FLORIDA STATUTE 768.28 NOTICE OF CLAIM
Florida Statute 768.28 is the state's waiver of sovereign immunity, which allows individuals to sue the state and its agencies for certain torts, such as negligence, up to a specified monetary limit.
It also establishes a claims process requiring a written notice to the state agency and the Florida Department of Financial Services within three years of the incident before a lawsuit can be filed.
There are limits on recovery, with the state not liable for more than ($200,000) per person or ($300,000) in total for a single incident…
* Unless the act was committed in bad faith or with malicious intent.
To view Florida Statute 768.28, click on the link below or see the PDF version below.
Link to Florida Statute 768.28
It also establishes a claims process requiring a written notice to the state agency and the Florida Department of Financial Services within three years of the incident before a lawsuit can be filed.
There are limits on recovery, with the state not liable for more than ($200,000) per person or ($300,000) in total for a single incident…
* Unless the act was committed in bad faith or with malicious intent.
To view Florida Statute 768.28, click on the link below or see the PDF version below.
Link to Florida Statute 768.28
WRITTEN NOTICE OF CLAIMS TO HILLSBOROUGH COUNTY SHERIFF, HILLSBOROUGH COUNTY, CITY OF TAMPA, THE TAMPA AQUARIUM,
PORT OF TAMPA AND FLORIDA DEPARTMENT OF FINANCIAL SERVICES
PURSUANT TO FLORIDA STATUTE § 768.28
Date: December 9, 2025
WRITTEN NOTICE OF CLAIMS TO HILLSBOROUGH COUNTY SHERIFF, HILLSBOROUGH COUNTY, CITY OF TAMPA, THE TAMPA AQUARIUM,
PORT OF TAMPA AND FLORIDA DEPARTMENT OF FINANCIAL SERVICES
PURSUANT TO FLORIDA STATUTE § 768.28
Subject: Hillsborough County Sheriff’s Deputy Desirae Krouse ABN 199236
Date: January 21, 2023
Location: Port of Tampa Terminal 2, The Tampa Aquarium Channelside Drive, Tampa, Florida
Incident: Unlawful Traffic Stop and Citation
Citation: AGD50KE (Failure to Yield to Public Transit Vehicle (Streetcar/trolley)
Traff. Ct No.: 23-TR005347
Cir. Ct. No.: 23-CA-12145
Office of Professional Standards Case No.: I-2023-008.
Hillsborough County Sheriff’s Office
Chad Chronister - Sheriff
Post Office Box 3371 Tampa, Florida 33601-3371
Sent Via Certified US Mail # 7022 3330 0000 6336 9984
Florida Department of Financial Services,
Division of Risk Management
200 E. Gaines Street Tallahassee, Florida 32399-0338
Sent Via Certified US Mail # 7022 3330 0000 6336 9991
Hillsborough County Board of County Commissioners
601 E. Kennedy Blvd. #2 Tampa, Florida 33602
Sent Via Certified US Mail # 9589 0710 5270 3548 7074 07
Ms. Amanda Granit - Chief Communications Officer
(HCSO) 1201 E. Orient Road, Tampa, FL 33619
Sent Via Certified US Mail # 7022 2410 0000 0981 9557
Ms. Kathryn Heller - Risk Management Director
Hillsborough County Sheriff's Office (HCSO)
725 E Kennedy Blvd, Tampa, FL 33602
Sent Via Certified US Mail # 7022 2410 0000 0981 9540
Mr. Paul Anderson - President and CEO - Port Tampa Bay
1101 Channelside Drive, Tampa, FL 33602
Sent Via Certified US Mail # 7022 2410 0000 0981 9533
Mr. Christopher Cooley - Environmental Director - Port Tampa Bay
1101 Channelside Drive, Tampa, FL 33602
Sent Via Certified US Mail # 9589 0710 5270 3548 7074 45
Mr. Charles E. Klug - Port Tampa Bay Counsel
1101 Channelside Drive, Tampa, FL 33602
Sent Via Certified US Mail # 7022 3330 0000 6337 0003
The Florida Aquarium
Attn: Executive Office / General Counsel
701 Channelside Dr. Tampa, FL 33602
Sent Via Certified US Mail # 9589 0710 5370 3548 7074 38
Mr. Roger Germann - President and CEO
The Florida Aquarium
701 Channelside Dr. Tampa, FL 33602
Sent Via Certified US Mail # 9589 0710 5270 3548 7073 91
Ms. Kimberly Casey
The Florida Aquarium
Risk Management, and Business Operations.
701 Channelside Dr. Tampa, FL 33602
Sent Via Certified US Mail # 9589 0710 5270 3548 7073 84
City of Tampa
Risk Management/Claims
306 East Jackson Street Tampa, Florida 33602
Sent Via Certified US Mail # 9589 0710 5270 3548 7074 21
City of Tampa Mayor's Office
Attn: Honorable Mayor Jane Castor
306 East Jackson Street Tampa, Florida 33602
Sent Via Certified US Mail # 9589 0710 5270 3548 7074 14
Also Listed:
Hillsborough County Sheriff Deputy Corporal Desirae Krouse
Hillsborough County Sheriff Deputy Todd Farrell
Hillsborough County Sheriff Deputy Demetrios Antoniades
Hillsborough County Sheriff Deputy Natalie Niemann
Hillsborough County Sheriff Deputy * Ortiz # 255462 (* First name redacted)
Claimant: Spiros C. Paizes
Address: 5719 39th Street Circle E. Bradenton, Florida 34203
Date of Birth: July 3, 1959
Social Security No. ▇▇▇▇▇▇ (REDACTED)
Place of Birth: Johannesburg, South Africa
Date of Incident: January 21, 2023
Incident Location: Hillsborough County, Florida
Type of Claim: Unlawful Traffic Stop and Citation and Other Claims.
Dear Hillsborough County Sheriff’s Office, Florida Department of Financial Services, Hillsborough County Board of County Commissioners, Port Tampa Bay, The Tampa Aquarium, City of Tampa, and the Honorable Tampa Mayor Jane Castor;
This notice is timely submitted pursuant to section § 768.28 Florida Statutes.
Notice is hereby given of forthcoming lawsuit(s) related to events that took place beginning January 21, 2023, at or near the Tampa Aquarium and Port of Tampa (Port Tampa Bay) Cruise terminal 2 at or about 651/701 Channelside Drive Tampa, Florida 33602.
It is my intent to provide you with information to enable you to come to an agreement to resolve this case without the need for litigation. I hereby request a meeting to discuss the possibility of resolving the case in favor of myself and without incurring unnecessary litigation costs that would only serve to further burden Florida's taxpayers.
However, one hundred eighty (180) days from the date of this notice, should this claim be unresolved, I will bring an action against Hillsborough County Sheriff’s Office, Hillsborough County, Port of Tampa, The Tampa Aquarium and the City of Tampa and others for all the damages suffered.
Nothing in this notice should be interpreted or is intended as a waiver by myself or my survivors to bring any other claim(s) or action(s), based on the relevant facts, against Hillsborough County Sheriff’s Office, Hillsborough County, Port of Tampa, The Tampa Aquarium, the City of Tampa or others or any other state agency, or any other person or party, for which pre-suit notice is unnecessary.
If I have failed to comply with Florida Statute § 768.28(6)(a) in any manner whatsoever, please advise accordingly by return mail specifying how I have failed. If there are any other agencies or entities that have liability for the injuries sustained for the claims, I ask that you provide this information and a copy of this Notice to them.
I am aware of no adjudicated penalties, fines, fees, victim restitution fund, and other judgments in excess of $200.00, whether imposed by civil, criminal, or administrative tribunal, owed by myself to the State of Florida, its agency, office or subdivision, any prior adjudicated unpaid claims in excess of $200.00.
The forthcoming lawsuit(s) will prove the following causes of action:
CLAIM 1
Unlawful Stop / False Detention / Threat of False Arrest
CLAIM 2
Deputies Committing Perjury in Sworn Administrative Interviews
CLAIM 3
Obstruction of Justice /Negligent Investigation
Failure to Report Known Perjury and Misconduct by Sworn Officers
CLAIM 4
Perjury by Deputy Krouse During Traffic Court Hearing
CLAIM 5
False Official Statement / Falsification of Records / Perjury
CLAIM 6
Assault and Battery
CLAIM 7
Obstruction of Justice (Interfering With Traffic Laws and Court Hearing)
CLAIM 8
Abuse of Process
CLAIM 9
Abuse of Power and Authority
CLAIM 10
Negligence – Failure of On Scene Officers to Intervene
CLAIM 11
Deliberate Falsification of Citation
CLAIM 12
Defamation / Slander and Damage to Reputation
CLAIM 13
Intentional Infliction of Emotional Distress
CLAIM 14
Obstruction of Justice by Sworn Officers and Investigating Detectives
Negligent Failure of Professional Standards Detectives to Act
AND OTHER CLAIMS
Pursuant to Florida Statute § 768.28, please accept this Notice of Claim. If this matter is not resolved within 180 days I will initiate civil action asserting the claims described herein and below. This notice preserves all claims and remedies arising from the January 21, 2023, incident involving:
(a) Hillsborough County Sheriff’s Deputy Corporal Desirae Krouse.
(b) All other Hillsborough Sheriff Office employees present during incident.
(c) Traffic citation AGD50KE issued by Krouse.
(d) Hillsborough County Sheriff’s Office Professional Standards-Internal Affairs personnel and their handling of the complaint against deputy Desirae Krouse, and subsequent investigatory decisions and findings.
(e) The professional relationship and contracts between the following agencies and businesses, and their respective employees:
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, The Port of Tampa and the City of Tampa.
II. STATEMENT OF CASE AND FACTS
1. On January 21, 2023, I was driving myself, my wife Maria Paizes, disabled mother-in-law Dolores Konior, and friend Margaret (Peggy) O’Neill from Bradenton, Florida, to visit the Tampa Aquarium at the Port of Tampa on Channelside Drive to celebrate Ms. O’Neill’s 70th birthday.
2. Several Hillsborough County Sheriff deputies were outside the Port of Tampa and The Tampa and Aquarium controlling and directing the flow of traffic in the area.
3. I was seeking the closest point to the Aquarium to drop my passengers before parking when I was given directions from Deputy * Ortiz (ABN 255462 * First name redacted) to enter The Tampa Aquarium driveway which requires crossing streetcar/trolley rail tracks.
4. As I proceeded, Deputy Corporal Desirae Krouse signaled for me to stop; I complied and came to a complete stop more than ten feet from the streetcar tracks where Deputy Desirae Krouse, Deputy Natalie Neimann and Deputy Demetrios Antoniades were posted.
5. Hillsborough Transit Authority (HART) Streetcar No. 430 operated by Motorman Ralph Rosado passed the scene without slowing or stopping and without sounding its audible external horn.
6. After the streetcar/trolley passed, I proceeded forward where I was confronted by an unreasonably hostile and rude deputy Desirae Krouse. Confused by her behavior I stated, “there’s no need to be rude.” My comment visibly enraged deputy Krouse further.
7. Deputy Desirae Krouse then engaged in an extended, hostile encounter, threatened to arrest me, detained my person and driver’s license, scared and detained my passengers who were relying on me for transport.
8. During the illegal stop I repeatedly objected to deputy Desirae Krouse concerning the lack of probable cause to conduct the stop, demanded a supervisor and repeatedly insisted that she turn her body worn camera on to record the incident, all to no avail.
9. Deputy Desirae Krouse issued an unfounded, bogus citation charging me with failing to yield to a transit vehicle (F.S. § 316.0815(1)), alleging that the trolley was forced to sound its horn and come to a stop to avoid a collision with my vehicle.
10. The encounter lasted between 20 and 25 minutes and each moment was a horrifying experience.
11. Afterward, I obtained HART forward and rear facing dash cam videos from the trolley named in the citation that showed my vehicle stopping safely several feet from the tracks.
12. I also obtained passenger (in my vehicle) affidavits detailing passengers’ observations of the unlawful stop, deputy Desirae Krouse’s demeanor and the effect the experience had on them.
13. On March 28, 2023, I attended a traffic hearing (video recorded) to challenge the citation. Traffic Hearing Officer Joseph Frank found me guilty and upheld the citation despite video evidence and affidavits disproving deputy Desirae Krouse’s allegations.
14. I then challenged the traffic hearing officer’s findings in the Circuit Court in its appellate capacity, where Judge Lindsay Alvarez reversed the decision on November 20, 2024.
15. Specifically, the appellate Court found that the record lacked competent, substantial evidence to support the citation, and that the video contradicted officer testimony, noting several irregularities regarding deputy Desirae Krouse’s testimony and other deputies called by Krouse as witnesses.
16. Although the Circuit Court’s official ruling was in reference to the lack of competent, substantial evidence, the court noted several instances of procedural safeguard violations during the hearing.
17. I filed a complaint with the Hillsborough County Sheriff’s Office, Professional Standards Bureau-Internal Affairs (PSB Case No.: I-2023-008), regarding deputy Desirae Krouse’s misconduct, followed by a supplemental complaint that included evidence I obtained.
18. Professional Standards investigators were provided copies of the trolley videos, and the independently obtained surveillance footage from the Port of Tampa of the incident.
19. Master Detective Belinda Denbigh, led the investigation and conducted numerous (20) audio recorded interviews (while under oath and penalty of perjury) with every officer present at the scene, myself, each of my passengers, the trolley motorman, and other Sheriff’s Office employees.
20. Unaware that surveillance footage existed, several officers provided knowingly false and misleading sworn statements concerning my alleged conduct and deputy Desirae Krouse’s misconduct in an coordinated attempt to shield Krouse from disciplinary proceedings.
21. Investigators ultimately determined that Krouse only violated department policy regarding the proper use of body worn cameras and her failure to activate her body camera when conducting the illegal stop and detention in this case.
22. The Professional Standards detectives took no action regarding the validity, or lack thereof, regarding the traffic stop, me and my passengers’ detainment, or the citation Krouse wrote alleging known false traffic violations.
23. Those findings were made before the Circuit Court reversed the traffic hearing court’s order, finding a complete lack of evidence to support the citation, while criticizing the traffic hearing as a whole, including harsh critique of deputy Krouse and her fellow deputy witnesses.
24. Despite having all relevant evidence and compelling video footage, Professional Standards Bureau personnel failed to notify their superiors that officers interviewed in connection with this case had knowingly offered dishonest statements, and did not take any action to confront or discipline the officers’ perjury.
25. The Professional Standards Bureau’s failures are indicative of a widespread problem regarding officer integrity and honesty, pointing to a department-wide culture of covering-up and wrongdoing. It is quite alarming and troublesome to consider that internal affairs investigators, along with officers present at the scene, so readily colluded to cover up deputy Desirae Desirae Krouse’s misconduct even in the face of conclusive video, witness affidavit and testimony evidence to the contrary.
26. The recent Hillsborough County Sheriff’s Office cheating scandal involving the resignation and/or termination of multiple high-ranking officers further strengthens the evidence in this case proving a culture of dishonesty and corruption within the agency.
27. It should be noted that the Division Commander Lora Rivera of the Professional Standards Bureau-Internal Affairs who supervised the agents assigned to investigate this case was one of the officials who resigned amid the cheating controversy, and Master Detective Denbigh is no longer assigned to the Professional Standards Bureau.
28. Following the conclusion of the appellate process reversing the traffic citation in 2024, I requested my complaint be reopened. The Hillsborough County Sheriff’s Office declined, stating the agency maintained their initial investigation’s findings.
29. I have suffered prejudice and damages as a result of the incident described herein and seek legal redress.
III. EVIDENCE SUMMARY
The following list details evidence being provided to support this Notice and future litigation. I reserve the right to amend or add to this list at any time as more information becomes available.
1. Hillsborough Transit Authority (HART) forward and rear dash cam videos (Streetcar No. 430) showing continuous, unimpeded trolley movement with the Claimant’s vehicle fully stopped, well clear of tracks and the trolley not stopping or sounding nuts horn.
2. Passenger affidavits (Dolores Konior and Margaret O’Neill).
3. Certified March 28, 2023, traffic hearing transcript.
4. March 28, 2023, Traffic Hearing video, recorded at the hearing.
5. Circuit Court Opinion and Order dated November 20, 2024, reversing the hearing officer’s ruling for lack of competent, substantial evidence.
6. Internal Affairs/Department of Professional Standards documents and evidence, including but not limited to:
(a) Initial complaint.
(b) Supplemental Complaint.
(c) Email chains between Claimant and Professional Standards-Internal Affairs (IA) personnel.
(d) Official findings that Krouse violated body camera policy (failure to activate).
7. Cell phone video captured by passenger at scene.
8. Surveillance video footage recorded by the Port Tampa Bay.
9. Audio recorded interviews under oath conducted by Hillsborough Sheriff Professional Standards-Internal Affairs investigator Master Detective Belinda Denbigh with accompanying non-certified transcripts of the following witnesses:
(a) Demetrios Antoniades, 3/15/23
(b) Anastasia Castillo, 5/4/23
(c) Jillene Caydis, IA Interview (2 interviews), 5/4/23
(d) Todd Farrell, 3/20/23
(e) Brandon Hartz, 3/30/23
(f) Kennedie Jackson, 4/4/23
(g) Dolores Konior, 3/8/23
(h) Desirae Krouse, 3/29/23
(i) Desirae Krouse, 4/26/23
(j) Desirae Krouse, 5/5/23
(k) Eric Lampe, 5/4/23
(l) Sankar Mantute, 5/4/23
(m) Natalie Niemann, 3/15/23
(n) Margaret (Peggy) O’Neill, 3/9/23
(o) Christian Ortiz Ortiz, 3/20/23
(p) Maria Paizes, 3/1/23
(q) Spiros Paizes, 2/28/23
(r) Ralph Rosado, 3/16/23
(s) Mike Signoracci, 3/8/23
(t) Kyle Varnum, 5/4/23
(u) Hearing officer Joseph Frank apologizing for being wrong video.
The evidence proffered and listed herein is stored on the various secure websites including: www.TampaCivilRights.com, www.DesiraKrouse.com, www.TampaCivilRightsCoalition.com and others which can be located under the tab titled EVIDENCE on the left side of each website for easy access. Each of the websites is secure using SSL/TLS Encryption and has a SSL certificate to protect website visitors and data.
IV. DETAILED CLAIMS
ELEMENTS, RECORD FACTS, EVIDENCE, AND RELIEF SOUGHT
CLAIM 1
Unlawful Stop / False Detention / Threat of False Arrest
Factual Basis
Deputy Corporal Desirae Krouse subjected Claimant to an unlawful, unreasonably prolonged traffic stop without probable cause under threat of arrest. On January 21, 2023, Corporal Krouse stopped Claimant, retained his driver’s license, illegally detained his person, and prevented Claimant and his passengers from leaving for over twenty (20) minutes. The illegal stop and detainment ended with deputy Desirae Krouse issuing Claimant a citation for failing to yield to a public transit vehicle, and alleged that Claimant did not stop to or give an oncoming trolley the right-of-way, causing the trolley to come to a halt, nearly causing a collision.
Contemporaneously, HART forward/rear dash cam video from the very trolley passing through demonstrates that Claimant yielded well clear of the tracks, did not obstruct or force the streetcar to stop or avoid a collision. The video directly contradicts the factual basis of the citation. At the time deputy Desirae Krouse wrote the citation she did not know the moment was being captured on video by the passing trolley, and since she refused to engage her body-worn camera, Krouse incorrectly believed Claimant would not be able to disprove her fictitious, manufactured allegations in the citation.
Deputies Natalie Niemann and Demetrios Antoniadis testified consistently with the video at the subsequent hearing, confirming that Claimant yielded properly. Despite this, Corporal Desirae Krouse detained Claimant and ultimately issued the citation she knew was false.
The Circuit Court, upon later review, determined:
“It is plain from the video that Paizes did, in fact, yield to the streetcar. In this regard, the video contradicts the testimony of Corporal Krouse.... Most significant, the video shows that Paizes both obeyed Corporal Krouse’s command and yielded to the streetcar. Both Deputy Neimann and Deputy Antoniadis testified in accordance with what the video depicted, that is, they both confirmed that Paizes did not fail to yield.”
The Court further held:
"Upon review of the testimony and evidence presented, the Court finds that no competent, substantial evidence supports the Hearing Officer’s finding of guilt with respect to the infraction cited.”
The reversal confirms the absence of probable cause, and as a whole that the traffic stop was unlawful. The stop was unreasonably prolonged. A routine traffic stop and citation typically lasts less than ten minutes. Here, Claimant was detained more than twice the average length of a stop without justification. Claimant is currently a 66 year old law abiding citizen with no outstanding warrants, who provided his license under threat of arrest and duress. Two of his passengers were elderly women (70 and 83 years old) and one was disabled, along with Claimant’s 56 year old wife.
The persuasive video evidence proves the stop of Claimant and his passengers was with the intended purpose of retaliation and intimidation and concluded with the issuance of what deputy Desirae Krouse knew was a fraudulent citation. Whereas deputy Desirae Krouse initiated the traffic stop on known pre-textual grounds in order to issue a citation based on fabricated allegations, the entire time deputy Desirae Krouse kept Claimant and his passengers from freely going about their business was time that she illegally detained the group.
Deputy Krouse’s misconduct is undeniable as it is captured on video, creating certain liability for her employer and every business or agency that came to contract her services through the Sheriff’s Office; anyone who owns or operates the property where the incident occurred, and the Hillsborough County Sheriff’s Office and all of its employees present at the incident.
Conclusion
Defendants are bound by the Circuit Court’s order reversing the traffic hearing officer’s decision. That order, rendered by a court of competent jurisdiction, is the strongest legal evidence supporting Claimants allegations. The Court’s independent analysis reached the only inevitable conclusion possible. That Claimant and his passengers were illegally stopped and unlawfully detained by deputy Corporal Desirae Krouse who was disciplined for some of her misconduct (but not all), and who gave perjured testimony at a biased traffic court hearing. The circumstances described herein caused Claimant significant harm. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 2
Deputies Committing Perjury in Sworn Administrative Interviews
Factual Basis
During the Professional Standards investigation into deputy Corporal Desirae Krouse’s misconduct, five Hillsborough County Sheriff’s deputies provided sworn interviews under oath.
Each of these officers falsely claimed that Claimant (Paizes) failed to yield, obstructed the trolley, lied or otherwise engaged in conduct that justified Krouse’s citation, or falsely denigrated Claimant’s character.
Detectives had in their possession contemporaneous trolley video footage that conclusively disproved these sworn statements. The video showed Claimant properly yielding, the trolley continuing without slowing or stopping, and no obstruction or violation occurring.
The five Deputies, (Antoniadis, Farrell, Krouse, Neimann, and Ortiz) all provided what they knew were false statements of material fact and testimony when under oath and being interviewed (under oath and audio recorded) by Master Detective Belinda Denbigh. The officers intended to mislead the investigators and conceal misconduct by deputy Desirae Krouse.
Deputy Demetrius Antoniadis deceived Professional Standards Detectives when he knowingly provided false testimony stating that he heard the passing trolley sound its horn, and that deputy Desirae Krouse was justified in writing the citation because it was a close call in reference to the alleged near collision that never occurred. Although Antoniadis did concede that Claimant stopped when ordered, he also attempted to defend deputy Desirae Krouse’s misconduct when illegally detaining Claimant, and committed perjury in the process.
Deputy Todd Farrell deceived Professional Standards-Internal Affairs (PSB-IA) investigators when he claimed deputy Desirae Krouse explained to Claimant why she was giving him a citation. Krouse herself admitted that she did not inform Claimant the reasons for the citation. When asked what his response would be if Complainant denied being informed why he got a ticket, Farrell responded, “…[h]e’s lying.” Farrell did not know that deputy Desirae Krouse confessed not educating Claimant on her decision to cite him, nor did he realize a video from the trolley existed when he was interviewed for the investigation.
Deputy Desirae Krouse claimed that she informed her immediate supervisor, Sergeant Brandon Hartz about the encounter with Claimant, a claim Sgt. Hartz denied. Krouse also made various claims as to the reasons she did not engage her body-worn camera when she stopped Claimant. During one interview she stated that Deputy Antoniadis told her she did not have to turn on her body-worn camera, a claim disputed by Antoniadis during his interview. In another interview deputy Desirae Krouse claimed she was told she did not have to use her body camera when on federally owned property, a claim she could not attribute to any source. Krouse also continued to maintain her position that Claimant committed a traffic violation despite the unequivocal video evidence to the contrary. Deputy Desirae Krouse also denied that Claimant stated to her, “there’s no need to be rude” when testifying at the traffic court hearing, then admitted she made the statement when being interviewed under oath for the Professional Standards investigation. Krouse also referred to the Claimant as a “First Amendment Auditor,” which is an unjust characterization of Claimant. First Amendment auditors are usually described as individuals who test the boundaries of free speech and the right to record by filming public officials and employees in public spaces like government buildings, libraries, and police stations, aiming to provoke reactions using confrontational and provocative behavior to challenge police officers.
Former deputy Natalie Neimann was also interviewed and gave conflicting information regarding the traffic stop and incident. Neiman made the following claims: “…[t]he vehicle started to pull up to the trolley tracks and there was a train coming, so we were motioning that car to stop. The individual driving the car drove past… And was that near the mouth? Oh yeah, right on the tracks, pretty much… you're taking on a big train… trying to stop a train from hitting his car.” Then testified at the traffic court hearing two weeks later that Claimant did in fact yield when ordered to. Her sworn statement to PSB/IA investigators was perjurious and proven dishonest via video footage.
In light of the irrefutable video evidence, there is no legitimate, good faith explanation or justification for the deputies’ perjured testimony. There is no mistake, confusion or other inadvertence can excuse the false material facts provided by deputies. Their concerted effort to aid deputy Desirae Krouse in avoiding discipline constitutes collusion to cover-up and conceal misconduct. Such conspiratorial behavior in what was an ordinary case, suggests a wide spread culture of collusion, concealment and dishonesty that is accepted and encouraged within the Hillsborough County Sheriff’s Office. Recent cheating scandals among high ranking Deputies emphasizes the toxic temperature throughout the ranks of the Sheriff’s Office. The ease in which the officers in this particular case chose to commit the crime of perjury indicates the scale of deliberate indifference to misconduct. This type of conduct unbecoming a law enforcement officer is accepted within the Sheriff’s Office, a culture that contributed the damage suffered by Claimant.
Conclusion
By committing perjury in an orchestrated effort to shield deputy Desirae Krouse of negative consequences for her misconduct, the officers impeded the investigation and obstructed justice, prejudicing Claimant in exercising his Constitutional rights seeking redress for the misconduct inflicted upon him by deputy Desirae Krouse. As a result, Claimant suffered considerable damages: physical, emotional, psychological and financial entitling him to relief.
Deputies Niemann, Antoniades, Ortiz and Farrell each gave different versions. Niemann
and Antoniades claimed the trolley stopped, Claimant did not stop and/or the traffic stop was justified. Farrell made false statements. Ortiz stated he heard deputies tell Claimant not to park on the tracks. Yet the video shows otherwise. Their sworn statements don’t match the evidence, and they don’t even match each other.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 3
Obstruction of Justice /Negligent Investigation /
Failure to Report Known Perjury and Misconduct by Sworn Officers
Factual Basis
Claimant hereby incorporates and re-alleges the information, facts, and evidence outlined in Claims 1 and 2 of this notice, and adds the following:
Hillsborough County Sheriff’s Office, Professional Standards detectives, mainly Master Detective Belinda Denbigh, were assigned to investigate deputy Desirae Krouse’s misconduct during the unlawful traffic stop of Claimant and his passengers. When interviewing witnesses in connection with Claimant’s complaint, multiple officers knowingly provided sworn audio recorded statements about Claimant and deputy Desirae Krouse’s conduct that were proven false by video evidence, hearing video and civilian witness testimony in the investigators possession.
Deputy Demetrius Antoniadis deceived Professional Standards detectives when he knowingly provided false testimony stating that he heard the passing trolley sound it horn, and that Krouse was justified in writing the citation because he believed, based on his meany years of experience the stop was justified regarding the alleged near collision that never occurred. Although Antoniadis did eventually concede that Claimant stopped when ordered, he also attempted to defend Krouse’s misconduct when illegally detaining Claimant, and committed perjury in the process.
Deputy Todd Farrell deceived IA investigators when he claimed deputy Desirae Krouse explained to Claimant why she was giving him a citation. Krouse herself admitted that she did not inform Claimant the reasons for the citation, alleging Claimant was too hostile to listen. When asked what his response would be if Complainant denied being informed why he got a ticket, Farrell responded, “...[h]e is lying.” Farrell did not know that Krouse confessed not educating Claimant on her decision to cite him, nor did he realize a video from the trolley existed when he was interviewed for the investigation.
Deputy Desirae Krouse claimed that she informed her immediate supervisor, Sergeant Brandon Hartz about the encounter with Claimant, a claim Sgt. Hartz denied. Krouse also made various claims as to the reasons she did not engage her body-worn camera when she stopped Claimant. During one interview she stated that Deputy Antoniadis told her she did not have to turn on her body-worn camera, a claim disputed by Antoniadis during his recorded interview. In another interview deputy Desirae Krouse claimed she was told she did not have to use her body camera when on federally owned property, a claim she could not attribute to any source. Krouse also continued to maintain her position that Claimant committed a traffic violation despite the unequivocal video evidence to the contrary. Deputy Desirae Krouse also denied that Claimant stated to her, “there’s no need to be rude” when testifying at the traffic court hearing, then admitted he made the statement when being interviewed under oath for the IA investigation, another lie.
Former Deputy Natalie Neimann was also interviewed and gave conflicting information regarding the traffic stop incident. Neiman made claims that the trolley stopped, then testified at the traffic court hearing two weeks later that Claimant did yield when ordered to. Her sworn statement to IA investigators was perjurious and proven dishonest via video footage.
In addition, deputy * Ortiz (first name redacted) dishonestly informed Professional Standards Bureau detectives that he heard several officers yelling at Claimant “don’t park on the tracks,” or “get off the tracks.” Since video footage proves Claimant never parked on the tracks, Deputy Ortiz’s claim of what other officers were yelling was not possible. Deputy Ortiz also claimed to have heard the trolley sound its horn or whistle, another fact proven false by the trolley video. Also, Motorman Ralph Rosado operates the subject trolley on the day in question and denied sounding his horn or slowing or stopping when interviewed by Professional Standards detective Belinda Denbigh.
The only explanation for deputy Ortiz to provide these false material statements is that he was attempting to assist deputy Desirae Krouse in avoiding discipline by validating her bogus traffic citation issued to Claimant. Ortiz was interviewed on March 20, 2023, eight days before the traffic hearing where Claimant introduced the trolley video. Therefore, at the time Ortiz was interviewed he was unaware a video existed that would refute his statements.
Detective Belinda Denbigh failed to notify her superiors that the deputies had lied to her while under oath, took no corrective or disciplinary measures, and joined in the collusion to shield deputy Desirae Krouse from accountability for her misconduct.
Professional Standards detectives possessed contemporaneous trolley video footage and, witness affidavits, interviews and other evidence that conclusively disproved the officers’ sworn accounts.
The video showed Claimant yielding to the passing trolley, contradicting claims that he forced the trolley to stop. Trolley motorman, Ralph Rosado, stated that he did not encounter any traffic hazards on the day of the incident, and that he did not have to slow down or stop, sound the trolley’s horn, and was not involved in a near collision as cited by deputy Desirae Krouse in her traffic ticket/citation, further corroborating Claimant’s allegations while disproving the sworn statements of the officers.
Despite clear evidence of perjury and falsification, the detectives failed to notify their superiors, initiate corrective action, or recommend discipline for the officers who lied under oath.
This failure deprived Claimant of a fair and thorough investigation, allowed false testimony to remain uncorrected in official records, and perpetuated harm to Claimant’s reputation and rights.
By failing to act, the detectives breached their duty to ensure integrity in internal investigations, obstructed the administration of justice, and contributed to the ongoing deprivation of Claimant’s constitutional rights.
Conclusion
Professional Standards detectives had a duty to ensure integrity in their investigation of deputy Deputy Krouse. By failing to notify superiors or take corrective action after discovering five officers lied under oath—a fact easily disproven by trolley video in their possession—the detectives obstructed justice, perpetuated falsehoods, and caused significant prejudice to Claimant. Hillsborough County Sheriff’s Office is liable for this negligent investigation and failure to report misconduct. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial entitling him to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 4
Perjury by Deputy Krouse During Traffic Court Hearing
Factual Basis
Deputy Desirae Krouse had a duty, both as a citizen and as a law enforcement officer, to provide honest and accurate testimony when called upon to be a witness.
At the traffic court hearing (video recorded), under oath, deputy Desirae Krouse knowingly gave perjured testimony consistent with the false allegations contained in the citation she issued to Claimant. Specifically, Krouse testified that Claimant did not stop his vehicle as ordered, and that an oncoming trolley was forced to stop to avoid a collision.
Claimant introduced video footage from cameras mounted on the trolley itself, which conclusively showing Claimant stopped several feet from the tracks, the trolley did not slow down, and it did not stop.
Even in the face of irrefutable video evidence, deputy Desirae Krouse maintained her false narrative.
Deputies Niemann and Antoniadis admitted Claimant did yield and posed no threat to the trolley, further disproving deputy Desirae Krouse’s testimony. Krouse’s perjury forced Claimant to appeal the citation to the Circuit Court at his own expense and effort. The Circuit Court reversed the citation, confirming the absence of competent, substantial evidence.
Deputy Desirae Krouse’s willingness to commit perjury under oath demonstrates misconduct that carries both criminal and civil liability.
Conclusion
Deputy Desirae Krouse’s perjured testimony under oath, combined with her issuance of a citation containing false allegations, constitutes both as perjury. Claimant suffered significant prejudice, reputational harm, and economic damages as a result. The Circuit Court’s reversal confirms the falsity of Krouse’s claims. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial and is entitled to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 5
False Official Statement / Falsification of Records / Perjury
Factual Basis
Deputy Desirae Krouse unlawfully detained Claimant and his three passengers for over twenty (20) minutes during a traffic stop later determined by the Circuit Court to lack competent, substantial evidence and probable cause to achieve its ultimate purpose of issuing Claimant a traffic citation, simpler because Claimant told Krouse “there’s nom need to be rude.” Speech that is protected by the United States Constitution and comparable provisions of the Florida Constitution. .
From the moment Claimant surrendered his driver’s license under threat of arrest and physical harm, until its return nearly a half hour later, Claimant was detained and not free to leave. Florida law is clear: when a citizen is compelled to provide a driver’s license and ordered not to leave by law enforcement, detention occurs, as no reasonable person would believe they were free to leave. Since Claimant was the driver, his three passengers—whose sole mode of transportation was Claimant’s vehicle—were also detained illegally. The Circuit Court’s order finding the stop unlawful confirms that the subsequent detention of Claimant and his passengers was also illegal
False Official Statement / Falsification of Records:
The citation narrative claimed Claimant “failed to yield to trolley despite multiple law enforcement officers directing him to stop” and “nearly causing a collision.” HART dash cam video and passenger affidavits (in Claimant’s vehicle) prove the trolley passed unimpeded and Claimant stopped well clear of the tracks.
Deputy Desirae Krouse testified under oath to facts contradicted by the video (e.g., that the trolley had to stop and sounded a whistle). The video and motorman statement directly refute these sworn assertions. When faced with video evidence proving her dishonesty, rather than confess her obvious untruthfulness, Krouse continued down her reckless path of deceit, maintaining the falsities detailed in the signed citation.
Deputy Desirae Krouse’s citation and courtroom testimony materially repeated the same false allegations. The Circuit Court expressly found the video contradicted her testimony. A traffic citation is an official document and knowingly providing false information in it for the purpose of causing Claimant undue hardship, embarrassment, financial loss, driving record blemishes; all with the initial intent of retaliation and harassment is an illegal act creating civil liability. Additionally, when affirming the dishonest allegations under oath during the traffic court hearing and subsequently in the internal affairs interviews, deputy Desirae Krouse committed perjury for which she has no legitimate or viable excuse or explanation. The traffic citation issued to Claimant was an officially prepared and signed statement containing material falsehoods that Krouse made knowingly and with reckless disregard for the truth.
Conclusion
Deputy Desirae Krouse’s unlawful detention of Claimant and his passengers, combined with her false official statements and perjured testimony, caused significant harm. The Circuit Court’s order confirms the absence of probable cause. Hillsborough County Sheriff’s Office and deputy Desirae Krouse have no viable defense for her misconduct. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial and is entitled to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 6
Assault and Battery
Factual Basis
Once Claimant parked and exited his vehicle, deputy Corporal Desirae Krouse immediately confronted him in an uncontrollable rage and physically threatening manner. Deputy Desirae Krouse forcefully invaded Claimant’s personal space, yelling within six inches of his face and spraying him with spittle. This unconsented, unlawful physical contact with bodily fluid constitutes offensive physical contact and qualifies as battery. The battery was intentional.
Deputy Desirae Krouse repeatedly ordered Claimant to provide his driver’s license and threatened physical restraint and arrest if he did not comply. Claimant protested, noting Krouse lacked probable cause for the stop and citation. However, her demeanor made Claimant fear she would physically attack him or use pepper spray, a taser, or her firearm if he did not comply with her unlawful demands. He surrendered his license under duress.
Deputy Desirae Krouse’s gestures and body language were aggressive and threatening to such a degree that Claimant feared for his safety, including the possibility of being shot and fatally injured. Elderly and disabled passengers provided affidavits confirming they too feared Claimant would be shot upon witnessing Krouse’s hostile demeanor. Deputy Krouse’s yelling, threats of arrest, and hostile demeanor created a reasonable belief of imminent force, constituting assault. Witness affidavits corroborate the aggressive conduct and confirm passengers feared Claimant would be physically harmed. The assault was intentional.
Several times during the encounter, Claimant demanded deputy Desirae Krouse activate her body-worn camera. She refused, and was later found in violation of departmental policy and reprimanded. Her refusal corroborates the assault and demonstrates consciousness of misconduct.
Conclusion
Deputy Desirae Krouse’s assaultive conduct, threats of unlawful force, refusal to activate her body-worn camera, and misuse of official process caused Claimant significant harm. Deputy Krouse’s assault was an intentional act creating a reasonable apprehension of imminent harmful or offensive contact for which Claimant reasonably feared physical harm. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial and is entitled to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 7
Obstruction of Justice (Interfering With Traffic Laws and Court Hearing)
Factual Basis
Law enforcement officers, including deputy Desirae Krouse, have a duty to lawfully enforce laws, protect the public, and aid in the administration of justice. As established by the Circuit Court’s order on appeal, Krouse issued Claimant a traffic citation containing several unequivocally false allegations disproven by video evidence. Krouse willingly and knowingly fabricated accusations, including that Claimant failed to yield when ordered, that a trolley was forced to stop to avoid collision, and that Claimant refused to obey commands.
Making false allegations to support an illegal traffic stop and unfounded citation established obstruction of justice. Krouse further obstructed justice by:
1. Failing to activate her body-worn camera during citizen interaction, in violation of policy.
2. Failing to exhibit professional behavior or deescalate the confrontation.
3. Conducting an unnecessarily prolonged traffic stop without probable cause.
At the traffic hearing, deputy Desirae Krouse selectively answered questions, refusing to respond to inquiries that would expose her retaliation and misconduct. The Circuit Court noted this selective testimony in reversing the citation. By withholding testimony and evidence favorable to Claimant, Krouse deprived the hearing officer of necessary information, denying Claimant due process under the State and U.S. Constitutions.
Conclusion
Deputy Desirae Krouse’s issuance of false allegations, refusal to activate her body-worn camera, selective, false testimony constituted obstruction of justice, interfering with the judicial process and laws of the land. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial and is entitled to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 8
Abuse of Process
Factual Basis
Deputy Desirae Krouse, acting under color of law, unlawfully manipulated procedures governing her duties to retaliate, harass, assault, and illegally detain Claimant during an unlawful traffic stop.
A lawful traffic stop requires an observable violation or probable cause. Neither existed here. Desirae Krouse initiated the stop simply because she was enraged by Claimant’s free speech statement: “there’s no need to be rude.” Krouse issued a citation for failing to yield as a pretext. The Circuit Court found absolutely no evidence supporting the citation. What should have never been a stop became a prolonged, irrational over 20 minute ordeal for Claimant and his passengers.
Deputy Desirae Krouse manipulated normal traffic stop processes to intimidate, threaten, punish and assault Claimant. The true purpose was retaliation for Claimant’s comment on her demeanor. Krouse lied at every stage: to Claimant at the scene, in the citation, to fellow officers and supervisors, under oath at the traffic hearing and subsequently in the audio recorded internal affairs investigation.
Specific abuses of process included:
1. Initiating a traffic stop without probable cause or a true traffic violation in retaliation to free speech.
2. Issuing a citation based on dishonest allegations, unsupported by competent, substantial evidence.
3. Engaging in unprofessional conduct unbecoming a Hillsborough County Sheriff’s Deputy.
4. Failure and refusal to activate her body-worn camera to record the incident.
5. Committing perjury at the traffic hearing (video recorded) and in the internal affairs investigation, which was audio recorded in three interviews.
6. Krouse was also dishonest to Professional Standards Bureau detectives when she claimed to have informed her supervisor of the incident, a claim her supervisor denied.
Deputy Desirae Krouse engaged in intentional manipulation of procedures for an ulterior motive, i.e., intimidating, retaliating, punishing and threatening Claimant, and using her position as a law officer to mislead and divert attention from her wrongdoing. These abuses deprived Claimant of rights and protections, causing significant damages.
Conclusion
Deputy Desirae Krouse’s manipulation of lawful procedures, issuance of false allegations, perjury, refusal to activate her body-worn camera, and extreme, outrageous conduct constituted abuse of process and intentional infliction of emotional distress. Claimant suffered significant damages as a result. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial and is entitled toed to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 9
Abuse of Power and Authority
Factual Basis
Deputy Desirae Krouse’s position as a law enforcement officer gave her authority to uphold the laws of Florida and the United States. That authority is bound by strict policies and rules of conduct.
Instead of responsibly exercising her authority, deputy Desirae Krouse abused it by conducting an unlawful traffic stop, assaulting Claimant, and illegally detaining him and his elderly and disabled passengers out of anger and retribution.
Krouse wielded her power in a totalitarian manner inconsistent with departmental policy and guidelines. She exercised complete dominion over Claimant—spitting in his face, demanding identification in a coercive manner, threatening physical restraint and arrest, and prolonging the abuse for nearly half an hour.
The Circuit Court’s order reversing the citation confirms there was no probable cause for the stop. Deputy Desirae Krouse’s misconduct was a clear abuse of the authority vested in her as a sworn deputy. Hillsborough County and Hillsborough County Sheriff’s Office must not permit such abuse by its deputies and should embrace accountability and transparency.
Conclusion
Deputy Desirae Krouse’s unlawful traffic stop, assaultive conduct, and retaliatory detention constituted a misuse and abuse of her power and authority. Claimant suffered significant damages as a result. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial and is entitled to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 10
Negligence – Failure of OnScene Officers to Intervene
Factual Basis
Hillsborough County Sheriff’s deputies Natalie Niemann and Demetrios Antoniadis were assigned to off-duty traffic control outside The Tampa Aquarium and Port Tampa Bay with deputy Desirae Krouse on the day of the incident. Niemann and Antoniadis witnessed all or parts of the unlawful traffic stop and misconduct perpetrated by Krouse against Claimant, including:
Deputies Niemann and Antoniadis testified consistent with the video that Claimant yielded properly, yet they failed to intervene, to deescalate or terminate the unlawful detention.
Despite having a duty to intervene, they allowed deputy Desirae Krouse to continue detaining and threatening Claimant. Their inaction prolonged the detention and contributed to the harms suffered. The record establishes their presence and failure to act, which proximately caused additional damages to Claimant.
Deputies Natalie Niemann and Demetrios Antoniadis had a duty to intervene to protect Claimant and preserve his constitutional rights. They knew Claimant’s rights were being violated and had a realistic opportunity to intervene, but failed to take reasonable steps. Their negligence allowed Claimant to suffer damages and deprivation of rights.
Conclusion
Deputies Natalie Niemann and Demetrios Antoniadis negligently failed to intervene despite witnessing deputy Desirae Krouse’s unlawful conduct. Krouse’s retaliatory actions against Claimant’s protected speech, combined with the prolonged unlawful detention and false citation, caused significant damages. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial and is entitled to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 11
Deliberate Falsification of Citation
Factual Basis
Deputy Desirae Krouse had a duty to conduct herself ethically and honestly, including when preparing citations. Krouse deliberately issued Claimant a citation for failing to yield to a transit vehicle, based on false information designed to validate her unlawful conduct in stopping Claimant in retaliation for protected First Amendment speech.
Allegations in the citation included that Claimant failed to yield despite being ordered to stop by several officers, and that the trolley was forced to stop to avoid collision.
The Circuit Court, in reversing the citation, found video footage from the trolley definitively showed Claimant stopped several feet from the tracks, the trolley did not slow down, and it did not stop.
The trolley engineer Ralph Rosado reported no incident or near collision, corroborating the video.
At the traffic hearing, confronted with video evidence, deputy Desirae Krouse maintained her false narrative rather than admit fabrication. Deputies Natalie Niemann and Demetrios Antoniadis eventually admitted Claimant did yield and posed no threat to the trolley.
Deputy Desirae Krouse knowingly falsified an official document and committed perjury rather than admit misconduct.
Conclusion
Deputy Desirae Krouse’s deliberate falsification of a citation, compounded by her failure to preserve exculpatory evidence through refusing to engage her body-cam, deprived Claimant of due process and caused significant damages. The Circuit Court’s reversal confirms the absence of factual support for her allegations. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial and is entitles to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 12
Defamation / Slander and Damage to Reputation
Deputy Desirae Krouse, Deputy Demetrios Antoniadis, Deputy Natalie Neimann, Deputy Todd Farrell and Deputy Ortiz all intentionally defamed and/or slandered Claimant by and through either issuing him a fraudulent traffic citation, or providing sworn statements to Professional Standards Bureau detectives when conducting an investigation into Krouse’s misconduct.
By issuing Claimant a fictitious citation for failing to yield, deputy Desirae Krouse knowingly made false allegations defaming Claimant, alleging he was a reckless driver who put himself, his elderly and disabled passengers, and public transit passengers in the passing trolley in imminent danger.
During a subsequent Professional Standards Bureau investigation initiated by a complaint filed by Claimant, deputy Desirae Krouse continued to disparage Claimant’s character and reputation. When giving sworn statements to Professional Standards detectives, Krouse made claims such that Claimant must not like women or Germans, and that he has a problem with women of authority. Krouse even stated multiple times that she believed Claimant is mentally ill. Each of her statements are false, and lack any substantive proof or evidence corroborating the claims she falsely made.
Deputy Demetrios Antoniadis made several slanderous remarks, in particular that Claimant voiced a prejudice or assumption that Deputy Krouse’s name was of German descent, thereby, comparing her to Nazi Germans, a wholly improper interpretation of the incident and what truly occurred. Antoniadis purposely mislead the investigators to wrongfully believe that Claimant was irrational and bias, while Krouse was allegedly professional courteous.
Deputy Todd Farrell made slanderous remarks without proof: Farrell stated: “He don't like taking orders from a woman.” To me, I don't know if he was sexist…” “He was just trying to push it, you know, just a little bit, you know, how to push buttons” and “he's lying.”
Deputy Natalie Niemann also made slanderous remarks without proof: Niemann stated:
“…antagonistic, arrogant.”
Conclusion
Claimant suffered damage to his name and reputation as a result of deputy Desirae Krouse’s, deputy Demetrios Antoniadis’s, deputy Todd Farrell’s, deputy Ortiz’s and deputy Natalie Niemann’s defamatory misconduct. Their false statements denigrating Claimant interfered with the Professional Standards Bureau investigation, further preventing Claimant the protections of law due him. Such defamation also exposes the false information and allegations to discovery through public records by any person. There is no method in which to shield Claimant from the harm caused by the deputies defamatory remarks. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: reputational, physical, emotional, psychological and financial and is entitled to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 13
Intentional Infliction of Emotional Distress
Factual Basis
Claimant suffered severe emotional distress intentionally inflicted by deputy Desirae Krouse.
The distress has impacted every aspect of Claimant’s life since being assaulted, threatened, and placed in a position of permanent mistrust when dealing with law enforcement officers.
Krouse’s conduct—including yelling inches from Claimant’s face, spitting on him, threatening arrest, and prolonging an unlawful detention for nearly half an hour—was outrageous and extreme beyond any reasonable policing interaction.
Claimant’s passengers, including an elderly and disabled individual, corroborated the fear and humiliation caused by deputy Desirae Krouse’s behavior. Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, as Krouse’s employers, bear the responsibility for compensating Claimant for the emotional distress intentionally inflicted by its deputies and/or contractual employees. Deputy Desirae Krouse issued a citation that led to enforcement proceedings against Claimant, which was exacerbated by collusion by deputy Natalie Niemann, Deputy Demetrios Antoniades, deputy Ortiz, deputy Todd Farrell and the failed investigation and cover up by Professional Standards Bureau, Master Sergeant Belinda Denbigh and her superiors.
The Circuit Court’s reversal of the citation constitutes favorable termination on the substantive merits.
The lack of probable cause, demonstrated by video evidence, witness testimony and the appellate decision, supports the wrongful prosecution element.
Evidence of retaliatory motive—specifically Krouse’s escalation after Claimant exercised First Amendment protected speech (“there’s no need to be rude”)—supports malice.
The citation and subsequent proceedings forced Claimant to expend time, effort, resources and finances to defend himself, causing both economic and emotional damages.
Conclusion
Deputy Desirae Krouse’s outrageous conduct intentionally inflicted severe emotional distress on Claimant, while her issuance of a baseless citation and pursuit of proceedings constituted malicious prosecution and abuse of process. The Circuit Court’s reversal confirms the absence of probable cause. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: reputational, physical, emotional, psychological and financial and is entitled to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 14
Obstruction of Justice by Sworn Officers and Investigating Detectives
Negligent Failure of Professional Standards Detectives to Act
Factual Basis
Five Hillsborough County Sheriff’s deputies provided sworn statements during Professional Standards interviews regarding deputy Corporal Desirae Krouse’s misconduct.
Each officer falsely claimed that Claimant failed to yield, obstructed the trolley, or otherwise engaged in unlawful conduct.
Detectives conducting the investigation had in their possession contemporaneous trolley video footage, civilian witness affidavits and testimony that conclusively disproved these deputies’ sworn statements. The video showed Claimant properly yielding, the trolley continuing without slowing or stopping, and no obstruction or violation ever occurring.
Despite clear evidence of perjury and falsification, Professional Standards detectives failed to notify their superiors, initiate corrective action, or recommend discipline for the officers who lied under oath.
By allowing false testimony to remain uncorrected in official records, detectives obstructed the administration of justice and deprived Claimant of a fair and thorough investigation. This failure perpetuated falsehoods, obstructed due process, and caused Claimant reputational harm, emotional distress, and economic damages (including costs of appeal, defense and subsequent costs to research and bring this action).
Conclusion
Five deputies committed perjury during sworn Professional Standards interviews by falsely claiming Claimant failed to yield—statements easily disproven by trolley video in the detectives’ possession. Professional Standards detectives, despite clear evidence, failed to notify superiors or take corrective action. This obstruction of justice perpetuated falsehoods, denied Claimant due process, and caused significant prejudice by the misconduct described herein and suffered considerable damages: reputational, physical, emotional, psychological and financial and is entitled to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
RELIEF SOUGHT
Claimant seeks damages for harm caused by the effect of the issues raised herein, compensatory, punitive, non-economic, and any and all other types of relief to which he may be entitled. Claimant intends to seek Declaratory relief that sworn falsehoods and investigative negligence occurred. Claimant will also seek Injunctive relief requiring policy change, mandatory reporting protocols, an independent audit of Professional Standards investigations, and formal administrative discipline for detectives who failed to act and officers who lied under oath. Claimant also intends to pursue criminal action with the appropriate prosecuting authority where applicable. Claimant seeks accountability and transparency of Hillsborough County and the Hillsborough County Sheriff’s Office and all members of the Sheriff department that were involved in the incident and investigation all the way up the hierarchy to Sheriff Chad Chorister, who signed off on the failed cover up investigation.
VI.
PRESERVATION DEMAND (Effective Immediately)
You are directed to preserve and not alter, delete, overwrite, or dispose of any materials potentially relevant to this incident, including but not limited to:
1. HART raw forward and rear dash cam video files for Streetcar No. 430 (Jan. 21, 2023; with metadata, GPS/timecode, file hashes, operator logs, and backups).
2. All HCSO body-worn camera (BWC) raw files, device assignment logs, activation logs, and SD card images for deputy Desirae Krouse, deputy Natalie Niemann, deputy Demetrios Antoniadis, deputy Todd Farrell, deputy Ortiz, and any other deputies present or involved in any way related to the incident and/or the internal affairs investigation.
3. All patrol dash cam recordings for vehicles present and in the area that day.
4. CAD/dispatch logs, radio transmissions, and call records for the relevant time window.
5. D.A.V.I.D./driver record query/audit logs showing any access to Claimant’s information on Jan. 21, 2023 (user, timestamps) and any subsequent searches of Claimant’s name in the D.A.V.I.D. system on the incident date and any day thereafter. If the D.A.V.I.D. system was accessed to inquire by any Sheriff’s Office personnel, the reason why the Claimant’s name was accessed.
6. Original citation (AGD50KE), any drafts, officer notes, incident supplements, supervisor reviews, and any internal memoranda referencing the incident.
7. Complete Professional Standards Bureau-Internal Affairs investigative file (interview recordings/transcripts, investigative exhibits, notes, IA findings, and discipline records). Preserve originals even if asserted confidential.
8. Any and all emails, text messages, or other communications referencing the incident, including any and all that contain the name of Claimant and any related communications.
9. Any private or third party video, photos, or audio referencing the incident.
10. Personnel and training records relevant to Body Worn Camera (BWC) use, and deescalation / off-duty training.
11. Any and all other document or tangible material that in any way may be related to the claims raised herein or to the persons named herein.
12. Complete personnel files of all deputies involved with the incident and investigation into Claimant’s complaint as stated herein, but not limited to deputy Desirae Krouse, deputy Natalie Niemann (including resignation departure letters of notes), deputy Demetrios Antoniades, deputy Todd Farrell, deputy * Ortiz ABN # 255462 (* first name redacted), and others.
13. Any and all complaints, discipline, corrective actions, reprimands or evaluations for each of the deputies mentioned in #12 above. This also includes any complaints filed by any citizen or any other Hillsborough County or Sheriff employee be it founded or unfounded.
12. All electronic communications between any and all Hillsborough County and Hillsborough County Sheriff personnel, be they sworn law enforcement officers, clerical or other staff employed by Hillsborough County and Hillsborough County Sheriff that mention or discuss Claimant, the incident or in any other way.
VII .
CERTIFICATE OF SERVICE /DELIVERY AND SIGNATURE
Claimant hereby certifies that each person, agency, municipality, entity listed on page one and two of this Notice has been served a copy of this document via certified U. S. Mail on this 9th day of December 2025.
Respectfully submitted,
Sincerely,
ORIGINALS SIGNED AND MAILED.
Claimant's information including contact information ids in the PDF version above.
PORT OF TAMPA AND FLORIDA DEPARTMENT OF FINANCIAL SERVICES
PURSUANT TO FLORIDA STATUTE § 768.28
Date: December 9, 2025
WRITTEN NOTICE OF CLAIMS TO HILLSBOROUGH COUNTY SHERIFF, HILLSBOROUGH COUNTY, CITY OF TAMPA, THE TAMPA AQUARIUM,
PORT OF TAMPA AND FLORIDA DEPARTMENT OF FINANCIAL SERVICES
PURSUANT TO FLORIDA STATUTE § 768.28
Subject: Hillsborough County Sheriff’s Deputy Desirae Krouse ABN 199236
Date: January 21, 2023
Location: Port of Tampa Terminal 2, The Tampa Aquarium Channelside Drive, Tampa, Florida
Incident: Unlawful Traffic Stop and Citation
Citation: AGD50KE (Failure to Yield to Public Transit Vehicle (Streetcar/trolley)
Traff. Ct No.: 23-TR005347
Cir. Ct. No.: 23-CA-12145
Office of Professional Standards Case No.: I-2023-008.
Hillsborough County Sheriff’s Office
Chad Chronister - Sheriff
Post Office Box 3371 Tampa, Florida 33601-3371
Sent Via Certified US Mail # 7022 3330 0000 6336 9984
Florida Department of Financial Services,
Division of Risk Management
200 E. Gaines Street Tallahassee, Florida 32399-0338
Sent Via Certified US Mail # 7022 3330 0000 6336 9991
Hillsborough County Board of County Commissioners
601 E. Kennedy Blvd. #2 Tampa, Florida 33602
Sent Via Certified US Mail # 9589 0710 5270 3548 7074 07
Ms. Amanda Granit - Chief Communications Officer
(HCSO) 1201 E. Orient Road, Tampa, FL 33619
Sent Via Certified US Mail # 7022 2410 0000 0981 9557
Ms. Kathryn Heller - Risk Management Director
Hillsborough County Sheriff's Office (HCSO)
725 E Kennedy Blvd, Tampa, FL 33602
Sent Via Certified US Mail # 7022 2410 0000 0981 9540
Mr. Paul Anderson - President and CEO - Port Tampa Bay
1101 Channelside Drive, Tampa, FL 33602
Sent Via Certified US Mail # 7022 2410 0000 0981 9533
Mr. Christopher Cooley - Environmental Director - Port Tampa Bay
1101 Channelside Drive, Tampa, FL 33602
Sent Via Certified US Mail # 9589 0710 5270 3548 7074 45
Mr. Charles E. Klug - Port Tampa Bay Counsel
1101 Channelside Drive, Tampa, FL 33602
Sent Via Certified US Mail # 7022 3330 0000 6337 0003
The Florida Aquarium
Attn: Executive Office / General Counsel
701 Channelside Dr. Tampa, FL 33602
Sent Via Certified US Mail # 9589 0710 5370 3548 7074 38
Mr. Roger Germann - President and CEO
The Florida Aquarium
701 Channelside Dr. Tampa, FL 33602
Sent Via Certified US Mail # 9589 0710 5270 3548 7073 91
Ms. Kimberly Casey
The Florida Aquarium
Risk Management, and Business Operations.
701 Channelside Dr. Tampa, FL 33602
Sent Via Certified US Mail # 9589 0710 5270 3548 7073 84
City of Tampa
Risk Management/Claims
306 East Jackson Street Tampa, Florida 33602
Sent Via Certified US Mail # 9589 0710 5270 3548 7074 21
City of Tampa Mayor's Office
Attn: Honorable Mayor Jane Castor
306 East Jackson Street Tampa, Florida 33602
Sent Via Certified US Mail # 9589 0710 5270 3548 7074 14
Also Listed:
Hillsborough County Sheriff Deputy Corporal Desirae Krouse
Hillsborough County Sheriff Deputy Todd Farrell
Hillsborough County Sheriff Deputy Demetrios Antoniades
Hillsborough County Sheriff Deputy Natalie Niemann
Hillsborough County Sheriff Deputy * Ortiz # 255462 (* First name redacted)
Claimant: Spiros C. Paizes
Address: 5719 39th Street Circle E. Bradenton, Florida 34203
Date of Birth: July 3, 1959
Social Security No. ▇▇▇▇▇▇ (REDACTED)
Place of Birth: Johannesburg, South Africa
Date of Incident: January 21, 2023
Incident Location: Hillsborough County, Florida
Type of Claim: Unlawful Traffic Stop and Citation and Other Claims.
Dear Hillsborough County Sheriff’s Office, Florida Department of Financial Services, Hillsborough County Board of County Commissioners, Port Tampa Bay, The Tampa Aquarium, City of Tampa, and the Honorable Tampa Mayor Jane Castor;
This notice is timely submitted pursuant to section § 768.28 Florida Statutes.
Notice is hereby given of forthcoming lawsuit(s) related to events that took place beginning January 21, 2023, at or near the Tampa Aquarium and Port of Tampa (Port Tampa Bay) Cruise terminal 2 at or about 651/701 Channelside Drive Tampa, Florida 33602.
It is my intent to provide you with information to enable you to come to an agreement to resolve this case without the need for litigation. I hereby request a meeting to discuss the possibility of resolving the case in favor of myself and without incurring unnecessary litigation costs that would only serve to further burden Florida's taxpayers.
However, one hundred eighty (180) days from the date of this notice, should this claim be unresolved, I will bring an action against Hillsborough County Sheriff’s Office, Hillsborough County, Port of Tampa, The Tampa Aquarium and the City of Tampa and others for all the damages suffered.
Nothing in this notice should be interpreted or is intended as a waiver by myself or my survivors to bring any other claim(s) or action(s), based on the relevant facts, against Hillsborough County Sheriff’s Office, Hillsborough County, Port of Tampa, The Tampa Aquarium, the City of Tampa or others or any other state agency, or any other person or party, for which pre-suit notice is unnecessary.
If I have failed to comply with Florida Statute § 768.28(6)(a) in any manner whatsoever, please advise accordingly by return mail specifying how I have failed. If there are any other agencies or entities that have liability for the injuries sustained for the claims, I ask that you provide this information and a copy of this Notice to them.
I am aware of no adjudicated penalties, fines, fees, victim restitution fund, and other judgments in excess of $200.00, whether imposed by civil, criminal, or administrative tribunal, owed by myself to the State of Florida, its agency, office or subdivision, any prior adjudicated unpaid claims in excess of $200.00.
The forthcoming lawsuit(s) will prove the following causes of action:
CLAIM 1
Unlawful Stop / False Detention / Threat of False Arrest
CLAIM 2
Deputies Committing Perjury in Sworn Administrative Interviews
CLAIM 3
Obstruction of Justice /Negligent Investigation
Failure to Report Known Perjury and Misconduct by Sworn Officers
CLAIM 4
Perjury by Deputy Krouse During Traffic Court Hearing
CLAIM 5
False Official Statement / Falsification of Records / Perjury
CLAIM 6
Assault and Battery
CLAIM 7
Obstruction of Justice (Interfering With Traffic Laws and Court Hearing)
CLAIM 8
Abuse of Process
CLAIM 9
Abuse of Power and Authority
CLAIM 10
Negligence – Failure of On Scene Officers to Intervene
CLAIM 11
Deliberate Falsification of Citation
CLAIM 12
Defamation / Slander and Damage to Reputation
CLAIM 13
Intentional Infliction of Emotional Distress
CLAIM 14
Obstruction of Justice by Sworn Officers and Investigating Detectives
Negligent Failure of Professional Standards Detectives to Act
AND OTHER CLAIMS
Pursuant to Florida Statute § 768.28, please accept this Notice of Claim. If this matter is not resolved within 180 days I will initiate civil action asserting the claims described herein and below. This notice preserves all claims and remedies arising from the January 21, 2023, incident involving:
(a) Hillsborough County Sheriff’s Deputy Corporal Desirae Krouse.
(b) All other Hillsborough Sheriff Office employees present during incident.
(c) Traffic citation AGD50KE issued by Krouse.
(d) Hillsborough County Sheriff’s Office Professional Standards-Internal Affairs personnel and their handling of the complaint against deputy Desirae Krouse, and subsequent investigatory decisions and findings.
(e) The professional relationship and contracts between the following agencies and businesses, and their respective employees:
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, The Port of Tampa and the City of Tampa.
II. STATEMENT OF CASE AND FACTS
1. On January 21, 2023, I was driving myself, my wife Maria Paizes, disabled mother-in-law Dolores Konior, and friend Margaret (Peggy) O’Neill from Bradenton, Florida, to visit the Tampa Aquarium at the Port of Tampa on Channelside Drive to celebrate Ms. O’Neill’s 70th birthday.
2. Several Hillsborough County Sheriff deputies were outside the Port of Tampa and The Tampa and Aquarium controlling and directing the flow of traffic in the area.
3. I was seeking the closest point to the Aquarium to drop my passengers before parking when I was given directions from Deputy * Ortiz (ABN 255462 * First name redacted) to enter The Tampa Aquarium driveway which requires crossing streetcar/trolley rail tracks.
4. As I proceeded, Deputy Corporal Desirae Krouse signaled for me to stop; I complied and came to a complete stop more than ten feet from the streetcar tracks where Deputy Desirae Krouse, Deputy Natalie Neimann and Deputy Demetrios Antoniades were posted.
5. Hillsborough Transit Authority (HART) Streetcar No. 430 operated by Motorman Ralph Rosado passed the scene without slowing or stopping and without sounding its audible external horn.
6. After the streetcar/trolley passed, I proceeded forward where I was confronted by an unreasonably hostile and rude deputy Desirae Krouse. Confused by her behavior I stated, “there’s no need to be rude.” My comment visibly enraged deputy Krouse further.
7. Deputy Desirae Krouse then engaged in an extended, hostile encounter, threatened to arrest me, detained my person and driver’s license, scared and detained my passengers who were relying on me for transport.
8. During the illegal stop I repeatedly objected to deputy Desirae Krouse concerning the lack of probable cause to conduct the stop, demanded a supervisor and repeatedly insisted that she turn her body worn camera on to record the incident, all to no avail.
9. Deputy Desirae Krouse issued an unfounded, bogus citation charging me with failing to yield to a transit vehicle (F.S. § 316.0815(1)), alleging that the trolley was forced to sound its horn and come to a stop to avoid a collision with my vehicle.
10. The encounter lasted between 20 and 25 minutes and each moment was a horrifying experience.
11. Afterward, I obtained HART forward and rear facing dash cam videos from the trolley named in the citation that showed my vehicle stopping safely several feet from the tracks.
12. I also obtained passenger (in my vehicle) affidavits detailing passengers’ observations of the unlawful stop, deputy Desirae Krouse’s demeanor and the effect the experience had on them.
13. On March 28, 2023, I attended a traffic hearing (video recorded) to challenge the citation. Traffic Hearing Officer Joseph Frank found me guilty and upheld the citation despite video evidence and affidavits disproving deputy Desirae Krouse’s allegations.
14. I then challenged the traffic hearing officer’s findings in the Circuit Court in its appellate capacity, where Judge Lindsay Alvarez reversed the decision on November 20, 2024.
15. Specifically, the appellate Court found that the record lacked competent, substantial evidence to support the citation, and that the video contradicted officer testimony, noting several irregularities regarding deputy Desirae Krouse’s testimony and other deputies called by Krouse as witnesses.
16. Although the Circuit Court’s official ruling was in reference to the lack of competent, substantial evidence, the court noted several instances of procedural safeguard violations during the hearing.
17. I filed a complaint with the Hillsborough County Sheriff’s Office, Professional Standards Bureau-Internal Affairs (PSB Case No.: I-2023-008), regarding deputy Desirae Krouse’s misconduct, followed by a supplemental complaint that included evidence I obtained.
18. Professional Standards investigators were provided copies of the trolley videos, and the independently obtained surveillance footage from the Port of Tampa of the incident.
19. Master Detective Belinda Denbigh, led the investigation and conducted numerous (20) audio recorded interviews (while under oath and penalty of perjury) with every officer present at the scene, myself, each of my passengers, the trolley motorman, and other Sheriff’s Office employees.
20. Unaware that surveillance footage existed, several officers provided knowingly false and misleading sworn statements concerning my alleged conduct and deputy Desirae Krouse’s misconduct in an coordinated attempt to shield Krouse from disciplinary proceedings.
21. Investigators ultimately determined that Krouse only violated department policy regarding the proper use of body worn cameras and her failure to activate her body camera when conducting the illegal stop and detention in this case.
22. The Professional Standards detectives took no action regarding the validity, or lack thereof, regarding the traffic stop, me and my passengers’ detainment, or the citation Krouse wrote alleging known false traffic violations.
23. Those findings were made before the Circuit Court reversed the traffic hearing court’s order, finding a complete lack of evidence to support the citation, while criticizing the traffic hearing as a whole, including harsh critique of deputy Krouse and her fellow deputy witnesses.
24. Despite having all relevant evidence and compelling video footage, Professional Standards Bureau personnel failed to notify their superiors that officers interviewed in connection with this case had knowingly offered dishonest statements, and did not take any action to confront or discipline the officers’ perjury.
25. The Professional Standards Bureau’s failures are indicative of a widespread problem regarding officer integrity and honesty, pointing to a department-wide culture of covering-up and wrongdoing. It is quite alarming and troublesome to consider that internal affairs investigators, along with officers present at the scene, so readily colluded to cover up deputy Desirae Desirae Krouse’s misconduct even in the face of conclusive video, witness affidavit and testimony evidence to the contrary.
26. The recent Hillsborough County Sheriff’s Office cheating scandal involving the resignation and/or termination of multiple high-ranking officers further strengthens the evidence in this case proving a culture of dishonesty and corruption within the agency.
27. It should be noted that the Division Commander Lora Rivera of the Professional Standards Bureau-Internal Affairs who supervised the agents assigned to investigate this case was one of the officials who resigned amid the cheating controversy, and Master Detective Denbigh is no longer assigned to the Professional Standards Bureau.
28. Following the conclusion of the appellate process reversing the traffic citation in 2024, I requested my complaint be reopened. The Hillsborough County Sheriff’s Office declined, stating the agency maintained their initial investigation’s findings.
29. I have suffered prejudice and damages as a result of the incident described herein and seek legal redress.
III. EVIDENCE SUMMARY
The following list details evidence being provided to support this Notice and future litigation. I reserve the right to amend or add to this list at any time as more information becomes available.
1. Hillsborough Transit Authority (HART) forward and rear dash cam videos (Streetcar No. 430) showing continuous, unimpeded trolley movement with the Claimant’s vehicle fully stopped, well clear of tracks and the trolley not stopping or sounding nuts horn.
2. Passenger affidavits (Dolores Konior and Margaret O’Neill).
3. Certified March 28, 2023, traffic hearing transcript.
4. March 28, 2023, Traffic Hearing video, recorded at the hearing.
5. Circuit Court Opinion and Order dated November 20, 2024, reversing the hearing officer’s ruling for lack of competent, substantial evidence.
6. Internal Affairs/Department of Professional Standards documents and evidence, including but not limited to:
(a) Initial complaint.
(b) Supplemental Complaint.
(c) Email chains between Claimant and Professional Standards-Internal Affairs (IA) personnel.
(d) Official findings that Krouse violated body camera policy (failure to activate).
7. Cell phone video captured by passenger at scene.
8. Surveillance video footage recorded by the Port Tampa Bay.
9. Audio recorded interviews under oath conducted by Hillsborough Sheriff Professional Standards-Internal Affairs investigator Master Detective Belinda Denbigh with accompanying non-certified transcripts of the following witnesses:
(a) Demetrios Antoniades, 3/15/23
(b) Anastasia Castillo, 5/4/23
(c) Jillene Caydis, IA Interview (2 interviews), 5/4/23
(d) Todd Farrell, 3/20/23
(e) Brandon Hartz, 3/30/23
(f) Kennedie Jackson, 4/4/23
(g) Dolores Konior, 3/8/23
(h) Desirae Krouse, 3/29/23
(i) Desirae Krouse, 4/26/23
(j) Desirae Krouse, 5/5/23
(k) Eric Lampe, 5/4/23
(l) Sankar Mantute, 5/4/23
(m) Natalie Niemann, 3/15/23
(n) Margaret (Peggy) O’Neill, 3/9/23
(o) Christian Ortiz Ortiz, 3/20/23
(p) Maria Paizes, 3/1/23
(q) Spiros Paizes, 2/28/23
(r) Ralph Rosado, 3/16/23
(s) Mike Signoracci, 3/8/23
(t) Kyle Varnum, 5/4/23
(u) Hearing officer Joseph Frank apologizing for being wrong video.
The evidence proffered and listed herein is stored on the various secure websites including: www.TampaCivilRights.com, www.DesiraKrouse.com, www.TampaCivilRightsCoalition.com and others which can be located under the tab titled EVIDENCE on the left side of each website for easy access. Each of the websites is secure using SSL/TLS Encryption and has a SSL certificate to protect website visitors and data.
IV. DETAILED CLAIMS
ELEMENTS, RECORD FACTS, EVIDENCE, AND RELIEF SOUGHT
CLAIM 1
Unlawful Stop / False Detention / Threat of False Arrest
Factual Basis
Deputy Corporal Desirae Krouse subjected Claimant to an unlawful, unreasonably prolonged traffic stop without probable cause under threat of arrest. On January 21, 2023, Corporal Krouse stopped Claimant, retained his driver’s license, illegally detained his person, and prevented Claimant and his passengers from leaving for over twenty (20) minutes. The illegal stop and detainment ended with deputy Desirae Krouse issuing Claimant a citation for failing to yield to a public transit vehicle, and alleged that Claimant did not stop to or give an oncoming trolley the right-of-way, causing the trolley to come to a halt, nearly causing a collision.
Contemporaneously, HART forward/rear dash cam video from the very trolley passing through demonstrates that Claimant yielded well clear of the tracks, did not obstruct or force the streetcar to stop or avoid a collision. The video directly contradicts the factual basis of the citation. At the time deputy Desirae Krouse wrote the citation she did not know the moment was being captured on video by the passing trolley, and since she refused to engage her body-worn camera, Krouse incorrectly believed Claimant would not be able to disprove her fictitious, manufactured allegations in the citation.
Deputies Natalie Niemann and Demetrios Antoniadis testified consistently with the video at the subsequent hearing, confirming that Claimant yielded properly. Despite this, Corporal Desirae Krouse detained Claimant and ultimately issued the citation she knew was false.
The Circuit Court, upon later review, determined:
“It is plain from the video that Paizes did, in fact, yield to the streetcar. In this regard, the video contradicts the testimony of Corporal Krouse.... Most significant, the video shows that Paizes both obeyed Corporal Krouse’s command and yielded to the streetcar. Both Deputy Neimann and Deputy Antoniadis testified in accordance with what the video depicted, that is, they both confirmed that Paizes did not fail to yield.”
The Court further held:
"Upon review of the testimony and evidence presented, the Court finds that no competent, substantial evidence supports the Hearing Officer’s finding of guilt with respect to the infraction cited.”
The reversal confirms the absence of probable cause, and as a whole that the traffic stop was unlawful. The stop was unreasonably prolonged. A routine traffic stop and citation typically lasts less than ten minutes. Here, Claimant was detained more than twice the average length of a stop without justification. Claimant is currently a 66 year old law abiding citizen with no outstanding warrants, who provided his license under threat of arrest and duress. Two of his passengers were elderly women (70 and 83 years old) and one was disabled, along with Claimant’s 56 year old wife.
The persuasive video evidence proves the stop of Claimant and his passengers was with the intended purpose of retaliation and intimidation and concluded with the issuance of what deputy Desirae Krouse knew was a fraudulent citation. Whereas deputy Desirae Krouse initiated the traffic stop on known pre-textual grounds in order to issue a citation based on fabricated allegations, the entire time deputy Desirae Krouse kept Claimant and his passengers from freely going about their business was time that she illegally detained the group.
Deputy Krouse’s misconduct is undeniable as it is captured on video, creating certain liability for her employer and every business or agency that came to contract her services through the Sheriff’s Office; anyone who owns or operates the property where the incident occurred, and the Hillsborough County Sheriff’s Office and all of its employees present at the incident.
Conclusion
Defendants are bound by the Circuit Court’s order reversing the traffic hearing officer’s decision. That order, rendered by a court of competent jurisdiction, is the strongest legal evidence supporting Claimants allegations. The Court’s independent analysis reached the only inevitable conclusion possible. That Claimant and his passengers were illegally stopped and unlawfully detained by deputy Corporal Desirae Krouse who was disciplined for some of her misconduct (but not all), and who gave perjured testimony at a biased traffic court hearing. The circumstances described herein caused Claimant significant harm. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 2
Deputies Committing Perjury in Sworn Administrative Interviews
Factual Basis
During the Professional Standards investigation into deputy Corporal Desirae Krouse’s misconduct, five Hillsborough County Sheriff’s deputies provided sworn interviews under oath.
Each of these officers falsely claimed that Claimant (Paizes) failed to yield, obstructed the trolley, lied or otherwise engaged in conduct that justified Krouse’s citation, or falsely denigrated Claimant’s character.
Detectives had in their possession contemporaneous trolley video footage that conclusively disproved these sworn statements. The video showed Claimant properly yielding, the trolley continuing without slowing or stopping, and no obstruction or violation occurring.
The five Deputies, (Antoniadis, Farrell, Krouse, Neimann, and Ortiz) all provided what they knew were false statements of material fact and testimony when under oath and being interviewed (under oath and audio recorded) by Master Detective Belinda Denbigh. The officers intended to mislead the investigators and conceal misconduct by deputy Desirae Krouse.
Deputy Demetrius Antoniadis deceived Professional Standards Detectives when he knowingly provided false testimony stating that he heard the passing trolley sound its horn, and that deputy Desirae Krouse was justified in writing the citation because it was a close call in reference to the alleged near collision that never occurred. Although Antoniadis did concede that Claimant stopped when ordered, he also attempted to defend deputy Desirae Krouse’s misconduct when illegally detaining Claimant, and committed perjury in the process.
Deputy Todd Farrell deceived Professional Standards-Internal Affairs (PSB-IA) investigators when he claimed deputy Desirae Krouse explained to Claimant why she was giving him a citation. Krouse herself admitted that she did not inform Claimant the reasons for the citation. When asked what his response would be if Complainant denied being informed why he got a ticket, Farrell responded, “…[h]e’s lying.” Farrell did not know that deputy Desirae Krouse confessed not educating Claimant on her decision to cite him, nor did he realize a video from the trolley existed when he was interviewed for the investigation.
Deputy Desirae Krouse claimed that she informed her immediate supervisor, Sergeant Brandon Hartz about the encounter with Claimant, a claim Sgt. Hartz denied. Krouse also made various claims as to the reasons she did not engage her body-worn camera when she stopped Claimant. During one interview she stated that Deputy Antoniadis told her she did not have to turn on her body-worn camera, a claim disputed by Antoniadis during his interview. In another interview deputy Desirae Krouse claimed she was told she did not have to use her body camera when on federally owned property, a claim she could not attribute to any source. Krouse also continued to maintain her position that Claimant committed a traffic violation despite the unequivocal video evidence to the contrary. Deputy Desirae Krouse also denied that Claimant stated to her, “there’s no need to be rude” when testifying at the traffic court hearing, then admitted she made the statement when being interviewed under oath for the Professional Standards investigation. Krouse also referred to the Claimant as a “First Amendment Auditor,” which is an unjust characterization of Claimant. First Amendment auditors are usually described as individuals who test the boundaries of free speech and the right to record by filming public officials and employees in public spaces like government buildings, libraries, and police stations, aiming to provoke reactions using confrontational and provocative behavior to challenge police officers.
Former deputy Natalie Neimann was also interviewed and gave conflicting information regarding the traffic stop and incident. Neiman made the following claims: “…[t]he vehicle started to pull up to the trolley tracks and there was a train coming, so we were motioning that car to stop. The individual driving the car drove past… And was that near the mouth? Oh yeah, right on the tracks, pretty much… you're taking on a big train… trying to stop a train from hitting his car.” Then testified at the traffic court hearing two weeks later that Claimant did in fact yield when ordered to. Her sworn statement to PSB/IA investigators was perjurious and proven dishonest via video footage.
In light of the irrefutable video evidence, there is no legitimate, good faith explanation or justification for the deputies’ perjured testimony. There is no mistake, confusion or other inadvertence can excuse the false material facts provided by deputies. Their concerted effort to aid deputy Desirae Krouse in avoiding discipline constitutes collusion to cover-up and conceal misconduct. Such conspiratorial behavior in what was an ordinary case, suggests a wide spread culture of collusion, concealment and dishonesty that is accepted and encouraged within the Hillsborough County Sheriff’s Office. Recent cheating scandals among high ranking Deputies emphasizes the toxic temperature throughout the ranks of the Sheriff’s Office. The ease in which the officers in this particular case chose to commit the crime of perjury indicates the scale of deliberate indifference to misconduct. This type of conduct unbecoming a law enforcement officer is accepted within the Sheriff’s Office, a culture that contributed the damage suffered by Claimant.
Conclusion
By committing perjury in an orchestrated effort to shield deputy Desirae Krouse of negative consequences for her misconduct, the officers impeded the investigation and obstructed justice, prejudicing Claimant in exercising his Constitutional rights seeking redress for the misconduct inflicted upon him by deputy Desirae Krouse. As a result, Claimant suffered considerable damages: physical, emotional, psychological and financial entitling him to relief.
Deputies Niemann, Antoniades, Ortiz and Farrell each gave different versions. Niemann
and Antoniades claimed the trolley stopped, Claimant did not stop and/or the traffic stop was justified. Farrell made false statements. Ortiz stated he heard deputies tell Claimant not to park on the tracks. Yet the video shows otherwise. Their sworn statements don’t match the evidence, and they don’t even match each other.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 3
Obstruction of Justice /Negligent Investigation /
Failure to Report Known Perjury and Misconduct by Sworn Officers
Factual Basis
Claimant hereby incorporates and re-alleges the information, facts, and evidence outlined in Claims 1 and 2 of this notice, and adds the following:
Hillsborough County Sheriff’s Office, Professional Standards detectives, mainly Master Detective Belinda Denbigh, were assigned to investigate deputy Desirae Krouse’s misconduct during the unlawful traffic stop of Claimant and his passengers. When interviewing witnesses in connection with Claimant’s complaint, multiple officers knowingly provided sworn audio recorded statements about Claimant and deputy Desirae Krouse’s conduct that were proven false by video evidence, hearing video and civilian witness testimony in the investigators possession.
Deputy Demetrius Antoniadis deceived Professional Standards detectives when he knowingly provided false testimony stating that he heard the passing trolley sound it horn, and that Krouse was justified in writing the citation because he believed, based on his meany years of experience the stop was justified regarding the alleged near collision that never occurred. Although Antoniadis did eventually concede that Claimant stopped when ordered, he also attempted to defend Krouse’s misconduct when illegally detaining Claimant, and committed perjury in the process.
Deputy Todd Farrell deceived IA investigators when he claimed deputy Desirae Krouse explained to Claimant why she was giving him a citation. Krouse herself admitted that she did not inform Claimant the reasons for the citation, alleging Claimant was too hostile to listen. When asked what his response would be if Complainant denied being informed why he got a ticket, Farrell responded, “...[h]e is lying.” Farrell did not know that Krouse confessed not educating Claimant on her decision to cite him, nor did he realize a video from the trolley existed when he was interviewed for the investigation.
Deputy Desirae Krouse claimed that she informed her immediate supervisor, Sergeant Brandon Hartz about the encounter with Claimant, a claim Sgt. Hartz denied. Krouse also made various claims as to the reasons she did not engage her body-worn camera when she stopped Claimant. During one interview she stated that Deputy Antoniadis told her she did not have to turn on her body-worn camera, a claim disputed by Antoniadis during his recorded interview. In another interview deputy Desirae Krouse claimed she was told she did not have to use her body camera when on federally owned property, a claim she could not attribute to any source. Krouse also continued to maintain her position that Claimant committed a traffic violation despite the unequivocal video evidence to the contrary. Deputy Desirae Krouse also denied that Claimant stated to her, “there’s no need to be rude” when testifying at the traffic court hearing, then admitted he made the statement when being interviewed under oath for the IA investigation, another lie.
Former Deputy Natalie Neimann was also interviewed and gave conflicting information regarding the traffic stop incident. Neiman made claims that the trolley stopped, then testified at the traffic court hearing two weeks later that Claimant did yield when ordered to. Her sworn statement to IA investigators was perjurious and proven dishonest via video footage.
In addition, deputy * Ortiz (first name redacted) dishonestly informed Professional Standards Bureau detectives that he heard several officers yelling at Claimant “don’t park on the tracks,” or “get off the tracks.” Since video footage proves Claimant never parked on the tracks, Deputy Ortiz’s claim of what other officers were yelling was not possible. Deputy Ortiz also claimed to have heard the trolley sound its horn or whistle, another fact proven false by the trolley video. Also, Motorman Ralph Rosado operates the subject trolley on the day in question and denied sounding his horn or slowing or stopping when interviewed by Professional Standards detective Belinda Denbigh.
The only explanation for deputy Ortiz to provide these false material statements is that he was attempting to assist deputy Desirae Krouse in avoiding discipline by validating her bogus traffic citation issued to Claimant. Ortiz was interviewed on March 20, 2023, eight days before the traffic hearing where Claimant introduced the trolley video. Therefore, at the time Ortiz was interviewed he was unaware a video existed that would refute his statements.
Detective Belinda Denbigh failed to notify her superiors that the deputies had lied to her while under oath, took no corrective or disciplinary measures, and joined in the collusion to shield deputy Desirae Krouse from accountability for her misconduct.
Professional Standards detectives possessed contemporaneous trolley video footage and, witness affidavits, interviews and other evidence that conclusively disproved the officers’ sworn accounts.
The video showed Claimant yielding to the passing trolley, contradicting claims that he forced the trolley to stop. Trolley motorman, Ralph Rosado, stated that he did not encounter any traffic hazards on the day of the incident, and that he did not have to slow down or stop, sound the trolley’s horn, and was not involved in a near collision as cited by deputy Desirae Krouse in her traffic ticket/citation, further corroborating Claimant’s allegations while disproving the sworn statements of the officers.
Despite clear evidence of perjury and falsification, the detectives failed to notify their superiors, initiate corrective action, or recommend discipline for the officers who lied under oath.
This failure deprived Claimant of a fair and thorough investigation, allowed false testimony to remain uncorrected in official records, and perpetuated harm to Claimant’s reputation and rights.
By failing to act, the detectives breached their duty to ensure integrity in internal investigations, obstructed the administration of justice, and contributed to the ongoing deprivation of Claimant’s constitutional rights.
Conclusion
Professional Standards detectives had a duty to ensure integrity in their investigation of deputy Deputy Krouse. By failing to notify superiors or take corrective action after discovering five officers lied under oath—a fact easily disproven by trolley video in their possession—the detectives obstructed justice, perpetuated falsehoods, and caused significant prejudice to Claimant. Hillsborough County Sheriff’s Office is liable for this negligent investigation and failure to report misconduct. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial entitling him to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 4
Perjury by Deputy Krouse During Traffic Court Hearing
Factual Basis
Deputy Desirae Krouse had a duty, both as a citizen and as a law enforcement officer, to provide honest and accurate testimony when called upon to be a witness.
At the traffic court hearing (video recorded), under oath, deputy Desirae Krouse knowingly gave perjured testimony consistent with the false allegations contained in the citation she issued to Claimant. Specifically, Krouse testified that Claimant did not stop his vehicle as ordered, and that an oncoming trolley was forced to stop to avoid a collision.
Claimant introduced video footage from cameras mounted on the trolley itself, which conclusively showing Claimant stopped several feet from the tracks, the trolley did not slow down, and it did not stop.
Even in the face of irrefutable video evidence, deputy Desirae Krouse maintained her false narrative.
Deputies Niemann and Antoniadis admitted Claimant did yield and posed no threat to the trolley, further disproving deputy Desirae Krouse’s testimony. Krouse’s perjury forced Claimant to appeal the citation to the Circuit Court at his own expense and effort. The Circuit Court reversed the citation, confirming the absence of competent, substantial evidence.
Deputy Desirae Krouse’s willingness to commit perjury under oath demonstrates misconduct that carries both criminal and civil liability.
Conclusion
Deputy Desirae Krouse’s perjured testimony under oath, combined with her issuance of a citation containing false allegations, constitutes both as perjury. Claimant suffered significant prejudice, reputational harm, and economic damages as a result. The Circuit Court’s reversal confirms the falsity of Krouse’s claims. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial and is entitled to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 5
False Official Statement / Falsification of Records / Perjury
Factual Basis
Deputy Desirae Krouse unlawfully detained Claimant and his three passengers for over twenty (20) minutes during a traffic stop later determined by the Circuit Court to lack competent, substantial evidence and probable cause to achieve its ultimate purpose of issuing Claimant a traffic citation, simpler because Claimant told Krouse “there’s nom need to be rude.” Speech that is protected by the United States Constitution and comparable provisions of the Florida Constitution. .
From the moment Claimant surrendered his driver’s license under threat of arrest and physical harm, until its return nearly a half hour later, Claimant was detained and not free to leave. Florida law is clear: when a citizen is compelled to provide a driver’s license and ordered not to leave by law enforcement, detention occurs, as no reasonable person would believe they were free to leave. Since Claimant was the driver, his three passengers—whose sole mode of transportation was Claimant’s vehicle—were also detained illegally. The Circuit Court’s order finding the stop unlawful confirms that the subsequent detention of Claimant and his passengers was also illegal
False Official Statement / Falsification of Records:
The citation narrative claimed Claimant “failed to yield to trolley despite multiple law enforcement officers directing him to stop” and “nearly causing a collision.” HART dash cam video and passenger affidavits (in Claimant’s vehicle) prove the trolley passed unimpeded and Claimant stopped well clear of the tracks.
Deputy Desirae Krouse testified under oath to facts contradicted by the video (e.g., that the trolley had to stop and sounded a whistle). The video and motorman statement directly refute these sworn assertions. When faced with video evidence proving her dishonesty, rather than confess her obvious untruthfulness, Krouse continued down her reckless path of deceit, maintaining the falsities detailed in the signed citation.
Deputy Desirae Krouse’s citation and courtroom testimony materially repeated the same false allegations. The Circuit Court expressly found the video contradicted her testimony. A traffic citation is an official document and knowingly providing false information in it for the purpose of causing Claimant undue hardship, embarrassment, financial loss, driving record blemishes; all with the initial intent of retaliation and harassment is an illegal act creating civil liability. Additionally, when affirming the dishonest allegations under oath during the traffic court hearing and subsequently in the internal affairs interviews, deputy Desirae Krouse committed perjury for which she has no legitimate or viable excuse or explanation. The traffic citation issued to Claimant was an officially prepared and signed statement containing material falsehoods that Krouse made knowingly and with reckless disregard for the truth.
Conclusion
Deputy Desirae Krouse’s unlawful detention of Claimant and his passengers, combined with her false official statements and perjured testimony, caused significant harm. The Circuit Court’s order confirms the absence of probable cause. Hillsborough County Sheriff’s Office and deputy Desirae Krouse have no viable defense for her misconduct. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial and is entitled to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 6
Assault and Battery
Factual Basis
Once Claimant parked and exited his vehicle, deputy Corporal Desirae Krouse immediately confronted him in an uncontrollable rage and physically threatening manner. Deputy Desirae Krouse forcefully invaded Claimant’s personal space, yelling within six inches of his face and spraying him with spittle. This unconsented, unlawful physical contact with bodily fluid constitutes offensive physical contact and qualifies as battery. The battery was intentional.
Deputy Desirae Krouse repeatedly ordered Claimant to provide his driver’s license and threatened physical restraint and arrest if he did not comply. Claimant protested, noting Krouse lacked probable cause for the stop and citation. However, her demeanor made Claimant fear she would physically attack him or use pepper spray, a taser, or her firearm if he did not comply with her unlawful demands. He surrendered his license under duress.
Deputy Desirae Krouse’s gestures and body language were aggressive and threatening to such a degree that Claimant feared for his safety, including the possibility of being shot and fatally injured. Elderly and disabled passengers provided affidavits confirming they too feared Claimant would be shot upon witnessing Krouse’s hostile demeanor. Deputy Krouse’s yelling, threats of arrest, and hostile demeanor created a reasonable belief of imminent force, constituting assault. Witness affidavits corroborate the aggressive conduct and confirm passengers feared Claimant would be physically harmed. The assault was intentional.
Several times during the encounter, Claimant demanded deputy Desirae Krouse activate her body-worn camera. She refused, and was later found in violation of departmental policy and reprimanded. Her refusal corroborates the assault and demonstrates consciousness of misconduct.
Conclusion
Deputy Desirae Krouse’s assaultive conduct, threats of unlawful force, refusal to activate her body-worn camera, and misuse of official process caused Claimant significant harm. Deputy Krouse’s assault was an intentional act creating a reasonable apprehension of imminent harmful or offensive contact for which Claimant reasonably feared physical harm. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial and is entitled to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 7
Obstruction of Justice (Interfering With Traffic Laws and Court Hearing)
Factual Basis
Law enforcement officers, including deputy Desirae Krouse, have a duty to lawfully enforce laws, protect the public, and aid in the administration of justice. As established by the Circuit Court’s order on appeal, Krouse issued Claimant a traffic citation containing several unequivocally false allegations disproven by video evidence. Krouse willingly and knowingly fabricated accusations, including that Claimant failed to yield when ordered, that a trolley was forced to stop to avoid collision, and that Claimant refused to obey commands.
Making false allegations to support an illegal traffic stop and unfounded citation established obstruction of justice. Krouse further obstructed justice by:
1. Failing to activate her body-worn camera during citizen interaction, in violation of policy.
2. Failing to exhibit professional behavior or deescalate the confrontation.
3. Conducting an unnecessarily prolonged traffic stop without probable cause.
At the traffic hearing, deputy Desirae Krouse selectively answered questions, refusing to respond to inquiries that would expose her retaliation and misconduct. The Circuit Court noted this selective testimony in reversing the citation. By withholding testimony and evidence favorable to Claimant, Krouse deprived the hearing officer of necessary information, denying Claimant due process under the State and U.S. Constitutions.
Conclusion
Deputy Desirae Krouse’s issuance of false allegations, refusal to activate her body-worn camera, selective, false testimony constituted obstruction of justice, interfering with the judicial process and laws of the land. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial and is entitled to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 8
Abuse of Process
Factual Basis
Deputy Desirae Krouse, acting under color of law, unlawfully manipulated procedures governing her duties to retaliate, harass, assault, and illegally detain Claimant during an unlawful traffic stop.
A lawful traffic stop requires an observable violation or probable cause. Neither existed here. Desirae Krouse initiated the stop simply because she was enraged by Claimant’s free speech statement: “there’s no need to be rude.” Krouse issued a citation for failing to yield as a pretext. The Circuit Court found absolutely no evidence supporting the citation. What should have never been a stop became a prolonged, irrational over 20 minute ordeal for Claimant and his passengers.
Deputy Desirae Krouse manipulated normal traffic stop processes to intimidate, threaten, punish and assault Claimant. The true purpose was retaliation for Claimant’s comment on her demeanor. Krouse lied at every stage: to Claimant at the scene, in the citation, to fellow officers and supervisors, under oath at the traffic hearing and subsequently in the audio recorded internal affairs investigation.
Specific abuses of process included:
1. Initiating a traffic stop without probable cause or a true traffic violation in retaliation to free speech.
2. Issuing a citation based on dishonest allegations, unsupported by competent, substantial evidence.
3. Engaging in unprofessional conduct unbecoming a Hillsborough County Sheriff’s Deputy.
4. Failure and refusal to activate her body-worn camera to record the incident.
5. Committing perjury at the traffic hearing (video recorded) and in the internal affairs investigation, which was audio recorded in three interviews.
6. Krouse was also dishonest to Professional Standards Bureau detectives when she claimed to have informed her supervisor of the incident, a claim her supervisor denied.
Deputy Desirae Krouse engaged in intentional manipulation of procedures for an ulterior motive, i.e., intimidating, retaliating, punishing and threatening Claimant, and using her position as a law officer to mislead and divert attention from her wrongdoing. These abuses deprived Claimant of rights and protections, causing significant damages.
Conclusion
Deputy Desirae Krouse’s manipulation of lawful procedures, issuance of false allegations, perjury, refusal to activate her body-worn camera, and extreme, outrageous conduct constituted abuse of process and intentional infliction of emotional distress. Claimant suffered significant damages as a result. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial and is entitled toed to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 9
Abuse of Power and Authority
Factual Basis
Deputy Desirae Krouse’s position as a law enforcement officer gave her authority to uphold the laws of Florida and the United States. That authority is bound by strict policies and rules of conduct.
Instead of responsibly exercising her authority, deputy Desirae Krouse abused it by conducting an unlawful traffic stop, assaulting Claimant, and illegally detaining him and his elderly and disabled passengers out of anger and retribution.
Krouse wielded her power in a totalitarian manner inconsistent with departmental policy and guidelines. She exercised complete dominion over Claimant—spitting in his face, demanding identification in a coercive manner, threatening physical restraint and arrest, and prolonging the abuse for nearly half an hour.
The Circuit Court’s order reversing the citation confirms there was no probable cause for the stop. Deputy Desirae Krouse’s misconduct was a clear abuse of the authority vested in her as a sworn deputy. Hillsborough County and Hillsborough County Sheriff’s Office must not permit such abuse by its deputies and should embrace accountability and transparency.
Conclusion
Deputy Desirae Krouse’s unlawful traffic stop, assaultive conduct, and retaliatory detention constituted a misuse and abuse of her power and authority. Claimant suffered significant damages as a result. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial and is entitled to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 10
Negligence – Failure of OnScene Officers to Intervene
Factual Basis
Hillsborough County Sheriff’s deputies Natalie Niemann and Demetrios Antoniadis were assigned to off-duty traffic control outside The Tampa Aquarium and Port Tampa Bay with deputy Desirae Krouse on the day of the incident. Niemann and Antoniadis witnessed all or parts of the unlawful traffic stop and misconduct perpetrated by Krouse against Claimant, including:
Deputies Niemann and Antoniadis testified consistent with the video that Claimant yielded properly, yet they failed to intervene, to deescalate or terminate the unlawful detention.
Despite having a duty to intervene, they allowed deputy Desirae Krouse to continue detaining and threatening Claimant. Their inaction prolonged the detention and contributed to the harms suffered. The record establishes their presence and failure to act, which proximately caused additional damages to Claimant.
Deputies Natalie Niemann and Demetrios Antoniadis had a duty to intervene to protect Claimant and preserve his constitutional rights. They knew Claimant’s rights were being violated and had a realistic opportunity to intervene, but failed to take reasonable steps. Their negligence allowed Claimant to suffer damages and deprivation of rights.
Conclusion
Deputies Natalie Niemann and Demetrios Antoniadis negligently failed to intervene despite witnessing deputy Desirae Krouse’s unlawful conduct. Krouse’s retaliatory actions against Claimant’s protected speech, combined with the prolonged unlawful detention and false citation, caused significant damages. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial and is entitled to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 11
Deliberate Falsification of Citation
Factual Basis
Deputy Desirae Krouse had a duty to conduct herself ethically and honestly, including when preparing citations. Krouse deliberately issued Claimant a citation for failing to yield to a transit vehicle, based on false information designed to validate her unlawful conduct in stopping Claimant in retaliation for protected First Amendment speech.
Allegations in the citation included that Claimant failed to yield despite being ordered to stop by several officers, and that the trolley was forced to stop to avoid collision.
The Circuit Court, in reversing the citation, found video footage from the trolley definitively showed Claimant stopped several feet from the tracks, the trolley did not slow down, and it did not stop.
The trolley engineer Ralph Rosado reported no incident or near collision, corroborating the video.
At the traffic hearing, confronted with video evidence, deputy Desirae Krouse maintained her false narrative rather than admit fabrication. Deputies Natalie Niemann and Demetrios Antoniadis eventually admitted Claimant did yield and posed no threat to the trolley.
Deputy Desirae Krouse knowingly falsified an official document and committed perjury rather than admit misconduct.
Conclusion
Deputy Desirae Krouse’s deliberate falsification of a citation, compounded by her failure to preserve exculpatory evidence through refusing to engage her body-cam, deprived Claimant of due process and caused significant damages. The Circuit Court’s reversal confirms the absence of factual support for her allegations. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: physical, emotional, psychological and financial and is entitles to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 12
Defamation / Slander and Damage to Reputation
Deputy Desirae Krouse, Deputy Demetrios Antoniadis, Deputy Natalie Neimann, Deputy Todd Farrell and Deputy Ortiz all intentionally defamed and/or slandered Claimant by and through either issuing him a fraudulent traffic citation, or providing sworn statements to Professional Standards Bureau detectives when conducting an investigation into Krouse’s misconduct.
By issuing Claimant a fictitious citation for failing to yield, deputy Desirae Krouse knowingly made false allegations defaming Claimant, alleging he was a reckless driver who put himself, his elderly and disabled passengers, and public transit passengers in the passing trolley in imminent danger.
During a subsequent Professional Standards Bureau investigation initiated by a complaint filed by Claimant, deputy Desirae Krouse continued to disparage Claimant’s character and reputation. When giving sworn statements to Professional Standards detectives, Krouse made claims such that Claimant must not like women or Germans, and that he has a problem with women of authority. Krouse even stated multiple times that she believed Claimant is mentally ill. Each of her statements are false, and lack any substantive proof or evidence corroborating the claims she falsely made.
Deputy Demetrios Antoniadis made several slanderous remarks, in particular that Claimant voiced a prejudice or assumption that Deputy Krouse’s name was of German descent, thereby, comparing her to Nazi Germans, a wholly improper interpretation of the incident and what truly occurred. Antoniadis purposely mislead the investigators to wrongfully believe that Claimant was irrational and bias, while Krouse was allegedly professional courteous.
Deputy Todd Farrell made slanderous remarks without proof: Farrell stated: “He don't like taking orders from a woman.” To me, I don't know if he was sexist…” “He was just trying to push it, you know, just a little bit, you know, how to push buttons” and “he's lying.”
Deputy Natalie Niemann also made slanderous remarks without proof: Niemann stated:
“…antagonistic, arrogant.”
Conclusion
Claimant suffered damage to his name and reputation as a result of deputy Desirae Krouse’s, deputy Demetrios Antoniadis’s, deputy Todd Farrell’s, deputy Ortiz’s and deputy Natalie Niemann’s defamatory misconduct. Their false statements denigrating Claimant interfered with the Professional Standards Bureau investigation, further preventing Claimant the protections of law due him. Such defamation also exposes the false information and allegations to discovery through public records by any person. There is no method in which to shield Claimant from the harm caused by the deputies defamatory remarks. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: reputational, physical, emotional, psychological and financial and is entitled to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 13
Intentional Infliction of Emotional Distress
Factual Basis
Claimant suffered severe emotional distress intentionally inflicted by deputy Desirae Krouse.
The distress has impacted every aspect of Claimant’s life since being assaulted, threatened, and placed in a position of permanent mistrust when dealing with law enforcement officers.
Krouse’s conduct—including yelling inches from Claimant’s face, spitting on him, threatening arrest, and prolonging an unlawful detention for nearly half an hour—was outrageous and extreme beyond any reasonable policing interaction.
Claimant’s passengers, including an elderly and disabled individual, corroborated the fear and humiliation caused by deputy Desirae Krouse’s behavior. Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, as Krouse’s employers, bear the responsibility for compensating Claimant for the emotional distress intentionally inflicted by its deputies and/or contractual employees. Deputy Desirae Krouse issued a citation that led to enforcement proceedings against Claimant, which was exacerbated by collusion by deputy Natalie Niemann, Deputy Demetrios Antoniades, deputy Ortiz, deputy Todd Farrell and the failed investigation and cover up by Professional Standards Bureau, Master Sergeant Belinda Denbigh and her superiors.
The Circuit Court’s reversal of the citation constitutes favorable termination on the substantive merits.
The lack of probable cause, demonstrated by video evidence, witness testimony and the appellate decision, supports the wrongful prosecution element.
Evidence of retaliatory motive—specifically Krouse’s escalation after Claimant exercised First Amendment protected speech (“there’s no need to be rude”)—supports malice.
The citation and subsequent proceedings forced Claimant to expend time, effort, resources and finances to defend himself, causing both economic and emotional damages.
Conclusion
Deputy Desirae Krouse’s outrageous conduct intentionally inflicted severe emotional distress on Claimant, while her issuance of a baseless citation and pursuit of proceedings constituted malicious prosecution and abuse of process. The Circuit Court’s reversal confirms the absence of probable cause. Claimant was prejudiced by the misconduct described herein and suffered considerable damages: reputational, physical, emotional, psychological and financial and is entitled to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
CLAIM 14
Obstruction of Justice by Sworn Officers and Investigating Detectives
Negligent Failure of Professional Standards Detectives to Act
Factual Basis
Five Hillsborough County Sheriff’s deputies provided sworn statements during Professional Standards interviews regarding deputy Corporal Desirae Krouse’s misconduct.
Each officer falsely claimed that Claimant failed to yield, obstructed the trolley, or otherwise engaged in unlawful conduct.
Detectives conducting the investigation had in their possession contemporaneous trolley video footage, civilian witness affidavits and testimony that conclusively disproved these deputies’ sworn statements. The video showed Claimant properly yielding, the trolley continuing without slowing or stopping, and no obstruction or violation ever occurring.
Despite clear evidence of perjury and falsification, Professional Standards detectives failed to notify their superiors, initiate corrective action, or recommend discipline for the officers who lied under oath.
By allowing false testimony to remain uncorrected in official records, detectives obstructed the administration of justice and deprived Claimant of a fair and thorough investigation. This failure perpetuated falsehoods, obstructed due process, and caused Claimant reputational harm, emotional distress, and economic damages (including costs of appeal, defense and subsequent costs to research and bring this action).
Conclusion
Five deputies committed perjury during sworn Professional Standards interviews by falsely claiming Claimant failed to yield—statements easily disproven by trolley video in the detectives’ possession. Professional Standards detectives, despite clear evidence, failed to notify superiors or take corrective action. This obstruction of justice perpetuated falsehoods, denied Claimant due process, and caused significant prejudice by the misconduct described herein and suffered considerable damages: reputational, physical, emotional, psychological and financial and is entitled to relief.
Hillsborough County Sheriff’s Office, Hillsborough County, The Tampa Aquarium, Port Tampa Bay and the City of Tampa, are jointly and severally liable under Florida Statute § 768.28 for the misconduct of deputies acting within the scope of their employment and under contractual agreements for traffic control and other services. Each entity had a duty to ensure lawful enforcement and supervision of officers. Their business or public safety decisions caused damages to Claimant.
RELIEF SOUGHT
Claimant seeks damages for harm caused by the effect of the issues raised herein, compensatory, punitive, non-economic, and any and all other types of relief to which he may be entitled. Claimant intends to seek Declaratory relief that sworn falsehoods and investigative negligence occurred. Claimant will also seek Injunctive relief requiring policy change, mandatory reporting protocols, an independent audit of Professional Standards investigations, and formal administrative discipline for detectives who failed to act and officers who lied under oath. Claimant also intends to pursue criminal action with the appropriate prosecuting authority where applicable. Claimant seeks accountability and transparency of Hillsborough County and the Hillsborough County Sheriff’s Office and all members of the Sheriff department that were involved in the incident and investigation all the way up the hierarchy to Sheriff Chad Chorister, who signed off on the failed cover up investigation.
VI.
PRESERVATION DEMAND (Effective Immediately)
You are directed to preserve and not alter, delete, overwrite, or dispose of any materials potentially relevant to this incident, including but not limited to:
1. HART raw forward and rear dash cam video files for Streetcar No. 430 (Jan. 21, 2023; with metadata, GPS/timecode, file hashes, operator logs, and backups).
2. All HCSO body-worn camera (BWC) raw files, device assignment logs, activation logs, and SD card images for deputy Desirae Krouse, deputy Natalie Niemann, deputy Demetrios Antoniadis, deputy Todd Farrell, deputy Ortiz, and any other deputies present or involved in any way related to the incident and/or the internal affairs investigation.
3. All patrol dash cam recordings for vehicles present and in the area that day.
4. CAD/dispatch logs, radio transmissions, and call records for the relevant time window.
5. D.A.V.I.D./driver record query/audit logs showing any access to Claimant’s information on Jan. 21, 2023 (user, timestamps) and any subsequent searches of Claimant’s name in the D.A.V.I.D. system on the incident date and any day thereafter. If the D.A.V.I.D. system was accessed to inquire by any Sheriff’s Office personnel, the reason why the Claimant’s name was accessed.
6. Original citation (AGD50KE), any drafts, officer notes, incident supplements, supervisor reviews, and any internal memoranda referencing the incident.
7. Complete Professional Standards Bureau-Internal Affairs investigative file (interview recordings/transcripts, investigative exhibits, notes, IA findings, and discipline records). Preserve originals even if asserted confidential.
8. Any and all emails, text messages, or other communications referencing the incident, including any and all that contain the name of Claimant and any related communications.
9. Any private or third party video, photos, or audio referencing the incident.
10. Personnel and training records relevant to Body Worn Camera (BWC) use, and deescalation / off-duty training.
11. Any and all other document or tangible material that in any way may be related to the claims raised herein or to the persons named herein.
12. Complete personnel files of all deputies involved with the incident and investigation into Claimant’s complaint as stated herein, but not limited to deputy Desirae Krouse, deputy Natalie Niemann (including resignation departure letters of notes), deputy Demetrios Antoniades, deputy Todd Farrell, deputy * Ortiz ABN # 255462 (* first name redacted), and others.
13. Any and all complaints, discipline, corrective actions, reprimands or evaluations for each of the deputies mentioned in #12 above. This also includes any complaints filed by any citizen or any other Hillsborough County or Sheriff employee be it founded or unfounded.
12. All electronic communications between any and all Hillsborough County and Hillsborough County Sheriff personnel, be they sworn law enforcement officers, clerical or other staff employed by Hillsborough County and Hillsborough County Sheriff that mention or discuss Claimant, the incident or in any other way.
VII .
CERTIFICATE OF SERVICE /DELIVERY AND SIGNATURE
Claimant hereby certifies that each person, agency, municipality, entity listed on page one and two of this Notice has been served a copy of this document via certified U. S. Mail on this 9th day of December 2025.
Respectfully submitted,
Sincerely,
ORIGINALS SIGNED AND MAILED.
Claimant's information including contact information ids in the PDF version above.
