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Filing # 16068137 Electronically Filed 07/18/2014 10:01:49 AM <br />IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT <br />IN AND FOR INDIAN RIVER COUNTY, FLORIDA <br />TOWN OF INDIAN RIVER SHORES, <br />a Florida municipality, and MICHAEL <br />OCHSNER, <br />CASE NO.: <br />Plaintiffs, <br />v. <br />CITY OF VERO BEACH, a Florida <br />municipality, <br />Defendant. <br />COMPLAINT <br />Plaintiff, TOWN OF INDIAN RIVER SHORES (the "Town") and Plaintiff, MICHAEL <br />IIIOCHSNER (the "Customer," and collectively with the Town, "Plaintiffs"), by and through their <br />undersigned attorneys, sue Defendant, CITY OF VERO BEACH ("Defendant" or the "City"), <br />and allege as follows: <br />• <br />JURISDICTION AND VENUE <br />1. This is an action for declaratory and injunctive relief over which this Court has <br />jurisdiction pursuant to Section 26.012(2)(c) and (3) and Chapter 86, Florida Statutes. <br />2. Venue is proper in this Court pursuant to Section 47.011, Florida Statutes, <br />because both the Town and the City are municipalities in Indian River County, Florida, the <br />Customer resides in Indian River County, the Town's rights-of-way and other public areas which <br />are at issue in this Complaint are located in Indian River County, and the cause of action accrued <br />in Indian River County. <br />74, <br />