IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA

REVOLVIS CONSULTING, INC.;

Plaintiff,
vs.

Case No. 12-3795-CA

PAIGE V. KREEGEL, M.D. d/b/a KREEGEL FOR CONGRESS;

Defendant,

/
SECOND AMENDED COMPLAINT

Plaintiff, REVOLVIS CONSULTING, INC. (the "Plaintiff'), sues Defendant PAIGE V.

KREEGEL, M.D. d/b/a KREEGEL FOR CONGRESS (the "Defendant") and as causes of
action alleges:

GENERAL ALLEGATIONS

1. At all times material to the matters alleged herein, Plaintiff, was and is a foreign
corporation conducting business in this state and was conducting business in Charlotte County,
Florida.

2. The Defendant, PAIGE V. KREEGEL, M.D., is a natural person, sui juris and, based

upon information and belief, is a resident of Charlotte County, Florida, doing business as
KREEGEL FOR CONGRESS, an unincorporated entity.

3. The Plaintiff and the Defendant entered into a written agreement (the "Agreement")
wherein the Plaintiff would provide campaign consulting services (the "Services") to the
Defendant in exchange for the Defendant's payment for said services; a true and correct copy of
the unexecuted contract is attached hereto as Exhibit "I" and incorporated herein by reference.

Page 1 of5

4. The Plaintiff fully performed its obligations under the Agreement.

5. The Defendant failed to remit payment in full pursuant to the Agreement.

6. Venue is appropriate in Charlotte County, Florida.

7. All conditions precedent to the filing of this action have been satisfied or otherwise
waived.

8. Plaintiff has retained the law firm of Fowler White Boggs P.A to represent it in this
action and has agreed to pay a reasonable fee for their services. Plaintiff is entitled to recover
these fees from the Defendant pursuant to the terms of the Agreement.
COUNT I: BREACH OF CONTRACT

9. This is an action for damages that exceed $15,000.00 exclusive of interest and costs.

10. The Plaintiff realleges and incorporates by reference the allegations of Paragraphs 1
through 8 as if set forth fully herein.

11. The Plaintiff and the Defendant entered into the Agreement whereby the Plaintiff
provided the Services to the Defendant and the Defendant agreed to pay for the Services.

12. The Defendant breached the Agreement by failing to remit payment in full for the

Services as evidenced by the invoices (the "Invoices") that are attached hereto as Exhibit "2"
and incorporated herein by reference.

13. The Plaintiff has been damaged by the Defendant's breach of the Agreement.
14. The Defendant owes the Plaintiff the sum of $52,262.63 that is the unpaid balance due

under the Agreement for the Services.

15. The Plaintiff has performed all conditions precedent to be performed by the Plaintiff, and

any conditions not performed were waived by agreement of the parties or prior breach by the
Defendant.

Page 2 of5

WHEREFORE, Plaintiff, REVOL vis CONSULTING, INC. respectfully requests this

Court enter Judgment against Defendant, PAIGE V. KREEGEL, M.D. d/b/a KREEGEL FOR
CONGRESS, for:

i) Damages plus interest thereon;

ii) Costs and reasonable attorneys' fees for this action; and
iii) Such further relief as the Court may deem just and proper.
COUNT II: ACCOUNT STATED

16. This is an alternative action for damages that exceed $15,000.00, exclusive of interest and
costs.

17. The Plaintiff realleges and incorporates by reference the allegations of Paragraphs 1, 2,
and 4 through 7 as if set forth fully herein.

18. Before the institution of this action, the Plaintiff and the Defendant had business
transactions that include, but are not limited to, the months of July 2012 through August, 2012.

19. The Plaintiff rendered letters (the "Notice Letters") regarding the outstanding account
statementlinvoices to the Defendant; a true and correct copy of the letters are attached hereto as
Exhibit "3" and incorporated herein by reference.
20. Defendant did not object to the amount stated in the Notice Letters.

21. Defendant owes Plaintiffthe agreed upon sum of$52,262.63.

WHEREFORE, Plaintiff, REVOLVIS CONSULTING, INC. respectfully requests this

Court enter Judgment against Defendant, PAIGE V. KREEGEL, M.D. d/b/a KREEGEL FOR
CONGRESS, for:

i) Damages; and
ii) Such further relief as the Court may deem just and proper.

Page 3 of5

COUNT III: OPEN ACCOUNT

22. This is an alternative action for damages that exceed $15,000.00, exclusive of interest and
costs.

23. The Plaintiff realleges and incorporates by reference the allegations of Paragraphs 1, 2,
and 4 through 7 as if set forth fully herein.
24. The Defendant requested and Plaintiff agreed to provide the Services to the Defendant.

25. The Plaintiff did provide the Services requested by the Defendant.
26. The Defendant owes the Plaintiff the agreed upon sum of $52,262.63 according to the

Invoices attached hereto as Exhibit "2."

WHEREFORE, Plaintiff, REVOLVIS CONSULTING, INC. respectfully requests this

Court enter Judgment against Defendant, PAIGE V. KREEGEL, M.D. d/b/a KREEGEL FOR
CONGRESS, for:

i) Damages; and
ii) Such further relief as the Court may deem just and proper.
COUNT IV: UNJUST ENRICHMENT

27. This is an alternative action for damages that exceed $15,000.00, exclusive of interest and
costs.

28. The Plaintiff realleges and incorporates by reference the allegations of Paragraphs 1, 2,
and 4 through 7 as if set forth fully herein.
29. The Plaintiff provided the Services to the Defendant.
30. The Defendant had actual or constructive knowledge that the Plaintiff was providing the

Services and never objected to the Plaintiff.

Page 4 of5

31. The Defendant received a benefit from the Plaintiffs Services but has not paid in full for
them.

32. The Plaintiff did not provide the Services gratuitously, and the Defendant had actual or
constructive knowledge of that fact.

33. The Defendant shall be unjustly emiched if allowed to benefit from the Plaintiffs
Services without paying for them.

34. The Plaintiff has no prompt, sufficient, and adequate and complete remedy at law that
would promote the ends of justice as an action in equity.

WHEREFORE, Plaintiff, REVOLVIS CONSULTING, INC. respectfully requests this

Court enter Judgment against Defendant, PAIGE V. KREEGEL, M.D. d/b/a KREEGEL FOR
CONGRESS, for:

i) Damages in the amount equal to the costs of the Services; and

ii) Such other and further relief as the Court may deem as just and equitable.
FOWLER WHITE BOGGS P.A. P.O. Box 1567 Fort Myers, FL 33902 (239) 334-7892 Fax No: (239) 334-3240

~~&~ By:---~
Corris L. McIntosh, Jr. Florida Bar No: 0052352 corris.mcintosh@fowlerwhite.com
45144827

Page 5 of5

, "'-VOiVIS~
Proposal for Consulting Services
Revolvis Consulting, having its principal place of business at 1029 K Street, Suite 44, Sacramento, CA 95814 (hereinafter "RevolvisU), appreciates the opportunity to submit a proposal to provide campaign consulting services to Paige Kreegel for Congress (hereinafter "Client") for the 2012 election cycle. The
entire team of Revolvis is available to advance your interests and is committed to providing the highest

~".'..'

level of service in furtherance of your goals. This proposal will describe the terms under which that
representation would occur.

1. Scope of work. Revolvis shall, as an independent contractor, at the general direction and with
the approval of Client and for the direct benefit of campaign on behalf of Client:

a. Prepare and implement a political campaign plan and campaign budget; b. Provide primary consultative supervision of the organization, management and direction of

the campaign, in conjunction with the manager, consulting team and Client;
c. Write, design and produce all direct mail, television, radio, print, and online voter contact;

d. Select and supervise vendors of goods and services to the campaign;

e. Perform or oversee other services which may include, but not be limited to, any or all of the following: strategy development; research (including opposition research); polling; coalition

building; supervise press officer and operations; provide where appropriate, direct press
contact; develop advertising concepts; if requested, produce and place with appropriate media all electronic communications;

f. Comply with the requirements of appropriate campaign reporting practices and law as
defined in paragraph 2(b) of this agreement.

Z. Obligations of Client. In addition to all the terms and conditions of this agreement, Client
specifically notes the provisions and agreements contained in a) and b) below:

a. Client acknowledges that it has been advised to seek the assistance of an attorney or other
qualified professional to ensure compliance with the requirements of campaign reporting

practices and law, as defined hereinafter.

b. As used in this agreement, the phrase "campaign practices and law" means any law, statute, regulation, ordinance, rule, resolution, other enactment, advisory opinion, judicial ruling or other action by any federal, state or local government unit, agency or political subdivision that, on its face or as applied, requires the reporting or disclosure of campaign contributions or expenditures, or both, or that regulates the campaign practices for any elective office or measure, of political committees or of other persons or entities engaged in political activity, or any liability sought to be imposed by any governmental unit, agency or political subdivision, or by any person for libel, slander, defamation, invasion of privacy or any other conduct under the statute or case law of any United States state, district, territory, commonwealth or other jurisdiction.

3. Fees. In exchange for these services, Client agrees to pay Revolvis:

a. Retainers i. Revolvis will send an invoice on the first of each month and payment is due by the

end of each month. C to the performance of this work will

_.'-'- -

"VOlVIS~
be billed in addition to the monthly retainer, and these costs may include travel and other expenses incurred on Client's behalf. No monthly costs that in the aggregate exceed $500 will be incurred without prior approvaL. i. $2,500 per month beginning January 1, 2012. b. Commissions i. Revolvis will receive 10% commission on direct mail, electronic media, and other
voter contact produced on behalf of Client.

c. Performance bonuses
i. If Client wins Republican nomination, Client agrees to pay Revolvis a $20,000 bonus payable within 60 days of election; ii. If Client is elected to office, Client agrees to pay Revolvis a $10,000 bonus payable within 90 days of election. d. Opportunity costs
i. If Client drops out of the race prior to the filing deadline, Client will pay Revolvis

$5,000 in opportunity costs;

ii. If Client drops out of the race after the filing deadline, Client will pay Revolvis

$10,000 in opportunity costs; e. Termination i. This agreement would proceed on a month-to-month basis and may be terminated by either party with 30 days written notice; ii. Client and Revolvis agree that contract automatically terminates upon the Clients election or defeat.
4. Vendor costs and payments. Based upon the budget approved by Client, Revolvis may contract with vendors for goods and services for Client's campaign.

5. Consultant's diligence; no warranty of success. Revolvis shall use best efforts and diligence in performing the services required by this agreement. Revolvis makes no warranty, expressed or implied, as to the results of the services provided or any future services that may be contracted.
6. Itemization of expenditures. Revolvis and its agents shall furnish Client full itemization of all

expenditures, including copies of original receipts if requested by Client, made and accrued with
respect to this agreement, in a timely fashion consistent with relevant campaign reporting procedures and deadlines. Neither Revolvis nor its agents shall assume any liability for Client's

obligation to properly comply with relevant campaign reporting and practices laws.

7. Indemnification. Client and Revolvis, their agents and employees, shall hold each other
harmless from any and all liability arising from or related to the campaign or any and all liability

arising from any act or omission, including active or passive negligence, or related to any
requirements imposed on the Client or Revolvis, by any campaign reporting and practices laws,

which arises from any act or omission, including active or passive negligence.

8. Simultaneous services by Revolvis to other campaigns. Client acknowledges its understanding

that Revolvis is engaged in the business of political campaign consulting and public relations and during the performance of this agreement Revolvis may be actively involved in furnishing services similar to those provided by this agreement in political campaigns for other candidates

Page 2 of4

~E~VO-lVIS;
and issues. Revolvis shall not be limited in any way in performing services for other clients that are not in direct conflict with the discharge of its obligations under this agreement.

9. Termination. Revolvis and Client have the right to terminate this agreement on thirty (30) days written notice, except that Client may only terminate this agreement upon payment and
settlement of all fees, vendor and service invoices currently due and provision settlement of

remainder fees per Section 4 above. Commissions are deemed to have been earned, due and
payable as of the date Revolvis contracted or ordered with any vendor to provide goods or services pursuant to this agreement or, in the case of media and slate commissions, as of the date the media was placed or slate reserved, as those phrases are known and understood in the

advertising industry.
10. Attorney's Fees. Prevailing party on any legal action to enforce the contract will be entitled to their reasonable attorney's fees and costs.
11. Ownership of work product; limited license to use. All work of Revolvis, including but not

limited to print copy, audio copy, audio and video tapes, any and all lists and data files
developed or created, themes, designs, slogans, and any and all other creative products of Revolvis, its agents or employees, are and shall be the joint property of Revolvis and Client.

12. Confidentiality. Revolvis agrees to maintain the confidentiality of Client's information, including but not limited to research conducted by Revolvis or a vendor of Revolvis on Client.

13. Complete Agreement. This Agreement is the complete agreement of the parties and supersedes any previous agreements, whether written or oral, between the parties. No agreement or understanding, oral or written, in any way modifies the terms and conditions set forth herein,
unless noted as an addendum to this contract, dated after this contract, and signed by a partner of Revolvis.

14. Jurisdiction and Governing law. Any action for break of this Agreement, for enforcement of this

Agreement, or for any cause of action purported to arise out of this Agreement must be commenced in a court of competent jurisdiction in the state of California. Each party agrees that
California is the proper forum state for the commencement of any legal action by any party to the Agreement. Each party further agrees to submit to the in-person am jurisdiction of the court in which an action is commenced.

Page 3 of4

f~iiFORMAnON

-4

Invoice
Revolvis Consulting, Inc.

7185 Navajo Road, Suite P

San Diego, CA 92119

Date

Invoice No.

08/22/12

R12-08-107

Bill To:
Paige Kreegel for Congress

Description
VOIP Minutes Used: July - August 15 - 8,725.3 minutes used @ $.035 per minute

Amount

305.39

Please include the invoice number on your check. Tha

Total

$305.39

Invoice
Revolvis Consulting, Inc.

7185 Navajo Road, Suite P

San Diego, CA 92119

Data

Invoice No.

08/13/12

R12-08-058

BmTo~

Paige Kreegel for Congress

PK08 "Illegal Immigration" Design Only 825.00

e$cription Amount

Please include the invoice number on your check. Thank you. Total' $Z!.)\O

Invoice
Revolvis Consulting, Inc.

7185 Navajo Road, Suite P

San Diego, CA 92119

Date

Invoice No.

08/07/12

R12-08-050

Siiit,
Paige Kreegel for Congress

August 4, 2012 TeleForum: 3,480.60

pescription . Amount - 49,405 Dials - 608 Inbound Minutes

Please include the invoice number on your check. Thank you. ittal' $3,4.80.00

Invoice
Revolvis Consulting, Inc.

7185 Navajo Road, Suite P

San Diego, CA 92119

Date

Invoice N\).

08/07/12

R12-08-049

Bill To:

Paige Kreegel for Congress

PK10 "Jllegals" (ihcludes printing and design) 7,976.07

Quantity: 52,010 Postage = $12,076.61

D~scri!Jtion Amount

Total cost of piece = $20,052.68

Please include the invoice number on your check. Thank you. Total $1;916,(1),1

Invoice
Revolvis Consulting, Inc.

7185 Navajo Road, Suite P

San Diego, CA 92119

Date

Invoice No.

08/07/12

R12-08-048

Bill To:

Paige Kreegel for Congress

.- l)sgi;jptron f\,mmmt

PK09 "Debt Clock" (includes printing and design) 8,291.29

Quantity: 55,000 Postage = $12,076.61 PAID DIRECTLY TO MAIL HOUSE

Total cost of piece = $20,367.90

Please include the invoice number on your check. Thank you. Total $$.,291.29

Invoice
Revolvis Consulting, Inc. 7185 Navajo Road, Suite P San Diego, CA 92119
Date
Invoice No.

08/01/12

R12-08-010

Bill To:

Paige Kreegel for Congress

Consulting Fee - August 2,500.00

Description . Artiount

Please include the invoice number on your check. Thank you. votal $2,500.00

Invoice
Revolvis Consulting, Inc. 7185 Navajo Road, Suite P San Diego, CA 92119
Date
Invoice No.

08/22/12

R12-08-113

Billra:
Paige Kreegel for Congress

FL CD 19 Polling: July 23, July 24, July 26 1,148.99 FL CD 19 Polling: July 30, July 31, Aug, 1 and Aug 2 1,530.64 FL CD 19 Pollng: Aug 6, Aug 7 and Aug 8 1,217.65

Description Amount

Please include the invoice number on your check. Thank you. ..1ttal' . $r,91.2g
~d .,','"'

Revolvis Consulting, Inc.

Invoice
Ihvoice NO.

7185 Navajo Road, Suite P

San Diego, CA 92119
12/13/12

R12-12-015

Paige Kreegel for Congress

Television and Radio Production Services Provided by Magma Creative Pnmary Election

5,955.00

2012
- Project: 1 x :60 WEB AD campaign piece

-Project: 1 x :30 lV campaign piece - Project: 1 x :30 lV Kreegel Spot 2 "Experienced Leader" - Project: 1 x :30 lV Kreegel Spot 3 "Send a Grown Up to Washington"
- Project: 1 x :30 Kreegel Radio campaign piece; utilizing stock & editing audio
***DUE UPON RECEIPT***

7,974.00 7,405.00 1,555.00 2,098.00

Please include the invoice number on your check. Thank you.

FOWLERe
Certified Article Number
Attorney,arL.1v "\Vr' ITE BOGGS ESTI943 wH

7196 9008 9111 3099 0799

SENDERS RECORD
CERTIFIED MAiV' RETURN RECEIPT REQUESTED

November 30, 2012

Paige V. Kteege1, M.D. d/b/a Kreegel for Congress

3821 B Tamiami Tral, No. 321

Port Charlotte, FL 33952

Re: IO-Day Demand Letter for Collection of Unpaid Invoices

Creditor: Revolvis Consulting, Inc. Debtor: Paige V. Kreegel, M.D. d/b/a Kreegel for Congress
To whom it may concern:

Please be advised that this firm represents your creditor, REVOL vis
CONSULTING, INC. ("REVOLVIS"), with respect to its business transactions with
you, Paige V. Kreege1 d/b/a Kreegel for Congress (the IiDebtor") and the collection of

the unpaid invoices (collectively, the "Invoices" and attached hereto as Exhibit "A")

that were billed to an account (the" Account") issued to the Debtor.

The amount due on the Account has not been paid despite repeated requests. As
of the date of this letter, the open balance for the lnvoices is $24,775.63. It has come to

my attention that you have not denied the above-stated amount that is due and owning,
but rather requested my client settle for less by accepting the remaining funds left in the

account for the campaign (as stated in the correspondence attached hereto as Exhibit
liB").

FOWLER WHITE BoGGS P.A.

TAMP A . FOR T Jvf Y Il S . TAL L A HAS S .E E . J A C lOON V i L L E . F OR T LA U D E R D A L .

2235 FIRST STREET. FORT MYERS, FL 3390 I . P. O. Box t 567 . f:ORT MYERS, FL 33902 TELEPHONE (139) 334-7B92 . FAX (239) 334.3240 . www.fowlerwhite.com

REVOL vis CONSUL TINC, INC.

Page 2

PLEASE BE ADVISED that demand is hereby made for payment in full of said

amount. If the outstanding balance is not paid within TEN (10) days of receipt of this

letter, I will have no altemative but to initiate appropriate actions to collect funds due
and owing.
If you agree to resolve the matter, remit the amount due of $24,775.63 in certified

funds payable to Fowler White Boggs P.A. Trust Account. Upon receipt and clearance,

a release will be provided. In the event I do not timely receive payment, my client has
instructed me to seek any and all remedies available to it at law and equity to collect the

outstanding balance on the Account.

PLEASE GOVERN YOURSELVES ACCORDINGLY.

Yours trulyi
Fowler White Boggs P.A.

~vl!$L
Corris L. McIntosh, Jr., Esq.
CLMJ/ch Enclosures as stated cc: Regular Mail/Client/2081 Sandy Pines Dr., Pwita Gorda, FL 33982
45085583

FOWLER WliiTE BOGGS P.A.

TAMPA. FORT MYERS. TALLAHASSEE. JACKSONVILLE. FORT LAUDERDALE

Invoice
Revolvis Consulting, Inc.

7185 Navajo Road, Suite P

San Diego, CA 92119

!Date

InyoieeNID',

08/22/12

R12-08-107

,BiUTC?,

Paige Kreegel for Congress

VOIP Minutes Used: July - August 15 305.39

;1J~~~i~~jeJtt Amount - 8,725.3 minutes used @ $.035 per minute

Please include the invoice number on your check. .~, ~ fQtti~ $'3t1.11!~3$
... EXHIBIT ,..... ._-. g ~ ~

~ - _.. .. --...

Invoice
7185 Navajo Road, Suite P
San Diego, CA 92119
Revolvis Consulting, Inc.
Date
Invoice No.

08/13/12

R12-08-058

6m"1fii

Paige Kreegel for Congress

PK08 KlIlagal Immigration" Design Only 825.00

'~~S~~P11~ia Am(,l!\it

";-'. .

~-,-" -' --

Please include the invoice number on your check. Thank you. ~ . ",'t .":1f:.Qf!tW--: *tl~~.(1;
_.._"c.,'_..."'.d'- . .". ~ --

Invoice
Revolvis Consulting, Inc. 7185 Navajo Road, Suite P San Diego, CA 92119
Qat~
Invoice N1l.

08/07112

R12-08-050

. ....

'lBilVt:rlf .,; ..... . . ..

Paige Kreegel for Congress

" .' .-

August 4, 2012 TeleForum: 3,480.60

-- ., -, .. --,' ...:.. ....... .." ,@~,lji~1i;~lit i -rn(i)lJimt - 49,405 Dials - 608 Inbound Minutes

Please include the invoice number on your check. Thank you. ., n;:'Qtt;l $$,.4a',t)f
,..... -.

Invoice
Revolvis Consulting, Inc. 7185 Navajo Road, Suite P San Diego, CA 92119
Date
;lnvoiCe ....... -.N. ..

08/07/12

R12-08-049

:l!liJnfl~. ,

Paige Kreegel for Congress

,.. '. Amount

PK10 "I!legals" (includes pnnting and design) 7,976.07

Quantity: 52,010 Postage ~ $12,076.61

,.

roe~l!i@tj()h

Total cost of piece = $20,052.68

Please include the invoice number on your check. Thank you. i;itrif .$!1',9;7:@,;1'
..'

Invoice
Revolvis Consulting, Inc. 7185 Navajo Road, Suite P San Diego, CA 92119
Dat

ItwiceNo.

08/07112

R12-08-048

if3i11lat ..

Paige Kreegel for Congress

PK09 "Debt Clock" (includes printing and design) 8,291.29

Quantity: 55,000 Postage = $12,076.61 PAID DIRECTL Y TO MAIL HOUSE

-. ~ .

;f!l~iile;;ilj~'lfP_ Arrioi,mt

Total cost of piece = $20,367.90

Please include the invoice number on your check. Thank you. tt~i: '$lil.~29'~;~$f
--,.

Invoice
Revolvis Consulting, Inc.

7185 Navajo Road, Suite P

San Diego, CA 92119

Date

ItivoiGe N.

08/01/12

R12-08-010

;IBIII '1fGJl

Paige Kreegel for Congress

Consulting Fee - August 2,500.00

-. DSSIi~,. Ameant. ~ .". _ ~,r .-"~",.':\ ".:-:.~-..- . '...

Please include the invoice number on your check. Thank you. 11'rat $-2,OJilO

.. - --

Invoice
Revolvis Consulting, Inc.

7185 Navajo Road, Suite P

San Diego, CA 92119

Date

Invoioe No.

08/22/12

R12-08-113

:am\illi: "~,'i'
;. .,.'. .,i~:---:" ,. ."

Paige Kreegel for Congress

FLCD 19 Polling: July 23, July 24, July 26 1,148.99 FLCD 19 Polling: July 30, July 31, Aug, 1 and Aug 2 1,530.64 FLeD 19 Polling: Aug 6, Aug? and Aug 8 1,217.65
., ..

.' " llir:tliJin~ ;1rl~e~Jllqm' " .'

". ,....'. "-,,.

Please include the invoice number on your check. Thank you. i:'~:Cf. ,'. Alttli ., ;$~~~7c;\~'$ ~:. ' - ...:.", ;'-:'. -.,. ".... '-~,."".-.' . .:-".

~han H. Andranian. Esq.

From:

Sent:
To:

Jason (abel Roe ..:jroe@jroe.org:::. Thursday, September 06, 20124:41 PM

Andranian Stephan
Fwd: Kreegel Aging as of 8/30

Subject:

Jason Cabel Roe I Revolvis Consulting

(800) 916-1770 I www.revolvis.com

Begin forwarded message:

From: Valerie Ashurst Dichiara -=:::varerie@revolvis.com~

Subject: Fwd: Kreegel Aging as of 8/30 Date: September 5,20125:13:16 PM PDT

To: jroe Roe -=:::jroe@ iroe.org~
Valerie Ashurst Dichiara I Revolvis Consulting I Partner Sacramento l San Diego I Seattle I Washington, DC C: 916-997-5029 I E: valerie@revolvis.com I W: www.revolvis.com

Begin forwarded message:

From: Paige Kreegel c::::kreegel@yahoo.com:::o-

Subject: Fw: Re: Kreegel Aging as of 8/30 Date: September 5,20125:10:23 PM PDT To: valerie@revolvis.com, DarolCarr c::::dcarr@farr.com~
Cc: limerick16317@embargmail.com
Valerie,
This seems to be a good time to address this issue, as there are vastly more invoices "generated" by Revolvis and their associated media companies than there is cash in the campaign account to pay for them.

There is about seven-thousand and change in the account.

While I fully expect Jason to have some different point of view, at the end of the day, the only question to me is, how would you like to have that amount dispensed? EXHIBIT

,,\ R,H '-.J

The usual matter of releases, etc. would need to be addressed.

I have forwarded a copy of this to my attorney Darol Carr (dcarr@farr.com) and a copy to Vickie as welL.

Paige

--- On Wed, 9/5/12, Michael & Vickie Potts .climerick16317@embarqniail.com~ wrote:

From: Michael & Vickie Potts -climerick16317@embarqmaii.com~ Subject: Re: Kreege1 Aging as of 8/30 To: "Valerie Ashurst Dichiara" -cvalerie@revo1vis.com/ Cc: "Kreegel" -CKreege1@yahoo.com?
Date: Wednesday, September 5, 2012, 10:53 PM

Valarie; I forwarded your request to Paige Kreege1

----- Original Message ----From: Valerie Ashurst Dichiara -cva1erie@revolvis.coID/

To: Vickie Potts -Cliinerick16317@embarqmail.com~

Cc: Matt Dobler -cmatthew.dobler@gmai1.com:::=--, jroe Roe .groe@jroe.org:::=--

Sent: Wed, 05 Sep 2012 15:34:50 -0400 (EDT) Subject: Re: Kreegel Aging as of 8130
Hi Vickie, Can you give me a status update on payment?
Thank you,

Valerie Ashurst Dichiara I Revolvis Consulting I Partner Sacramento I San Diego I Seattle I Washington, DC c: 916-997-5029 I E: valerie@revolvis.com I W: www.revolvis.com

On Aug 30,2012, at 3:03 PM, Valerie Ashurst Dichiara wrote:

Hi Vickie, Attached is the aging report for Kreege1. Please give me a status update on payment. If you need any of the invoices resent please let me know.
Thank you,

-cKreege1 Aging as of 8:30.xIsx/

Valerie Ashurst Dichiara I Revolvis Consulting I Partner Sacramento I San Diego I Seattle I Washington, DC C; 916-997-5029 I E: valerie@revolvs.com I W: www.revolvs.com

-- Vickie Potts (cell) 941-457-7793

limerick16317@embarqmail.com

" 111111 III/ ""11111'" I

7196 9D08 9111 3099 D799
lt3"
~:Service Type CERTIFIED MAILTM

D. I. delivery address different from Iem 1? li VES, enler delivery address below:

x~,c. Signature

DAgent DAddressee DVes DND

i~,i:ieslrcted Delivery? (Extra Fee)

1. Article Addressed to:

DYes

Paige V. Kreegel, M.D. d/b/a Kreegel for Congress

3821 B Tamiami Trail, No. 32 i

Reference Information
7120237 Carris L. McIntosh, Jr.

Port Charlotte, FL 33952

PS Form 3811, January 2005

Domestic Return Receipt

Certified Article Niiinber

FOWLER_
A"o,",~~'i~\; WHITE BOGGS
December 17, 2012

7196 9008 9L11 3099 0829

SENDERS RECORD
CERTIFIED MAIL/ RETURN RECEIPT REQUESTED 71969008911130990829

Paige V. Kreegel, M.D. d/b/a Kreegel far Congress c/a Daral H.M. Carr, Esq. 99 Nesbit Street Punta Gorda, FL 33950

Re: 10-Day Demand Letter for Collection of Unpaid Invoices

Dear Mr. Carr,

Please be advised that this firm represents REVOL vis CONSULTING, INC.

("REVOL ViS"), with respect to its business transactions with your client, Paige V.

Kreegel d/b/a Kreege1 for Congress ("Kreegel") and the collection of the unpaid
invoice (the "Invoice"; attached hereto as Exhibit II A") that was billed to an account (the

"Account") issued to Kreegel.

The Invoice amount has not been paid despite repeated requests. As of the date

of this letter, the open balance for the Invoice is $24,987.00. This amount is in addition

to the unpaid balance stated in my letter to Kreegel dated November 30, 2012.
PLEASE BE ADVISED that demand is hereby made for payment in full of said

amount. If the outstanding balance is not paid within TEN (10) days of receipt of this

letter, I will have no alternative but to initiate appropriate actions to collect funds due
and owing.

FOWLER WHITE BOGGS P.A.

TAMPA. FORT MYERS. TALLAHASSEE. JACKSONVILLE. FORT LAUDERDALE
2235 FIRST STREET. FORT MYERS. FL 33901. P.O. Box 1567. FORT MYERS, FL 33901 TELEPHONE (239) 334,7892 . FAX (239) 334.3240 . www.fowlerwhite.com

REVOL vis CONSULTING, INC.

Page 2

If you agree to resolve the matter, remit the amount due of $24,987.00 in certified

funds payable to Fowler White Boggs P.A. Trust Account. Upon receipt and clearance,

a release will be provided. In the event I do not timely receive payment, my client has
instructed me to seek any and all remedies available to it at law and equity to collect the

outstanding balance on the Account.

PLEASE GOVERN YOURSEL VES ACCORDINGLY.

Yours truly,
Fowler White Boggs P.A.

Corris L. McIntosh, Jr., Esq.

CLMJ/ch Enclosures as stated cc: Regular Mail/Client

~r

45116499

FOWLER WHITE BOGGS P.A.

TAMPA. FORT MYERS' TALLAHASSEE' JACKSONVILLE. FORT LAUDERDALE

7185 Navajo Road, Suite P

San Diego, CA 92119

Revolvis Consulting, Inc.

Invoice
Date
Invoice No.

12/13/12

R12-12-015

Bill To:

Paige Kreegel for Congress

Description
Television and Radio Production Services Provided by Magma Creative Pnmaiy Election

Amount

5,955.00

2012
- Project: 1 x :60 WEB AD campaign piece -Project: 1 x :30 TV campaign piece

- Project: 1 x :30 TV Kreegel Spot 2 "Experienced Leader"

- Project: 1 x :30 TV Kreegel Spot 3 "Send a Grown Up to Washington" - Project: 1 x :30 Kreegel Radio campaign piece; utilizing stock & editing audio
"""DUE UPON RECEIPT......

7,974.00 7,405.00 1,555.00 2,098.00

i eXHIBIT
~
~

"A."
Total
$24,987.00 I

Please include the invoice number on your check. Thank you.