AFFIDAVIT OF LILLIAN TYSINGER

STATE OF FLORIDA

COUNTY OF LEON

BEFORE ME, the undersigned authority, personally appeared, Lillian Tysinger, who,

being by me first duly sworn, deposes and says:

1. My name is Lillian Tysinger, and I am over the age of 18 years.

2. I began working with the Senate Majority Office on November 14, 2016.

3. I was contacted by Rachel Perrin Rogers shortly after Senator Wilton Simpson was

named the Majority Leader.

4. I had never met Ms. Rogers prior to this contact.

5. Ms. Rogers contacted me and expressed that she was excited about working with

me in the future, given that she served as an Aide for Senator Simpson.

6. The following day I received a text message from Rachel Perrin Rogers where she

suggested that we should schedule a lunch appointment where we could become acquainted.

7. I was puzzled by her introduction so I asked Senate Majority Chief of Staff Cheri

Vancura why Senator Simpson's Aide was insisting that we would be working so closely together.

8. Ms. Vancura responded by warning me that Ms. Rogers was intense and she went

on to add that I should be careful about confiding in Ms. Rogers. Ms. Vancura told me specifically

to only tell Ms. Rogers things that I did not mind being repeated and she closed by noting that Ms.

Rogers "doesn't really keep friends."

9. I agreed to meet Ms. Rogers for lunch and we began a friendship that developed in

an oddly fast manner.

10. The Senate Majority Office is located on the third floor of the Senate Office
building and the same day that I went to lunch with Ms. Rogers she began moving her possessions

into that shared office space.

11. Ms. Rogers always portrayed herself as though she was far more important than her

title would have suggested, and it was commonly mentioned around the Capitol that she considered

herself to be the "41 st Senator."

12. Ms. Rogers sent me a text message at one point where she told me "don't mistake

your salary or title for your level of influence. I don't." See text messages attached hereto as

Exhibit "T -1".

13. Ms. Rogers certainly conducted herself in that manner during the time that I worked

with her.

14. For example, she would routinely drink alcoholic shots with the acting Senate

Majority Receptionist, Camille Johnson, during the lunch hour and she would return to the office

after consuming those drinks.

15. Ms. Rogers was very close friends with Ms. Johnson and they would routinely

associate outside of work.

16. In fact, Ms. Johnson temporarily resided with Ms. Rogers at one point, and Ms.

Johnson would routinely perform errands.

17. Ms. Rogers would also drink alcoholic beverages in the office with great regularity.

18. Ms. Rogers would also openly discuss taking "Canadian Tylenol" in the office and

she kept a box of loose pills that she would offer to people.

19. For example, Ms. Rogers offered me "Canadian Tylenol" on multiple occasions

when my schedule was busy or hectic.

20. I always refused her "Canadian Tylenol" and used my allergy to codeine as an
excuse.

21. Ms. Rogers also missed an inordinate amount of work. In fact, she was rarely at

the office unless the Senators were in the office.

22 . Ms. Rogers also boasted about her ability to use her influence to have people

terminated or moved and that she could manipulate the Senate to sabotage people's careers.

23. For example, Ms. Rogers boasted that she had Keaton Alexander "re-homed."

24. Ms. Alexander was a Legislative Aide for Senator Simpson.

25. From our conversations it appeared as though Ms. Rogers' turned on Ms. Alexander

simply because she believed that Ms. Alexander was growing too close to Senator Simpson.

26. As will become clear below, it is also worth noting that Ms. Rogers took Ms.

Alexander on a vacation to Key West prior to ending Ms. Alexander' s Senate career.

27. One night I was at Ms. Rogers' house when she told me that she had called Senator

Simpson about having Laquisha Persak removed from her position as Press Secretary.

28. Ms. Rogers told me that Senator Simpson was discussing Ms. Persak' s removal

with Senate President Negron.

29. Ms. Rogers never gave a reasonable explanation for her vitriol against Ms. Persak,

but she was always mean to Ms. Persak with no justification.

30. Ms. Rogers began attacking the Staff Director and trying to undermine his career.

31. I personally believe that she was jealous of the Staff Director' s power and that is

why she leveled those accusations against him.

32. At one point Ms. Rogers was incorrectly identified as the "Staff Director" in a

Miami Herald article.

33. Ms. Rogers personally attacked a Senate Aide who was widely respected and
viewed as the most well-likedSenate Aide.

34. Ms. Rogers was not included in the events that he planned with other Aides and

that, along with his influence with other Aides, seemed to bother Ms. Rogers.

35. Eventually, Ms. Rogers leveled some serious allegations against that Aide by

stating that he had made derogatory comments about Jewish people.

36. I am Jewish and that was obviously troubling to me, but I quickly dismissed her

allegations because I knew that they were completely inconsistent with his character and

demeanor.

37. Ms. Rogers also made general comments about having sabotaged other people's

careers although she did not provide their names.

38. Not long after I began associating with Ms. Rogers other people came to me and

warned me about becoming too close with Ms. Rogers.

39. An Aide who saw me associating with Ms. Rogers took me aside and warned me

that I should be careful what I told Ms. Rogers and repeatedly offered veiled comments that

suggested Ms. Rogers was troublesome.

40. Nonetheless, I maintained a friendship with Ms. Rogers and she ultimately spread

malicious rumors about me to sabotage my career.

41. One of my first concerns surrounded the manner Ms. Rogers treated me after my

Grandfather passed on April 19, 2017.

42. I was not particularly close to my Grandfather so I was appropriately grief stricken

but I was not openly grieving.

43. Ms. Rogers knew that my Grandfather was sick and she would regularly ask about

his condition.
 44. As such, I told Ms. Rogers of his passing, but I made it very clear that I wanted to

keep his passing private.

45. Contrary to my request, when I returned to my office I found multiple sympathy

cards addressed to me from my colleagues.

46. I asked Ms. Rogers why she had ignored my request that his passing remain private

and she responded by saying "well you weren' t telling people so I needed to."

47. For the next two or three weeks, Ms. Rogers repeatedly asked me how I was

handling my Grandfather's passing and I assured her that I was fine.

48. Suddenly Ms. Rogers expressed her belief that I needed grief counseling.

49. This began by her providing me with names of therapists and progressed to the

point where she started scheduling appointments for me to receive treatment from a therapist.

50. When I failed to appear for two appointments she arranged for a therapist to meet

me in the Legislative Clinic.

51. All of these actions occurred without my consent and against my will.

52. Ms. Rogers came to my office and issued an ultimatum that I would either see the

therapist in the Legislative Clinic or she was going to have my supervisor send me home for the

day.

53. Reluctantly I saw the therapist for approximately 15 minutes and he gave me a

prescription for Lexapro.

54. I did not intend on filling that prescription, and I left the prescription on my desk

while I attended a Committee meeting.

55. When I returned to my desk I found that Ms. Rogers had on her own volition taken

the prescription and had it filled and left the medicine in a gift bag on my desk.
 56. I later heard that Ms. Rogers claimed that I had threatened suicide over the passing

of my Grandfather.

57. She never made those comments in my presence, but I have heard that she made

those claims through third-parties.

58. It is important to reiterate that I was not very close to my Grandfather and I never

gave Ms. Rogers the impression that I was.

59. Moreover, I certainly never threatened to commit suicide and any such claim is

preposterous.

60. Ms. Rogers' behaviors were far more cruel and traumatic than my Grandfather' s

passing and I stopped viewing Ms. Rogers as a friend immediately thereafter.

61. My 22 nd birthday fell on the same date as Senator Latvala' s campaign fundraiser

that was scheduled to occur in Maine.

62. Ms. Rogers repeatedly suggested that we should travel by train to Maine to

celebrate my birthday and to attend Senator Latvala's fundraiser.

63. Ms. Rogers was obsessed with Senator Latvala.

64. For example, Ms. Rogers recounted for me a "dream" that she had about Senator

Latvala where he had lost "100 pounds" and had "dark hair" like he had when his Senate Majority

Leader photograph was taken.

65. The same photograph that Ms. Rogers was referencing from her dream 1s

prominently displayed in the Senate Majority Office where she worked.

66. Ms. Rogers ' text messages about her "dream" are attached hereto as Exhibit "T-

2".

67. For the reasons discussed above, I repeatedly declined Ms. Rogers ' suggestions that
we travel to Maine and she stopped discussing Maine after she learned that Senator Latvala's

campaign did not invite her to attend.

68. Thereafter Ms. Rogers suggested that we should travel to Plains Georgia to stay in

a hotel that was purportedly haunted.

69. That trip also involved taking a train ride and I likewise declined that invitation.

70. The week of my birthday Ms. Rogers began to deliver gifts that symbolized the

seven letters of my name.

71. On the Sunday two weeks prior to my birthday, Ms. Rogers asked to meet me in a

parking lot so that she could deliver a lollipop tree to me with the emphasis being placed on the

"L" in lollipop.

72. Thereafter she delivered the presents to my office which in order were as follows:

an inflatable drink holder, a scratch off lottery ticket, margarita glasses full of limes with a letter

announcing that we were going on a trip to the Keys, arrows that signify my College Sorority, and

the final gift was supposed to be brought to the Keys but I never received that gift.

73. Ms. Rogers' gestures, while nice, were uninvited and somewhat awkward.

74. Ms. Rogers' benevolence did not come without a price, because she would

regularly remind you of her kindness and her gestures always seemed to be driven by a larger

agenda.

75. For example, it is strange that Ms. Rogers would routinely text Senators but she

had maintained no significant friendships with Aides.

76. The Keys trip was a mess.

77. Present on the trip was Rachel Rogers, Camille Johnson and myself.

78. We also met reporter Marc Caputo on the trip who joined us for lunch at our hotel
and we thereafter accompanied him to his rental house.

79. It was clear that Ms. Rogers and Mr. Caputo were very close.

80. Camille and Rachel seemed to pair up and it quickly became apparent that I had

little in common with them.

81. As such, I began to do activities on my own that did not involve Rachel or Camille.

82. On our last night we went to establishments on Duval Street and we seemed to have

a good time until we were returning to our hotel.

83. During the trip back to the hotel Ms. Rogers became inexplicably distraught and

began to insist that she was intent on booking a flight home that night.

84. It was approximately 2:00 am, and her behavior was beyond bizarre.

85. Ms. Rogers sudden onset of mania persisted but she could not book the flight due

to having lost her debit card.

86. As such, she indicated that she could not leave that night and we returned to

Tallahassee the next day.

87. Our return trip was altered however, given that we originally planned on spending

the night in Ft. Myers before driving to Tallahassee, but Ms. Rogers insisted that we depart

immediately from Ft. Myers.

88. Her insistence caused me to drive the final leg of the trip to Tallahassee between

3:00 and 5:00 am while Ms. Rogers slept.

89. I avoided Ms. Rogers after we returned to Tallahassee due to her odd behavior, and

I curtailed our contact significantly while trying to maintain a professional relationship.

90. Approximately four to six weeks after we returned from the Keys, a verbal

altercation occurred between two of Senator Gainer's staff members and a political committee
employee.

91. I later learned that Ms. Rogers used that altercation as a basis to schedule a lunch

with Senator Gainer's wife, where Ms. Rogers allegedly told Ms. Gainer that I was having

numerous affairs with people involved in the political process.

92. Ms. Rogers went on to tell Ms. Gainer that I should prohibit Senator Gainer's staff

from associating with me.

93. Any such allegation against me is categorically false, and I have no understanding

as to the origin of any such false accusation.

94. On November 5, 2017, I was removed from my position within the Senate Majority

Office and was repositioned to the Senate Secretary's Office.

95. No reason was provided for my transfer, and the demotion resulted in an $11,000 a

year pay cut.

96. After my demotion, approximately two weeks ago, I received a call from the

Sergeant at Arms where he inquired about the kind of car that I drive.

97. I later heard that Ms. Rogers had complained that I was improperly parked in a

Senator's parking space.

98. That allegation was untrue, and the Sergeant at Arms told me the next day that he

had "received some bad information."

99. It is important to note that I am not friends with Senator Latvala, and I am not

offering this statement as a favor to him.

100. I had limited interactions with Senator Latvala, but he had a reputation for being

grumpy.

101. His reputation 1s diametrically opposed to the image that is portrayed in the
Complaint against him and is wholly inconsistent with my personal interactions with Senator

Latvala.

102. He is the opposite of "handsy" based upon my interactions with him, although there

are those who are inappropriate in their interactions with women, I have never observed Senator

Latvala act in that manner.

DATED this 30th day of November, 2017.

FURTHER, at this time, Affiant sayeth naught.

STATE OF FLORIDA

COUNTY OF LEON

PERSONALLY APPEARED BEFORE ME, the undersigned authority, duly authorized to

take acknowledgments and administer oaths, Lillian Tysinger, after first being duly sworn on oath,

deposes and says: that she is the individual described in and who executed the above and foregoing

document, the statements contained therein are true and correct.

Lillian Tysinger, is _ _ personally known to me or x has produced

as identification, and has/has not taken an oath.

WITNESS my hand and official seal in the County and State last aforesaid this 30th day

ofNovember, 2017.

NotaryPublic(Pri
My commission expires:
My commission number:
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I an1 a low level employee

Loi

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< Rachel
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Or IWB

IT WILL BE

YOUR PROBLEM

Tippers

Yuppers

I am a low level employee

Loi

Don't mistake your salary or

title for your level of influence

I don't

-
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< Rachel
CD
EXHIBIT

Have you told him abou t our I T-2.

mess iness yet

Loi

I sort of mean our friendship

but messiness seems like a
good way of puttin g it

Flash back

Last night latval a was in my

dream

He had lost over 100 lbs

He also h,ad dark hair

< Rachel
CD

He also had dark hair

It was like his officia l senat e

photo came to life
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forev vvver rr

Satur day

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