So that would mean that Hunt thinks that Black and Anderson are part of the conspiracy?

That would seem to fit with Hunt's prior statements that a Fifth Column element in Venice was out to get him, as recounted by Venice City Councilman Rick Tacy in the transcripts of the city's EPA "shade meetings:"

Moreover, as will be shown below, Hunt's attorney is claiming knowledge of vastly more documentation than has ever factually existed.

Attorney Peter Baranowicz responds
On April 24, Patten's attorney, Peter Baranowicz, filed a "Motion for More Definite Statement."

This is known in legal movies as "put up or shut up."

You can read Baranowicz' entire motion here. In a nutshell, Baranowicz states:

"[Hunt's] complaint is so vague and ambiguous that the defendant [Patten] cannot reasonably be required to answer same. The complaint fails to specify what statements were made, to whom and when, and fails to set forth specific information to evaluate defenses, including... whether plaintiff's allegation that he was not a 'public figure' renders this a sham pleading, and... whether expedited review of the merits is obtainable under Florida's 'SLAPP' statute."

If that still doesn't make things clear, look at it this way: suppose a court complaint was made against you for murder and the complaint basically said that the defendant (you) at some as-yet unknown time and place killed some as-yet unknown person and disposed of the body and all physical evidence at some as-yet unknown place. The complaint then asked you to provide any and all physical evidence that would support the claim.

Can you see where you, a defense attorney and a judge might have a slight problem?

What's a SLAPP suit?
SLAPP stands for "Strategic Litigation Against Public Participation." SLAPP suits are typically filed by public officials, developers and others with a vested interest in particular ongoing public proceedings. A SLAPP suit is not intended to win actual damages as such, rather it is designed to shut down governmental critics for a time so that the plaintiff can continue on with his/her public business unencumbered by public criticism.

SLAPP suits almost always allege defamation and/or interference in a business relationship, two things that Hunt alleges in his lawsuit complaint.

Generally, a "SLAPP" is a (1) civil complaint or counterclaim; (2) filed against individuals or organizations; (3) arising from their communications to government or speech on an issue of public interest or concern. SLAPPs are often brought by corporations, real estate developers, government officials and others against individuals and community groups who oppose them on issues of public concern. SLAPP filers frequently use lawsuits based on ordinary civil claims such as defamation, conspiracy, malicious prosecution, nuisance, interference with contract and/or economic advantage, as a means of transforming public debate into lawsuits.
-- from The First Amendment Project's SLAPP resource web site

Filing a SLAPP suit for the mere purpose of shutting down public participation is something that the courts take a very dim view of. While SLAPP suits can work in the short term, the legal backlash in the form of a countersuit can be utterly devastating, this thanks to anti-SLAPP laws that have been passed in numerous states -- including Florida.

You can find out more about SLAPP suits here.

Pulp fiction
Hunt currently works for Barefoot Bay, a state-chartered "recreational district" in Brevard County. Over the last two years, he has applied for city manager jobs with three Florida municipalities: Treasure Island, Fernandina Beach and West Melbourne. Public records requests can be made by anyone, private citizen or media reporter, to those entities to verify Hunt's claims.

Of the four governments mentioned above, the only e-mailed communications that exist are with Fernandina Beach's then-interim city manager Jerry Sinclair and the city's then-interim city clerk, Anita Ross. Those e-mails are all directly related to a public records request for Hunt's resume packet and additional investigative background materials compiled by Fernandina Beach. These materials were later used in a story about governmental headhunter Colin Baenziger that was published to the web on January 9, 2006. This is in sharp contrast to Hunt's allegation that "...the [e-mailed] statements published and verbal communications to various third parties by Mr. Patten were not for purposes of public dissemination of information, but were private correspondences and verbal communications."

Copies of those e-mails to and from Patten can be obtained by a public records request to the City of Fernandina Beach. Additionally, local media can review those e-mails at the office of Venice Florida! dot com upon request.

In spite of Hunt's firm declaration to the contrary, no other e-mail communications of the kind described by Hunt were ever made by Patten. None. Nada. Period.

Additionally, Hunt's complaint alleges that e-mails were sent by Patten to various public officials in Barefoot Bay. This is a fiction -- it never happened. Again, a public records request to officials in Barefoot Bay will reveal that no such e-mails were ever sent to any public officials there.

It is this web site's position that Hunt's complaint is a complete and utter fiction overall, a fishing expedition designed to test out a shaky theory.

Barefoot Bay's board and the mayor of Venice give a thumbs up to a SLAPP suit
Hunt's lawsuit is, moreover, a SLAPP suit designed for two purposes.

The first purpose was to prevent the public dissemination of The Weglein Report, a document that chronicles, among other things, forged e-mails that were distributed to trustees in Barefoot Bay as an explanation for some serious financial shortcomings in Hunt's handling of the recreational district's books. The ultimate irony is that this web site had originally decided to take a pass on writing about the The Weglein Report. It wasn't until Hunt filed a lawsuit that the report had any meaning here in Venice.

The second purpose was to instill fear of Hunt, both here in Venice and in Barefoot Bay, and to prevent public criticism of his current performance there and past performance here in Venice.

To that extent, Hunt's lawsuit has been moderately successful. Despite knowledge of forged documents that have entered into the public record in Barefoot Bay, neither the community's attorney nor any of their trustees have yet to approach law enforcement to ask for a criminal investigation into the forgeries, this in spite of the fact that they each have a mandatory lawful duty to report such events. So Hunt's scare tactics have apparently worked well In Barefoot Bay, enough so that he has officials abandoning their sworn duties.

By the same token, city officials here are thoroughly unimpressed with Hunt. Just two weeks ago, Council voted to take a Hunt-negotiated lease to court in an attempt to nullify it. Councilman John Moore believes that Hunt gave away the store when he negotiated a land lease with the Sharky's on the Pier restaurant. It's a sore point that goes back to March of 2003 when Hunt was roasted in front of council for negotiating a lease with blank spaces where dollar amounts should have been. A few weeks after that incident, Hunt stormed out of a negotiation meeting, leaving the restaurant owner, the city attorney and Moore staring at each other in amazement. Now Moore wants to take the whole thing in front of a judge to have the deal nullified and council agreed in a unanimous vote.

Those two purposes, to prevent dissemination of information and to instill fear, are endorsed by both Barefoot Bay's local government and, to a somewhat lesser extent, the (now ex-) mayor of Venice, Dean Calamaras:

"I hope this action quiets things down in the Bay, removes some of the negative thinking, and will allow most of the Trustees and George to keep moving forward... George is a doer so lets let him do. I, for one enjoy working with George. I am also one that was happy for the Bay he stayed, but then I'm greedy."
-- Bob Carillion, Trustee, posted to the web on 03/31/06, one of many comments Carillion has made publicly endorsing Hunt's lawsuit

Calamaras, whose picture Patten once juxtaposed on his Web site with a picture of Mayor Quimby from The Simpsons, said he considered a similar suit himself. "...now he's going to pay for it."
-- then-Mayor Dean Calamaras as quoted in the Sarasota Herald-Tribune on 04/05/06

While it could be argued that Calamaras' comments are more of the usual public hissy fits that Venice has come to love and expect from him, Carillion's comments are an entirely different matter and could prove to be very problematic for Barefoot Bay later on. As Carillion continues to put the Board of Trustees' stamp of approval on Hunt's suit, Carillion places himself and the board squarely in the middle of the squabble.

If a judge later determines that Hunt's suit is indeed a SLAPP suit, an obvious question will arise: is the recreational district of Barefoot Bay, by its tacit endorsements through self-appointed spokesperson Bob Carillion, a willing party to a SLAPP suit?

...to be continued... ...unfortunately...