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I THE CIRCUIT COURT OF THE FIRST JUDICIAL CIRCUIT I A D FOR WALTO COU TY, FLORIDA CIVIL DIVISIO JOH

P. CARROLL, Plaintiff, v. WATERSOU D BEACH COMMU ITY ASSOCIATIO , I C., Florida Corporation DAVID LILIE THAL, individually and as Director, MARY JOULE, SA DRA MATTESO , RO ALD VOELKER, WATERCOLOR COMMU ITY ASSOCIATIO , I C. JOH DOE and JA E DOE Defendants. ____________________________________________/ MOTIO FOR CO TEMPT A D PROTECTIVE ORDER COMES NOW PLAINTIFF who asks the Court for an Order of Contempt and Protection against Defendant WaterSound Beach Community Association, Inc. and states as follows: 1. 2. This Court entered a Case Management Order closing discovery on May 31, 2011. On or about June 17, 2011, the office of Scott, Sullivan, Streetman & Fox attempted Case o.: 09CA002021

to interfere with a current contract which Plaintiff Carroll has with his clients Michael and Christine Davis. 3. Mr. Georges office attempted to solicit criticism of Carrolls work under the guise of

Discovery in the present case. Said Discovery period was previously closed by Order of the Court. 4. Defendants Counsel knows that this activity is improper and serves no purpose but to

create frustration of Carrolls contractual benefits with his clients. 5. As has been Carrolls fundamental complaint in the underlying case, Defendant

WaterSounds actions were again taken covertly so as to continue their stratagem of ambush and boycott of all Carrolls beneficial contractual relations. 6. Carroll asks this Court to hold an evidentiary hearing, complete with Plaintiff and

Defendant witnesses testimony, at a date and time acceptable to the Court in which Defendants Counsel is required to present phone records and testimony to fully disclose any and all such off record communications they have had with Carrolls current and past customers. Wherefore, Plaintiff prays this Court find Defendant WaterSound in direct contempt of the Courts Order and take a stand to protect Plaintiff Carroll by issuing a meaningful and direct sanction against Defendant WaterSound Beach Community Association, Inc. Further, Carroll requests the Court sign a protective Order which will permanently bar the Defendants from committing future economic boycotts against Carroll and his business interests. I HEREBY CERTIFY that on July 28, 2011, I have furnished copies to Christopher L. George, Esq., PO Box 1034, Mobile, AL 36633 and to Mark D. Davis, Esq., 694 Baldwin Ave. Suite 1, PO Box 705, DeFuniak Springs, FL 32435 and to Gary Shipman, Esq., 1414 Co. Hwy. 283, Suite B, Santa Rosa Beach, FL by regular mail this 28th day of July, 2011.

_____________________________ John P. Carroll Box 613524 WaterSound, FL 32461 850-231-5616 Tel. 850-622-5618 Fax.