Educational Purpose

 WHEREFORE, Petitioner respectfully requests that this Court:

I. Regarding Count I (Mandamus):

Issue a Writ of Mandamus commanding the Respondent to immediately produce the requested public records for inspection and copying;

II. IN THE ALTERNATIVE, Regarding Count II (Declaratory/Injunctive Relief):

Enter a Declaratory Judgment finding that the records requested by Petitioner are "public records" as defined by Chapter 119, Florida Statutes, and that no statutory exemption applies to justify their withholding;

Issue a Permanent Injunction requiring Respondent to provide Petitioner access to said records;

III. Regarding All Counts:

Conduct an In Camera Inspection of the records if the Respondent claims any portion is exempt, to verify the validity of such claims;

Award Petitioner Reasonable Attorney’s Fees and Costs pursuant to Section 119.12, Florida Statutes, as the Respondent has unlawfully refused access to public records;

Grant an Immediate Hearing on this matter as required by the accelerated hearing provisions of Section 119.11, Florida Statutes; and

Grant such other and further relief as this Court deems just and proper.

WHEREFORE, Petitioner respectfully requests that this Court:

I. Regarding Count I (Mandamus):

Issue a Writ of Mandamus commanding the Respondent to immediately produce the requested public records for inspection and copying;

II. IN THE ALTERNATIVE, Regarding Count II (Declaratory/Injunctive Relief):

Enter a Declaratory Judgment finding that the records requested by Petitioner are "public records" as defined by Chapter 119, Florida Statutes, and that no statutory exemption applies to justify their withholding;

Issue a Permanent Injunction requiring Respondent to provide Petitioner access to said records;

III. Regarding All Counts:

Conduct an In Camera Inspection of the records if the Respondent claims any portion is exempt, to verify the validity of such claims;

Award Petitioner Reasonable Attorney’s Fees and Costs pursuant to Section 119.12, Florida Statutes, as the Respondent has unlawfully refused access to public records;

Grant an Immediate Hearing on this matter as required by the accelerated hearing provisions of Section 119.11, Florida Statutes; and

Grant such other and further relief as this Court deems just and proper.

Because you are filing a Petition for Mandamus, you generally need to "verify" the document. This means adding a short statement at the end, before your signature, stating under penalty of perjury that the facts in the petition are true.

also there should be a jurat

Under Florida Statute § 117.05, a jurat must specifically state whether you appeared in person or via audio-video technology. Here is the exact wording you should use at the end of your petition:

STATE OF FLORIDA
COUNTY OF [Name of County]

The foregoing instrument was sworn to (or affirmed) and subscribed before me by means of [ ] physical presence or [ ] online notarization, this ____ day of ________, 2026, by [Your Full Legal Name], who is personally known to me or who has produced ______________________________ as identification.

Notary Public, State of Florida
(Print, Type, or Stamp Commissioned Name of Notary Public)
(Affix Notary Seal/Stamp)

Before you head to the Notary, ensure you have:

Numbered every paragraph in your statement of facts.

Attached your Public Records Request (the email or letter you sent) as "Exhibit A."

Attached any denial or "radio silence" logs as "Exhibit B."

I did my best with 1 subject, 1 verb statements.  Since "piercing the corporate veil" is an extremely high bar in NC, I instead plead facts that show participation, ratification, scienter, etc.  Causes of action plead all of the elements for each with facts.

I did my best to tell a chronological story with necessary facts and then give the reasons why I demand relief.  It is a case of first impression from my research in Westlaw and elsewhere.

I served Discovery at the same time as the summons and complaint.  It took a couple of months to create a coordinated discovery strategy against all defendants that creates prisoner dilemmas between each defendant and uncomfortable questions that need to be answered. 

I had a few more causes of action and defendants listed in the current complaint.  However I decided to scale back and leave the 3 COAs & 4 defendants that would best survive 12(b)(6).  When I get to discovery, I've designed it in a way that should produce evidence that will lead to more causes of action and more defendants that I could petition to amend the complaint...when justice so requires - i felt like that was safer and more conservative.

my main focus now, is back to studying the Rules of civil procedure, Local rules, Doc's courses, and preparing for 12(b)(6).

With a timeline.  Dates, times, what you did to followup.   Emails, phone calls, left message.   Whatever you did and they didn't respond

Thanks Ill use this kind of list for verbal request in recorded administrative hearings that no one granted or took as testimony but they have recorded (audio recordings, and they record it in some of the judges’ hearing notes that I discovered exist in their computer systems, one of these BAR member attorneys pretending to be “judges” denied his own reason for adjournment a few months earlier, but now I know it exists in a “record” that they deny me access to while writing that exact right in their “decision” full of made up “facts” that no party ever said existed nor is there Any records or proof, these BAR members are licensed to steal and licensed to be frauds).

Just throwing this out here: In the future, being a "Certified Litigator" will be more powerful than a "licensed attorney" - Grant it Lord.

Also, you could post an interesting podcast titled "Mistakes people make when trying to litigate and win their own cases." 1. They file in the wrong court. 2. They don't prove the elements of their cases. 3. This, that and the other.... Create enough interest to compel your followers to subscribe to your courses. 

Catherine Albertini:
Tips to win a court case!
https://youtube.com/shorts/E_df4uiTw_g?si=EG5QBrEQCiC-uH3x

Here is one example of what you can do Dr. Graves

How To Defend Yourself in Court without a Lawyer (and Win): Tips from Aw...
https://youtube.com/watch?v=qQ7uj7PyVaY&si=Iz6Z1lfqd_fQOirS