Tax boss says dismiss suit as too long
Is 93pp complaint ‘short and plain statement’ against Eye of Sauron?
CHATTANOOGA, Tenn., Friday, April 4, 2025 — Tennessee’s commissioner of revenue says a lawsuit alleging a mass fraud by his department should be booted as too long.
In a filing in Davidson County Chancery Court, Cmsr. David Gerregano says the 93-page complaint by Eagle Radio Network reporter David Tulis violates a court rule requiring “a short and plain statement of complaint.”
The suit has an abstract, a jurisdiction statement, a list of the parties, a fact background section, a summary of the controversy section, a parties list, a factual background section, an introduction, an analysis of controversy, an argument, a summary of abrogated provisions and a conclusion, Gerregano says.
Amended complaint State ex rel Tulis
Gerregano criticizes Tulis for 30 paragraphs describing relief demanded. Tulis details how the “Eye of Sauron” program — the EIVS electronic insurance verification system — should be reformed to comply with the Tennessee financial responsibility law of 1977.
“This length objection is laughable,” Tulis says. “Our tax chief believes my riveting analysis of a major fraud involving two departments creating 40,800 wrongful criminal convictions a year is ‘merely a conglomeration of facts, legal arguments, conjecture, grandiloquent expressions, rhetorical questions, verbiage, impertinence, redundancy, immateriality, scandalous matter, innuendos, character assassination,’ and the like,” he says, quoting a state filing.
“Let’s ignore the ruin this capricious, illegal program imposes on the working poor, left standing on the side of the road when cops order their cars towed for no insurance.”
Gerregano says the case is not ripe for litigation as Tulis is fighting two tag revocation cases in agency. Tulis says the case also targeting safety commissioner Jeff Long is not directly connected with administrative proceedings and that all hearings under financial responsibility have to be heard in the department of safety.
“All hearings in revenue under financial responsibility are void as a matter of law. Being denied a lawful venue for appeal is a violation of due process.” Tulis has offered to amend the complaint under the court’s direction.

David runs a personal nonprofit fighting and mercy ministry. He thanks you for checks sent directly to c/o 10520 Brickhill Lane, Soddy-Daisy, TN 37379. Also at GiveSendGo.