What is the difference between the U,S. Embassy in the Middle East and a car on the way home from Jasper if public business is discussed?. Nothing the law says. If Spencer and Tonja want to have a discussion about Town Business. to wit discussion a citizen’s comments at a meeting of the School Board the only thing stopping them is the Law that the Florida News Papers and the First Amendment Foundation.; But what the hell, it is only two minority Council members who think the law doesn’t apply to them because they are minorities. Can’t read a lick but are certain of a law that they have no inkling of.

FACTUAL BACKGROUND 15. On May 22, 2019, Governor DeSantis formally announced he would be leading a delegation of over 90 people ( consisting of, among others, government officials, business leaders, and academics) on a “business development” trip to Israel. Attorney General Moody, Commissioner Fried, and Mr. Patronis were named as members of the delegation. A true and correct copy of the Governor’s press release announcing the trip is attached as Exhibit A. 16. On May 23, 2019, Governor DeSantis released an itinerary for the trip. That itinerary included a “Ceremonial Meeting of the Florida Cabinet,” which is scheduled to occur on Wednesday May 29, 2019. A true and correct copy of the released itinerary is attached as Exhibit B. 17. The web homepage for the Cabinet ( provides additional detail about the Meeting. It states that the Meeting will occur May 29, 2019 at 8:30 a.m. (EDT) and be held at the U.S. Embassy in Jerusalem. It also states that the meeting will be “livestreamed” in the “Cabinet Meeting Room” at the Capitol Building. A true and correct copy of the Cabinet’s homepage is attached as Exhibit C. 18. The agenda for the Meeting has also been posted to the Cabinet’s website. Among other agenda items, the Cabinet will: (1) entertain a “Resolution” regarding the “IsraeliFlorida relationship”; (2) consider a “Presentation” titled “Victims of Terror”; (3) consider a “Presentation” titled “Water Quality”; and ( 4) consider a “Presentation” titled “Emergency Management”. A true and correct copy of the released Meeting agenda is attached as Exhibit D. 19. Previous public meetings of the Cabinet m which “resolutions” and “presentations” have been considered were public meetings and held m Tallahassee, Leon
County, Florida. True and correct copies of Cabinet meeting agendas from March 12, 20 I 9 and April 2, 2019 are attached as Composite Exhibit E.3 20. In justifying a Cabinet meeting occurring over 6,000 miles away from the citizens of Florida, Helen Ferre, spokesperson for Governor DeSantis, has stated that “This meeting of Florida cabinet members is not considering board or agency business; it will be an information gathering meeting where they will listen to Israeli best practices on issues of mutual interest for Florida and Israel, such as water resources and security.” A true and correct copy of a news article where Ms. Ferre’s statement appears is attached as Exhibit F. 21. Per the Meeting agenda, among other things, the Cabinet will take official action via resolution with regard to defining the nature of the relationship between Israel and Florida. The Cabinet will also consider matters related to environmental water quality and terrorism/security. Both subjects of direct import to the citizens of Florida and concern issues that could foreseeably come before the Cabinet upon which action could be taken. 22. Governor DeSantis has made clear these agenda items relate to official business, noting in statements to the media that partnerships between Israel and Florida relating to clean water and cybersecurity. Other government officials, including Florida’s Director of emergency management, Jared Moskowitz, have stated that officials are engaging with Israeli officials on emergency response procedures. A true and correct copy of a news article detailing these statements is attached as Exhibit G. 23. Fact-finding or informational meetings attended by members of a public body constitute meetings under the Sunshine Law. The right of direct public access attaches to such meetings. 3 Archived video of these public meetings is available at the Cabinet’s website and can be found at: https:/ / and 6
24. The Meeting will occur in Jerusalem, Israel, outside the jurisdictional limits of Florida. 25. Jerusalem is over 6,000 miles from Florida. 26. Among others, Florida citizens who do not maintain a valid travel passport cannot attend the Meeting. 27. Among others, Florida citizens of Palestinian, Arab, and/or Muslim descent would confront travel/access issues that significantly frustrate access to the Meeting.4 28. The Meeting will be held in the U.S. Embassy in Jerusalem, a secure facility for which the public has no general right of access. 29. Upon information and belief, due to security concerns, general members of the public will not be permitted to attend the Meeting in person. 30. Upon information and belief, due to security concerns only those individuals specifically authorized to attend the Meeting will be allowed to do so. 31. Upon information and belief, due to security concerns, members of the news media who are traveling with and reporting on the delegation will not be able to use laptops or cellular phones while attending the Meeting. A true and correct copy of a news article detailing media reporting restrictions is attached as Exhibit H. 32. Upon information and belief, only the Florida Channel will be permitted to live stream the Meeting. Live streaming the meeting from a single news source is not a legally pe1missible alternative to allowing the public direct access to the Meeting.
4 On May 23, 2019, the American-Arab Anti-Discrimination Committee wrote Governor DeSantis expressing these, and other concerns, related to the Meeting. A copy of that letter can be found at: 7
33. The Meeting is a public meeting subject to the requirements of Article I, Section 24 of the Florida Constitution and the Sunshine Law. By intending to proceed with the Meeting, the Cabinet and its co-Defendant members are willfully violating the law. 34. The public is being willfully denied their constitutional and statutory right to attend the Meeting, offer public comment, and otherwise monitor the official actions of the Cabinet.


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