Good morning Mr. Rogers,
Thank you for your time today. We spoke at length regarding the Court’s notice of dismissal for lack of prosecution. During that phone call we discussed attempting to settle the matter with PS Bay by drafting a document that maintains the status quo in a relatively simple manner. We also discussed returning to the Court at the scheduled hearing on May 3, 2023 to inform the Court regarding what has transpired and that Sunny Shores is concerned that should the case be dismissed, the status quo will change and accordingly because the parties were unable to draft a temporary injunction outside of court, we’d like to set a hearing where the Court assists us in that process. Thereafter, we would attempt to settle with PS Bay and that way we keep the status quo by having something in writing. The last option would be to fully litigate this matter.
At this time, you and your contingent would like to proceed with returning to the Court and requesting the Court’s assistance in drafting a temporary injunction. Thereafter, we would seek a written settlement with PS Bay that would transfer to a new buyer or at the very least would provide notice of Sunny Shores’ right to use the ramp. Due to the age of this file within our office, the file was administratively closed and the retainer which was previously paid has been exhausted. Prior to updating the retainer agreement and obtaining an updated retainer fee of $5,000, you informed me that Sharon France should be removed as a contact and you’d like to add another individual as a contact. Please provide their name, address, email and phone number in response to this email.
Also, by way of email I’m introducing you to Jessica Gabriel who now assists me on all matters. Any future correspondence or questions should be directed to her or me and we will endeavor to return phone calls or emails expeditiously. Let me know if you have any questions and thank you for your attention.
Best regards,
Richard P. Green | Senior Attorney
100 Second Avenue South, Suite 501-S | St. Petersburg, Florida 33701