like

that since May earlier that year

Doc. 29.4 – p. 22, line 25, to p. 23, line 3.

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complaints of sex discrimination. He included “intervening” reasons that occurred

after she sent her EEOC letter complaining of his sexually discriminatory conduct,

one of which involved an attempt to document his claim that she did not provide

him with all of the documents she had provided a citizen – but he failed to maintain

the documentation that purportedly supported this charge. In general, the City has

referred to all of the reasons amounting to Tebo being discharged for being

“disloyal” to Parrott. However, a jury could reasonably conclude that the ultimate

“disloyal” act had been Tebo’s EEOC letter of complaint and that from that

moment forward, Parrott was single focused on developing rationale to justify his

termination of Tebo’s employment. A jury could find his list of reasons suspect

and mere pretext for discrimination and in retaliation.

The City argues that Tebo cannot show that Parrott did not “honestly

believe” each of the reasons he has cited. However, when the decisionmaker is the

same person who is accused of sexual discrimination, the bias of the decisionmaker

cannot be overcome by his simply claiming he believed other things to be true. To

allow persons accused of discrimination to terminate employees who file a charge

of discrimination as disloyal would eviscerate any discrimination claim. Courts

have recognized that “[a]lmost every form of opposition to an unlawful

employment practice is in some sense disloyal to the employer, since it entails a

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disagreemen t with the employer’s views and … policies,” EEOC v. Crown

Zellerbach Corp., 720 F.2d 1008, 1014 (9th Cir.1983), but have also consistently

held that an employee’s behavior may warrant Title VII protection when it can be

considered intemperate or even disloyal, so long as it is not disruptive and

inappropriate. Rollins v. State of Fla. Dept. of Law Enforcement, 868 F. 2d 397,

401 (11th Cir. 1989). Tebo did not act in a disruptive or inappropriate manner in

faxing her complaint to the EEOC or in sending a copy to Parrott. She did not hold

a press conference or call untoward attention to her having complained about

Parrott’s sexually discriminatory conduct. A jury could reasonably conclude that

Parrott took a personal affront to being accused of discriminatory conduct and that

Parrott, a biased decisionmaker, looked for reasons to fire Tebo and would claim to

“believe” anything so long as it would accomplish his goal of getting rid of her. A

jury could reasonably conclude that Parrott was motivated by discrimination and

retaliation, that his articulated reasons are not worthy of belief, and that they are

simply pretext for discrimination and retaliation.

A jury could reasonably find that Tebo was fired as a result of discrimination

on account of her gender. The fact that Parrott – the person with the discriminatory

animus – is the decisionmaker for the tangible employment action (termination of

Tebo’s employment) gives rise to an inference that discriminatory animus

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motivated the action. See, Llampallas v. Mini-Circuits, Lab., Inc., 163 F.3d 1236,

1247 (11th Cir. 1998)3/ Tebo has provided sufficient evidence that sex

discrimination motivated her termination from employment and the Court’s

summary judgment on this claim should be reversed.

  1. THE DISTRICT COURT ERRED IN DISMISSING TEBO’S

RETALIATION CLAIMS

As discussed above on the sex discrimination claim, Defendant primarily

argues that Tebo cannot contest the reasonable belief of Parrott in the various

reasons he listed to support her termination from her employment with the City.

(City’s Brief – Pg 26). Tebo re-asserts that a jury should be allowed to determine if

Parrott’s motivation was retaliatory: her termination was not done by some

objective decisionmaker or someone unaware of her complaint to the EEOC but

instead was done by the very person whom she accused of discrimination to the

3/ The Court held:

We assume that the harasser, because she harbors a discriminatory

animus towards the plaintiff, could not act as an objective,

non-discriminatory decisionmaker with respect to the plaintiff. Thus,

any time the harasser makes a tangible employment decision that

adversely affects the plaintiff, an inference arises that there is a causal

link between the harasser’s discriminatory animus and the

employment decision. A Title VII plaintiff, therefore, may establish

her entire case simply by showing that she was sexually harassed by a

fellow employee, and that the harasser took a tangible employment

action against her.

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EEOC. A jury could reasonably conclude Parrott was clearly motivated to believe

(or say he believed) anything negative about Tebo, a person he had determined

could no longer be trusted, once she filed her EEOC complaint about him.

Unlike the prior relationship between them prior to her EEOC letter, Parrott

began to document and write up everything he could find to create issues, in an

apparent effort to get her to resign, including removing her from her job public

records duties and removing her from her position as City Clerk and placing

himself in that position, prior to terminating her employment. A jury could

reasonably conclude that his actions would not have occurred but for her protected

conduct of complaining to the EEOC. Indeed, in the email he sent her taking away

her public record job duties, he explicitly says he was doing so because she had

filed an EEOC Charge of Discrimination. While not the ultimate adverse

employment action of termination, it was the beginning of the chain of events

leading to her termination, and is probative evidence for a jury to consider in the

retaliation claim.

Tebo was not, as City contends, a disloyal employee. But her loyalty was to

her employer, the City, not to the City Manager whose sexually discriminatory

conduct she had reported to the EEOC (as well as previously to several City ouncil

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members and a former City Council member).4/

The City wrongly argues that Tebo’s letter to the EEOC should not provide a

basis for her retaliation claim, as it was only an informal complaint to the EEOC,

not a true charge of discrimination. (City’s Brief – Pg 24) It is well established

that the protection afforded by the anti-retaliation provision extends not only to

individuals who have filed formal complaints, but also to those who informally

voice complaints to their superiors or who use internal grievance procedures.

Rollins, 868 F.2d at 400. Tebo’s informal complaint to the EEOC is sufficient

evidence to demonstrate that she engaged in protected activity.

Tebo has also demonstrated the causal link between her informal complaint

to the EEOC and her termination from employment. “We construe the causal link

element broadly so that `a plaintiff merely has to prove that the protected activity

and the negative employment action are not completely unrelated.'” Goldsmith v.

Bagby Elevator Co., 513 F.3d 1261, 1278 (11th Cir.2008) (quoting Olmsted v.

4/City argues that Tebo should not have spoken to City Council members

about Parrott’s sexually discriminatory conduct and language, discounting Tebo’s

explanation that there was no internal mechanism to complain about the City

Manager, and stating instead that she should have gone to the EEOC sooner,

despite any claimed fear of retaliation. (City’s Brief – Pg.4 & n.4) Contrary to

City’s assertion that she had “no evidence to justify such fear” (City’s Brief – n.4),

both the layoff of the Assistant City Manager immediately after she filed a Charge

of Discrimination and Tebo’s own termination of employment show that such fears

were well-founded.

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Taco Bell Corp., 141 F.3d 1457, 1460 (11th Cir.1998)). Particularly in light of that

standard, a jury reasonably could find that the City retaliated against Tebo and the

summary judgment on her retaliation claim should be reversed.

III. SUMMARY JUDGMENT ON TEBO’S SECTION 1983 CLAIMS

SHOULD BE REVERSED

If this Court reverses summary judgment on either Tebo’s sex discrimination

or the retaliation claims, then it should also reverse summary judgment on Tebo’s

Section 1983 claim against Parrott, since the district court dismissed the Section

1983 claim based on dismissing Tebo’s Title VII claims (Doc 49 – Pg 25). Parrott

argues that qualified immunity also provides another basis for this Court to justify

summary judgment in favor of Parrott. (City’s Brief – Pg 30). Under the City’s

argument, if Parrott can show he terminated Tebo for mixed motivations – lack of

loyalty plus either or both discrimination or retaliation, that he would be entitled to

qualified immunity. (Id. – Pg. 31). However, Parrott’s framing of the basis for

firing Tebo for her supposed lack of loyalty to him ignores how intertwined that

“lack of loyalty” is with the essence of the case: Parrott identifies Tebo’s lack of

loyalty as her having told City Council members about his sexist comments and

refusal to hire a woman as the financial administrator for the City.5/ Whether

5/The timing of these actions by Tebo pre-date her termination by nearly a

year and that fact could also lead a jury to conclude Parrott’s reasons lack merit.

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Parrott can meet his burden of proving that he would have fired Tebo in the

absence of both discrimination and retaliation is a credibility determination for the

jury.

Further, to establish § 1983 liability, the causal connection between a

government actor’s acts or omissions and the alleged constitutional violation may

be established by proving that the official was personally involved in the acts that

resulted in the constitutional deprivation. Brown v. City of Huntsville, Ala., 608

F.3d 724, 737 (11th Cir. 2010). Parrott was personally involved in the decision to

terminate Tebo’s employment so the causal connection is established.

No qualified immunity should exist for Parrot and the motion for summary

judgment on that issue should be denied and the summary judgment on Tebo’s

Section 1983 claim should be reversed.

CONCLUSION

Tebo’s claims should be reinstated and she should be allowed to go to a jury

on all claims.

Respectfully Submitted,

/s/ Martha Ann Chapman

Florida Bar No. 4464

marty@martychapmanlaw.net

MARTHA A. CHAPMAN, P.A.

1219 E. Livingston Street

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Orlando, Florida 32803

Telephone: 407-896-4835

Fax: 407-574-7912

Counsel for Appellant Stacy Tebo

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CERTIFICATE OF COMPLIANCE WITH TYPE-VOLUME LIMIT,

TYPEFACE REQUIREMENTS, AND TYPE STYLE REQUIREMENTS

Counsel for Appellant certifies as follows:

  1. Type-Volume

This Reply Brief complies with the word limit of FRAP because, excluding the

parts of the document exempted by FRAP 32(f), this document contains 3,182

words.

  1. Typeface and Type-Style

This document complies with the typeface requirements of FRAP 32(a)(5) and the

type-style requirements of FRAP 32(a)(6).

Respectfully Submitted,

/s/ Martha Ann Chapman

Florida Bar No. 4464

marty@martychapmanlaw.net

MARTHA A. CHAPMAN, P.A.

1219 E. Livingston Street

Orlando, Florida 32803

Telephone: 407-896-4835

Fax: 407-574-7912

Counsel for Appellant Stacy Tebo

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CERTIFICATE OF SERVICE

This is to certify that I have, on this 21st day of February, 2019, served a

copy of the Reply Brief of Appellant Stacy Tebo upon the parties listed below by

depositing same in the United States mail, with sufficient postage thereon,

addressed to:

Michael H. Bowling

Bell & Roper, P.A.

2707 E. Jefferson Street

Orlando, Florida 32803-6116

Counsel for Appellees City of DeBary and Parrott

/s/ Martha Ann Chapman

Florida Bar No. 4464

marty@martychapmanlaw.net

MARTHA A. CHAPMAN, P.A.

1219 E. Livingston Street

Orlando, Florida 32803

Telephone: 407-896-4835

Fax: 407-574-7912

Counsel for Appellant Stacy Tebo

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