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PART ONE (See Page 1, PART ONE - Required Information.): Your Name: Ir / Organization: Q Address: &A1 _ State: City: Zip Codef^? 1 Phone:^/? ^55J^ 6,3 Email: ACAP Reference No. — Attorney's Name: Address: City: State: Zip C o d e g g f Telephone: >/? -

PART TWO (See Page 1, PART TWO - Facts/Allegations.): The specific thing or things I am complaining about are-

JUL 1 6 2012
i he Honda Ba-- ACAP

PART THREE (See Page 1, PART THREE - Witnesses.): The witnesses in support of my allegations are: [see attached sheet].

PART FOUR (See Page 1, PART FOUR- Signature.): Under penalties ofp/fjptry, true, correct and complete.

I declare that the foregoing facts are





July 10,2012

Mr. Michael Pinson 146Dunbar Ave SteD Oldsmar, FL 34677 Re: Mr. Paul Marshall Phillips; RFA No. 12-21845

JUL 1 6 2012
The Florida Bar- ACAP Tallahassee Florida


Dear Mr. Pinson: The Supreme Court of Florida has adopted rules that require the allegations be signed and under oath. In order to comply with this rule you must sign the oath below and return it to us by July 20,2012 before we can proceed with an investigation. Under penalty of perjury, I declare that the facts contained in the inquiry submitted to The Florida Bar concejning Mf) Phillips are true, correct and complete. , Mr. |vlichael Pinson / Date

you do not complete and return the oath form to us, we may be unable to proceed with the investigation. A copy of the rule imposing this obligation (3-7.3(c)) may be found on the Bar's web site at Also, if you have documents that you feel support your allegations, please provide copies of them when you return the oath. Thank you for your cooperation. Sincerely,

Anne-Marie Martinez, Bar Counsel Attorney Consumer Assistance Program ACAP Hotline 866-352-0707

Michael Pinson
146DunbarAve#D Oldsmar, FL 34677 (813) 855-3663 office

VIA FEDERAL EXPRESS July 2, 2012 The Florida Bar Attorney/Consumer Assistance Program (ACAP) 651 East Jefferson Street Tallahassee, FL 32399-2300 RE: Formal complaint of misconduct against attorney Paul Phillips, FL Bar #41888 Dear Ladies and Gentlemen, The factual basis for this complaint arises from attorney Paul Phillips fraudulent willful and contrived misrepresentations. In July 2010,1 contacted attorney Paul Phillips for legal advise regarding a blogger who was relentlessly harassing and defaming me and my company online. After consulting with Mr. Phillips and disclosing privileged and confidential information regarding my case with him, he advised me that I had "no case" against the perpetrator of these illegal acts and he attempted to dissuade me from pursuing further legal action against the blogger. Months later, I learned that Mr. Phillips had deceived me, intentionally made false statements and failed to disclose a conflict of interest he held with the blogger, whom is now his client. The allegations here regarding attorney Paul Phillips are summarized as follows: 1. Numerous, Multiple and Repeated Instances of Unprofessional and Unethical Behavior 2. Acts of Moral Turpitude including Extortion, Dishonesty, Untruthful Means, Lack of Candor 3. Representing Conflicting Interests; Failure to Disclose a Conflict of Interest 4. Fraudulent Willful & Contrived Misrepresentations 5. Acted with Oppression, Malice, and Fraud 6. Professional Misconduct 7. Motivated by Bad Faith or a Conscious Desire to Injure Me and My Business

8. Honesty Requirement; Prohibition on Deception 9. Unreturned Settlement Payment in the Amount of $3,200 The allegations are explained below. (1) At the heart of the skills which a lawyer offers to his client is the exercise of his independent professional judgment. Given the realities of the American adversary system, a lawyer's total loyalty must be to his client, restricted only by his duty to the court and to the law. The first code of ethics regulating the legal procession, adopted by the American Bar Association in 1908, expressly prohibited an attorney from representing conflicting interests unless all concerned consented after a full disclosure of the facts. In the 1970 Code of Professional Responsibility, the American Bar Association promulgated an even stricter, and certainly more extensive, set of rules governing conflicts of interest. Further, the Florida Bar Association has adopted disciplinary rules and ethical considerations which generally prohibit a lawyer from participation in any conflict of interest situation. It is attorney Paul Phillips undisclosed business and personal interests with liberal blogger and political consultant Peter Schorsch; the individual who invaded my privacy, relentlessly harassed and defamed me, and caused tremendous financial injury to me and my business, whom I sought Mr. Phillips advice to take legal action against, so that I could protect my business from further degradation, which is the cause of my complaint. (2) In early 2007,1 became heavily involved in supporting, then Gov. Charlie Crist's political issues, beginning with the Amendment One campaign. As my role in the business community in Tampa Bay grew, so did my involvement concerning issues facing the business community. I was asked by an advisor of the Governor, Republican Party of Florida (RPOF) board member Gregg Truax, to become involved in supporting the McCain/Palin Presidential Campaign in 2008.1 was asked to be a surrogate, as my successful track record as a business owner placed me in a position to speak out on issues pertinent to the business community in Florida, which was a constituency of particularly interest to Governor Crist. I was asked to be in attendance at press conferences and events with the Governor and vocally support his fiscal agenda statewide. In the summer of 2009, advisors close to the Governor began to court my interest in supporting Governor Crist's candidacy for the United States Senate. I was reluctant to support the Governor, given the terrible fiscal condition Florida was in at the time. I thought it imprudent for a first term Governor to jump ship, during the worst financial down turn our state has faced in recent memory. However, the pressure mounted for me to do support Governor Crist's Senate campaign.


In August 2009,1 was invited to attend a fundraiser at a private home in St. Petersburg, Florida. I donated $1,000 to Charlie Crist's U.S. Senate Campaign. I met with the Governor privately and was eager to hear his plan to lift Florida out of the fiscal turmoil which had engulfed nearly every profitable industry in our state. However, the Governor advised me he had no intention of speaking out on key issues, ideas or solutions to help Florida recover. Instead, to my dismay, the Governor advised me he just wanted me to help him raise more money and that he would discuss the "issues" after he becomes elected to the U.S. Senate. I conveyed to Governor Crist that business owners wanted detailed solutions, not personal attacks. I recommended the Governor go head-to-head in detailed debates regarding key issues with former Speaker of the Florida House, Marco Rubio. The Governor advised me he would not debate Rubio, nor would his campaign mention his name, because he could win the Senate seat merely on the volume of money he planned to raise. The Governor's discourse in these matters caused me great concern. Albeit, I was not yet ready to close the door on our relationship, until I delved a bit deeper. I had several more conversations with the Governor and his chief advisor, Greg Truax over the next several weeks. I began to ask questions about how donor money was being spent and the answers provided to me where deeply disconcerting. After the conclusion of several discussions, I determined I could no longer support Governor Crist's agenda, as it was my belief the Governor had become too influenced by corporate interests, lobbyists and big government bureaucrats and he was out of touch with the issues facing Florida's small business owners, such as myself. I was also concerned about what I thought could be an illegal misappropriation of donor monies. (4) In late September 2009,1 publicly declared my support for Governor Crist's opponent, Marco Rubio and encouraged my network of 5,000 Facebook friends, family members and business associates to do the same. A tide seemed to have turned away from the Governors favor. I made a video to share with colleagues and other small business owners in my community to explain why I was pulling my support for Governor Crist and endorsing Marco Rubio for the US Senate. The video found its way onto the Internet and went viral and was picked up by the press. Thirty days after I endorsed Marco Rubio, Governor Crist lost the GOP straw poll in his own county (Pinellas County) and shortly thereafter announced he was leaving the GOP and continuing his campaign for the U.S. Senate as an independent. It was just shortly after Governor Crist lost the Republican Primary race and announced that he would run as an Independent for the US Senate in March 2010, that a person unknown to me, political consultant and liberal blogger Peter Schorsch began writing false and defamatory articles about me, my business and posting maliciously false and


intentionally defamatory articles on his blog, www., and elsewhere throughout the internet. I had no idea at that time that Paul Philips and Peter Schorsch were connected to Governor Crist. Schorsch wrote several intentionally false and defamatory articles claiming, Gov. Rick Scott, who was a candidate for Governor at the time, had filed a restraining order against me, when nothing of the sort had ever occurred. He took photos from my Facebook account, without my authorization of permission, of Miss Tampa and people I am affiliated with professionally, at charity events we attended, and wrote articles referring to these women as "paid prostitutes". Miss Tampa, who is a woman of Asian decent, was referred to as a "Tia hooker". This blatant racism and sexism perpetuated by Schorsch's blog posts was disgusting and I began to consider taking legal action against his unlawful conduct. Further, I became concerned for my safety and the safety of my employees as threats of retribution mounted, which Schorsch claimed would be carried out relentlessly "until I get out of the GOP as a business owner". The implication was that my reputation would continue to be destroyed if I did not disavow myself from my political affiliation with the Republican Party. Although, Schorsch admits in his own blogs that he had never even met me, he attempted to communicate "personalized" threats that he intended to ruin my business name and personal reputation. These false, malicious and defamatory statements were posted on Schorsch's website and circulated on the Internet to over 40 online blogs, and websites that are affiliated with Schorsch. After learning of Schorsch's political ties, his extensive civil and criminal background, with a history of squeezing his political clients for money, including a $66,000 unpaid fine with the Florida Elections Commission, with 40 counts of election law violations, and approximately $100,000 in civil judgments already against him I contacted attorney Paul Phillips for legal advice about suing Schorsch in July 2010, due to the irreparable harm which his patently false and defamatory stories had caused me and my business. I originally requested to meet Mr. Phillips at his firm's office in Tampa, Florida. However, Mr. Phillips asked if we could meet over drinks at Ocean Prime, instead. When I arrived to meet Mr. Phillips at Ocean Prime, he advised me of his customary consultation fee, but stated I could "pick up the tab" for dinner and that would be equivalent. I agreed. During my meeting with Mr. Phillips, I discussed information regarding my case that was privileged and confidential in nature. We discussed all aspects of the case, what evidence I had to date, and I gave Mr. Phillips copies of evidence which contained personal threats which Schorsch directed at me. We also discussed how in the world could Republican campaign monies being paid to people in Tampa Bay who had massive civil and criminal backgrounds, such as Peter Schorsch, who is a liberal, albeit extremely active in Republican circles.

Throughout our conversation, Phillips asked probing questions about what I knew about Governor Crist's US Senate campaign and other Republican elected officials campaign money being appropriated from the RPOF and local Republican Executive Committees across Tampa Bay. I attempted at several times to steer the conversation back to redressing my legal concerns about Schorsch and the injury he was causing to my business. Phillips stated that I had "no case" against Schorsch, that his writings were all "satire" and Phillips dissuaded me from taking any legal action at all, irrespective of the fact that Schorsch continued to inflict injury on my business and professional reputation. Shortly after my attempt to hire Paul Phillips as my attorney in July 2010, unexpectedly, Schorsch became even more vitriolic and aggressive in his online jihad against me. Schorsch began utilizing the help of several surrogates, including Governor Crist's aide Michelle Todd, who is now his wife, and members of the Pinellas County Republican Executive Committee, and members of the Hillsborough County Republican Executive Committee to continue his online harassment via third parties. At no time during any of my initial conversations with Mr. Phillips did he ever advise me that he had a conflict of interest, personal or financial interests with Schorsch. Later that fall, I was shocked to have learned that Mr. Phillips, has since early 2010, perhaps even prior to that has provided legal representation to Schorsch's web site and political consulting company. Mr. Phillips, at no time disclosed his conflict of interest, or the fact that he authored a weekly column for Peter Schorsch, on the same web site where the defamatory stories about me were being posted. Furthermore, I discovered Schorsch at many times descrined Mr. Phillips as his "attorney on retainer". The evidence was clear that Phillips was Schorsch's attorney. Mr. Phillips was intentionally dishonest and disingenuous by failing to disclose these facts to me prior to our consultation, where I disclosed privileged and confidential information about my perspective case against Schorsch. In the fall of 2010, after countless attempts to try to end Schorsch's harassment, I spoke with Mr. Phillips, during a social event and asked him how could he not have had a conflict of interest with this legal advice to me when I have since discovered all of the facts above? He stated that I had never actually hired him as his attorney, so he never really gave me legal advice even though he agreed to meet with me for a consultation. I reminded Mr. Phillips of our first meeting, when he stated to me that the initial consultation was free if I bought him dinner at Ocean Prime, that we certainly discussed the case and he advised me at that time NOT to sue and not to take any action at all against Schorsch; since, as Mr. Phillips put it, I did not have a case at all. I had provided Mr. Philips with proprietary and Client Confidential information about this case over that dinner meeting to file a legal action against Schorsch. Mr. Phillips clearly failed to disclosed his relationships with Schorsch that evening.

Ironically, it is to my understanding that Mr. Phillips has taught "Ethics" classes to students aspirating toward a legal career at Saint Petersburg College. Assuredly, the college would call into question conduct such as this by one of its adjunct professors. (6) Later on, through information and knowledge, I learned that Schorsch was the live-inboyfriend of Michelle Todd, a woman who had recently left a position she held with the State of Florida, as a district aide for Governor Crist to become Crist's campaign director on his U.S. Senate campaign. Further, I learned from many others that Schorsch was a hired gun used by both Democrats and Republican campaigns to launch personal attacks to discredit private citizens, in an effort to harass and intimidate these individuals for exercising their First Amendment rights. In April - May 2011, while I was attending a public event, Mr. Phillips stated, if I don't stop asking why Republican campaign money is being funneled to Peter Schorsch and Barry Edwards, that Schorsch would write and destroy my families' charity — the Pinson Foundation. It was unclear what Mr. Phillips was eluding to at that time. A month later, Mr. Phillips told my attorney that if I file a lawsuit against Schorsch that he would destroy my personal life, business reputation and the Pinson Foundation's name. I had no knowledge of any issues involving our Foundation, but clearly Mr. Phillips had knowledge and information which I was unaware of. In July-August 2011,1 filed a criminal complaint against Schorsch in Pinellas County Sheriffs Office. However, the state attorney's office advised me that Florida does not have a provision which protects citizens from what Schorsch was doing as "Cyber Harassment" or "Cyber Stalking". It is my belief, based on information and knowledge, that Schorsch filed a complaint against my Foundation in June 2011 with the State of Florida, in retaliation because I continued to question Republican Party leaders about why political donor money was being paid out to individuals with massive civil and criminal backgrounds. Schorsch lodged his complaint with the State of Florida, claiming he was unable to obtain the Foundations' 990N forms online. Again, Schorsch promoted false and misleading stories online, this time he implied our Foundation committed charity fraud to reporter Noah Pransky at CBS Channel 10 News. Upon leaving my office in September 2011, a camera crew ambushed me in my companies parking lot. Reporter Noah Pransky rattled off several accusations, and questioned "where the charity money went". The news video was edited to show a negative story vs my full statements of facts. This false malicious story, instigated by Mr. Phillips and Schorsch, which has no journalistic integrity whatsoever, has been spread all over the internet, intended to defame me and impugn my integrity, reputation and professional opportunities. These false stories incited death threats against me by



strangers, after Pransky's story aired. They knew exactly how to grossly mislead the public and despite the obvious facts. 72 hours prior to the Channel 10 News story being aired, Schorsch posted information notifying the public that a story by reporter Noah Pransky regarding the Pinson Foundation was forthcoming. The implication was that Pransky had leaked the release date of the story to Schorsch, so that it would appear Schorsch site had an inside scoop of Pransky's investigative report. Through information and knowledge, I discovered that Noah Pransky, the reporter who ran the false and factually incorrect story about the Pinson Foundation, was also a personal friend of Peter Schorsch. Furthermore, it was verified that the reporter Noah Pransky, attended Schorsch's wedding in January 2012, which was officiated by former Governor Charlie Crist. Mr. Schorsch married Michelle Todd, the Governor's former campaign employee. (9) In January 2012,1 called Charlie Crist at his law office ofMorgan & Morgan to discuss a mediation with Schorsch, since I was aware Crist would be in the St. Petersburg area around that time to officiate the wedding of Schorsch and Crist's former aide, Michelle Todd. I also left a voice mail for attorney John Morgan to call me to seek some sort of resolution or end to this mess. Neither, Governor Crist or John Morgan would returned my call. A short time later, I was contacted by Mr. Phillips, who communicated with me via text message. Mr. Phillips advised me Schorsch would remove the false and defamatory blog postings out of every web site for $3,500 cash. About a week later, Mr. Phillips advised me that he was raising the asking price to $4,200, which included a guarantee that Schorsch would not harass, defame me, my company or write anything about me for the next three years. I suspect, that part of these monies were also being paid to Phillips disguised as so called "Legal Fees" but he never admitted this. For the sake of the 23 families which my company employs, I felt I had no choice, except to surrender to Mr. Phillips and Schorsch's financial demands to remove the massive blogs, photos, and use of my name from his numerous web sites. There was no help from law enforcement on this matter. Schorsch already had nearly $100,000 in civil judgments against him, a several criminal records which included Fraud and Embezzlement of $10,000 in political campaign funds from the Democratic Party and an unpaid $67,000 fine from the State of Florida for 40 counts of Florida election law violations. Schorsch's original financial demand was $3,500, then $3,250, then $4,200 total of which Phillip's brokered as his attorney. I agreed, as I had no choice but to pay him $3200 now to remove all blog posts, photos and my name from his multiple web sites, and another $1,000 by Sept 1, 2012, provided that none of the cached articles or videos by Schorsch

or his blogger affiliates showed up in the first 30 pages of any search engine. Also, that they both, and their associates, and affiliates stated that they would leave my and my family alone, and not write anything more about on the internet for a period of not less than three years for these monies. Brokered by Mr. Phillips, Peter Schorsch agreed. I felt that this was nothing more than extortion. Mr. Phillips presented several fraudulent and dishonest schemes to hide what the payment to Schorsch was for. He first tried to called it that I was buying Ad space, but there was never any ad space offered. When I asked Mr. Phillips to define the ad space size and ad time on the web site, he refused to reply at all about it. He also tried to call these monies "Consulting Fees" paid to them, to suggest I was buying consulting services from Schorsch and that I was somehow liable to Schorsch. However, when I made him detail what he was talking about, he did not answer the questions. Phillips also attempted to claim is was some sort of professional fee to remove the blogs from Google, thus attempted another fraud as everyone knows a person cannot do something magical to remove anything from Google's servers. Schorsch and Phillips both knew this. None of these terms made it to the final Agreement as we made it very clear that were paying for the removal of these slanderous blogs from the many web sites of Schorsch and for Schorsch to leave myself and family alone for at least the next three years. The Agreement is signed by Schorsch, as we refused to allow them to cover up why I was paying them their financial demands. We originally identified Mr. Phillip's name in the 2012 Agreement. However, Mr. Phillips asked not to disclose his name and to use the word "Attorney" or "Law Firm" in the Agreement, even though it was clear that Mr. Phillips would be receiving part of these monies. We required that Mr. Phillips have his client, Mr. Schorsch signed a sworn statement under the penalty of perjury, stating he approved the agreement and his statements in that Agreement were true and correct. Additionally, the Agreement was signed and notarized [See Attached Agreement]. Several days after it was signed by Schorsch, we deposited $3,200 in the Trust Fund Account of Phillips law firm where in the Agreement, and by cover letter that Mr. Phillips agrees that no funds are to be released to anyone until I have inspected the removal of all blogs, articles, photos and my names from the Internet. Phillips and Schorsch both confirmed in writing they agreed to these terms and conditions. However, Schorsch started to remove only part of the articles, Schorsch violated the Agreement by intentionally leaving my name listed on web pages, and in the titles of URLs which point to article he falsely wrote about me. Further, he violated the Agreement by refusing to remove images and pictures of me, my friends, colleagues and associates, which he took without my consent from my Facebook account. Dozens of these images were linked to false and defamatory stories Schorsch wrote about me on

affiliate websites. Mr. Phillips confirmed with Schorsch, and had his client state under oath that Schorsch had control over the web site, such a When my attorney and I discovered that Phillips and Schorsch was once again playing games, we gave Mr. Phillips, until June 8, 2012, to either have them both fully comply with the agreement and fully deleted everything off the Internet or Phillips must return the $3200 from his law firm's trust account. Our agreement clearly stated that Phillips could not distribute the funds to Schorsch not can Mr. Phillips pay himself from and such funds, unless I have personally reviewed all deleted content from the websites and that I must sign a release before Phillips is legally authorized to release the funds. After Phillips had received the funds, he then notified me that his client had committed an error Under Oath of Perjury, where Schorsch claimed he controlled the website and had the authority to remove the false and defamatory stories he had written himself, which was not factual. Nevertheless, Mr. Phillips indicated I should still pay for the deletion of this false and defamatory content and leave all negative content up about me on, even though Mr. Phillips helped draft the Agreement, which Schorsch signed. Mr. Phillips was advised that Schorsch was in breach of agreement and was given until June 8, 2012 to comply with our agreement or return my money. On June 8, 2012, Phillips Agreed to return all monies from his law firm Trust Account. On June 13, 2012, my attorney telephoned and emailed Mr. Phillips asking where the money were. Mr. Phillips has refused to return my attorney's email and calls. As of July 2, 2012, Mr. Phillips has not returned the monies from his Trust Account. It is very clear that that Mr. Phillips knew what he was doing all along. Mr. Phillips either has already distributed the monies illegally, or has breached his fiduciary duty as a Florida attorney by keeping the funds at his law firm to cause me additional legal expense. We were tired of being jerked around where I was spending $300 per hour with my attorney as Phillips continued to play these games. It was clear that Phillips wanted to increase my legal expenses even more by his Bad Faith actions as punishment for not agreeing to again modify the Agreement that Schorsch signed under "Oath subject to Perjury" by paying the monies anyway, and leaving some of the slanderous blogs on the Internet. As a direct and proximate result of the conduct described above, I have suffered emotional distress, tremendous damage to my personal and professional reputation, as well as financial losses for my business. When someone Google's my name, they can find no mention of my professional credentials, only Schorsch's defamatory blog posts, which have no journalistic accuracy or merit. Schorsch's statements and comments on his blog have impugned me, and slandered my honesty, integrity, virtue, reputation and professionalism.

Assuredly, Mr. Phillips was consciously aware, prior to consulting with me in July 2010, that his relationship with Schorsch would have had an adverse impact on the outcome of my case. To date, the matter involving Mr. Phillips and Schorsch has cost my company in approximately $20,000 in legal and public relations costs dealing with his cyber smearing and personal attacks. Mr. Phillips has made numerous comments to myself and others how he thinks this is all "Funny". I would challenge this assertion, as the 23 families, which Pinson Communications employs do not consider their continued employment being placed in jeopardy or a negative impact on their financial futures "Funny". Attorney Phillips' behavior is so outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency or professional conduct. Phillips' unethical and fraudulent misrepresentations illustrates he is motivated by hatred, ill will or spite or by a reckless disregard for my rights, with the intention of causing me personal, professional and financial harm. Mr. Phillips falsely and fraudulently counseled me, using deceptive means to influence me to drop my plans to sue Schorsch in 2010. Clearly, Mr. Phillips' knowingly intended to deceive me, conceal his conflicting interests with Schorsch, which has caused me personal and professional injury, that is further promulgated by an adverse legal outcome. The information Mr. Phillips gathered about my case during the intake and consultation process, which I was led to believe would be used related to the representation of my case, was instead was used by Mr. Phillips to benefit himself and his client Peter Schorsch, to induce an extortion payment from me every three years. I wish to make it clear that the Agreement signed by Schorsch, that Phillips co-drafted states that all slanderous blogs, my name and photos will be removed from the Internet, that they will leave myself, family and business alone and not write anything about me, or his associates or affiliates write anything about me for the next three years for payment of $4,200 total. As I believe several violations of the Florida Bar's Standards for Lawyer Sanctions exists, I request your office aggressively investigate this matter, so that other potential clients seeking legal assistance in their hour of need, do not fall prey to Mr. Phillips. I also request the Florida Bar conduct an audit of Mr. Phillips' law firm and trust accounts concerning the funds which he has not yet returned. The $3,200 has not been returned by Phillip's as such funds are now missing and unaccounted for. Additionally, with respect to a current Florida Department of Law Enforcement (FDLE) investigation regarding the alleged misappropriation of campaign contributions of former Governor Crist and/or others, the discovery of which was recently made public in the corruption trial of former Chairman of the Republican Party of Florida, Jim Greer; I request this Bar


Complaint and attached documents be made available to the Florida Election Commission, and to law enforcement authorities for the furtherance of investigations concerning these matters.


ichael Enclosures

JUL 1 6 2011
. ne Honda dai-AW i Florid?


RELEASE OF CLAIMS AND SETTLEMENT AGREEMENT Michael Pinson (hereinafter referred to as the "Releasor") agrees to pay Peter Schorsch (hereinafter referred to as the "Releassee") the sum of Four Thousand TwoHundred Dollars ($4,200), at Releasee's request, for and in consideration of the mutual obligations specified hi this Release of Claims, (hereinafter referred to as the "Release"). Upon full performance of the obligations set forth hi this Release, Releasor, for himself and his respective heirs, executors, administrators and assigns, does hereby completely and fully release and discharge Releasee of and from any obligation, liability or responsibility arising out of any claim and/or action arising from any publication, blog, internet posting, article, or statement of any kind Releasee has made about, concerning, or describing Releasor that was made prior to the date that the Releasor signs and dates this Release. It is understood and agreed that this Release is hi full compromise of a disputed claim, and that neither this Release, nor the performance of the obligations specified in this Release, shall be construed as an admission of liability by either party to the Release. I. MUTUAL OBLIGATIONS

Each party to this Release, in consideration of inducing the other party to enter into this Release, agrees to perform the obligations specified herein. n. / OBLIGATIONS OF THE RELEASOR a. Within ten days of Releasee signing this Release, Releasor will place into the trust account of Releasee's attorney, the sum of Three Thousand TwoHundred Dollars ($3,200.00). It is agreed that said funds will only be paid to Releasee under the conditions set forth in this Release. Releasee hereby agrees and directs Releasee's attorney, or any other attorney or law firm holding said funds in trust to not release said trust funds to Releasee until such time as Releasor provides to Releasee's attorney, or any other attorney or law firm holding said funds in trust, a written acknowledgement that Releasee has complied with his obligations set forth hi this Release. Said written acknowledgement shall not be withheld in bad faith. b. If, on or before September 1, 2012, no statement and/or opinion that Releasee has ever published referencing in any manner Releasor, Pinson Communications, and/or any other business or charity with which Releasor is associated (including but not limited to "The Pinson Foundation", "John Michael Pinson", "Americans for Freedom", "Pinson", or "Michael Pinson Tampa" appears within the first thirty (30) search results for said search terms or appears as an active link on the following search engines: Google; Yahoo; Bing; Dogpile; Lycos; MSN; Ask; "Michael Pinson, Releasor agrees to pay to Releasee an additional $1,000.00, with said payment to be made on or before September 10, 2012. Releasee will move in good faith to accomplish the

provisions set forth in Section II(b): however Releasor understands that the specified search engines are not controlled by Releasee.

a. Within ten (10) days of Releasee signing this Release, Releasee agrees to remove from, and will certify in writing, that all content concerning Releasor, Pinson Communications, and/or The Pinson Foundation has been deleted from www. wwvv.tampabaybatdegro^ Releasee's channels,, or any other website or publication with which Releasee is associated. By" his signature below Releasee does hereby swear and affirm that he presently does not, nor ever has had, an association of any kind with and b. Within ten (10) days of Releasee signing this Release, Releasee shall provide to Releasor a list of any and all web sites to which Releasee has contributed articles for, owns^ controls, manages, or has any interest in whatsoever. As to each of the websites on the list provided pursuant to this provision of the Release^ Releasee sfiall remove, within ten (10) days ofjRelcasec signing this agreement, any ail references to Releasor, The Pinson Foundation, Pinson Communications., Inc., and any other business or charity with which Reieasor is associated, c. For three (3) years subsequent to the date Releasee signs this Release, Releasce shall not post on any internet sight or publish any manner., either directly, indirectly, or through a third party, any statements or opinions relating to or referencing in any manner Releasor, The Pinson Foundation, Pinson Communications, and any other business or charity with which Releasor is associated. If Releasee is found to have violated this provision of the Release, Releasor agrees to never make any reference or comment about, to any past events or articles from others that were published about the Releasee prior the date of the Agreement If Releasee violates this provision of the Release, Releasee shall be liable to Releasor any attorney's fees or costs that Releasor incurs in enforcing this provision, as well as any damages Releasor incurs. d. Releasee, within ten (10) days of signing this Release, agrees to provide a written, signed, and notarized a document transferring to Releasor any and all copyrights to any written statements or opinions that Releasee has published in any manner concerning, about, or relating to, or referencing Releasor, The Pinson Foundation, Pinson Communications, and/or any other business or charity with which Releasor is associated, e. Releasee, within ten (10) days of signing this Release, agrees to remove from each website listed pursuant to Paragraph III(b) of this Release, any internet

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link to any other website and/or blog containing statements and/or opinions referencing Releasor to include remove any and all web site links and search engine promotions or optimizations relating to about, the Releasor, Pinson Communications, Inc. the Pinson Foundation, Inc., and/or any other business or charity with which Releasor is associated. IV. ATTORNEYS' FEES

Each party hereto shall bear their own attorneys' fees and costs incurred for any reason prior to the date of this Release V. CONFTOENTIALITY OF SETTLEMENT

The parties hereto are obligated to keep confidential the terms of this settlement as is set forth herein. It is specifically understood that no release of information concerning this settlement shall be made to the news media, and that disclosure of the terms of settlement shall be restricted to those disclosures which are required by law and/or as may be necessary to enable the undersigned to facilitate appropriate tax reporting, or in the conduct of business necessary to complete this settlement and/or as is responsive to any investigations made by any State or Federal Governmental Agency or Department. If inquiry is made by any person about this release or the settlement agreement, the parties agree that they will state only that they have resolved their differences amicably and mat no litigation is pending or complicated. VI. TAX CONSEQUENCES OF SETTLEMENT

No representations have been made by Releasor regarding the taxability of all or any portion of this settlement. Releasee stipulates that he has had the opportunity to seek independent advice regarding the tax consequences of this settlement, and accept

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responsibility for satisfaction of any tax obligation that may result from this settlement. VH. JURISDICTION AND CHOICE OF LAW

This Release and claims arising out of or in connection therewith shall be governed by and construed and enforced in accordance with the laws of the State of Florida and both the Releasee and Releasor consent to jurisdiction in the state courts situated in Pinellas County, ACKNOWLEDGEMENT
I understand that I am swearing or affirming under oath to die trudifulness of die statements of fact made in tiiis Release and Settlement Agreement that die punishment for knowingly making a false statement includes fines and/or imprisonment. Dated: .5 PETER SCHORSCH STATE OF FLORIDA COUNTY OF Sworn to or affirmed and signed before me on
SEANBAtLEY MY COMHBSKWEE155214 EXPIRES: Febntaiy 7.2016 Bonded Dm Notary PutftUnferaibs otary PutftU

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Personally known-* Produced identification Type of identification produced _

I understand that I am swearing or affirming under oath to die truthfulness of die statements of fact made in this Release and Settlement Agreement that die punishment for knowingly making a false statement includes fines and/or imprisonment. Dated: MICHAEL PINSON STATE OF FLORIDA PINELLAS COUNTY NOTARY PUBLIC or DEPUTY CLERK Personally known Produced identification Type of identification produced _

Initials^?- Initials

From: Mark G. Rodriguez [mailto:atty@markrodriguezlaw.corn| Sent: Thursday, April 26, 2012 1:49 PM To: Paul Phillips Cc: Michael Pinson Subject: Pinson/Schorsch Settlement Agreement Dear Mr. Phillips, I have had the opportunity to review with Mr. Pinson your proposed revisions to the proposed settlement agreement. "" ~~ " " ~~ (1) The proposed revisions to the introductory paragraph and Paragraph II (a) are acceptable. (2) The proposed revision to Paragraph 1Kb) is acceptable, but Mr. Pinson requires additional language that the $1,000.00 payment would only be made if the condition is met, despite Mr. Schorsch's good faith efforts. (3) The proposed revision to Paragraph III (a) is not acceptable. Mr. Pinson is of the belief that and are under Mr. Schorsch's control. (4) Your suggested additions of severability, choice of law and forum selection provisions is acceptable. Mr. Pinson requires a_response by close of business Wednesday, Please do not hesitate to contact me should you have any questions or wish to discuss the matter.

On Jun 1, 2012, at 2:35 PM, Paul Phillips <> wrote: FYI TBBuzz is not Peter's site. He has no affiliation with it. Regards, Paul M. Phillips, MSF, CFA


From: Mark G. Rodriguez [] Sent: June 1, 2012 3:06 PM To: 'Mr. Paul Marshall Phillips' K^T— Subject: Schorsch/Pinson On Jun 1, 2012, at 3:06 PM, "Mark G Rodriguez, Esq" <> wrote: It is specifiedin the agreement-page 2 first paragraph. Mark G Rodriguez, Esq.


From: [] Sent: Sunday, June 03,_2012Ji):52_AM • To: Mark G Rodriguez, Esq Subject: Re: Pinson/Schorsch Settlement Agreement What. They signed a deal saying tb buzz is peters web site now they say no? And they want to keep all up. Fine. I have not signed deal tell them to return all money next week. J. Michael Pinson, CEO Pinson Communications Sent from my iPhone

From: Paul Phillips [] To: Mark G. Rodriguez Subject: RE: Pinson/Schorsch Settlement Agreement Received your call. Our Trust account is in Tallahassee. I am, and ha\e been, in depos in Vero Beach all week, but will instruct our offices to mail check to vour offices todav.
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Regards, Paul M. Phillips, MSF, CFA

From: Mark G. Rodriguez [] Sent: Wednesday, June 13, 2012 9:46 AM To: 'Mr. Paul Marshall Phillips' Subject: Schorsch/Pinson Good morning Mr. Phillips, Could you please confirm that the trust account check has been mailed to my office? As of yesterday's mail it has not been received. * ,



From:] Sent: Tuesday, June 26, 2012 7:30 PM To: Mark Rodriguez Subject: Paul Phillips Bar Complaint Mark This is to confirm your text [and phone conversation] tonight to me that as of today your law firm has not received our funds held in trust from Paul Phillips law firm trust account. Also Mr Phillips told you back on June 8, 2012 that the monies from the trust account were being mailed to us in several days When you called and emailed him about 10 days ago he never returned your call or email. I am proceeding with these facts in the bar complaint which will be filed tomorrow I wish to also confirm that Paul Phillips co-drafted the Agreement in detail that he had his client Peter Schorsch sign under oath of perjury. After Phillips received the funds into his trust account he called you claiming his client made a false statement in error under oath where Schorsch's signature was notarized but Phillip's wished to have us to change the agreement for him [where not everything would be removed from the Internet] and Schorsch keep the funds anyway. This lead to us canceling payment to their financial demands and the deal Phillips agreed to return the monies in a few days after June 8th which we have not received as of today. J. Michael Pinson, CEO Pinson Communications Sent from my iPhone


Mark G. Rodriguez, P.A.
701 S. Howard Avenue. Suite 201 Tampa, FL 33606 Telephone: 813-227-9642 Facsimile: 813-354-4402 Jeeves Law Group P.A. Of Counsel for Personal Injury. Medical Malpractice, and Wrongful Death

May 23,2012 Paul Phillips Igler & Dogherty, P.A. 500 N.Westshore Blvd.
STE 1010

Tampa, FL 33609 Re: Your client Peter Schorsch Dear Mr. Phillips, Please find enclosed my Finn's Check No.: 1065 in the amount of Three Thousand Two Hundred Dollars ($3,200.00), said check payable to the Trust Account of Igler and Dogherty, PA. This check is being submitted pursuanTfo the Release of Claims and Settlement Agreement that your client signed on May 10,2012 and which you submitted to my office on May 15,2012. Pursuant to Paragraph II(a) of the Settlement Agreement, these funds are_not to be released to Mr. Schorsch until Mr. Pinson provides to you the release specified in that Paragraph. Please do not hesitate to contact me should you have any questions. Sincerely,

*-~^ lark G. Rodriguez, Esq.
cc: Michael Pinson.