| IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT IN AND FOR LEON COUNTY, FLORIDA DELAITREJ. HOLLINGER; PRISCILLA A. HAWKINS Plaintifits), ys. FLORIDA A&M UNIVERSITY Case No: 2022 CA 000299 BOARD OF TRUSTEES; Larry Robinson, PhD., in his official capacity as President; William Hudson, Ph.D., in his official capacity as Vice President for Student Affairs Defendant(s) connate FOR TEMPORARY RESTRAINING ORDER, renee ney TEMPORARY INJUNCTION AND PERMANENT INJUN( iCTION S 8 COMES NOW, DELAITRE J. HOLLINGER (“Hollinger”) PRISCILLA A. HAWKINS (“Hawkins”), pro se, Plaintiffs in the and mumbled proceeding, and files this their Complaint fora Temporary Restraining Order, Emergency Temporary Injunction and Permanent Injunction, pursuant td Florida Rule of Civil Procedure 1.610 and in support thereof would show as follows: ary1. Plaintiffs| UNIVER‘ official ¢; filed their Complaint against Defendants, FLORIDA A&M ‘SITY BOARD OF TRUSTEES, Larry Robinson, Ph.D., in his ;pacity as President, William Hudson, Ph.D., in his official capacity as Vice President for Student Affairs (“FAMU”), on February 21, 2022, seeking a temporary restraining order, emergency temporary injunction and permanent injunction, appointment of a receiver and other relief, which Complaint is incorporated herein by reference for all purposes. 2. As set for immediat rth in the Complaint, Plaintiffs Hollinger and Hawkins assert that e, irreparable harm will be done if FAMU engages in demolishing Truth Hall, the last remaining historic female dormitory on the university campus, located at 1699 South Martin Luther King, Jr. Boulevard, Tallahas: ce, Leon County, Florida. Plaintiffs therefore request emergency injunctive relief enjoining the Defendants from engaging in such adverse action, which will cause irreparable harm and irreversible damage to a significant historical resource belonging to the state. 3. Also, De} fendants are in control of FAMU, and have acted, are acting/will act in a manner that is illegal and oppressive. As directed by Chapter 267.031, Florida individu: statutes and Chapter 267.061, Florida Statutes, Section agencies and s with direct or indirect jurisdiction over state lands or state-* assisted projects on state lands are responsible for considering the effect proposed] undertakings may have on historic properties. Qualifying undertakings may include, but are not limited to, ground disturbance, building Or structure alteration, and new construction. Additional effort to thoroughly identify historic properties within a project area may be necessary if an undertaking has the potential to affect unrecorded historic properties. Chapter 267 requires consultation with the Florida Department of State, Division pf Historical Resources (‘DHR”) for undertakings on state lands. This consultation assures that significant historic properties are not inadvertently disturbed, transferred, sold, demolished, substantially altered, or allowed to deteriorate significantly. In cases where adverse effects to significant historic properties may occur, Chapter 267 directs agencies to pursue opportunities in consultation with DHR to avoid, minimize, or mitigate any adverse effect. FAMU demolished four (4) historic buildings/dormitories in 2019, which were each listed in the National Register of Historic Places, via the Florida Agricultural and Mechanical College National Historie District, Listed in the National Register of Historie Places on May 9, 1996 (Ref: LE2410). Plaintiffs also state that FAMU must comply with Chapter 267 and resurvey the campus to determine its continuedeligibility for this register, in light of the previous demolitions, pursuant to this Chapter. 7 ois also assert that the Defendants are in violation of Chapter 287.094511, Florida Statutes. The Legislature finds that there is evidence of a systematic pattern of past and continuing racial discrimination against minority pusiness enterprises and a disparity in the availability and use of minority business enterprises in the state procurement system, It is determined to be a compelling state interest to rectify such discrimination and uel Based upon statistical data profiling this discrimination, the Legislature has enacted race-conscious and gender-conscious remedial | programs to ensure minority participation in the economic life of the state, in state contracts for the purchase of commodities and services; and in construction contracts. The purpose and intent of this section is to increase participation by minority business enterprises accomplished by encouraging the use of minority business enterprises and the entry of new and diversified minority business enterprises into the marketplace. FAMU has not engaged minority contractors in its processes, in several respects, including in the demolition of McGuinn Hall, Cropper Hall, Diamond Hall, and Wheatley Hall; nor|were minority contractors involved in the construction of the | 4 i» © 10. FAMU Towers buildings, the Center for Access and Student Success, or the demoliti n of Paddyfote Complex. . FAMU has not engaged or involved the university’s alumni, or citizens of the state of: Florida at-large in these decisions. Public notification has only taken place after decisions from the Defendants have been made, without public input. ] Hawkins establishes legal standing as an alumna of FAMU, community historian, concerned citizen and creative director of historical preservation organizatjon. Hollinger establishes legal standing as a community historian, president of an historical preservation organization, concemed citizen, and member of philanthropic organizations associated with financially supporting FAMU. Plaintiffs COUNTI TEMPORARY RESTRAINING ORDER |reallege and incorporate herein paragraphs 1 ~7. Plaintiffs|seek a temporary restraining order restraining FAMU from demolishing Truth Hall. COUNT IT | EMERGENCY TEMPORARY INJUNCTION Plaintiffs reallege and incorporate herein paragraphs 1 — 7.11. Plaintiff seeks emergency temporary injunction enjoining FAMU from demolishing buildings on FAMTU"s campus that are deemed to be eligible for listing in the National Register of Historic Places, or that are currently listed in the National Register of Historic Places. COUNT IT PERMANENT INJUNCTION 12. Plaintiffs reallege and incorporate herein paragraphs 1 — 7. 13. Plaintiffs seek permanent injunction, enjoining FAMU from demolishing Truth Hall, preventing FAMU from demolishing buildings on FAMU’s campus that are deemed to be eligible for listing in the National Register of Historic Places, or that are currently listed in the National Register of Historic Places, and requiring FAMU to comply with Chapter 267.031, Florida Statutes, Chapter 267.061, Florida Statutes and Chapter 287.09451, Florida Statutes. | PRAYER FOR RELIEF WHEREFORE, Plaintifis respectfully request that this Court enter: @a temporary restraining order restraining FAMU from demolishing Truth Hall | (b)an emergency temporary injunction enjoining FAMU from demolishing buildings on FAMU’s campus that are deemed to be eligible for listing in 6the National Register of Historic Places, or that are currently listed in the Natiosl Register of Historic Places. (permanent injunction, enjoining FAMU from demolishing Truth Hell, preventing FAMU from demolishing buildings on FAMU’s campus that are deemed to be eligible for listing in the National Register of Historic Places, or that are currently listed in the National Register of Historic Places, and requiring FAMU to comply with Chapter 267.031, Florida Statutes, Chapter 267.061, Florida Statutes and Chapter 287.09451, Florida Statutes. (d)And day further relief as this Court deems just and proper.| Respectfully submitted, /s/ Delaitre J, Hollinger Delaitre J. Hollinger Pro Se 501 Alpha Avenue Tallahassee] Florida 32305 (850) 296-5590 [email protected] Respectfully submitted, /s/ Priscilla A. Hawkins Priscilla A. Hawkins ProSe 6033 Button Willow Lane Tallaassec) Florida 32305 (850) 879-9282 PriscillaHawkins@hotm: ym