IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT,

IN AND FOR LAKE COUNTY, FLORIDA

DON KARL JURAVIN,

Case No.: 35.2017-DR-001326-AXXX-XX

Petitioner,

and

RANDALL GREENE,
-i iri
~i o o

Respondent.

A M E N D E D P E T I T I O N F O R I N J U N C T I O N F O R P R O T E C T I O N A G A I N S T S TA L K I N G

COMES NOW, the Petitioner, DON KARL JURAVIN, by and through the undersigned

counsel, files with this Honorable Court this Amended 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:
Summary

As detailed below. Respondent RANDALL F. GREENE has taken a dispute between

Petitioner, a property owner, and the developer of his residential community, DCS Real Estate
Investments, LLC ("DCS"), and resorted to terrorizing Petitioner and his family. Agents of DCS,
including Dwight Schar, a minority owner of the Washington Redskins, Richard Arrighi, a
disbarred attorney and convicted felon, and Respondent, have devised a systematic campaign of
bullying Petitioner, which Respondent has executed. This campaign includes "cyberstalking" and
physical vandalism designed to harass and intimidate Petitioner. Respondent has sent numerous
harassing text messages to Petitioner, launched an online, defamatory "smear campaign" aimed
at Petitioner, utilized the security force of Petitioner's subdivision to harass and intimidate him,
and has either directly participated in, or ordered others to vandalize Petitioner's property.

Section I. Petitioner

1. Petitioner, Don Karl Juravin, currently resides at the following address: 15118 Pendio

Drive, Montverde, Florida 34756.

1
 2. Mr. Juravin's attorney in this matter is the undersigned counsel, Andrew C. Hill with the
mailing address of 6136 Cypress Hill Road, Winter Garden, Florida 34787 and the
telephone number 813-410-1648.

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, "bumers."

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:Mak

Date of Birth: 11/18/1965

Height: O:

Weight: unknown

Eye Color: unknown

Hair Color: Dark with Grav at the Temples

No known distinguishing marks and/or scars.

Vehicle: 2005 Elise Lotus Color: Grey Tag Number: C0PB8T
5. Other names Respondent has used: Terry Wainwright of Monteverde, Florida with the
e-mail addrress of [email protected].

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

2
Section III. Case History and Reason For Seeking Petition
1. On June 2,2017, Petitioner filed his original petition for injunction and protection against

stalking, which this Court denied, without prejudice^ for failure to include "a short and
plain statement of the ultimate facts showing that the pleader is entitled to relief as
required by Fla. R. Civ. P. 1.10(b).
2. Petitioner has previously attempted, but not received an injunction for protection against

stalking against Respondent in this Court.

3. To the knowledge of Petitioner, Respondent has not received or tried to get an injunction
for protection against stalking against Petitioner in this or any other court.
4. Petitioner and Respondent do not have any other pending or closed court cases between
these two parties.

5. Petitioner is a victim of stalking because Respondent has:

a. Committed stalking;
b. X_ Previously threatened, harassed, stalked, cyberstalked, or physically
abused Petitioner;

c. Threatened to harm Petitioner or family members or individuals closely

associated with Petitioner;

d. Intentionally injured or killed a family pet;

e. Used, or threatened to use, against Petitioner any weapons such as guns or

knives;
f. A criminal history involving violence or the threat or violence, if known;

g. Another order of protection issued against him or her previously from

another jurisdiction, if known;

h. X Destroyed personal property, including, but not limited to, telephones or

other communication equipment, clothing, or other items belonging to Petitioner.

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

a. Petitioner, Don Karl Juravin, has endured too long the abusive, threatening and

pointless harassment, stalking, and cyberstalking by Respondent Randall Greene, which appears

3
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.

b. 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 intemet posts with the sole purpose of causing damage to Mr. Juravin.'
c. As a result of the conduct of Respondent that is the subject of this petition, Mr.

Juravin, his wife, and their minor daughters live in constant fear of harassment in their home, the

place where they should feel the safest.

d. 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.

e. Bella Collina is a deed restricted community within the Bella Collina Property

Owners Association and shall hereafter be referred to as, "BCPOA."

f. 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.

g. A letter, dated December 19, 2016, from law firm 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").

' It should be noted that the Respondent has engaged in similar tactics with other Bella Collina residents with similar
views as Mr. Juravin. These incidents are recounted in vivid detail in the Complaint in the case CS Business
Systems, et al. v. Schar, et al., Case No: 5:I7-cv-00086-PGB-PRL, filed in the U.S. District Court for the Middle
District of Florida, Ocala Division.

^ Mr. Juravin's published reviews of the Bella Collina community are legally appropriate because of his
constitutional right to express his opinion about a community in which he has had ample opportunity to experience
and form said opinion through his residence in said community. U.S. Const. Amend I.

4
 h. On December 28, 2016, Mr. Juravin sent a text message to a contact he

understood to be Andrew GorrilP, 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").
i. 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")

j. 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, j&om 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")

k. 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

' Andrew Gorill's mobile telephone number is 818-831-7262 and the total number of pertinent texts between this
number and Mr. Juravin is offered in chronological order (See Exhibit "X") in addition to the specific citations to
exhibits.

" The admission of Andrew Gorrill that he conferred with the individual, Randall Greene, whom he describes as his,
"boss," displays that Mr. Greene enjoys a supervisory status of unknown source in relation to Mr. Gorrill and said
conference reveals that Mr. Gorrill acts at Mr. Greene's behest.

5
from the mobile telephone number 561-317-3354^ in which said message listed the identification
of, "Randall F. Greene." (See Exhibit "E").
1. The text message from Randall Greene was an aggressive, personal, and
threatening 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").

m. There were several consistencies between the text messages from Gorrill and

Greene, which is evidence that the "boss" and his employee were working closely together in
responding to Mr. Juravin's legitimate concerns for his family's safety from large automobiles
speeding through the gated community.'
n. 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, this time

demanding that Mr. Juravin cease filing police reports regarding Mr. Randall Greene, who was
described by the letter as the president of BCPOA. This letter failed to set a new deadline for

' At the request of Mr. Juravin, Florida Defense Investigations, conducted an investigation of Randall F. Greene and
found the mobile telephone number 561-317-3354 to be listed to Randall F. Greene. (See Exhibit "F[') the total
number of pertinent texts between this number and Mr. Juravin is offered in chronological order (See Exhibit Y ) in
addition to the specific citations to exhibits.

^ The demand letter from Shutts & Bowen dated December 19, 2016 to Mr. Juravin provided him only until
December 23, 2016 to remove the posts in question with the promise that legal action would follow. Additionally,
said demand letter did not demand, request or mention any restriction of communication between Mr. Juravin and
the various mysterious, undefined entities associated with the community of Bella Collinato remain solely between
retained legal counsel for the parties.
' At the request of Mr. Juravin, Florida Defense Investigations, conducted an investigation of Randall F. Greene and
it was determined that Andrew Gorrill is Mr. Greene's brother-in-law.

6
compliance or even extend the previous deadline listed by the previous demand letter.® (See
Exhibit "G")

o. On January 13, 2017, Priscila Cucutta, an employee 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").

p. 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." ^

q. 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").

® Mr. Juravin found it difficult to consider the letters from Shutts & Bowen to be good faith notices of imminent
legal action when both client and lawyer fail to heed, observe, or be conscious of their own demands, thereby
eviscerating said act of all legitimate purpose leaving only the pretext providing camouflage for the obvious mission
to intimidate and threaten Mr. Juravin.

' The Ryan Law Group letter provides some allowance to communicate with security, but fails to list any
contemplation of a property owner's rights to participate as a part of said, "Association," or the role of the property
management company. Aegis Community Management, and the Aegis Property Manager, David Bumham, in this
restricted communication demand. It is unknown at this time if Mr. Bumham is a family member similar to the
familial relation between Mr. Greene and Mr. Gorrill that has resembled the structure of a mafia family in
organization and tactic.

7
 r. 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 ).
s. 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. Juravin
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").
t. 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").

u. 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").
V. 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")

w. The harassment and stalking was not solely confined to commumcations via

letters and text messages. A series of defamatory 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)

At the request of Mr. Juravin, Florida Defense Investigations, conducted an investigation of Randall F. Greene and
found the mobile telephone number 818-252-8159 to likely be a burner cell number.. (See Exhibit "F')
8
 X. There are numerous similarities between all of the various wntings 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, "C0PB8T." (See Exhibit "F").

y. 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 ).
z. Furthermore, within the past calendar year. Petitioner has had his property

vandalized numerous times, including the following: the destruction of his outdoor pizza oven;

the destruction of many of the property's irrigation sprinklers, destruction of many of the

property's landscaping features; and cutting a hose to the Mr. Juravin's pool, essentially
rendering it unusable. Given the fact that Bella Collina is a "luxury gold residential community"
with twenty-four (24) hour manned security controlling access to the property, the only logical
explanation is that Respondent is behind this vandalism.

" The defamatory online publishings regarding Mr. Juravin are largely anonymous and include self serving
comments from obvious counterfeit identities such as, "Vinny" from Las Vegas or, "Hans," from Germany. (See
Exhibit "N" through Exhibit "V")
9
 aa. The actions taken by Respondent are outside the course and scope of any position
he holds on behalf of the Bella Collina developer, DCS Real Estate Investments, LLC, and/or the

BCPOA.

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;

10
 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
H E A R I N G . I U N D E R S TA N D T H AT I F E I T H E R R E S P O N D E N T O R I F A I L T O
APPEAR AT THE FINAL HEARING, WE WILL BE BOUND BY THE TERMS OF ANY
INJUNCTION OR ORDER ISSUED AT THAT HEARING.

I U N D E R S TA N D T H AT I A M S W E A R I N G O R A F F I R M I N G U N D E R O AT H TO T H E
T R U T H F U L N E S S O F T H E C L A I M S M A D E I N T H I S P E T I T I O N A N D T H AT T H E
P U N I S H M E N T F O R K N O W I N G LY M A K I N G A F A L S E S TAT E M E N T I N C L U D E S
F I N E S A N D / O R I M P R I S O N M E N T.

I H AV E R E A D E V E R Y S TAT E M E N T M A D E I N T H I S P E T I T I O N A N D E A C H
STATEMENT IS TRUE AND CORRECT. I UNDERSTAND THAT THE STATEMENTS
M A D E I N T H I S P E T I T I O N A R E B E I N G M A D E U N D E R P E N A LT Y O F P E R J U R Y,
PUNISHABLE AS PROVIDED IN SECTION 837.02, FLORIDA STATUTES.

(initials)

Signature of Petitioner

11
STATE OF FLORIDA

COUNTY OF Kr\K<^
Dn/^ ! n? A
Sworn to or affirmed and signed before me on /

NOTARY PUBLIC or DEPUTY CLERK

(Print, type, or stamp commissioned name of

notary clerk.)

Personally known

Produced identification

Type of identification produced

12