LAw OFFICE OF DAVID M.

SNYDER
PROFESSIONAL ASSOCIATiON

ArrORNEY

& COUNSELOR AT LAw

SUITE FOUR

181 0 SOUTH MACDILL AVENUE TAMPA, FLORIDA 33629-5960 TELEPHONE (81 3)258-4501 FACSIMILE (813)258-4402
E-MAIL: DMSNYDER@DM5-LAW.COM

ADMITIED IN FLORIDA AND

NEW YORK

CERTIFIED MEDIATOR

U.S. DISTRICT COURT. M.D. FLA.

CIRCUIT AND COUNTY CJVIL

N.A.S.D. ARBITRATOR & MEDIATOR

September 7,2006

Ryan C. Rodems Barker, Rodems & Cook, P.A. 300 W Platt St, Suite 150 Tampa FL 33606

Re:

Gillespie v. Barker, Rodems & Cook, P.A., etc., Case No. 05-7205 Circuit Court, Hillsborough County, Florida

Dear Mr. Rodems: Neil Gillespie has engaged this firm to assist him with the above-styled action. Mr. Gillespie's claim has survived a motion to dismiss. Defendant's counterclaim for defamation, while it may have stated a cause of action at the outset, has little chance of ultimate success given the limited distribution and privileged nature of the publication complained of. See e.g. Nodar v. Galbreath, 462 So. 2d 803 (Fla. 1984). Mr. Gillespie has authorized me to propose settlement of all claims between him and Barker, Rodems & Cook, P.A., Mr. Cook, and the firm's officers, directors, employees, agents, successors and assigns, for payment to Mr. Gillespie of $6,224.78, exchange of mutual general releases, and dismissal with prejudice of the above-styled lawsuit, which each party to bear his/its own costs and attorneys' fees.

WWW.DMS..LAW.COM

Ryan C. Rodems

September 7,2006. Page 2

Please contact me at your convenience if you have questions or comments. Thank you for your prompt consideration of and response to this offer, which expires at 5 p.m., September 17, 2006. Very truly yours,

DMS
Encl cc: Neil Gillespie

L;i.

Snyder

WWW.DMS-LAW.COM

BARKER, RODEMS & COOK

PROFESSIONAL ASSOCIAnON
ATrORNEYS AT LAW
CHRtS A. BARKER.

R.YAN CHR.ISTOPHER RODEMS

WILLIAM

400 North Ashley Drive, Suite 2100

Tampa, Florida 33602

J.

COOK

Telephone 813/489 1001 Facsimile 813/489 1008

September 14, 2006

David M. Snyder, Esquire Law Office of David M. Snyder 1810 South MacDill Avenue, Suite 4 Tampa, Florida 33629-5960
Nell J. Gillespie v. Barker, Rodems & Cook, P.A., a Florida Corporation; and William J. Cook Case No.: 05-CA-7205; Division "F" Our File No. 2005.5422

Re:

Dear Mr. Snyder:

I have and thank you for your letter of September 7, 2006. Your offer is rejected.

We would agree, however, to a walk away. That is, each party dismisses all claims with prejudice, each party to bear his or its own attorneys' fees and costs. Your letter is somewhat ambiguous on your role; if you intend to appear as counsel of record, I ask that you submit a Notice of Appearance. Sincerely,

(
. .../

Ryan Christopher Rodems

RCRlso

Oc t. 5. 2006 11: 58AM

No. 0200

P. 1

BARKER, RODEMS & COOK

PROPESSIONAL ASSOCIAnON ATIOINEYS AT LAW
CHItII A. BAllil
IYAN CHllilTOPHl1t aODIMS
WI1.LIAM ]. COOl;

400 North Alhley Drive, Suite 2100

Tampa. Florida 33~02

Tch:plaullG 81 )/419 .. 1001

'lc,lmUa 813/489 .. 1008

Ootober S, 2006
VIA FACSIMILE ONLY 813-258-4402

David M. Snyder, Esquire Law Office ofDavid M. Snyder 1810 South MacDill Avenue, Suite 4

Tampa, Florida 33629-5960

Re: NeD J. GlUllpie v. Barker, RodelDl Ie Cook, P.A.,

Florida Corporation; IDd William I. Cook Cue No.: 05-CA-7205; DivilioD "F" Our FIle No. 2005.5422

Dear Mr. Snyder:

To clarifyt our offer to settle is 88 follows: (1) We will dismiss our claims with prejudice, Gillespie dismisses his with prejudice, and neither side will pay the other any money; and, (2) Gillespie agrees to sign a general release to be prepared by us; and, (3) Gillespie must aaree to appear in court to announce the settlement and submit to questioniDa from me regarding the voluntlrineu ofbis settlement; and, (4) Gillespie must aaree to hire and pay a court reporter to transcribe the settlement hearing.

The offer is open until 5:00 p.m. on Friday, October 6, 2006 and must be accepted in writing received in this office before the deadline by faclimilo or hand delivery with your or his signature.

Ryan Christopher Rodema

R.CRlso

LAw OFFICE OF DAVID M. SNYDER

PROFESSIONAL ASSOCIATION

AlTORNEY & COUNSELOR AT LAw

SUIlEFOUR

1810 SOlTTH MACDlu. AVENUE TAMPA. FLORIDA 33629-5960 TELEPHONE (81 3)25&450 1 FACSIMILE (81 3)25&4402
E-MAIL: DMSNYDERttoMSUW.COM

ADMITTED IN FLoRIDA AND NEW YORK

CERTlF1ED MEDIATOR

U.S. DISTRICT COURT. M.D. FLA.

CIRCUIT AND COUNTY CIVIL

NAS.D. ARBITRATOR a MEDIATOR

October 5,2006 Ryan C. Rodems Barker, Rodems & Cook, P.A. 300 W Platt St, Suite 150 Tampa FL 33606 Re: Gillespie v. Barker, Rodems & Cook, P.A., etc., Case No. 05-7205 Circuit Court, Hillsborough County, Florida

Dear Mr. Rodems:

I have your October 5, 2006 letter. This firm no longer represents Neil Gillespie. I have forwarded your letter to him and you may contact him directly.
Very truly yours,

~.
DMS
Encl cc: Neil Gillespie

.(' Q---..-----C?-;)

David M. Snyder

WWW.DMSi..AW.COM