Theodore P. Littlewood Jr., Florida Bar CounselRE: Ryan C. Rodems TFB File No. 2013-10,271 (13E) October 16, 2012Page 3November 18, 2010 the same day I filed a Verified Petition for Writ of Prohibition and MotionFor Order of Protection in the Second District Court of Appeal, case no. 2D10-5529.Martha Cook is ethically compromised due to past insolvency and violation of the Code of Judicial Conduct, Canons 2, 3, 5 and 6 as set forth in
Plaintiff’s 4th Motion To Disqualify Judge Martha J. Cook
, filed November 10, 2010.My inquiry into Martha Cook’s eminent financial collapse served as a basis for the TampaTribune story and attorney scrutiny in this matter. My efforts uncovered Martha Cook’s troubledfinances and alerted attorneys who practice mortgage foreclosure defense about her conflict.Martha Cook is ethically compromised, which is described further at Exhibit 2 to this rebuttal.Martha Cook is profoundly dishonest as shown in this rebuttal. Her rulings are not reliable.Rebuttal to Rodems’ Exhibit 1: Complaint Against Rodems TFB No. 2007-11,162(13D)Improper Closure By Susan Bloemendaal November 19, 2007As set forth above, my complaint against Mr. Rodems submitted June 20, 2007 was notprocessed by the central ACAP complaint intake office in Tallahassee, even though I providedthe complaint directly to Mr. Marvin in Tallahassee. Therefore any action by Ms. Bloemendaalwas premature since she did not have authority over the complaint on November 19, 2007.Mr. Rodems’ response at Exhibit 1 shows he may be confused about my two complaints againsthim in 2007. While similar, my first complaint submitted February 20, 2007
alleged disabilitydiscrimination and the second complaint submitted June 20, 2007 did not. Each complaintinformed the Bar that on January 13, 2006, Judge Nielsen found a cause of action for fraud andbreach of contract against William J. Cook and Barker, Rodems & Cook, PA. Judge Nielsenrejected Mr. Rodems’ “claim” to $50,000 in “court-awarded costs and fees”. Each Bar complaintincluded a copy of Judge Nielsen’s Order. Mr. Rodems’ “claim” to $50,000 in “court-awardedcosts and fees” was denied, decided res judicata, precluding him from again raising this claim.First complaint: February 20, 2007, TFB No. 2007-11,162(13D) submitted to the Tampabranch office and improperly closed by Assistant Staff Counsel Troy Matthew Lovell. A publicrecord copy of this complaint appears at Exhibit 3 to this rebuttal. Accompanying the complaintat Exhibit K was Plaintiff’s Accommodation Request, Americans with Disabilities Act (ADA), acertified copy of which appears at Exhibit 4 to this rebuttal. Judge Nielsen’s Order accompaniedthe complaint at Exhibit C, a certified copy of which appears at Exhibit 5.Second Complaint: June 20, 2007 submitted to Mr. Marvin in Tallahassee, who sent it tothe Tampa Brach Office. No complaint number was assigned to this complaint. The complaintwas not investigated. For almost five months the Bar took no action. Then Ms. Bloemendaalclosed the complaint by letter November 19, 2007, a letter that referenced the first complaint.
I submitted Exhibits A through H with the complaint submitted February 20, 2007. Exhibit H was PlaintiffsAccommodation Request, Americans With Disabilities Act that showed Mr. Rodems used information about mydisability against me, information he learned from his law firm's prior representation of me.