IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT

IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
GENERAL CIVIL DIVISION
NEIL J. GILLESPIE,
Plaintiff, CASE NO.: 05-CA-7205
vs.
BARKER, RODEMS & COOK, P.A., DIVISION: C
RECEIVED
a Florida corporation; WILLIAM
J. COOK,
JUN 14 2010
Defendants.
CLERK OF CIRCUIT COURT
--­ / l-iILLSBOROUGH COUNTY. FL
PLAINTIFF'S MOTION FOR STAY PENDING ADA DETERMINATION
Plaintiff pro se, Neil J. Gillespie, moves the Court for an Order to Stay all
proceeding pending a determination of his ADA accommodation request, and states:
1. Plaintiff provided his ADA accommodation request (ADA Request), and ADA
Assessment and Report by Ms. Karin Huffer, MS, MFT, (ADA Report) to Mr. Gonzalo
B. Casares, ADA Coordinator for the 13th Judicial Circuit by hand delivery February 19,
2010. Plaintiff also provided Mr. Casares a completed and signed ADA Request for
Accommodations Form for the 13th Judicial Circuit. Courtesy copies of the documents
were provided to Judge Barton. ADA is an administrative function. As such copies of the
documents were not provided to Defendants, nor is this considered ex parte
communication.
2. Ms. Huffer noted the following about the ADA Report: "This report is to be kept
under ADA Administrative confidential management except for use by the ADA
Administrator revealing functional impairments and needed accommodations
communicated to the Trier of Fact to implement administration of accommodations. This
information is NOT to become part of the adversarial process. Revealing any part of this
report may result in a violation ofHIPAA and ADAAA Federal Law."
3. Mr. Casares notified Plaintiff by email April 14, 2010 (relevant portion) "Your
request is not within our nleans to resolve and was referred to the Legal Department for
the appropriate course of action." In an email to Plaintiff May 4, 2010, Mr. Casares wrote
(relevant portion) "The medical file was never within our department's means to help and
was handed over to Legal." Plaintiff assumes the "medical file" is the ADA Assessment
and Report by Ms. Karin Huffer, MS, MFT, (ADA Report). As of today the Legal
Department, also identified as David Rowland, has not responded.
4. The completed and signed ADA Request for Accommodations Form for the 13th
Judicial Circuit Plaintiff submitted noted the following under (6) special requests or
anticipated problems (specify): I am harassed by Mr. Rodems in violation of Fla. Stat.
section 784.048..Mr. Rodmes is relentlessly harassing Plaintiff as shown by the record.
Exhibit '4A" is an example of Mr. Rodems' bizarre behavior in another case, his comments
about Eric Bischoff, a witnesses in Wrest/eReunion, LLC v. Live Nation, Television
Holdings, Inc., United States District Court, Middle District of Florida, Case No. 8:07-cv­
2093-T-27, trial August 31-September 10,2009. Mr. Rodems and his client failed to
prevail at trial. This is an example of Rodems' bizarre and harassing behavior toward
another participant in litigation. It is ruthless and wrong.
WHEREFORE, Plaintiff respectfully moves this Court for an Order to Stay all
proceedings and tolling of time pending a detennination of his ADA accommodation
request.
Page - 2
RESPECTFULLY SUBMITTED this 14
th
day of June, 2010.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been furnished by US mail
to Ryan Christopher Rodems, Attorney, Barker, Rodems & Cook, P.A., 400 North Ashley
Drive, Suite 2100, Tampa, Florida 33602, this 14
th
day of J
Page - 3
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sal COlTeflte of WrestieReunloo had a lawsuit against Clear Channel/Live Nation because they reneged on a
contract with him. The case went before a jury and Mr. Corrente lost the case, which many feel was unjust.
But Eric Bischoff made a statement on wrestlezone.com, whim is below, that caused sal's lawyer to send his
statement:
In my last post regarding the WrestleReunion/Live Nation lawsuit, I suggested that Bill Behrens and Eric
Bisdloff were expert witnesses for WrestleReunion. That was not the case as they were actually witnesses
for the Clear Channel/Live Nation side. I just spoke with Eric Bischoff who said he agreed to be an expert
witness after reading and taking Interest in the case, however he was not called to the stand.
"The case was wrapped up quickly," Bischoff told Wrestlezone.com, "the jury didn't waste any
time and came bacll with what 1 felt was the correct decision ".
Eric was happy with the outcome, to say the least. "Rob Russen and Sal Corente 111ft t:Ite wrestlllJ(l
business a bad nllme, n he SDtted, "so I'm 1I111d justice prevlliled lind t:Ite bottom feeders didn't win
one".
Bischoff wanted to make sure that everyone knew his comments and opinions were solely his and did not
reflect those of Clear Channel/Live Nation.
In regards to the above statement. we have a statement from Mr. Corrente's lawyer:
"It is odd that Eric Bischoff, whose well-documented incompetence caused the deml.. of WCW,
should have any comment on the outcome of the Wrestl....unlon, LLC lawsuit. 'Jbe .xpert report
BllIChoff submitted In this CHe bordered on 1IIlteracy, and Bischoff w.. not ev.n called to testify
by aur Otannel/Uve Nation because BI8chofr perjured himself In a d.posltlon In late-July 2009
before running out and refusing to a__any more quutlo.,. rwgardlng his .-Ioua problems
with alcohol and ..xual deviancy at the Gold aub while the '-d of WCW. To even sit In the
room and qu.-tlon him was one of the moat dlstasWul things I've ever had to do In 17 yurs of
practicing law. In fact, we understllnd that B1echoff _s afraid to even come to Tampa and
tutIfy because he _uld have to answer questionll under oath for a third time about his
embarra..lng past.
The SlId state of profesalonal wrestling today Is directly attributable to this snake 011 .....man,
WhOA previous ca....r highllghtllindude seiling meat out of the back 01 a truck, befora he filed
bankruptcy and had his car repo...-ed. Today, after running WCW Into the ground,
Bischoff peddl.. schlock Ilk. "Girls Gone Wild" and reality sho_ featuring 8-lIsten.
Sal Corrente, on the other hand, has always been an honorable man, and h. delivered on every
proml.. and paid every wrestler while ataglng the th.... W..-lIeReunlon eventll. Unlike the
cowardly Bischoff, Mr. Corrente took the stand In this ca... AIthoU9h his company did not
prevail, sal Corrente proved that he WIIS man enoU9h to ftght to the finish -- something Bischoff
could never understand."
Sincerely,
Ryan Christopher Rodems
Barker, Rodems • Cook, P.l'.
400 North Ashley Drive, Suite 2100
Tampa, Florida 33602
813/489-1001
E-mail:
We just wanted to give Mr. Corrente's lawyer a chance to speak his mind.
Since I have always had wrestlers autograph signings as a speciality for any website I worked for, I know for
sure, Mr. Corrente is an honest promoter who has NEVER stiffed a wrestler working tor hiS shows or
conventions. I would have heard about it.
There are many promoters who do that in this business, which is very sad.
1M itJfotm.tioo 00 ttl'- Mtebli,. i$ excJu$ive ptop«ty oIlhe Dedendion of Independenls end cannot be uNd "..whete linlc CIWdit. .AJJ 001 pun;ha3W
ate ltOft.(fffundllble "" mltiJ teJee:tronJc 01' pO"') ..", to 1M 001 becomes ptOperty of the OOI.-triM _.10... thiI 001 to r."rlnt t1Ntf e.m.JlIn II'a enltWl)' by doing so. 11
the 8IMi is COtI$tdet.el
112812010 http://www.declarationofmdependents.net/doi/pageslcorrente910.html

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