--------------

IN THE CIRCUIT COURT OF THE TIDRTEENTH JUDICIAL

CIRCUIT IN AND FOR IDLLSBOROUGH COUNTY, FLORIDA
GENERAL CIVIL DIVISION
NEIL J. GILLESPIE,
Plaintiff, CASE NO.: 05CA7205
vs.
BARKER, RODEMS & COOK, P.A., DNISION: C
a Florida corporation, and
WILLIAM J. COOK,
Defendants.
/
PLAINTIFF'S MOTION TO CONSIDER PRIOR
ADA ACCOMMODATION REQUESTS
Plaintiff moves the Court to consider his prior ADA accommodation requests and
states:
1. The Clerk of the Court reassigned this case to the Honorable James M. Barton, II
effective February 13, 2007.
2. Plaintiffs Accommodation Request Americans with Disabilities Act (ADA) was
submitted February 20, 2007. (Exhibit A). Plaintiff's ADA request set forth the following:
a. Plaintiffwas determined totally disabled by Social Security in 1994.
b. Defendants are familiar with Plaintiffs disability from their prior representation ofhim.
c. Plaintiff has medical conditions which are disabling.
d. Mr. Rodems has aggravated Plaintiff's disability for advantage in the litigation.
3. Plaintiffs Amended Accommodation Request Americans with Disabilities Act
(ADA) was submitted March 5, 2007. (Exhibit B). Plaintiff's Amended ADA request sets
for the information in paragraph two, and adds the following:
Plaintiff's Motion to Consider Prior ADA Accommodation Requests
Gillespie v. Barker, Rodems & Cook, PA, case 05-CA-7205
a. Defendants were aware of the medication prescribed to Plaintiff; and
b. Plaintiff was diagnosed with Type 2 diabetes in 2006.
4. The Court expressed unfamiliarity with Plaintiff's disability during a hearing
January 26, 2010: THE COURT: "...1mean if you are saying your disability, which is yet
unclear to me, hasn't been dealt with accordingly -- I believe this is the first time we are
hearing about this.(transcript, January 26, 2010, p. 8, beginning line 11).
5. Because the Court was not previously aware of Plaintiffs disability, he requests
the Court consider it now.
6. Plaintiffhired at his own expense Ms. Karin Huffer, MS, MFT, as his ADA
accommodation advocate and designer.
7. Ms. Huffer prepared an ADA Report for Plaintiff that was submitted to the
Court's ADA Coordinator Mr. Casares February 19, 2010. Plaintiff submitted a separate
ADA accommodation request to Mr. Casares February 19,2010.
8. On April 14, 2010 Mr. Casares notified Plaintiff "Your request is not within our
means to resolve and was referred to the Legal Department for the appropriate course of
action." As of today the Legal Department has not responded to Plaintiff. (Exhibit C).
9. The ADA requests described in paragraphs 2 and 3 describe Plaintiff's difficulty
hearing. A transcript ofthe hearing before Judge Isom February 5, 2007 (page 45, line 7)
shows Plaintiff had difficulty hearing during the proceeding.
10. Plaintiffinfonned the Court's ADA Coordinator Mr. Casares about his hearing
difficulties. Mr. Casares offered to provide Plaintiff a "hand-help amplification device".
However Plaintiff already has a hearing aid as a result of being diagnosed with hearing
loss and prescribed a hearing aid years ago. Plaintiff believes his hearing difficulty will
Page - 2 of5
Plaintiff's Motion to Consider Prior ADA Accommodation Requests
Gillespie v. Barker, Rodems & Cook, PA, case 05-CA-7205
not be remedied with a hearing aid. Therefore real-time transcription services are an
appropriate and reasonable accommodation. Plaintiff submitted this request to Mr.
Casares by certified letter dated April 26, 2010. (Exhibit D).
11. While the Court stated it was not familiar with Plaintiff's disability, Mr. Rodems
was aware of Plaintiffs disability from his firm's prior representation of Plaintiff in a
substantially related matter. With malice aforethought Rodems distributed copies of
Plaintiffs ADA accommodation request outside these proceedings, to Mr. Pedro Bajo,
Chair of the 13
th
Circuit JNC, and perhaps to others.
12. Mr. Rodems has written derogatory letters about participants in other litigation. In
WrestleReunion, LLC v. Live Nation, Television Holdings, Inc., United States District
Court, Middle District of Florida, Case No. 8:07-cv-2093-T-27, trial August 31
September 10, 2009, Mr. Rodems lost the case and later wrote a letter attacking the
credibility of Eric Bischoff, a witnesses. (Exhibit E). It is highly unusual that an attorney
would write such a libelous letter. It presents Mr. Rodems as a 'Dr. Jekyll and Mr. Hyde'
or split personality. This is not meant to demean Mr. Rodems but to point out to the Court
that Mr. Rodems' disruptive behavior is not limited to this case. It is unfair to punish
Plaintiffwith extreme sanctions for alleged transgressions when Mr. Rodems has
culpability and is acting with malice to put Plaintiff in a false light.
13. Mr. Rodems has aggravated Plaintiffs disability for advantage in this litigation.
Mr. Rodems wrote a derogatory letter to a participant in other litigation. Therefore it is
appropriate to consider Plaintiffs disability and ADA accommodation requests when
deciding matters of case management. Plaintiff submitted a notice to convene a case
management conference. Plaintiff also submitted a motion to declare complex litigation.
Page - 3 of5
Plaintiff's Motion to Consider Prior ADA Accommodation Requests
Gillespie v. Barker, Rodems & Cook, PA, case 05-CA-7205
14. Mr. Rodems has set a level of animosity in this lawsuit described by plaintiffs
former attorney Mr. Robert W. Bauer on the record: " ... Mr. Rodems has, you know,
decided to take a full nuclear blast approach instead of us trying to work this out in a
professional manner. It is my mistake for sitting back and giving him the opportunity to
take this full blast attack." (transcript, August 14, 2008, emergency hearing, the
Honorable Marva Crenshaw, p. 16, line 24). Plaintifftherefore requires ADA
accommodations that are reasonable considering the "full nuclear blast approach" taken
by Mr. Rodems in this lawsuit.
15. Plaintiff also request the Court implement procedure used in the Second District
Court of Appeal, Notice to Attorneys and Parties, July 1, 2009, Rule 9, Supplemental
Authority, that a lawyer must notify the opposing party of the full citation BEFORE oral
argument and file with the court. This should be done, except in exceptional
circumstances, early enough for opposing counsel to be prepared to respond to the
supplemental authority at oral argument.
16. Mr. Rodems submitted "Defendants Motion To Strike Plaintiff's "Motion For
Leave To Amend Americans With Disabilities Act (ADA) Accommodation ofNeil J.
Gillespie" April 1, 2010. Plaintiff disagrees with the motion. Nonetheless Plaintiff agrees
to strike the motion in place of this motion in an effort of good will toward Mr. Rodems.
The Court should also be aware that Mr. Rodems has been attaching "sticky notes"
addressed to Plaintiff in violation of Judge Isom's directive of February 5, 2007. An
example of one such note is attached as Exhibit F.
WHEREFORE Plaintiff moves the Court to consider his prior ADA
accommodation requests, the provision of real-time transcription services, support for
Page - 4 of5
Plaintiff's Motion to Consider Prior ADA Accommodation Requests
Gillespie v. Barker, Rodems & Cook, PA, case 05-CA-7205
case management as provided by the Fla.R.Civ.P, a case management conference, Rule
1.200(a), designation of complex litigation, Rule 1.201(a), and implement procedure used
in the Second District Court of Appeal, Notice to Attorneys and Parties, July 1, 2009,
Rule 9, Supplemental Authority.
RESPECTFULLY SUBMITTED April 28, 2010.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy ofthe foregoing has been
furnished by mail to Ryan Christopher Rodems, attorney, Barker, Rodems & Cook, P.A.,
Attorneys for Defendants, 400 North Ashley Drive, Suite 2100, Tampa, Florida 33602,
this 28
th
day of April, 20IO.
I HEREBY CERTIFY that a true and correct copy ofthe f<5regoing has been
furnished by mail to Gonzalo B. Casares, ADA Coordinator, Thirteenth Judicial Circuit,
800 E. Twiggs Street, Room 604, Tampa, Florida 33602 this 28
th
day of April, 2010.
Page - 5 of5
--------------
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL
CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
GENERAL CIVIL DIVISION
NEIL J. GILLESPIE,
Plaintiff, CASE NO.: 05-CA-7205
vs.
BARKER, RODEMS & COOK, P.A., DIVISION: H
a Florida corporation, WILLIAM
J. COOK,
Defendants.
/
PLAINTIFF'S ACCOMODATION REQUEST
AMERICANS WITH DISABILITIES ACT (ADAl
Plaintiff requests an accommodation under the Americans With Disabilities Act
(ADA) and states:
1. Plaintiff was determined totally disabled by Social Security in 1994.
2. Defendants are familiar with Plaintiffs disability from their prior
representation of him. Defendants investigated his eligibility to receive services from the
Florida Department of Vocational Rehabilitation (DVR). DVR determined that Plaintiff
was too severely disabled to benefit from services. Defendants concurred, and notified
Plaintiff of their decision in a letter to him dated March 27, 2001. (Exhibit A).
3. Plaintiff has the following medical conditions which are disabling and
prevent him from effectively participating in court proceedings, including:
a. Depression and related mood disorder. This medical condition prevents
Plaintiff from working, meeting deadlines, and concentrating. The inability to
concentrate at times affects Plaintiffs ability to hear and comprehend.
EXHIBIT
I !1
I
i
I
I
!
Gillespie v. Barker, Rodems & Cook, P.A., case no. 05-CA-7205
b. Post Traumatic Stress Disorder (PTSD), makes Plaintiff susceptible to
stress, such as the ongoing harassment by Defendants' lawyer, Mr. Rodems.
c. Velopharyngeal Incompetence (VPI) is a speech impairment that affects
Plaintiffs ability to communicate.
d. The medical treatment for depression includes prescription medication
that further disables Plaintiffs ability to do the work ofthis lawsuit, and further
prevents him from effectively participating in the proceedings.
4. Prior to the onset of the most disabling aspects Plaintiffs medical
condition(s), he was a productive member of society, a business owner for 12 years, and a
graduate of both the University of Pennsylvania and The Evergreen State College.
5. On March 3, 2006, Ryan Christopher Rodems telephoned Plaintiff at his
home and threatened to use information learned during Defendants prior representation
against him in the instant lawsuit. Mr. Rodems' threats were twofold; to intimidate
Plaintiff into dropping this lawsuit by threatening to disclose confidential client
information, and to inflict emotional distress, to trigger Plaintiffs Post Traumatic Stress
Disorder, and inflict injury upon Plaintiff for Defendants' advantage in this lawsuit.
6. On March 6, 2006, Mr. Rodems made a false verification the Court about
the March 3, 2006 telephone call. Mr. Rodems submitted Defendants' Verified Request
For Bailiff And For Sanctions, and told the Court under oath that Plaintiff threatened acts
of violence in Judge Nielsen's chambers. It was a stunt that backfired when a tape
!
recording of the phone call showed that Mr. Rodems lied. Plaintiff notified the Court
about Mr. Rodems' perjury in Plaintiffs Motion With Affidavit To Show Cause Why
Ryan Christopher Rodems Should not Be Held In Criminal Contempt Of Court and
Incorporated Memorandum Of Law submitted January 29, 2007.
Page - 2 of 4
I
Gillespie v. Barker, Rodems & Cook, P.A., case no. 05-CA-7205
7. Mr. Rodems' harassing phone call to Plaintiff of March 3, 2006, was a
tort, the Intentional Infliction ofEmotional Distress. Mr. Rodems' tort injured Plaintiff
by aggravating his existing medical condition. From the time of the call on March 3,
2006, Plaintiff suffered worsening depression for which he was treated by his doctors.
a. On May 1, 2006 Plaintiffs doctor prescribed Effexor XR, a serotonin
norepinephrine reuptake inhibitor (SNRl), to the maximum dosage.
b. Plaintiffs worsening depression, and the side affects of the medication,
lessened Plaintiffs already diminished ability to represent himself in this lawsuit.
c. On October 4,2006 Plaintiff began the process of discontinuing his
medication so that he could improve is ability to represent himself in this lawsuit.
d. On or about November 18,2006, Plaintiff discontinued the use of anti
depression medication, to improve his ability to represent himself in this lawsuit.
8. Mr. Rodems continued to harass Plaintiff during the course of this lawsuit
in the following manner:
a. Mr. Rodems lay-in-wait for Plaintiff outside Judge Nielsen's chambers
on April 25, 2006, following a hearing, to taunt him and provoke an altercation.
b. Mr. Rodems refused to address Plaintiff as "Mr. Gillespie" but used his
first name, and disrespectful derivatives, against Plaintiffs expressed wishes.
c. Mr. Rodems left insulting, harassing comments on Plaintiffs voice mail
during his ranting message of December 13,2006.
d. Mr. Rodems wrote Plaintiff a five-page diatribe of insults and ad
hominem abusive attacks on December 13,2006.
9. Plaintiff notified the Court of his inability to obtain counsel in Plaintiff's
Notice ofInability to obtain Counsel submitted February 13,2007.
Page - 3 of4
Gillespie v.Barker, Rodems & Cook, P.A., case no. 05-CA-7205
10. Plaintiff acknowledges that this ADA accommodation request is unusual,
but so are the circumstances. Defendants in this lawsuit are Plaintiffs former lawyers,
who are using Plaintiff's client confidences against him, while contemporaneously
inflicting new injuries upon their former client based on his disability.
WHEREFORE, Plaintiff requests additional time to obtain counsel, a stay in the
proceedings for 90 days. Plaintiff also requests accommodation in the fonn of additional
time to meet deadlines when needed due to his disability.
RESPECTFULLY this 20
lh
day of February, 2007.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy ofthe foregoing has been
furnished via US Mail to Ryan C. Rodems, attorney, Barker, Rodems & Cook, P.A., 400
N Ashley Dr., Suite 2100, Tampa, FL 33602, this 20
th
day of!ebruary. 2007. .7
_.__------- J ? 4
/ //.

,/' /
Page - 4 of4
BARKER, RODEMS is,l COOK
1'ltOI'I':;,;llIN/\I.I\SSUCI!\TION
ATI'l.lI(NI;YS 1\'1' 1.1\ W
I :1I1l1'.'\ It ... I-I(
,e; 13/I::\L It)OI
JOO \'{/c:;t I'lait Street, SlIitr 150
1
1
,\":\1\1
.5/-1:)1)100:)
Cc II \\;.'1111.'\'''' I T;H,q'", I'Il'rid" 3.160b
March 27, 200 I
Neil ./. (jillcspic
Aparlment ('-2
117.1 Beach Drive NE
SI. Pdcrshurg, Florida 33701-1434
nt,,: Voct'ion:.1 Rchabilil:llioll
I ;UII cnclo:-;ing the material yOll provided to liS. We have reviewed them and, unJi.Htllllatdy,
we arc 1101 ill ,I positioll to represent yotl tor any claims yOtl Inay have. Please understand I hal our
decision docs nolmeall Ihat your claims lack merit, and allothcr attorney might wish to represent YOll.
Iryoll wish 10 consult with another allorney, we recollJlllend that yOll do so immedi;rlely as;1 slalute
. . .
or limilalions will apply to any claims you llIay have. As you kHOW, a statute or lilllilatiOJlS is a kgal
lk:tdlinc I()r /ilillg a lawsuit. Thallk you for the opportunity to review your
Sincerely,
William .I. Cook
WH '!Inss
FnclnSl1 res
I
EXHIBIT
f1
-------------
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL
CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
GENERAL CIVIL DIVISION
NEIL J. GILLESPIE,
Plaintiff, CASE NO.: 05-CA-7205
vs.
BARKER, RODEMS & COOK, P.A., DIVISION: C
a Florida corporation, WILLIAM
J. COOK,
Defendants.
/
PLAINTIFF'S AMENDED ACCOMODATION REQUEST
AMERICANS WITH DISABILITIES ACT (ADA)
Plaintiff requests an accommodation under the Americans With Disabilities Act
(ADA) and states:
1. Plaintiff was determined totally disabled by Social Security in 1994.
2. Defendants are familiar with Plaintiff's disability from their prior
representation of him. Defendants investigated his eligibility to receive services from the
Florida Department of Vocational Rehabilitation (DVR). DVR determined that Plaintiff
was too severely disabled to benefit from services. Defendants concurred, and notified
Plaintiff oftheir decision in a letter to him dated March 27, 2001. (Exhibit A).
Defendants were also informed of Plaintiff's medication for depression by fax dated
October 6,2000, Effexor XR 150mg. (Exhibit B).
3. Plaintiff has the following medical conditions which are disabling and
prevent him from effectively participating in court proceedings, including:
a Depression and related mood disorder. This medical condition prevents
\
Plaintiff from working, meeting deadlines, and concentrating. The inability t o " _ I I I I I I I I I I I ~ I I ! I ! I ! ~ _
EXHIBIT
I ~ -
Gillespie v. Barker, Rodems & Cook, P.A., case no. 05-CA-7205
concentrate at times affects Plaintitrs ability to hear and comprehend. The
medical treatment for depression includes prescription medication that further
disables Plaintiff's ability to do the work of this lawsuit, and further prevents him
from effectively participating in the proceedings.
b. Post Traumatic Stress Disorder (PTSD), makes Plaintiff susceptible to
stress, such as the ongoing harassment by Defendants' lawyer, Mr. Rodems.
c. Velopharyngeal Incompetence (VPI) is a speech impairment that affects
Plaintiffs ability to communicate.
d. Type 2 diabetes. This was diagnosed in 2006 after Defendants'
representation.
4. Prior to the onset of the most disabling aspects Plaintifrs medical
condition(s), he was a productive member of society, a business owner for 12 years, and a
graduate of both the University of Pennsylvania and The Evergreen State College.
5. On March 3, 2006, Ryan Christopher Rodems telephoned Plaintiff at his
home and threatened to use information learned during Defendants prior representation
against him in the instant lawsuit. Mr. Rodems' threats were twofold; to intimidate
Plaintiff into dropping this lawsuit by threatening to disclose confidential client
information, and to inflict emotional distress, to trigger Plaintiff's Post Traumatic Stress
Disorder, and inflict injury upon Plaintifffor Defendants' advantage in this lawsuit.
6. On March 6, 2006, Mr. Rodems made a false verification the Court about
the March 3, 2006 telephone call. Mr. Rodems submitted Defendants' Verified Request
For Bailiff And For Sanctions, and told the Court under oath that Plaintiff threatened acts
of violence in Judge Nielsen's chambers. It was a stunt that backfired when a tape
recording of the phone call showed that Mr. Rodems lied. Plaintiff notified the Court
Page - 20f4
Gillespie v. Barker, Rodems & Cook, P.A., case no. 05-CA-7205
about Mr. Rodems' perjury in Plaintiff's Motion With Affidavit To Show Cause Why
Ryan Christopher Rodems Should not Be Held In Criminal Contempt Of Court and
Incorporated Memorandum Of Law submitted January 29,2007.
7. Mr. Rodems' harassing phone call to Plaintiff of March 3,2006, was a
tort, the Intentional Infliction ofEmotional Distress. Mr. Rodems' tort injured Plaintiff
by aggravating his existing medical condition. From the time of the call on March 3,
2006, Plaintiff suffered worsening depression for which he was treated by his doctors.
a. On May 1,2006 Plaintiff's doctor prescribed Effexor XR, a serotonin-
norepinephrine reuptake inhibitor (SNRI), to the maximum dosage.
b. Plaintiff's worsening depression, and the side affects of the medication,
lessened Plaintiff's already diminished ability to represent himself in this lawsuit.
c. On October 4,2006 Plaintiff began the process of discontinuing his
medication so that he could improve is ability to represent himself in this lawsuit.
d. On or about November 18,2006, Plaintiff discontinued the use of anti
depression medication, to improve his ability to represent himself in this lawsuit.
8. Mr. Rodems continued to harass Plaintiff during the course of this lawsuit
in the following manner:
a. Mr. Rodems lay-in-wait for Plaintiff outside Judge Nielsen's chambers
on April 25, 2006, following a hearing, to taunt him and provoke an altercation.
b. Mr. Rodems refused to address Plaintiff as "Mr. Gillespie" but used his
first name, and disrespectful derivatives, against Plaintiffs expressed wishes.
c. Mr. Rodems left insulting, harassing comments on Plaintiffs voice mail
during his ranting message of December 13, 2006.
I
I
Page - 3 of4
\
Gillespie v. Barker, Rodems & Cook, P.A., case no. 05-CA-7205
d. Mr. Rodems wrote Plaintiff a five-page diatribe of insults and ad
hominem abusive attacks on December 13,2006.
9. Plaintiff notified the Court ofhis inability to obtain counsel in Plaintiff's
Notice ofInability to obtain C'ounsel submitted f'ebruary 13, 2007..
10. Plaintiff ac_knowledges that this ADA accommodation request is unusual,
but so are the circumstances. Defendants in this lawsuit are Plaintiff's former lawyers,
who are using Plaintiffs client confidences against him, while contemporaneously
inflicting new injuries upon their fonner client based on his disability.
WHEREFORE, Plaintiff'" requests additional time to obtain counsel, a stay in the
proceedings for 90 days. Plaintiff also requests accommodation in the fonn of additional
time to meet deadlin_es when needed due to his disability_
RESPECTFULI.JY SUBMITTED this 5
th
day of March, 2007.
CERTIFICATE OF SERVICE
I H_EREBY CERTIFY that a true and correct copy of the foregoing has been
furnished via US Mail to Ryan C. Rodems, attorney, Barker, Rodems & Cook, P.A., 400
N Ashley Dr., Suite 21.00, Tampa, FL 33602, this 5
th
day of March, 2007.

,....! . //
,/ /;:/ t .,'
I' .fY ;7'" ,/;/'
". -., ",' (...-'"
,//" ,/jI" ...:.'''/
/f/ .....
Page - 4 of4
BARI(EI{" RODEMS & CC)()I<

/\'rn)RNFYS AT 1./\ \Xl
( IIIU S ..\, I'. l\ H " F F
It" l\ N ('II H I T ( I' II ER It n p F tv1
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300 \Vest Pbu ... t, Suit.t' 1.50
FI\Hida 33606
T (,1 (' l' h n l\ C

S 1J! "l St). 10 \11

l\1arch 27, 200 1
Neil J. CiilJcspic
Aptlrt 'l1ent
I 121 13each [)rive
Sf. Ilor.ida 33701-1434
Ite: tioll:tl 11.chnIJilit,:.tiou
r Nci I
I (lIn cncl()sing the 111atcrinl you provided to liS. "Ve have revie\ved then1 and, un-fortunatcly,
\VC are not in a position to you l(.1r any Cl(ljnls yOll ulay have. l)lcase understand that our
docs 110t lllCUll that your cJainls lack lllcrit, and another attorney Blight: \vish t() represent you.
Ifyol.l\vish to consult vvith another attorney, ,ve recolnnlcnd that you do so i.-nlllediatcly as a statute
orlilni1ali()lls \vill apply to any cluinJs you 1l1ay have. As you kno\v, a statute of IiIII it ations is a legal
deadline l()f filing a la\vsuit. 'fhank yOll for the opport unity to revie\v YOll1' Inaterials.
Sincerely,
\Villi,Ull J.
'vV.J('/nlSS
re:-;
EXHIBIT
IJL
Fax
From: Neil J. Gillespie
1121 Beach Drive NE, Apt C-2
St. Petersburg, FL 33701
Phone/Fax: (727) 823-2390
To: William J. Cook, Attorney at Law
Fax: (813) 228-9612
Date: October 6, 2000
Pages: just this page
'---._-- ._-------------
Re: ACE Check Cashing deposition
o Urgent o Please Reply 0 ForYoMr Review
-_._.__...._-------------------
8 Comments:
RE: Current medications
Effexor XR 150 mg (depression)
Levoxyl 0.075 mg (hormone)
EXHIBIT
1-13
Page 1 of 1
Neil Gillese!! _
From: "Casares, Gonzalo" <CASAREGB@fljud13.org>
To: <neilgiliespie@mfLnet>
Sent: Wednesday, April 14, 2010 8:35 AM
Subject: ADA
RE: CASE # 05-7205
GILLESPIE vs. BAKER, RODEMS, & COOK; PA
Dear Mr. Gillespie,
Thank you for your letter dated April 7
th
201 O.
Court Facilities Management is the point of contact for all facilities related issues such
as repairs and/or maintenance work. As such, we can determine if an ADA function is
at issue in our set of buildings and track requests for accommodations. Your request is
not within our means to resolve and was referred to the Legal Department for the
appropriate course of action.
Your difficulty-in-hearing was not known to me until your latest correspondence. On
this matter, we can help you. We will provide the hand-help amplification device upon
your request.
Sincerely,
Gonzalo B. Casares
ADA Coordinator
13
th
Judicial Circuit Court
Tampa, FI. 33647
casaregb@fljud13.org
(813)272-6169
EXHIBIT
Ie
4/18/2010
Neil J. Gillespie
8092 SW 115
th
Loop
Ocala, Florida 34481
VIA US CERTIFIED MAIL. RRR
Article No.: 7008 1300000180544986
April 26. 201 0
Mr. Gonzalo B. Casares. ADA Coordinator
Thirteenth Judicial Circuit
800 E. Twiggs Street, Room 604
Tampa, Florida 33602
RE: Americans With Disabilities Act (ADA) Accommodation Request
Gillespie v. Barker, Rodems & Cook, case no.: 05-CA-7205, Division C
Dear Mr. Casares:
This is in response to your email dated April 14, 2010. Thank you for your offer ofa
"hand-help amplification device". I am assuming that is some kind of hearing aid? Many
years ago I was diagnosed with hearing loss and prescribed a hearing aid which is
available to me. Is the "hand-help amplification device" designed to be used with my
existing hearing aid? I believe my difficulty in hearing is due to Post Traumatic Stress
Disorder (PTSD) and therefore real-time transcription services are an appropriate and
reasonable accommodation. This is a request for those services.
My ADA accommodation request was properly addressed to you as the ADA
Coordinator. Your email appears to claim that your ADA authority is limited to Court
Facilities Management, the repair and/or maintenance of buildings for accommodation.
If so it appears the Thirteenth Judicial Circuit lacks an ADA Coordinator with the
background, training and authority to fully implement and administer the ADA.
This is evident by your assertion that "Your request is not within our means to resolve
and was referred to the Legal Department for the appropriate course ofaction." Please
identify the person in the Legal Department to whom you referred my ADA request.
Kindly provide the person's name, business address, business telephone/fax, and position.
As oftoday no one from the Legal Department has contacted me. Thank: you.
y,
I
cilJ. ~ ~ ~ b - - - e - : : > ' ' -
cc: Ms. Karin Huffer, MS, MFT
Enclosure: Email ofGonzalo B. Casares, ADA Coordinator, April 14, 2010 ... EXHIBIT
I 0
Page lofl
Neil Gillesl!!!l.-- _
From: I.Casares, Gonzalo" <CASAREGB@fljud13.org>
To: <neilgillespie@mfi.net>
sent: wednesday, April 14, 20108:35 AM
Subject: ADA
RE: CASE # 05-7205
GILLESPIE vs. BAKER, RODEMS, & COOK; PA
Dear Mr. Gillespie,
Thank you for your letter dated April 7
th
2010.
Court Facilities Management is the point of contact for all facilities related issues such
as repairs and/or maintenance work. As such, we can determine if an ADA function is
at issue in our set of buildings and track requests for accommodations. Your request is
not within our means to resolve and was referred to the Legal Department for the
appropriate course of action.
Your difficulty-in-hearing was not known to me until your latest correspondence. On
this matter, we can help you. We will provide the hand-help amplification device upon
your request.
Sincerely,
Gonzalo B. Casares
ADA Coordinator
13
th
Judicial Circuit Court
Tampa, FI. 33647
casaregb@fljud13.org
(813)272-6169
4/25/2010
DOlwrestling.com - Declaration of Independents - The Number 1 Independent Pro Wrestl... Page 10f3
DOIY'DEO.COM
Ten".;r D,> 'UOi!1<j 2" "hoot I
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tcr';I('w5
sal Corrente of WrestleReunlon had a lawsuit against Clear Channef/Uve Nation because they reneged on a
contract 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 his
statement:
In my last post regarding the Wre5tleReunion/Live Nation lawsuit, I suggested that Bill Behrens and Eric
Bischoff were expert witnesses for WrestleReunion. That was not the case as they were actually witnesses
for the Clear Channel/Live Nation side. 1 just spoke with Eric Bischoff who said he agreed to be an expert
witness after reading and taking Interest in the case, however he was not called to the stand.
"The Clise WliS wrllpped up quickly," Bischoff tolcl Wrestle.zone.com, "theJury didn't waste any
time and came back with what 1 felt was the correct decision".
Eric was happy with the outcome, to say the least. "Rob Russen and sal Corente Illve the wrestling
business a IMd name, n he sr.-ted, "so I'm iliadJustice pre1flllled and ".. boftom feeders didn't win
one".
Bischoff wanted to make sure that everyone knew his comments and opinions were solely his and did not
renect those of Clear Channel/Live Nation.
In regards to the above statement, we have a statement from Mr. Corrente's lawyer:
"It is odd thllt Eric Bischoff, whose well-documented Incompetence cauHd tta. clemi.. of WCW,
should heve any comment on the outcome of the WrMtleRieUnlon, LLC la_It. 'lba expert report
BlKhoff .ubmitbMI In thi. C_ bordered on 1II......cy, .nd 8IKhoff w.. not even called to tatify
by a ..r Clulnnel/Live Netton beQu.. BI.ctIoff perjured him..., In depHItIon In I.te-July 2009
before running out and ...fuslna to .......ny more questlo.. regarding hili MI'IoulI problems
with .lcohoI .nd ..xual deviancy at the GoIcI aub while the hud of WCW. To even .tt In tta.
room .nd q...-tlon him w one of the dlstan.ful thlnp I've ever had tID do In 17 y..... of
p...cticing law. In hIct, we under_nd th.t 818Choff _ afrIIlcI to even come tID T.mpe and
tatIfy beQu.. he would h.ve to answer questions under CNIth for a third time about his
embarraulng past.
The sad state of profenional .......Ina today is directly .ttributable to thl. 011 .....m.n,
wh_ previous career highlights Include Mlilna mut out of tta. back 01 truck. before he filed
b.nkruptcy .nd hed hi. car repo....-d. Today, .n.r runnlna WCW Into tta. ground,
BIKIIoff peddl.. Khlock IIka "Girt. Gone WIld" .nd rullty .ho_'-turtng 8-11.....
Sal Corrente, on the other h.nd, has lIlw.ys been .n honor.ble m.n, end he delivered on every
prom'" lind paid every wrestler while _ging the three W,..tIeReunlon events. Unlike the
cow.rdly BlIIChoff, Mr. Corrente took the and In th. ca... Although hi. compeny did not
prav.lI, Sal Corrente proved that he w.. m.n enough to ftght to the fin" -- -.thIng Bischoff
coulcl never underst.nd:'
Sincerely,
Ryan Christopher Rodems
S.rker, Rodems Cook. P.A.
400 Nol1tl Ashley Drive, Suite 2100
T.mpa, Florida 33602
813/489-1001
E-mail:
We just wanted to give Mr. Corrente's lawyer a chance to speak his mind.
Since I have always had wrestlers autograph signings as a speciality for any website I worked for, I know for
sure, Mr, Corrente is an honest promoter who has NEVER stiffed a wrestler working for his shows or
conventions, 1 would have heard about it.
There are many promoters who do that in this business, which is very sad.
EXHIBIT
.irWtmellion on ttl" Mtbai,. exdusive property of ... oea.r.tion oIlndttpetJdenU MId cannot be ullld".whent without proper ,nil credit. AM001putC/lB.SfI$
",. nonootWNndabl!e, AI m4l (eleCO"Onic or pO*" ."r to tIN 001 become. pIOipefty 01 ... 001 'IIIhit;;h afro_1M 001 to,."nnt that In..., enflWf'y by dOing so,1I
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http://www.declarationofmdependents.net/doi/pages/corrente91O.html 1/28/2010
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
GENERAL CWIL DMSION
NEIL J. GILLESPIE,
Plaintiff,
VI. Case No.: OSCA7205
Division: F
BARKER, RODEMS & COOK, P.A.,
a Florida corporatioD; and WILLIAM
J.COOK,
Defendants.
-----------,
DEFENDANTS' MOTION TO STRIKE PLAINTIFF'S "MOTION FOR LEAVE
TO AMEND AMERICANS WITH DISABILITY ACT (ADA)
ACCOMMODATION OF NEILJ. GILLESPIE"
Defendants Barker, Rodems & Cook, P.A. and William J. Cook move to strike PlaintiffNeil J.
Gillespie's for Leave to Amend Americans with Disability Act (ADA) Accommodation ofNei]
J. Gillespie," pursuant to Fla.. R. Civ. P. 1. 140(t), and as grounds therefor would state:
1. Florida Rule ofCivil Procedure 1.140(f) provides that "the court may strike redun.dant,
immaterial, impertinent, or scant March 29, 201
Disability Act (ADA)
Accommodation ofNeil J. Gilles
PlaintiffNeil J. Gillespie served
rial and impertinent
information.
llees involving an 2. The motion recit(
attorney by the name of Jonathan . larriage proceeding.
Gillespie's motion attaches motiol nents that have
nothing to do with the case at bar.
3. Gillespie's basis f( --_ .... "U'" Ul1unnatlon regarding Mr. Alpert is to "answer" the
undersigned's "often expressed concern that Plaintiffhas taken inconsistent positions regarding the ADA
accommodation and being able to represent himself." (Plaintiff's motion for leave,' 6). Accordil"_------_
EXHIBIT
I F