Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Look up keyword
Like this
2Activity
0 of .
Results for:
No results containing your search query
P. 1
Rebuttal to Ryan Christopher Rodems, TFB File No. 2013-10,271 (13E)

Rebuttal to Ryan Christopher Rodems, TFB File No. 2013-10,271 (13E)

Ratings: (0)|Views: 28|Likes:
Published by Neil Gillespie
Susan Bloemendaal improperly closed my complaint against Mr. Rodems by letter November 19, 2007. Ms. Bloemendaal was then, and is today, Chief Branch Discipline Counsel for the Tampa Branch Office of The Florida Bar. My complaint was not processed by the central ACAP complaint intake office in Tallahassee, even though I provided the complaint directly to Kenneth Marvin, Director of Lawyer Regulation in Tallahassee. Mr. Marvin sent my complaint
to Tampa, which was procedurally incorrect. There is a mandatory complaint intake process, set forth in the Bar Counsel Manual. The mandatory complaint intake process begins at ACAP in
Tallahassee. My complaint was not processed by central ACAP. Therefore Ms. Bloemendaal lacked proper authority to consider my complaint at that point in the process. Ms. Bloemendaal and Mr. Lovell improperly dismissed my complaints as shown in this rebuttal.

My complaints made during the years 2004 through 2007 were inarticulate due to inexperience with the complaint process. My complaints alleged closing statement fraud (Rule 4-1.5(f)(5)), no signed contingent fee agreement (Rule 4-1.5(f)(2)), and representation against a former client on the same or substantially related matter. (Rules 4-1.7, 4-1.9, 4-1.10). Other things I complained about were subordinate, and also inartfully alleged. Ms. Bloemendaal authored four letters to me dated November 19, 2007 that ignored the essence of my former lawyers’ misconduct.
Susan Bloemendaal improperly closed my complaint against Mr. Rodems by letter November 19, 2007. Ms. Bloemendaal was then, and is today, Chief Branch Discipline Counsel for the Tampa Branch Office of The Florida Bar. My complaint was not processed by the central ACAP complaint intake office in Tallahassee, even though I provided the complaint directly to Kenneth Marvin, Director of Lawyer Regulation in Tallahassee. Mr. Marvin sent my complaint
to Tampa, which was procedurally incorrect. There is a mandatory complaint intake process, set forth in the Bar Counsel Manual. The mandatory complaint intake process begins at ACAP in
Tallahassee. My complaint was not processed by central ACAP. Therefore Ms. Bloemendaal lacked proper authority to consider my complaint at that point in the process. Ms. Bloemendaal and Mr. Lovell improperly dismissed my complaints as shown in this rebuttal.

My complaints made during the years 2004 through 2007 were inarticulate due to inexperience with the complaint process. My complaints alleged closing statement fraud (Rule 4-1.5(f)(5)), no signed contingent fee agreement (Rule 4-1.5(f)(2)), and representation against a former client on the same or substantially related matter. (Rules 4-1.7, 4-1.9, 4-1.10). Other things I complained about were subordinate, and also inartfully alleged. Ms. Bloemendaal authored four letters to me dated November 19, 2007 that ignored the essence of my former lawyers’ misconduct.

More info:

Published by: Neil Gillespie on Oct 22, 2012
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

10/24/2012

pdf

text

original

 
Via Email: tlittlew@flabar.org, and October 16, 2012U.P.S. No. 1Z64589FP291776281Theodore P. Littlewood Jr., Bar CounselACAP, The Florida Bar651 East Jefferson StreetTallahassee, FL 32399-2300REBUTTAL: Ryan Christopher Rodems; TFB File No. 2013-10,271 (13E)Dear Mr. Littlewood:This is my rebuttal to the forty-six (46) page response submitted by Mr. Rodems datedSeptember 17, 2012. In your letter to me dated October 2, 2012 you granted me permission,pursuant to my letter to you dated September 21, 2012, to file a rebuttal of up to 46 pages, thatmay refer to additional documents or exhibits, made in writing by October 16, 2012, with a copyto Mr. Rodems. Thank you for your letter of October 2, 2012. Below is my rebuttal.Opening StatementSusan Bloemendaal improperly closed my complaint against Mr. Rodems by letter November19, 2007. Ms. Bloemendaal was then, and is today, Chief Branch Discipline Counsel for theTampa Branch Office of The Florida Bar. My complaint was not processed by the centralACAP
1
complaint intake office in Tallahassee, even though I provided the complaint directly toKenneth Marvin, Director of Lawyer Regulation in Tallahassee. Mr. Marvin sent my complaintto Tampa, which was procedurally incorrect. There is a mandatory complaint intake process, setforth in the Bar Counsel Manual. The mandatory complaint intake process begins at ACAP inTallahassee. My complaint was not processed by central ACAP. Therefore Ms. Bloemendaallacked proper authority to consider my complaint at that point in the process. Ms. Bloemendaaland Mr. Lovell improperly dismissed my complaints as shown in this rebuttal.My complaints made during the years 2004 through 2007 were inarticulate due to inexperiencewith the complaint process. My complaints alleged closing statement fraud (Rule 4-1.5(f)(5)), nosigned contingent fee agreement (Rule 4-1.5(f)(2)), and representation against a former client onthe same or substantially related matter. (Rules 4-1.7, 4-1.9, 4-1.10). Other things I complainedabout were subordinate, and also inartfully alleged. Ms. Bloemendaal authored four letters to medated November 19, 2007 that ignored the essence of my former lawyers’ misconduct.The Complaint Intake Process was considered by the
Special Commission on Lawyer Regulation
chaired by Henry Cox, and is the first issue in the Report and Recommendation. (“Cox Report”).The Report was drafted by the Commission in a series of conferences ending April 18, 2006.The Cox Report states that the Commission recommended ACAP style screening of all writteninquiries and complaints so that all questions concerning the conduct of members of the bar are 
1
Attorney Consumer Assistance Program
 
Theodore P. Littlewood Jr., Florida Bar CounselRE: Ryan C. Rodems TFB File No. 2013-10,271 (13E) October 16, 2012Page 2addressed in a similar fashion. The Commission also recommended a central intake systemutilizing ACAP resources in Tallahassee.The Report’s implementation status said the proposed budget for fiscal year 2006-2007 includedfunding to implement the recommendation for central intake for ACAP style screening of allwritten complaints, and if approved in the final budget, provided funding effective July 1, 2006.In a letter dated October 3, 2012, I asked Kenneth Marvin, Director of Lawyer Regulation for theFlorida Bar, the following questions:Mr. Marvin, was a central ACAP style Complaint Intake Process implemented inTallahassee in 2006 as suggested by the Report? If not, when did the Florida Barimplement a central ACAP style Complaint Intake Process?As of today I do not have a response from Mr. Marvin. A copy of my letter appears at Exhibit 1.Mr. Rodems’ response shows at Exhibit 1 a letter from Ms. Bloemendaal dated November 19,2007. It appears from the Cox Report that my complaints in 2007 should have gone to a centralACAP style complaint intake process in Tallahassee. The reason for central intake is clear: theCommission recommended ACAP style screening of all written inquiries and complaints so thatall questions concerning the conduct of members of the bar are addressed in a similar fashion. Inother words, the Commission knew that some complaints, like my complaints against Rodemsand his partners, would not be “addressed in a similar fashion” by the Branch Office in certaininstances where the attorney was favored and politically connected.On October 2, 2012 I made a records request to Jenny R. Jolinski, Records Manager for theFlorida Bar, for a copy of the “bar counsel manual” described in the Cox Report. Yesterday,October 15, 2012, Ms. Jolinski provided me a copy of the bar counsel manual by email at 1:10p.m. The manual consists of 440 pages. Given the size of the manual, I have not had time tostudy it in detail to see if the Florida Bar complied with its own procedure in my earliercomplaints against Mr. Rodems and his partners. Therefore I may need to amend this rebuttal ormake a subsequent rebuttal once I have studied the bar counsel manual.Martha Cook Is Ethically Challenged - Henry P. Trawick Mr. Rodems’ response shows at Exhibits 2, 3 and 4, various orders from Martha Cook, a judgeof questionable ethics, according to a story published in the Tampa Tribune by ShannonBehnken on July 21, 2011: “Critics: Judge with interest in bank shouldn't hear foreclosures”.A number of Florida legal authorities have publicly criticized Martha Cook, including Henry P.Trawick Jr., a Sarasota lawyer and author of Florida's Practice and Procedure. The TampaTribune story was also profiled on The Florida Bar’s Daily News Summary July 22, 2011.Martha Cook’s Order Prohibiting Plaintiff From Appearing Pro Se was entered November 15,2010 to silence legitimate inquiry into her murky fiancees with a Brazilian billionaire whoinvested millions to bailout Martha Cook’s bank. Martha Cook recused herself sua sponte
 
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
2
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. 
2
 
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.

You're Reading a Free Preview

Download
scribd
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->