Separate Appendix-Petition 13-7280-NOT SERVED

download Separate Appendix-Petition 13-7280-NOT SERVED

of 55

  • date post

  • Category


  • view

  • download


Embed Size (px)

Transcript of Separate Appendix-Petition 13-7280-NOT SERVED

  • 8/11/2019 Separate Appendix-Petition 13-7280-NOT SERVED


    Petition No: 13-7280

    IN THE









    Petitioners Supplemental Brief

    Separate Volume Appendix


    Attorney Eugene P. Castagliuolo

    Correspondence referencing Neil J. Gillespie and/or

    the Social Security Disability Administration


    Appendix 1 Letter June 19, 2013 Eugene Castagliuolo to Susan Bloemendaal, The Florida Bar

    I have collected a large pile of the many, many documents filed in various, places by

    Gillespie over the past several years, and I am looking forward to furnishing that pile to

    the SSDI abuse investigator for Florida....Once the SSA reviews the fruits of Gillespie's

    labor, I'm confident that his handicap status will be very much at issue.

    The letter shows cc: Office of the Inspector General, Social Security Disability Administration

    (by regular U. S. Mail).

    Appendix 2 Bar Counsel Leonard Clark provided 23 pages of email from Mr. Castagliuolo,

    included here with Mr. Clarks letter to Neil Gillespie. Mr. Castagliuolo threatened Mr. Clark byemail February 12, 2013 at 11:13 AM, and called his veracity into question:

    Mr. Clark, I cannot remember when (if ever) in my career that I've been so deceived and

    outright lied to by an attorney in a position such as yours. I am seriously considering

    filing an ethics violation against YOU myself, but I want to calm down and consider this

    situation rationally before I do.

    BRIEF NOT FILED:Petitioner's

    Supplemental Briefwas not filed. I

    was unable to file due to illness and


  • 8/11/2019 Separate Appendix-Petition 13-7280-NOT SERVED



    No, Mr. Clark, you most certainly did NOT tell me that, following the chair's

    "recommendation," that you would yourself have to make yet another

    "recommendation." What you explicitlytold me was that both you and the chair were

    in complete agreement that not a scintilla of evidence existed in support of this creep's

    complaint(s), not only against me, but against the other attorneys as well. You made it

    quite clear that this matter was done and over with . There was no indecision on yourpart, other than that you planned to wait until Gillespie's ridiculous Florida Supreme

    Court pleading deadline had passed (on or about December 10, 2012) before you would

    send out the letter advising me of your decision, and advising him that, once again, he

    was a loser.

    As you well know, Mr. Clark, the REAL problem with this matter is that The Florida Bar

    shivers and quakes whenever Gillespie opens his mouth or begins to type. Gillespie

    certainly has received far more consideration from your Office than I, a Florida Bar

    member, has enjoyed. By seeking to avoid Gillespie's venom, you have thrown me and

    several other Florida Bar membersunder the bus. That you and your colleagues do not

    protect Florida Bar memberswho have been savaged by garbage like Gillespie is sad.

    I assure you that this is not the end of this Mr. Clark.


    Mr. Castagliuolo wrote Mr. Clark February 12, 2012 at 9:56 AM:

    Kindly reply to my previous 2 e-mails and my telephone call to your office last week, all

    of which have gone unanswered. If I don't hear from you in due course, my next call will

    be to your boss in Tallahassee. Thanks Eugene

    Mr. Castagliuolo wrote Mr. Clark February 6, 2013 at 11:57 AM:

    Dear Mr. Clark:

    First, please adjust your records to reflect my new e-mail address.

    Secondly, please provide me with a letter of final disposition of this Gillespie

    abomination. I have a whistleblower complaint about this fool to file with the Social

    Security Administration, but I want to receive your letter first.

    Thank you EPC,

    Eugene P. Castagliuolo, Esquire

    Mr. Castagliuolo sent copies of his email to The Florida Bar cc to Mr. Rodems and Mr.

    Laurato, each of who rebuffed Castagliuolos contact.

    Email response of Ryan Rodems 02/12/2013 12:16 PM

  • 8/11/2019 Separate Appendix-Petition 13-7280-NOT SERVED



    Mr. Clark:

    I am not sure why Mr. Castagliuolo has copied me on this e-mail he wrote to you. I am at

    a complete loss to understand why he has written this to you. I assure you that I do not

    share his sentiments.


    Ryan Christopher Rodems

    Barker, Rodems & Cook, P.A.

    Email response of Michael Laurato, 02/12/201301:03:37 PM

    What does all of this have to do with me? And, why am I receiving emails on this?

    Michael V. Laurato

    Mr. Castagliuolo wrote Mr. Clark 04/16/2013 10:27:21 AM

    Thank you Mr. Clark. And I'm sorry for giving you a hard time a few months ago, but

    this guy is like a snake, and for someone claiming to be handicapped, he never gives up.

    We as lawyers have little or no defense to attacks like his, but lucky for us, there aren't

    too many Gillespies out there.


    It ain't about how hard you hit, it's about how hard you can GET hit....and keep moving

    forward Rocky Balboa

    The foregoing is representative of the 23 pages of email of Mr. Castagliuolo.

    Appendix 3 Email Oct-22-2012, Mr. Castagliuolo to Theodore Littlewood, The Florida Bar,

    provided by letter of Bar Counsel Leonard Clark October 26, 2012.

    But can you possibly tell me exactly how much longer I must endure the slings and

    arrows of this piece of garbage Gillespie before you will act upon his "complaint" ?

    I plan to sue Gillespie as soon as The Florida Bar complaint is closed.

    Appendix 4 Response Aug-30-2012, Castagliuolo to Florida Bar complaint, 2013-10,162(D)

    This is my response to the nonsensical complaint filed against me by my former client,

    Neil J. Gillespie...Gillespie is on the government dole, perhaps wrongfully...

    Indeed he is a "professional complainant" who gives new meaning to the phrase useless human being.

    The response shows cc: Office of the Inspector General, Social Security Disability

    Administration (by regular U. S. Mail).

  • 8/11/2019 Separate Appendix-Petition 13-7280-NOT SERVED



    Appendix 5 Response Sep-19-2012, Castagliuolo to Mr. Littlewood, The Florida Bar

    Once again, it's hard to imagine how Gillespie, while being saddled with such a long

    laundry list of handicaps, would be capable of producing this epic 59 page tome! I'm

    quite sure that will be the first question asked by the SSDI Benefits Fraud Unitinvestigators after they examine the entire public record of this debacle. All in good time,

    all in good time...

    Letter shows evidence of coordinated racketeering, cc: to Mr. Rodems and Mr. Bauer.

    Appendix 6 Email Oct-26-2012, Castagliuolo to Leonard Clark, The Florida Bar

    Each of these filings, like all of his previous filings, sound like the rantings of a lunatic.

    As such, I will not dignify either with a detailed response, other than to generally deny

    each and every statement uttered by Gillespie in these filings.

    I must make one clarification, however, of a point that I raised in my previous rebuttals. I

    had previously stated that "in my spare time" I would challenge Gillespie's handicapped

    status with the Social Security Administration. I no longer feel this way. Instead, I plan to

    devote whatever time and energy is necessary to bring Gillespie's prolific defamatory

    statements and conduct to the attention of the SSA as crystal clear evidence that he is not

    handicapped. My pursuit of this goal will be anything but casual.

    Furthermore, I have a lawsuit drafted and ready to be filed in Pinellas County against

    Gillespie just as soon as you close this case...

    Appendix 7 ADA Accommodation Request, October 26, 2012, Neil Gillespie to Florida BarCounsel Leonard Clark, cc: "Karin Huffer" ; "Paul F Hill"

    ; "Kenneth Lawrence Marvin" ; "Theodore P


    Dear Mr. Clark: Attached you will find my letter to Mr. Littlewood dated October 25,

    2012 relative to Mr. Castagliuolos ongoing criminal harassment of me in violation of

    Section 784.048(2), Florida Statutes. Included is my September 25, 2012 notice to Mr.

    Castagliuolo not to send email.

    Today I received email from you at 2:02 p.m. that forwarded Castagliuolos email below.

    This is not acceptable. In the future please respond to me in writing. This is a disabilityaccommodation request made under the Americana With Disabilities Act (ADA), 42

    USC 12101 et seq., and Sections 504 and 508 of the Rehabilitation Act of 1973, and any

    other applicable law.

    As soon as possible I plan to make more formal and detailed disability accommodation

    request to Paul Hill. But the nature of my disability has delayed that request.

    Castagliuolos threats and harassment today have delayed my complaint to ACAP about

  • 8/11/2019 Separate Appendix-Petition 13-7280-NOT SERVED



    Robert W. Bauer, so Castagliuolos ongoing criminal harassment is preventing, delaying

    or interfering with my use the services of, or participation in programs or activities

    provided by the Florida Bar, a public entity.

    In addition, Florida Bar Rule 4-8.4(d) states "A lawyer shall not engage in conduct in

    connection with the practice