Reply to Commission on Ethics regarding Rhett Bullard

February 12, 2018

 

Mr. Gray Schafer, Senior Attorney

State of Florida

COMMISSION ON ETHICS

  1. O. Drawer 15709

Tallahassee Florida 32317-5709

 

Re:   Complaint No. 18-015, In re RHETT BULLARD

 

Prior to responding to the inquiries made in your February 7, 2018 letter, I am herewith providing the following pages from the White Springs Charter relating to elected officials of the Town Council and to the Town Manager, labeled Addendum 1 and Addendum 2 respectively.  The White Springs Charter is based upon the “Weak Mayor” form of .0-the foregoing) is the Mayor of White Springs, Florida.

Tonja Brown is the Vice Mayor of White Springs and Willie Jefferson is a councilor.  Together with Rhett Bullard, we have what is referred to, the “Power of Three”. Others have seen the three make decisions prior to meetings in violation of the Sunshine Laws and the three vote as one.  Rhett Bullard will start the motion or discussion and the two will readily make or second the motion, each taking turns at council meetings. In many situations, the motions are made rapidly that the other two councilors do not have an opportunity for discussion.  Yet, much of this is not verifiable due to the fact that the Finance Director, in charge of the recorder at meetings, shuts down the recorder with respect to anything which would appear damaging to the power of three or the Town Manager. Likewise the meeting minutes are void of information.

Rhett Bullard does not place any of his requests in writing but rather has the Town Manager Stacy Tebo do his bidding for which he provides protection with the “Power of Three”   That protection has constituted a violation of their fiduciary responsibilities to the Town’s citizens. When asked whether there is a cap on legal expenses, the citizens were told at a meeting there is no cap and should money be required over the $20,000 in the current budget for legal expenses, it will be taken from other areas of the budget.   This is wrong but the African American population as well as many who are in poverty are afraid to bring forth information against the three for fear of some form of retaliation such as increased water and sewer bills, etc. .

THE FOLLOWING STATEMENTS RESPOND

TO YOUR INQUIRIES 1, 2 AND 5 of your letter dated February 7, 2018

Anita Rivers, while employed as the Administrative Assistant for White Springs submitted a complaint by electronic mail of discrimination. It was sent to Town Attorney Frederick L. Koberlein, Jr., esquire, Mayor Rhett Bullard and Town Manager Stacy Tebo. (See Addendum 2 for the address of Attorney Larkin.)

Anita Rivers was hired as the Administrative Assistant during Dr. Helen B. Miller’s tenure as mayor. The two had an excellent relationship due to Ms. River’s efficiency and adaptability to learn and perform any tasks which were given to her.

You will see in Addendum 3 that Ms. Tebo was unhappy about the aforementioned relationship because of her dislike for Dr. Miller.

Rhett Bullard in his protection of Ms. Tebo told her to have Fred Koberlein secure Robert Edward Larkin, III, Esquire, to handle the Anita Rivers’ Case.  Attorney Larkin had recently assisted Mr. Koberlein in a Lake City Employment Case where the case was awarded in favor of the City.  

When Ms. Tebo contacted Town Attorney Frederick L. Koberlein, Jr. to secure Robert Edward Larkin in the Rivers’ case, both attorneys were told that the White Springs Town Council had approved their hiring to make an investigation in this case.

Ms. Rivers intended for our Town Attorney Koberlein to assist her in her complaint of discrimination and as a whistle blower into the actions of Town hall. Ms. Rivers had no intention to secure an attorney at the time but only to settle her claim of discrimination against Town Manager Stacy Tebo.

Prior to Ms. Rivers’ March 27, 2017 complaint, the “power of three” led by Mayor Rhett Bullard dismissed all complaints made by citizens; even if the laws which were listed on the complaint forms, had been violated. This included a petition signed by numerous citizens, who are African-Americans, relating to a May Day Celebration.  It was just ignored by Rhett Bullard even though councilor McKenzie said the Town should respond..

Town Attorney Koberlein also addressed that “Robert’s Rules of Order” per the Town Charter are required to be abided by.  Rhett Bullard’s response was that we are a small town and cannot be expected to follow those rules. When questioned, Rhett Bullard stated “You want us to admit we did not follow the law?”

The Rivers’ case was not made public nor to councilors Dr. Miller and Walter McKenzie until the money for Attorney Larkin was addressed in the council meeting. Our Town Attorney Frederick Koberlein secured a court reporter and the building under which statements were taken under oath.  His total charge including legal services was $13,965.22 with Attorney Larkin charging $12,000 for his legal services, for a total of ‘$25,965.22, which again was not approved by Town Council.

Rhett Bullard made no attempt to mediate the situation between Stacy Tebo and Anita Rivers but he felt that he could hire an outside attorney through our own Town Attorney without securing full council approval.  When Rhett Bullard was asked why council approval was not sought, he just stated “he didn’t do it, our Town Attorney did”. In other words, Rhett Bullard was placing all blame and liability on our Town Attorney. That money had to be carried over into our 2018 budget because we did not have the funds.

In the meantime, Frederick L. Koberlein and Robert Edward Larkin, III, felt or were told there had been council approval for their legal services.  In fact Attorney Larkin thanked the White Springs Council for hiring him in the summary provided to White Springs. The Town’s clerk refused to send us the paperwork in the Rivers’ case but Mr. Larkin did by electronic mail. (See Addendum 3 for Stacy Tebo’s sworn statement)

Due to the aforementioned statement under oath by Ms. Tebo and other staff, it was found that Police Chief Rodriquenz found what she described as a pill which she felt was an opioid in the unisex bathroom and later found one on the floor of the woman’s bathroom. Upon her asking who lost the pill, Stacy Tebo admitted it was hers and that it was Percoset.  (See both Addendum 4 and Addendum 3 –Page 87-21 of the Statements under Oath).

To respond to Inquiry 5, Frederick Koberlein advised the Council at a regular council meeting that Stacy Tebo’s contract had not been renewed from September of 2016.  Counselors Dr. Helen Miller and Walter McKenzie brought up the findings that Ms. Tebo was using Percoset, an opioid drug. As such, they had concern about renewing her contract without an investigation regarding her drug use and whether the drug had actually been prescribed. This especially was true due to the apparent mood swings Ms. Tebo seems to have; rendering her to remain in a closed door office for most of the day, sending e-mails as any form of communication to the Town Staff.

Rhett Bullard interrupted Dr. Miller several times and appeared to be screaming at her, telling Dr. Miller that she could not discuss Stacy Tebo’s medical condition.  He stated it was private; however, Town Attorney Koberlein concurred with Dr. Miller that the statements made regarding her use of Percoset was a matter of public record.

Rhett Bullard then decided to quash this discussion and asked Attorney Koberlein whether he could prepare an extension to Stacy Tebo’s contract.  Attorney Koberlein said he could not do that and until the matter is decided with a new contract Ms. Tebo was an “at will” employee and he explained the term of “at-will employee” at the public meeting.

Not listening to Attorney Koberlein, Rhett Bullard then said, we will extend the contract for ninety (90) days and the remaining power of three made the motion and seconded it for a verbal three month extension which Attorney Koberlein corrected since an extension could not be made to the existing contract verbally or in writing.

Rhett Bullard stated a discussion of Ms. Tebo’s contract would take place at a special meeting in the near future.  He continually called the ninety days, an extension even though he had been corrected even by me that Ms. Tebo was an “at will” employee.

Thereafter, Rhett Bullard and the Town Manager, who admitted she disliked Dr. Miller under oath, decided to rid themselves of Dr. Miller by forfeiting her seat.  I was told that Rhett Bullard, Stacy Tebo and Finance Director/City Clerk Tomlinson went through various records for a period of two weeks to see what they could find against Dr. Miller.

In a subsequent meeting, Rhett Bullard had Stacy Tebo read various accusations made against Dr. Miller.  These Accusations initially involved some old items for which Dr. Miller had council approval when she was Mayor.   Rhett Bullard would not allow Dr. Miller a chance to respond, unlike what the Jasper News Printed. Dr. Miller had not received a copy of the complaints which Ms. Tebo verbally read.

Within a week a new set of complaints showed up in the Jasper News/Suwannee Democrat.  Yet Dr. Miller had not initially seen the complaints nor had she been provided with the listing, except for what was printed in the newspaper.

See Addendum 5A “Town manager calls Miller ‘rogue council member’

See Addendum 5B White Springs Council votes to declare Miller seat forfeited…from the Jasper News.

From the Jasper News, the power of three managed to pull Tebo’s contract from the Agenda per Rhett Bullard’s request – Article from the Jasper News:

 

Discussion of Tebo’s contract pulled from agenda

 

 

WHITE SPRINGS — Town Manager Stacy Tebo’s contract was not discussed at the White Springs Town Council’s Oct. 10 meeting. Although it was on the agenda, Vice Mayor Tonja Brown made a motion to delete the discussion of the Town Manager’s Contract under old business, which was seconded by Council Member Willie Jefferson.The item was asked to be placed on the agenda by Council Member Dr. Helen Miller.

 

During discussion of removing the item, Council Member Walter McKenzie asked: “Isn’t this an opportunity to talk about it, so we can see if we want to renew it when the time comes?”Brown said since they gave her three months they had to wait until the three months are over to discuss the issues with the contract.  Miller and McKenzie both disagreed.

 

“Plus, if we go back to how that motion was made to stop the discussion, I believe that was made improperly,” Miller said. “I had the floor and I was making relevant comments, the town manager interrupted me over and over again, which she did not have the right to do. The Mayor did not exercise his duty to curtail the interruption.

 

“Finally, I think you made a improper motion, which the Mayor allowed for a vote.”Miller brought up that the motion would need a two-thirds majority vote, but only received 60 percent majority vote based on Robert’s Rules of Order.

 

McKenzie reiterated that the council reconsider voting against the motion because the contract needs to be discussed before the three months are over. The motion passed in a 3-2 vote deleting the discussion of the contract from the agenda.                             End of Article

 

Helen Miller hired Mark Herron of Tallahassee FL to represent her at her upcoming hearing to save her seat on the council.   Because of this, Rhett Bullard apprised the council that the Town had to pay for an attorney to defend Stacy Tebo. Not only did Counselor Walter McKenzie object but Town Attorney Frederick L. Koberlein objected, citing that such a thing has never been done (i.e. paying for staff’s attorney to sue a councilor). It is outside of the Town’s insurance due to it being a willful and actually a malicious act.

 

Rhett Bullard, however, was determined and started her defense budget at $7,500.  He also said that Stacy could choose her own attorney from those she would be contacting.  The remaining power of three, Tonja Brown and Willie Jefferson made and seconded the motion respectively in spite of our Town Attorney’s objections.

 

  1.  At the next meeting, Stacy Tebo advised that she had chosen an acquaintance of hers, Mr. Darren Elkind, esquire to assist her.  Mr. Elkind had worked with her in Sanford and although he charged far more than our Town Attorney, Frederick Koberlein (who could and would not represent her), Mr. Elkind had litigation experience.

 

Thereafter, the council agreed for 30 days of advertising for a new town attorney office to represent them since the Koberlein Law Offices provided the Town with a 30 day notice of intent to terminate the agreement with the town on October 4th.

 

Walter McKenzie encouraged the council to do an exit interview with Koberlein’s office.  Rhett Bullard refused and said this happened because Koberlein is now the attorney for Live Oak whose meetings are on the same date.  Walter McKenzie, however, did call Frederick Koberlein to find that the termination was due to the manner in which White Springs handles its business.

.

Dr. Miller’s Hearing was held October 25, 2017

Darren Jay Elkind; RFA No. 18-8079  represented Stacy Tebo and the Staff.

Dr. Helen Miller as a member of the Town was represented by Mark Herron

Town Attorney Frederick Koberlein officiated the hearing

The councilors were to act as judge and jury based upon the information received; however, the decision had already been made by the power of three to charge Helen B. Miller with Malfeasance in all four complaints, even though Dr. Miller broke no laws.  Rhett Bullard had been working with Staff to make certain Dr. Miller was removed.

My recollection of this since I attended the hearing is:

Dr. Miller’s Attorney, Mark Herron, initially requested a continuance due to the fact that the charges changed from those sited in the newspaper against Dr. Miller.  Mr. Herron said he was not providedsufficient time to secure the appropriate witnesses since the new charges were not received until October 19, 2017.  Mr. Herron provided this in writing as well as vocally in the meeting.   He advised that he only had two hours to go over the material with Dr. Miller.

 

Attorney Elkind, the Staff attorney, formerly known as Stacy Tebo’s attorney, said he was against the continuance because all e-mails and paperwork were forwarded to Attorney Herron well prior to the new charges. He further stated that Dr. Miller did not have the right to ask for a continuance or see the complaints against her.

 

Rhett Bullard went into rapid antics saying that a continuance would not be acceptable in any way, while condemning Dr. Miller.   Councilman Jefferson said we have waited for months and there should have been enough time to prepare.

 

Later in the hearing it was brought forward that not all the e-mails were forwarded to Attorney Herron  An E-mail whereby Stacy Tebo appointed Helen Miller as the TOWS HOPE administrator was not included but fortunately Helen Miller retrieved copies establishing Stacy Tebo’s request.

 

As the HOPE administrator through the Hamilton County School Board, Dr. Miller was approved by TOWS (Town of White Springs) and did nothing wrong.  The conditions were set up by the benefactor for the benefit of White Spring youth. If the money had not been received immediately from Hamilton County, any one of the staff could have called the County.  The money was available, but this was the first year the benefactor did not wish to give TOWS the funds. Or, one of the Staff could have contacted Dr. Miller to contact the county. Instead Ms. Tomlinson refused to issue a check and blamed Helen Miller for the money not being in the White Springs Account.  Yet by Contract, the Town had the obligation of paying the employee whether or not there was money. As such Hamilton County did release the funds and the employee was paid within two days.

 

Nevertheless Dr. Miller was blamed by Rhett Bullard for the lack of funds.  Yet the Town Manager is to provide the council monthly financial reports but has not done so in her tenure.  And furthermore it was established at the hearing that none in the Town, including Rhett Bullard who signs the TOWS contracts, have ever read the details and stipulations of said contract.  

 

Of course when Pam Tomlinson was initially told that Hamilton County was to handle payroll before anyone read the contract,  she laughed and said she was happy that she did not have to do the payroll because it was less work for her.  

 

When Police ChiefTracy Rodriquenz was asked if she would assist any council member who asked for her assistance, she said of course, she would assist anyone.  However, either she had a memory lapse or did not intend to be truthfully initially, because she stated only Helen Miller had requested anything from her.  That led to Walter McKenzie stipulating he had requested something from her relating to the Bike Club and then Tonja Brown admitted something about hot dogs.  It was stated that if a council person may not ask for assistance from the Staff or from the Town Manager, then  everyoneshould be ousted from the Council.   Yet that would only apply to the remaining councilor who does not agree with the power of three, Walter McKenzie.

 

When Attorney Herron elected to bring forth information from DeBary whereby Ms. Tebo did not provide all the e-mails requested by her Town Manager or she sanitized them.  She also attempted to have her Manager terminated by discussions with the council.   Rhett Bullard our Mayor and lawyer, who seems to not understand the law, objected to this line of conversation.  As if he knows everything and had the right to comment on Mark Herron’s defense, Rhett Bullard said that was unnecessary but a “ good legal ploy”.   Yet Attorney Herron was finally allowed to show similarities of what happened in DeBary is now happening in White Springs to councilwoman and former Mayor Helen Miller.  Of course Mark Herron ignored the childish comment made by Rhett Bullard which was ridiculous in the least..

 

Mark Herron, Dr. Miller’s attorney included definitions as shown below relating to 119 Fla 119, Supreme Court of Florida  STATE ex rel. v. COLEMAN  May 26, 1934 relating to Public Public Employment Conduct or Misconduct in General “Malfeasance”  as did Town Attorney Frederick Koberlein.  Nevertheless, Rhett Bullard and the remaining power of three voted that Helen B. Miller violated the Charter and charged her with four counts of Malfeasance, without understanding the meaning.

 

The cost for Attorney Elkinds services to and from the hearing and defending Stacy Tebo and staff at the hearing was $8738.50

Throughout the years, Dr. Helen Miller has received money from the following benefactor so that she could assist White Springs Children.

 

H.B. Calder, Ph.D.

1159 Little Bird Court

Henderson, Nevada 89011

 

26 June 2017

Letters to the Editor

The Jasper News

P.O. Box 370

Live Oak, FL 32064

Dear Editor,

I am writing concerning an article entitled “White Springs council votes to declare Miller seat forfeited” which appears in your 22 June edition and subsequently appeared on your website.  Since the actions discussed predominately concern funds which I provided, I believe it appropriate to provide my insights.

I have had the privilege of knowing and working with Dr. Helen Miller for nearly twenty-five years.  While in Ann Arbor, Michigan she maintained full-time employment; volunteered in the City to plan, fund and implement a wide range of infrastructure projects oriented towards improving public safety, and served as president of the Ann Arbor Huron High School Athletic Booster Club, working throughout the entire public school system to restructure and expand girls and boys athletic programs, implement fund raising programs contributing in excess of $500,000 annually to pay for sports activities, infrastructure shortfalls, awards events and more and to implement a school system-wide alcohol and drug diversion program (which subsequently was deployed State-wide, including the University of Michigan).

When Dr. Miller retired to Florida she recognized the needs of White Springs’ youth and decided to bring her experience and expertise to the challenge.  Working with church groups and community leaders, one of her first activities was to put in place a summer program.  Though I personally have no ties to White Springs, I gladly offered to help fund these efforts through my Charitable Giving Fund because I felt that the programs would impact the lives of young people and because I knew that Dr. Miller would be successful.  Between 2010 and 2015, I contributed $134,500 directly to the city of White Springs for the purpose of supporting the Project HOPE and the summer activities for the youth of White Springs.  In 2016 , I contributed an additional $15,000 to the Hamilton County School District for the exclusive benefit of White Springs youth/Project Hope.  In this regard I provided funds to be spent at the exclusive direction of Dr. Miller for any general expenditure she deemed appropriate to facilitate her summer, or other programs; a provision agreed to by the White Springs Town Council in 2010.  I visited White Springs several times and  observed first-hand the ongoing activities, I was impressed with the activities and continued my funding on an annual basis.

I have known Dr. Helen Miller to provide nothing less than the highest quality work at the highest level of integrity.  The expenditures made with funds provided by my contributions were proper and well within the grant guidelines.  I am proud of the results that Dr. Miller’s tireless efforts have achieved for the White Spring’s community and for its youths.

 

Sincerely

H.B. Calder, Ph.D.

 

The Suwannee Democrat and Jasper News, however had the following article:

 

SLIPPERY SLOPE – SUWANNEE DEMOCRAT EDITORIAL

Editorial: Council starts down slippery slope

As both Mark Herron and Darren Elkind, the two opposing lawyers in the Oct. 25 public hearing regarding Helen Miller’s seat on the White Springs Town Council, agreed: the council took upon itself a solemn responsibility with the hearing.

It was the council that charged Miller with malfeasance, misfeasance or non-feasance while in office at its June meeting when it moved to declare her seat forfeited.

It was that same council that then heard the evidence at last week’s public hearing and issued the verdict on whether Miller would indeed have to give up her seat.

But in doing so, the council started down a slippery slope.

One of the four charges heard at the quasi-judicial hearing against Miller involved her asking if staff could move chairs from one building to another to host a dinner for the Suwannee River League of Cities, which Miller serves as the organization’s president.

Herron, Miller’s lawyer, called the charge “probably one of the most trivial charges in terms of trying to deprive the people of their representative on this board that is imaginable.”

We agree that it’s hard to imagine how making a request about moving tables and chairs can lead to someone losing their elected office. Watergate, this is not.

In fact, Elkind even admitted that the charge seemed petty, although he quickly touted the importance of not interfering with employees’ jobs and responsibilities.

Petty and trivial as it may be, the council — by virtue of a 3-1 vote from Mayor Rhett Bullard, Vice-Mayor Tonja Brown and Willie Jefferson with only Walter McKenzie voting against — decided it still constituted a willful violation of the town’s charter. They also voted her in violation on the other three allegations of questionable employee pay requests and overstepping through unilateral direction to city staff.

And in doing so, the council opened itself up to the potential for more seat forfeiture hearings in the future. McKenzie earlier in the hearing admitted to having made requests of Police Chief Tracy Rodriquenz. “I’ve asked Chief Rodriquenz to do things, I’ve asked her if she would mind taking care of the bicycles for the Suwannee Bike (Association) that were donated to the kids for the Christmas program,” McKenzie said, later adding that he also contacted the supervisor of utilities about a water main break that flooded his yard, which could be interpreted as a no-no: “According to the way we’re doing business here tonight, I could be charged with a violation of the charter. And I will openly stand up and say, ‘Yes I did that.’”

That admission seemed to have jogged Rodriquenz’s memory, who had just said that Miller was the lone council member who asked for her help.“Everybody asks me to do things,” she said. “He’s absolutely right in that he’s come to me about the bicycles and I believe Miss Tonja has come to me about hot dogs.“It’s whatever the community needs.”

Except requesting help to fulfill the community’s needs apparently is a willful violation of an express prohibition of the charter.At least, that is what the council declared last week

End of Article

 

After advertising for over thirty days for a new attorney to replace Frederick Koberlein, Jr. who had resigned October 4th, no one attorney or firm applied.  Rhett Bullard then contacted former 18 year Assistant State’s Attorney Karen Hatton, who now has a private law practice in Mayo, to apply. Her information was received one day after the deadline.

 

Since her costs were much higher than former Town Attorney Koberlein’s, Rhett Bullard told Stacy Tebo to re-negotiate Karen Hatton’s fees.  This was during the council meeting. When an objection was made, Rhett Bullard said “But that’s her job”. Citizen Joe Griffin said he had better not give it to her (Stacy) and Councilor Walter McKenzie said in accordance with the Charter and Sunshine laws, it was the Council’s duty to interview Ms. Hatton. Thereafter, a special meeting was called to interview councilor prospects to fill Helen Miller’s seat and for the council to interview and negotiate fees with Ms. Karen Hatton, who is now our attorney as of December 27, 2017.

 

However, Dr. Miller’s Attorney in the interim filed on November 21, 2017 A “Petition for Writ of Certiorari” in the Circuit Court of the Third Judicial Circuit in and for Hamilton County.   We did not have a Town Attorney, at the time, and Darren Elkind previously defended the Staff of White Springs at the hearing. Mr. Elkind only provided the Town of White Springs one contract covering only said staff.  However the writ involved actual “Town of White Springs.  See Addendum 6A We asked for a a specific contract be made showing Mr. Elkind’s fees.  We asked for the new contract from both the Town Staff and from Mr. Elkind himself.  Yet we knew that there was no prior council approval for Mr. Elkind to defend the Town in this action since there was never a vote at a regular or special meeting.  We were told he did not need to provide a separate contract. Obviously the Town Manager was not concerned since Rhett Bullard has covered her infractions.  

 

Stacy Tebo even contacted the court reporter at the hearing telling her she was needed when Attorney Koberlein stepped in and set the record straight.

 

On December 21, 2017 Darren J. Elkind, Esquire, stipulated the response if ordered, would not be an “answer” to a complaint but rather would be in the nature of an appellate answer brief.  See Addendum 6B

 

Then on January 31, 2018, Circuit Judge Andrew J. Decker III issued an order directing respondent to file response to petition for Writ for Certiorari ……. stipulating a review of the Petition appears to demonstrate a preliminary basis for relief.   See Addendum 6C

 

In the interim, The Town of White Springs has hired Karen Hatton as the Town Attorney as of December 27, 2017. Although Darren Elkind had a contract for the hearing to defend Stacy Tebo and staff, he is not the attorney of record to represent the “Town of White Springs” under which the Writ for Certiorari has been made.  

 

A complaint was made to the bar, after telling Mr. Elkind that the White Springs Council would be required to approve his defense of the Town of White Springs. He said he did not need to because Rhett Bullard allowed Stacy Tebo to make the decision to hire Mr. Elkind, without approval or a contractual basis. In the meantime, we, the citizens are expected to pay higher fees for Mr. Elkind who lives two hours away from White Springs rather than having our Town Attorney Karen Hatton take over the case since she is the attorney who represents the Town of White Springs…and at a lesser cost.

 

When a complaint was made to the Florida Bar, this was the response received.

 

 Joshua E. Doyle Executive Director

850/561-5600

www.FLORIDABAR.org

 January 19, 2018

  Re:       Darren Jay Elkind; RFA No. 18-8079 Dear Mr. Griffin:

I have received and reviewed your January 4, 2018 inquiry regarding Mr. Darren Elkind, Esq.

 The issues raised in your inquiry appear to be issues that can be raised in the civil court system, perhaps as part of the pending matter referenced in your inquiry. The Supreme Court of Florida has ruled that the disciplinary process and proceedings are not to be used as a substitute for civil proceedings and remedies. See The Florida Bar v. Della-Donna, 583 So.2d 307 (Fla. 1989). As such, The Florida Bar is not the correct forum in which to have your allegations adjudicated, and resolution of those issues must be left to the appropriate tribunal. In the event the proper tribunal makes a finding or enters an order which supports your allegations against Mr. Elkind, you may resubmit your complaint along with a copy of such findings or order. At that point in time, the Bar would be in a position to further address the issue.

 For the foregoing reason(s), our file remains closed. This decision does not preclude you from seeking the advice of counsel or from pursing any legal or equitable remedies to which you may be entitled. Pursuant to the Bar’s records retention schedule, the computer record and file will be disposed of one year from the date of closing (the date of closing is January 18, 2018).

 Sincerely,

Jack Franklin Wise, IIL Bar Counsel Attorney Consumer Assistance Program ACAP Hotline 866-352-0707 

cc:       Mr. Darren Jay Elkind (w/ enclosure)

 

Summary/Opinion

 

Rhett Bullard has attempted for some time to remove Helen B. Miller PhD from the White Springs Council by reason she would question items such as why we should buy Andrew Greene a new truck so that he can go to and from work to Gainesville to be with his fiancé” We only needed a pre-used vehicle for utility work. Dr. Miller further felt complaints should be heard and decided upon, in accordance with our Charter.   Furthermore, we are a Drug Free Workplace and White Springs’ office should remain a drug free zone.

Ms, Tebo had been fired by the City of DeBary.  She first filed an EEOC complaint against that city, then sued the City of Debary as well as her former manager Dan Parrott as soon as she accepted a position with White Springs.,The suit relates to  sexist remarks even though she herself has not been the recipient of these remarks.

It has been Ms. Tebo’s Intent to have her previous job back at DeBary and a settlement; however, thus far it does not appear favorable for her.  But because of the time she has required for meeting with attorneys, depositions and the like as well as going to her Orange City permanent home in Volusia County on Weekends, Ms. Tebo has taken a substantial amount of personal time off…such time not acceptable in accordance with our personnel manual and her contractual obligations..  In the first year alone, $11,000 was wasted due to the fact that Ms. Tebo took Friday’s off and did not return much before noon on Mondays.  When questioned, Rhett Bullard stated on her behalf that she had doctors’ appointments every Friday.

Since we have common problems, the City of DeBary and we share public records information.  And since both Ms. Tebo’s attorney and DeBary’s attorney were notified of Ms. Tebo’s drug use, this is what Ms. Tebo relayed under oath in her deposition in DeBary of August, 2017:

The attorney asked whether Stacy sought any psychiatric, psychological counseling related to the incident in this case, the incidents in this case? To which Stacy replied No.   When she was asked whether she was taking any medication, she said yes.  And the Attorney said “Are you taking any medication that might have affected your ability to recall testimony you’ve given here today and she said no. 

Yet instead of saying she is taking Percoset, she said she had been taking Xanax at the time she was terminated in DeBary and now she asked the doctor for Bupropion the generic name for Wellbutrin.  She has been going to three to four doctors whoever may see her on Saturdays. Two are general practitioners and one is a gynecologist.

The contributing factor of how our town office is run is by fear alone.   Rhett Bullard puts on a friendly face but wishes things his way and will do anything to be rid of someone and those are similarities of Stacy Tebo as well. Anyone who speaks to the wrong people, is not part of the group, or is super efficient and intelligent will not last long at Town Hall. Stacy Tebo may not be questioned which employees have stated under oath and she spends the majority of her time behind a closed office door, writing e-mails and working on her personal cases.

After the Rivers case was closed by Attorney Larkin, Anita Rivers’ employment with White Springs was terminated. Although special payment schedules are made for some of the citizens regarding utilities, Anita, even though she had paid the late fees, had not turned her water off.   Stacy Tebo called her a thief and fired her over $60.00. There were never any other warnings given to Ms. Rivers. In this case also, there was no forewarning or a request for payment because the power of three and Ms. Tebo wished Anita removed.

The same rules do not apply to the power of three.  Rhett Bullard purchased a home he had previously rented from the Methodist Church in November of 2016.  The Water Utility Deposit of $300 is due for any change in ownership. The only exception to not paying the $300 is if one purchases another home in White Springs and sells their existing home, then the $300 Deposit will move to the new home.  Rhett Bullard told Town Hall that the water transferred with the sale of the home to him by the Methodist Church. However our Ordinance stipulates there may not be such a transfer so Rhett Bullard technically owes the Town $300 but because he is the Mayor and makes his own rules, the money will never be paid.  Deposits are never returned by the Town and should not be called “deposits” and Mr. Bullard probably knows this.

In answer to Inquires 3. And 4.

  1. 3. Although there was ample time for Stacy Tebo to stipulate a Memorandum of Complaint regarding Chief Kevin Pittman, Stacy Tebo did so one hour prior to the January 9, 2018 council meeting.  The council members had not received her complaint in their council packets nor had Kevin Pittman received the complaint to review until the meeting started..   

See Addendum 7 – Tebo states that she had requested his resignation as Fire Chief, and that he could remain a volunteer if he wished on November 29, 2017.  She did this because she wished to avoid any public embarrassment caused by disciplinary action.  She stated, “knowing that any public records created for that purpose would certainly be publicized on a local blog”. ..   “I was also mindful that anything I created would become part of his personnel file which could be reviewed by potential future employers and anyone that wished to see it.”

Tebo also states that the Charter provides that only the Town Manager, town attorney and police chief are hired by the Council.  Again, the Charter does not discuss the Fire Department which technically has equal billing to the police department; therefore it should be under the auspices of the Town Council not the Town Manager, but currently the Charter has no mention of who is in charge.  Secondly all volunteers are approved by the council with a vote and our firefighters are volunteers.  My husband and I are probably the only volunteers to be denied even with extensive experience and educaton.   Stacy Tebo did accredit Andrew Greene for giving her the name of Kevin Pittman to be fire chief.

 

Chief Pittman organized an in-house course to get our volunteers certified.  The Town does not pay or reimburse our fire fighters to attend Fire College and for room and board so Kevin Pittman who had a previous certification as an instructor trained our firefighters so they could pass the 206 hour course.

 

Tebo’s major complaint relating to Kevin Pittman was that he was a CERTIFIED INSTRUCTOR until his certification expired on June 30, 2015 and he did not opt for the one year extension until 6/30/2016 because he did not take the 40 hour course.   Therefore instead of thanking him for what he had done personally with the fire fighters to assure they would pass, the Fire College did not accept Kevin Pittman’s signature.  As a result, one of the students who he assisted was fired by the Division of Forestry because the lack of certification.  Yet other Chiefs signed the certifications on Pittman’s behalf.

 

IT HAS NEVER BEEN REQUIRED THAT OUR FIRE CHIEF BE A CERTIFIED INSTRUCTOR AND THERE ARE NO SPECIFICS WITHIN OUR CHARTER.  NONE OF THE OTHER CHIEFS WERE CERTIFIED INSTRUCTORS.   PITTMAN ASSISTED THE FIREFIGHTERS WHO HAD NO MONEY TO PAY FOR THE COURSE AND THAT IS ADMIRABLE. The Town does not pay for fire school, nor for board or room while going to school, nor for fuel and gas used by volunteers and does not even provide required equipment in many cases.

 

Tebo also blamed Kevin Pittman for having major repairs completed on the newly purchased pre-owned fire engine in October before the Council had even approved the agreementShe complained he ordered decals for the engine and removed the Windsor decals.  She was upset with him about the purchasing policy and although she apprised Mr. Pittman that he should maintain the pre-used fire engine, she was angry that she did not get the cost in advance.  $3,702.51 was required for repairs, mainly because of the Turbo which Stacy did not understand was essential to be repaired. When she initially was asked by Kevin Pittman and Thomas Brazil, she told them to get the maintenance done and did not tell them to secure an estimate first.    Furthermore, if Thomas Brazil and Kevin Pittman did not tell Stacy Tebo that Windsor was having a title problem, the vehicle was still in the Town’s possession which is nine points of the law. 

Stacy Tebo did not have a copy of her complaint for Kevin Pittman but rather Rhett Bullard gave him a copy.  Mr. Pittman was given five minutes to read the complaint and essentially called it crap and resigned. When there was a complaint made that a copy should have been given to Kevin Pittman in advance, Rhett Bullard said, he should have known what he did wrong.   Yet I am certain these charges were never communicated to him. Then the members of the fire department who were there stood up and Rhett Bullard told them they were out of order and we were done with Fire Department Business.  Thomas Brazil was the first to say My name is Thomas Brazil, I’m a Firefighter engineer for White Springs Fire Department and this is my resignation.”.

We were told that Andrew Greene Assistant Fire Chief would not allow the Fire Department to spend money even though they receive $17,000 from the County each year.  They required breathing apparatuses and Andrew Greene said such were frivolous or something to that effect. He said Stacy would not provide it because we did not have money.  Then Stacy blamed Mr. Pittman for not securing a grant for breathing apparatuses when it is the Manager’s duty to coordinate and place together grant information.

Stacy Tebo and Rhett Bullard will do nothing to reimburse the firefighters, for fuel and use of their own vehicles.  This is a shame because they should receive a stipend each time they show up for duty, especially since they have to use their own vehicles to follow the fire truck since the second SUV is not available to them..

 

Andrew Greene uses the new SUV fire truck personally.  Not only does he receive $120 per month but all maintenance and fuel is paid for by the Town, even when he takes frequent trips to Tampa and he lives in Lake City.   This leaves other volunteers who have to catch up with the fire truck using their own vehicles which they maintain and for which they pay all costs of fuel.

 

When it comes to Stacy Tebo however, we will pay her legal fees with no applicable limit or cap; but we cannot allow the volunteers to use the fire truck for which the grant was meant for nor can we provide them with breathing apparatuses.  Yet Rhett Bullard gives her complete control and will not agree to mediating differences.

 

White Springs fire chief, six other firefighters resign

 

 

 

WHITE SPRINGS, Fla. — Seven members of the White Springs Fire Rescue, including Fire Chief Kevin Pittman, resigned at Tuesday night’s town meeting.

The resignations came after discussion at the December meeting in regards to Town Manager Stacy Tebo asking for Pittman’s resignation Nov. 29. Also during that meeting, members of the fire department asked for support in a vote of no confidence against Assistant Fire Chief Andrew Greene.

The council then decided to move the issues with the fire department to the January agenda.

During Tuesday’s meeting, Tebo submitted a Memorandum of Complaint against Pittman, providing each council member a copy.Several citizens asked for a copy of the memo as well as Pittman, who said he had not seen or heard of the memo.

“This document was created today and was finished right before the meeting,” Tebo replied.+ Pittman said: “Since it involves me I would like to be able to read through it.”

According to the memo, Tebo asked for Pittman’s resignation in order to avoid public embarrassment and keep disciplinary action out of his personnel file. Tebo added that when she asked for Pittman’s resignation it was just as chief, that he could decide whether to remain as a volunteer firefighter.

In the memo, Tebo outlined the reasons that led to her decision to seek the resignation, mainly stemming around attempts to get certification for the town’s volunteer firefighters.According to the memo, Pittman allegedly had told Tebo he was a certified instructor and with the help of another instructor would hold classes to provide certification for the firefighters.

Last summer, Tebo and Pittman had talked about recognizing everyone who earned their certifications publicly at a meeting, according to the memo. The recognition was rescheduled from June to July because not everyone had received their certificates. The recognition was held at the July 11 meeting.

However, Tebo states in the memo that she received a call from Hamilton County Emergency Management Director Henry Land on Aug. 2, stating one of the individuals was not certified and Pittman’s signature was not being accepted by the fire college.

Land offered Tebo assistance in getting students certified and could sign off on the certificates, according to the memo. Tebo told Pittman and he allegedly stated it would not be necessary.

In the memo, Tebo states she then looked further into Pittman’s previous employment and certifications where she found an expired instructors certification. It expired June 30, 2015, and was given a one-year extension to June 30, 2016.

While looking into his previous employment at Suwannee County Fire Rescue it shows he was terminated on July 12, 2012, and is stated on his resume that he worked with SCFR through July 2013.

“He was dishonest to me about his instructor certification,” Tebo wrote, adding “he was also dishonest on his resume.

“The integrity of the Town, the Council, and myself was compromised as we unwittingly participated in the deception.”

Also in the memo, Tebo documented issues surrounding the purchase of a fire truck from the Windsor Fire Department. The memo states that Pittman had spent money on repairs and decals for the truck prior to the council approving the agreement, also alleging that the repairs were done without her approval.

After given a chance to read through the memo and prior to the memo being read aloud at the meeting, Pittman resigned.

“I have been fired before and I have quit a lot of jobs, so effective right now you have my resignation as fire chief for this department,” Pittman said. “Tomorrow I will return the truck, personal items and the keys, my keys to the town.

“There is no point in going through this, this nothing but… crap. I’m just going to say it and I am not going to have my name put out there and walked on.”

Following Pittman’s resignation, six volunteer members of the department resigned as well.

“Hold on. We have moved on from the fire department, there’s no…” Mayor Rhett Bullard said before the six volunteers cut in stating: “Let’s just do this right then right now. If you’re going to move on, then we’re going to move on. My name is Thomas Brazil, I’m a Firefighter engineer for White Springs Fire Department and this is my resignation.”

Brazil was joined by Antonio Perez, William Register, Peter Shanks, Andy Stormant and Andrea Thompson in submitting their resignation, leaving nine members at the fire department as of Wednesday afternoon.

End of Article

At the December 12th meeting, the firefighters had approached councilors on their way to the meeting to protest the firing of Kevin Pittman. Mr. Pittman did not attend the meeting.  Rhett Bullard pretended that he knew nothing about the request to remove Kevin Pittman as fire Chief and made no admission. Walter McKenzie warned the council that if we remove Mr. Pittman without a fair hearing, we will no longer have a fire department.  Currently under Kevin Pittman as Fire Chief we have had more volunteers who are certified and who have protected White Springs and the surrounding area as no other town has had.

On behalf of all the Firefighters, one firefighter read the following to the Town Council in the December meeting:

WHITE SPRINGS FIRE RESCUE      December 12, 2017 VOTE OF NO CONFIDENCE

We, the members of the White Springs Fire Rescue, have composed this letter to express our dissatisfaction with the current Assistant Chief, Joseph Andrew Greene.  Unfortunately circumstances have left us with no other recourse.  We have lost all trust, faith and confidence in Assistant Greene’s ability to lead this department

Asst. Chief Greene’s lack of dedication and inability to perform his duties in a timely fashion has damaged the department’s performance.  These problematic tendencies are very crucial in a field where mistakes and divisive behavior can cost department members and citizens their lives.  He has not upheld his position or responsibility to the Department and has not attended any department trainings, functions nor Station shifts since April 29, 2017.  Records show since July 1, 2017 a total of (51) responses have been required in and around White Springs.  Chief Pittman has responded to (35) of those calls.  Firefighter Brazil has responded to (29) calls, Firefighter’s Perez and Register have responded to (27), Greene has only responded to (7).  Other members of the department who are not able to reach the station in an adequate response time are often performing shifts and duties at the fire station on their days off from full time employment.  The only shift Greene has participated in was a contractual paid event.  During that shift, both he and member Dominique Greene were dismissed from their duties for inappropriate behavior and misconduct within a patient care area.

.

His lack of leadership, mismanagement and poor policy decisions have damaged the relationships within the department.  In June of 2017, Chief Pittman met with the Town Manager, Stacy Tebo, on behalf of the department to discuss Assistant Chief Greene’s lack of communication and his deliberate avoidance of training and department procedures.  Attempts to address workplace problems with Assistant Greene have gone unheeded by the Town Manager regardless of the number of complaints.

 

During Hurricane Irma, several members were present at the station for up to (72) hours each to perform their needed services due to the catastrophic impact of the storm.  Greene, who is also the town Utilities Director, was not present to fulfill his duties in public works and the fire department, before or during Irma.  No contact was maintained with the department during this time and several individual members were approached by contractors, city employees and citizens attempting to contact Greene.  This was a major devaluation of Greene’s dedication to the department, as Chief Pittman was present for the entirety of the storm including preparations and cleanup efforts alongside other responders, maintaining clear communication with all members.

 

Greene refuses to address issues presented to him by department members, answering inquiries in a dismissive manner showing disregard to the chain of command and the need of the department.  When approached by department personnel regarding essential firefighting equipment needing repair or replacement, he deflects questions and says “I do not have to explain myself”.  In other confrontations, he has told members that Town Manager Tebo has not allotted any budget for the department’s frivolous spending” and the equipment shall have to suffice, even though we must stress that the difference between life and death for firefighters is the degree of functioning equipment they possess.

 

With (8) certified Firefighter One members and (2) Firefighter Two members in the department with only (3) functioning air packs, this places all members in dangerous situations.  Greene’s lack of care for the issue shows his total disregard for department members.  He does not show respect to the livelihood or wellbeing of the firefighter’s safety.

 

 

In October, Assistant Chief Greene and Town Manager Tebo removed personnel access to the station’s computers required for reporting runs and other necessary information.  Taboo’s memo claimed that Greene would be taking full responsibility for the logging of paperwork and the running of reports.  Since this was enacted, Green has not performed his duties in a timely manner, often requiring members to tape reports, receipts and requests to his office door.  This attitude of poor management has sown distrust with his refusal to communicate properly.

 

We feel that the relationship with Assistant Chief Green is irreparable.  He has brought morale to an all-time low with his lack of leadership and poor management style.  Greene has established a pattern and practice of inequitable treatment of department personnel.  A bad manager can take a functioning staff and destroy it by causing the best employees to leave the Department and those which remain to lose all motivation.

In closing, we would like to reiterate one last time that the members of White Springs Fire Rescue have lost all trust and faith in Assistant Chief Andrew Greene’s ability to lead this Department.  We therefore, respectively ask that you support our VOTE OF NO CONFIDENCE and relieve Assistant Chief Greene of his duties and responsibilities pertaining to the Fire Department.

 

Respectifully yours,

The Members of White Springs Fire Rescue 

End of Letter

 

Making a vote of no confidence in Andrew Greene,  in a public forum, was their last hope in this towns’ city officials to do something about the problem. It was brought to Stacy Tebo’s attention in a meeting she and Kevin Pittman had.   When he asked her who appointed Greene as Assistant Chief an She stated Stith did (A former chief who quit twice who used Greene as an administrator only but neither fought fires as volunteers).

Pittman also informed her that he was going to remove Greene from the Assistant Chief spot and just do away with it because it was not needed due to the quality of leaders he had under Greene. . Stacy Tebo said ”No; You cannot remove Greene again”. She was told he can stay on the department as a fire fighter but not as the Assistant Chief again. She said “No!”.   Much of this information was received from the firefighters themselves.

Andrew Greene handles the Wastewater Treatment plant and he assisted Robert C. Townsend former Town Manager and a cousin of Rhett Bullard’s prior to taking over the utility when the former was fired. Although he was appointed Assistant Fire Chief by former Fire Chief Steven Stith at the direction of Rhett Bullard, and former Town Manager Robert C. Townsend, he has never been inside a structure fire or been to one in three years. He has shown up to two fires in shorts and flip flops handing water to the other firefighters. Yet he uses the new SUV for personal use and shows up at the annual Christmas parade, various restaurants in Lake City and various areas of Tampa.. And as such the Town’s insurance will be liable for a possible Auto Liability claim in the event he has a blackout or a workers’ compensation’ claim for Greene, since there is no paperwork and as long as he drives the vehicle whether work or personally he is covered for workers’ compensation.

The reason Rhett protects Andrew Greene is because his number one client is Andrew’s grandmother Ethen McGhin, so there is a clear conflict of interests and ethics. It all goes back to the conflict of interests between Rhett’s law practice who just happens to have as one of their biggest clients, Andrew’s grandmother Ethel McGhin  Rhett won’t let any harm come to the boy because it affects him financially

If you want more proof on Andrew’s condition, we were told one should should look into Andrew’s use of sick leave at work.  Some of these days may have been because he was sick but some them may have been to cover up his seizures and blackoutsSpecifically days where Andrew may have come to work but then at some point in time had to go home sick

The members of the Fire Department on the night of the council meeting did not intend to resign but when Ms. Tebo did not provide the memo to Mr. Pittman in advance of the meeting so he could defend these allegations, the firefighters felt they would be treated the same. As members of the department, they felt that if Rhett Bullard and Stacy Tebo would do that to Chief Pittman, bringing up issues from many years ago, they felt they no longer had the support of their town officials.”  The members decided that they had no other choice but to leave the department because if Ms. Tebo did it to two different chiefs and Rhett Bullard would not stand up for the department, who would be next?.

Pittman was the only chief that worked for in this town/department that stepped up to do the job to get everyone trained to hold meetings, family dinners, and events for the kids in this town. He stepped up when no one else would take a broken down department with little to nothing an bring it into the 21st century. The Town had no dedicated members before he took over. It is known first hand that  previous members of the department did not show up for calls in the middle of the night during the day or even come wash a truck. 

When Chief Pittman took over the fire department gained some of the best members any department could ask for.  They showed up to calls cleaned and manned the station cleaned the trucks took care of the equipment. They gave a damn about this department and this town’s citizens.

The firefighters tried to give the best of the best to the town and we were constantly shut down by city hall.

We had the most members of any department in the county now this town is left with nothing but three even though the town manager stipulates there are seven firefighters. It doesn’t matter how many names you have on a piece of paper it matters on how many show up. How many show up in the middle of the night to help you. How many show up when you need them at your most critical times is what counts. So this list means nothing and holds no water when no one shows up.

“Just know we as members are sorry that we could not do more for this town but just know we gave it our best and we did, all we could do, with NO SUPPORT FROM THE TOWN OFFICIALS ie Stacy Tebo the town Mayor and two of the council members.”

Kevin Pittman was a certified Firefighter II, a medic, a hazmat tech and a fire inspector. He did not lie to her about everyone being certified as he stated to her that the firefighters have completed the required class of 206 hours and were awaiting the state certification at this time. The firefighters were aware that there was an issue with a signature and ll were aware that it was being worked on and it was taken care off.

Just know Chief Pittman did everything for this town.  He was the only fire chief I have seen show up in the middle of the night for medical calls, fires, crashes, Landing zone set ups.  He showed up. The firefighters said it was not the same for the previous chief or the assistant chief. Chief Pittman showed up when this town needed him; when this town needed a chief and a leader. He single handedly turned a broken run down untrained unstaffed department and turned it into a full on working staff and trained a loyal department no thanks to City Hall, Rhett Bullard or Stacy Tebo.

Mayor Bullard, Vice Mayor Tonja Brown and Councilor Willie Jefferson allowed Stacy Tebo to fix what was not broken.  Now we technically do not have a fire department so in accordance with this ordinance, the Town better hire a third party fire agency because they are liable for this ordinance/contractual duty or bring Kevin Pittman back as Fire Chief and the fire fighters will follow

 

ORDINANCE #12-01 amends Section 5.06 of the Charter of the Town of White Springs as follows:

The Town of White Springs, Florida has the responsibility for providing fire protection services, whether by or through a White Springs Volunteer Fire Department or by and through an appropriate  contractual relationship with a third party fire agency.

The Town Council shall have the sole discretion in determining the manner for providing fire protection services for the safety and well being of the citizens of White Springs, Florida.  Nothing herein shall prevent the White Springs Volunteer Fire Department from assisting agencies as the need arises.

As the firefighters told me, the Town can lie that we have fire fighters, and make up some number or put in names from neighboring towns….but what matters is who shows up.  The firefighters we had showed up and as volunteers were treated poorly. This was mainly because Rhett Bullard desired Andrew Greene to be fire chief or to remain as the Assistant Chief.

Regarding Mayor Bullard giving the second fire truck to Andrew Greene

for his personal use.

There are no Town Regulations regarding Staff personally using the fire trucks.  At one time Tracy Rodriquenz was allowed to drive to and from Jacksonville and she was required to pay a portion of the fuel cost.

In the case of Andrew Greene, Helen Miller stopped the Town from purchasing a new Vehicle Pickup 4/4 so Andrew could travel back and forth to Gainesville.  Since he was favored by Rhett Bullard and Pam Tomlinson, they were upset and a motion was made before the power of three could vote against Helen Miller’s motion.

Greene was of course upset with us as well and the fact that we reported him driving, I believe, the bush truck.  He would display lights and sirens when coming by our house and would throw firecrackers at our Jeep and house along with one of his cousins.  We had to report it to the police. Yet he used it as his personal toy to look like a valid firefighter.

Each case is decided on its own merits but only favored employees such as Tracy Rodriquenz and Andrew Greene have received this additional benefit by reason of Rhett Bullard and his power of three.

 

Attached is a letter written by Dr. Helen Miller who as a former mayor and councilor knows what our grants relating to the fire vehicles require and what has transpired to cause White Springs to lose our firefighters. She has a wealth of experience in the handling of Town Business.

(See Addendum 8)

Please contact me by mail, phone (386)397-2951 or by e-mail kashafly@gmail.com should you have any further questions.   Thank you for your consideration of our dilemma.

 

Sincerely yours

Karin Ann Griffin, CPCU

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