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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 A is an example of Mr. Rodems' bizarre behavior in another case, his comments about Eric Bischoff, a witnesses in WrestleReunion, LLC v. Live Nation, Television Holdings, Inc., United States District Court, Middle District of Florida, Case No. 8:07-cv2093-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 determination of his ADA accommodation request.
Titre original
Motion to Stay Pending ADA Determination, 05-CA-7205, June-14-2010
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 A is an example of Mr. Rodems' bizarre behavior in another case, his comments about Eric Bischoff, a witnesses in WrestleReunion, LLC v. Live Nation, Television Holdings, Inc., United States District Court, Middle District of Florida, Case No. 8:07-cv2093-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 determination of his ADA accommodation request.
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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 A is an example of Mr. Rodems' bizarre behavior in another case, his comments about Eric Bischoff, a witnesses in WrestleReunion, LLC v. Live Nation, Television Holdings, Inc., United States District Court, Middle District of Florida, Case No. 8:07-cv2093-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 determination of his ADA accommodation request.
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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 DOlwrestling.com - Declaration of Independents - The Number 1 Independent Pro Wrest!". Page 1 of3 ,(':,' ,; : .,' "", . .' - :. ........ -'" .,......... ...," ... 1'. ',. DOIVt DEO.COM Ton:> of DVD original shoot Inter'vlews
t' L J to ' ...... J. ' " .. ... .. 4:...,. 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$ive ptopty oIlhe Dedendion of Independenls end cannot be uNd "..whete linlc CIWdit. .AJJ 001 pun;ha3W ate ltOft.(fffundllble "" mltiJ teJee:tronJc 01' pO"') ..", to 1M 001 becomes ptOperty of the OOI.-triM _.10... thiI 001 to r."rlnt t1Ntf e.m.JlIn II'a enltWl)' by doing so. 11 the 8IMi is COtI$tdet.el 112812010 http://www.declarationofmdependents.net/doi/pageslcorrente910.html
(Oxford Monographs in International Law) Alebeek, Rosanne Van - The Immunity of States and Their Officials in International Criminal Law and International Human-Oxford University Press USA (2008)