Via Email: tlittlew@flabar.

org, and October 22, 2012

U.P.S. No. 1Z64589FP292665925
Theodore P. Littlewood Jr., Bar Counsel
The Florida Bar, ACAP
651 East Jefferson Street
Tallahassee, FL 32399-2300
Addendum to Rebuttal: Ryan Christopher Rodems, TFB File No. 2013-10,271 (13E)
Dear Mr. Littlewood:
Subsequent to my rebuttal dated October 16, 2012, Arne Vanstrum responded (enclosed) on
behalf of Mr. Marvin to my letter of October 3, 2012. Mr. Vanstrum wrote in relevant part:
Your question asks when the central intake process was implemented. While we do not
have specific data to draw upon, I have checked with individuals who were involved in
the initial implementation of the Intake Department.
The process began in 2007 with new complaints which would have normally gone
directly to the Tallahassee branch office. Each of The Florida Bar's other 4 branch offices
were added one at a time until the entire state was covered by May 2008.
My last contact with Ms. Bloemendaal about Mr. Rodems was February 8, 2010 (enclosed) and
concerned TFB No. 2007-11,162 (13D), her letter of November 19, 2007, and my request to
submit another Bar complaint. Ms. Bloemendaal never informed me that central ACAP was in
place in 2010. Below is the relevant portion of my letter questioning Ms. Bloemendaals straw
man fallacy, and her sophistic, specious and farcical response of November 19, 2007:
Dear Ms. Bloemendaal,
This is in response to your letter dated, November 19, 2007, copy enclosed. Regarding
your assertion on page two, paragraph three about "Defendant's Verified Request for
Bailiff and for Sanctions" you wrote It appears that the pleading fairly represents your
telephone conversation and we therefore cannot conclude that it was materially
misleading. Actually I complained about perjury for an exact quote by Mr. Rodems
attributed to me, not that the pleading was materially misleading. If you do not
understand my complaint, I can submit another complaint about exact quote perjury.
With malice aforethought Mr. Rodems made a verified pleading that falsely put Judge
Nielsen in the exchange. Mr. Rodems stated, under oath, that this is the exact quote
attributable to me: I am going to slam you up against the wall in Judge Nielsens
chambers. I did not say in Judge Nielsens chambers but in fact I said like I did
before. These are not exact quotes but two very different statements. It is a very
serious offense calling into question the lawyers fitness to practice law.
Theodore P. Littlewood Jr., Bar Counsel
The Florida Bar, ACAP October 22, 2012
Page - 2
Mr. Rodems committed perjury in violation of 837.02(1) and 837.06. Mr. Rodems
verified pleading was made during an official proceeding as described in 837.011(1),
made under oath as described in 837.011(2) and concerned a material matter as
described in 837.011(3). I request you reevaluate my claim of perjury against Rodems.
Ms. Bloemendaal responded by letter dated February 17, 2010 (enclosed) that did not address
my specific complaint about Mr. Rodems exact quote perjury. Ms. Bloemendaal wrote Your
most recent letter requests that the Bar reverse the previous decision to close the file, without
providing any new evidence that would warrant further review. Ms. Bloemendaals statement
was false; I did not request the Bar to reverse the previous decision. Clearly I asked to submit
another complaint to reevaluate my claim of exact quote perjury against Rodems.
Throughout this matter Ms. Bloemendaal has made similar sophistic responses that call into
question her integrity, and her ability to fairly and honestly hold Mr. Rodems accountable.
In February 2010 Ms. Bloemendaal should have instructed me to submit a new complaint against
Mr. Rodems to central ACAP in Tallahassee. Instead Bloemendaal obstructed my complaint.
If language is to have meaning, the phrase exact quote has a specific meaning. My statement
was a self-proving metaphor, not a threat. When an attorney voluntarily swears under the penalty
of perjury about an exact quote, he should be held to the standard he set for himself in his
verified pleading to the Court. Also, the transcript shows another issue, the totality of my
conversation with Rodems was significantly different than what he represented to Judge Nielsen.
Subsequently Mr. Rodems has repeated my self-proving metaphor as an actual threat, including
in a email sent June 20, 2011 to Mr. Castagliuolo on the eve of my coercive confinement in the
George E. Edgecomb Courthouse in Tampa for a deposition.
How do I proceed with a complaint about Mr. Rodems perjury and misquotes, given that Ms.
Bloemendaal has so thoroughly corrupted the process? Ms. Bloemendaal has not evaluated the
evidence or the findings in the investigation by the Tampa Police Department into Mr. Rodems
perjury, and my rebuttal to the TPD, which occurred after her letter dated February 17, 2010.
Mr. Rodems is guilty of, if not perjury, a strategic maneuver intended to disrupt the tribunal to
gain an unfair advantage in the litigation after Judge Nielsen rejected Rodems phony claim to
$50,000 in court-awarded costs and fees by Order January 13, 2006. For the next five (5)
years, Mr. Rodems made a misleading legal argument based on a knowingly false representation
of law, in violation of the following Advocate (Rule 4.3) Rules of Professional Conduct:
Rule 4-3.1 After Judge Nielsen rejected Mr. Rodems phony claim to $50,000 in
court-awarded costs and fees, Rodems contention was no longer meritorious.
Theodore P. Littlewood Jr., Bar Counsel
The Florida Bar, ACAP October 22, 2012
Page - 3
Rule 4-3.2 Mr. Rodems subsequent and ongoing assertion of his phony claim to
$50,000 in court-awarded costs and fees, made after Judge Nielsens Order rejected the claim,
obstructed this litigation for five years, and did not expedite litigation as required by the Rule.
Rule 4-3.3 Mr. Rodems misleading legal argument based on a knowingly false
representation of law violated every aspect of Rule 4-3.3, Candor Toward the Tribunal.
Rule 4-3.4 a lawyer shall not (a) conceal an order that the lawyers knows is relevant to a
proceeding, (b) fabricate evidence, i.e., a claim to $50,000 in court-awarded costs and fees,
(c) knowingly disobey an obligation under the rules of a tribunal, i.e. Judge Nielsens Order that
denied res judicata Rodems phony claim to $50,000 in court-awarded costs and fees, (d)
made frivolous discovery requests of me, and intentionally failed to comply with my legally
proper discovery requests, (e) in trial (final summary judgment, Sep-28-2010) state a personal
opinion about the credibility of a witness, assert personal knowledge of facts in issue except
when testifying as a witness, or state a personal opinion as to the justness of a cause, or the
culpability of a civil litigant. (Rodems violated this subpart at every SJ or JOTP hearing), (g)
present, participate in presenting, or threaten to present criminal charges solely to obtain an
advantage in a civil matter, i.e. Rodems claim that ACAP is felony extortion; his affidavit and
motion for sanctions on a false claim of a violent physical attack in Judge Nielsens chambers.
Rule 4-3.5 (a) improper influence of a judge with a false affidavit, which (c) disrupted the
tribunal, and resulted in the recusal of Judge Nielsen November 22, 2006.
Rule 4-3.7 A lawyer shall not act as advocate at a trial in which the lawyer is likely to be
a necessary witness on behalf of the client. I believe Mr. Rodems advocacy as a witness on
contested issues and factual matters during hearings on SJ or JOTP is essentially the same as a
trial. Judge Nielsen provided in his Order May 12, 2006 for a rehearing on disqualification of
Mr. Rodems as a witness. Combining the roles of advocate and witness can prejudice the
tribunal and the opposing party and can also involve a conflict of interest between the lawyer and
client. (Underline added. BTW, this is not a conflict with me, a former client, but a conflict
between Mr. Rodems and his client, his firm and partner). The trier of fact may be confused or
misled by a lawyer serving as both advocate and witness. The combination of roles may
prejudice another party's rights in the litigation. A witness is required to testify on the basis of
personal knowledge, while an advocate is expected to explain and comment on evidence given
by others. It may not be clear whether a statement by an advocate-witness should be taken as
proof or as an analysis of the proof. (Comment, in part, Rule 4-3.7).
Conclusion
In the past Ms. Bloemendaal and the Tampa Branch Office have obstructed my Bar complaints
against Mr. Rodems. If you determine that the alleged conduct, if proven, would constitute a
violation of the Rules warranting the imposition of discipline, how will my complaint be fairly
considered by the Tampa Branch, given its history with my prior complaints against Rodems?
(Assuming that the complaint goes to the Tampa Brach as part of the discipline process).
Theodore P. Littlewood Jr., Bar Counsel Page - 4
The Florida Bar, ACAP October 22, 2012
In addition, I want to clarify several other issues.
1. As to David A. Rowland, Court Counsel, and his letter dated July 9, 2010, his comments
refer to my ADA accommodation request of July 6, 2010, which was the same request submitted
February 19, 2010; in that ADA request the undisputed allegations show Mr. Rodems harassed
me, and his behavior was a crime under section 784.048(2), Florida Statutes.
2. On April 26, 2006 I submitted Plaintiffs Motion for Summary Judgment, with Affidavit
in Support, based on Judge Nielsen's ruling January 13, 2006 that established a cause of action
for Fraud and Breach of Contract, and rejected Mr. Rodems' misleading legal argument that his
firm was entitled to a "claim" of $50,000 in "court-awarded costs and fees". My motion for
summary judgment was set for hearing August 1, 2006 but not heard because Rodems objected.
3. As to the sham Order Prohibiting Plaintiff From Appearing Pro Se, notice of its falsity
was also submitted to the Second District Court of Appeal in case 2DI0-5197, see Appellant's
Motion To Amend Notice of Appeal, July 18, 2011.
Finally, Mr. Rodems' affidavit alleging a violent physical attack in Judge Nielsen's chambers
strains credulity. The Tampa Courthouse has dozens of Hillsborough County Sheriffs Deputies
present during business hours. My rebuttal shows Mr. Rodems has many potential enemies.
Given the level of court security, it is not believable that someone would attack Mr. Rodems "in
Judge Nielsen's chambers", given that Rodems' home address, 210 Excalibur Ct., Brandon,
Florida, is shown in public records and is therefore public knowledge. Yet Mr. Rodems
continues to make this false allegation, such as in his letter dated December 28, 2009 to Pedro
Bajo, former Chair of the JNC: "Among other things, Mr. Gillespie has: Threatened to "slam"
me "against the wall;" as a result, I requested that a bailiff be present at all hearings. (Exhibit
"4"). As a precaution, I also scheduled Mr. Gillespie's deposition in a building requiring visitors
to pass through a metal detector;". Perhaps a separate complaint is needed for Mr. Rodems' false
statements and misrepresentation on his various applications to the JNC.
The fact that Mr. Rodems is able to freely and safely travel is a testament to the law-abiding
nature of the many survivors of Mr. Rodems' crimes and professional misconduct.
Thank you for considering this Addendum to my Rebuttal. If necessary to comply with the
earlier-established 46 page limit, please adjust the Exhibits to my Rebuttal by reducing by seven
pages to allow this Addendum; or grant an extension of the number of pages permitted.
Sincerely,
Neil J. Gillespie
8092 SW 115th Loop
Ocala, Florida 34481
Enclosures
cc: Ryan Christopher R o d e ~ s , V A V.P.S. No. lZ64589FP293864333
THE FLORIDA BAR
651 EAST JEFFERSON STREET
JOHN F. HARKNESS, JR. TALLAHASSEE, FL 32399-2300 850/561-5600
EXECUTIVE DIRECTOR www.FLABAR.ORG
October 15, 2012
Mr. Neil J. Gillespie
8092 SW 115
th
Loop
Ocala, Florida 34481
Re: Your correspondence of October 3,2012
Dear Mr. Gillespie:
The above referenced letter to Kenneth Marvin has been referred to me for a response.
Your question asks when the central intake process was implemented. While we do not have
specific data to draw upon, I have checked with individuals who were involved in the initial
implementation of the Intake Department.
The process began in 2007 with new complaints which would have normally gone directly to the
Tallahassee branch office. Each ofThe Florida Bar's other 4 branch offices were added one at a tinle
until the entire state was covered by May 2008.
I hope you find this information useful.
Sincerely,

Vanstrum
Associate Director, Lawyer
Regulation
Neil J. Gillespie
8092 SW 115
th
Loop
Ocala, Florida 34481
VIA US CERTIFIED MAIL, RETURN RECEIPT
Article No.: 7009 2820 0003 5102 9712
February 8, 2010
Susan V. Bloemendaal, Chief Branch Disciplinary Counsel
The Florida Bar, Department of Lawyer Regulation
5521 West Spruce Street, Suite C49
Tampa, Florida 33607-5958
RE: Inquiry/Complaint regarding Ryan Christopher Rodems
TFB No. 2007-11,162 (13D)
Dear Ms. Bloemendaal,
This is in response to your letter dated, November 19, 2007, copy enclosed. Regarding
your assertion on page two, paragraph three about "Defendant's Verified Request for
Bailiff and for Sanctions" you wrote "It appears that the pleading fairly represents your
telephone conversation and we therefore cannot conclude that it was materially
misleading." Actually I complained about perjury for an "exact quote" by Mr. Rodems
attributed to me, not that the pleading was materially misleading. If you do not understand
my complaint, I can submit another complaint about "exact quote" perjury.
With malice aforethought Mr. Rodems made a verified pleading that falsely put Judge
Nielsen in the exchange. Mr. Rodems stated, under oath, that this is the exact quote
attributable to me: "I am going to slam you up against the wall in Judge Nielsen's
chambers." I did not say "in Judge Nielsen's charrlbers" but in fact I said "like I did
before." These are not "exact quotes" but two very different statements. It is a very
serious offense calling into question the lawyer's fitness to practice law.
Mr. Rodems committed perjury in violation of 837.02(1) and 837.06. Mr. Rodems'
verified pleading was made during an official proceeding as described in 837.011(1),
made under oath as described in 837.011(2) and concerned a material matter as
described in 837.011(3). I request you reevaluate my claim of perjury against Rodems.
J. Gillesp
closure
Mr. John F. Harkness, Jr., Executive Director, The Florida Bar (with enclosure)
Mr. Kenneth Lawrence Marvin, Director of Lawyer Regulation (with enclosure)
THE FLORIDA BAR
MAILING ADDRESS: PHYSICAL ADDRESS:
JOHN F. HARKNESS, JR. 4200 GEORGE J. BEAN PKWY AIRPORT MARRIOTT HOTEL 813/875-9821
EXECUTIVE DIRECTOR
SUITE 2580 SUITE 2580
www.FLABAR.ORG
TAMPA, FL 33607 TAMPA, FL 33607
February 17,2010
Neil 1. Gillespie
8092 SW 115
th
Loop
Ocala, Florida 34481
Re: Inquiry/Complaint regarding Ryan Christopher Rodems
TFB No. 2007-11,162 (l3D)
Dear Mr. Gillespie:
I am responding to your February 8,2010 letter wherein you request reevaluation of the above
referenced complaint. This complaint was closed by the Bar on May 15,2007, and the subject of
subsequent review by this office. You have provided a copy of the letter dated November 19,
2007 which explains in detail the basis for the closing.
Your most recent letter requests that the Bar reverse the previous decision to close the file,
without providing any new evidence that would warrant further review. It is clear that the same
allegations were previously considered. We understand that you continue to disagree with the
outcome; however, there is no basis for further disciplinary proceedings.
Sincerely,
c=:: ::> ~ Y? s es
Susan V. Bloemendaal
Chief Branch Discipline Counsel
SVB/emh