UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
Ronald Wayne Clark Jr.
Ken Tucker Sec. Dept. of Corrections, et al, Defendants
Case No. 3:11-CV-1051-J-34TEM
MOTION SEEKING A TEMPORARY TRAINING RESTRAINING ORDER
Comes now the plaintiff Ronald Wayne Clark Jr prose before this Honorable Court, in this motion seeking a Temporary Restraining order, in an attempt to stop Defendants from retaliating and "endangering plaintiff's life" as defendants did last year, while plaintiff was conducting a hunger strike.
Plaintiff avers the following:
1.) Defendants began retaliating against plaintiff in May 2011 over plaintiff's blog site www.thedeathrowpoet.blogspot.com which got shut down due to the retaliation.
2.) Plaintiff filed this retaliatory First Amendment violation lawsuit in late 2011 and the amended complaint.
3.) Since then plaintiff has been seeking out counsel to no avail. Please see [Exhibit (A)] legal correspondence from Florida Justice Institute. I contact the lawyer referral service of the Florida Bar who referred me to Jacksonvilles Referral Service, who I have yet to hear from.
4.) On April 3, 2012 one of the defendants, Bennett Kilgore, came to my cell P-2204 and began harassing me and threatening me, stating "you don't need to say anything to me. I can make you say anything that I want you to say," which he and C.O. Timothy Slone did back on Sept. 9, 2011 in DR#213-111515.
5.) Plaintiff would file Grievance of Reprisal #1204-213-055 which was returned without action.
6.) Plaintiff on April 19, 2012 would file Informal Grievance #04-12-294, please see attached as [Exhibit (B)], that was was returned on April 26, 2012, stating the allegations will be handled by the chief of security and the Inspector General's office.
7.) Three days later plaintiff was set up with a bogus DR#213-120732 written by C.O. Aaron D. Stokes who states on April 29, 2012 while searching my cell P-2204 he found a rolled cigarette behind my light. Please see attached DR Appeal that is being filed on May 16, 2012 as [Exhibit (C)].
8.) Plaintiff had also been making an issue over Lt. Kilgore's dismissal over the August 15, 2009 assault of inmate Paul Kennedy, please see attached [Exhibit (D)] Bradford County telegraph that has been placed on both of plaintiff's blogs in April 2012. See blogs http://thedeathrowpoet.wordpress.com and http://betweenthebars.org/blogs/1581/ronald-w-clark-jr.
9.) Defendants have continued the retaliatory shakedowns since last year and are constantly leaving plaintiff's legal files in shambles, which is going to make it impossible for plaintiff to represent himself.
10.) Plaintiff on June 1, 2012 is going to conduct a hunger strike, a peaceful protest to bring attention to what has been taking place here (the retaliation and other inhuman abuse), in hopes of not only stopping it and bringing change but also hoping that an attorney will see this document and the Civil Rights Complaint and assist plaintiff in progressing this case.
11.) Last year during a hunger strike that took place from May 20 through June 9, defendants retaliated and placed plaintiff in a strip cell in R Dorm cell #1202 taking plaintiff's mattress, blanket, clothing, toilet paper, etc. and leaving plaintiff in cell R-1202 with the air condition blasting with plaintiff in nothing but his underwear.
12.) That was a very dangerous situation, for which defendants may repeat, and endanger plaintiff's health and safety. Plaintiff is not trying to commit suicide, plaintiff is simply trying to stop the constitutional violations that are taking place here under this administration and stop all further retaliation. Please see attached Formal Complaint dated May 3, 2012 as [Exhibit (E)].
13.) Plaintiff for over a year has been trying to better the conditions of death row, see memorandum as [Exhibit (F)] and the April 20, 2011 Response as [Ehibit (G). Plaintiff is conducting this hunger strike to bring needed attention to.
14.) Plaintiff has a constitutional right to conduct this hunger strike and refuses medical intervention under Art I sec 23 of the Fla. Constitution, see attached as [Exhibit (H)] Singletary v. Costello, 665 so. 2d. 1099 (Fla. APP. 4 Dist 1996) without retaliation from the defendants or interference from the D.O.C.
Wherefore plaintiff prays that this honorable court will issue a T.R.O. stopping the defendants from endangering plaintiff's life during this June 1, 2012 hunger strike.
May 16, 2012
Ronald W. Clark Jr
2013 may 18
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