Page 3 of 14
C. The City of Orlando (the “City”)
Defendant, the City of Orlando (the “City”), is a Florida municipality. It is governed by a
Mayor and a City Council comprised of six City Commissioners. At all times pertinent hereto,
Patty Sheehan was a City Commissioner representing District Four, which includes downtown
In 2005, OFNB began conducting food sharing events in Lake Eola Park once a week on
Wednesdays at 5:00 p.m. TR at 102, 177 and 180. At these events, OFNB provided free food to
hungry and homeless individuals. At some point thereafter, the City began receiving complaints
from individuals who lived or worked near Lake Eola Park.4 TR at 240-42. The complaints
related to the large number of homeless people that had been dispersing into their neighborhoods
after the food sharing events. TR at 242. In response to these complaints,5 the City Council
drafted the Large Group Feeding Ordinance [hereinafter the “Ordinance”], which it presented to
the public at meetings held on June 19, 2006 and June 24, 2006. TR at 243.
4The neighborhoods closest to Lake Eola Park are referred to as the “Thornton Park neighborhood” and the “Lake Eola neighborhood” or “Lake Eola South.”
5Some of the complaints were sent directly to Commissioner Sheehan. On June 12, 2006, Sheehan’s Assistant, Charles Smith, sent an email to eight constituents who had made complaints, informing them that an ordinance had been drafted and would be presented to the public at a meeting scheduled for June 19, 2006. PL. EX. 3. The email stated that “the intent of this ordinance is to try to move the large groups of homeless out of downtown and create less of a ‘situation’ for the residents, businesses, etc. in the Lake Eola/Thornton Park neighborhoods when these groups disperse after feedings occur.” Id. Smith’s email also stated that Sheehan was “hoping the passage of this ordinance will resolve many of the post-feeding issues that everyone’s experiencing downtown.” Id.