Fraud on the Court by Ryan C. Rodems, Discovery, Jul-27-2010

8/6/2019 Fraud on the Court by Ryan C. Rodems, Discovery, Jul-27-2010

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IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUITIN AND FOR HILLSBOROUGH COUNTY, FLORIDAGENERAL CIVIL DIVISION

NEIL J. GILLESPIE,Plaintiff and Counter-Defendant, CASE NO.: 05-CA-7205vs.

BARKER, RODEMS & COOK, P.A., DIVISION: Ga Florida corporation; WILLIAMJ. COOK,

Defendants and Counter-Plaintiffs. JUL 27 2010___________ ......;1 CLtRK OF CIRCUIT COURTNOTICE OF FRAUD ON THE COURT BY HILLSBOROUGH COUNTY, FL

RYAN CHRISTOPHER RODEMS -DISCOVERYPlaintiff pro se Gillespie hereby reports fraud on the court by Ryan Christopher

Rodems counsel for Defendants and Counter-Plaintiffs, and in support thereof states:1. Upon infonnation and belief, Mr. Rodems submitted a letter to Judge C o o ~ dated

July 12, 2010. A copy of the letter is attached as Exhibit A.2. Mr. Rodems stated for item 1: "Mr. Gillespie did not file any response orobjection to the request for production." Gillespie objected to the deposition June 14,2010 with Plaintiffs Motion To Cancel Deposition Duces Tecum June 18,2010 And ForAn Order of Protection. (Exhibit B). GiHespie provided objections to Mr. Rodems by faxJune 21, 2010. (Exhibit C). Gillespie filed the letter with the court June 21, 2010.(Exhibit D). After the court denied Gillespie's Motion For Reconsideration he providedMr. Rodems the outstanding discovery by letter dated June 25, 2010. (Exhibit E).3. Mr. Rodems stated for item 2: "Mr. Gillespie's former counsel served unsigned,unsworn answers that were evasive or incomplete. Thus. this circumstance does not meet


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the criteria for entry of an Order compelling discovery without a hearing." This is false.Responses to Defendants' Interrogatories of September 2,2008 were provided by myformer lawyer Robert W. Bauer, October 1,2008. (Exhibit F). Mr. Bauer notified Mr.Rodems October 2,2008 that he was "attempting to comply with your discovery request."(Exhibit G). I signed the verification page and it was notarized October 2,2008. Bauersubmitted the signed and notarized verification page to the Clerk of Court October 3,2008. (Exhibit H). Mr. Bauer moved to withdrawal from the case October 13, 2008before completing discovery. Gillespie submitted the remaining response to InterrogatoryNo.2 on April 28, 2010, see Affidavit And Inventory Of Personal Property OfNeil J.Gillespie And Designated Exemptions. (Exhibit I).4. Mr. Rodems lied to the court because he has a conflict representing himself andhis independent professional judgment is materially limited by the lawyer's own interest,see Emergency Motion To Disqualify Defendants' Counsel Ryan Christopher Rodems &Barker, Rodems & Cook, PA submitted July 9,2010.

RESPECTFULLY SUBMITTED July 27,2010.

Certificate of ServiceI HEREBY CERTIFY that a copy of the foregoing was mailed July 2 ,2010 toMr. Ryan C. Rodems, Barker, Rodems & Cook, PA, 40 As ey . e, S 'te 2100,

Tampa, Florida 33602.

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COpyBARKER, RODEMS & COOKPROFESSIONAL ASSOCIATIONATTORNEYS AT LAW

CHRIS A. BARKER Telephone 813/489 . 1001400 North Ashley Drive, Suite 2100RYAN CHRISTOPHER RODEMS Facsimile 813/489 . 1008WILLIAM J. COOK Tampa, Florida 33602

July 12, 2010The Honorable Martha J. CookCircuit Court JudgeCircuit Civil, Division "G"800 E. Twiggs 8treet, Room 511Tampa, Florida 33602

Re: Neil J. Gillespie v. Barker, Rodems & Cook, P.A.,a Florida Corporation; and William J. CookCase No.: 05-CA-7205; Division "G"

Dear Judge Cook:Following the hearing of even date, I reviewed, as you requested, the circumstances surroundingthe below described motions to compel to determine if they met the criteria under AdministrativeOrder 8-2008-145, 14, which provides in pertinent part: "When a motion to compel complyingwith Florida Rule of Civil Procedure 1.380(a)(2) alleges the absence of a response or objection todiscovery and there has been no request for an extension of time to respond, the court, without ahearing, may enter an order requiring compliance with the original discovery request . . . ."My review shows as follows:

1. "Defendant's Motion for an Order compelling Plaintiff to Respond to theDefendant's Request for Production and Attend Deposition"

Mr. Gillespie did not file any response or objection to the request for production. Thus, it meetsthe criteria, and an Order compelling a response is enclosed. As for the depositions that Mr.Gillespie failed to attend, he did object. Thus, the motion to conlpel his attendance at thedeposition does 'not meet the criteria for entry of an Order compelling attendance without ahearing.When this morning's hearings began, you advised that the purpose was for case management only.After Mr. Gillespie asked to be excused due to his apparent illness, I advised that this motion tocompel was noticed for hearing today. Given that Mr. Gillespie departed before this was clarified,Defendants would prefer to reschedule the hearing to avoid any claim that Mr. Gillespie wasdenied an opportunity to be heard.

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The Honorable Martha J. CookJuly 12, 2010Page 2

2. "Defendant 's Motion for an Order Compelling Plaintiff to Respond to theDefendant's Interrogatories"

Mr. Gillespie's former counsel served unsigned, unsworn answers that were evasive or incomplete.Thus, this circumstance does not meet the criteria for entry of an Order compelling discoverywithout a hearing.We request hearing time on the following:

1. "Defendants' Motion for Proceedings Supplementary for Execution" (10 minutesrequested);

2. "Defendant's Motion for an Order compelling Plaintiff to Respond to theDefendant's Request for Production and Attend Deposition" (only on the depositionportion)(5 minutes requested);3. "Defendant's Motion for an Order Compelling Plaintiff to Respond to the

Defendant's Interrogatories" (5 minutes requested);4. "Defendant's Motion for Final Summary Judgment" (30 minutes requested); and,5. "Defendants' Motion for Examination Pursuant to Section 56.29(2), Florida

Statutes" (5 minutes requested).Courtesy copies of all nlotions are attached.We previously requested hearing dates from your judicial assistant for the summary judgmentmotion, and slle offered August 24, 2010 at 9:00 a.m., but Mr. Gillespie advised me that the hourwas too early, and he refused to agree to that date and time. Given the scarce judicial resources,we respectfully suggest that Mr. Gillespie should make arrangements to be available during allnormal business hours.

RCR/soEnclosurescc: Mr. Neil J. Gillespie (w/encl)


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IN TH E CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUITIN AND FOR HILLSBOROUGH COUNTY, FLORIDA

GENERAL CIVIL DIVISION

NEIL J. GILLESPIE,Plaintiff, CASE NO.: 05-CA-7205vs.

BARKER, RODEMS & COOK, P.A., DIVISION: Ga Florida corporation; WILLIAMJ. COOK,

Defendants._____________ ----'1PLAINTIFF'S MOTION TO CANCEL DEPOSITION DUCES TECUM

JUNE 18,2010 AND FOR AN ORDER OF PROTECTIONPlaintiff pro se, Neil J. Gillespie, moves the Court to cancel Defendants'

Deposition Duces Tecum on June 18,2010 and for an Order of Protection and states:1. Defendants counsel Ryan C. Rodems failed to coordinate the time and date

of the hearing with the Plaintiff. This is an ongoing problem with Rodems.2. Plaintiff cannot appear June 18, 2010 and has other commitments.3. Plaintiffs Motion to Stay Pending ADA Determination, filed June 14,2010

requests an Order to Stay all proceedings pending a determination of his ADAaccommodation request.

4. Mr. Rodems and associates have a history of violence and defamationagainst other participants in contentious litigation. This lawsuit is especially contentious,a former client suing his lawyer for fraud, breach of duty, etc., etc.

a. Mr. Rodems and his former law partners were named in a $5 million dollardefamation lawsuit brought by attorney Arnold Levine, Buccaneers Limited Partnership

B


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v. Alpert, Barker & Rodems, PA, US District Court, Middle District of Florida, TampaDivision, case 99-2354-CIV-T-23C. In retaliation, a Tampa Police Department reportdated June 5, 2000, case number 00-42020, alleges Mr. Alpert committed battery, FloridaStatutes 784.03, upon attorney Arnold Levine by throwing hot coffee on him. At thetime Mr. Levine was a 68 year-old senior citizen. The report states: "The victim anddefendant are both attorneys and were representing their clients in a mediation hearing.The victim alleges that the defendant began yelling, and intentionally threw the contentsof a 20 oz. cup of hot coffee which struck him in the chest staining his shirt. A request forprosecution was issued for battery." Mr. Rodems is listed as a witness on the policereport. A copy of the police report is attached as Exhibit A.

b. Another example ofMr. Rodems' bizarre behavior against participants inlitigation are his defamatory comments about Eric Bischoff, a witnesses inWrestleReunion, LLC v. Live Nation, Television Holdings, Inc., United States DistrictCourt, Middle District ofFlorida, Case No. 8:07-cv-2093-T-27, trial August 31-September10, 2009. Mr. Rodems and his client failed to prevail at trial. The comments may be foundonline at: http://www.declarationofindependents.net/doi/pages/corrente91 O.html, andinclude, " The expert report Bischoff submitted in this case bordered on illiteracy, andBischoff was not even called to testify by Clear Channel/Live Nation because Bischoffperjured himself in a deposition in late-July 2009 before running out and refusing toanswer any more questions regarding his serious problems with alcohol and sexualdeviancy at the Gold Club while the head ofWCW." and "The sad state of professionalwrestling today is directly attributable to this snake oil salesman, whose previous careerhighlights include selling meat out of the back ofa truck, before he filed bankruptcy and

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had his car repossessed. Today, after running WCW into the ground, Bischoff peddlesschlock like "Girls Gone Wild" and reality shows featuring B-listers." A copy of Rodems'comments are attached as Exhibit B.

5. Another stunt used by Mr. Rodems against participants in contentiouslitigation is a sworn affidavit used to falsely accuse his opponent ofwrongdoing for thepurpose of advantage. On March 6, 2006 Mr. Rodems made a verified pleading that falselynamed Judge Nielsen in an "exact quote" attributed to Plaintiff, putting the trial judge intothe controversy. The Tampa Police Department recently determined that the swornaffidavit submitted by Mr. Rodems to the court about an "exact quote" attributed toPlaintiff was not right and not accurate.

6. These lawyers have a history of physical violence and defamation againstparticipants in contentious litigation, and Plaintiff fears for his safety and well-being.

WHEREFORE, Plaintiff moves the Court to cancel Defendants' Deposition DucesTecum on June 18,2010 and for an Order of Protection.

CERTIFICATE OF SERVICEI HEREBY CERTIFY that a copy of the foregoing has been furnished by US mail

to Ryan Christopher Rodems, Attorney, Barker, Rodems & Cook, P.A., 400 North AshleyDrive, Suite 2100, Tampa, Florida 33602, this 14 th day of June 010.

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CITY ZIP

CROSS COMPl:A!NT ISSUED"DYES it'NO

CHECK ONE


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DOIwrestling.com - Declaration of Independents - The Number 1 Independent Pro Wrestl... Page 1 of3

DOIVIDEO.COM 'Tons of wrestling DVD's including original shoot i n t ~ ~ i e w s

Sal Corrente of WrestleReunion had a lawsuit against Clear Channel/Live Nation because they reneged on acontract with him. The case went before a jury and Mr. Corrente lost the case, which many feel was unjust.But Eric Bischoff made a statement on wrestlezone.com, which is below, that caused Sal's lawyer to send hisstatement:In my last post regarding the WrestleReunion/Live Nation lawSUit, I suggested that Bill Behrens and EricBischoff were expert witnesses for WrestleReunion. That was not the case as they were actually witnessesfor the Clear Channel/Live Nation side. I just spoke with Eric Bischoff who said he agreed to be an expertwitness after reading and taking interest in the case, however he was not called to the stand."The case wa s wrapped up quickly," Bischoff told Wrestlezone.com, "the jury didn't waste an ytime and came back with what I felt was the correct decision".Eric was happy with the outcome, to say the least. "Rob Russen an d Sal Corente give the wrestlingbusiness a ba d name," he stated, "so I'm glad justice prevailed and the bottom feeders didn't winone".Bischoff wanted to make sure that everyone knew his comments and opinions were solely his and did notreflect those of Clear Channel/Live Nation.In regards to the above statement, we have a statement from Mr. Corrente's lawyer:" I t is odd that Eric Bischoff, whose well-documented incompetence caused th e demise of WCW,should have any comment on th e outcome of th e WrestleReunion, LLC lawsuit. Th e expert reportBischoff submitted in this case bordered on illiteracy, and Bischoff was no t even called to testifyby Clear Channel/Live Nation because Bischoff perjured himself in a deposition in late-July 2009before running ou t and refusing to answer any more questions regarding his serious problemswith alcohol and sexual deviancy at th e Gold Club while the head of WCW. To even si t in theroom an d question him was one of the most distasteful things I 've ever had to do in 17 years ofpracticing law. In fact, we understand that Bischoff was afraid to even come to Tampa andtestify because he would have to answer questions under oath fo r a third t ime about hisembarrassing past.The sad state of professional wrestling today is directly attributable to this snake oi l salesman,whose previous career highlights include selling meat out of th e back of a truck, before he filedbankruptcy and had his car repossessed. Today, after running WCW into the ground,Bischoff peddles schlock like "Girls Gone Wild" an d reality shows featuring B-Iisters.Sal Corrente, on the other hand, has always been an honorable man, and he delivered on everypromise and paid every wrestler while staging the three WrestleReunlon events. Unlike thecowardly Bischoff, Mr. Corrente took the stand In this case. Although his company did notprevail, Sal Corrente proved that he was man enough to f ight to th e finish -- something Bischoffcould never understand."Sincerely,Ryan Christopher RodemsBarker, Rodems &. Cook, P.A.400 North Ashley Drive, Suite 2100Tampa, Florida 33602813/489-1001E-mail: [email protected] just wanted to give Mr. Corrente's lawyer a chance to speak his mind.Georgie [email protected] I have always had wrestlers autograph signings as a speciality for any website I worked for, I know forsure, Mr. Corrente is an honest promoter who has NEVER stiffed a wrestler working for his shows or conventions. I would have heard about it.There are many promoters who do that in this business, which is very sad.The information on this website is exclusive property of the Declaration of Independents and cannot be used elsewtJBfS without proper ink credff. All 001 purchasesare non-refundab1e. All mail (electronic or postal) sent to the 00 1 becomes property of the 001 which allows the DOf to reprint that emaif In H's entirety by doing so, ffthe email is considered newsworthy.Copyright declarationofindependents.net & dorwrestting.com. All Rights Reserved.

http://www.declarationofmdependents.netldoi/pages/corrente91 O.html 1/28/2010B


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Neil J. Gillespie8092 SW 115th LoopOcala, Florida 34481

June 21, 2010VIA FAX (813) 489-1008Mr. Ryan Christopher Rodems, Attorney at LawBarker Rodems & Cook, PA400 North Ashley Drive, Suite 2100Tampa, Florida 33602

RE: Gillespie v. Barker, Rodems & Cook, PA, et al.Case No.: 05-CA-7205, Division G

Dear Mr. Rodems:This is in response to the last paragraph ofyour letter of June 11, 2010 concerningdiscovery and Rule 1.380(a)(4). This is my good faith effort to provide the discoverywithout court action and/or response justifying not providing the discovery.As you know, much ofyour discovery to me is outstanding, some of it dating to 2006.Currently the following motions to compel your discovery are pending:

1. December 14, 2006, Plaintiffs Motion to Compel Defendants' Discovery2. February 1, 2007, Plaintiffs Second Motion to Compel Defendants' Discovery3. March 30, 2010, Plaintiffs Third Motion to Compel Discovery

Mr. Rodems, when can I expect to receive your outstanding discovery?Your June 11, 2010 letter states "I made sincere efforts to coordinate the July 12, 2010hearing date, but you have not reciprocated." This is a false statement. You did not makesincere efforts to coordinate the July 12, 2010 hearing date with me. Instead you placedcalls to a number that you knew or should have known was no longer valid or associatedwith this litigation. Upon information and belief, the number you called, (352) 502-8409was associated years ago with my cell phone and disconnected and reassigned in 2007.See Notice OfFra.ud On The Court By Ryan Christopher Rodems, filed June 17, 2010.

C


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Mr. Ryan Christopher Rodems, Attorney at Law Page - 2Barker Rodems & Cook, PA June 21, 2010

In response to the motions you improperly set for June 9, 2010, and the hearing ofwhichJudge Cook canceled, the motions are all related to collection of the final judgment of$11,550. A Motion For Reconsideration of the final judgment and other orders andrulings made by disqualified Judge Barton was filed under Fla.R.Jud.Admin., Ru1e2.330(h), Prior Ru1ings. Prior factual or legal rulings by a disqualified judge may bereconsidered and vacated or amended by a successor judge based upon a motion forreconsideration. Schlesinger v. Chemical Bank, 707 So.2d 868, Fla.App. 4 Dist.,1998.held that final judgment entered by a judge who was later disqualified is, like any otherorder, subject to being reconsidered by successor judge.Because a motion for reconsideration has been filed, and considering the holding ofSchlesinger v. Chemical Bank, it is reasonable to assume that the final judgment of$11,550 will be voided because of the extreme injustice it represents. Therefore yourmotions related to the collection of the final judgment of$11,550 are now misplaced.If the final judgment is voided, your motions will be moot. Therefore I am justified in notproviding the discovery and I am justified in not attending the deposition.Again, when can I expect to receive your outstanding discovery Mr. Rodems?


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FaxFrom: Neil J. Gillespie8092 SW 11Sth LoopOcala, FL 34481

To: Mr. Ryan C. Rodems, Barker, Rodems & Cook, PAFax: (813) 489-1008Date: June 21 , 2010Pages: three (3), including this pageRe: see accompanying letter with Rule 1.380(a)(4) response

NOTE: This fax and the accompanying infonnation is privileged and confidential and is intended only for use bythe above addressee. Ifyou are not the intended recipient, you are hereby notified that any use, dissemination orcopying of this fax and the accompanying communications is strictly prolnbited I fyou have received thiscommunication in error, please immediately notify the sender by telephone, collect i fnecessary, and return theoriginal message to me at the above address via u.s. mail. Thank you for your cooperation.All calls on home office business telephone extension (352) 854-7807 are recorded for quality assurance purposespursuant to the business use exemption ofFlorida Statutes chapter 934, section 934.02(4XaXl) and the holdingofRoyal Health Care Servs., Inc. v. Jefferson-Pilot Lift Ins. Co., 924 F.2d 215 (11th Cir. 1991).


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IN THE CIRCUIT COURT OF THE TmRTEENTH JUDICIAL CIRCUITIN AND FOR HILLSBOROUGH COUNTY, FLORIDAGENERAL CIVIL DIVISION

NEIL J. GILLESPIE,Plaintiff, CASE NO.: 05-CA-7205

vs.BARKER, RODEMS & COOK, P.A., DIVISION: Ga Florida corporation; WILLIAMJ. COOK,

Defendants./

NOTICE OF FILING LETTERS, DISCOVERY

Plaintiff and Counter-Defendant Neil J. Gillespie pro se hereby files copies ofletters pertaining to discovery and Rule 1.380(a)(4), his good faith effort to provide thediscovery without court action and/or response justifying not providing the discovery.

1. Letter and enclosures of Ryan C. Rodems, Barker, Rodems & Cook, PA to NeilJ. Gillespie dated June 11, 2010;

2. Letter ofNeil J. Gillespie to Mr. Rodems dated June 21, 2010.RESPECTFULLY SUBMITTED June 21, 2010.

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Certificate ofServiceI HEREBY CERTIFY that a true and correct copy of the foregoing has been

furnished by mail June 21, 2010 to the office ofRyan Christopher Rodems, attorney forthe Defendants and Counter-Plaintiffs, at Barker, Rodems & Cook, PA, 400 North AshleyDrive, Suite 2100, Tampa, Florida 33602.

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BARKER, RODEMS & COOKPROFESSIONAL ASSOCIATIONATIORNEYS AT LAW

CHRIS A. BARKER Telephone 813/489 . 1001400 North Ashley Drive, Suite 2100RYAN CHRISTOPHER RODEMS Facsimile 813/489 . 1008WILLIAM J. COOK Tampa, Florida 33602

June 11, 2010

Mr. Neil J. Gillespie8092 SW IISth LoopOcala, Florida- 34481 ro COpy

Re: Gillespie v. Barker, Rodems & Cook, P.A.,Case No.: 05-CA-7205; Division "G"Dear Mr. Gillespie:I have and thank you for your letter of even date, transmitted by facsimile. Regardless of your accusations that I didnot call you, I made multiple telephone calls, some in the presence ofmy start: to coordinate hearings on June 9 andJuly 12, 2010, and I dialed the same telephone number that I have successfully used to call you in the past.What is most troubling about your letter is that you claim a hearing transcript shows that I am prohibited from callingyou, but you did not include the entirety of the transcript excerpt. Here is the pertinent language you omitted:

THE COURT: And as my dear father always says, discretion being the better part of valor, I would requestthat you not engage in any telephonic communication with Mr. Gillespie between now and the next hearing.MR. RODEMS: I will not, Your Honor. No phone messages, no direct calls. I'll conduct all of mycommunications with Mr. Gillespie in writing.

Your omission of the entirety of the discussion creates a misperception; Judge Isom's request limited the request to"between now and the next hearing."I made sincere efforts to coordinate the July 12,2010 hearing date, but you have not reciprocated. Although I will notcancel it based on your claim to not be available, I will renew my offer made regarding the motions to compel whenthey were scheduled for June 9: If you agree to provide the discovery within ten days and attend the deposition, then Iwill cancel the hearing on the motions to compel (but not the Case Management Conference). The incentive for youto consider that may be the prospect of being held liable for my clients' attorneys' fees and costs, under Rule1.380(a)(4).I look forward to hearing from you.

RCRlsocc: Honorable Martha J. CookEnclosure


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1 proceed with your lawsuit. You of course can take a2 voluntary dismissal i f you so choose. However, they3 f i led a counterclaim. So even i f you take a voluntary4 dismissal tha t doesn ' t dismiss the counterclaim.5 MR. GILLESPIE: Uh-huh.6 THE COURT: But you know, again, because o f your7 express desire to f i le a motion to disqual i fy me, we're8 going to terminate today's hearing to give you an9 opportunity to do 50 . COpy0 MR. GILLESPIE: Thank you, Judge.

11 THE COURT: All right. Thank you, s i r . 12 MR. RODEMS: Your Honor, before we13 THE COURT: I think I will hang on to a l l of th i s 14 s tu f f j u s t in case we need them for any o ther hearings.15 MR. RODEMS: Your Honor, before we c lose the16 record, am I s t i l l to prepare the orders based on your17 rulings today and to submit them to you?18 THE COURT: Please do.19 MR. RODEMS: Yes, ma'am. I will of course send

"20 them to Mr. Gil lespie in advance of sending them to21 Your Honor.22 THE COURT: And as my dear fat"her always says,23 discre t ion being the bet ter par t of valor, I would24 request tha t you not engage in any te lephonic

communication with Mr. Gillespie between now and the5

Berryhi l l & Associates, Inc.


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next hearing.MR. RODEMS: I will not, Your Honor. No phone

messages, no direc t cal l s . I ' l l conduct a l l of mycommunications with Mr. Gillespie in wri t ing.

THE COURT: I th ink that would be advisable .That way we don ' t have to be concerned with whether ornot the re ' s any other improper statements or contact.

MR. GILLESPIE: Thank you, Judge. THE COURT: Okay. Thank you, s i r . (Thereupon, the hearing concluded.)

o COpy

Berryhill & Associates, Inc .


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Neil J. Gillespie8092 SW IISth LoopOcala, Florida 34481

June 21, 2010VIA FAX (813) 489-1008Mr. Ryan Christopher Rodems, Attorney at LawBarker Rodems & Cook, PA400 North Ashley Drive, Suite 2100T a m ~ Florida 33602 ro COpyRE: Gillespie v. Barker, Rodems & Cook, PA, et ale

Case No.: 05-CA-7205, Division GDear Mr. Rodems:This is in response to the last paragraph ofyour letterof June 11, 2010 concerningdiscovery and Rule 1.380(a)(4). This is my good faith effort to provide the discoverywithout court action and/or response justifying not providing the discovery.As you know, much ofyour discovery to me is outstanding, some of it dating to 2006.Currently the following motions to compel your discovery are pending:

1. December 14,2006, Plaintiff's Motion to Compel Defendants' Discovery2. February 1, 2007, Plaintiff's Second Motion to Compel Defendants' Discovery3. March 30,2010, Plaintiff's Third Motion to Compel Discovery

Mr. Rodems, when can I expect to receive your outstanding discovery?Your June 11, 2010 letter states "I made sincere efforts to coordinate the July 12, 2010hearing date, but you have not reciprocated." This is a false statement. You did not makesincere efforts to coordinate the July 12, 2010 hearing date with me. Instead you placedcalls to a number that you knew or should have known was no longer valid or associatedwith this litigation. Upon information and belief, the number you called, (352) 502-8409was associated years ago with my cell phone and disconnected and reassigned in 2007.See Notice OfFraud On The Court By Ryan Christopher Rodems, filed June 17, 2010.


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In response to the motions you improperly set for June 9, 2010, and the hearing ofwhichJudge Cook canceled, the motions are all related to collectionof the final judgment of$11,550. A Motion For Reconsideration of the final judgment and other orders andrulings made by disqualified Judge Barton was filed under Fla.R.Jud.Admin., Rule2.33O(h), Prior Rulings. Prior factual or legal rulings by a disqualified judge may bereconsidered and vacated or amended by a successor judge based upon a motion forreconsideration. Schlesinger v. Chemical Bank, 707 So.2d 868, Fla.App. 4 Dist.,1998.held that final judgment entered by ajudge who was later disqualified is, like any otherorder, subject to being reconsidered by successor judge.Because a motion for reconsideration has been filed, and considering the holding ofSchlesinger v. Chemical Bank, it is reasonable to assume that the final judgment of$11,550 will be voided because of the extreme injustice it represents. Therefore yourmotions related to the collection of the fmaljudgment of$II,550 are now misplaced.If the fmal judgment is voided, your motions will be moot. Therefore I am justified in notproviding the discovery and I am justified in not attending the deposition.Again, when can I expect to receive your outstanding discoveryMr. Rodems?

ro (opy?4. . opie


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Neil J. Gillespie8092 SW 115 th LoopOcala, Florida 34481

June 25,2010Mr. Ryan Christopher Rodems, Attorney at LawBarker Rodems & Cook, PA400 North Ashley Drive, Suite 2100Tampa, Florida 33602

RE: Gillespie v. Barker, Rodems & Cook, PA, et al.Case No.: 05-CA-7205, Division G

Dear Mr. Rodems:This is a follow-up to my June 21,2010 fax good faith effort to provide the discoverywithout court action and/or response justifying not providing the discovery pursuant toRule 1.380(a)(4).I received Judge Cook's Order Denying Motion For Reconsideration of June 22, 2010yesterday, June 24,2010. Since I am no longer justified in not providing the discovery,please find enclosed the following:Exhibit 1. Responses to Defendants' Interrogatories ofSeptember 2, 2008Exhibit 2. Responses to Defendants' Request for Production submitted Sept. 2,2008Exhibit 3. Responses to Defendants' Request for Production submitted October 13, 2009Note: this request for production was made in violation of Judge Barton's Order ofOctober 9, 2009: IT IS FURTHER ORDERED that the above action be shall be stayedfor 60 Days to allow the Plaintiff to find replacement counsel. (relevant portion).

Exhibit 4. Responses to Defendants' Request for Production submitted June 1,2010Exhibit 5. Responses to Defendants' Motion for Examination Pursuant to Section56.29(2), Florida Statutes, submitted June 1,2010.As you know, much of your discovery to me is outstanding, some of it dating to 2006.Currently the following motions to compel your discovery are pending:

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1. December 14,2006, Plaintiffs Motion to Compel Defendants' Discovery2. February 1,2007, Plaintiffs Second Motion to Compel Defendants' Discovery3. March 30, 2010, Plainti ffs Third Motion to Compel Discovery

A letter from you dated December 19,2006 falsely states "documents have already beenproduced" but I have not received any documents from you.Mr. Rodems, when can I expect to receive your outstanding discovery?

Enclosures


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Responses to Defendants Interrogatories of September 2, 2008 were provided by my former

lawyer Robert W. Bauer, October 1, 2008, see attached.

The verification page was signed and notarized by me October 2, 2008. Mr. Bauer submitted the

signed and notarized verification page to the Clerk of Court October 3, 2008.

New information.

Interrogatory No. 1. Mr. Bauer previously provided bank records. There are no other records

available to provide any additional information that would allow the Plaintiff to answer this

question. On November 16, 2009 I requested my client file from Mr. Bauer. He responded by

letter November 23, 2009 that he was exercising a charging lien and refused to provide the file.

The matter is currently subject to regulatory process.

In response to Mr. Rodems speculation contained in Defendants Motion For An Order

Compelling Plaintiff To Respond To The Defendants Interrogatories that Defendant in good

faith believes Plaintiff uses more than one bank account, has debit cards or credit cards, andoperates a business or makes purchases using PayPal or other similar payment services:

Plaintiff has no bank account.

Plaintiff has no credit card.

Plaintiff uses throw-away debit cards that have no records.

Plaintiff does not operate a business or make purchases for the business using PayPal or other

similar payment services.

Interrogatory No. 2. Plaintiff provided the answer by way of his Affidavit and Inventory of

Personal Property of Neil J. Gillespie and Designated Exemptions submitted to the court April

28, 2010, see copy attached.

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1

Responses to Defendants Request for Production submitted Sept. 2, 2008

1. Objection, relevance, annoyance, embarrassment, or oppression. The equitable interest

of a defendant as beneficiary of a trust is not subject to garnishment. The Gillespie

Family Living Trust has a spendthrift provision. The creditors of the trustee are not

entitled to an attachment to subject trust property held by the trustee to the payment ofthe trustee's debts. Tillman v. Taylor, 99 Fla. 1326, 128 So. 846, Fla. 1930. The remedy is

not available even if the debt is chargeable to the trust itself. Johnston v. Smith, 76 Fla.

474, 80 So. 184, Fla. 1918. The equitable interest of a defendant as beneficiary of a trust

is not subject to garnishment, at least in the absence of express statutory authorization.

McLeod v. Cooper, 88 F.2d 194, C.A.5 1937.

2. There is no list of documents responsive to the request and the rules do not require the

creation of a record when the record does not exist.



4. None.

5. None.

6. Already provided. If you want them again, please advise.


8. None.


10. The quit claim deed was provided. If you want it again, please advise.

11. There is no list of documents responsive to the request and the rules do not require

the creation of a record when the record does not exist. Otherwise none, other than what

is owned to Barker, Rodems & Cook.

12. None

13. None.

14. None.

15. None.

16. None.

2


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2

17. None.

18. None. I opted out of receiving paper documents, see insurer for whatever you want.

19. None. I do not own a home. I do not have renters insurance.

20. None.

21. None that I can recall.

22. None.

23. None.

24. None.

25. None.

26. See Affidavit and Inventory of Personal Property of Neil J. Gillespie, Designated

Exemptions, and Motion for Dissolution of Writ of Garnishment, filed April 28, 2010,

and related documents.

27. IRS EIN from 2002, already provided, if you want it again, please advise.

28. Already provided, if you want it again, please advise.

29. None.

30. None.

31. None.

32. None.

33. None.

34. None.

35. None.

36. None.

37. All contracts undue which you currently have any legal rights. Request makes no

sense.

38. Objection, vague, what is a trust instrument? Otherwise see #1


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3

39. None.

40. Objection vague. Otherwise none.

41. Repeated request, see the response to #26


43. Objection, vague. Otherwise none.


the creation of a record when the record does not exist.



46. I do not have a copy of my credit report.


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1

Responses to Defendants Request for Production submitted October 13, 2009













4. None.

5. None.



8. None.






12. None

13. None.

14. None.

15. None.

16. None.

3


31/51

2

17. None.



20. None.


22. None.

23. None.

24. None.

25. None.






29. None.

30. None.

31. None.

32. None.

33. None.

34. None.

35. None.

36. None.

37. All contracts undue which you currently have any legal rights. Objection, request

makes no sense.



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3

39. None.

40. Objection vague. Otherwise none.










33/51

1

Responses to Defendants Deposition Duces Tecum submitted June 1, 2010













4. None.

5. All contracts undue which Gillespie currently have any legal rights. Objection,

request makes no sense.


7. None.

8. Objection, vague. Otherwise none.







12. There is no list of documents responsive to the request and the rules do not requirethe creation of a record when the record does not exist.


14. None.

15. None.

4


34/51

2



18. None.






22. None.

23. None.

24. None.

25. None.

26. None.

27. None.



30. None.


32. None.

33. None.

34. None.

35. None.

36. Repeated question, see response to #9.

37. Repeated question, see response to #10.


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3


39. None.

40. None.

41. None.

42. None.

43. None.

44. None.

45. None.


36/51

Responses to Defendants Motion for Examination Pursuant to Section 56.29(2), Florida

Statutes, submitted June 1, 2010

4a. Objection, relevance, annoyance, embarrassment, or oppression. The equitable interest of a

defendant as beneficiary of a trust is not subject to garnishment. The Gillespie Family Living

Trust has a spendthrift provision. The creditors of the trustee are not entitled to an attachment tosubject trust property held by the trustee to the payment of the trustee's debts. Tillman v. Taylor,

99 Fla. 1326, 128 So. 846, Fla. 1930. The remedy is not available even if the debt is chargeable

to the trust itself. Johnston v. Smith, 76 Fla. 474, 80 So. 184, Fla. 1918. The equitable interest of

a defendant as beneficiary of a trust is not subject to garnishment, at least in the absence of

express statutory authorization. McLeod v. Cooper, 88 F.2d 194, C.A.5 1937.

b. There is no list of documents responsive to the request and the rules do not require the


c. There is no list of documents responsive to the request and the rules do not require the creation

of a record when the record does not exist.

d. None.

e. All contracts undue which you currently have any legal rights. Request makes no sense.

f. Objection, see #1

g. None.

h. Objection vague. Otherwise none.

i. See Affidavit and Inventory of Personal Property of Neil J. Gillespie, Designated Exemptions,

and Motion for Dissolution of Writ of Garnishment, filed April 28, 2010, and related documents.

j. IRS EIN from 2002, already provided, if you want it again, please advise.

k. There is no list of documents responsive to the request and the rules do not require the


l. There is no list of documents responsive to the request and the rules do not require the creation

of a record when the record does not exist.

m. I do not have a copy of my credit report.

n. None.

o. None.

p. Already provided. If you want again, please advise.

5


37/51

q. Already provided. If you want again, please advise.

r. None

s. Already provided. If you want again, please advise.

t. The quit claim deed was provided. If you want again, please advise.

u. There is no list of documents responsive to the request and the rules do not require the

creation of a record when the record does not exist. Otherwise none, other than what is owned to

Barker, Rodems & Cook.

v. None.

w. None.

x. None.

y. None.

z. None.

aa. None.

bb. None. I opted out of receiving paper documents, see insurer for whatever you want.

cc. None. I do not own a home. I do not have renters insurance.

dd. None.

ee. None that I can recall.

ff. None.

gg. None.

hh, None.

ii. None.

jj. See Affidavit and Inventory of Personal Property of Neil J. Gillespie, Designated Exemptions,

and Motion for Dissolution of Writ of Garnishment, filed April 28, 2010, and related documents.

kk. IRS EIN from 2002, already provided, if you want again, please advise.


38/51

ll. Already provided, if you want again, please advise.

mm. None.

nn. None.

oo. None.

pp. None.

qq. None.

rr. None.

ss. None.


39/51

The Law Offices ofRobert W . Bauer, P .A.2815 NW 13th Street, Suite 200, Gainesville, FL 32609

www.bauerlegal.comRobert W Bauer, Esq.Tanya M Uhi, Esq.

Phone: (352)375.5960Fax: (352)337.2518

October 1, 2008

Hillsborough County Clerk ofCourt FYI OnlyPO Box 989Tampa, Florida 33601-0989

No A c t ~ o n Re: Case .No.: 05-CA-007205 NecessaryDear C I ~ r k of the Court:Enclosed for filing in connection with the above referenced case please find the following:

Plaintiffs Notice of Service ofResponses to Interrogatories to PlaintiffNeilJ. Gillespie.If you have any questions, then please contact me at 352-375-5960.Thank you for your assistance with this matter.

s t m e ~ ~ / y Meghan E. GodbyRWB/megMr. Neil Gillespie8092 SW 115th LoopOcala, Florida 34481Ryan C. Rodems Esq.400 N Ashley DrSte 2100Tampa, Florida 33602

F


40/51

- - - - - - - - - - -

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUITIN AND FOR HILLSBOROUGH COUNTY, FLORIDA

GENERAL CIVIL DIVISION

NEIL J. GILLESPIE, Case No.: 2005-CA-7205Division: CPlaintiff,

vs.BARKER, RODEMS, & COOK, P .A.,a Florida Corporation, and WILLIAM J. COOK,an individual,

Defendants.- - - - - - ~ - - - - - - - - - _ / PLAINTIFF'S NOTICE OF SERVICE OF RESPONSES TO INTERROGATORIES TO

PLAINTIFF NEIL J. GILLESPIEThe Plaintiff, NEIL J. GILLESPIE, through their undersigned attorney, hereby gives

notice of serving the PLAINTIFF'S RESPONSES TO INTERROGATORIES TO PLAINTIFFNEIL J. GILLESPIE without verification page, verification page to follow.

CERTIFICATE OF SERVICETHE UNDERSIGNED Robert W. Bauer, Esq., attorney for the Defendants hereby certifies that

a true and correct copy of the foregoing was furnished to each person listed below by US Mail onOCT 01 2008

Ryan C. Rodems, Esq.400 North Ashley Drive, 2100Tampa, FL 33602 T.he L ~ .. "' . .. of Robert W. Bauer...w ." ~ By: .

Robert W. Bauer, Esq.Attorney for DefendantsFlorida Bar No. 0011058Tanya M. Uhl Esq.Florida Bar No. 00529242815 NW 13 th Street, Suite 200EGainesville, FloridaTelephone: (352) 375-5960Fax: (352) 337-2518


41/51

INTERROGATORIES1. For each such payment since January 1, 2005, identify the name and address of

each person who gave you cash or other payments for any reason (including butnot limited to payments made by cash, credit card, PayPal, check, in-kind) andstate why the person gave you cash or any other payments.See Attached.

Gillespie v. Barker, Rodems & Cook, P.A, Case No.:05-CA-7205, Div. F.Page 2 of 7


42/51

2. Identify with specificity each and every item of tangible personal property youown whether individually or jointly, including but not limited to: motor vehicles,articles of clothing, furniture (e.g., bed, dresser, table, desk), guns, knives,exercise equipment (e.g., bicycles, treadmills), electronic device (e.g., computer,IPOD, television, stereo, calculator, printer, camera, videocamera, videogameconsole), jewelry, artwork, appliances (e.g., washer, dryer, oven, microwave,dishwasher), equipment, tools, animals (including domestic and farm), stocks,bonds, savings, retirement accounts (e.g., 401K, IRA, annuities), lawn or gardenequipment, cleaning equipment, linens, items made of cloth, items made ofplastic, items made of iron, copper, bronze, silver, platinum, gold, clay, ceramic ormarble. For each such item, identify the date obtained, the market value, theserial number (i f the item has one).

See Attached.



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3. For each transaction since January 1,2005, identify with specificity each item oftangible personal property you owned, individually or jointly, but have sold,donated, gifted or otherwise disposed of own whether individually or jointly,including but not limited to: motor vehicles, articles of clothing, furniture (e.g.,bed, dresser, table, desk), guns, knives, exercise equipment (e.g., bicycles,treadmills), electronic device (e.g., computer, IPOD, television, stereo, calculator,printer, camera, videocamera, videogame console), jewelry, artwork, appliances(e.g., washer, dryer, oven, microwave, dishwasher), equipment, tools, animals(including domestic and fann), stocks, bonds, savings, retirement accounts (e.g.,401K, IRA, annuities), lawn or garden equipment, cleaning equipment, linens,items made of cloth, items made of plastic, items made of iron, copper, bronze,silver, platinum, gold, clay, ceramic or marble. For each such item, identify thedate sold, donated, gifted or otherwise disposed of, the name of the person orentity the item was so given, the market value, the serial number (if the item hasone).

See Attached.



44/51

4. Do you own, jointly or individually, any real property? Do you have any interestas a beneficiary, trustee or other legal status, in any real property or trust? If so,identify with specificity the real property owned or the interest as a beneficiary,trustee in any real property or trust.See Attached.



45/51

RESPONSES TO INTERROGATORIES TO NEIL GILLESPIE

1. Please see bank records that have been previously provided. There are no otherrecords available to provide any additional information that would allow the Plaintiff to answerthis question.

2. The Plaintiffis still compiling a list of his personal property at this time. ThePlaintiffrequests an additional fifteen (15) days to complete this list.

3. No such records exist at this tinle that \vould enable the Plaintiff to provide therequested infonnation.

4. The Plainti tf does not own allY real property in any capacity and does not haveany interests in real property or trust at this tinle.


46/51

The LawOffices o f

Robert W . Bauer, P.A.2815 NW 13th Street, Suite 200, Gainesville, FL 32609

www.bauerlegal.com

Robert W Bauer, Esq.Tanya M Uhi, Esq.

Phone:Fax:

(352)375.5960(352)337.2518

October 2, 2008Ryan C. Rodems Esq.400 N Ashley Dr FYI Onlyte 2100Tanlpa, Florida 33602OU f client: Neil Gillespie

Dear Sir:We are still attempting to comply with your discovery request. Please allow an additional 15days for my client to gather all the documents requested. I will further the production alongwith the requested inventory when it is completed. Thank you in advance for your cooperationin this matter.

Sincerely,

; n ~ ~ Bauer, Esq.Mr. Neil Gillespie8092 SW 115th LoopOcala, Florida 34481

G


47/51

The Law Offices o fRobert W. Bauer, P.A.2815 NW 13th Street, Suite 200, Gainesville, FL 32609

www.bauerlegal.comRobert W Bauer, Esq.Tanya M Uhl, Esq.

Phone: (352)375.5960Fax: (352)337.2518

October 3,2008 FYI Onlyo ActionHillsborough County Clerk of Court NecessaryPO Box 989Tampa, Florida 33601-0989Re: Gillespie v. Barker, Rodems, & Cook, P.A. et al / 2005-CA-007205Dear Clerk of the Court:Enclosed for filing in connection with the above referenced case please find the following:

PLAINTIFF'S NOTICE OF SERVICE OF VERIFICATION PAGE FOR RESPONSESTO INTERROGATORIES TO PLAINTIFF NEIL J. GILLESPIEIf you have any questions, then please contact me at 352-375-5960.Thank you for your assistance with this matter.

Sincerely,i 't. J \ '. I ' 0 " - r- ..,11, :,'l.'/ t )1' i: 1 II".'--J i /7 '.0' ' U ~ . ,oJ1/ . :. . . . . . . .",I ~ /. .'/0.""Meghan E. Godby

Mr. Neil Gillespie8092 SW I I5th LoopOcala, Florida 34481Ryan C. Rodems Esq.400 N Ashley DrSte 2100Tampa, Florida 33602

H


48/51

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUITIN AND FOR HILLSBOROUGH COUNTY, FLORIDA

Case No.: 2005-CA-007205Division: .o:::C' _NEIL 1. GILLESPIE,

Plaintiff,vs.BAKER, RODEMS, & COOK, a FloridaCorporation and WILLIAM 1. COOK, an individual,

Defendants.----------------_/

PLAINTIFF'S NOTICE OF SERVICE OF VERIFICATION PAGE FOR RESPONSESTO INTERROGATORIES TO PLAINTIFF NEIL J. GILLESPIEThe Plaintiff, NEIL 1. GILLESPIE, through his undersigned attorney, hereby gives notice

of serving the PLAINTIFF'S NOTICE OF SERVICE OF VERIFICATION PAGE FORRESPONSES TO INTERROGATORIES TO PLAINTIFF NEIL J. GILLESPIE. On October 1,2008, the Plaintiff served the PLAINTIFF'S RESPONSES TO INTERROGATORIES TO NEIL1. GILLESPIE without the verification page, as the ver ification page was to follow.

CERTIFICATE OF SERVICETHE UNDERSIGNED Robert W. Bauer, Esq., attorney for the Plaintiff, hereby certifies

that a true and correct copy of the foregoing was furnished to each person listed below by US Mailon OCT 0 3 2008 .Ryan C. Rodems, Esq.400 North Ashley Drive, Suite 2100Tampa, FL 33602 The ~ S J . w - B f j i c e of Robert W. Bauer, P.A.

.--: d ' : ~ ' "By:!/ .' /Z/V. Zc~ ~ a u e r , E s q Attorney for PlaintiffFlorida Bar No. 0011058Tanya M. Uhl, Esq.Florida Bar No. 00529242815 NW 13th Street, Suite 200EGainesville, FL 32609Telephone: (352) 375-5960Fax: (352) 337-2518


49/51

BY:.7fwperSTATE OF FLORIDACOUNTY OF _ . . . ; . l _ \ l \ _ c _ ~ , _ r _ , 'v_"j_"_

/ ) O BEFORE ME, the undersigned authority, this oZ day of etah y> , 200 personally appeared Aj ~ " \ 3. G.It e. sf ' t::. , who deposes and says that the foregoinganswers to this Interrogatory are true and correct. .JJ c,', l:::r; Gj I' e ~ I 'e is eitherpersonally known to me or produced -F'L ~ . " ; . I e r:S \ L,:::' as identification.

" " ~ ~ " ' : ~ ~ ' " DAVID S, liNDAHL: ' ~ ~ ' . f ~ : ; i \ Notary Public State of Florida~ (: r!ct).J:). ~ M Commission Expires Jan 2;), 2010' ; . . J . > d : : ~ ' ~ , o \ ' ~ ' ' : Commission II DO 511509

~ I I ~ / " ; , : \ \ ~ \ " ' " Bonded Bv Nation.:=tl Notary Assn.~ . F ~ : : i ~ : , : : , , - J . ~ " t ; ....,.:i1;."""" c,.:",:-ot,." , ' : I f ' ::\,..> ~ ' . . J . . ' ~ i ' \ ' t ! - " 4 . / , ~ ~ "

Print name -b C\. '" J.e! ..:5, L, h C ) ~ 1.-\Notary Public, State at Large(commission number and expirationdate)



50/51

AFFIDAVIT AND INVENTORY OF PERSONAL PROPERTY OF NEIL J. GILLESPIEAND DESIGNATED EXEMPTIONSBefore me, the undersigned, an officer duly authorized to administer oaths, personallyappeared NEIL J. GILLESPIE, who being fITSt duly sworn, deposes and says:

1. I am a bona fide resident ofMarion County, Florida. I am over the age of 18 years,am competent to make this affidavit.2. I filed a voluntary bankruptcy petition, Chapter 7 case 02-14021-8B7, US BankruptcyCourt. Middle District ofFlorida. The case was discharged March 5, 2003. The casewas terminated December 30, 2003.3. I was homeless for the period approximately September 2002 through February 2005.4. In February 2005 I moved to 8092 SW 115th Loop, Ocala, Florida 34481, MarionCounty, to care for my elderly mother, an unremarried widow.5. The premises at 8092 SW 115th Loop, Ocala, Florida 34481, Marion County isowned by The Gillespie Family Living Trust. The contents are owned by the trust.6. The following inventory contains a true and correct schedule of all personal propertyowned by me in the state ofFlorida, including its fair market value:

Clothing and personal effects, $348Used laptop computer, $150Proceeds from the Reuter V. Check 'n Go Settlement Fund, $394.32Social Security Disability benefits of $22,049 a year (2009)1990 Dodge Grand Caravan, serial #IB4FK54R6LX309555, $300.00

7. According to F.S. 222.061(1), affiant elects to apply the following exemptions:(a) Debtor's interest in personal property, not to exceed $4,000, pursuant tosection 222.25(4), Florida Statutes:

Clothing and personal effects, $348Used laptop computer $150Proceeds from the Reuter V. Check 'n Go Settlement Fund, $394.32Total: 892.32

(b) 1990 Dodge Grand Caravan pursuant to section 222.25(1), Florida Statutes, adebtor' s interest, not to exceed $1,000 in value, in a single motor vehicle.Total: $300.00

I


51/51

(c ) Social Security Disability benefits pursuant to section 222.18 Florida Statutes.SWORN to this day ofApril, 2010.

STATE OF FLORIDACOUNTY OF MARION

BEFORE ME, the undersigned authority authorized to take oaths andacknowledgments in the State of Florida, personally appeared NEIL J. GILLESPIE,known to me, who, after having first been duly sworn, deposes and says that the abovematters contained in this document are true and correct to the best ofher knowledge andbelief.WITNESS my hand and official seal this 8 day ofApril, 2010.

. ~ ~ ~ ~ - ._-' - - - - ~

CINDY L. BORDIEN..BAUMBAR ERNotary Public, State of F l o r i - - - - ~ My Comm. Expires Aug. 25, 2011

Now 00690208CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the foregoing has been furnished by mail toRyan Christopher Rodems, Attorney, Barker, Rodems & Cook, P.A., 400 North AshleyDrive, Suite 2100, Tampa, Florida 33602, this d r day ofApril, 2010.

Fraud on the Court by Ryan C. Rodems, Discovery, Jul-27-2010

Documents