IN THE CIRCUIT COURT OF THE TIDRTEENTH JUDICIAL CIRCUIT

IN AND FOR IDLLSBOROUGH COUNTY, FLORIDA

GENERAL CIVIL DIVISION

NEIL J. GILLESPIE, Plaintiff and Counter-Defendant, vs. BARKER, RODEMS & COOK, P.A., a Florida corporation; WILLIAM J. COOK, Defendants and Counter-Plaintiffs. / DIVISION: G CASE NO.: 05-CA-007205

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PLAINTIFF'S NOTICE OF FILING AFFIDAVIT OF NEIL J. GILLESPIE

Plaintiff and Counter-Defendant pro se Gillespie hereby notice the filing of the Affidavit of Neil J. Gillespie: RESPECTFULLY SUBMITTED September 3, 2010.

Certificate of Service I HEREBY CERTIFY that copy of the foregoing was mailed September 3, 2010 to Mr. Ryan C. Rodems, attorney for the Defendants and Counter-Plaintiffs, at Barker, Rodems & Cook, PA, 400 North Ashley Drive, Suit pa, Flori 602.

IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT

IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
GENERAL CIVIL DIVISION

NEIL J. GILLESPIE, Plaintiff and Counter-Defendant, vs. BARKER, RODEMS & COOK, P.A., a Florida corporation; and WILLIAM J. COOK, Defendants and Counter-Plaintiffs. / DIVISION: G CASE NO.: 05-CA-7205

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AFFIDAVIT OF NEIL J. GILLESPIE

Neil J. Gillespie, under oath, testifies as follows:

1. My name is Neil J. Gillespie, and I am over eighteen years of age. This

affidavit is given on personal knowledge unless otherwise expressly stated. 2. 3. I am the Plaintiff and Counter-Defendant pro se in this lawsuit. I received a letter from Mr. Ryan Christopher Rodems and Barker,

Rodems & Cook, PA dated December 19, 2006, attached hereto as Exhibit A. 4. Mr. Rodems wrote "The documents have already been produced, and I

would hope to avoid you having to pay additional money or expending additional time on this when you already have the documents." (Paragraph 1). Mr. Rodems' statement is false and the documents were not produced. FURTHER AFFIANT SAYETH NAUGHT.
Dated this 29th day of July 2010.

STATE OF FLORIDA COUNTY OF MARION BEFORE ME, the undersigned authority authorized to take oaths and acknowledgments 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 above matters contained in this Affidavit are true and correct to the best of his knowledge and belief. WITNESS my hand and official seal this 29th day of July 2010.

~~
State of Florida

BARKER, RODEMS
CHRIS A. BARKER RYAN CHRISTOPHER RODEMS WILLIAM I. COOK

& COOK
Telephone 813/489.1001 Facsimile 813/4891008

PROFESSIONAL ASSOCIATION ATTORNEYS AT LAW

400 North Ashley Drive. Suite 2100

Tampa. Florida 33602

December 19,2006

Mr. Neil J. Gillespie

8092 SW 115 1h Loop Ocala, Florida 34481

Dear Neil: I have and thank you for your letter of December 13,2006. We will be happy to make those documents available for your inspection and copying. You may wish to review the requests and the response. The documents have already been produced, and I would hope to avoid you having to pay additional money or expending additional time on this when you already have the documents. In any event, since we have already produced the documents, it would be a burden to produce the documents for inspection at an alternative location. Therefore, we object to any procedure that does not involve inspection and copying at our office. If you wish to have copies of documents made, our staff will make them for you in our office, but we will only do so if you designate which documents you wish to have copied and agree to pay our $.25 per copy charge. If you are uncomfortable paying that amount of money, you may arrange for alternative copying services, provided that the copying is done in our offices.

RCR/so

this document added later, for context

Neil J. Gillespie
8092 SW 115 Loop Ocala, Florida 34481 Telephone: (352) 502-8409
th

December 13,2006 Ryan Christopher Rodems, Attorney at Law Barker, Rodems & Cook, P.A. 400 North Ashley Drive, Suite 2100 Tampa, Florida 33602

RE: Gillespie v. Barker, Rodems & Cook, P.A., case no.: 05-CA-7205, Div. H
Dear Mr. Rodems, This is a request to inspect and copy the documents responsive to the following: 1. Defendants' Response to Plaintiffs Request for Production to BRC submitted July 31,2006. This includes documents responsive to categories 11,24 and 25; your current response that the documents were "previously produced" is neither truthful nor lawful. I expect you to comply and produce the documents for copying. 2. Defendants' Response to Plaintiff's Request for Production to William J. Cook submitted July 31,2006. This includes documents responsive to categories 11 and 12; your current response that the documents were "previously produced" is neither truthful nor lawful. I expect you to comply and produce the documents for copying. I want to complete the copying of your clients' documents within 30 days. Kindly contact me with some available dates for the copy service to appear at your office to copy the documents at my expense. At this time I do not intend to be present, but I can be if you want. Please advise. In the alternative to copying the documents at your office, you can bring your clients' documents to the copy service company for copying at my expense. Currently I am considering Berryhill and Associates, Inc., General Court Reporting Services, 501 E. Kennedy Blvd., Suite 1225, Tampa, Florida 33602. Please advise if Berryhill is acceptable, or if your prefer another copy service company. Please respond to this request not later than 5:00 p.m., Friday, December 22, 2006. If I do not receive a response from you by that date and time, I will assume that you are refusing to produce the documents for copying and I will proceed on that basis.