Filing # 169939204 E-Filed 03/29/2023 04:13:24 PM

IN THE CIRCUIT COURT OF THE

FIFTH JUDICIAL CIRCUIT IN AND
FOR MARION COUNTY, FLORIDA

CASE NO.:

JOSE JUAREZ,

Plaintiff,

vs.

FLORIDIANS FOR ETHICS

AND TRUTH IN POLITICS, a Political
Committee, BRET DOSTER, an individual,
FRONT LINE STRATAGIES, INC. d/b/a
THE FRONT LINE AGENCY; a Florida
corporation,

Defendants.
_____________________________________/

COMPLAINT

Plaintiff, JOSE JUAREZ (“Juarez”), sues Defendants, FLORIDIANS FOR ETHICS AND

TRUTH IN POLITICS (“FETP”), BRET DOSTER (“Doster”), FRONT LINE STRATAGIES,

INC. d/b/a THE FRONT LINE AGENCY (“Front Line Agency”), and states as follows:

The Parties, Jurisdiction and Venue

1. Plaintiff is an individual living in Marion County, Florida, and otherwise sui juris.

Plaintiff is a conservative Republican who ran as a candidate for Florida Special House of

Representatives, District 24 which was held on March 7, 2023.

2. FTEP is a political action committee located in Tallahassee, Florida and known to

fund ads, mailers, and flyers for political campaigns, and is otherwise sui juris.

TOBIN REYES ALVAREZ & DE BIASE, PLLC

MIZNER PARK OFFICE TOWER • 225 N. E. MIZNER BOULEVARD, SUITE 510 • BOCA RATON, FLORIDA • 33432
 3. Doster is a political consultant and manager, the owner of the Front Line Agency,

a resident of the State of Florida, and otherwise sui juris. Doster has a long history of public

relations and political career in the state of Florida and founded the Front Line Agency in 2005.

4. The Front Line Agency is a Florida corporation, and otherwise sui juris. The Front

Line Agency is a full-service media, public relations, and political campaign consulting firm

providing advocacy and consultation services for politicians, political campaigns and political

committees while also producing all types of paid media for them as well.

5. Pursuant to Section 47.011, Florida Statutes, venue is proper in Marion County,

Florida because the causes of action alleged herein arose in Marion County, Florida.

General Allegations

6. Plaintiff has been a resident of Ocala for about 40 years and has built a good and

strong reputation over the years in the community as a successful entrepreneur and business owner.

7. In fact, Plaintiff founded and has successfully built an intelligence/marketing firm,

Victory Solutions Inc., that assists motorcycle dealerships nationwide and, Barbacuban, LLC, a

BBQ Sauce Company with Cuban fusion which distributes specialty sauces to 500 stores in

Florida, Georgia and Alabama.

8. Moreover, Plaintiff is an active and well-known member of the Marion County

community whose personal reputation is beyond reproach.

9. During the course of the District 24 campaign, FTEP caused to be published certain

mailers entitled Multi-Millionaire Jose Juarez Scammed Taxpayers! (“Hit Piece 1”), and Illegal

Aliens are Streaming Across our Border. Bringing Fentanyl and Gang Violence. (“Hit Piece 2”)

(collectively “Hit Pieces”). A true and correct copy of the Hit Pieces are attached hereto as Exhibit

“A” and Exhibit “B” respectively.

TOBIN REYES ALVAREZ & DE BIASE, PLLC

MIZNER PARK OFFICE TOWER • 225 N. E. MIZNER BOULEVARD, SUITE 510 • BOCA RATON, FLORIDA • 33432
 10. Upon information and belief, Doster and the Front Line Agency were working in

concert with FTEP to publish and disseminate the Hit Pieces in Marion County in an attempt to

injure Plaintiff’s political reputation in favor of his opponent for the District 24 seat, Ryan

Chamberlain.

11. Ironically, the Hit Pieces state that they are “a paid electioneering by Floridians For

Ethics and Truth in Politics;” (emphasis added). However, there is nothing “ethical” or “true”

about the Hit Pieces or the publication of the same.

12. Rather, as set forth more fully below, the Hit Pieces contained false and defamatory

statements of fact about the Plaintiff as well as defamatory implications from the omission of key

facts and/or the juxtaposition of statements intended to impart a misrepresentation of facts about

the Plaintiff to the reader.

Hit Piece 1

13. Hit Piece 1 contains false statements of “fact” regarding Plaintiff.

14. Specifically, in Hit Piece 1, the Defendants falsely stated that Plaintiff took

“$214,000 in taxpayer-funded bail out loans NEVER paid back.”

15. This statement is patently false.

16. The loans at issue were either paid, in full, or were forgiven.

17. The Defendants knew or should have known that the statement was false as even a

simple Google search shows the loans at issue are not outstanding and/or “Paid in Full.”

18. In addition, by and through Hit Piece 1, the Defendants attempted to mislead

readers by implying and falsely claiming that Juarez has engaged in criminal or tortious conduct

as they claim Juarez has “scammed taxpayers.”

19. Again, this statement is patently false.

TOBIN REYES ALVAREZ & DE BIASE, PLLC

MIZNER PARK OFFICE TOWER • 225 N. E. MIZNER BOULEVARD, SUITE 510 • BOCA RATON, FLORIDA • 33432
 20. While the Defendants failed to identify the facts upon which they relied in making

this statement, to the extent those “facts” include the false statements about loans, it remains that

the loans are not, in fact, outstanding and the statement that Plaintiff “scammed taxpayers” is

defamatory per se.

21. To the extent the statement was not intended to refer to those loans, the statement

is defamatory by implication as the Defendants omitted key facts with the intention to create a

false impression about the Plaintiff.

22. The false statements in Hit Piece 1 that Juarez engaged in fraudulent, unlawful

and/or unethical conduct were made maliciously with the intent to injure Juarez politically and, in

turn, his personal and professional reputations as well.

23. As evidence of the Defendants’ malicious intent, the Hit Piece 1 continued by

falsely stating “[h]e laughed all the way to the bank. Now he wants to manage all your tax dollars

in the legislature” and discriminatorily emphasizing “No Way, Jose!”

Hit Piece 2

24. In Hit Piece 2, the Defendants falsely claim that Plaintiff’s campaign is funded by

“WOKE CORPORATIONS who support Joe Biden’s ‘No Borders’ policy”.

25. Once again, this statement is false.

26. Once again, the Defendants have failed to identify the facts upon which they rely

in making this false statement about the sources for Plaintiff’s campaign funds. In accordance with

Florida law, those sources and the contributions made by each are publicly available. Nevertheless,

the Defendants have failed to identify any of the same.

TOBIN REYES ALVAREZ & DE BIASE, PLLC

MIZNER PARK OFFICE TOWER • 225 N. E. MIZNER BOULEVARD, SUITE 510 • BOCA RATON, FLORIDA • 33432
 27. In Hit Piece 2, the Defendants intentionally and maliciously omitted crucial

information in an attempt to mislead the readers/voters in an attempt to injure the Plaintiff’s

political, professional and personal reputations.

28. The statements in Hit Piece 2 constitute defamation and/or defamation by

implication as they are not factually supported, and the Defendants juxtaposed and omitted facts

to mislead and create false impressions regarding Plaintiff.

Defendants’ Actual Malice

29. The Hit Pieces were published and disseminated in Marion County on or about

February 25, 2023 – just ten (10) days prior to the March 7th election – in a clear attempt to injure

Plaintiff’s political, professional and personal reputations within the District 24 community and

constituency.

30. On February 28, 2023, Plaintiff provided written notice to the Defendants of the

falsity of the statements in the Hit Piece and demanded a retraction of the same (“Retraction

Demand”). A true and correct copy of the Retraction Demand is attached hereto and incorporated

herein as Exhibit “C.”

31. As additional evidence of actual malice, the Defendants failed and refused to issue

a retraction for the Hit Pieces or otherwise attempt to ameliorate their unlawful conduct despite

written demand by the Plaintiff to do so in advance of the March 7, 2023 election.

32. All conditions precedent to the filing of this lawsuit have been performed, satisfied,

or waived.

COUNT I – DEFAMATION
(Against FTEP)

33. This is an action for damages in excess of $50,000.00 exclusive of interest and

costs, for defamation.

TOBIN REYES ALVAREZ & DE BIASE, PLLC

MIZNER PARK OFFICE TOWER • 225 N. E. MIZNER BOULEVARD, SUITE 510 • BOCA RATON, FLORIDA • 33432
 34. Plaintiff incorporates and re-alleges the allegations in paragraph 1 through 32

above, as if set forth fully herein.

35. The statements in the Hit Pieces about the Plaintiff are false.

36. FTEP made, published and/or caused to be published the Hit Pieces.

37. FTEP knew or should have known that the statements in the Hit Pieces were false

when made and published.

38. The statements in Hit Piece 1 that Plaintiff “scammed taxpayers” and “NEVER

paid back” $214,000 in loans constitute libel per se because, by their nature, the statements

subjected Plaintiff to distrust, ridicule, and contempt and injured Plaintiff’s reputation as they

falsely accused Plaintiff of fraudulent, criminal and/or unethical conduct.

39. At the very least, however, those statements constitute actionable defamation by

implication.

40. The statement in Hit Piece 2 that Plaintiff’s campaign is funded by “WOKE

CORPORATIONS who support Joe Biden’s ‘No Borders’ policy” also constitutes actionable

defamation and/or defamation by implication.

41. The statements in the Hit Pieces were made and/or published by FTEP with actual

malice because FTEP knew they were false or acted with reckless disregard as to the truth and

falsity of the statements.

42. Plaintiff has been damaged by the publication of the defamatory statements, not

only in his political campaign but in his professional career and personal life as well. Plaintiff

intends to pursue a claim for punitive damages upon leave of Court.

TOBIN REYES ALVAREZ & DE BIASE, PLLC

MIZNER PARK OFFICE TOWER • 225 N. E. MIZNER BOULEVARD, SUITE 510 • BOCA RATON, FLORIDA • 33432
 WHEREFORE, Plaintiff, JOSE JUAREZ, demands judgment against Defendant,

FLORIDIANS FOR ETHICS AND TRUTH IN POLITICS, for damages, together with an award

of interest and costs, and any such other and further relief this court deems just and proper.

COUNT II – CONSPIRACY
(Against All Defendants)

43. This is an action for damages in excess of $50,000.00 exclusive of interest and

costs, for civil conspiracy.

44. Plaintiff incorporates and realleges the allegations in paragraphs 1 through 32 above

as if fully set forth herein.

45. FTEP conspired with Doster and the Front Line Agency to defame the Plaintiff to

injure his political, professional and/or personal reputations in an attempt to support the Plaintiff’s

political opponent in the District 24 election, Ryan Chamberlain.

46. Doster and the Front Line Agency are political consultants/strategists who were

working on behalf of the Chamberlain campaign in the 2023 District 24 election.

47. During the District 24 campaign, Doster and the Front Line Agency agreed with

FTEP to create and disseminate the Hit Pieces, including the defamatory statements therein, in an

effort to injure the Plaintiff and, in turn, help the Chamberlain campaign.

48. In furtherance of that agreement, FTEP published and/or caused the Hit Pieces to

be published.

49. The false statements in Hit Piece 1 that Plaintiff “scammed taxpayers” and

“NEVER paid back” $214,000 in loans are per se defamatory and/or constitute actionable

defamation by implication.

TOBIN REYES ALVAREZ & DE BIASE, PLLC

MIZNER PARK OFFICE TOWER • 225 N. E. MIZNER BOULEVARD, SUITE 510 • BOCA RATON, FLORIDA • 33432
 50. The false statement in Hit Piece 2 that Plaintiff’s campaign is funded by “WOKE

CORPORATIONS who support Joe Biden’s ‘No Borders’ policy” also constitutes actionable

defamation and/or defamation by implication.

51. In furtherance of the Defendants’ agreement, the statements in the Hit Pieces were

made and/or published by FTEP with actual malice because FTEP knew they were false or acted

with reckless disregard as to the truth and falsity of the statements.

52. Plaintiff has been damaged by the publication of the defamatory statements, not

only in his political campaign but in his professional career and personal life as well. Plaintiff

intends to pursue a claim for punitive damages upon leave of Court.

WHEREFORE, Plaintiff, JOSE JUAREZ, demands judgment against Defendants,

FLORIDIANS FOR ETHICS AND TRUTH IN POLITICS, BRET DOSTER, and FRONT LINE

STRATAGIES, INC. d/b/a THE FRONT LINE AGENCY for damages, together with an award

of interest and costs, and any such other further relief this Court deems just and proper.

DEMAND FOR JURY TRIAL

Plaintiff hereby demands trial by jury on all issues so triable as of right and further demands

costs and such other relief as the Court deems just and equitable.

TOBIN REYES ALVAREZ & DE BIASE, PLLC

MIZNER PARK OFFICE TOWER • 225 N. E. MIZNER BOULEVARD, SUITE 510 • BOCA RATON, FLORIDA • 33432
 NOTICE OF DESIGNATION OF ELECTRONIC MAIL (E-MAIL) ADDRESSES

Pursuant to Jud. Admin. 2.516(b)(1)(A), the undersigned counsel, on behalf of Plaintiff,

JOSE JUAREZ, designates the following e-mail address to be used in the above referenced matter:

Primary: [email protected]
Secondary: Ricardo A. Reyes, Esq. [email protected]
Secondary: Michelle M. Horton, FRP [email protected]
Secondary: Pedro S. Quintana, Esq. [email protected]
Secondary: Roseanne Reid, Legal Asst. [email protected]

and all further documents required or permitted to be served in the above referenced matter shall

be served to each of the above-referenced e-mail addresses.

Dated: March 29, 2023.

Respectfully submitted,

s/ Ricardo A. Reyes
Ricardo A. Reyes ([email protected])
Florida Bar No. 864056
Pedro S. Quintana ([email protected])
Florida Bar No. 1026411
Attorneys for Plaintiff
TOBIN, REYES, ALVAREZ &
DE BIASE, PLLC
225 N.E. Mizner Boulevard, Suite 510
Boca Raton, Florida 33432
Tel: (561) 620-0656
Fax: (561) 620-0657
Primary Email: [email protected]
Secondary Email: [email protected]
Secondary Email: [email protected]
Secondary Email: [email protected]

TOBIN REYES ALVAREZ & DE BIASE, PLLC

MIZNER PARK OFFICE TOWER • 225 N. E. MIZNER BOULEVARD, SUITE 510 • BOCA RATON, FLORIDA • 33432
EXHIBIT A
EXHIBIT B
EXHIBIT C
 225 N. E. MIZNER BOULEVARD, SUITE 510
BOCA RATON, FLORIDA 33432
TELEPHONE (561) 620-0656
FACSIMILE (561) 620-0657
Writer’s E-Mail: [email protected]

February 27, 2023

Via Federal Express

Michael Hanna Brett Doster
Floridians for Ethics and Truth in Politics Front Line Strategies, Inc.
1700 North Monroe Street d/b/a The Front Line Agency
Suite 11-297, Tallahassee, 1800 Dove Field Run
Florida, 32303 Tallahassee, FL, 32317

And

Ryan Chamberlin
Ryan Chamberlin Campaign
12305 SE 55th Avenue Road,
Belleview, Florida 34420

RE: Jose Juarez (“Mr. Juarez”) adv. Ryan Chamberlin Campaign (“Ryan
Campaign”), Floridians for Ethics and Truth in Politics (“FETP”) and The
Front Line Agency (“FLA”)

Cease and Desist Notice / Retraction Demand

Gentlemen,

Please be advised that the undersigned firm has been retained on behalf of Mr. Juarez, a
candidate for the Florida Special Election in House District 24 seat (“District 24”). Please direct
all future communications concerning this matter to our attention. The purpose of this
correspondence is to demand the immediate retraction of the libelous statements you caused to be
published regarding Mr. Juarez and that you cease and desist from any future publication.
We are aware that the Ryan Campaign retained FLA’s services in the District 24 campaign,
and that FLA coordinated the dissemination of certain mailers through FTEP entitled Multi-
Millionaire Jose Juarez Scammed Taxpayers! (“Hit Piece 1”), and Illegal Aliens are Streaming
Across our Border. Bringing Fentanyl and Gang Violence. (“Hit Piece 2”) (collectively “Hit
Pieces”). Copies of the Hit Pieces are enclosed.
It is obvious and apparent that no independent investigation or research was done to support
either mailer as they would never have otherwise been published. The Hit Pieces are clearly
libelous statements which were maliciously published not only to negatively affect Mr. Juarez’s
Floridians for Ethics and Truth in Politics
Front Line Strategies, Inc.
Ryan Chamberlin Campaign

February 27, 2023

campaign for District 24 but also to tarnish his business reputation. Mr. Juarez has built a good
and strong reputation over the years in the community as a successful entrepreneur and business
owner. Mr. Juarez founded and has successfully built Victory Solutions Inc., a marketing firm, and
Barbacuban, a BBQ Sauce Company with Cuban fusion. Yet, through the Hit Pieces, you are
attempting to create false impressions about Mr. Juarez’s political campaign, his career, and
business reputation. In addition to making baseless and false accusations about Mr. Juarez, the Hit
Pieces also juxtapose a series of facts (intentionally taken out of context) to imply a defamatory
connection and then omit facts to create false impressions. Such publications constitute actionable
defamation under Florida law.
Notably, Hit Piece 1 attempts to mislead readers and is defaming Mr. Juarez by falsely
claiming that Mr. Juarez has “scammed taxpayers” by allegedly not repaying certain “taxpayer-
funded bailout loans.” Such an assertion is false on its face, or at a minimum defamation by
implication, as Hit Piece 1 specifically and crucially omits the fact that there was no requirement
to pay back such loans. It is clear that you published Hit Piece 1 to create a false impression in the
public that Mr. Juarez did something improper when, in fact, there was no legal obligation to repay
the loans, which was true with many other businesses.
Similarly, Hit Piece 2 falsely claims that Mr. Juarez’s Campaign is funded by ‘Woke
Corporations’, which is completely false. A review of the contributions made to Mr. Juarez’s
Campaign via the Florida Department of State Division of Election’s Campaign Contribution
website would show that no such “Woke Corporations” have contributed to or otherwise funded
Mr. Juarez’s Campaign.
Hit Piece 2 further falsely alleges and implies an improper and false connection between
Mr. Juarez and President Biden. Hit Piece 2 claims that they have the same “friends” and “that see
eye to eye on weak border policy” without naming any of the third parties that are allegedly
funding Mr. Juarez’s Campaign or supporting an alleged weak border policy. Such mailer once
more omits crucial information in an attempt to mislead their readers. Any research conducted
would have confirmed no such connections exist with Mr. Juarez’s campaign and no contributions
from such parties were ever received.
Needless to say, such defamatory statements were made by FLA and FETP on behalf of
the Ryan Campaign maliciously and in a deliberate attempt to damage Mr. Juarez’s personal and
professional reputation and gain an improper advantage in the election. The dissemination of the
Hit Pieces has also damaged Mr. Juarez’s business reputation which will last beyond the election.
Accordingly, DEMAND is hereby made for FLA, FETP and the Ryan Campaign to retract
the Hit Pieces immediately upon receipt of this notice. This letter shall further serve as a
DEMAND that you CEASE and DESIST from any and all future publication of the Hit Pieces
as well as publishing any of the false statements used therein on any other mailer or campaign
propaganda.

2
TOBIN, REYES, ALVAREZ, & DE BIASE, PLLC
MIZNER PARK OFFICE TOWER • 225 N. E. MIZNER BOULEVARD, SUITE 510 • BOCA RATON, FLORIDA • 33432
 If you fail or refuse to retract the Hit Pieces as demanded herein and continue publication
of any of the false statements therein, we will proceed to file an action for libel seeking injunctive
relief to prevent further interference with the District 24 campaign and join all parties involved in
publishing of the defamatory remarks. We will also seek an award of compensatory and punitive
damages for the ongoing harm that has been caused by the defamation.
This letter shall also constitute notice to preserve and not destroy any evidence related to
the publication of the Hit Pieces, including all documents, drafts, checks, invoices, wire transfers,
communications, recordings and electronically stored information. This litigation hold specifically
encompasses communications and information exchange with any political campaigns. Failure to
comply with this demand may subject you to additional liability for Court-imposed sanctions based
upon any spoliation of evidence.

PLEASE GOVERN YOURSELF ACCORDINGLY.

TOBIN, REYES, ALVAREZ

& DE BIASE, PLLC

s/Ricardo A. Reyes
Ricardo A. Reyes, Esq.

Encls.

3
TOBIN, REYES, ALVAREZ, & DE BIASE, PLLC
MIZNER PARK OFFICE TOWER • 225 N. E. MIZNER BOULEVARD, SUITE 510 • BOCA RATON, FLORIDA • 33432