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Calibri;Calibri; \*Riched20 10.0.22621 **IN THE CIRCUIT COURT OF [YOUR COUNTY], FLORIDA** **CIVIL DIVISION** **CASE NO.: [Your Case Number]** **[YOUR NAME],** Plaintiff, v. **FLORIDA DEPARTMENT OF REVENUE, STATE ATTORNEY [NAME], HEARING OFFICER [NAME], AND OTHER UNKNOWN DEFENDANTS,** Defendants. --- ### **COMPLAINT FOR DAMAGES AND DECLARATORY RELIEF** COMES NOW, the Plaintiff, **[Your Name]**, pro se, and files this Complaint against the **Florida Department of Revenue, the assigned Hearing Officer, the State Attorney, and other unknown defendants**, alleging violations of his constitutional and legal rights, and seeking damages, declaratory relief, and other relief deemed just and proper. In support thereof, Plaintiff states as follows: --- ### **PARTIES AND JURISDICTION** 1. Plaintiff **[Your Name]** is a resident of **[Your County], Florida**. 2. Defendant **Florida Department of Revenue (DOR)** is a state agency responsible for enforcing child support laws. 3. Defendant **[State Attorneys Name]** is an agent of the State of Florida responsible for representing DOR in child support enforcement proceedings. 4. Defendant **[Hearing Officers Name]** is a judicial officer responsible for ruling on child support cases. 5. This Court has jurisdiction pursuant to **Florida Statutes 26.012** and the **Florida Constitution**, as the wrongful acts occurred in the State of Florida. 6. Venue is proper in **[Your County]**, as the events giving rise to this Complaint occurred within this jurisdiction. --- ### **FACTUAL ALLEGATIONS** 7. Plaintiff was **wrongfully incarcerated** for contempt of court due to non-payment of child support **while receiving Temporary Assistance for Needy Families (TANF)**, which prohibits such enforcement actions. 8. After Plaintiff's release, the Florida Department of Revenue (DOR) sent a letter confirming that Plaintiff was **TANF-eligible during the time of incarceration**, proving the enforcement action was unlawful. 9. During a court hearing, the State Attorney reviewed official records and **confirmed that Plaintiff was on TANF**, yet no corrective action was taken to rectify the wrongful imprisonment. 10. Instead, the Hearing Officer **dismissed the evidence** and denied Plaintiffs request to vacate wrongful arrears and purge payments. 11. The court improperly **merged Plaintiffs case** with a previous case despite procedural irregularities, including failure to provide **notice or an opportunity for a DNA test**. 12. The court admitted in open proceedings that it had the **correct mailing address** for Plaintiff but **intentionally sent legal notices to an incorrect address**, resulting in a default judgment and subsequent arrest warrants. 13. As a result of these wrongful actions, Plaintiff suffered **financial loss, emotional distress, unlawful imprisonment, and damage to his credit report**. --- ### **CAUSES OF ACTION** #### **COUNT I FALSE IMPRISONMENT (FLORIDA STATE LAW)** 14. Defendants unlawfully incarcerated Plaintiff despite his **TANF status**, which prohibits such enforcement actions. 15. The wrongful imprisonment resulted from **gross negligence and failure to follow proper legal procedures**. 16. As a direct and proximate result of Defendants conduct, Plaintiff suffered **physical, emotional, and financial harm**. WHEREFORE, Plaintiff seeks **compensatory damages** in the amount of **$[amount]** for wrongful incarceration, emotional distress, and lost wages. --- #### **COUNT II DUE PROCESS VIOLATIONS (14TH AMENDMENT & 42 U.S.C. 1983)** 17. Defendants violated Plaintiffs constitutional right to **due process** by failing to serve him properly and **denying his right to contest paternity**. 18. Defendants knowingly used an **incorrect mailing address**, resulting in an **uncontested default judgment**. 19. Defendants actions constitute **fraudulent process service** and **denial of fundamental fairness** under the U.S. and Florida Constitutions. WHEREFORE, Plaintiff seeks declaratory relief invalidating the judgments, compensatory damages, and punitive damages in the amount of **$[amount]**. --- #### **COUNT III NEGLIGENCE AND GROSS MISCONDUCT** 20. Defendants, acting in their official capacity, failed in their **duty of care** to Plaintiff by refusing to correct acknowledged mistakes. 21. Defendants knowingly allowed **wrongful arrears, wrongful imprisonment, and legal misrepresentation** to persist. 22. Plaintiff suffered **severe financial, emotional, and reputational harm** due to Defendants negligence. WHEREFORE, Plaintiff seeks monetary damages in the amount of **$[amount]** and court-ordered corrective action to amend arrears. --- ### **PRAYER FOR RELIEF** WHEREFORE, Plaintiff respectfully requests that this Court: A. **Declare** that Defendants violated Plaintiffs constitutional and legal rights; B. **Vacate** wrongful arrears and default judgments obtained through improper service; C. **Award** compensatory and punitive damages in the amount of **$[amount]**; D. **Grant** any other relief deemed just and proper by this Court. Respectfully submitted, **[Your Name]** [Your Address] [Your Phone Number] [Your Email] ---