Parsons Complaint File No. 2014-30,525 (09A) - Brewer Notice

John F.
Harkness, Executive Director

The Florida Bar
651 East Jefferson Street
Tallahassee, FL 32399-2300
Email: jharkness@flabar.org
Patricia Ann Toro Savitz

The Florida Bar
1000 Legion Place, Suite 1625
Orlando, Florida 32801-1050
Email: psavitz@flabar.org
November 30, 2016 - - Brewer Notice - - to make a record in the following matter:
Re: Gillespie complaint against Danielle Nicole Parsons, TFB No. 2014-30,525 (09A)
Attorney discipline by suspension or disbarment protects the public from bad lawyers
Dear Mr. Harkness and Ms. Savitz,
This is not a request for review by Shanell Schuyler et al.
My complaint against Danielle Nicole Parsons, was limited to matters of discipline of attorneys
(ethics) admitted to practice in Florida. Article V, Section 15, of the Florida Constitution states,
SECTION 15. Attorneys; admission and discipline.The supreme court shall have
exclusive jurisdiction to regulate the admission of persons to the practice of law and the
discipline of persons admitted.
The Florida Supreme Court has exclusive jurisdiction to discipline persons admitted to practice law
My complaint did not ask The Florida Bar to intervene in my case, or take action in any case.
My complaint did not ask The Florida Bar to act as the state attorney, or the attorney general.
My complaint did not ask The Florida Bar to investigate/discipline judges, or act as the JQC.
My complaint did not ask The Florida Bar to address any legal issues, only misconduct (ethics).
Rule 3-4.3, Misconduct and Minor Misconduct states:
The standards of professional conduct to be observed by members of the bar are not
limited to the observance of rules and avoidance of prohibited acts, and the enumeration
herein of certain categories of misconduct as constituting grounds for discipline shall not
be deemed to be all-inclusive nor shall the failure to specify any particular act of
misconduct be construed as tolerance thereof. The commission by a lawyer of any act
that is unlawful or contrary to honesty and justice, whether the act is committed in the
course of the attorney's relations as an attorney or otherwise, whether committed within
or outside the state of Florida, and whether or not the act is a felony or misdemeanor,
may constitute a cause for discipline.
See for example, The Florida Bar v. Donald Joseph Thomas, Supreme Court Case No.
SC10-944, and The Florida Bar File No. 2010-51,555(15G).
Under penalties of perjury, I declare that the foregoing facts are true, correct and complete.
Sincerely,
Neil J. Gillespie
8092 SW 115th Loop
Ocala, Florida 34481
Neil J Gillespie
Telephone: 352-854-7807
Email: neilgillespie@mfi.net
Digitally signed by Neil J Gillespie

DN: cn=Neil J Gillespie, o, ou,
email=neilgillespie@mfi.net, c=US
Date: 2016.11.30 13:17:45 -05'00'
Enclosures
The Florida Bar

John F. Harkness, Jr.
Executive Director
Orlando Branch Office

The Gateway Center
(407) 425-5424
www.FLORIDABAR.org
February 10, 2015

AMENDED
Via email only neilgillespie@mfi.net
Neil J. Gillespie
8092 S.W. 115Th Loop
Ocala, FL 34481
Re:
Complaint by Neil J. Gillespie against Danielle Nicole Parsons

The Florida Bar File No. 2014-30,525 (9A)
Dear Mr. Gillespie:

Pursuant to Rule 3-7.4(k), this document serves as a Letter Report of No Probable Cause
Finding. On the basis of a diligent and impartial analysis of all the information available, on
January 28, 2015, the grievance committee found no probable cause for further disciplinary
proceedings in this matter. The membership of the committee is made up of both attorneys and
non-attorneys.
The grievance committee reviewed all information and documentation submitted by both you
and Ms. Parsons. The allegations in your complaint involve the civil and federal cases regarding
the efforts to pursue a foreclosure on your home. The underlying litigation is ongoing and
vigorously contested. It is clear from your materials that it remains your position that Ms.
Parsons engaged in unethical conduct during her representation of foreclosure plaintiff, Reverse
Mortgage Solutions, Inc. However, the grievance committee has determined that there
insufficient basis for further disciplinary proceedings regarding the actions taken by Ms. Parsons
in the foreclosure case. Moreover, it would appear that the issues raised in this matter are
appropriate for review and determination by a court of competent jurisdiction assigned to handle
such cases. Accordingly, this case is now closed.
Because the bar only has the authority to address questions of ethics, the committee could not
address any legal issues about which you may feel concerned.

Page 2
Pursuant to the Bars records retention schedule, the computer record and file will be disposed of
one year from the date of closing.
Sincerely,

Bar Counsel
cc:
Robert J Stovash, Chair via email

Paul Louis SanGiovanni, Designated Reviewer - via email
Jon Marshall Oden, Investigating Member - via email
Frank Harlan Killgore, Investigating Member - via email
Barry Rodney Davidson, via email bdavidson@hunton.com
The Florida Bar

Executive Director

The Gateway Center
(407) 425-5424
www.FLORIDABAR.org
January 30, 2015
Neil J. Gillespie
Ocala, FL 34481
Re:

Dear Mr. Gillespie:

Pursuant to Rule 3-7.4(k), this document serves as a Letter Report of No Probable Cause
Finding. On the basis of a diligent and impartial analysis of all the information available, on
January 28, 2015, the grievance committee found no probable cause for further disciplinary
proceedings in this matter. The membership of the committee is made up of both attorneys and
non-attorneys. This case is now closed.
Because the bar only has the authority to address questions of ethics, the committee could not
address any legal issues about which you may feel concerned.
Pursuant to the Bars records retention schedule, the computer record and file will be disposed of
one year from the date of closing.
Sincerely,

Bar Counsel
PAS/rmp
cc:
Robert J Stovash, Chair

Paul Louis SanGiovanni, Designated Reviewer
Jon Marshall Oden, Investigating Member
Barry Rodney Davidson, via email bdavidson@hunton.com
Mr. Neil J. Gillespie

Ocala, FL 34481
IN THE SUPREME COURT OF FLORIDA

(Before a Grievance Con1mittee)
IN RE:

NOTICE OF ASSIGNMENT OF INVESTIGATING MEMBER
AND/OR PANEL
TO:
Neil J. Gillespie
8092 SW 115th Loop
Ocala, FL 34481
Barry Rodney Davidson

Counsel for Respondent
Barclays Financial Center
1111 Brickell Ave. Floor 25
Miami, FL 33131-3101
Tele: (305)810-2500
bdavidson@hunton.com
The complaint is hereby assigned to the following member(s) of the committee for
investigation:
Frank Harlan Killgore Jr.
Killgore, Pearlman, Stamp, Ornstein &
Squires
P.O. Box 1913
Orlando, FL 3280-21913
Tele: (407)425-1020
Jon Marshall Oden

Ball Janik L.L.P.
201 E. Pine St. Ste .825
Tele: (407)902-2077
Notice is given that this case will be considered by the committee.

Respondent and complainant shall contact the investigating members within 10
days from the date of this notice to discuss the investigation of this matter.
DATED this 2day of September, 2014.
Bar Counsel
The Florida Bar
(407) 425-5424
psavitz@flabar.org
Copies furnished to:

Frank H. Killgore' Jr., Chair, Ninth Judicial Circuit Grievance Committee "A" and
Investigating Member
Jon Marshall Oden, Investigating Member
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https://www.floridabar.org/DIVEXE/BD/CMStanding.nsf/WGRCommittees/13DEC9302442AC0485256EA700540637?OpenDocument
ABOUT THE BAR
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Grievance Committees
Ninth Circuit Grievance Committee "A"

Grievance committees are made up of volunteer members, at least one-third of whom are not lawyers. Each of Florida's 20 judicial circuits has at least one such committee. The grievance committee reviews complaints
with much the same purpose as a grand jury. That is, the committee decides, after a case is submitted to them by bar counsel, whether there is probable cause to believe a lawyer violated the professional conduct rules
imposed by the Supreme Court of Florida and whether discipline against the lawyer appears to be warranted.
Staff Contact
Patricia A. Savitz
Office
City
Term
Frank Harlan Killgore, Jr.
Chair
Orlando
October, 2014
Robert J Stovash
Vice Chair
Orlando
February, 2015
Paul Louis SanGiovanni
Designated Reviewer
Orlando
June, 2015
Mark Owen Cooper
Attorney Member
Maitland
June, 2017
Jon Marshall Oden
Attorney Member
Orlando
December, 2015
Glennys Eloisa Ortega Rubin
Attorney Member
Orlando
June, 2017
Rhonda Childers *
Public Member
Orlando
February, 2015
Kathy Ennis *
Public Member
Orlando
December, 2015
Gary H. Weber *
Public Member
Orlando
November, 2016
* Public Member
Member Login
[Revised: 09-04-2014]
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The Florida Bar

Executive Director

The Gateway Center
(407) 425-5424
www.FLORIDABAR.org
August 6, 2014
Via email only
Neil J. Gillespie
8092 SW 115th Loop
Ocala, FL 34481
Re:
Complaint of Neil J. Gillespie against Danielle Nicole Parsons

Dear Mr. Gillespie:

This correspondence is to clarify the current status of this matter. The case has been referred to
the Ninth Judicial Circuit Grievance Committee 09A. The chair of the committee is Lisa M.
Acharekar. You will be notified in writing regarding the appointment of Investigating Members
for further investigation by the committee. The case has not been referred to the Attorney
Generals Office or the Office of the Statewide Prosecutor for investigation.
Thank you for your continued cooperation with this matter.
Sincerely,

Bar Counsel
Cc:
Barry R. Davidson, Counsel for Respondent- via email only

Lisa M. Acharekar, Chair- via email only
Page 1 of 1
Neil Gillespie
From:
To:
Cc:
"Rose M Prichnick" <RPrichnick@flabar.org>

<neilgillespie@mfi.net>
"Patti A. Savitz" <psavitz@flabar.org>; <lisa.acharekar@myfloridalegal.com>;
<bdavidson@hunton.com>
Sent:
Wednesday, August 06, 2014 9:26 AM
Attach:
Letter to Complainant.pdf
Subject: Complaint of Neil J. Gillespie against Danielle Nicole Parsons The Florida Bar File No. 2014-30,525
(09A)
Letter to Complainant 08/05/2014
__________________________
Rose M. Prichnick
Legal Secretary
Lawyer Regulation
THE FLORIDA BAR
Phone: 407-425-5424, Ext. 4426

Fax:
407-841-5403
Email: rprichni@flabar.org
Web: http://www.floridabar.org
Please note: Florida has very broad public records laws. Many written communications to or from The Florida Bar
regarding Bar business may be considered public records, which must be made available to anyone upon
request. Your e-mail communications may therefore be subject to public disclosure.
8/6/2014
The Florida Bar

The Gateway Center

Executive Director
(407) 425-5424
www.FLORIDABAR.org
July 29,2014
Via email onlylisa.acharekar@myfloridalegal.com

Lisa M. Acharekar, Chair
Office of Statewide Prosecution
135 W. Central Blvd Stet 1000
Re:

Dear Ms. Acharekar:

This is to advise that the above-referenced matter has been forwarded to your committee for
further investigation and disposition.
The documents will soon be posted to the Grievance Committee Webpage for the Committee's
convenience. As always, if I can be of further assistance, please do not hesitate to contact me.
Sincerely,
Bar Counsel
PAS/rmp
cc:
,I.
.~arry Rodney Davidson, via email onlybdavidson@hunton.com

\./Neil J. Gillespie
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8092 SW 115th l.Joop
Ocala, FL 34481
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THE FLORIDA BAR / Find A Lawyer / MemberProfile
Lisa M. Acharekar
Member in Good Standing
Eligible to Practice Law in Florida
Bar Number:
734721
Address:
Office of Statewide Prosecution

135 W Central Blvd Ste 1000
United States
Phone:
407-245-0893
Fax:
407-245-0356
Email:
lisa.acharekar@myfloridalegal.com
vCard:
County:
Orange
Circuit:
Admitted:
04/12/2004
10-Year Discipline
History:
None
Committees:
Committee
Office
Term
9th Judicial Circuit Grievance Comm "A"
Public Member
2014
Law School:
University of Florida, Fredric G. Levin College of Law
Graduation Year:
2003
Degree:
Doctor of Jurisprudence/Juris Doctor
About the Bar

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Professionalism
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ABOUT THE BAR
NEWS & EVENTS
FOR THE PUBLIC
MEMBER SERVICES
FIND A LAWYER
THE FLORIDA BAR / About the Bar
The Florida Bar
www.floridabar.org
Grievance Committees
Ninth Circuit Grievance Committee "A"

Grievance committees are made up of volunteer members, at least one-third of whom are not lawyers. Each of Florida's 20 judicial circuits has at least one such committee. The grievance committee reviews complaints
with much the same purpose as a grand jury. That is, the committee decides, after a case is submitted to them by bar counsel, whether there is probable cause to believe a lawyer violated the professional conduct rules
imposed by the Supreme Court of Florida and whether discipline against the lawyer appears to be warranted.
Staff Contact
Patricia A. Savitz
Office
City
Term
Frank Harlan Killgore, Jr.
Vice Chair
Orlando
October, 2014
Paul Louis SanGiovanni
Designated Reviewer
Orlando
June, 2015
Mark Owen Cooper
Attorney Member
Maitland
June, 2017
Jon Marshall Oden
Attorney Member
Orlando
December, 2015
Glennys Eloisa Ortega Rubin
Attorney Member
Orlando
June, 2017
Robert J Stovash
Attorney Member
Orlando
February, 2015
Lisa M. Acharekar
Public Member
Orlando
August, 2014
Rhonda Childers *
Public Member
Orlando
February, 2015
Kathy Ennis *
Public Member
Orlando
December, 2015
Gary H. Weber *
Public Member
Orlando
November, 2016
* Public Member
Member Login
[Revised: 06-12-2014]
About the Bar

President's Page
Board of Governors
Committees
What We Do
News, Events &

Publications
Daily News Summary
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For the Public
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Professionalism
Ethics Opinions
LOMAS - Law Office
THE FLORIDA BAR

JOHN
F. HARKNESS, JR.
651 EAST JEFFERSON STREET

TALLAHASSEE, FL 32399-2300
EXECUTIVE DIRECTOR
850/561-5600
WWW.FLORIDABAR.ORG
December 6, 2013
Ms. Danielle Nicole Parsons
225 E Robinson St Ste 660
Re:
Dear Ms. Parsons:

Enclosed is a copy of an inquiry/complaint and any supporting documents submitted by the
above referenced complainant(s). Your response to this complaint is required under the
provisions of Rule 4-8.4(g), Rules of Professional Conduct of the Rules Regulating The Florida
Bar, and is due in our office by December 20, 2013. Responses should not exceed 25 pages and
may refer to any additional documents or exhibits that are available on request. Faillire to
provide a written response to this complaint is in itself a violation of Rule 4-8.4(g). Please note
that any correspondence must be sent through the u.s. mail; we cannot accept faxed material.
You are further required to furnish the complainant with a complete copy of your written
response, including any documents submitted therewith.
Please note that pursuant to Rule 3-7.1 (b), Rules of Discipline, any reports, correspondence,
papers, recordings and/or transcripts of hearings received from either you or the complainant(s)
shall become a part of the public record in this matter and thus accessible to the public upon a
disposition of this file. It should be noted that The Florida Bar is required to acknowledge the
status of proceedings during the pendency of an investigation, if a specific inquiry is made and
the matter is deemed to be in the public domain. Pursuant to Rule 3-7.1(t), Rules of Discipline,
you are further required to complete and return the enclosed Certificate of Disclosure form.
Further, please notify this office, in writing, of any pending civil, criminal, or administrative
litigation which pertains to this grievance. Please note that this is a continuing obligation should
new litigation develop during the pendency of this matter.

December 6, 2013
Page Two
Finally, the filing of this complaint does not preclude conlmunication between the attorney and
the complainant(s). Please review the enclosed Notice for information on submitting your
response.
Sincerely,
.~ ~
. . . . . . . Q,1I.
Theodore P. Littlewood Jr., Bar Counsel

Attorney Consumer Assistance Program
ACAP Hotline 866-352-0707
Enclosures (Certificate of Disclosure, Notice of Grievance Procedures, Copy of Complaint,

Notice - Mailing Instructions)
cc:
NOTICE OF GRIEVANCE PROCEDURES
1.
The enclosed letter is an informal inquiry. Your response is required under the
provisions of The Rules Regulating The Florida Bar 4 8.4(g), Rules of Professional Conduct.
Failure to provide a written response to this complaint is in itself a violation of Rule 4 8.4(g). If
you do not respond, the matter will be forwarded to the grievance committee for disposition in
accordance with Rule 3-7.3 of the Rules of Discipline.
2.
Many complaints considered first by staff counsel are not forwarded to a grievance
committee, as they do not involve violations of the Rules of Professional Conduct justifying
disciplinary action.
3.
"Pursuant to Rule 3-7.I(a), Rules of Discipline, any response by you in these proceedings
shall become part of the public record of this matter and thereby become accessible to the public
upon the closllre of the case by Bar counselor upon a finding of no probable cause, probable
cause, minor misconduct, or recommendation of diversion. Disclosure during the pendency of
an investigation may be made only as to status if a specific inquiry concerning this case is made
and if this matter is generally known to be in the public domain."
4.
The grievance committee is the Bar's "grand jury." Its function and procedure are set
forth in Rule 3-7.4. Proceedings before the grievance committee, for the most part, are non
adversarial in nature. However, you should carefully review Chapter 3 of the Rules Regulating
The Florida Bar.
5.
If the grievance committee finds probable cause, formal adversarial proceedings, which
ordinarily lead to disposition by the Supreme Court of Florida, will be commenced under
3-7.6, unless a plea is submitted under Rule 3-7.
NOTICE
Mailing Instructions
The Florida Bar converts its disciplinary files to electronic media. All submissions are being scanned
into an electronic record an~ hard copie.s are discarded. To help ensure the timely process~g of your
inquiry/complaint, please review the following guidelines prior to sublnitting it to our office.
1. Please limit your su bmission to no more than 25 pages including exhibits. If you have
additional documents available, please make reference to them in your written submission as
available upon request. Should Bar counsel need to obtain copies of any such documents, a
subsequent request will be sent to you.
2. Please do not .bind, or index your documents. You may underline but do not highlight
documents under any circumstances. We ~can documents for use in our disciplinary files and
when scanned, your doculnent highlighting will eith.er not be picked up or may obscure any
underlying text.
3. Please refrain from attaching media such as audio tapes or CDs, oversized do~iiinents, or.
photographs. We cannot procfss any n:edia that cannot be scanned into tIle electronic record.
4. Please do not submit your original documents. All documents will be discarded after
scan.ning and we will not be able to return any originals" submitted to our office. The only
original document .that should be proyided to our office is the inquiry/complai?t form.
5. Please do not submit confidential or privileged information. Documents submitted to our
office become public rec.ord. Confidential/privileged information should be redacted. Such
infonl1ation includes, but is not lill1ited to, ballk account numbers, social security numbers, credit
card ac.count nUlnbers, 111edical records, dependency nlatters, termination of parental rights,
guardian ad litem records, child abuse records, adoption records, doclilnents containing names of
lninor children, original birth and death certificates, Baker Act records, grand jury records, and
juvenile delinquency r~cords. If information of this nature is important to your submission,
please describe the nature of the infonnation and indicate that it is available upon request. Bar
counsel will contact you to make appropriate arrangements for the protection of any such
infonnation that is required as part of the investigation of the .complaint.
Please be aware that materials received that do not meet these guidelines may be returned. ThaJ.lk
you for your consideration in this respect.
THE FLORIDA BAR

651 EAST JEFFERSON STREET
JOHN
F. HARKNESS, JR.
TALLAHASSEE,
FL 32399-2300
EXECUTIVE DIRECTOR
850/561-5600
WWW.FLORIDABAR.ORG
December 6, 2013
8092 S.W. 115th Loop
Ocala, FL 34481
Re:
Danielle Nicole Parsons; The Florida Bar File No. 2014-30,525 (9A)
Dear Mr. Gillespie:

Enclosed is a copy of our letter to Ms. Parsons which requires a response to your complaint.
Once you receive Ms. Parsons's response, you have 10 days to file a rebuttal if you so desire. If
you decide to file a rebuttal, you must send a copy to Ms. Parsons. Rebuttals should not exceed
25 pages and may refer to any additional documents or exhibits that are available on request. Please
address any and all correspondence to me. Please note that any correspondence must be sent
through the U.S. mail; we cannot accept faxed material.
Please be advised that as an arm of the Supreme Court of Florida, The Florida Bar can
investigate allegations of misconduct against attorneys, and where appropriate, request that the
attorney be disciplined. The Florida Bar cannot render legal advice nor can The Florida Bar
represent individuals or intervene on their behalf in any civil or crinlinal nlatter. Further, please
notify this office, in writing, of any pending civil, criminal, or administrative litigation which
pertains to this grievance. Please note that this is a continuing obligation should new litigation
develop during the pendency of this matter.
Please review the enclosed Notice on mailing instructions for information on submitting your
rebuttal.
Sincerely,
..:
<0
~", ~."'''''
"
.~~~.
Theodore P. Littlewood Jr., Bar Counsel

Attorney Consumer Assistance Program
ACAP Hotline 866-352-0707
Enclosures (Notice of Grievance Procedures, Copy of Letter to Ms. Parsons; Notice - Mailing
Instructions)
cc:
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THE FLORIDA BAR
INQUIRy/COMPLAINT FORM
PART ONE (See Pa2e 1, PART ONE - Required Information.):
Your Name: Neil 1. Gillespie
Attorney's Nan1e: Danielle Nicole Parsons
Organization: n/a
Address: 225 E. Robinson St., Suite 660
Address: 8092 SW 115th Loop

City: Ocala
Zip Code: 34481
City: Orlando
State: FL
Zip Code: 32801
State: ~
Telephone: 407-674-1850
Phone: 352-854-7807
Email: neilgillespie@mfi.net
ACAP Reference No. none
-----------
PART TWO (See Pa2e 1, PART TWO - Facts/Alle2ations.): The specific thing or things I am complaining about are:
See accompanying complaint.
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 ofperjury, I declare that the foregoing facts are
true, correct and complete.
Date
John F. Harkness, Executive Director

The Florida Bar
651 East Jefferson Street
Email: jharkness@flabar.org
VIA U.P.S. No. 1Z64589F0392969709
Ghunise Coaxum, UPL Bar Counsel

Florida Bar Orlando Branch Office
Email: N/A
VIA U.P.S. No. 1Z64589FP293587311
Lori Holcomb, UPL Counsel, Unlicensed

Practice Of Law Standing Committee
The Florida Bar, 651 East Jefferson Street
Email: lholcomb@flabar.org
VIA U.P.S. No. 1Z64589FP294475323
Patricia M. Moring, Chair

Fifth Circuit UPL Committee
Moring & Moring, P.A.
7655 W. Gulf To Lake Hwy. Suite 12
Crystal River, Florida 34429-7910
Email: pmoring@moringlaw.com
VIA U.P.S. No. 1Z64589FP291806499
December 2, 2013
Florida Bar Complaint against Danielle Nicole Parsons, FL Bar ID 29364, for her own
misconduct, and misconduct in supervision of her paralegal Yolanda I. Martinez.
Note: The Florida Bar is investigating me for UPL for representing my interests in his
matter, the wrongful foreclosure of my homestead on a HECM reverse mortgage.
Dear Ladies and Gentlemen of The Florida Bar:
Enclosed please find a signed Florida Bar inquiry/complaint form for Danielle Nicole Parsons,
FL Bar ID 29364, for her own misconduct, and misconduct in supervision of her paralegal
Yolanda I. Martinez, a non-lawyer. Ms. Parsons and Ms. Martinez are employed by McCalla
Raymer, LLC, 225 E. Robinson St., Suite 660, Orlando, FL 32801.
Wet-ink signed documents were provided to Mr. Harkness. Copies were provided otherwise.
[Rule 2.515(c), Fla.R.Jud.Admin.].
This inquiry/complaint against Danielle Nicole Parsons shows misconduct for Ms. Parsons, some
of which is attributable only to Ms. Parsons. Other misconduct by Ms. Parsons is related to UPL
and fraud of Ms. Martinez. Separately I made a UPL complaint against Yolanda I. Martinez, a
non-lawyer, which is presented with this Bar inquiry/complaint in a Separate Appendix. Due to
The Bars 25 page limit, the UPL Appendix for Ms. Martinez is not provided, but is available on
request. For The Bars convenience all the Exhibits and the UPL Appendix are posted on Scribd.
This inquiry/complaint against Danielle Nicole Parsons also shows misconduct for Ms. Parsons
as the attorney responsible for supervising Ms. Martinez. A member of The Florida Bar is
responsible for the work of a paralegal. Rule 10-2.1(b).
Rules Governing Unlicensed Practice, 10-2 Definitions
Rule 10-2.1. Generally
Florida Bar Complaint, Danielle Nicole Parsons

McCalla Raymer LLC, Orlando Florida
December 2, 2013
Page - 2
(b) Paralegal or Legal Assistant. A paralegal or legal assistant is a person qualified by

education, training, or work experience, who works under the supervision of a member of
The Florida Bar and who performs specifically delegated substantive legal work for
which a member of The Florida Bar is responsible. A nonlawyer or a group of
nonlawyers may not offer legal services directly to the public by employing a lawyer to
provide the lawyer supervision required under this rule. It shall constitute the unlicensed
practice of law for a person who does not meet the definition of paralegal or legal
assistant to use the title paralegal, legal assistant, or other similar term in offering to
provide or in providing services directly to the public.
Table of Contents
Section I.
Section II.
P. 4
P. 5
Section III.
P. 7
Section IV.
Section V.
Section VI.
Section VII.
Section VIII.
Section IX.
Section X.
Section XI.
Section XII.
Section XIII.
P. 13
P. 18
P. 19
P. 20
E. 15
E. 15
E. 15
E. 15
E. 15
E. 15
Cases involved, foreclosure of a HECM reverse mortgage; SCOTUS

Rule 4-3.3 Candor Toward The Tribunal; Information Packet, Candor
Toward the Tribunal, UPL-paralegal, federal offenses, judicial misconduct
Ms. Parsons Rule 4-3.3 Candor violations, state court Verified Complaint,
Misconduct by Ms. Parsons in state court, prior to removal to U.S.D.C.
UPL of paralegal Yolanda I. Martinez in federal court
Fraud or impairment by Ms. Martinez/Ms. Parsons of federal case
Ex parte communication Ms. Martinez/Ms. Parsons, federal judicial officers
UPL of paralegal Yolanda I. Martinez in state court
UPL investigation of Neil Gillespie for defending foreclosure of his home
Mr. Rodems legal advice to Gillespie on foreclosure of reverse mortgage
Political persecution of Neil Gillespie by The Florida Bar et al.
U.S. Congressman Elijah E. Cummings letter to FHFA, McCalla Raymer
McCalla Raymer LLC, criminal enterprise for Atty. Gen. investigation
Disability of Neil J. Gillespie, exploitation by McCalla Raymer/RMS
Overview
Danielle Nicole Parsons represents client Reverse Mortgage Solutions, Inc. by and through
McCalla Raymer LLC, supported by paralegal Yolanda I. Martinez, in cases involving the
disputed foreclosure of my homestead on a Home Equity Conversion Mortgage1 or HECM, a
FHA2 reverse mortgage program administered by the United States Department of Housing
and Urban Development. (HUD).
My name is Neil J. Gillespie, a law-abiding, indigent, 57 year-old disabled single man, a
surviving reverse mortgage borrower and homeowner reluctantly appearing pro se to save my
home in a 55+ community in Ocala Florida from wrongful foreclosure.
12 U.S.C. 1715z20 - Insurance of home equity conversion mortgages for elderly

homeowners, and 24 C.F.R. Part 206, Home Equity Conversion Mortgage Insurance.
2
The Federal Housing Administration (FHA) is a United States government agency.

December 2, 2013
Page - 3
Ms. Parsons repeatedly violated Rule 4-3.3 Candor Toward The Tribunal. Her Complaint filed in
state court was so misleading that I included The Bars Information Packet, Candor Toward the
Tribunal in my motion to dismiss. Ms. Parsonss misconduct in federal court, her Agreed To
Motion For Extension of Time (Doc. 11) was a fraud on the court aided by paralegal Martinez.
Henceforth I included a printout of The Bars Rule 4-3.3 Candor Toward The Tribunal in my
Rule 11 Motion for Sanctions, and Verified Objection To, And Motion For Relief From, A
Magistrate Judges Order (Doc. 12). I found Ms. Parsons to be a compete liar.
The American Bar Association reported online in the ABA Journal Law News Now a story May
17, 2013 by Debra Cassens Weiss, Law prof confesses: I am a sociopath. The article is adapted
from a memoir called Confessions of a Psychopath: A Life Spent Hiding in Plain Sight, written
under the pseudonym M. E. Thomas. As quoted from the ABA story:
Before becoming a trial lawyer, the author says she prosecuted misdemeanors in the
District Attorneys office and was an associate in a law firm. "My sociopathic traits make
me a particularly excellent trial lawyer," Thomas writes. "I'm cool under pressure. I feel
no guilt or compunction, which is handy in such a dirty business. Misdemeanor
prosecutors almost always have to walk into a trial with cases they've never worked on
before. All you can do is bluff and hope that you'll be able to scramble through it. The
thing with sociopaths is that we are largely unaffected by fear. Besides, the nature of the
crime is of no moral concern to me; I am interested only in winning the legal game."
http://www.abajournal.com/news/article/law_prof_confesses_i_am_a_sociopath/
The American Bar Association reported online in the ABA Journal Law News Now a story
November 13, 2012 by Debra Cassens Weiss, The Legal Field Attracts Psychopaths, Author
Says; Not That There Is Anything Wrong with That. The story appears at the link below.
http://www.abajournal.com/news/article/the_legal_field_attracts_psychopaths_author_says_not_
that_there_is_anything/
Any profession that does not see a problem with attracting Psychopaths will have difficulty
enforcing, for example, The Bars Rule 4-3.3 Candor Toward The Tribunal, inter alia.
Disabled pro se parties are vulnerable to attorney misconduct, which often denies them
meaningful access to justice in court proceedings. The American Bar Association is the national
representative of the legal profession. The ABA has reported in the above cited stories that the
legal field attracts psychopaths and sociopaths. Disabled pro se parties need protection from
opposing counsel who are psychopaths or sociopaths, or who use those psychopathic or
sociopathic litigation tactics, in order to guarantee disabled pro se parties due process and equal
protection rights. Disability accommodation is a reasonable way to assure access legal and court
services in a legal action in an effective and expeditious manner, as required by the Constitution
and laws of the United States of America, and the Constitution and laws of the State of Florida.

December 2, 2013
Page - 4
Ghunise Coaxum, UPL Bar Counsel, opened a vexatious UPL investigation of me for defending
my interest in this foreclosure, on the complaint of attorney Ryan Christopher Rodems, a partner
in the firm Barker, Rodems & Cook who formerly represented me. The UPL investigation of me
by The Florida Bar is political persecution that also includes U.S. Judge William Terrell Hodges,
and Florida attorney Eugene P. Castagliuolo, in retaliation for my Petition No. 12-7747 to the
U.S. Supreme Court seeking, inter alia, better regulation of the legal profession.
U.S. Congressman Elijah E. Cummings complained to the FHFA, the Federal Housing Finance
Administration, about fraud and misconduct by foreclosure mills, most of whom are Florida law
firms. McCalla Raymer LLC is named in the Congressmans letter to the FHFA. Unfortunately
the Florida Attorney General is not protecting Floridians from lawyers operating as criminals
who are wrongly taking homes from people under color of law without due process.
Section I.
Cases involved, foreclosure of a HECM reverse mortgage; SCOTUS
Reverse Mortgage Solutions, Inc. v. Neil J. Gillespie, et al., Marion County Florida, Fifth
Judicial Circuit, No. 42-2013CA-000115-AXXX-XX, a.k.a. case no. 2013-CA-000115.
Presiding. Hon. Hale Ralph Stancil, Florida Circuit Court Judge, trial judge Marion Co.
Reverse Mortgage Solutions, Inc. v. Neil J. Gillespie, et al., removed February 4, 2013 to U.S.
District Court, Ocala Division, Middle District Florida, No. 5:13-cv-00058-WTH-PRL
Presiding. U.S. Judge William Terrell Hodges, Senior Status, trial judge Ocala Division
Presiding U.S. Magistrate Judge Philip R. Lammens, magistrate judge Ocala Division
Reverse Mortgage Solutions, Inc. v. Neil J. Gillespie, et al., U.S. Court of Appeals for the
Eleventh Circuit, No. 13-11585-B.
This matter, inter alia, is before the Supreme Court of the United States, Petition No. 13-7280,
Neil J. Gillespie v. Reverse Mortgage Solutions, Inc. et al. The Florida Bar is a cross-party for
political persecution of me in retaliation for me seeking a First Amendment redress of grievances
in Petition No. 12-7747, and the case with Reverse Mortgage Solutions, Inc. and Neil J. Gillespie
v. Thirteenth Judicial Circuit Florida et al, 5:11-cv-539-WTH-TBS in U.S. District Court, Ocala.
Petition No. 13-7280 alleges UPL by Ms. Martinez in the Table of Contents, and on page 34:
UPL by paralegal Yolanda I. Martinez, McCalla Raymer, Rule 10-2.1(a), Ethics Opinion
70-62, activity which requires the attorney's personal judgment and participation;
Florida Court, see emails Aug-07-2013 Gillespie-Martinez (Sep. Vol. App No. 2);
District Court, see Rule 11 sanction motion (Doc. 15); Rule 55 motion for default
judgment, (Doc. 16); Rule 72/Rule 60(b)(3) Verified Objection to Magistrate Order (Doc.
17); Affidavit 28 U.S.C. 144 (Doc. 22)
If I had more time to make the petition I would have drawn a sharper point on the misconduct of
Ms. Parsons. Still, the pleadings speak for themselves, Ms. Parsons Verified Complaint to

December 2, 2013
Page - 5
Foreclose Home Equity Conversion Mortgage in Florida case no. 2013-CA-000115, and her
Agreed Motion For Extension of Time (Doc. 11) in federal case 5:13-cv-00058-WTH-PRL.
Section II.
Rule 4-3.3 Candor Toward The Tribunal; UPL by a paralegal, federal

offenses, judicial misconduct
RULE 4-3.3 CANDOR TOWARD THE TRIBUNAL

(a) False Evidence; Duty to Disclose. A lawyer shall not knowingly:
(1) make a false statement of material fact or law to a tribunal;
(2) fail to disclose a material fact to a tribunal when disclosure is necessary to avoid
assisting a criminal or fraudulent act by the client;
(3) fail to disclose to the tribunal legal authority in the controlling jurisdiction known to
the lawyer to be directly adverse to the position of the client and not disclosed by
opposing counsel; or
(4) permit any witness, including a criminal defendant, to offer testimony or other
evidence that the lawyer knows to be false. A lawyer may not offer testimony that the
lawyer knows to be false in the form of a narrative unless so ordered by the tribunal. If a
lawyer has offered material evidence and thereafter comes to know of its falsity, the
lawyer shall take reasonable remedial measures.
(b) Extent of Lawyer's Duties. The duties stated in subdivision (a) continue beyond the
conclusion of the proceeding and apply even if compliance requires disclosure of information
otherwise protected by rule 4-1.6.
(c) Evidence Believed to Be False. A lawyer may refuse to offer evidence that the lawyer
reasonably believes is false.
(d) Ex Parte Proceedings. In an ex parte proceeding a lawyer shall inform the tribunal of all
material facts known to the lawyer that will enable the tribunal to make an informed decision,
whether or not the facts are adverse.
Rule 102.1(b) of the Rules Regulating The Florida Bar defines a paralegal as a person who
works under the supervision of a member of The Florida Bar and who performs specifically
delegated substantive legal work for which a member of The Florida Bar is responsible. Only
persons who meet the definition may call themselves paralegals.
Professional Ethics of The Florida Bar (Exhibit 1)
Ethics Opinion 70-62, February 12, 1971
Lay personnel may be used in a law office only to the extent that they are
delegated mechanical, clerical or administrative duties. The attorney may not
ethically delegate to a lay employee any activity which requires the attorney's
personal judgment and participation.

December 2, 2013
Page - 6
Paralegals in a law office and the unlicensed practice of law.(UPL Update)

Florida Bar News - February 15, 2004, by Ghunise Coaxum (Exhibits 2 and 3)
Attorneys rely on paralegals and other nonlawyer office staff to perform various
activities. Generally, the activity may constitute the unlicensed practice of law if
it is something that requires the attorney's independent judgment and
participation, and it is performed by the paralegal. See, The Florida Bar Ethics
Opinion, 70-62.
Fraud or Impairment of a legitimate government activity, 18 U.S.C. 371
DOJ Criminal Resource Manual 923, paragraph 1
18 U.S.C. 371Conspiracy to Defraud the United States
The general conspiracy statute, 18 U.S.C. 371, creates an offense "[i]f two or more
persons conspire either to commit any offense against the United States, or to defraud the
United States, or any agency thereof in any manner or for any purpose. (emphasis added).
See Project, Tenth Annual Survey of White Collar Crime, 32 Am. Crim. L. Rev. 137,
379-406 (1995)(generally discussing 371).
http://www.justice.gov/usao/eousa/foia_reading_room/usam/title9/crm00923.htm
925 Obstructing or Impairing Legitimate Government Activity
1739 Offenses Related to Obstruction of Justice Offenses
Deprivation of rights under color of law, 18 U.S.C. 242
DOJ Summary. Section 242 of Title 18 makes it a crime for a person acting under color
of any law to willfully deprive a person of a right or privilege protected by the
Constitution or laws of the United States.
http://www.justice.gov/crt/about/crm/242fin.php
Conspiracy against rights, 18 U.S.C. 241.
If two or more persons conspire to injure, oppress, threaten, or intimidate any person in
any State, Territory, Commonwealth, Possession, or District in the free exercise or
enjoyment of any right or privilege secured to him by the Constitution or laws of the
United States, or because of his having so exercised the same; or

December 2, 2013
Page - 7
If two or more persons go in disguise on the highway, or on the premises of another, with
intent to prevent or hinder his free exercise or enjoyment of any right or privilege so
secured
They shall be fined under this title or imprisoned not more than ten years, or both; and if
death results from the acts committed in violation of this section or if such acts include
kidnapping or an attempt to kidnap, aggravated sexual abuse or an attempt to commit
aggravated sexual abuse, or an attempt to kill, they shall be fined under this title or
imprisoned for any term of years or for life, or both, or may be sentenced to death.
http://www.law.cornell.edu/uscode/text/18/241
Letter May 28, 2013 from U.S. Senator Bill Nelson of Florida, and six pages of information on
making a complaint under the Judicial Conduct and Disability Act of 1980, 28 U.S.C. 351364 ("Act"). (Exhibit 10). From page 13 of Petition No. 13-7280:
U.S. Senator Bill Nelson provided in his letter to me May 28, 2013 information on how
to make a complaint of judicial misconduct3. I believe the success rate is about zero for a
pro se litigant who makes a complaint of judicial misconduct, regardless of the
complaints merits.
Also, I am not familiar enough with the federal complaint process to make a judicial complaint. I
do not have time to stop and learn the process now. I am trying to save my home from wrongful
foreclosure. Judicial complaints, like Bar complaints, do not provide the complainant with any
useful relief. If time allows later, I may make a complaint then, if needed.
Section III
Ms. Parsons Rule 4-3.3 Candor violations, state court Verified Complaint
Impeachment of Ms. Parsons Verified Complaint (Doc. 2)(Exhibit 4) is found in my Motion To

Dismiss Verified Complaint To Forecloses Home Equity Conversion Mortgage, filed February 4,
2013 in state court, and immediately removed to U.S. District Court, Ocala. (Doc. 5)(Exhibit 18)
I only filed one motion to dismiss and noted it was a response for me personally, and as a cotrustee. For the sake of clarity, I only represent my interest in the trust. The other co-trustee, my
brother Mark Gillespie, is represented by counsel, Kaufman, Englett and Lynd, PLLC, which
filed Notice of Defendants Consent to Judgment in 42-2013CA-000115 for his interests.
Ms. Parsons verification of her Verified Complaint was a defective, a sham. For one thing,
there were no identifiable exhibits attached to the so-called Verified Complaint. The following
text is taken from my motion to dismiss, begining 17, filed as Document 5 in federal court.
3
Filing a Complaint of Judicial Misconduct or Judicial Disability Against A Federal Judge. The
process is governed by the Judicial Conduct and Disability Act of 1980, 28 U.S.C. 351-364
(Act), and Rules for Judicial-Conduct and Judicial-Disability Proceedings, 248 F.R.D. 674
(2008)

December 2, 2013
Page - 8
PLAINTIFFS DEFECTIVE RULE 1.110(b) VERIFICATION OF THE COMPLAINT

No Identifiable Exhibits are Attached to the Verified Complaint
17. There are no Exhibits attached to the Verified Complaint that are identifiable with the
pleadings. The Verified Complaint alleges at paragraph 2, Copies of the Note and
Mortgage are attached as Exhibits "A" and "B," respectively. This is false. There is
nothing attached as Exhibits "A" and "B," respectively. Instead, defective copies of the
HECM Note and Second Note taken from the HUD complaint appear as Exhibits 11 and
12, and are missing the Direct Endorsement Allonge that became a permanent part of
said Note on May 29, 2008 (Exhibit 4) which date occurred a week before the HECM
closing June 5, 2008, when the Note and Mortgage were executed and delivered from the
Borrowers to the Lender, Liberty Reverse Mortgage, Inc. Somehow Liberty sold a
nonexistent Note and Mortgage to Bank of America. This is a fatal defect to the chain of
custody of the HECM Note and Mortgage.
18. Likewise, defective copies of the HECM Mortgage and Second Mortgage taken from
the HUD complaint are attached as Exhibits 32 and 33, and show interlineation after
execution, hand-written alterations, not initialed and not dated, which vitiates the
Mortgage. This defect only became known to Neil Gillespie in July 2012 when he found
it filed with the Clerk.
19. Paragraph 3 of the Verified Complaint alleges, Copies of the relevant Assignments
of Mortgage are attached as Composite Exhibit "C." This is false. Nothing is attached as
Composite Exhibit "C." Instead, a single unmarked page, Assignment of Mortgage,
March 27, 2012, from Bank of America to the Plaintiff, appears at the end of the Verified
Complaint. Any previous assignments of mortgage are missing.
Ms. Parsons also misidentified this residential homestead foreclosure in a 55+ community as a
commercial foreclosure on the Civil Cover sheet Form 1.997 attached to Verified Complaint. I
speculate this dishonesty was to make difficult asserting consumer defense claims.
THIS IS NOT A COMMERCIAL FORCLOSURE Counsels Misrepresentation: Civil
Cover Sheet Form 1.997 attached to Verified Complaint (Exhibit 17, this Bar complaint)
20. Counsel wrongly filed this action as a Commercial foreclosure $50,001 -$249,999
shown on Form 1.997 CIVIL COVER SHEET, II. TYPE OF CASE, attached to the
Verified Complaint, and signed by Plaintiffs counsel Danielle Parsons, who represented
I CERTIFY that the information I have provided in this cover sheet is accurate to the
best of my knowledge and belief. Counsels certification is false. This properly is the
homestead of Neil Gillespie under Section 4, Article X of the Florida Constitution. This
action is a Homestead residential foreclosure $50,001 -$249,999. Oak Run is a
residential senior citizen community. No commercial activity is permitted. The HECM
reverse mortgage was made on the residential property. It appears counsels false

December 2, 2013
Page - 9
declaration was intended to deceive the Clerk and the Court that this is a commercial
foreclosure, in violation of F.S. 837.06, False official statements.
F.S. 837.06, False official statements is the Perjury chapter
837.06 False official statements.Whoever knowingly makes a false statement in
writing with the intent to mislead a public servant in the performance of his or her official
duty shall be guilty of a misdemeanor of the second degree, punishable as provided in s.
775.082 or s. 775.083.
From my motion to dismiss page 39, 149:
Supreme Court of Florida and The Verification Rule
149. On February 11, 2011, the Supreme Court of Florida decided it was time to address
the so-called lost note count and released In re Amendments to the Florida Rules of Civil
Procedure. Among other things, this opinion called for an amendment to Rule 1.110(b) of
the Florida Rules of Civil Procedure to require verification of mortgage foreclosure
complaints involving residential real property. In an effort to end fraud on the court by
foreclosing plaintiffs, the Supreme Court now required parties to verify, under penalty of
perjury, that the information in the complaint is true and correct to the best of their
knowledge and belief.
150. The Verified Complaint alleges at paragraph 4 entitlement to enforce the Note
and Mortgage, but the Plaintiff has not provided copies of the Note and Mortgage as
pled. Therefore the Verified Complaint fails to state a cause of action and must be
dismissed.
151. The Plaintiff alleged in the Verified Complaint, paragraph 2, Copies of the Note
and Mortgage are attached as Exhibits A and B respectively. Plaintiffs statement is
false. There are no Exhibits A and B attached to the Complaint. The only exhibits
attached to the Complaint are numbered, not lettered. Those exhibits are numbered 11,
12, 32 and 33 and therefore impossible to relate to the Verified Complaint or the
Plaintiffs alleged claims therein.
152. The Verified Complaint, in paragraph 3, states The described subject Mortgage
was subsequently assigned to Plaintiff. Copies of the relevant Assignments of Mortgage
are attached as Composite Exhibit "C." Plaintiffs statement is false. There is no
Composite Exhibit C attached to the Complaint. There is a single page attached
purporting to be an Assignment of Mortgage attached but it is not marked in any way as
an Exhibit or Composite and therefore impossible to relate to the Verified Complaint or
the Plaintiffs alleged claims therein..

December 2, 2013
Page - 10
153. The Verified Complaint is verified pursuant to Rule 1.110(b), Fla. R. Civ. P., by
Debbie Sims, Vice President, Reverse Mortgage Solutions, Inc., on December 20, 2012,
and includes the following statement:
UNDER PENALTY OF PERJURY, I declare that I have read the foregoing and that the
facts alleged therein are true and correct to the best of my knowledge and belief.
154. Debbie Sims, under penalty of perjury, declared that she read the Verified
Complaint and that the facts alleged therein were true and correct. The Verified
Complaint at paragraph 2 states a fact: Copies of the Note and Mortgage are attached as
Exhibits A and B respectively. This fact is not true and correct. This statement is
false. Exhibits A and B are not attached.
155. Debbie Sims, under penalty of perjury, declared that she read the Verified
Complaint and that the facts alleged therein were true and correct. The Verified
Complaint at paragraph 3 states a fact: Copies of the relevant Assignments of Mortgage
are attached as Composite Exhibit "C." This fact is not true and correct. This statement
is false. Composite Exhibit C is not attached.
FRAUD ON THE COURT
Perjury by Debbie Sims Intended to Mislead the Court
157. The Defendants respectfully requests the Court on its own initiative to DISMISS
WITH PREJUDICE the Plaintiffs VERIFIED COMPLAINT TO FORECLOSE HOME
EQUITY CONVERSION MORTGAGE as a sanction imposed for perjury by Debbie
Sims who verified for the Plaintiff under penalty of perjury facts as true and correct,
when those facts were not true and correct, contrary to her Verification as Vice President
for the Plaintiff made under Rule 1.110(b) Fla.R.Civ.P.
158. Debbie Sims, by alleging facts under penalty of perjury as true and correct, when
those facts are not true and correct, violated section 837.06, Florida Statutes, False
official statements.
837.06 False official statements.Whoever knowingly makes a false statement in
writing with the intent to mislead a public servant in the performance of his or her
official duty shall be guilty of a misdemeanor of the second degree, punishable as
provided in s. 775.082 or s. 775.083.
Debbie Sims knowingly made a false statement in writing with the intent to mislead this
Court to benefit the Plaintiff in this HECM reverse mortgage residential home
foreclosure.
Danielle N. Parsons, Esq. - Officer of the Court
Lack of Candor Before The Tribunal

December 2, 2013
Page - 11
159. Plaintiffs counsel, Danielle N. Parsons, Esq. (Fla. Bar No.: 0029364), submitted
the Verified Complaint to the Court and bears responsibility for perjury by Debbie Sims
made on behalf of the Plaintiff in this residential mortgage foreclosure. As an attorney,
Ms. Parsons is an officer of this Court, and her conduct is subject to judicial supervision
and scrutiny:
Attorney is an officer of the court and an essential component of the
administration of
justice, and, as such, his conduct is subject to judicial supervision and scrutiny.
State ex rel. Florida Bar v. Evans, 94 So.2d 730 (1957).
As an attorney, Ms. Parsons must comply with the Rules of Professional Conduct,
including candor before the tribunal, as described in the Florida Bar Informational
Packet, Candor Before The Tribunal, provided in Defendants Composite A. The
lawyer's duty not to assist witnesses, including the lawyer's own client, in offering false
evidence stems from the Rules of Professional Conduct, Florida statutes, and caselaw.
Rule 4-1.2(d) prohibits the lawyer from assisting a client in conduct that the lawyer
knows or reasonably should know is criminal or fraudulent.
Rule 4-3.4(b) prohibits a lawyer from fabricating evidence or assisting a witness to testify
falsely.
Rule 4-8.4(a) prohibits the lawyer from violating the Rules of Professional Conduct or
knowingly assisting another to do so.
Rule 4-8.4(b) prohibits a lawyer from committing a criminal act that reflects adversely on
the lawyer's honesty, trustworthiness, or fitness as a lawyer.
Rule 4-8.4(c) prohibits a lawyer from engaging in conduct involving dishonesty, fraud,
deceit, or misrepresentation.
Rule 4-8.4(d) prohibits a lawyer from engaging in conduct that is prejudicial to the
administration of justice.
Rule 4-1.6(b) requires a lawyer to reveal information to the extent the lawyer reasonably
believes necessary to prevent a client from committing a crime.
This rule, 4-3.3(a)(2), requires a lawyer to reveal a material fact to the tribunal when
disclosure is necessary to avoid assisting a criminal or fraudulent act by the client, and 43.3(a)(4) prohibits a lawyer from offering false evidence and requires the lawyer to take
reasonable remedial measures when false material evidence has been offered.
Rule 4-1.16 prohibits a lawyer from representing a client if the representation will result
in a violation of the Rules of Professional Conduct or law and permits the lawyer to

December 2, 2013
Page - 12
withdraw from representation if the client persists in a course of action that the lawyer
reasonably believes is criminal or fraudulent or repugnant or imprudent. Rule 4-1.16(c)
recognizes that notwithstanding good cause for terminating representation of a client, a
lawyer is obliged to continue representation if so ordered by a tribunal.
160. Florida caselaw prohibits lawyers from presenting false testimony or evidence.
Kneale v. Williams, 30 So. 2d 284 (Fla. 1947), states that perpetration of a fraud is
outside the scope of the professional duty of an attorney and no privilege attaches to
communication between an attorney and a client with respect to transactions constituting
the making of a false claim or the perpetration of a fraud. Dodd v. The Florida Bar, 118
So. 2d 17 (Fla. 1960), reminds us that "the courts are . . . dependent on members of the
bar to . . . present the true facts of each cause . . . to enable the judge or the jury to
[decide the facts] to which the law may be applied. When an attorney . . . allows false
testimony . . . [the attorney] . . . makes it impossible for the scales [of justice] to balance."
See The Fla. Bar v. Agar, 394 So. 2d 405 (Fla. 1981), and The Fla. Bar v. Simons, 391
So. 2d 684 (Fla. 1980). To permit or assist a client or other witness to testify falsely is
prohibited by F.S. 837.02 which makes perjury in an official proceeding a felony, and
by F.S. 777.011 which proscribes aiding, abetting, or counseling commission of a
felony.
SANCTIONS: DISMISS THE FORECLOSURE WITH PREJUDICE
161. The Court has the inherent power to sanction perjury, misconduct and other fraud by
the Plaintiff. A plain reading of section 57.105(1) Florida Statutes shows sanctions may
be awarded upon the courts initiative. The Defendant respectfully requests this Court
sanction the Plaintiff upon the courts initiative and Dismiss the Foreclosure with
Prejudice.
DISABILITY OF NEIL GILLESPIE
162. Neil Gillespie is an indigent, fifty-six (56) year-old single man, law-abiding, latein-life college educated, and a former business owner, disabled with physical and mental
impairments. Neil Gillespie has a record of craniofacial disorder and speech impairment
since birth. Neil Gillespie has a record of traumatic brain injury sustained in 1988. The
record shows Neil Gillespie suffers from depression, post traumatic stress disorder
(PTSD), diabetes type II adult onset, traumatic brain injury (TBI), velopharyngeal
incompetence (VPI), craniofacial disorder, and impaired hearing. Social Security
determined Neil Gillespie totally disabled in 1993. The Florida Division of Vocational
Rehabilitation (DVR) approve a rehabilitation plan in 1994, but denied Neil Gillespie
services in 1997 when it determined his disability was too severe for services to result in
employment. Neil Gillespie is also regarded as impaired by others.
163. Neil Gillespie initially requested January 13, 2013 disability accommodation in
this HECM foreclosure to Tameka Gordon, ADA Coordinator, Marion County Judicial
Center, with a copy to Plaintiffs counsel Ms. Parsons. Neil Gillespie will file a motion

December 2, 2013
Page - 13
under the Americans with Disabilities Act (ADA) with specific requests for disability
accommodation.
Section IV
UPL of paralegal Yolanda I. Martinez in federal court
Pleadings showing UPL, or related to Unlicensed Practice of Law, by Ms. Martinez:

Rule 11 Motion For Sanctions Danielle N. Parsons McCalla Raymer, LLC
Document 15, filed February 26, 2013
Rule 55 Motion For Default Judgment, Document 16, filed February 26, 2013
Rule 72/Rule 60 Verified Objection, Motion For Relief, Magistrate Judges Order (Doc.
12) Document 17, filed March 5, 2013
Affidavit of Neil J. Gillespie, 28 U.S.C. 144, Document 22, filed April 8, 2013.
My Rule 11 Motion shows Ms. Martinez engaged in UPL by email Thursday, February 21,
2013 2:52 PM as held in Ethics Opinion 70-62 when she engaged in activity which requires
the attorney's personal judgment and participation. [Ethics Opinion 70-62]
Specially, Ms. Martinez:

1. Conducted with me by email a conference pursuant to Local Rule 3.01(g), M.D. FL
2. During the Rule 3.01(g) conference, Ms. Martinez knowingly misrepresented to me by
email the legal date Plaintiffs response to my Motion to Dismiss was due:
Our response to your Motion to Dismiss is due today per the Federal Court Rules
and at this time we are requesting an extension of time to file a reply to the
Motion to Dismiss of 20 days or on or before March 13, 2013.
The email of Ms. Martinez appears at Exhibit A to my Rule 11 Motion For Sanctions.
(Doc. 15). The email of Ms. Martinez accompanies this UPL complaint as Exhibit 5.
Local Rule 3.01(g):
(g) Before filing any motion in a civil case, except a motion for injunctive relief, for
judgment on the pleadings, for summary judgment, to dismiss or to permit maintenance
of a class action, to dismiss for failure to state a claim upon which relief can be granted,
or to involuntarily dismiss an action, the moving party shall confer with counsel for the
opposing party in a good faith effort to resolve the issues raised by the motion, and shall
file with the motion a statement (1) certifying that the moving counsel has conferred with
opposing counsel and (2) stating whether counsel agree on the resolution of the motion.
A certification to the effect that opposing counsel was unavailable for a conference
before filing a motion is insufficient to satisfy the parties obligation to confer. The

December 2, 2013
Page - 14
moving party retains the duty to contact opposing counsel expeditiously after filing and
to supplement the motion promptly with a statement certifying whether or to what extent
the parties have resolved the issue(s) presented in the motion. If the interested parties
agree to all or part of the relief sought in any motion, the caption of the motion shall
include the word unopposed, agreed, or stipulated or otherwise succinctly inform
the reader that, as to all or part of the requested relief, no opposition exists.
Ms. Martinez engaged in UPL because a Rule 3.01(g) conference is activity which requires the
attorney's personal judgment and participation. Furthermore, Rule 3.01(g) does not provide for
a conference with an unrepresented nonlawyer party. I am not a lawyer, and am not subject to the
plain language of the local rule, which specifies opposing counsel or counsel.
Plaintiffs counsel Ms. Parsons did not respond to any of my Rule 3.01(g) attempts to confer, and
I noted her failure in the three pleadings above.
Ms. Martinez further engaged in UPL by purporting to determine a legal deadline to respond to
my motion to dismiss under Federal Court Rules; Ms. Martinez knew the information she
provided was wrong, and provided with a corrupt purpose. Notwithstanding the knowing
falsehood with malice aforethought about the deadline, she waited until 1 hour and 8 minutes
before the Court closed at 4:00 PM. This is not a good faith effort under Rule 301(g).
My Rule 55 Motion For Default Judgment, Document 16, filed February 26, 2013, shows:
1. Rule 55(a), F.R.C.P., Entering a Default. When a party against whom a judgment for
affirmative relief is sought has failed to plead or otherwise defend, and that failure is
shown by affidavit or otherwise, the clerk must enter the party's default. In this case the
Plaintiff failed to respond within 14 days (Rule 12(a)(4)) to Gillespies motion to dismiss
filed February 4, 2013. The time for default was February 19, 20134. The Plaintiff has
defaulted and Gillespie is entitled to a Default Judgment.
2. Gillespie filed contemporaneously with this motion a Rule 11 Motion for Sanctions
against Plaintiffs Counsel Danielle N. Parsons and the law firm McCalla Raymer, LLC.
The motion shows that Ms. Parsons mislead the Court and Gillespie in her Agreed
Motion For Extension of Time (Doc. 11). Ms. Parsons and her staff also misled
Gillespie regarding the good-faith conference pursuant to Middle District Local Rule
3.01(g). Gillespie respectfully incorporates his Rule 11 Motion for Sanctions into this
Rule 55 Motion for Default Judgment.
3. In reliance upon Ms. Parsons misrepresentations, this Court entered an Order (Doc.
12). Unfortunately, due to Ms. Parsons misrepresentations to the Court in her Agreed
Motion For Extension of Time (Doc. 11), the Order should rescind the Order. (Doc. 12).
The Court was closed Monday February 18, 2013 for Presidents Day, the actual due date.

December 2, 2013
Page - 15
My Rule 72/Rule 60 Verified Objection, Motion For Relief, Magistrate Judges Order (Doc.
12) Document 17, filed March 5, 2013.
Appearing pro se, Defendants, NEIL J. GILLESPIE, and NEIL J. GILLESPIE COTRUSTEE, (herein after Gillespie) hereby make a verified objection under Fed. R. Civ.
P. 72 to the Magistrate Judges Order (Doc. 12) entered February 22, 2013. In addition to
and in the alternative to the relief sought above, Gillespie moves under Fed. R. Civ. P.
60(b)(3) for relief from the Magistrate Judges Order (Doc. 12) entered February 22,
2013, and states:
1. Magistrate Judge Philip R. Lammens entered an Order (Doc. 12) February 22, 2013
granting the Plaintiff relief based on Ms. Parsons Agreed Motion For Extension of
Time filed the previous day February 21, 2013 (Doc. 11). Unfortunately Ms. Parsons
motion was a fraud on the Court wherein she made false statements and material
misrepresentations, and engaged in misconduct, set forth in Gillespies Rule 11 Motion
For Sanctions Against Danielle N. Parsons and McCalla Raymer, LLC (Doc. 15).
Gillespies Rule 11 motion shows Ms. Parsons missed a deadline to file a response to
Gillespies Motion to Dismiss (Doc. 5), and engaged in fraud, misrepresentation and
misconduct to secure an extension to file a response, when in fact the Plaintiff defaulted
and Gillespie was entitled to a Default Judgment. (Doc. 16). Gillespie moved for Default
Judgment February 26, 2013. (Doc. 16).
2. Ms. Parsons made a number of false statements and material misrepresentations to the
Court in her motion (Doc. 11) intended to mislead the Court and federal judge(s) for the
purpose of advantage to: A. Cover-up Counsels incompetence and lack of diligence for
not timely filing a response to the motion to dismiss, a response due February 19, 2013.
(Rule 12(a)(4)); and B. Trick Gillespie into believing Plaintiffs response was due January
21, 2013, when otherwise he could move for Default Judgment. (Rule 55). (Doc. 15, 8).
3. Gillespie respectfully incorporates into this pleading the following related pleadings he
previously submitted to the Court, including:
Rule 11 Motion For Sanctions Against Danielle N. Parsons And McCalla
Raymer, LLC (Doc. 15), filed February 26, 2013
Rule 55 Motion For Default Judgment (Doc. 16), filed February 26, 2013
Objections To Magistrate Judge Philip R. Lammens Report and
Recommendation, filed March 4, 2013.
4. Ms. Parsons made several material representations to the Court in her Certification
Pursuant To Middle District Local Rule 3.01(g) (Doc. 11) that stated:
Counsel for Plaintiff hereby advises this Honorable Court that it has attempted in
good faith to confer with pro se Defendant, Neil Gillespie via electronic mail as

December 2, 2013
Page - 16
this is the only form of communication we have. Counsel sent an email to Mr.
Gillespie advising him that we were in need of an extension. Defendant, Neil
Gillespie, has agreed to the within request for an extension of time.
First, Counsel did not contact Gillespie at any time to confer in good faith as required
by Local Rule 3.01(g). Ms. Parsons misled the Court when she wrote electronic mail is
the only form of communication we have. Gillespies home telephone number is
provided on all his pleadings, on his Florida Rule 2.516 notice in state court, and is listed
on the Courts civil docket along with his home address. Ms. Parsons further lied to the
Court when she wrote Counsel sent an email to Mr. Gillespie advising him that we were
in need of an extension. Ms. Parsons did not send Gillespie an email advising that she
was in need of an extension. Instead, Yolanda I. Martinez, paralegal to Ms. Parsons,
contacted Gillespie by email February 21, 2013 at 2.52 PM for the purpose of misleading
Gillespie about the extension: (Doc. 15., 9). (Exhibit A).
Unfortunately Ms. Martinez misrepresented to Gillespie in her email that Our
response to your Motion to Dismiss is due today per the Federal Court Rules...
The statement of Ms. Martinez is false. The Plaintiffs response was due two days
earlier, February 19, 2013. The false statement made in connection with the Local
Rule 3.01(g) was not made in good faith as required, and denied Gillespie
informed consent in which to respond.
5. Ms. Parsons misrepresented to the Court February 21, 2013 in her Agreed Motion For
Extension of Time (Doc. 11) as follows:
In paragraph 1: On or about February 6, 2013, Defendant, Neil Gillespie, filed
its Motion to Dismiss with the Court.
Ms. Parsons statement is false. Ms. Parsons knows that Gillespie filed his Motion to
Dismiss with the Court (Doc. 5) on February 4, 2013, a date certain, and no other date.
Gillespies Motion to Dismiss shows when it was filed on the docket, and on the top of
the document: Case 5:13-cv-00058-WTH-PRL Document 5 Filed 02/04/13 Page 1
of 47 PageID 86
In paragraph 2: Pursuant to the Federal Rules of Civil Procedure, a response is
due to the Motion to Dismiss on or about February 21, 2013.
Ms. Parsons statement is false. In fact, pursuant to the Federal Rules of Civil Procedure
a response was due to the Motion to Dismiss on January 19, 20135, a date certain and no
other date. Accordingly the Plaintiff is in default and Gillespie is entitled to a Default
5
The Court was closed Monday February 18, 2013 for Presidents Day, the actual due date.

December 2, 2013
Page - 17
Judgment.
7. Gillespie agreed to extend the time for Ms. Parsons to file a response, but that was
based on a false statement by Plaintiffs Counsel [through paralegal Ms. Martinez].
Gillespie did not agree to Counsel making false statements or representations during the
good-faith conference required by Local Rule 3.01(g), and/or filing a false record of
events with the Court, which appears calculated to:
A. Cover-up Counsels incompetence and lack of diligence for not timely filing a
response to the motion to dismiss, a response due February 19, 2013. (Rule
12(a)(4))
B. Trick Gillespie into believing Plaintiffs response was due January 21, 2013,
when otherwise he could move for Default Judgment. (Rule 55).
8. Ms. Parsons further misrepresented to the Court in paragraph 5, No parties will be
prejudiced by the granting of this extension of time. (Doc. 11, 5). Ms. Parsons
statement is false. Gillespie is prejudiced because he is entitled to a Default Judgment.
Gillespie moved for Default Judgment February 26, 2013. (Doc. 16).
14. Gillespie requested in his Notice of Removal (Doc. 1, p 4, 16) that any rulings made
by a U.S. Magistrate Judge be in conformity with the Report and Recommendation
format. The subject Order (Doc. 12) was not made in a Report and Recommendation
format.
My Affidavit of Neil J. Gillespie, 28 U.S.C. 144, Document 22, filed April 8, 2013, shows:
13. U.S. Congressman Elijah E. Cummings wrote February 25, 2011 to Inspector General
Linick of Federal Housing Finance Agency (FHFA) asking that he initiate an
investigation into widespread allegations of abuse by private attorneys and law firms
hired to process foreclosures as part of the "Retained Attorney Network"...
14. The Plaintiff in this case is represented by McCalla Raymer, LLC. The letter of Rep.
Cummings complains about McCalla Raymer, LLC by name:
Another firm in the Retained Attorney Network, McCalla Raymer, L.L.C., is a
defendant in a federal lawsuit in which the plaintiffs allege that it engaged in
fraud, racketeering, and the manufacture of fraudulent foreclosure documents.
Reportedly, this firm established operations in Florida under the name Stone,
McGehee & Silver and hired ten former Stern law firm employees. The firm
Stone, McGehee and Silver, LLC, dba McCalla Raymer currently appears as a
"Designated Counsel/Trustee" in Florida for Freddie Mac.
15. Unfortunately McCalla Raymer, LLC is now doing business in Florida under its own
name in Orlando Florida. I have personal knowledge of this firms misconduct in this case.
16. On February 26, 2013 I filed a Rule 11 Motion For Sanctions Against Danielle N.

December 2, 2013
Page - 18
Parsons And McCalle Raymer, LLC (Doc 15). The Court has not ruled on my motion.
17. On February 26, 2013 I filed a Rule 55 Motion For Default Judgment (Doc. 16.)
The Court has not ruled on my motion.
18. On March 5, 2013 I filed a Verified Objection To, And Motion For Relief From, A
Magistrate Judges Order (Doc. 12) under Fed. R. Civ. P 72, and Rule 60(b)(3). The
Court has not ruled on my motion.
25. [relevant portion only] [Note: Ms. Parsons of McCalla Raymer, LLC filed a
fraudulent civil cover sheet in the state court foreclosure of the subject mortgage.]
25. (number 25 repeated by mistake in the pleading)Unfortunately, I do not believe I can
get a fair hearing in any Florida state or federal court due to the corrupting power and
influence of The Florida Bar set forth in Petition 12-7747.
Section V
Fraud or impairment by Ms. Martinez/Ms. Parsons of the federal case
Evidence shows Yolanda I. Martinez, Danielle N. Parsons, and McCalla Raymer, LLC, engaged
in fraud or impairment of case 5:13-cv-00058-WTH-PRL
My Rule 11 Motion shows Ms. Martinez emailed me Thursday, February 21, 2013 at 2:52.
Ms. Martinez knowingly misrepresented to me by email the legal date Plaintiffs response to my
Motion to Dismiss was due:
Our response to your Motion to Dismiss is due today per the Federal Court Rules
and at this time we are requesting an extension of time to file a reply to the
Motion to Dismiss of 20 days or on or before March 13, 2013.
The email of Ms. Martinez appears at Exhibit A to my Rule 11 Motion For Sanctions. (Doc. 15).
The email of Ms. Martinez accompanies this UPL complaint as Exhibit 5.
In paragraph 1: On or about February 6, 2013, Defendant, Neil Gillespie, filed
its Motion to Dismiss with the Court.
Ms. Parsons statement is false. Ms. Parsons knows that Gillespie filed his Motion to
Dismiss with the Court (Doc. 5) on February 4, 2013, a date certain, and no other date.
Gillespies Motion to Dismiss shows when it was filed on the docket, and on the top of
the document: Case 5:13-cv-00058-WTH-PRL Document 5 Filed 02/04/13 Page 1
of 47 PageID 86

December 2, 2013
Page - 19

In paragraph 2: Pursuant to the Federal Rules of Civil Procedure, a response is
due to the Motion to Dismiss on or about February 21, 2013.
Ms. Parsons statement is false. In fact, pursuant to the Federal Rules of Civil Procedure
a response was due to the Motion to Dismiss on January 19, 2013[fn2], a date certain and
no other date. Accordingly the Plaintiff is in default and Gillespie is entitled to a Default
Judgment. [fn2] The Court was closed Monday February 18, 2013 for Presidents Day,
the actual due date.
10. Ms. Parsons further misrepresented to the Court in paragraph 5, No parties will be
prejudiced by the granting of this extension of time. Ms. Parsons statement is false.
Gillespie is prejudiced because he is entitled to a Default Judgment....
My Rule 55 Motion For Default Judgment, Document 16, filed February 26, 2013, shows the
Plaintiff defaulted and I am entitled to a Default Judgment.
Section VI
Ex parte communication Ms. Martinez/Ms. Parsons, federal judicial officers
Evidence shows Ms. Martinez and Ms. Parsons, thru McCalla Raymers email service, engaged
in ex parte communication with U.S. Judge Hodges and U.S. Magistrate Judge Lammens.
The Order (Doc. 12) entered February 22, 2013 by U.S. Magistrate Judge Lammens arrived by
U.S. Mail first class to me with additional papers that show email communication between the
Court and Yolanda I. Martinez at yim@mccallaraymer.com. This is unusual because the Court
did not communicate by email with Tiffany Caparas of Kaufman, Englett & Lynd, PLLC,
counsel of record for Mark Gillespie et al. [compare, yolanda.martinez@mccallaraymer.com]
Tellingly the Court did not use McCalla Raymers designated primary email for service pursuant
to Fla. R. Jud. Admin 2.516, mrservice@mccallaraymer.com
See Ms. Parsons Notice of Compliance with Rule 2.516 and Designation of Email Address in
state court: MRService@mccallaraymer.com (Exhibit 14)
The Court shows this information on a paper sent to me. (Exhibit 6).
5:13-cv-00058-WTH-PRL Notice has been electronically mailed to: Danielle N. Parsons
dnp@mccallaraymer.com, yim@mccallaraymer.com
The signature block of Ms. Martinezs email shows yolanda.martinez@mccallaraymer.com, but
yim@mccallaraymer.com appears in the caption section of email of Ms. Martinez.

December 2, 2013
Page - 20
Tellingly the Court did not send email to Tiffany Caparas of Kaufman, Englett & Lynd, PLLC,
counsel of record. Instead Ms. Caparas was provided notice delivered by other means. I got the
notice [the Order Doc. 12] delivered by other means, by US Mail first class. (Exhibit 6).
Tellingly Magistrate Lammens entered the Order (Doc. 12) on Plaintiffs motion the next day.
The Order (Doc. 12) was entered February 22, 2013 but was not mailed to me until February 25,
2013 according to the Courts postage meter imprint. Unfortunately the U.S. District Court for
the Middle District of Florida has a discriminatory pro se policy that prohibits e-filing and access
to the Courts CM/ECF system for pro se litigants, consumers of legal and court services
affecting interstate commerce. My motion has been pending since February 6, 2013 for
authorization to file electronically (Doc. 7), so that I may access legal and court services in this
action in an effective and expeditious manner, as provided by the Constitution and laws of the
United States, and Constitution and laws of the state of Florida.
I requested in my Notice of Removal (Doc. 1, p 4, 16) that any rulings made by a U.S.
Magistrate Judge be in conformity with the Report and Recommendation format. The subject
Order (Doc. 12) was not made in conformity the Report and Recommendation format.
The above email scenario was repeated in the following decisions by the Court:
Order Remanding Case (Doc. 19) by US Judge Hodges, March 7, 2013:
Judgment in a Civil Case (Doc. 20) by Clerk Sheryl L Loesch March 11, 2013,
Order (Doc. 24) by US Judge Hodges, April 12, 2013 (denied inter alia my affidavit 28 USC 144)
Section VII
UPL of paralegal Yolanda I. Martinez in state court
Yolanda I. Martinez engaged in UPL by email on Wednesday, August 07, 2013 when she
engaged in activity which requires the attorney's personal judgment and participation. [Ethics
Opinion 70-62]. Specifically Ms. Martinez provided me legal advice on the meaning of an Order
entered July 25, 2013 by the U.S. Eleventh Circuit in Appeal Number: 13-11585-B.
Ms. Martinezs UPL began with her email to me August 07, 2013 1:44 PM: (Exhibit 7).
Case No.: 2013-CA-000115

December 2, 2013
Page - 21
Mr. Gillespie:
We would like to set a hearing on your Motion to Dismiss Plaintiff's Complaint before
the Honorable Hale R. Stancil. In that regard I have contacted the Judge's Judicial
Assistant and she has provided me with the following available dates and times for
the hearing:
Tuesday, September 3, 2013 between the hours of 1-5
Friday, September 6, 2013 between the hours of 1-5
We would like to secure a 15 minute hearing time during those hours. Kindly let me
know which date and time works best for you so that I can contact the judge and
secure our hearing time.
Thank you.
Yolanda I. Martinez,
Paralegal to: Danielle N. Parsons
I responded to Ms. Martinez by email August 07, 2013 4:07 PM. (Exhibit 8).
Dear Ms. Martinez:
Good afternoon. I object to any hearings in state court until the Eleventh Circuit Court of
Appeals rules on my petition for mandamus relief. Attached is my letter to the court,
served yesterday to Ms. Parsons at mrservice@mccallaraymer.com Thank you.
Sincerely,
Neil J. Gillespie
8092 SW 115th Loop
(352) 854-7807.
I provided my responsive email to Ms. Martinez, and to the following persons by email,
including the trial judge, the Hon. Hale Ralph Stancil:
"Yolanda Martinez" <yim@mccallaraymer.com>;
<TCaparas@kelattorneys.com>;
"Hon. Hale Ralph Stancil" <hstancil@circuit5.org>;
"Jane Bond" <jane.bond@mccallaraymer.com>;
"Robyn Katz" <rrk@mccallaraymer.com>;
"Curtis Wilson" <Caw@McCallaRaymer.com>
Cc: "Danielle Parsons" <dnp@mccallaraymer.com>;
"Mark Gillespie" <mark.gillespie@att.net>;
"Neil Gillespie" <neilgillespie@mfi.net>
Ms. Martinez responded to me by email August 07, 2013 4:18 PM. (Exhibit 9).
Mr. Gillespie:

December 2, 2013
Page - 22
The 11th Circuit Court of Appeals has rendered its decision and has denied your Motion
for Reconsideration as you can see from the attached Order. In that regard, kindly advise
as to your availability for a hearing in the Circuit court.
Thank you.
Yolanda I. Martinez,
Paralegal to: Danielle N. Parsons
The legal interpretation of the Order Ms. Martinez provided me by email was UPL because she
engaged in activity which requires the attorney's personal judgment and participation. [Ethics
Opinion 70-62]. In addition Ms. Martinez provided false and misleading information about the
Order entered July 25, 2013 by the U.S. Eleventh Circuit in Appeal Number: 13-11585-B.
I responded to Ms. Martinez by email August 07, 2013 4:50 PM: (Exhibit 10).
Dear Ms. Martinez:
Good afternoon. I object to any hearings in state court until the Eleventh Circuit Court of
Appeals rules on my petition for mandamus relief.
Unfortunately you are not reading the order properly. Kindly consult with an attorney at
your firm. The decision entered allows a separate petition for mandamus relief. The U.S.
Eleventh Circuit entered a favorable Order July 25, 2013 that states in relevant part:
"Should Gillespie wish to petition for mandamus relief, he may file a separate petition for
a writ of mandamus or prohibition with this Court. See 28 U.S.C. 1651;
Fed.R.App.P.21".
This was the only option the court had, which is why it denied the motion to reconsider a
remand for lack of jurisdiction, but offered mandamus relief. Corporate Mgmt. Advisors,
Inc. 561 F.3d 1294, 1296 (11th Cir. 2009) held the failure to allege facts sufficient to
establish subject matter jurisdiction in a notice of removal is a defect in the removal
procedure, and consequently, the district court cannot sua sponte remand a case to state
court on that ground.
A writ of mandamus is the proper means by which a party may challenge a remand order.
Thermtron Products, Inc. v. Hermansdorfer, 423 U.S. 336, 352-53, 96 S.Ct. 584, 593-94,
46 L.Ed.2d 542 (1976). A remand order based on subject matter jurisdiction is not
reviewable by appeal. 28 U.S.C. 1447(d). But such remand order entered sua sponte is
a defect in the removal process within the meaning of 1447(c), and may be challenged
by writ of mandamus. New v. Sports & Recreation, Inc., 114 F.3d 1092, 1095-96 (11th
Cir. 1997).
In the past you and Ms. Parsons disrupted the tribunal in federal district court, and I hope
that does not happen again. Your misconduct is shown in the following pleadings in US
District Court, Middle District, Florida, Ocala Division, 5:13-cv-58-oc-WTH-PRL
Rule 11 sanction motion, Ms. Parsons, McCalla Raymer (Doc. 15)

December 2, 2013
Page - 23
G-illespie default motion, Rule 55 (Doc. 16)

Gillespie Verified Objection to Magistrate Order Doc. 12 (Doc. 17)
Unfortunately you and Ms. Parsons appear to have engaged in misconduct with the either
US Judge Hodges or Magistrate Judge Lammens. I alerted federal authorities. Attached
you will find a letter from U.S. Senator Bill Nelson instructing me on how to make a
formal complaint under the Judicial Conduct and Disability Act of 1980...
So, I object to any hearings in state court until the Eleventh Circuit Court of Appeals
rules on my petition for mandamus relief, which is allowed in the order you attached.
However you, Ms. Parsons and foreclosure mill McCalla Raymer are free to do whatever
you like, subject to law.
Thank you.
Sincerely,
Neil J. Gillespie
8092 SW 115th Loop
(352) 854-7807.
I did not hear back from Ms. Martinez or Ms. Parsons. No hearing was set in state court. The
email was sent to the persons shown above, including Judge Stancil.
After the Eleventh Circuit Order was entered July 25, 2013, the Clerk provided instructions on
n1aking a petition for writ of certiorari in forma pauperis to the U.S. Supreme Court, which was
filed October 23, 2013 as Petition No. 13-7280. Ultimately I chose that option over the C.A.11.
Ms. Parsons should be found guilty of misconduct, and permanently disbarred from the practice
of law, see Florida Standards For Applying Lawyer Discipline, Standard 6.11.
Under penalties of perjury, I declare that the foregoing facts are true, correct and complete.
Note: This Bar complaint exhausted The Florida Bar's 25 page limit, as follows: Bar complaint
form (1 page), this con1plaint (23 pages), and the Index to Exhibits (1 page).
Florida Bar Complaint - Danielle Nicole Parsons - December 2, 2013
Index to Exhibits - due to The Bars 25 page limit, Exhibits are available, not enclosed.
Exhibit 1
Ethics Opinion 70-62, The Florida Bar
Exhibit 2
Paralegals in a law office and the unlicensed practice of law. (UPL Update)
Florida Bar News - February 15, 2004, by Ghunise Coaxum
Exhibit 3
Invoice $5.95, Amazon Order June 3, 2013, Paralegals in a law office and UPL
Exhibit 4
Plaintiffs Verified Complaint To Foreclose Home Equity Conversion Mortgage,

state court action 2013-115-CAT, removed to U.S.D.C. Ocala Division
Case 5:13-cv-00058-WTH-PRL Document 2 Filed 02/04/13 Page 1 of 38 PageID 32
Exhibit 5
Email of Yolanda I. Martinez, February 21, 2013 2.52 PM
Exhibit 6
Evidence of ex-parte email U.S. District Court and Danielle N. Parsons
Exhibit 7
August 7, 2013 email 1.44pm paralegal Martinez/McCalla Raymer LLC to Gillespie
Exhibit 8
August 7, 2013, email 4.07pm Gillespie to paralegal Yolanda Martinez/McCalla

Raymer LLC, w/attached letter to Clerk
Exhibit 9
August 7, 2013, email 4.18pm paralegal Yolanda Martinez/McCalla Raymer

LLC to Gillespie, w/attached court order denied reconsideration
Exhibit 10
August 7, 2013, email 4.50pm Gillespie to paralegal Yolanda Martinez/ McCalla

Raymer LLC, w/attached letter-Sen. Nelson w/information for judicial complaint
Exhibit 11
U.S. Congressman Elijah E. Cummings letter Feb-25-11 to FHFA, McCalla Raymer
Exhibit 12
Notice of Defendants' Consent to Judgment, case no. 2013-CA-000115
Exhibit 13
Gillespies denial of UPL accusation, Page 34, Petition No. 13-7280 SCOTUS
Exhibit 14
Ms. Parsons Notice of Compliance with Rule 2.516 and Designation of Email
Address: MRService@mccallaraymer.com
Exhibit 15
Sections VIII through XIII of the Bar Complaint
Exhibit 16
Agreed Motion for Extension of Time (Doc. 11). 5:13-cv-00058-WTH-PRL
Exhibit 17
Civil Cover Sheet Form 1.997 attached to Verified Complaint To Foreclose Home
Equity Conversion Mortgage, state court 2013-115-CAT
Exhibit 18
Defendants Motion to Dismiss Certified Complaint to Foreclose Home Equity

Conversion Mortgage, state court 2013-115-CAT, removed U.S.D.C. Ocala Div
Case 5:13-cv-00058-WTH-PRL Document 5 Filed 02/04/13 Page 1 of 47 PageID 86

Parsons Complaint File No. 2014-30,525 (09A) - Brewer Notice

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Parsons Complaint File No. 2014-30,525 (09A) - Brewer Notice

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John F.

Harkness, Executive Director

Patricia Ann Toro Savitz

Digitally signed by Neil J Gillespie

The Florida Bar

Orlando Branch Office

February 10, 2015

Complaint by Neil J. Gillespie against Danielle Nicole Parsons

Dear Mr. Gillespie:

Complaint by Neil J. Gillespie against Danielle Nicole Parsons

Patricia Ann Toro Savitz

Robert J Stovash, Chair via email

The Florida Bar

Orlando Branch Office

January 30, 2015

Complaint by Neil J. Gillespie against Danielle Nicole Parsons

Dear Mr. Gillespie:

Patricia Ann Toro Savitz

Robert J Stovash, Chair

Mr. Neil J. Gillespie

IN THE SUPREME COURT OF FLORIDA

Complaint by Neil J. Gillespie against Danielle Nicole Parsons

NOTICE OF ASSIGNMENT OF INVESTIGATING MEMBER

Barry Rodney Davidson

Jon Marshall Oden

Notice is given that this case will be considered by the committee.

Patricia Ann Toro Savitz

Copies furnished to:

I " ' " .... ,.,

1000 LEGION PLACE, SUITE 1625

r,c .en,- . . . . MAILED FROM ZIP CODE 32801

Visit our website: www.FLORIDABAR.org

Mr. Neil J. Gillespie

'I' jJJ J. II JJ', If lui jlJl.. J, II II JlJu h"'11'," J I'" II II J'"

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