Filing # 235838629 E-Filed 11/14/2025 03:11:34 PM

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT

IN AND FOR ORANGE COUNTY, FLORIDA

Case No.: ____________________

REGINA HILL,

Plaintiff/Contestant,
v.

SHANIQUA ROSE and

CITY OF ORLANDO CANVASSING BOARD,

Defendants.
______________________________/
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COMPLAINT TO CONTEST ELECTION

COMES NOW the Plaintiff, Regina Hill, by and through her

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undersigned attorney, and hereby contests the election held on November 4,

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2025, for the office of City Commissioner, District 5, City of Orlando, Florida,
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and alleges as follows:
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Jurisdiction and Venue

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1. This Court has jurisdiction pursuant to Fla. Stat. § 102.168.

2. Venue is proper in Orange County because the contested election

occurred in the City of Orlando.

3. Plaintiff has standing to bring suit as an unsuccessful candidate in the

subject election.

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4. This Complaint is timely, as the election results in question were

certified by the City of Orlando Canvassing Board on November 7, 2025.

Parties

5. Plaintiff Regina Hill, whose address is 100 S. Cottage Hill Orlando,

Florida 32805, was an unsuccessful candidate in the election for the office of

City Commissioner, District 5, City of Orlando, Florida.

6. Defendant Shaniqua Rose prevailed in that election.

7. Defendant City of Orlando Canvassing Board includes its individual

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members/officials, Stephanie Herdocia, Patty Sheehan, Bakari F. Burns.

Facts
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8. The election for City Commissioner, District 5, City of Orlando, held
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on November 4, 2025, resulted in a certified victory for Defendant Shaniqua

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Rose.
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9. After the election, Plaintiff discovered credible evidence of violations

of Fla. Stat. § 102.168 committed by or on behalf of Defendant Shaniqua

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Rose, also known as Shan Rose, as described below.

Count I - Violation of Fla. Stat. § 102.168(3)(D) - Offering Voters Money,

Property and Things of Value.

10. On or about July 10, 2025, an associate of Defendant Rose’s campaign,

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Joneal Brunner, gave or promised “things of value” to voters in exchange for

their votes.

11. Specifically, Mr. Brunner offered each individual voter health testing

and screening valued between $2,500 and $3,500, as well as Visa gift cards

worth $45.00.

12. These items, which constituted “things of value” for purposes of Fla.

Stat. § 102.168(3)(D), were provided through Care Access Research LLC

(“Care Access”).

13.
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Mr. Brunner describes himself as an “Ambassador” for Care Access.

See Exhibit A.
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14. Defendant Rose, or someone acting on behalf of her campaign,
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distributed campaign flyers throughout District 5 offering those same “Free

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Health Screenings” valued between $2,500 and $3,500, as well as a $45.00

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Visa gift card for individuals who visited Care Access. See Exhibit B.
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15. The flyers depict a QR code that linked to a webpage

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https://jojotaxi.com/careaccess/, which when accessed during the timeframe

of the election displayed several “Free Health Screenings” locations, all oddly

located in Seminole County, Florida.

16. The webpage also directed visitors to call or text (407) 917-2868 for

questions, and at the bottom of the page prominently displays a “Support Shan

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Rose” advertisement very similar to the ones used by Defendant Rose during

her most recent campaign, accompanied with a link to

www.voteshanrose.com. See Exhibit C, Screenshots of web page

https://jojotaxi.com/careaccess/.

17. The phone number (407) 917-2868, which belongs to Mr. Brunner, is

also featured prominently in advertisements published on Facebook and

elsewhere promoting campaign events sponsored by and held for Defendant

Rose, which establishes Mr. Brunner’s affiliation with her campaign. See
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Exhibit D, Screenshot of Facebook advertisement.

18. Mr. Brunner’s (407) 917-2868 phone number is listed as a contact in

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another Facebook post from Defendant Rose’s official “District 5, City of
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Orlando” account, which also promoted the $2,500-$3,500 Care Access and
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$45 Visa gift cards prior to the date of the election. See Exhibit E, Facebook
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screenshot.
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19. Another Facebook post from that same “District 5, City of Orlando”
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account contains Mr. Brunner’s (407) 917-2868 phone number and is

accompanied by a digital flyer identical to the flyer in Exhibit B except for

the fact that the QR code directs users to another website,

https://cardiometabolicscreening.careaccess.com/en/community/lady-lake,

which shows that Defendant Rose had the opportunity to provide the benefit

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without linking it to her campaign, but chose instead to avail herself of the

illegal campaign tactic of offering voters things of value in exchange for their

support and votes. See Exhibit F, Facebook screenshot of post with flyer.

20. On November 7, 2025, after Defendant Rose was publicly made aware

of the allegations involving the violation of Fla. Stat. § 102.168(3)(D), she, or

someone on her behalf, altered the website to delete the illegal campaign flyer

from it. See Exhibit G, Screenshot of webpage and screenshot of internet

archive of updates to the page via www.web.archive.org.

21.
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The rapid deletion of inculpatory evidence from the website establishes

that Defendant Rose sought to hide her actions from the public and insulate
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herself from the courts.
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22. On November 8, 2025, Cameron Hope spoke with Joneal Brunner by

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phone and asked him about his involvement in creating the website linked to
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the QR code on the flyer in Exhibit B.
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23. Mr. Brunner admitted to Mr. Hope that he created and published the
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page under the instruction and approval of Defendant Rose. See Exhibit H,

Affidavit of Cameron Hope.

24. Mr. Brunner also admitted that there were two QR codes used, one of

which directed users to the official Care Access website, while another QR

code directed voters to the jojotaxi.com website shown in Exhibit C that

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contained campaign-related material, including images and language

soliciting voters by offering them free health screenings worth between

$2,500 and $3,500, as well as $45.00 Visa gift cards.

25. By November 6, 2025, the web page https://jojotaxi.com/careaccess/

had 383 views according to the counter embedded for view. See Exhibit C.

26. This shows that the page reached 383 voters who were targeted in

District 5 by Defendant Rose, in violation of Fla Stat. § 102.168(3)(C), which

states that “Proof that any voter, election official, or canvassing board member
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was given or offered a bribe or reward in money, property, or any other thing

of value for the purpose of procuring the successful candidate’s nomination

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or election or determining the result on any question by referendum or
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constitutional amendment” provides a ground for contesting an election.

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Count II - Violation of Fla Stat. § 102.168(3)(C) - Ballot Harvesting

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27. On November 10, 2025, Cameron Hope conducted interviews with
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several elderly residents at Guardian Care Facility, 350 S. John Young

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Parkway, Orlando Florida. See Exhibit I.

28. Those interviews revealed that, on or about October 22, 2025,

individuals associated with Defendant Rose’s campaign collected absentee

ballots from voters without lawful chain of custody, including ballots cast by

residents Dallas Rhynes and Nathaniel Malone.

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29. When asked about voting, Mr. Malone reported that he did not fill out

a ballot or vote, which conflicts with a ballot purportedly cast in his name on

October 22, 2025.

30. The interviews with voters also show a coordinated effort by multiple

individuals acting in coordination with Defendant Rose’s campaign to

request, fill out and collect ballots from other residents in the facility.

31. On or about October 27, 2025, during the election, Reginald Sinclair

personally observed an individual identified as a campaign worker for

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Defendant Rose engaging in activity that included signing and picking up a

ballot of Judy Lokenauth. See Exhibit J.

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32. Upon information and belief, the number of illegal votes harvested by
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Defendant Rose’s campaign were sufficient to change or place in doubt the

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result of the election.

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33. The foregoing actions violate Fla Stat. § 102.168(3)(C), which lists
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“Receipt of a number of illegal votes or rejection of a number of legal votes

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sufficient to change or place in doubt the result of the election” as a ground

for contesting an election.

Relief Requested

Based on the foregoing, Plaintiff respectfully requests that this Court:

A. Declare that the election held on November 4, 2025, for City

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Commissioner, District 5, City of Orlando, is invalid due to violations of Fla.

Stat. § 102.168(3)(C)-(D)

B. Order the Canvassing Board to set aside its certification and either

declare Plaintiff the winner or order a new election; and

C. Award Plaintiff other relief deemed just and appropriate.

Respectfully submitted,

/S/ Andrew B. Greenlee

Andrew B. Greenlee, Esq.
Florida Bar No. 96365
ANDREW B. GREENLEE, P.A.
um rt ial 401 East 1st Street, Unit 261
Sanford, Florida 32772
(407) 808-6411
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[email protected]
Counsel for Plaintiff
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