Here is the Complaint:
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IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT,
IN AND FOR LAKE COUNTY, FLORIDA
AUTUMN JACUNSKI, a Republican
Precinct Committeewoman,
Plaintiff,
v. CASE NO.:
THE LAKE COUNTY REPUBLICAN PARTY,
and MICHAEL TRAINOR,
Defendants.
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COMPLAINT FOR BATTERY AND NEGLIGENCE
Plaintiff AUTUMN JACUNSKI sues Defendants THE LAKE COUNTY REPUBLICAN PARTY, and MICHAEL TRAINOR, and states:
JURISDICTION, VENUE, & PARTIES
1. This is an action for damages that exceed $50,000.
2. Venue is proper in Lake County under Fla. Stat. § 47.011 because it is where the cause of action accrued.
3. Plaintiff AUTUMN JACUNSKI is a resident of Lake County and a precinct committeewoman of THE LAKE COUNTY REPUBLICAN PARTY.
4. Defendant Mike Trainor is a resident of Lake County and the Vice-Chairman of THE LAKE COUNTY REPUBLICAN PARTY.
5. Defendant THE LAKE COUNTY REPUBLICAN PARTY (“LCREC”) is a political party and entity organized under Chapter 103, Florida Statutes, headquartered in Lake County, FL.
FACTS
6. Plaintiff Jacunksi was physically battered by a member of the LCREC—her hand intentionally crushed in a steel door—at a meeting of the Lake County Republican Party, on August 19th, 2025, resulting in an emergency visit to the UF Shands Hospital for several hours, and a recommendation for continued care. See Exhibit 1.
7. Plaintiff Jacunksi applied and was accepted to join the LCREC. She attended an official meeting of the LCREC taking place at 6pm on August 19th, 2025, at the Leesburg Venetian Center, to take the oath of office.
8. While in attendance at the LCREC, Plaintiff Jacunksi approached the exit door to walk outside main foyer, prior the meeting starting. As she opened the door and began to walk outside, Defendant Mike Trainor, with all his force, slammed the steel door shut on her, pinning her hand and crushing it against the frame. Plaintiff Jacunksi screamed in pain and was treated by three paramedics who responded form Leesburg EMS. She was in continuous pain for many hours.
9. Defendant Mike Trainor was directed by the Chairman of the LCREC and the LCREC Board to act as a “doorman” and to “block” anyone who looked “troubling” from going out—or in—of the Leesburg Venetian Center. He was specifically instructed to “slam” the door on anyone who sought to exit or enter without his express permission.
10. Defendant Mike Trainor had a specific intent to harm plaintiff and carried the attack out with violent intent due to Plaintiff Jacunksi being identified as a “troublesome” participant. When asked why he crushed Plaintiff’s hand and injured Plaintiff, Defendant Mike Trainor gave the crowd of invitees “the middle finger” and laughed at them.
11. Defendant Mike Trainor willfully and maliciously assaulted and battered plaintiff, slamming a steel door into her hand, crushing it, and causing severe pain and injury to defendant.
12. As a result, plaintiff suffered bodily injury and resulting pain and suffering and spent several hours at UF Shands Hospital in Leesburg, FL.
13. Plaintiff’s losses are either continuing and plaintiff will suffer losses in the future.
14. Plaintiff is also entitled to and requests punitive damages in accordance with Chapter 768 of the Florida statutes because of the especially egregious behavior of defendant; Defendant Trainor had a specific intent to harm plaintiff and carried the attack out with violent intent due to his animosity towards her political viewpoints.
15. Plaintiff had actual knowledge of the wrongfulness of the conduct and a high probability that injury or damage to the claimant would result and, despite that knowledge, intentionally pursued that course of conduct, resulting in injury.
16. Plaintiff must now conduct treatment with a Chiropractor for extended care, to include, treating hand and wrist injury, particularly those related to musculoskeletal issues, nerve compression, or repetitive strain.
COUNT 1 – BATTERY
(Against Defendant MICHAEL TRAINOR)
17. Plaintiff re-alleges paragraphs 1 – 16 above.
18. Defendant MICHAEL TRAINOR committed acts intending to cause harmful or offensive contact with plaintiff or causing plaintiff to be in imminent apprehension of such a contact; and Defendant made an offensive contact with plaintiff.
COUNT 2 – RESPONDEAT SUPERIOR / VICARIOUS LIABILITY FOR BATTERY
(Against Defendant THE LAKE COUNTY REPUBLICAN PARTY)
19. Plaintiff re-alleges paragraphs 1 – 16 above.
20. For the conduct of an employee to be considered within the scope of employment, “Florida law requires that the conduct (1) must have been the kind for which the employee was employed to perform; (2) must have occurred within the time and space limits of his employment; and (3) must have been activated at least in part by a purpose to serve the employment.” Spencer v. Assurance Co. of Am., 39 F.3d 1146 (11th Cir.1994).
21. Defendant Mike Trainor was instructed by LCREC Chairman to “man” the door and to shut the door on anyone coming in or out who did not previously consent with Defendant Mike Trainor for “permission” to enter of exit.
22. Defendant Mike Trainor employed to perform to duty that caused plaintiff’s injury.
23. Defendant Mike Trainor injured plaintiff during the time and space limits of his employment.
24. Defendant Mike Trainor was activated by a purpose to serve the employment or agency and tasks signed to him by his principal, LCREC Party Chairman Taylor Yarkosky.
25. Defendant Mike Trainor served an agent of the LCREC. Where the relationship of principal-agent exists, the doctrine is referred to as “respondeat superior.” 1 Modern Tort Law: Liability and Litigation § 7:2 (2d ed.). Therefore, the terms respondeat superior and vicarious liability are often used interchangeably when a principal or employer is sought to be held liable for the acts of an agent or employee. Therefore, the LCREC is vicariously liable for Trainor’s actions.
COUNT 3 – NEGLIGENCE
(Against Defendant MICHAEL TRAINOR)
26. Plaintiff re-alleges paragraphs 1 – 16 above.
27. Defendant Trainor owed a duty to plaintiff to protect the plaintiff from a particular injury or damage by not operating the door in a way to injure plaintiff as an invitee to the building.
28. Defendant breached this duty by slamming the door shut on her.
29. Defendant’s breach was the proximate cause of injury or damage to plaintiff.
30. Plaintiff suffered damages caused by the breach.
COUNT 4 – RESPONDEAT SUPERIOR / VICARIOUS LIABILITY FOR NEGLIGENCE
(Against Defendant THE LAKE COUNTY REPUBLICAN PARTY)
31. Plaintiff re-alleges paragraphs 1 – 16 above.
32. For the conduct of an employee to be considered within the scope of employment, “Florida law requires that the conduct (1) must have been the kind for which the employee was employed to perform; (2) must have occurred within the time and space limits of his employment; and (3) must have been activated at least in part by a purpose to serve the employment.” Spencer v. Assurance Co. of Am., 39 F.3d 1146 (11th Cir.1994).
33. Defendant Mike Trainor was instructed by LCREC Chairman to “man” the door and to shut the door on anyone coming in or out who did not previously consent with Defendant Mike Trainor for “permission” to enter of exit.
34. Defendant Mike Trainor employed to perform to duty that caused plaintiff’s injury.
35 Defendant Mike Trainor injured plaintiff during the time and space limits of his employment.
36. Defendant Mike Trainor was activated by a purpose to serve the employment or agency and tasks signed to him by his principal, LCREC Party Chairman Taylor Yarkosky.
37. Defendant Mike Trainor served an agent of the LCREC. Where the relationship of principal-agent exists, the doctrine is referred to as “respondeat superior.” 1 Modern Tort Law: Liability and Litigation § 7:2 (2d ed.). Therefore, the terms respondeat superior and vicarious liability are often used interchangeably when a principal or employer is sought to be held liable for the acts of an agent or employee.
38. Therefore, the LCREC is vicariously liable for Trainor’s actions.
WHEREFORE plaintiff demands judgment for compensatory and punitive damages against defendant and a trial by jury.
DATED: 8.19.2025
Respectfully submitted.
/s/ ANTHONY F. SABATINI
FL Bar No. 1018163
[email protected]
SABATINI LAW FIRM, P.A.
T: (352)-455-2928
Attorney for Plaintiff
