Professional Documents
Culture Documents
File 0279
File 0279
CHRISTOPHER E. DORWORTH,
JURY TRIAL DEMANDED
Plaintiff,
v.
Case No.: 2023-CV-_____________
JOEL MICAH GREENBERG, ANDREW W.
GREENBERG, SUE GREENBERG, ABBY
GREENBERG, AWG, INC., GREENBERG
DENTAL ASSOCIATES, LLC, GREENBERG
DENTAL & ORTHODONTICS, P.A.,
GREENBERG DENTAL SPECIALTY GROUP,
LLC, and A.B.,
Defendants.
VERIFIED COMPLAINT
counsel, and for his Complaint against Defendants states and alleges as follows:
1. Joel Greenberg is a convicted felon and current federal prisoner. He became one of
the most corrupt politicians in Florida history by using his position as a county tax collector to
steal more than One Million Dollars from the taxpayers of Seminole County through
cryptocurrency theft, bribery of public officials, and kickbacks. He also used the power of his
2. For years, Joel Greenberg, his parents, spouse, and family business entities have
enterprises, having been threatened and extorted by the enterprise to pursue (1) a pardon for Joel
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Greenberg’s criminal activities and/or (2) termination or reassignment of the Assistant United
family, through the racketeering enterprise, falsely accused Dorworth of being involved in, among
other things, child sex trafficking and an illegal ghost candidate scheme. As a result of the
5. Joel Greenberg is a predator, not just of women, as his conviction for human
trafficking reflects, and not just for alleging that his political opponent was a child molester.
Greenberg preyed on the taxpayers of Seminole County, enriching himself via racketeering
activities. When Joel Greenberg’s illegal behavior was finally exposed, he then turned his
predatory power on former “friends,” including Plaintiff Dorworth, when Dorworth was unwilling
to participate in a scheme to obtain a preemptive pardon to avoid facing future charges, and later
when Dorworth refused to participate in having the Assistant United States Attorney that was
Representatives, a prominent businessman, and served as a lobbyist prior to leaving the profession
7. Dorworth has retained undersigned counsel and is obligated to pay a reasonable fee
Florida. He is the former elected constitutional officer and tax collector of Seminole County,
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Florida, and is presently an inmate incarcerated by the United States Bureau of Prisons. He is
serving an 11-year sentence after pleading guilty to crimes including Underage Sex Trafficking,
Enterprise.
Florida. He is the father of Joel Greenberg and serves as President of Greenberg Dental Associates,
LLC, President of Greenberg Dental & Orthodontics, P.A., and principal of AWG, Inc.
Florida. She is the wife of Andrew W. Greenberg and mother of Joel Greenberg.
Florida. She is the current ex-wife of Joel Greenberg, with their divorce filed October 15, 2021,
14. Defendant AWG, Inc. is a Florida corporation with its principal address located in
Forest City, Seminole County, Florida. AWG, Inc., is the business enterprise of the Greenberg
family.
Company with its principal address in Altamonte Springs, Seminole County, Florida.
Association with its principal address in Altamonte Springs, Seminole County, Florida.
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17. Defendant Greenberg Dental Specialty Group, LLC, is a Florida Limited Liability
Company with its principal address in Altamonte Springs, Seminole County, Florida.
18. Herein, Greenberg Dental Associates, LLC, Greenberg Dental & Orthodontics,
P.A., and Greenberg Dental Specialty Group, LLC, are collectively referred to as “Greenberg
Dental.”
19. Defendant A.B. is an individual and, upon information and belief, is a resident of
20. Upon information and belief, A.B. was compensated by the Greenberg
21. This is an action for damages exceeding fifty thousand dollars, exclusive of attorney
22. This Court has general jurisdiction over the individual defendants pursuant to
Section 48.193(1) and (2), Florida Statutes, because they reside in Florida and/or engage in
23. This Court has general jurisdiction over the business entity defendants pursuant to
24. Venue is proper in this Circuit pursuant to Section 47.011, Florida Statutes, because
one or more Defendants reside in, or are headquartered in, Seminole County, Florida, and because
the cause of action accrued in Seminole County, Florida as set forth throughout this Complaint.
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ALLEGATIONS COMMON TO ALL COUNTS
25. None of Joel Greenberg’s misconduct could have been committed without support
from his parents, Sue and Andrew Greenberg, and the dental chain they founded and co-own,
Greenberg Dental.
26. Despite his history of mental health issues, drug addiction and socially abnormal
behavior, Greenberg Racketeering Enterprise directly and indirectly supplied Joel Greenberg with
$246,000 in funds to seek election to the Seminole County Tax Collector’s Office.
27. The Greenberg Racketeering Enterprise is directly responsible for 97.1% of the
campaign resources used in Joel Greenberg’s successful campaign for the Office of the Tax
28. From his first day in office in January 2017 until his indictment three and a half
years later, Greenberg committed dozens of felonies involving a wide-ranging variety of crimes
including, among other things, human trafficking of a minor for sex purposes, stalking, bribery,
theft from the tax collector’s office, and fraud against the government, and as is reflected in his
29. Joel Greenberg used funds obtained through the Greenberg Racketeering Enterprise
to procure sex in exchange for money and traffic a minor for sex.
30. As the Greenbergs were aware of Joel’s ongoing criminal enterprise, they utilized
resources derived from Greenberg Dental, which then flowed through AWG, Inc., to sustain
Greenberg in office, allow him to escape detection for his crimes, and to mitigate his exposure,
31. Upon information and belief, the Greenberg Racketeering Enterprise underwrote a
massive effort to falsely implicate Plaintiff and others in misconduct, either in retaliation for their
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failure to aid Greenberg in escaping accountability, or in a misguided attempt to obtain a further
32. The Greenberg Racketeering Enterprise also paid all fines and restitution necessary
to minimize the prison sentence of Joel Greenberg, including $1.355 million to Seminole County,
33. As an elected official, Joel Greenberg was required to file financial disclosure
forms. These forms reveal that the Greenberg family, through the Greenberg Racketeering
Enterprise, provided 100% of the financial support permitting Greenberg’s massive racketeering
efforts.
34. Once it appeared inevitable that Joel Greenberg would receive a prison sentence for
his crimes, the Greenberg Racketeering Enterprise began seeking a federal pardon from then-
Dorworth as the key to obtaining said pardon, due to Dorworth’s friendship with Congressman
Matt Gaetz and Dorworth’s employment at Ballard Partners, an international public affairs and
36. Joel Greenberg first threatened Rebekah Dorworth, Dorworth’s wife, then
threatened Mr. Dorworth orally and by text message that unless Dorworth undertook all necessary
efforts obtain a pardon from President Trump, that Greenberg would embroil Dorworth in
37. After Dorworth refused to acquiesce to such threats, the Greenberg Racketeering
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38. The Greenberg Racketeering Enterprise also demanded, via threat of prosecution,
that Dorworth use all available means to have then-Assistant U.S. Attorney (and current U.S.
Attorney) Roger Handberg fired from his position to stop the prosecution and conviction of Joel
Greenberg.
39. After Dorworth refused to acquiesce to these additional threats, Joel Greenberg, in
concert with the Greenberg Racketeering Enterprise, conspired to defame Dorworth and falsely
A. The Greenberg Racketeering Enterprise Sets Sights on the Tax Collector’s Office
40. Florida Tax Collector laws date back to the foundation of Florida as a state.
41. In Florida, there are five types of Constitutional Officers as designated by the
Florida Constitution: Sheriffs, Tax Collectors, Property Appraisers, Supervisors of Election and
Clerks of Court.
42. Tax Collectors are the only Constitutional Officers in the state of Florida not subject
43. Each Tax Collector submits a budget for approval by the Florida Department of
Revenue.
44. The Department of Revenue approves or rejects the budget of the Seminole County
Tax Collectors.
45. All other constitutional officers are funded through and subject to budgetary
46. Florida Statute defers to individually elected tax collectors the establishment of
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47. Due to the constitutional status of Tax Collectors, they are not required to
48. Thus, the tax collector determines who to hire and what to pay them without input
49. A tax collector has the option of turning over excess tax collections to the county if
the tax collector determines they will no longer need the resources for the collection of taxes.
50. The previous Seminole County Tax Collector, Ray Valdes, served in the capacity
51. Mr. Valdes turned over large sums of excess tax collections to Seminole County:
52. Over these 14 years, Valdes turned over an average of $4,961,251.29 per year.
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53. Joel Greenberg observed an opportunity with up to $7 million and an average of
almost $5 million per year in entirely discretionary dollars with limited oversight, and embarked
54. Over Joel Greenberg’s four years as Seminole County Tax Collector, he turned over
$2,910,151 in 2017, $2,697,504 in 2018, $2,859,947 and $2,896,551 in 2020, substantially smaller
taxes to Seminole County, a reduction of $2,120,213.04 per year from the Valdes average.
56. On average, Joel Greenberg turned in 42.73% less excess revenue to Seminole
County than this predecessor did over the preceding 13-year period.
57. Despite a life full of failure, addiction, mental health issues and criminal activity,
Joel Greenberg lived a life of privilege that few people could imagine because of the financial
58. Joel Greenberg’s serious behavioral problems began when he was a child.
59. On May 30, 2000, Orlando Sentinel Columnist Brian Schmitz wrote an article
entitled “Life Lessons” in which Joel Greenberg’s mother, Sue Greenberg, explains the challenges
60. Joel Greenberg was 16 years old when the article was published.
61. Sue Greenberg is quoted as saying: “Joel is my shining star that needs more
polishing, more buffing. He's the one who keeps me on my knees. It was a belligerent, defiant,
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Id.
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62. Schmitz, the article’s author, continues: “Susan said Joel has been a handful ever
since he was diagnosed with attention deficit disorder as a toddler. While taking Ritalin, he
developed Tourette's syndrome. Behavior problems escalated, and by the seventh grade, Joel was
stealing money from his parents. He then stole from a store. He wound up in Operation Right Track
63. Joel’s problems were aptly summed up by Joel’s own counsel during his
sentencing:
If you read the family section of the PSR, Mr. Greenberg's mother details his
struggles with self-worth and self-esteem throughout his childhood, his struggles in
school, his struggles with mental illness in school.
December 1, 2022 Sentencing Trans. at 11:25-12:3. Thus, Greenberg’s mother admits she was
aware of his limitations yet still helped him become Tax Collector.
64. Joel Greenberg was expelled from Orangewood Christian School and Florida Air
Academy.
65. Only through Andrew and Sue Greenberg’s “directed philanthropy” was Joel
66. Joel Greenberg spent seven years taking classes at Rollins College between 2005-
67. At the age of 18, Joel Greenberg’s name appeared in a burglary report.
68. Joel Greenberg was involuntarily committed for psychiatric care at the age of 21
69. While involuntarily committed, Joel Greenberg accused an orderly of grabbing his
penis while Greenberg was confined to a chair. No evidence supported Greenberg’s claim.
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Id.
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70. This is the beginning of Joel Greenberg’s pattern of utilizing allegations of sexual
71. Joel Greenberg’s sole professional endeavor was a short-lived sports radio show.
72. After the indictment and conviction of Joel Greenberg and his co-host Joe “Big
Joe” Ellicott, Orlando Sentinel Sports Columnist Mike Bianchi addressed the radio career of Joel
Greenberg.
73. In his column, Bianchi stated that he knew that when he saw that Joel Greenberg
had been elected Tax Collector for Seminole County, it would end in negative consequences. 4
74. He wrote:
You see, I used to know Joel Greenberg. I didn’t know him very well, but I knew
him from when he was a wannabe sports radio host at the station (FM 96.9 and AM
740) where I have been doing my Open Mike morning radio show for more than a
decade. I’m not going to say I predicted Greenberg would someday be arrested and
charged with theft of public funds, sex trafficking, cryptocurrency fraud and a
variety of other crimes, but I knew when he was somehow elected as the Seminole
County Tax Collector in 2016 that it would be a disaster.
How did I know? Because a few years before that, Greenberg’s career goal was to
be a sports radio entrepreneur, and he persuaded station management to let him,
and a couple of his pals do a one-hour early morning radio show — The Morning
Blitz — that would start at 5 a.m. and serve as a lead-in to my 6 a.m. show. I
remember warning Greenberg at the time, “You know it’s a total lifestyle change
and a grind to get up every morning at 3 or 4 a.m. to prepare and do a radio show.”
Of course, Greenberg was all gung-ho for the first day or two, but by the end of
Week 1 he was straggling into the station bleary-eyed right before 5 a.m., and you
could tell he did absolutely no show prep. Just turned on the microphones and
started babbling. By the end of Week 2 or 3, Greenberg quit coming into the station
altogether and that was pretty much the end of his sports radio career. I haven’t
seen him since. 5
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Id.
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75. The Greenberg Racketeering Enterprise underwrote Joel’s short radio host plan
76. Greenberg failed to perform the tasks necessary to run a radio station through
77. The Greenberg Racketeering Enterprise had the opportunity to observe Joel
Greenberg’s mental health problems, addiction problems, criminal activities and near pathological
irresponsibility at school and in business ventures yet they continued to underwrite 100% of his
luxurious life.
B. The Sole Source of Joel Greenberg’s Wealth, Income and Assets Came from the
Greenberg Racketeering Enterprise
78. Joel Greenberg disclosed to Dorworth that he received $100,000 a quarter from his
parents via disbursements from AWG, Inc, which received its value and income from Greenberg
79. Joel Greenberg advised Dorworth that he provided strategic advice and counsel to
80. As an elected official in Florida, Joel Greenberg is responsible for filing a Form 6
with the Florida Commission on Ethics, which is a statutorily mandated disclosure for elected
officials in Florida that receive compensation for their service that must be filed on an annual basis.
81. Greenberg filed financial disclosures for 2016, when he was first elected, 2017,
82. On these disclosures, Greenberg was obligated to disclose his income, his net
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83. According to these disclosures, 100% of Joel Greenberg’s income came from his
parents, Sue and Andrew Greenberg, as well as AWG, Inc, which received its income from
Greenberg Dental.
Form 6.
85. On July 5, 2017, Joel Greenberg filed a Form 6 with the Florida Commission on
86. On Joel Greenberg’s 2016 Form 6, he lists a total salary of $400,000, all from
AWG, Inc.
87. No other income came to Joel Greenberg in 2016 according to his Form 6.
88. On the same 2016 Form 6, Joel Greenberg listed a net worth of $6,038,000, of
which $5,500,000 was stock in AWG, Inc, AWG FLP and JMG LLC. A search of Sunbiz.org shows
that organizational papers for JMG, LLG were filed on April 13, 2006.
90. At the time, there was another JMG, LLC organized and operational in Florida.
91. The Joel Greenberg-controlled JMG, LLC never filed an annual report with the
Florida Department of State and was listed as Inactive Pending Reinstatement on January 28, 2015.
92. A possible explanation for the administrative termination of JMG, LLC is the
existence of another company unaffiliated with Joel Greenberg’s JMG, LLC that was organized
and operational when Joel Greenberg attempted to organize his JMG, LLC, which prohibited him
93. As Joel Greenberg did not own or control JMG, LLC, any representation of it
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94. The Joel Greenberg-managed JMG, LLC did not exist in 2016, and as such could
96. Upon information and belief, the Form 6 lumps the three companies together in an
attempt to conceal the fact that all of Greenberg’s purported wealth was from AWG, Inc.
97. The remaining two stocks were AWG, LLC, and AWG FLP.
98. The $5.5 million in value attributed to AWG INC, AWG FLP, and JMG LLC,
represent 91% of the total $6,038,000 net worth listed by Joel Greenberg during the entirety of his
campaign to take control of the Seminole County Tax Collector’s Office for racketeering purposes.
99. In 2016, AWG, Inc. represented 100% of Joel Greenberg’s $400,000 income and
91% of his net worth was derived from AWG, Inc. and AWG FLP.
101. Both the Amended Form 6 and the originally-filed Form 6 list February 28, 2017,
as an effective date.
102. Only two changes appear between the original and Amended Form 6.
103. On the original Form 6, under “Automobile,” Joel Greenberg claimed, “Range
104. On the amended Form 6, “Jeep” is removed, but the $115,000 value remains.
105. On the amended report, both AWG FLC and JMG, LLC are removed as stocks with
value.
106. By reporting the three companies as stock holdings in one line item, Joel Greenberg
misled the public into believing that he had income or employment outside of his parents.
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107. Nonetheless, the Amended Form 6 clearly denotes that AWG, Inc. and only AWG,
Inc. provided income to Joel Greenberg during the campaign to take control of the Seminole County
108. Joel Greenberg utilized his initial Form 6 to suggest that some of his net worth of
millions might have come from something other than the Greenberg Racketeering Enterprise and
corrected the report to show that 100% of his income, valuables and wealth came from AWG, Inc,
109. The 2016 Amended Form 6 reveals that the only stock with value - $5,500,000 - is
AWG, LLC.
110. In 2017, Joel Greenberg reported a net worth of $6,208,800 in net worth, of which
$5,665,000, or 91% of his net worth, came from a jointly reported AWG, Inc. and JMG Ventures.
111. According to Sunbiz.org and the Florida Division of Corporations, JMG Ventures
113. On the 2017 Form 6, Joel Greenberg reports $400,000 in salary from AWG, Inc.
and $149,253 in salary from the Seminole County Tax Collector’s Office.
114. On the 2018 Form 6, Joel Greenberg lists a net worth of $5,857,135, of which
116. Across all of Joel Greenberg’s filed Form 6’s, all of his wealth is derived from
AWG, Inc. stock, income from AWG, Inc. salary as Seminole County Tax Collector that was
effectively purchased for him by AWG, Inc. and homes, furniture and jewelry acquired via
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117. Joel Greenberg took control of the Seminole County Tax Collectors office via
election.
118. Joel Greenberg and the Greenberg Racketeering Enterprise funded the election of
Joel Greenberg.
119. On the day Sue Greenberg was advised her son was going to run for Seminole
County Tax Collector utilizing money given to him by the Greenberg Racketeering Enterprise, she
120. Abby Greenberg, Joel’s wife, also cried and stated her belief that his time in elected
C. The Greenberg Racketeering Enterprise Takes Control of the Seminole County Tax
Collector’s Office
121. The decision of the Greenberg Racketeering Enterprise to finance the historically
expensive campaign of Joel Greenberg to become tax collector despite being aware of his history
of theft (i.e. stealing from his parents, stealing from a store, appearing in a burglary report), mental
health and drug addiction, failed businesses, never completing college after seven years of attending
Rollins, appearances in drug rehab and failed radio shows demonstrates a reckless disregard for the
122. The Greenberg Racketeering Enterprise facilitated the fraud and crime spree of Joel
Greenberg by paying for 97.1% of the money spent for his historically expensive campaign.
123. In 2016, Joel Greenberg filed to run for Seminole County Tax Collector.
124. The Greenberg Racketeering Enterprise knew that Joel Greenberg would be paid
$149,253 in pre-tax income as the tax collector of Seminole County for what is considered full-
time employment.
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125. According to the Seminole County Supervisor of Elections website, Greenberg
received a total of $248,512.52 in monetary contributions, in-kind contributions, and loans that
were not repaid from members of the Greenberg Racketeering Enterprise and his two brothers.
126. Joel Greenberg loaned the campaign $100,000 on May 16, 2016.
127. Joel Greenberg donated $1,000.00 to his campaign on May 16, 2016.
128. Between May 16, 2016, and May 31, 2016, Joel Greenberg contributed $3,415.81
129. On May 13, 2016, Joel Greenberg repaid $27,323.25 in loans to the campaign.
130. Joel Greenberg repaid $7,000 of the loan on June 16, /2016.
131. Joel Greenberg on June 29, 2016, loaned the campaign $5,000.
138. The addresses of Sue Greenberg, Andrew Greenberg, Martin Greenberg, Adam
Greenberg, AWG, Inc. and AWG Family Limited Partnership are all 3129 Cecelia Drive, Apopka,
Florida 32703.
139. After June 27, 2016, Joel Greenberg in-kind contributed another $6,625.42.
140. On July 5, 2016, Joel Greenberg repaid himself $1,000 of the loan he made to the
campaign.
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141. All told, totaling Joel Greenberg's loans, contributions and in-kind contributions
while factoring in repayment of loans, Greenberg spent $235,591.52 to win the primary to become
the Seminole County Tax Collector and take control of the enterprise.
142. Joel Greenberg and his family enterprise paid $241,591.52 to obtain control of the
Seminole County Tax Collector that position because he intended, conspired, and did immediately
begin a pattern of racketeering with the unique constitutional prerogative of tax collectors in Florida
and with full knowledge that he would have control over millions of dollars every year in excess
143. Comparatively, Ray Valdes, the 28-year incumbent Joel defeated spent a combined
144. Despite spending 5.4 times what the incumbent spent, Joel Greenberg received just
Clerks of the Court and Property Appraisers positions are considered full-time positions.
146. The decision to spend amounts equal to two years of after-tax pay for the election
of Seminole County Tax Collector that would require Joel Greenberg to work for two years just to
recoup his initial investment was a poor financial decision, particularly when Greenberg supposedly
147. There is no evidence that any of the Greenbergs were civic minded so as to justify
such an expenditure.
148. Joel Greenberg and the Greenberg Racketeering Enterprise spent after tax amounts
equal to 1.6 years of pre-tax salaries because they were aware of lax state oversight of Tax
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Collectors and the existence of $5-7 million a year of available discretionary capital to feed their
racketeering enterprise.
149. Facing only a write-in opponent, Greenberg was formally elected tax collector in
November of 2016 and officially took control of the office on January 1, 2017.
150. The resources expended by the Greenberg Racketeering Enterprises surpasses any
amount ever spent in the history of Seminole County Tax Collector elections and far surpasses what
was spent in substantially larger counties in the 2016 election cycle anywhere else in the state of
Florida.
152. For context, Volusia County held its first-ever election for tax collector in 2020.
153. Volusia adjoins Seminole County to the north and is larger in terms of overall
154. In the Republican Primary for tax collector, one Republican candidate raised
$45,193, none of which came from himself, and the winning candidate raised $33,072.12, of which
155. According to the various Supervisors of Elections websites across the state of
Florida, Joel Greenberg spent more than any candidate in a primary for Tax Collector than any
other tax collector in the state of Florida dating back to the 2012 election cycle.
156. Greenberg’s complete unsuitability for the job meant that the Greenberg
157. Given the disproportionate amounts spent by Joel Greenberg, both in relation to the
amount others spent, as well as to the legitimately accruing benefits of the position, it is clear that
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the Greenberg Racketeering Enterprise spent these sums to acquire control over the Seminole
County Tax Collector’s Office intending to use the position for illegal and improper purposes.
158. Criminal wrongdoing in the Seminole County Tax Collector’s Office started the
first day Joel Greenberg was in office and continued even after his resignation. As stated in the
Greenberg’s criminal conduct began prior to his 2016 election as the Tax Collector
for Seminole County. In November 2015, after purchasing a boat from an
individual, R.Z., Greenberg used R.Z.’s personal information to change R.Z.’s
mailing address and obtain a replacement license in R.Z.’s name, without R.Z.’s
consent or knowledge. PSR ¶ 49. Greenberg’s election then fueled a fire that began
a pervasive and wide-spread crime-spree, for which he used his position, and
instrumentalities of the Tax Collector’s office, to fund and facilitate.
On the very day that Greenberg took office, January 3, 2017, Greenberg used his
position to access the Florida Driver and Vehicle Information Database (DAVID)
and search for R.Z. Id. at ¶ 52. He then reverted R.Z.’s mailing address back to
R.Z.’s actual residence. R.Z. never knew what Greenberg had done. Id. In
November 2017, Greenberg searched for R.Z. again in DAVID, and using a badge-
making machine that he had purchased with Tax Collector funds, produced a fake
driver’s license containing R.Z.’s information and Greenberg’s picture. Id. at ¶¶ 53-
54.
159. The amount of and variety of crimes committed by Joel Greenberg is so far ranging
that it led to then-NBC National News correspondent Mark Caputo calling Greenberg “one of the
160. With control of the government office for unlawful and racketeering purposes,
Greenberg undertook actions that resulted in him being charged with thirty-three different felonies.
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161. As part of a plea deal, 27 charges were dropped, and Greenberg plead guilty to the
remaining six.
162. Greenberg also committed additional uncharged felonies, such as perjury, false
163. In addition to using the Tax Collector’s Office for unlawful and racketeering
purposes, Joel Greenberg unnecessarily spent millions of dollars on employees, contractors and
legal fees that deprived the taxpayers of use of the tax money paid for legitimate purposes.
164. The Greenberg Racketeering Enterprise had long funded Joel Greenberg’s sex
addictions through payments from AWG, Inc. used to pay women for sex via websites.
165. AGW’s payments to women on behalf of Joel Greenberg predated his election to
allowed Joel Greenberg to utilize privileged government resources for human trafficking.
167. The U.S. Department of Justice alleged Joel Greenberg used the state’s driver’s
license system (D.A.V.I.D.) to obtain the photograph and license number of the minor victim for
168. According to an Orlando Sentinel news article, Joel Greenberg also looked up
169. Joel Greenberg utilized his position as a constitutional officer and Seminole County
Tax Collector to traffic an underaged woman for sex and elude detection.
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170. According to the indictment, Joel Greenberg used customers’ discarded licenses at
the tax office to make the fake licenses, which were done to facilitate commercial sex acts.
171. Between September 2018 to June 2020, Greenberg produced a false Puerto Rico
driver’s license containing Greenberg’s photo but the name and personal info of E.J.C.C. (Counts
concerned student,” allegedly sent letters to Trinity Preparatory School, where his political
opponent Brian Beute (“Beute”) worked, claiming the employee had engaged in sexual
misconduct, created a fake Twitter account using the name and photo of the political opponent that
was then used to express support for the school teacher’s white supremacy, and created a fake
Facebook page of a “very concerned teacher” that claimed the political opponent was engaged in
173. Greenberg searched D.A.V.I.D. records for individuals with whom he was engaged
174. A “sugar daddy” is a rich older man who lavishes gifts upon one or more young
175. Without the resources of the Greenberg Racketeering Enterprise, Greenberg would
have lacked either resources to recruit women for sex or the governmental tools necessary to aid
176. The Greenberg Racketeering Enterprise directly paid 97.1% of the cost of obtaining
control of the organization for criminal purposes including theft and embezzlement of
cryptocurrency.
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177. In November 2017, Greenberg allegedly used a Tax Collector Office credit card to
179. In December 2017 and December 2018, Greenberg allegedly transferred 8.1583
Bitcoin (valued at more than $20,000) to his personal accounts (Counts 22, 23 of 3rd superseding
indictment).
Government Blockchain Systems to a cryptocurrency account he controlled. (Counts 15, 16, 17,
181. December 2018, Greenberg transferred $200,000 from Tax Collectors Office to a
182. In December 2017 and December 2018, Greenberg transferred 8.1583 Bitcoin
(valued at more than $20,000) to his personal accounts (Counts 22, 23 of 3rd superseding
indictment)
183. The Greenberg Racketeering Entity’s theft and misappropriation of bitcoin was
184. On September 26, 2019, Greenberg in-kind donated $240,340 in bitcoin to his
185. According to campaign finance reports, Joel Greenberg had not moved any of the
186. Joel Greenberg’s initial Form 6 lists no bitcoin assets on December 31, 2019.
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187. Joel Greenberg’s Amended Form 6 lists $100,000 in Bitcoin on December 31,
2019.
188. Under either circumstance, Greenberg did not have personal possession of
189. It is not known if the Bitcoin in-kinded belonged to Andrew Greenberg specifically,
the Greenberg Racketeering Entity or was the property of the Seminole County Tax Collector’s
office.
190. The Bitcoin was either stolen, misreported, or donated in excess of campaign
191. Either way, the stolen and/or misreported Bitcoin was invested into the Greenberg
Campaign, part of the Greenberg Racketeering Enterprise in an attempt to keep Joel Greenberg in
192. On January 27, 2020, Greenberg in-kind donated $194,000 in bitcoin to his
193. On the Form 6 Financial Disclosure as to his net worth on December 31, 2019, Joel
194. Upon information and belief, Greenberg utilized $194,000 in stolen bitcoin to
maintain control of the Seminole County Tax Collector’s to continue the Racketeering Enterprise.
195. Greenberg’s two deposits totaled $434,000 in Bitcoin, but Joel Greenberg only had
196. Even if he emptied both of his bank accounts of $276,000, Joel Greenberg would
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197. Sale of AWG, Inc. stock, use of stolen cryptocurrency or use of Bitcoin owned by
other members of the Greenberg Racketeering Enterprise are viable explanations, and all continue
198. It is unclear whether the source of the cryptocurrency was the resources of AWG
Inc, Greenberg Dental and Andy Greenberg or if it was taxpayer owned cryptocurrency that
199. Theft of cryptocurrency and campaign finance irregularities were just the start of
the criminal activities undertaken by the Greenberg Racketeering Entity’s efforts to retain control
200. Greenberg performed the foregoing actions in an attempt to maintain control of the
Seminole County Tax Collector’s Office in an attempt to continue the Greenberg Racketeering
Enterprise.
201. On June 17, 2020, Greenberg was indicted by a grand jury on the first indictment.
202. On the same day, Joel Greenberg resigned from the Seminole County Tax
Collector’s Office.
203. Greenberg was bailed out post arrest with funds from AWG, Inc., Greenberg
Dental, and Andy Greenberg shortly after he is arrested on June 23, 2020.
204. All legal bills associated with the racketeering and criminal enterprise of Joel
205. Having resigned his job as Seminole County Tax Collector, the Greenberg
Racketeering Enterprise was now the sole source of revenue to support Joel Greenberg and his
family.
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206. Three days after Joel Greenberg’s resignation, on June 20, 2020, according to the
federal indictment, Joel Greenberg filed false EIDL applications to receive $132,900 in funding
on behalf of himself through a fraudulent loan from the Small Business Administration that offered
207. On June 28, 2020, according to the federal indictment, Greenberg allegedly filed a
false EIDL application on behalf of his former company, DG3 Network, and later received
$149,900 from the Small Business Administration with the intent to steal from the Small Business
208. On July 17, 2020, Greenberg allegedly bribed a Small Business Administration
employee by sending her payments for her assistance preparing and processing the loan
209. The resources utilized to bribe the Small Business Administration employee were
provided either directly by the Greenberg Racketeering Enterprise or through proceeds therefrom.
210. On July 21, 2020, Greenberg allegedly filed a false EIDL application on behalf of
his former company, Greenberg Media, and later received $149,900. (Counts 30, 33 of 3rd
superseding indictment).
211. Dorworth met Joel Greenberg in October of 2016 at a fundraiser for Donald Trump
at the home of Robert de la Russo being mutually introduced by their wives, Rebekah Dorworth
212. Dorworth was not any part of the campaign to elect Joel Greenberg as Tax
Collector.
26
213. Dorworth was not a friend of Joel Greenberg prior to his election and was unaware
of his history of mental health, addiction, gambling, legal troubles and business and academic
failings.
214. Despite being an active donor in local political races, Dorworth did not contribute
215. Prior to meeting Joel Greenberg, Dorworth had represented other Tax Collectors
216. On November 5, 2015, Dorworth registered via his employer Ballard Partners to
217. The Orange County Tax Collector was Scott Randolph, a registered Democrat and
former State Representative and chairman of the Orange County Democratic Party.
218. On behalf of the Orange County Tax Collector’s office, Dorworth advocated before
the legislature on a wide variety of tax collector related issues, including fees, private license tag
agencies and legislation that impacted the ability of independently elected tax collectors to do their
jobs.
219. Dorworth represented the Orange County Tax Collector’s Office for the entirety of
220. Dorworth represented other government entities at the same time, including the
221. After Joel Greenberg became aware that Dorworth had experience in representing
Tax Collectors, Joel Greenberg asked Dorworth to represent him and the interests of the Seminole
County Tax Collector in a similar manner to his representation of the Orange County Tax
Collector’s Office.
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222. On March 9, 2017, Dorworth and Ballard Partners registered to represent the
223. During the 2017 Florida legislative session, the agendas of both tax collectors
224. During the 2018 Florida legislative session, the Orange County Collector’s
225. On January 28, 2019, Dorworth registered to represent another Orange County
226. Despite earlier assurances that Greenberg pursue an agenda that would create
conflicts in Dorworth’s practice, Greenberg on multiple occasions attempted to push issues that
Dorworth had informed him he could not handle, despite his previous agreement and knowledge
of Dorworth’s conflict.
227. During their time working together, Joel Greenberg demonstrated an almost
comical absence of understanding as to how the process of advocacy before the government
worked.
228. Joel Greenberg would often demand that Dorworth, in his capacity as lobbyist for
the Seminole County Tax Collector’s Office, call various elected officials and threaten them with
various political consequences at the hand of Joel Greenberg if they did not do what he requested.
229. This behavior Greenberg demanded and expected is unprofessional and the results
of it would be disastrous for both the client and any lobbyist who followed said directions.
230. Numerous members of the legislature and lobbyists advised Joel Greenberg that
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231. At the conclusion of the 2019 Florida legislative session, Dorworth and Greenberg
agreed that future representation of the Seminole County Tax Collector’s office by Dorworth was
no longer wise and prudent and Dorworth was therefore withdrawn as the lobbyist for the Seminole
232. When Joel Greenberg tried to rehire Dorworth in September 2019, Dorworth
declined the opportunity to work with the Seminole County Tax Collector’s office.
234. On October 21, 2019, the Seminole County Tax Collector’s Office retained another
firm.
236. After Dorworth withdrew from representation at the end of the 2019 Session,
neither Dorworth nor any of his family members had business or financial dealings with Joel
Greenberg, the Seminole County Tax Collector’s Office, or any other members of the Greenberg
Racketeering Enterprise.
Dorworth.
238. In Joel Greenberg’s possession was a lengthy subpoena for records from the United
239. Joel Greenberg came to Dorworth to seek advice as to who to hire as legal
representation.
240. Dorworth read the subpoena and advised Greenberg to hire Vincent Citro “Citro”,
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241. Fourteen months later, on June 9, 2020, Joel Greenberg advised Dorworth that he
had received clearance from the Department of Justice for the cryptocurrency transactions and he
242. Joel Greenberg’s retrospectively obvious lie was plausible at the time because he
had faced other investigations and emerged unscathed with letters from the State Attorney
exonerating him.
243. Shortly thereafter, Joel Greenberg advised Dorworth that because he had resolved
all the criminal legal issues pertaining to his federal subpoena, he would pursue a second term as
Tax Collector.
244. Dorworth was unaware of looming stalking investigations and unlawful use of
another person’s identity investigations or any of the official misbehavior that led to Greenberg’s
245. Joel Greenberg claimed that his experience being investigated by the federal
government had given him new perspective, and that he wanted to serve a second term to make
things right.
247. On numerous occasions before, during and after his representation of the Seminole
County Tax Collectors Office, Joel Greenberg contacted Dorworth about helping Greenberg
248. The conversations originated from the suggestion by Joel Greenberg that Greenberg
reimbursement laws.
30
249. Dorworth, Joel Greenberg, Andrew Greenberg and others met to discuss some of
251. On other occasions, Joel Greenberg called Dorworth and informed him that he
spoken to his father about the need for Greenberg Dental to have a “fixer.”
252. Dorworth inquired as to what Joel Greenberg precisely meant when he said “fixer.”
256. Dorworth had not then seen Ray Donovan and was unfamiliar with the plot of the
257. The character Ray Donovan regularly kills people and exacts violence to cover up
unlawful behavior.
258. Dorworth inquired with others who had watched the show and ascertained that Ray
259. Dorworth called Joel Greenberg to inform him that asking for a Ray Donovan-
styled fixer could be interpreted as an attempt to hire an assassin, to which Greenberg responded,
261. Greenberg did not limit his actions on behalf of Greenberg Dental to the
262. Flouting the profound wealth of the Greenberg Racketeering Enterprise was of
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263. Greenberg would often make casual jokes about the size, market value, political
and legal strength of Greenberg Dental when expressing his ability to effectuate change and exact
264. Projecting wealth, status and power were key to Joel Greenberg’s persona.
265. Once, when discussing a female legislator who had sharply criticized Greenberg,
Joel Greenberg said to Dorworth she “has never been fucked by a $900 million cock. She will
266. The “$900 million cock” was Greenberg’s way of saying the that the resources of
267. The entity that Joel Greenberg referred to as being worth $900 million is Greenberg
Dental.
268. Joel Greenberg would also make comments about the nature of the Greenberg
Dental business.
269. Joel Greenberg would make statements about the race and income brackets of the
customers interspersed with racist rhetoric, once telling Dorworth that a long-time family joke had
been “Greenberg Dental fixes black kids’ teeth because the government pays them very well to do
so. If the government paid this much for making black people stop smelling so bad, we would
270. Joel Greenberg would make frequent jokes about Greenberg Dental’s reputation as
a “pill mill,” a term for an illegal facility that resembles a pain clinic, but regularly prescribes
monitoring, or documentation.
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271. For example, Joel Greenberg would say jokingly to Dorworth that “the reason my
parents are so rich is that they figured out how to make Medicaid pay for people’s opioids instead
272. Joel Greenberg once said to Dorworth that “the formula for Greenberg Dental’s
success is really quite straightforward. People really want opioids and Greenberg Dental is happy
to give them the maximum amount of opioids that they can and somebody else pays for it.”
273. Prescribing unnecessary painkillers and charging the same to government or private
insurance is wire fraud, mail fraud, health care fraud, false claim, and/or false statement, among
other crimes.
274. Joel Greenberg told Dorworth on several occasions that he had, in previous years,
275. Joel Greenberg told Dorworth that he obtained the oxycontin by using prescription
276. Joel Greenberg told Dorworth that Andrew and Sue Greenberg were fully aware
that Greenberg was stealing the prescription pads because their thinking was that at least
pharmaceutical grade Oxycontin would be safer than Oxycontin obtained on the streets for their
addict son.
277. Joel Greenberg owns $5,500,000 in AWG, Inc., stock, whose value is derived from
278. Dorworth has no first-hand knowledge of the finances, operations and policies of
Greenberg Dental and makes these pleadings upon information and belief based upon the
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I. Greenberg Stalks a Political Opponent and Unlawfully Uses His Identity.
279. On June 23, 2020, an indictment was unsealed charging Joel Greenberg with two
felony charges. Joel Greenberg was accused of stalking a political opponent and unlawful use of
280. Before dawn, law enforcement officers raided the home of Joel and Abby
Greenberg.
281. Joel Greenberg wrote and mailed anonymous letters to the administration of Trinity
283. Beute was the President of Save Rural Seminole, a nonprofit that focused on
284. Plaintiff Dorworth was an applicant for a Future Land Use and Zoning Change for
a mixed-use project “River Cross” in the rural area of Seminole County in 2018.
286. Dorworth then filed via counsel a Fair Housing Act Segregative Effect Disparate
287. In all the exchanges regarding River Cross, despite being on different sides of an
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https://www.orlandosentinel.com/news/crime/os-ne-joel-greenberg-case-stalking-charge-
envelopes-20210408-d6lwf56qfzgt7nsqgtq2owg4mq-story.html
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289. An FHA Segregative Effect lawsuit is statistic and expert driven and does not
290. At no point did Dorworth ever accuse anyone, Beute or otherwise, of being a
segregationist.
291. In the bio section for the fake Brian Beute twitter page for which Joel Greenberg
292. In placing “Segregationist,” Joel Greenberg implied to all concerned that Dorworth
293. There is no other reason known to Dorworth or others why Brian Beute would be
called a segregationist.
294. Despite fourteen months having passed between the River Cross vote and the letters
to Trinity Preparatory School with no confrontation between Beute and Dorworth, lawyers for
Beute offered Dorworth to the authorities as the most likely culprit due to the inclusion of the word
“segregationist.”
295. Joel Greenberg sought to misdirect others into thinking Dorworth led an
unprovoked attack on a private school music teacher over a disagreement over a land deal fourteen
months before, and not because Beute had just filed to run in the Republican primary against Joel
296. Joel Greenberg sent letters to Trinity Preparatory School alleging that a young male
student was aware of sexual relations taking place between Brian Beute and the unnamed
statement, but chose to put “Segregationist” for the purpose of convincing others that it was
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J. Post-Indictment and Resignation, Greenberg Racketeering Enterprise Takes Illegal
Steps to Conceal Joel Greenberg’s Ownership of, and Involvement in, AWG, LLC,
while Continuing to Finance Greenberg’s Unlawful Activities
297. On June 9, 2020, three days before his indictment was unsealed and he was arrested,
Joel Greenberg filed his Form 6 for the 2019 year in compliance with Florida election law
requirements that candidates for office file a Form 6 as part of their qualification process.
298. However, the Greenberg Racketeering Enterprise magically made $5.5 million of
AWG, Inc. stock and $251,513 retroactively disappear in an amended report in a ham-handed
effort to conceal the source of resources utilized to conduct the Greenberg Racketeering Enterprise.
299. On the June 9, 2020 Form 6, Joel Greenberg again lists his net worth on the specific
date of December 31, 2019 at $5,857,135, the identical amount of his 2018 Form 6.
300. On the June 9, 2020, Form 6, Joel Greenberg again lists the value of his AWG, Inc.
301. On his June 9, 2020, Form 6, Joel Greenberg states that he earned $140,263 from
302. On his June 9, 2020, Form 6, Joel Greenberg utilizes the date of December 31,
2019.
303. On his June 9, 2020, Form 6, Joel Greenberg claims that as of December 31, 2019,
over five months before, the aggregate value of his household goods and personal effects was
$149,350.
304. On his June 9, 2020, Form 6, Joel Greenberg claims that as of December 31, 2019,
over five months before, the value of his jewelry and furniture was $85,500.
305. On his June 9, 2020, Form 6, Joel Greenberg claims that as of December 31, 2019,
over five months before, that he had $224,000 in a Merrill Lynch Bank Account.
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306. On his June 9, 2020, Form 6, Joel Greenberg claims that as of December 31, 2019,
over five months before, he had $52,000 cash in an account at Fairwinds Credit Union.
307. On his June 9, 2020, Form 6, no ownership of a primary residence or mortgage for
308. On June 23, 2020, the Department of Justice unsealed an indictment against Joel
309. After posting bail, Joel Greenberg resigned from the office of tax collector.
310. On September 3, 2020, Greenberg submitted an amended Form 6 for 2019 in which
311. The amended Form 6 still stated that the effective date for the information provided
312. On the amended Form 6 dated September 3, 2020, Greenberg’s stated net worth
from December 31, 2019, decreased from $5,857,135 to $322,030, a retroactive reduction of
94.5%.
313. On the amended Form 6 dated September 3, 2020, Greenberg’s stated ownership
314. On the amended Form 6 dated September 3, 2020, Greenberg’s stated income from
AWG retroactively from the previous calendar was reduced from $391,776 to $175,000.
315. On the amended Form 6 dated September 3, 2020, Greenberg’s cash in a Merrill
Lynch bank account on December 31, 2019, was reduced from $224,000 to zero.
316. On the amended Form 6 dated September 3, 2020, Greenberg’s cash in a Fairwinds
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317. On the amended Form 6 dated September 3, 2020, Joel Greenberg’s Jewelry,
Furniture and Household Items on December 31, 2019, decreased from $85,500 on the June Form
6 to $60,000.
318. On the amended Form 6 dated September 3, 2020, Joel Greenberg lists a primary
319. On the amended Form 6 dated September 3, 2020, Joel Greenberg lists $100,000
320. After Joel Greenberg’s misconduct came to light, the Greenberg Racketeering
Enterprise sought to conceal the total assets of Joel Greenberg to keep the assets for itself.
321. The reductions demonstrate that the Greenberg Racketeering enterprise had control
over the resources allocated to Joel Greenberg through his ascent into the Tax Collector’s Office
in 2016, throughout his criminal enterprise in 2017 to 2020 and afterwards, in paying for the fines
and restitution and wrongdoing of Joel Greenberg from the assets of the Greenberg racketeering
exercise.
322. Rebekah Dorworth and Abby Greenberg remained friends after the first arrest of
Joel Greenberg, though they had not been close for quite some time.
323. Abby Greenberg vacationed at the JW Marriott Orlando Grande Lakes, paid for by
Greenberg’s parents, while she processed the criminal status of her then-husband days after her
324. Abby Greenberg extended an invite to Rebekah Dorworth to visit the resort pool
with her daughter. Abby Greenberg and Rebekah Dorworth’s daughters are close in age.
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325. Abby Greenberg proactively informed Rebekah Dorworth that Joel Greenberg
326. Rebekah Dorworth agreed to support Abby Greenberg because her husband had
327. While Rebekah Dorworth was on her way to the JW Marriott, Abby Greenberg
revealed Joel would be coming to the hotel, but stated he would be golfing. Abby insisted Joel
328. Despite two felony charges pending and no job, the Greenberg Racketeering
Enterprise continued its support and provided a penthouse golf and pool weekend for Abby and
Joel Greenberg.
329. Rebekah Dorworth expected to find a burdened and distraught Abby Greenberg,
331. When asked how she was coping, Abby Greenberg smiled and stated seriously to
Rebekah, “[her] marriage had never been better” and referenced the spending money, vacations,
and gifts Joel Greenberg’s parents were “taking care of” since Joel’s indictment and the
Greenbergs’ resulting fear that Abby would move away with their two grandchildren.
332. Abby Greenberg consistently used the children to exact sums of money and favors
from Sue and Andrew Greenberg. When pregnant with their second child, son Micah, Abby often
gloated that the power would be shifting now to her because she had the Greenberg family’s male
heir.
333. Upon arrival at the JW Marriott, Rebekah Dorworth and her daughter were to meet
Abby at the hotel pool, but were asked to come upstairs while Abby finished changing.
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334. Yet again, Abby Greenberg’s warranties regarding the presence and intentions of
335. Joel Greenberg was in the penthouse hotel suite and greeted Rebekah Dorworth.
336. Joel Greenberg initially and in earshot of his wife, informed Rebekah Dorworth
that the charges were silly and that he was confident he would beat them.
337. Later, while Abby Greenberg and Rebekah Dorworth were at the pool, Joel
Greenberg arrived and cornered Rebekah Dorworth, where his demeanor and tone changed
338. Joel Greenberg demanded that Rebekah Dorworth convince Congressman Matt
Gaetz (“Gaetz,”) and Dorworth to pursue and obtain a preemptive pardon for Joel Greenberg for
his crimes.
339. Gaetz and Dorworth served in the Florida House of Representatives together from
340. In 2016, Gaetz ran for and was elected congressman from the First District of
Florida.
341. In office, Gaetz became a staunch ally in Congress of President Donald Trump
(“Trump”).
342. Gaetz and Trump were known to be close political allies. As President of the United
343. Joel Greenberg was currently indicted of two felonies but was aware of pending
investigations that would lead to a total of 33 felony counts against Joel Greenberg.
344. Greenberg told Rebekah Dorworth that “it would be better for everyone if I (Joel
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345. He stated that Donald Trump should want to give him a pardon because Joel
Greenberg triggered the release of WikiLeaks by posting a message on a billboard that triggered a
346. Joel Greenberg suggested that due to his alleged involvement in this release, he was
347. Dorworth has no knowledge of any involvement of Joel Greenberg in any way
involving WikiLeaks, and lacks understanding as to how this could create some debt to Greenberg.
348. Rebekah Dorworth considered the comments and the overall demeanor of Joel
349. Joel Greenberg stated that he was concerned that his father, Andrew Greenberg,
had criminal exposure because of Bitcoin investments, which Rebekah Dorworth assumed was
350. Joel Greenberg stated that Gaetz should know that investigators were looking
through his Venmo records and that “he didn’t know what any of them would say.”
351. “He didn’t know what any of them would say” was a common refrain from Joel
352. If Joel Greenberg had any knowledge of information or testimony that would have
been damaging to Dorworth or Gaetz, he would have presented the information in an attempt to
353. Rebekah Dorworth repeatedly attempted to change the conversation and removed
herself with Abby to a different part of the hotel pool. Joel Greenberg continued the conversation
and followed, as well as brought up various sexual activities that he and Abby were engaged in
with other couples, “that he wouldn’t want coming out from his text messages.”
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354. Rebekah and Chris Dorworth have an exclusive marriage, and until the JW Marriott
incident, Rebekah Dorworth was unaware that Joel and Abby were engaged in an open marriage
lifestyle, although Joel had previously informed Chris Dorworth of this fact.
355. Rebekah confronted Abby about what Joel had said about what they were engaged
in. She laughed at first, but then stated that “it wasn’t something that she wanted to be a part of,
356. On the drive home, Rebekah Dorworth phoned Gaetz and informed him of
wider political events, and to ask him what all this meant and what was going on, being previously
357. Gaetz responded to Rebekah Dorworth that, “it appears Greenberg is trying to make
358. Gaetz further expressed disbelief that, “Joel Greenberg would attempt to extort a
359. Rebekah Dorworth concluded the phone conversation and returned home to recount
360. The resources used to procure the hotel suite utilized by Joel Greenberg come from
361. Dorworth, having heard that Greenberg had attempted to extort and blackmail
Dorworth and Gaetz via Dorworth’s wife, requested an in-person meeting with Joel Greenberg to
confront him.
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L. Greenberg again Extorts Dorworth for a Pardon
362. Shortly thereafter, Dorworth and Joel Greenberg met for breakfast at “Another
363. Dorworth was, at this time, only aware of Greenberg’s charges related to stalking
364. Dorworth confronted Joel Greenberg about the threatening words and manner he
365. Joel Greenberg then alerted Dorworth that his personal situation had grown more
dire as he was under investigation for having sex with A.B.when she was under the age of 18.
366. Dorworth asked what exposure Joel Greenberg had in the looming investigations.
367. Like Greenberg conveyed to Rebekah Dorworth, he told Chris Dorworth he was
optimistic that the issue could be handled because he was paying for A.B.’s attorneys and
anticipated that the Greenberg Racketeering Enterprise could make her not testify by paying her
368. At first, Greenberg made jokes belittling A.B., calling her “a porn star with braces”
and lamenting that “she’s already proven she will do literally anything for money.”
369. Greenberg’s then referred to deviant acts performed by A.B. on the internet for
money and then said “. . . I’m pretty sure she’ll do what I tell her to for legal fees.”
371. The nature of the videos includes some of the more extreme elements of
pornography.
372. Dorworth asked Joel Greenberg if Dorworth had ever met the girl in question, to
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373. Greenberg became insistent that Dorworth persuade Gaetz to obtain a pardon for
374. When Dorworth explained that it neither could nor would not happen, Greenberg
grew irritable and insistent that if a pardon was not issued, he faced extensive exposure and that
he would seek vengeance on those who turned a blind eye to him at a time of need.
375. Joel Greenberg stated repeatedly that he did not believe it would be very difficult
376. Joel Greenberg insisted that if Gaetz wanted to persuade Trump to extend a pardon
377. Dorworth advised that he had spoken with Gaetz after Greenberg had attacked
Rebekah and that Gaetz’s direction to Dorworth to relay to Greenberg was, “you’ve done some
very bad things and have some bad times ahead but there is nothing I can do to help you.”
378. Joel Greenberg then pivoted his strategy, stating that the Greenberg Racketeering
Enterprise was “willing to pay any amount of money to Ballard Partners to get him (Joel
379. Dorworth informed Greenberg that due to the nature of the crime, human sex
trafficking of a minor, that Dorworth was unwilling to accept that engagement or propose it to his
superiors.
380. Joel Greenberg emphasized the value of Greenberg Dental and the resources it
could summon to exonerate Joel Greenberg from further responsibility for his racketeering crimes.
381. Dorworth again declined and informed Joel Greenberg that irrespective of the
wealth and resources of Greenberg Dental, nobody would be able to procure a preemptive pardon
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382. Joel Greenberg begged Dorworth to present the offer to Dorworth’s boss, and
383. Joel Greenberg grew very angry that Gaetz and Dorworth were unwilling to
384. Joel Greenberg evoked the name of Roger Stone, who had his sentence commuted
by Trump, then received a pardon, as evidence that such activities were achievable.
385. Dorworth responded that while Trump did not know Joel Greenberg at all, he had
known Roger Stone for decades and had been personal friends with him.
386. Dorworth further responded that Stone’s alleged crimes stemmed from a later
debunked investigation into whether Ukraine interfered in the 2016 presidential election and that
Joel Greenberg’s crimes were stalking and potentially human trafficking of a minor.
387. Dorworth was unaware of the thirty other felonies that Joel Greenberg would be
388. Dorworth further elaborated that despite the decades of friendship between Roger
Stone and Trump, Stone was charged, tried, convicted, and sentenced, and his appeal was filed
and lost before Trump commuted Stone’s sentence just before his surrender date to the Bureau of
Prisons.
389. Joel Greenberg seemed to accept the explanation that even if a pardon was to be
miraculously issued, he would need to be sentenced, handle the appeal, and then possibly pursue
a pardon, but that a preemptive pardon was not something he could reasonably expect given the
390. Dorworth advised Greenberg that because of the nature of the crime he was facing
and Dorworth having an adult daughter, Dorworth could no longer talk to or be associated with
45
someone accused of human trafficking because of the message it sent to Dorworth’s adult
daughter.
391. That was the last time Dorworth saw Joel Greenberg or communicated with him
392. Joel Greenberg, having become convinced that the preemptive pardon was not
viable, turned his attention to having the Assistant United States Attorney terminated to avoid
future prosecution.
393. Joel Greenberg incorrectly believed that Gaetz could effectuate the termination of
394. Joel texted Dorworth to request that the prosecutor investigating him be fired.
395. Copies of the screenshots were provided by Dorworth via counsel to the
46
396. Dorworth and Vincent Citro (“Citro”), had been acquaintances over the previous
16 years.
47
401. Joel Greenberg had just informed Dorworth that Citro had told him “everyone
402. However, Citro’s response that Joel Greenberg said that Dorworth might want a
lawyer directly contradicts his own client’s statement from 37 minutes before that “Vince says
48
403. If Citro had warned that everyone was going to need a lawyer, he would have no
404. Based on 16 years of friendship, if Citro had been aware of any accusations of
wrongdoing against Dorworth, need for an attorney, he would have recommended counsel, not
405. Had Dorworth been aware of any wrongdoing on his part that necessitated any
406. Joel Greenberg lied to Dorworth about Citro’s belief that everyone would need a
lawyer to spur and motivate him to participate in getting the Assistant U.S. Attorney fired.
408. Greenberg’s statement that he was paying the attorney fees for A.B. is consistent
with his threat expressed to Dorworth from Another Broken Egg that “she (A.B.) would do
409. Dorworth’s rejection of Greenberg’s request for help spurred the efforts of
410. Joel Greenberg also stated that he was paying the attorney’s fees for A.B..
411. According to Joel Greenberg’s final Form 6, all of Joel Greenberg’s resources came
412. Thus, Greenberg Racketeering Enterprise was paying for A.B.’s legal fees, not Joel
Greenberg.
N. Joel Greenberg Affirmatively States that Dorworth Has “Done Nothing Wrong.”
49
413. After Citro’s 9:16pm text clarifying that it was Joel Greenberg and not Citro who
was advising the need for attorneys, Dorworth confronted Greenberg in writing:
414. Dorworth texted Greenberg “I called Vince. I have nothing to do with any of this
and think it is incredibly uncool you are trying to be part of it, Joel. Not. Fucking. Cool.” (Supra)
50
416. Joel Greenberg states “I know you aren’t” in response to Dorworth’s assertions
twice stated assertion that Dorworth is “not in involved in this in any way, shape or form.”
417. Throughout the totality of the text exchange, at no point does Greenberg suggest or
push back that Dorworth did anything inappropriate, instead saying “You’ve done nothing wrong.”
418. As Greenberg was fabricating the accusations and executing the fraud paid for
entirely by A.B., Dorworth could not be aware of the nature of the allegations that Greenberg was
claiming.
419. As Dorworth had never met A.B., he did not know her age, appearance, or any other
420. As Dorworth has never in his life been a member of any dating website, specifically
421. Joel Greenberg begins to reveal the nature of his allegations with the suggestion
422. If Dorworth was aware of instances where a woman who was part of a human sex
trafficking investigation who had “partied” at his home was about to give testimony about said
parties, Dorworth would have been highly motivated to secure legal counsel as soon as possible.
423. Dorworth never “partied” with A.B. at his house or anywhere else.
424. Greenberg reveals that the Greenberg Racketeering Enterprise is paying for A.B.’s
attorneys, confirming his statements from Another Broken Egg that he controlled her testimony
because the Greenberg Racketeering Enterprise, specifically Andrew Greenberg and Sue
Greenberg was going to “pay her off to make that problem go away.”
425. Dorworth has no Venmo or other financial app history with any woman in his entire
51
426. Greenberg was asking Dorworth “I need help here” to assist in the termination of
an Assistant United States Attorney, despite the ridiculousness and impossibility of the request.
427. If Greenberg was aware of ANY wrongdoing on any front conducted by Dorworth,
he would have presented the information instead of saying “you’ve done nothing wrong.”
428. Upon Dorworth’s refusal to participate in the termination of then Assistant U.S.
Attorney, Greenberg then followed through on this promise to Dorworth to “make this a problem
for everyone” by claiming that Dorworth, Congressman Matt Gaetz and others were involved in
429. The Greenberg Racketeering Enterprise resorted to accusing others of having sex
with a minor in a fashion identical to the way they accused Brian Beute of having sex with a minor
but instead of an anonymous note, they deployed lawyers paid for exclusively by the Greenberg
Racketeering Enterprise.
430. Joel Greenberg knew Dorworth and “others” would need to lawyer up because he,
through control of A.B.’s testimony by paying her attorney’s fees, would offer untruthful
testimony.
O. Greenberg Is Indicted for the Human Trafficking of A.B., then a Minor; Greenberg
Falsely Implicates Dorworth
431. On August 19, 2020, a superseding indictment added a single count of sex
432. A.B. is the woman Joel Greenberg pled guilty to human trafficking.
9
As described earlier in this Complaint, a “sugar daddy” is a rich older man who lavishes gifts
upon one or more young women in return for sex.
52
434. According to the Daily Beast, Joel Greenberg was a prolific user of
www.seekingarrangement.com.
www.seekingarrangement.com.
old.
437. A.B. was 17 when she registered and lied about her age.
actions of the Greenberg Racketeering Enterprise, Joel Greenberg followed through on his promise
439. Dorworth has never, to the best of his recollection, met, interacted, communicated,
440. Dorworth was aware of the existence of a person with the first name of A.B. via a
tax collector employee and friend and former roommate of Joel Greenberg, who Dorworth knew
to be dating a K.M..
441. Dorworth did meet the K.M. in her capacity as the friend’s girlfriend.
442. On a couple of occasions, the friend asked if his girlfriend’s roommate was
443. Dorworth agreed and said it would be fine, not knowing a single defining
444. Dorworth does not know if A.B. ever joined the girlfriend or the friend.
445. Upon review of photographs of the person Dorworth now knows to be A.B., he
53
446. At no time did Dorworth ever have a friendship, sexual or non-sexual relationship
with A.B..
pornography website, and to star in numerous porn videos where she performs under stage name.
448. In reporting on why the Department of Justice decided not to bring charges against
Dorworth related to sex trafficking a minor, CNN quoted sources claiming that the
untrustworthiness of Greenberg and A.B. resulted in the DOJ closing the investigation.
P. Joel Greenberg Engages in a Stand Off with Law Enforcement and Is Jailed
Pending Sentencing
449. On February 28, 2021, Joel Greenberg broke terms of his pretrial release and
traveled outside the Middle District of Florida to look for Abby Greenberg at her mother’s home
450. Joel Greenberg broke into the mother’s home looking for Abby Greenberg, who
was out getting coffee, startling a friend of Abby Greenberg’s who was lying in bed.
451. Abby Greenberg’s mother called the police, who arrived on the scene.
452. After the reporting officer was unable to contact Joel Greenberg’s federal parole
455. Abby Greenberg contacted law enforcement, who arrested Joel Greenberg for
54
456. Greenberg barricaded himself into his personal residence and made suicidal
statements including “stating at various times that he would take pills, utilize firearms, and that he
457. Joel Greenberg threatened to have explosive devices and expressed a willingness
458. Finally, after hours of standoff and negotiation, Joel Greenberg turned himself into
custody.
459. Incarcerated pending sentencing, Joel Greenberg began offering false testimony
460. Gaetz was and is known to be close ally and adviser to former President Donald J.
Trump.
461. Ballard Partners was known throughout the press and throughout the country to be
462. Joel Greenberg believed that Gaetz and Dorworth could obtain relief for Greenberg.
463. Joel Greenberg lacked the knowledge of civics to realize that a President of the
United States cannot merely, at his or her own discretion, directly terminate an Assistant United
States Attorney.
465. Dorworth sat with two Assistant U.S. Attorneys and four agents of the Federal
Bureau of Investigation.
10
https://www.tampabay.com/news/2021/04/07/joel-greenberg-claimed-to-have-explosives-
during-hours-long-negotiation-records-say/
55
466. Dorworth’s legal counsel, Richard Hornsby, spoke with Todd Gee and was advised
that someone claimed Mr. Dorworth engaged in sexual activity with A.B. prior to her 18th
birthday.
467. Dorworth also provided the screen shots of Joel Greenberg’s threat and demand to
have the Assistant U.S. Attorney Roger Handberg fired, along with Joel’s remark that the
468. Dorworth also provided the text exchange with Citro showing that Greenberg had
470. On April 30, 2021, Dorworth was polygraphed at the Office of Richard Hornsby,
471. A report was generated summarizing the results of the Dorworth Polygraph Report.
The Dorworths and the Greenbergs began socializing on a regular basis. Dorworth
already knew Congressman Matt Gaetz, from their time serving together in the
Florida legislatures. Greenberg was subsequently indicted on a wide array of
federal charges. Dorworth advised that Greenberg has subsequently dragged Gaetz
and himself into the federal probe, because Ballard Partners was closely affiliated
with the Trump Campaign, and Greenberg though this would help him obtain favor
with federal authorities. Dorworth advised he recently resigned from Ballard
Partners due to the negative press involving Greenberg’s allegations.
...
Dorworth advised that around ten couples would show up as the parties progressed
and any girls that did show up “were usually attached to a guy.” Dorworth as casual
parties out by the pool with casual talking, food, and music. These parties would
usually start out in the mid afternoon and progress into the early evening and were
attended by friends, co-workers, politicians, business, and real estate professionals,
etc.
56
Dorworth was asked regarding allegations that a minor female had performed oral
sex at parties hosted by Dorworth at his home. The minor female was associated
with Greenberg in early 2017, Greenberg learned the girl was under the age of 18.
Dorworth identified the minor female as [A.B.]. Dorworth was asked whether he
knew [A.B.] and he could not recall if he had met her. Dorworth advised [A.B.]
was the roommate of K.M., who is the girlfriend of Joe Ellicot, who is Joel
Greenberg’s best friend and Chief Deputy in the Seminole County Tax Collector’s
Office.
Dorworth advised sometime in 2017, he was asked by Joe Ellicot if [A.B.] could
come by for one of the parties at his house and he advised he had no recollection as
to whether she ever showed up. Dorworth advised it is possible that she did come
by, however, he does not recall her attendance at his home. Dorworth advised he
subsequently looked up [A.B.] online and learned that she was in the porn industry.
After seeing [A.B.] online, Dorworth has no recollection as to whether [A.B.] ever
attended any of the parties at his home in 2017, or any other time.
473. The questions and answers during the Polygraph Examination were as follows:
Question #1 – “In 2017, did you have any sexual contact with [A.B.]? Dorworth
Answer: No”
Question #2 – “In 2017, did you have any contact with [A.B.] for sexual reasons?
Dorworth answer: No”
Question #3 – “During parties at your house in 2017, have you had sexual contact
with anyone other than your wife? Dorworth answer: No”
475. Although the year was limited to 2017 because of A.B.’s age, Dorworth never had
476. The polygraph report was conducted by Curtis Holleman, former FBI special agent
and polygraph administrator who currently does polygraph work for U.S. Customs and Homeland
Security.
57
478. The “Test Results” Section of the Report states simply that “[e]ach of the relevant
480. Dorworth did not have any contact, to say nothing of sexual contact, with A.B., and
did not have any exchange of resources with someone who was, in the words of U.S. District Judge
Gregory Presnell, “was essentially a prostitute.” December 1, 2022 Sentencing Trans. at 43:1-2.
481. Greenberg has previously pleaded guilty to falsely and anonymously accusing a
482. Using the resources of the Greenberg Racketeering Enterprise, Greenberg did the
483. Dorworth paid a total of $3,000 for the first polygraph to defend his reputation
484. Dorworth presented to the Assistant U.S. Attorney a copy of the polygraph
58
R. Dorworth Is Forced to Exit Ballard Partners because of Greenberg Allegations
485. Dorworth was the Managing Partner of the Central Florida Office of Ballard
Partners from 2012 until he was forced to leave in the wake of Greenberg’s false allegations against
him.
486. Dorworth was a prominent member of the Ballard Firm’s Tallahassee practice,
487. Dorworth earned seven-figure compensation during his time at Ballard Partners.
488. Dorworth had no other personnel issues or conflicts that would have led to his
termination or resignation.
489. Dorworth and his employer mutually agreed that the scrutiny of the allegations and
subsequent federal investigation would spill onto clients and their issues and that it was not feasible
491. Because of the defamatory statements of Joel Greenberg and the Greenberg
492. Upon information and belief, Greenberg deliberately leaked these allegations to the
493. The lies and attacks set forth by Joel Greenberg and funded by the Greenberg
Racketeering Enterprise came only because Dorworth was unwilling to threaten a U.S.
Congressman on Joel Greenberg’s behalf to obtain a pardon and because Dorworth was unwilling
(and frankly totally unable) to procure termination of the prosecutor investigating Greenberg.
59
494. Having passed a polygraph regarding any sexual behavior with A.B., the
495. In September 2021, during dinner Dorworth received a phone call from Gaetz.
496. Gaetz told Dorworth he had been telephoned by his ex-girlfriend, Brianna Garcia
(“Garcia”).
497. Dorworth and his wife had socialized with Gaetz and Garcia while Gaetz and
500. Garcia had interned in the U.S. Congress and worked on a statewide gubernatorial
campaign.
501. Garcia was employed as a policy analyst at the Florida Department of Education.
503. Gaetz advised that Garcia had spoken to A.B. and was informed that A.B. had been
504. Gaetz had no understanding of the context of how Dorworth or Gaetz were
505. Dorworth contacted Garcia to further understand the context of how Dorworth had
been mentioned.
506. Garcia called Dorworth back the next morning and advised that she believed it had
507. In Dorworth’s text exchange with Greenberg in which Greenberg stated, “I need
help with this” and wherein he advised that the Assistant U.S. Attorney “needs to get fired” and
60
wherein he stated he was paying A.B.’s legal bills, he specifically said “I would think you’d want
to at least have a heads up if some chick says she partied at your house or something.”
508. Dorworth knew that Greenberg was making good on his promise to involve others
through perjury and false testimony via A.B., whose attorney fees were being paid by the
Greenberg Racketeering Enterprise and who Greenberg asserted would be compensated by the
509. Dorworth’s first call was to his wife, Rebekah Dorworth, to advise her of the news,
511. Nor did Dorworth attempt to persuade anybody to say anything to anyone.
512. Dorworth’s phone call was purely informational, and revealed key information that
further bolstered Dorworth’s belief that Joel Greenberg was attempting to encourage A.B. to
perjure herself.
513. Dorworth’s counsel Richard Hornsby reached out to U.S. Attorney Todd Gee to
514. Assistant U.S. Attorney Todd Gee informed Hornsby that the scope of the
investigation had turned to whether justice was obstructed over the course of a phone call between
515. Recognizing that the Greenberg Racketeering Enterprise was fully engaged in
defaming Dorworth and Gaetz, Dorworth sought a second polygraph to dispel any notion that he
516. The interview was conducted at the Law Offices of Richard Hornsby.
61
517. Curtis Holleman, the retired FBI Special Agent of 35 years currently doing contract
work for the U.S. Customs Authority and the Department of Homeland Security, conducted the
examination.
On September 28, 2020, Dorworth was having dinner with (a friend) at Fishbones
Seafood Restaurant in Lake Mary, Florida, when he received a phone call from US
Congressman Matt Gaetz…. “Hey just to put it on your radar, that he (Gaetz) just
talked to Bree (Brianna Garcia) and that she had called Gaetz to give him a heads
up that a bunch of people were mentioned during a Federal Grand Jury and that you
(Dorworth) were one of them.
Dorworth advised that he trusted Gaetz but wanted to verify this information,
therefore, stepped away from the dinner table and called Briana Garcia to confirm
whether or not he had been mentioned by the grand jury, as Gaetz had said. During
their brief conversation, Briana said she could not provide any details, but “a bunch
of people were mentioned and you were one of them.” Briana could not provide
any specifics when he (Dorworth) asked her “where he was at in this thing?”
Dorworth advised it was Briana’s feeling that Dorworth was not the subject of an
investigation, therefore he was not concerned. Dorworth advised that he took a
picture a few hours later at the restaurant which depicts him in a jovial mood.
The next day Briana called Dorworth back and told him that she forgot to mention
“I think they asked questions about your house and displayed drivers licenses of
Dorworth, Gaetz and others.” Dorworth advised that he had an idea as to who the
others might be, but did not know for sure. Briana told Dorworth that [A.B.] and
K.M. had appeared before the Grand Jury.
Dorworth advised “he never asked anyone to say anything to these girls and that he
was only in the mode of trying to obtain information.” Dorworth advised he had
no idea that anyone had appeared before a Federal Grand Jury until he received the
phone call from Gaetz. Dorworth advised that he never asked that anyone relay
any type of message to [A.B. or K.M.].
519. As Dorworth had never met A.B., it is certainly understandable that Dorworth
would want as much information as possible about why his name was being mentioned before a
520. Garcia’s revelation that “I think they asked questions about your house…,” meshed
perfectly with the language used by Joel Greenberg in his text exchange with Dorworth.
62
521. During that exchange, Greenberg stated at 9:43pm, “Understood. My only concern
is that I don’t know what could possibly come out of their mouths, and if any of them where we
met etc. I would think you’d want to at least have a heads up if some chick said she partied at your
house or something.”
522. Greenberg also confirmed to Dorworth in that text exchange that “[y]ou’ve done
nothing wrong.”
questions:
Question Number One was “Did you ever make any effort to get K.M. or A.B. to lie to the
Grand Jury (Dorworth) Answer: No”
Question Number Two was “Did you ever do anything to get K.M. or A.B. to lie to the
Grand Jury? (Dorworth) Answer: No”
Question Number Three was “Did you ever ask Briana (Garcia) to discourage anyone from
cooperating with the government? (Dorworth) Answer: No.”
524. Holleman determined there was “NO SIGNIFICANT REACTIONS to the relevant
questions and that there was less than a .034 probability this report was a produced by a deceptive
person.”
U. Joel Greenberg Gives False Testimony to the 18th Circuit State Attorney Falsely
Accusing Dorworth of Illegal and Immoral Behavior through Resources Provided
by The Greenberg Racketeering Enterprise
528. Human Trafficking of a Child for Sex Purposes carried with it a ten-year minimum
63
529. Aggravated Identity theft carried a two-year minimum mandatory consecutive
prison sentence.
530. The Greenberg Racketeering Enterprise thus channeled energy and resources into
531. Joel Greenberg began cooperating with the authorities and provided substantial
cooperation that led to the arrest of Michael Shirley, Joe Ellicott, Keith Ingersoll, and others.
532. Those charged with crimes and those convicted were all friends of Joel Greenberg’s
533. In other words, it was only the people that Joel brought into his schemes who were
prosecuted.
534. The “political” names offered by Greenberg have not been charged with anything.
536. In fact, after the charges had pended for over a year before his plea, Greenberg’s
sentencing was further continued numerous times over nearly a year and a half from mid-2021
537. Despite this, none of Greenberg’s accusations against any of the “political” names
were charged.
538. In other words, Greenberg did not help solve any crimes other than the crimes that
he conducted.
539. The political names of Dorworth and Gaetz were offered by Joel Greenberg because
he believed they could have procured him a pardon if they had tried hard enough.
540. Having pled guilty to six felonies, Joel Greenberg continued fulfilling his promise
64
541. Greenberg’s failure to bring criminal prosecution through fraudulent testimonial
County Campaign for the State Senate, Dorworth was not involved in the campaign of Jestine
543. Dorworth has never met Jestine Iannotti nor communicated with her directly or
indirectly.
544. Dorworth did not participate in the recruitment of Jestine Iannotti in any way.
546. The 18th Circuit State Attorney released redacted testimony of a jailhouse interview
conducted with Greenberg by Stacey Sammons, Chief Assistant State Attorney for the 18th Circuit
547. In the 119-page document, Greenberg continuously lies about Dorworth and others
in the community to spur investigation and to defame and libel the name of Dorworth and others.
548. Salmons warned Greenberg to testify truthfully at the beginning of the interview:
Salmons: When an assistant state attorney puts an individual under oath, what
you’re doing is technically testifying before me, which means that this becomes an
official proceeding for purposes of the perjury statute. If you lie to a prosecutor
under oath in this type of environment, even though its somewhat relaxed – we’re
conducting an interview, and it’s with regard to a material matter; you could be
charged with a third-degree felony of perjury. Do you understand that?
Greenberg: I do.
Salmons: I say that not because I think you’re going to lie to me, but because I want
you to understand that although this is a somewhat relaxed environment by way of
the interview, what you are doing is tantamount to testifying in court before a judge.
Do you understand that?
Greenberg: I do.
65
Jailhouse Interview 2:23:43.
549. At no point was Joel Greenberg privy to any conversation with Ben Paris,
Foglesong, Dorworth and Jason Brodeur because no conversation with those people ever took
550. At no time did Dorworth ever converse with Greenberg about participating in the
551. Furthermore, at the time of the alleged conversations, Joel Greenberg was thought
to be under investigation by the U.S. Secret Service and had faced numerous investigations from
553. While the conversations described above did not happen, they certainly would not
554. Greenberg traces the idea that he would recruit a third-party candidate to run to a
555. Dorworth did not attend the 2019 Reagan Day dinner.
I was -- was -- I was I’d planned to do the same thing. I did eventually have a third-
party candidate get in. It was a -- a female. Their strategy was -- and this goes back
to the conversation in 2000 – late 2019 at the Reagan Day dinner where it was
myself, Bob Cortez (sic), um -- what was her name? The lady running against Val
Demings last time.
557. Bob Cortes is a former city councilman and mayor of Longwood, Florida, who
66
558. Bob Cortes is the Senior Administrator for Community Affairs for the Seminole
County Sheriff’s Office and is the chairman of the Board of Trustees for Seminole State College.
559. Dorworth was physically unable to participate in this conversation as he was not in
560. Nor was Frank Artiles present at the 2019 Seminole County Reagan Day Dinner.
561. Dorworth, to the best of his recollection, has never met or communicated with
Vennia Francois, the “lady running against Val Demings last time (in 2020).”
562. Joel Greenberg states affirmatively that Bob Cortes would “corroborate what I’m
saying.”
564. Greenberg claims he was present in the presence of Dorworth, Jason Brodeur, Ben
Paris and Foglesong during political conversations “at least a dozen times.” Jailhouse Interview
14:40.
565. Joel Greenberg claims to have been present at meetings with various members of
566. At the time, Greenberg was under investigation by the U.S. Secret Service.
567. Joel Greenberg had provided Dorworth a copy of the subpoena investigating
numerous crimes.
568. Joel Greenberg had been investigated by the 18th Circuit State Attorney for
569. Joel Greenberg had made national news with defamatory statements about
Muslims.
67
570. Joel Greenberg asserted that Richard Anderson, Jason Brodeur, Joel Greenberg,
Eric Foglesong and Ben Paris participated “in as many as a dozen” conversations about political
events, including the inclusion of a third-party candidate in the race against Brodeur.
571. No conversations with those participants ever took place in the presence of Joel
573. Jason Brodeur (“Brodeur”) is a member of the Florida State Senate and a resident
of Seminole County.
574. Ben Paris (“Paris”) is a former city commissioner and mayor of Longwood, Florida.
577. Greenberg asserted that Setzer and Anderson would corroborate conversations with
Foglesong, Brodeur, Dorworth and Paris. Jailhouse Interview 15:23-18:12; 15:48 (Anderson);
17:34 (Setzer).
578. Joel Greenberg’s assertion that Setzer and Anderson would confirm these
579. The reputation of Joel Greenberg at the time of these alleged conversations was not
580. The meetings referenced by Greenberg did not happen, with or without Greenberg.
581. Greenberg’s legal representation was paid for by the Greenberg Racketeering
Enterprise.
68
582. Greenberg’s attempts to involve and smear Dorworth and others were part of an
attempt to cause legal damage to Dorworth because Dorworth failed to procure a pardon.
583. The State Attorney of the 18th Florida Circuit announced indictments against
584. After discussing alleged conversations involving Dorworth and others Greenberg
585. Greenberg states “My humble opinion is it’s absolutely connected. These guys are,
for the most part, extremely organized with what they do. They’re very intelligent. And they
586. The very next paragraph, upon information and belief, Greenberg describes
587. Greenberg called the group a mafia to further encourage law enforcement
investigation in line with the efforts of Joel Greenberg and the Greenberg Racketeering Enterprise
588. A very intelligent, extremely organized “mafia” would not include in any improper
conversation someone who was known to be under investigation by the U.S. Secret Service,
589. The conversations that are described uniformly did not happen, but the suggestions
that the people who had them were both (1) intelligent and (2) included troubled Joel Greenberg
590. Greenberg also falsely alleged Dorworth had an extramarital affair. On two separate
occasions during his interview, Joel Greenberg suggests Dorworth was having an extramarital
affair with his female attorney. Jailhouse Interview at 31:32-41, 100:28-42. These statements
69
became part of Greenberg’s discoverable file with the Florida Department of Law Enforcement
and, as a result of discovery requests in other cases, have been placed into the public domain.
591. At no time did Dorworth and his attorney have an extramarital affair.
592. At no time did Dorworth suggest to Joel Greenberg any affair with his attorney.
593. Joel Greenberg returns to his pattern of accusing his opponents of sexually
594. The only purpose in stating this was to cause harm to the reputation and marriage
of Dorworth.
595. Throughout the 119-page document, Joel Greenberg spews generalities falsely
596. As referenced above, Dorworth has no history of any money transfers via PayPal,
CashApp, Venmo, etc. to Joel Greenberg, Joe Ellicott, Matt Gaetz, or any females throughout.
597. Joel Greenberg suggests that the absence of any money trail, be it cash withdrawals
or transfers using money apps like Venmo, PayPal, Apple Cash, etc., is because Dorworth
600. Stelling and his wife, Lorayne, are elderly and subside largely off their social
security checks.
601. At no time since Dorworth met Joel Greenberg in October 2016 to date has Stelling
602. Stelling is elderly and does not have the resources to lend.
70
603. Greenberg’s statement that an 80-year-old man has large sums of cash in his home
with no evidence or knowledge that he does invites unnecessary danger on an elderly couple.
604. Joel Greenberg had no reason to believe that Stelling lent Dorworth any money.
loan money.
606. At no time did Dorworth tell Joel Greenberg that he’d borrowed money from
Stelling.
607. Had Dorworth borrowed money from Stelling it would have been in no way illegal
or improper.
608. Greenberg’s suggestion that Dorworth was borrowing cash from Stelling sought to
explain why Dorworth had no money trail for the crimes and criminal activity that Joel Greenberg
609. Joel Greenberg states that Dorworth borrowed cash from Stelling to avoid detection
610. Greenberg’s lies exist to defame the name of Dorworth and to suggest he
611. Stelling has never been arrested or convicted of any felony or misdemeanor.
612. Stelling has never been accused of lying in any court matter.
613. Greenberg entirely fabricated a history of Dorworth borrowing money from Jim
Stelling, presumably because Greenberg knew that Dorworth had no history of transactions or
614. This lie, intended to hurt Dorworth’s reputation, was entirely fabricated.
71
615. Most all the unredacted portions of the Greenberg testimony consist of broad
generalities and no specific detail of any conversation, just Joel Greenberg’s assertion that he was
part of them.
616. Joel Greenberg has a series of excuses about why he can’t remember things that
range from his consumption of alcohol to “when you sit in 15 a cell for 23 hours a day your mind
617. Greenberg also fabricated a link between Dorworth and the financing of the Senate
District 9 race.
618. At no time did Foglesong ask Dorworth for money to contribute to the campaign
and at no time Dorworth offer to give money to the campaign or to help pay a qualifying fee for
Jestine Iannotti.
619. Dorworth did not give Ben Paris, his wife or any affiliated person or entity any
money whatsoever for any purpose, to say nothing of $25,000, and certainly not in connection
620. The allegation that Dorworth gave Ben Paris or his wife $25,000 to run for
Seminole County Board of County Commissioners was made by Abby Greenberg, who despite
her divorce from Joel Greenberg, was and remains a member of the Greenberg Racketeering
Enterprise.
621. Abby Greenberg continues to receive payments and compensation from the
622. The marriage of Joel and Abby Greenberg was not a typical marriage.
72
624. Dorworth met Joel Greenberg through his wife, Rebekah Dorworth, and Abby
Greenberg.
625. Abby Greenberg and Rebekah Dorworth first met as members of the Junior League
626. Abby Greenberg and Rebekah Dorworth met again at the Heathrow Modern Mom’s
children.
627. Abby Greenberg and Rebekah Dorworth introduced Dorworth and Joel Greenberg
at a political fundraiser.
628. The first time Joel Greenberg met Dorworth, Joel Greenberg advised Dorworth that
629. Dorworth asked Joel Greenberg, “Does your wife know that?”
631. Dorworth had no reason to doubt or care about the nature of Joel and Abby
Greenberg’s marriage.
632. Characteristics were obvious that Joel and Abby Greenberg’s marriage was
atypical, including frequent jokes about each other’s sexual promiscuity, drug usage and past
633. Joel Greenberg would often make statements to groups of people about Abby
Greenberg in front of Abby Greenberg that surprisingly got laughs out of Abby Greenberg for
revealing things that married couples would never typically disclose about a spouse.
73
634. For example, Joel Greenberg would reveal that prior to marriage, Joel and Abby
Greenberg were in a “sugar baby” relationship, wherein she would have sex with Joel Greenberg
635. Joel Greenberg would often joke in front of groups and in front of Abby Greenberg
that the first day he met her he offered to pay her rent and she accepted his offer and thus began
636. Abby and Joel Greenberg’s divorce was finalized in April 2022, after filing in
October 2021.
638. Abby Greenberg is charged no rent to live in her home, having been given a life
1253 Bella Vista Circle prior to issuing a life estate to Abby Greenberg.
641. Joel Greenberg disclosed in a joking manner in front of executive staff at the
Seminole County Tax Collectors office that Abby Greenberg had been diagnosed with the sexually
transmitted disease Chlamydia during the doctors’ visits in which they determined she was
642. Joel Greenberg disclosed in a joking manner in front of others and Abby Greenberg
that he had, “turned a ho into a housewife,” a reference to a line delivered by one of Abby
74
643. Joel Greenberg disclosed in a non-joking manner in front of others that he had
sexual relations with 600 women and Abby Greenberg that she had engaged in sex with one
644. Joel Greenberg would often attempt to procure men for Abby Greenberg to have
645. Abby Greenberg had sex with at least one current or former employee of the
646. Joel Greenberg was remanded to custody after violating the terms of pre-sentencing
release because he drove to Abby Greenberg’s mother’s home to confront Abby Greenberg about
647. When law enforcement sent Joel Greenberg away, he returned to the family’s home
648. Reporting from the Daily Beast shows that there are more than 150 Venmo
payments to women in exchange for sex that took place during the marriage of Joel and Abby
Greenberg, which apparently did not upset Abby Greenberg because of their open marriage. 11
649. Despite the divorce and despite being married to a man who insulted her prolifically
and publicly, bragged about giving her multiple venereal diseases concurrent with the conception
of their two children, destroying her dresses and handbags, Abby Greenberg opted to keep the
disgraced Greenberg last name instead of reverting to her maiden name and remains compensated
11
https://www.thedailybeast.com/joel-greenberg-letter-written-for-roger-stone-says-matt-gaetz-
paid-for-sex-with-minor east.com)
75
650. Abby Greenberg is a frequent tool of the Greenberg Racketeering Enterprise’s
efforts to defame and slander political enemies of the Greenberg Racketeering Enterprise.
651. For example, Abby Greenberg was the source of the information that Dorworth had
652. When fallout from the scandal began, Abby Greenberg was upset that other people
653. Abby was “furious [Joel] had taken the fall” and “would be receptive to any [of the
654. Joel Greenberg perpetrated a horrific series of personal and legal endeavors, leaving
Abby Greenberg’s children without a father for 11 years while he is incarcerated, yet he is highly
655. Nobody mentioned in this transcript did anything adverse or negative to Abby
656. To the contrary, on the day Joel Greenberg was arrested, Abby and Sue Greenberg
657. Dorworth, as a courtesy to the mother and wife of recently arrested Joel Greenberg,
658. Rebekah Dorworth visited Abby Greenberg to check on her well-being after Joel
Greenberg’s initial arrest and, after being told by Abby Greenberg that Joel Greenberg would not
659. That Abby Greenberg believes Joel Greenberg has not harmed her and that others
more than any other other person has makes no logical sense.
76
660. Abby Greenberg is given access to a home valued at approximately $783,000 by
Enterprise.
662. Abby Greenberg is angry that Dorworth and Gaetz would not, could not and did
not pursue a preemptive pardon for Joel Greenberg nor would attempt to have Roger Handberg
663. As a result of her compensation from the Greenberg Racketeering Enterprise, Abby
Greenberg defamatorily states that Dorworth paid $25,000 to Ben Paris to run for the Seminole
County Board of County Commissioners despite no knowledge that such action took place –
664. Abby Greenberg disclosed this information to Joel Greenberg knowing that he was
entirely fictional.
665. When Abby Greenberg shared this untrue information, she did so knowing that it
666. For Abby Greenberg to transmit this information without doing any research as to
667. On September 13, 2022, Dorworth submitted himself to the third polygraph
examination to contradict the testimony given by Greenberg to seek his promised vengeance for
not seeking the termination of an Assistant U.S. Attorney Roger Handberg and in not successfully
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668. The Polygraph reads as follows:
Mr. Hornsby advised that Joel Greenberg has alleged that Dorworth was involved
in a ghost candidate scheme regarding the 2020 Florida Senate District Nine
election and paid sums of cash to various people involved with the ghost candidate.
During a recent proffer, Greenberg alleged that Dorworth’s former business partner
Jim Stelling, kept large sums of cash at his home and would give it to Dorworth if
asked. Greenberg suggests that it was used for illegal campaign finance of the
District 9 Senate race and whatever else, including, in the words of Greenberg, “for
females, drugs, fill in the blank.”
Greenberg also alleged that Dorworth gave Eric Foglesong cash to aid in the
qualification of Jestine Iannotti in the District Nine Florida Senate race and
Dorworth likewise denied this allegation.
Greenberg alleges his ex-wife Abby Greenberg told him that while she was at a
Seminole County Republican Executive Committee Meeting, she heard Dorworth
paid Ben Paris $25,000 to run for political office.
Dorworth was thereafter asked since meeting Joel Greenberg in September 2016,
had Dorworth had ever received any cash from Jim Stelling for any reason and
Dorworth denied this allegation. Dorworth advised that Stelling is a neighbor,
long-time friend, former business partner, and previously served as the chairman of
the Seminole County Republican Party and as vice-chairman and chairman of the
Rules Committee of the Republican Party of Florida.
Dorworth was asked regarding the allegation that Dorworth gave cash to Eric
Foglesong to assist in the qualification of Jestine Ianotti (sic) in the District Nine
Florida Senate race and Dorworth likewise denied this allegation.
Finally, Dorworth was asked whether he ever paid Ben Paris to run for political
allegation, stating it was false. Dorworth advised that Dorworth is a friend, the
Mayor of Longwood, Florida, and current chairman of the Republican Party of
Seminole County.
669. In the Relevant Questions section, Dorworth was asked three questions:
Question #1 was “Since September 2016, 12 has Jim Stelling ever given you any
cash for any reason? (Dorworth) Answer: No.”
Question #2 “Did you ever give Eric Foglesong any money to aid any third-party
candidates? Answer: No.”
12
Dorworth met Joel Greenberg in September 2016.
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Question #3 “Did you ever pay Ben Paris any money to run for office? (Dorworth)
No.”
670. Under “TEST RESULTS”, the report denotes “Each of the relevant questions was
672. Fritz Scheller has represented Joel Greenberg since Citro and Greenberg parted
ways.
673. Fritz Scheller is open about his desire to incriminate as many other people as
674. Fritz Scheller’s legal bills were entirely funded by the Greenberg Racketeering
Enterprise.
675. In the courthouse transcript, Fritz Scheller tells investigators that he has created a
“shadow investigation.”
79
677. The Greenberg Racketeering Enterprise funded Fritz Scheller’s efforts on Joel
Greenberg’s behalf.
678. On April 8, 2021, Scheller was quoted in many news publications, including the
Orlando Sentinel, as saying “I am sure Matt Gaetz is not feeling very comfortable today.” 13
679. Shadow investigations require extensive resources, which have been paid for by the
680. The sole source of resources for the “independent investigation” was the Greenberg
Racketeering Enterprise.
681. In a December 7, 2022, WFTV ABC Channel 9 news story written by Doralene
Jones, Scheller actively encourages the prosecution of others using the resources of the Greenberg
Racketeering Entity even after the conviction and sentencing of Joel Greenberg. 14 Jones writes
that:
Former Seminole County Tax Collector Joel Greenberg’s attorney is lashing out at
the Department of Justice in Washington, pushing it to pursue charges against
people his client implicated in other crimes during the investigation.”
“To emphasize to the public how important, how significant his cooperation was
and also to set the table for him to get a sentence re-education (sic) under what’s
known as rule 35 (b),” attorney Fritz Scheller said of his motivation.
...
Jones asked Scheller whether Greenberg deserves to have any more time taken off
his sentence.
13
https://www.politico.com/news/2021/04/08/key-figure-in-matt-gaetz-probe-likely-
cooperating-with-federal-prosecutors-480289
14
https://www.wftv.com/news/local/seminole-county/joel-greenbergs-attorney-pushing-more-
prosecutions/UG3QR3TRRJBFPP64FFZH3HMT4A/
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“He destroyed lives, but ultimately destroyed his own life. Yes he should serve his
time, but if he can make a difference that’s his only path toward redemption,”
Scheller said.
Greenberg is now serving 11 years, which is just a fraction of the 27 years he was
facing for federal charges linked to sex trafficking, identity theft, public corruption
involving taxpayer money and contracts, stalking and fraudulent SBA loans.
Scheller said he’s concerned that Greenberg was an easy prosecution because his
conduct was blatant, and he believes other people implicated are going to be a little
bit tougher.
“Other than the SBA, there’s a common thread — you can’t look at them in
isolation. You have oftentimes the same players involved in,” he said. “What’s
really a threat to our democracy is the dark money that flows through elections and
especially the ghost candidates that are being run.”
Scheller refused to give up names. But he said there as many as 10 people connected
to politics in Orange, Seminole, Broward and Leon counties who he believes should
be charged with crimes based on the testimony and physical evidence Greenberg
provided, including lobbyists, fundraisers, former candidates and more than a few
current politicians at the state level.
“There’s more than a few at the state level. There’s this idea that Greenberg got
kickbacks that he pocketed, and that’s certainly true but some of those kickbacks
didn’t go into his pocket, they went into campaigns,” Scheller said.
He said some of that was taxpayer money. He says while people should be
concerned about the other crimes Greenberg committed, the bigger threat to the
general public is the election crimes.
Joel Greenberg pled guilty to stealing cryptocurrency that he then used to obtain
his reelection.
“You can always run third-party candidates, that’s not illegal, but how they’re
funded, that’s the crime. Instead of having a straightforward election, they’re
putting in candidates to tip the vote one way or another,” Scheller said.
Id.
682. Scheller’s client Joel Greenberg admitted to putting a third-party candidate in his
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683. Scheller is fully aware that his client has a history of pathological lying tendencies
and conviction for lying about others having sex with minors as a revenge yet relies upon the
684. Scheller’s comments illustrate the desire of the Greenberg Racketeering Enterprise
to incriminate others.
December 1, 2022:
“We expect the federal government to take on the hard cases and not just the easy
convictions,” Scheller said, urging prosecutors to “pursue others.”
“That’s what they’re there for,” Scheller added, saying the Justice Department
should hold “higher-level” figures accountable for the sake of democracy.
Scheller said he and Greenberg communicated “fairly recently … in the past few
months” with prosecutors as part of his cooperation in the sex-trafficking
investigation.
...
Scheller, Greenberg’s attorney, said his client has lost everything, including his
marriage and his kids. He said Greenberg’s parents cut him out of their will, and
that Greenberg sold his home so he could pay back the money he stole from
Seminole County and the Small Business Administration. 15
686. The Greenberg Racketeering Enterprise is lying about who paid the restitution for
Joel Greenberg.
15
https://www.cnn.com/2022/12/01/politics/joel-greenberg-sentencing/index.html
82
687. The Final Form 6 filed by Joel Greenberg discloses his home’s worth of $624,000
689. Joel Greenberg and Abby Greenberg divorced and divided the remaining assets.
690. Without the continued support of the Greenberg Racketeering Enterprise, Joel
691. Joel Greenberg paid a total of $1,340,000 via wire from Scheller’s office, according
692. Greenberg paid another $590,000 for federal restitution over theft from the Small
Business Administration.
693. Joel Greenberg did not have the financial resources to pay the restitution amounts
to minimize the amount of jail time served by Joel Greenberg, but the Greenberg Racketeering
exercise took responsibility for the purpose of minimizing the criminal sentence of Joel Greenberg.
suggesting that the restitution was paid for by his home, although his Form 6 declared equity in
defame Dorworth, Gaetz and others only for the benefit of Joel Greenberg and the Greenberg
Racketeering Enterprise.
696. On December 30, 2022, legal counsel representing A.B. wrote to Hornsby:
Dear Mr. Hornsby: Our firm represents Ms. [A.B.] who was the 17-year-old at issue
in the attached article which references your client, Chris Dorworth. Ms. [A.B.] has
hired us to pursue claims against your client and others including child sex
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trafficking and rape. This letter is to inquire as to whether a private resolution of
these claims is possible prior to commencing a lawsuit. If your client is interested
in such a resolution, please, either yourself or someone else on his behalf, get back
to me prior to January 6, 2023. If you would like to discuss this matter further
before that date, let me know and we’ll schedule a time to talk.
697. The article forwarded by A.B.’s attorneys was a May 17, 2021, news article written
698. The article mentions Dorworth only once in the context of investigations into third
party candidates in the SD 9 article and not in connection with the investigation regarding A.B..
699. The only portion of the article references Dorworth is the following:
The New York Times has reported that federal investigators were looking into a
conversation about the ghost candidate between Gaetz and Chris Dorworth, a
Seminole County-based developer and former lawmaker who ran in the same
Republican circles as Greenberg. Scheller was asked whether Greenberg was
relaying any information about that race to investigators. 16
700. It is known from Joel Greenberg’s jailhouse testimony that Joel Greenberg is the
source of information that Dorworth was involved with any third-party candidate, a claim
701. Hornsby asked the attorneys representing A.B. for details pertaining to the alleged
702. During the meeting between Dorworth and Joel Greenberg at Another Broken Egg,
Joel Greenberg told Dorworth he was paying for A.B.’s attorneys and that “she would do what he
said.”
concerning whether Dorworth had sexual contact with A.B. and whether Dorworth had any contact
16
https://www.usatoday.com/story/news/politics/2021/05/17/joel-greenberg-rep-matt-gaetz-
wingman-admits-child-sex-trafficking-cooperating-with-authorities/5129972001/
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with A.B. for sexual purposes. The report concluded each response was evaluated as “no deception
indicated” and that there was less than a .01 probability of deception.
704. In the text message, Joel Greenberg confirmed that he was paying A.B.’s attorney
fees.
705. All of Joel Greenberg’s resources and ability to pay for A.B.’s attorneys come from
706. Hornsby summarized the information he learned during the conversation with
Based on our conversation, your client alleges on one occasion before her 18th
birthday, she engaged in commercial sexual intercourse with Mr. Dorworth at a
hotel in July 2017.
You claim Joel Greenberg was present and would corroborate her allegation,
although you have not independently spoken with him to confirm this. You also
advise your client has no evidence of payment from Mr. Dorworth (i.e., Venmo,
CashApp, PayPal, etc. but Mr. Greenberg must have paid on my client’s behalf.
Further, while not per se relevant to liability, but clearly relevant to damages, you
postulate Mr. Dorworth knew your client was underage because Greenberg and
“others” referred to her as “Vintage99,” which is supposedly a fine-wine reference
to her birth year. However, you don’t claim to possess actual evidence Mr.
Dorworth knew her as “Vintage99” or referred to her as such.
707. A.B. knows Greenberg will testify because Greenberg has paid for her attorneys
and has been directed by Greenberg to undertake whatever activities are necessary to further
708. Joel Greenberg pled guilty to and is serving time for lying about a political
710. The relationship between a defendant and a person they pled guilty to trafficking
for sex purposes would not presumably have a guilty party in prison overly willing to testify.
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711. Joel Greenberg, through lawyers and resources provided by the Greenberg
Racketeering Entity, attempts to continue his vendetta because Dorworth would not aid in
obtaining a preemptive pardon and would not engage in Obstruction of Justice by attempting to
tamper with the employment of the Assistant U.S. Attorney investigating Greenberg.
712. Moreover, Joel Greenberg attempted to snare Dorworth into the investigation by
utilizing a screen name to identify her, but Dorworth was not aware of her identity.
713. The attempts of A.B.’s attorneys to cite Dorworth’s knowledge of A.B. screen name
is part of a coordinated attack first advanced by Joel Greenberg when he demanded the termination
of Roger Handberg.
714. To minimize the fiscal impact and lower his sentence, the Greenberg Racketeering
715. The Greenberg Racketeering Enterprise paid $1.25 million via a wire initiated by
716. Joel Greenberg had been incarcerated for over a year on the date of the wire.
718. According to Greenberg’s Form 6’s, 100% of Joel Greenberg’s assets were
719. A cashier’s check from the U.S. Treasury for $109,786.12 was paid to the Seminole
720. Joel Greenberg was incarcerated and could not have physically obtained a cashier’s
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721. According to the Orlando Sentinel, Joel Greenberg paid $590,000 to the Federal
723. Upon information and belief, if Joel Greenberg had not come up with $1.93 million,
he would have received a harsher prison sentence due to greater loss to the taxpayer.
724. Assets of the Greenberg Racketeering Enterprise paid 100% of the restitution to the
state and federal government for the criminal wrongdoing of Joel Greenberg.
725. According to the government, the investigation into human trafficking and related
issues has been closed with no charges for Dorworth, Gaetz or any other “political” person.
A. THE ENTERPRISES
726. The complex and far-reaching tentacles of the Greenberg family’s unlawful
a. The Greenberg Dental Enterprise, through which the Greenberg family has
c. The Seminole County Tax Collector’s Office, during the period Joel
enterprises, and through which the Greenberg family has acted, and
87
B. THE PARTIES TO EACH ENTERPRISE
727. Each enterprise is comprised of the same actors: Joel Greenberg, Andrew
Greenberg, Sue Greenberg, Abby Greenberg, Greenberg Dental, and AWG, Inc.
729. Greenberg Dental holds itself out as having “90+ Florida offices.”
730. Andrew and Sue Greenberg have enjoyed significant wealth as a result of the
731. Joel Greenberg told Dorworth that the dental clinics were essentially run as “pill
mills,” which are illegal facilities that regularly prescribe opioids without sufficient medical
732. Specifically, on various occasions, Joel Greenberg told Dorworth the following:
a. “The reason my parents are so rich is that they figured out how to make
733. Joel Greenberg made frequent jokes to Dorworth about Greenberg Dental’s
734. Joel Greenberg also told Dorworth that he (Greenberg) obtained oxycontin by using
735. Joel Greenberg told Dorworth the use of Greenberg Dental’s prescription pads was
done with the full knowledge and consent of Andrew Greenberg and Sue Greenberg, who believed
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it would be safer for Joel to use pharmaceutical grade oxycontin rather than the version obtainable
on the streets.
736. Joel Greenberg’s statements suggest the Greenberg Dental Enterprise has violated
numerous state and federal laws, including, but not limited to:
substance;
care fraud.
737. Upon information and belief, some or all of Andrew Greenberg’s income from
Greenberg Dental flows to Andrew Greenberg’s corporation, AWG, Inc. The principal address of
738. AWG, Inc., is the vehicle through which Andrew and Sue Greenberg fund their
739. Joel Greenberg told Dorworth that he (Greenberg) receives $400,000 per year to
740. Dorworth has known Joel Greenberg since 2016 and has never seen or heard of Joel
Greenberg performing activities for AWG, Inc. To the best of Dorworth’s knowledge, Joel
Greenberg had been continuously unemployed, save for employment at the radio station and Tax
Collector’s office.
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741. Abby Greenberg, as Joel’s former spouse has benefitted from Greenberg Dental,
AWG, Inc., Andrew Greenberg, Sue Greenberg’s funding of Joel’s activities and lifestyle. She
continues to benefit even though she and Joel Greenberg have divorced.
742. Andrew Greenberg, Sue Greenberg, and Abby Greenberg were aware of Joel
Greenberg’s history of drug abuse and theft dating to his teen years.
743. They were also aware of Joel Greenberg’s long history of taking advantage of
opportunities, such as only receiving a high school degree through the directed philanthropy of his
parents, remaining in college for seven years without earning a degree, and living off his parents’
money.
744. They were also aware of Joel Greenberg’s use of unfounded allegations to achieve
his goals. For example, while under an involuntary psychiatric commitment at age 21 as a result
of taking LSD, Joel accused an orderly of grabbing his penis. No evidence supported the claim.
745. On the day Sue Greenberg learned Joel planned to run for the Seminole County Tax
Collector’s Office, she cried and stated, “he’s going to wind up in prison.”
746. Tax collectors are responsible for the collection of property taxes in their respective
747. In the State of Florida, tax collectors are county constitutional officers, meaning
their position is designated in the Florida Constitution, along with sheriffs, property appraisers,
748. Tax collectors enjoy autonomy because of their county constitutional officer status,
such as the ability to establish branch offices at their discretion. They are also not required to
90
competitively bid services, meaning the tax collector determines who to hire and what to pay them,
749. Whereas other county constitutional officers are funded through their respective
Board of County Commissioners, tax collectors are funded through the Florida Department of
Revenue.
750. As a result, the tax dollars received by the county tax collector are first held by the
Tax Collector’s office. After the office’s expenses are paid, the tax collector may, at his/her option,
751. Before Joel Greenberg assumed office in 2017, the prior Seminole County Tax
752. For the fourteen years before Joel Greenberg’s tenure, Mr. Valdes turned over to
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753. Because a tax collector is not required to turn over any specific amount to the
county, Joel Greenberg saw an opportunity to access millions of dollars per year with limited
government oversight, through which he could not only enrich himself and his friends, but also
fund his criminal endeavors and next election via cryptocurrency stolen from the office.
754. Joel Greenberg knew he could not be elected on his own. He needed the help of the
knowledge of Joel’s long history of failure, addiction, skirting the law, and Sue Greenberg’s belief
that Joel would wind up in prison, the Greenberg Racketeering Enterprise stepped up to the plate.
takeover of the Seminole County Tax Collector’s Office even though it knew Greenberg would
756. In the primary, Joel Greenberg was facing the long-time incumbent, Ray Valdes.
757. Andrew Greenberg, Sue Greenberg, AWG, Inc., AWG Family Limited Partnership,
Martin Greenberg (Joel’s brother), and Adam Greenberg (Joel’s brother), each donated $1,000 to
Joel’s campaign.
758. During this time, Defendant AWG, Inc., also continued providing Joel Greenberg
759. Joel Greenberg used Andrew Greenberg and Sue Greenberg’s funds from AWG,
760. The Greenbergs, their business entities and sons directly funded 97.21% of the
$248,515.52 in total expenditures spent in the campaign, with only $6,924 coming from all other
sources.
92
761. In total, the Enterprise spent $241,591.52 on the Republican primary in the hope of
competing in the general election for a position with a salary of $149,253 per year.
762. In contrast, Mr. Valdes spent only $46,000 toward his election.
763. According to Supervisors of Elections websites across the State of Florida, which
contain histories dating to the 2012 election cycle, Joel Greenberg spent more than any other
764. This historic spend secured Joel Greenberg a slim primary victory against the long-
765. Facing only a write-in opponent in the general election, Joel Greenberg was elected
in November 2016 and took control of the Seminole County Tax Collector’s Office on January 1,
2017.
766. Joel Greenberg, with the support of the Greenberg Racketeering Enterprise, quickly
767. By the time of his 2020 indictment, he had racked up 33 federal crimes – all felonies
768. These charges ranged from stalking a political opponent, bribery of a federal
employee, and identity theft, to sex trafficking a minor, wire fraud, and theft of cryptocurrency.
769. A number of the 33 felony charges relate to his sex trafficking of A.B., who was a
Greenberg was charged with numerous counts related to procuring them both false identification
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documents and misuse of the Florida driver’s license database for purposes of procuring false
identification documents.
a. Count One: Sex Trafficking of a Child, 18 U.S.C. § 1591(a), (b)(2) (c), and
(e)(3).
1028A(a)(1).
771. In addition to sex trafficking a minor, Joel Greenberg also engaged in a scheme by
which he embezzled $400,000 of money and property from the Seminole County Tax Collector’s
Office through a cryptocurrency scam and misuse of government credit cards for his personal
benefit.
18 U.S.C. § 1957.
772. According to page 14 of the Third Superseding Indictment, Joel Greenberg “would
and did use funds obtained from a family member” in attempting to cover up the cryptocurrency
scheme.
94
773. Upon information and belief, the unnamed family member is Andrew Greenberg
and/or Sue Greenberg, as they have been engaged in each of the Enterprises and have the financial
774. To retain office – and access to millions of dollars – Joel Greenberg began a
campaign of stalking and defaming Brian Beute, his political opponent who worked as a teacher.
775. Joel Greenberg sent anonymous letters to the opponent’s school, posing as an
anonymous student. In the letters, he claimed to have personal knowledge that the male opponent
was engaged in a sexual relationship with a male student. These allegations were utterly false,
776. Joel Greenberg also falsely set up a Twitter account using the name and image of
the teacher, though which he published false tweets containing fascist and anti-Semitic language.
777. He then set up a Facebook group under the false identity of a teacher, again
publishing statements that the opponent was engaged in a sexual relationship with a male student.
778. The Third Superseding Indictment included the following charges relating to these
false allegations:
779. As a further means of using the Tax Collector’s Office for his personal benefit, Joel
furtherance of a scheme to submit false claims for COVID-19 funds and defraud the government
95
a. Count Twenty-Six: Conspiracy to Bribe a Public Official, Submission of a
780. The Greenberg Racketeering Enterprise participated in each of the above acts,
directly or indirectly.
781. Joel Greenberg was indicted on June 23, 2020, relating to the stalking and
782. Shortly thereafter, Abby Greenberg invited Dorworth’s wife, Rebekah, and
daughter to join her at the pool at JW Marriott Orlando Grande Lakes for a weekend funded by the
Enterprise. She assured Rebekah that Joel Greenberg would not be present at the pool, though he
783. While waiting in the Greenberg’s penthouse suite for Abby to finish getting ready
for the pool, Joel Greenberg was present. He told Rebekah Dorworth the charges were silly and
784. Joel Greenberg reappeared while Rebekah Dorworth was at the pool. He cornered
Rebekah and used a tone and demeanor Rebekah felt was threatening.
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785. Joel Greenberg demanded that she and Plaintiff convince Congressman Matt Gaetz
to pursue and obtain a pardon for not only the pending charges, but those remaining under
investigation.
786. Plaintiff and Congressman Gaetz are close friends and served together in the
787. Joel Greenberg was aware of Plaintiff and Congressman Gaetz’s close friendship,
788. Greenberg told Rebekah Dorworth that “it would be better for everyone if I got a
pardon.”
789. Joel stated he was worried about his family’s criminal exposure relating to bitcoin
investments. He also wished to avoid publication of text messages relating to Joel and Abby’s
790. He also made a seeming threat against Congressman Gaetz, saying that the
Congressman should be aware that investigators were reviewing Joel Greenberg’s Venmo records
and that “he didn’t know what any of them would say.”
791. Upon hearing of Joel Greenberg’s conversation with Rebekah Dorworth, Plaintiff
requested a meeting with Joel. The two had a breakfast meeting shortly thereafter.
792. During this breakfast meeting, Joel Greenberg expressed that he was hopeful no
sex trafficking charges would be brought because he, through the Greenberg Racketeering
Enterprise, was paying for the attorney for the victim, A.B.. He also stated he anticipated the
Greenberg Racketeering Enterprise could seek her cooperation by paying her off.
793. Despite this, Greenberg continued to press Dorworth to have Gaetz obtain a pardon
97
794. When Dorworth refused to participate in attempting to obtain a pardon, Greenberg
changed tactics, seeking instead to have the Assistant United States Attorney investigating him
fired.
795. Joel Greenberg incorrectly believed that Gaetz could effectuate the termination by
lobbying Trump.
796. Joel texted Dorworth to request he convince Gaetz to have the prosecutor
797. Upon Dorworth’s refusal to participate in the termination of the Assistant U.S.
Attorney, Greenberg then followed through on this promise to Dorworth to “make this a problem
for everyone” by claiming that Dorworth, Congressman Matt Gaetz and others were involved in
798. At sentencing, Greenberg’s attorney claimed that “[a]s a result of his conduct, he
lost his marriage. He lost his children. He was cut out of his parents' will completely. He's lost all
financial support. And you'll see today his family is not here.” December 1, 2022 Sentencing Trans.
at 14:1-4.
799. However, given Greenberg’s low six-figure personal wealth of $322,030 shown on
his Amended 2019 Form 6, it would have been impossible for Greenberg to have paid multimillion
dollar restitution amounts, let alone his legal fees, without support from his family and the
800. Through these actions, the Greenberg Racketeering Enterprise has engaged in the
violations of numerous state and federal statutes, including but not limited to:
98
b. 18 U.S.C. § 1503, influencing or injuring officer, by seeking the firing of
801. Greenberg showed a clear pattern of racketeering in every aspect of his life.
802. Greenberg used every opportunity he had to commit crimes to advance his own
interests.
But I also have never seen a defendant who has committed so many different
types of crime within a relatively short period like those crimes committed by
Mr. Greenberg.
He was a public official. And the conduct that he engaged in undermines the
public's trust in our governmental system. And all of us -- all of us are victims
of a crime or crimes where public trust is abused. And as Mr. Handberg pointed
out, Mr. Greenberg continued with his criminal conduct even after he knew he
was under criminal investigation and violated the terms of his supervised
release imposed by a magistrate judge of this court. It does indicate that Mr.
Greenberg, just a year ago, showed no respect for the law because he violated
99
the order of a magistrate judge that allowed him to retain his liberty during the
process of this proceeding.
804. Thus, Greenberg committed a continuous and pervasive pattern of RICO acts, even
805. Greenberg’s misconduct began before he gained control and did not end even after
I think what Ms. Harrington did so well in the sentencing memo is she put it in
chronological order so that everyone could see just the scope of the crimes that were
being committed and also the continuous nature from 2017 through 2020. And that
took a little bit of time in the sentencing memo to do. And that's not because the
United States was focusing improperly or excessively on the offenses. It's because
the crimes that Mr. Greenberg committed say a lot about what the sentence should
be in this case. They talk to the seriousness of the offense. They also go to his
history and characteristics as a person. In many of my cases, I like to try to find a
short version of what I would tell someone the case was about. This one, it's difficult
to do, to summarize quickly. Over the course of three years, Mr. Greenberg spent
over $70,000 engaging in commercial sex acts, consisting of over 150 financial
transactions. His commercial sex acts included seven where he paid a minor for
sex. While that was going on, Mr. Greenberg was using his position as a Seminole
County tax collector to defraud his office out of hundreds of thousands of dollars
that he used to buy cryptocurrency, to buy and sell cryptocurrency machines, to
basically operate, at the end of his tenure as a tax collector, a business out of the
tax collector's office. Some of those machines he attempted to use to mine
cryptocurrency for himself, which resulted in one of his offices catching on fire. In
the course of that scheme, Mr. Greenberg lied to his chief financial officer and the
auditors, individuals who were intended to be, you know, protections for the county
that their money wasn't being misused. He made two false representation letters to
the auditors. He had a secret bank account. He used another bank account controlled
by him. He engaged in over 97 purchases of cryptocurrency, over a hundred
transactions involving the purchase and sale of cryptocurrency machines, and
transferred hundreds of thousands of dollars in layered financial transactions
involving different financial accounts. He used a corporation for one part of his
scheme as a front for his fraud and deposited hundreds of thousands of dollars of
cryptocurrency into wallets that were controlled by him, all of which he did over
the course of three years. That's not all. While that was going on, he was using his
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position and the resources of his office to make fake driver's licenses for himself
using stolen identities. And these weren't insignificant documents. Those two fake
driver's licenses were found in Mr. Greenberg's wallet. That's not all. While that
was going on, Mr. Greenberg decided to stalk a political opponent. One of the most
terrible things I think you can do to someone who's a teacher is to falsely accuse
them of engaging in sexual misconduct with a student. And that's what Mr.
Greenberg did. And he did it publicly on Facebook. As I said, this case defies a
short, easy summary. And each part of what I just summarized has many more
details that I could go into. And each of those establishes that the crimes in this case
are very serious. But there's moments, too, that also provide further information. I
often think in any criminal case there's moments that are especially important. I'm
going to talk about three of them. The first is one you -- I think you might be
surprised I would actually reference, which is January 3rd of 2017. That's a date of
significance for two reasons. That was the date that Mr. Greenberg assumed office
as the Seminole County tax collector. It's also the date that we got the first
indication of how he was going to use and abuse the trust he had been given. Prior
to becoming tax collector, he had engaged in a transaction with an individual. As
part of that, he got their personal information and ordered a driver's license for that
person without their knowledge. And in the process of doing that, Mr. Greenberg
changed where the driver's license went. He changed it to an address that he could
then get the driver's license from. And on his very first day in office, one of the first
things he did was he used the DAVID system, the Florida driver's license system,
to go in and change that, to change it back to the person's actual address. So from
the very beginning, what Mr. Greenberg, I think, showed was he had the intent to
use his office in ways that benefited him from day one. And that's something that
continued during the entire time that he was the Seminole County tax collector.
And so what Mr. Greenberg did was he attempted to cover up what he had done, as
acknowledged in the plea agreement and the PSR. And he continued on with his
scheme. He was not deterred. We saw that again in the third date I'm going to talk
about, which is June 23rd of 2020. On that date, early in the morning, federal agents
went to Mr. Greenberg's house and executed a search warrant at his residence and
arrested him. He was brought to this building for his initial appearance on a federal
indictment. He had conditions of release set and was released. What would only be
determined later was at the time that that happened, Mr. Greenberg had already
started down the road of a false SBA claim. And after sitting in federal court and
having a federal magistrate judge tell him that he is not to commit any further
crimes or offenses and obey all of the conditions of release, the next day he finished
up the paperwork to get his fake loan. And then he did it two other times.
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808. Greenberg’s misconduct threatened to continue indefinitely, and it has, where
809. Greenberg continued his misconduct even after he began pretending to cooperate
810. As described herein, Dorworth has been substantially injured by the Greenberg
COUNT ONE
Federal Civil RICO, 18 U.S.C. § 1962(a)
Acquiring/Maintaining Control in an Enterprise
(Against all Defendants Except A.B.)
811. Dorworth hereby incorporates herein all Allegations Common to All Counts and
813. The Greenberg Campaign and the Seminole County Tax Collector’s Office are both
815. Upon information and belief, the Greenberg Racketeering Enterprise acquired
816. The Greenberg Racketeering Enterprise then used these proceeds to establish the
Greenberg Campaign.
817. The Greenberg Racketeering Enterprise also used these proceeds to help Greenberg
acquire and maintain control of the Seminole County Tax Collector’s Office.
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819. Pursuant to 18 U.S.C. 1964(c), Dorworth is entitled to treble damages, his costs of
bringing this action, including attorney fees, and all other relief the Court deems just and proper.
COUNT TWO
Federal Civil RICO, 18 U.S.C. § 1962(b)
Acquiring/Maintaining Control in the Seminole County Tax Collector’s Office
(Against all Defendants Except A.B.)
820. Dorworth hereby incorporates herein all Allegations Common to All Counts and
822. The Greenberg Campaign and the Seminole County Tax Collector’s Office are each
823. Defendants associated with, operated, controlled, and benefitted from, each
enterprise.
824. Defendants acquired and maintained control in the Seminole County Tax
825. The Seminole County Tax Collector’s Office is engaged in and its activities affect
interstate commerce.
826. Through their interest in, or control of, the Greenberg Racketeering Enterprise,
Defendants committed numerous criminal acts, as set forth in the RICO Section above, and in the
violations of 18 U.S.C. § 1962(b), Dorworth has been significantly injured, including, but not
limited to, suffering a substantial financial loss and damage to his reputation and livelihood.
828. Pursuant to 18 U.S.C. 1964(c), Dorworth is entitled to treble damages, his costs of
bringing this action, including attorney fees, and all other relief the Court deems just and proper.
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COUNT THREE
Federal Civil RICO, 18 U.S.C. § 1962(c)
Substantive RICO Violations
(Against Defendant Joel Greenberg)
829. Dorworth hereby incorporates herein all Allegations Common to All Counts and
831. The Greenberg Campaign, Seminole County Tax Collector’s Office, and the
Greenberg Racketeering Enterprise are each an enterprise as defined by 18 U.S.C. § 1961(4) and
1962(c). Defendant Joel Greenberg is associated with, and benefits from, each enterprise.
832. At all times material, Defendant Joel Greenberg was engaged in activities that affect
interstate commerce.
833. Since at least 2016 and continuing to the present, Defendant Joel Greenberg
racketeering activity within the meaning of 18 U.S.C. § 1961(1), 1961(5), and 1962(c).
834. Defendant Joel Greenberg’s pattern of racketeering activity consists of the various
835. Defendant Joel Greenberg issued numerous false statements in furtherance of his
b. Falsely averring Dorworth was involved in the scheme to sex traffic minors;
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e. Falsely averring Dorworth was involved in the ghost candidate scheme
involving the 2020 Florida Senate District Nine election and incurred
h. Falsely averring Dorworth was having an extramarital affair with his female
attorney; and
836. Defendant Joel Greenberg engaged in each of the acts described in the Third
Superseding Indictment and set forth throughout this Complaint and incorporated herein by
reference.
pardon and the firing of the Assistant U.S. Attorney handling his criminal case.
838. Defendant Joel Greenberg violated 18 U.S.C. §§ 1341 and 1346 (honest services
fraud) by depriving Seminole County taxpayers of the intangible right to honest services through
his schemes of theft, bribery, kickbacks, wire fraud, and other crimes committed while serving as
seeking the firing of the Assistant U.S. Attorney handling his criminal case.
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840. Defendant Joel Greenberg violated 18 U.S.C. § 1510 (obstruction of a criminal
investigation) by seeking the firing of the Assistant U.S. Attorney handling his criminal case.
841. Defendant Joel Greenberg violated 18 U.S.C. § 1512 (tampering with a victim,
witness, or informant) by coercing Defendant A.B. to provide false statements to law enforcement
punish Dorworth for failing to help him, cause investigators to include Dorworth in the
investigation, and possibly obtain further cooperation by attempting to induce the government to
charge Dorworth.
843. Of these incidents, at least two had the same or similar intent related to reducing or
eliminating Joel Greenberg’s criminal liability, the same or similar intent related to sex trafficking,
and were not isolated incidents. Defendant Joel Greenberg participated in all of the above acts.
informal, of Joel Greenberg, Andrew Greenberg, Sue Greenberg, Abby Greenberg, Greenberg
845. The Greenberg Racketeering Enterprise functioned as a continuing unit and has a
846. Once Greenberg’s unlawful activity was known to both all involved and the entire
world, the Greenberg Racketeering Enterprise acted unlawfully to cause the extortion and
defamation of Dorworth.
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847. Each above-mentioned crime victimized Dorworth by causing a substantial
848. Dorworth’s substantial loss and injury is directly and proximately caused by the
849. Pursuant to 18 U.S.C. 1964(c), Dorworth is entitled to treble damages, his costs of
bringing this action, including attorney fees, and all other relief the Court deems just and proper.
COUNT FOUR
Federal Civil RICO, 18 U.S.C. § 1962(c)
Substantive RICO Violations
(Against Defendants Andrew Greenberg, Sue Greenberg, Abby Greenberg,
Greenberg Dental, and AWG, Inc.)
850. Dorworth hereby incorporates herein all Allegations Common to All Counts and
1961(4) and 1962(c). Each of the Defendants in this Count is associated with, and benefits from,
the enterprise.
853. At all times material, Dorworth and Defendants were engaged in activities that
854. Since at least 2016 and continuing to the present, Defendants conducted or
855. Defendants’ pattern of racketeering activity consists of the various predicate acts
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856. Defendants engaged in a scheme of extortion in attempts to secure a pardon and the
firing of the Assistant U.S. Attorney handling Joel Greenberg’s criminal case.
the firing of the Assistant U.S. Attorney handling Joel Greenberg’s criminal case.
investigation by seeking the firing of the Assistant U.S. Attorney handling Joel Greenberg’s
criminal case.
859. Defendants violated 18 U.S.C. § 1512 regarding tampering with a victim, witness,
or informant, by coercing Defendant A.B. to provide false statements to law enforcement through
failing to help him, cause investigators to include Dorworth in the investigation, and possibly
861. Of these incidents, at least two had the same or similar intent related to reducing or
eliminating Joel Greenberg’s criminal liability, the same or similar intent related to sex trafficking,
and were not isolated incidents. Defendant Joel Greenberg participated in all the above acts.
862. The enterprise was an ongoing organization, formal or informal, of Joel Greenberg,
Andrew Greenberg, Sue Greenberg, Abby Greenberg, Greenberg Dental, and AWG, Inc. It
functions as a continuing unit and acted for several common purposes, one of which was the
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863. Each above-mentioned crime victimized Dorworth by causing a substantial
864. Dorworth’s substantial loss and injury is directly and proximately caused by the
865. Pursuant to 18 U.S.C. 1964(c), Dorworth is entitled to treble damages, his costs of
bringing this action, including attorney fees, and all other relief the Court deems just and proper.
COUNT FIVE
Federal Civil RICO, 18 U.S.C. § 1962(d), Conspiracy
(Against all Defendants)
866. Dorworth hereby incorporates herein all Allegations Common to All Counts and
867. Defendants Joel Greenberg, Andrew Greenberg, Sue Greenberg, Abby Greenberg,
A.B., Greenberg Dental, and AWG, Inc., are persons as defined by 18 U.S.C. § 1961(3).
1961(4) and 1962(d). Each of the Defendants is associated with, and benefits from, the enterprise.
869. At all times material, Dorworth and Defendants were engaged in activities that
871. Each Defendant other than A.B. also acted to facilitate the schemes to control the
872. The conspiracy has been in effect since at least 2016 and remains ongoing.
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873. The conspiracy’s purpose was to engage in a pattern of racketeering activity with
874. As is set forth in Counts 1 through 4, Joel Greenberg and the other Defendants
engaged in a pattern of racketeering activity designed to reduce or eliminate his criminal liability.
875. Defendant Abby Greenberg participated in the extortion of Dorworth and making
false representations when Dorworth did not follow through on Joel Greenberg’s threats. She also
engaged in the obstruction of justice by seeking the firing of the Assistant U.S. Attorney handling
876. Defendant A.B. knowingly falsified her testimony and statements to the
government to implicate Dorworth, knowing those statements were false and only had an effect of
877. The remaining Defendants knowingly and repeatedly provided substantial financial
support for the unlawful activities and conspired to facilitate the scheme giving rise to each
878. Each Defendant helped to advance the overall objective of the conspiracy and the
879. Dorworth’s substantial loss and injury is directly and proximately caused by the
880. Pursuant to 18 U.S.C. § 1964(c), Dorworth is entitled to treble damages, his costs
of bringing this action, including attorney fees, and all other relief the Court deems just and proper.
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COUNT SIX
Defamation
(Against Defendants Greenberg and A.B.)
881. Dorworth hereby incorporates herein all Allegations Common to All Counts.
882. Defendants Joel Greenberg and A.B. made false and defamatory statements against
Dorworth.
883. Defendant Joel Greenberg made numerous false statements, including, but not
a. Falsely averring Dorworth was involved in the scheme to sex traffic minors;
involving the 2020 Florida Senate District Nine election and incurred
g. Falsely averring Dorworth was having an extramarital affair with his female
attorney; and
884. Defendant A.B. also made false statements regarding Dorworth, including:
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a. Falsely averring Dorworth was involved in the scheme to sex traffic minors;
886. The above-described statements convey a defamatory meaning. They were made
with actual malice and for the express purpose of harming Dorworth.
888. To the extent Defendants issued allegations to the government, they had an
improper purpose in doing so because they knew the allegations were false and they were simply
889. The above statements directly injured Dorworth by diminishing his reputation and
890. As a direct and proximate result of Defendants’ false statements, Dorworth has been
significantly injured, including, but not limited to, suffering a substantial financial loss and damage
892. Dorworth is entitled to a judgment for compensatory damages, costs of suit, and all
COUNT SEVEN
Aiding and Abetting Defamation
(Against Andrew Greenberg, Sue Greenberg, Abby Greenberg,
Greenberg Dental, and AWG, Inc.)
893. Dorworth hereby incorporates herein all Allegations Common to All Counts.
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895. Defendants Andrew Greenberg, Sue Greenberg, Abby Greenberg, Greenberg
Dental, and AWG, Inc., each possessed knowledge of Joel Greenberg and A.B.’s defamation.
896. Defendants each provided substantial assistance to Joel Greenberg and A.B. by
providing financial resources to enable the defamatory actions, among other actions.
897. Defendants provided these resources with the knowledge and intent that they would
898. As a result of Defendants’ aiding and abetting defamation, Dorworth has been
significantly injured, including, but not limited to, suffering a substantial financial loss and damage
899. Dorworth is entitled to a judgment for compensatory damages, costs of suit, and all
COUNT EIGHT
Civil Conspiracy
(Against all Defendants)
900. Dorworth hereby incorporates herein all Allegations Common to All Counts
901. Defendants conspired to create, finance, and disseminate false information about
the Dorworth.
902. Defendants agreed to, and knowingly did, disseminate or assist in disseminating
903. Each Defendant was aware of an overall plan to harm Dorworth’s reputation,
904. Each Defendant acted to further the plan to harm Dorworth’s reputation.
906. Defendants’ activity also violates the RICO statute, as set forth above.
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907. As a direct and proximate result of the conspiracy, Dorworth has been significantly
injured, including, but not limited to, suffering a substantial financial loss and damage to his
908. Defendants intentionally, willfully, and wantonly conspired and acted in concert
909. Dorworth is entitled to a judgment for compensatory damages, costs of suit, and all
COUNT NINE
Declaratory Relief
(Against A.B.)
910. Dorworth hereby incorporates herein all Allegations Common to All Counts
911. Dorworth seeks a declaration of this Court that Dorworth has not had sexual contact
with A.B. at any time; that Dorworth has not solicited, paid, or otherwise compensated A.B. for
sexual acts; and that he is not liable to her for any allegations of the same.
912. The December 30, 2022, Letter from A.B.’s counsel threatening litigation
demonstrates the existence of a bona fide, actual and present dispute between A.B. and Dorworth.
913. At minimum, there exists the ripening seeds of a controversy or litigation, such that
litigation in the immediate future appears unavoidable. This entitles Dorworth to declaratory relief.
914. The declaratory action deals with a present, ascertained or ascertainable state of
915. Some immunity, power, privilege or right of Dorworth and/or A.B. is dependent
916. The relief sought is not merely the giving of legal advice by the courts or the answer
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917. Dorworth respectfully requests this Court issue an Judgment declaring that
Dorworth has not had sexual contact with A.B. at any time; that Dorworth has not solicited, paid,
or otherwise compensated A.B. for sexual acts; and that he is not liable to her for any allegations
of the same, along with costs of suit, and all other relief the Court deems just and proper.
c. A declaratory judgment order consistent with the relief requested in Count Nine, above;
f. Such other and further relief as the Court deems just and warranted.
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