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Filing # 124327083 E-Filed 04/05/2021 02:51:52 PM
IN THE CIRCUIT COURT OF THE FIFTH
JUDICIAL CIRCUIT, IN AND FOR
MARION COUNTY, FLORIDA
CASE NO.: 2019-CA-002722-CA
DIVISION: 3-D
CODY MCMASTERS,
Plaintiff,
vs.
RANDY GLENN SPELL,
Defendant.
/
NOTICE OF ACCEPTANCE OF PLAINTIFF, CODY MCMASTERS’
PROPOSAL FOR SETTLEMENT TO DEFENDANT, RANDY GLENN SPELL
Defendant, RANDY GLENN SPELL, by and through his undersigned
counsel, hereby accepts the Plaintiff, CODY MCMASTERS’s Proposal
for Settlement bearing certificate date of March 4, 2021. A copy
of the Proposal for Settlement is attached hereto.
****REMAINDER OF PAGE INTENTIONALLY LEFT BLANK****
Electronically Filed Marion Case # 19CA002722AX 04/05/2021 02:51:52 PM1 HEREBY CERTIFY that a true and correct copy of the foregoing
has been furnished via Florida Courts E-Filing Portal this ve
day of April, 2021, to: Ms. Adrienn N. Toth, Esq., Morgan & Morgan,
P.A., 20 N. Orange Ave., Suite 1600, Orlando, Florida 32801,
atoth@forthepeople.com; emilysmith€forthepeople.com.
Xv
Andisdw . Leeper
wrt Lee 717029
Rene B. Diaz
Florida Bar No.: 88962
Leeper & Associates, P.A.
218 Annie Street
Orlando, FL 32806
Telephone No.: (407) 488-1881 (Rbd)
Facsimile No.: (407) 488-1999
iegalservice@ihlaworlando.com
Attorneys for Defendant
Randy Glenn SpellIN THE CIRCUIT COURT OF THE
FIFTH JUDICIAL CIRCUIT, IN AND FOR
MARION COUNTY, FLORIDA
CASE NO: 19-CA-2722
CODY MCMASTERS,
Plaintiff,
vs.
RANDY GLENN SPELL,
Defendant.
f
PROPOSAL FOR SETTLEMENT
Plaintiff, CODY MCMASTERS, by and through the undersigned counsel offers to settle the
claim or claims identified below against Defendant, RANDY GLENN SPELL with reference to the
above-styled case. Plaintiff's proposal for settlement is as follows:
1. BASIS FOR PROPOSAL. This proposal is made pursuant to Rule 1.442 of the
Florida Rules of Civil Procedure and section 768.79 of the Florida Statutes.
2. PARTY MAKING THIS PROPOSAL. This Proposal for Settlement is made
by: Plaintiff, CODY MCMASTERS.
3. PARTIES TO WHOM PROPOSAL IS BEING MADE. This Proposal for
Settlement is made to the following party: Defendant, RANDY GLENN SPELL.
4, PROPOSAL TO SETTLE ALL DAMAGES. This Proposal for Settlement
resolves all damages that would otherwise be awarded in a final judgment in the above-styled
action, subject to Rule 1.442(c)(2)(F) of the Florida Rules of Civil Procedure.5. RELEVANT CONDITIONS. Plaintiff states that if Defendant, RANDY
GLENN SPELL, accepts this Proposal for Settlement, Plaintiff, CODY MCMASTERS will
dismiss this case with prejudice.
6. PROPOSED SETTLEMENT AMOUNT. Plaintiff CODY MCMASTERS,
proposes to settle all damages against Defendant RANDY GLENN SPELL for a total sum of
thirty thousand ($30,000.00).
7. PROPOSED AMOUNT FOR PUNITIVE DAMAGES, IF ANY. Plaintiff
states that $0.00 dollars have been allocated to any punitive damages claim Plaintiff, CODY
MCMASTERS has or may have against Defendant, RANDY GLENN SPELL. Acceptance of
this Proposal for Settlement will settle any punitive damages in this action that Plaintiff, CODY
MCMASTERS might otherwise be awarded against Defendant, RANDY GLENN SPELL in the
final judgment in this action.
8. ATTORNEYS’ FEE CLAIM: Plaintiff, CODY MCMASTERS states that
attorneys’ fees are not included in this Proposal for Settlement. Attomeys’ fees are not a part of
Plaintiff, CODY MCMASTERS’s legal claim against Defendant, RANDY GLENN SPELL.
[Certificate of Service on the following page]CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 4" day of March, 2021, I forwarded the foregoing via
electronic mail to the following: Andrew J. Leeper, Esquire, Leeper & Associates, P.A., 218
Annie Street, Orlando, FL 32806 [legalservice@\hlaworlando.com; nochoa@hlaworlando.com;
nashmore@|hlaworlando.com}.
ésl Adrienn N. Toth
ADRIENN N. TOTH, ESQUIRE
Florida Bar Number 1002866
Morgan & Morgan, P.A.
20 N. Orange Avenue
Suite 1600
Orlando, FL 32801
Telephone: (407) 420-1414
Facsimile: (407) 245-3485
Primary email: atoth@forthepeople.com
Secondary email: emilysmith@forthepeople.com;
vanessac@forthepeople.com
Attormeys for Plaintiff
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Filing # 124327083 E-Filed 04/05/2021 02:51:52 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, IN AND FOR MARION COUNTY, FLORIDA CASE NO.: 2019-CA-002722-CA DIVISION: 3-D CODY MCMASTERS, Plaintiff, vs. RANDY GLENN SPELL, Defendant. / NOTICE OF ACCEPTANCE OF PLAINTIFF, CODY MCMASTERS’ PROPOSAL FOR SETTLEMENT TO DEFENDANT, RANDY GLENN SPELL Defendant, RANDY GLENN SPELL, by and through his undersigned counsel, hereby accepts the Plaintiff, CODY MCMASTERS’s Proposal for Settlement bearing certificate date of March 4, 2021. A copy of the Proposal for Settlement is attached hereto. ****REMAINDER OF PAGE INTENTIONALLY LEFT BLANK**** Electronically Filed Marion Case # 19CA002722AX 04/05/2021 02:51:52 PM1 HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via Florida Courts E-Filing Portal this ve day of April, 2021, to: Ms. Adrienn N. Toth, Esq., Morgan & Morgan, P.A., 20 N. Orange Ave., Suite 1600, Orlando, Florida 32801, atoth@forthepeople.com; emilysmith€forthepeople.com. Xv Andisdw . Leeper wrt Lee 717029 Rene B. Diaz Florida Bar No.: 88962 Leeper & Associates, P.A. 218 Annie Street Orlando, FL 32806 Telephone No.: (407) 488-1881 (Rbd) Facsimile No.: (407) 488-1999 iegalservice@ihlaworlando.com Attorneys for Defendant Randy Glenn SpellIN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, IN AND FOR MARION COUNTY, FLORIDA CASE NO: 19-CA-2722 CODY MCMASTERS, Plaintiff, vs. RANDY GLENN SPELL, Defendant. f PROPOSAL FOR SETTLEMENT Plaintiff, CODY MCMASTERS, by and through the undersigned counsel offers to settle the claim or claims identified below against Defendant, RANDY GLENN SPELL with reference to the above-styled case. Plaintiff's proposal for settlement is as follows: 1. BASIS FOR PROPOSAL. This proposal is made pursuant to Rule 1.442 of the Florida Rules of Civil Procedure and section 768.79 of the Florida Statutes. 2. PARTY MAKING THIS PROPOSAL. This Proposal for Settlement is made by: Plaintiff, CODY MCMASTERS. 3. PARTIES TO WHOM PROPOSAL IS BEING MADE. This Proposal for Settlement is made to the following party: Defendant, RANDY GLENN SPELL. 4, PROPOSAL TO SETTLE ALL DAMAGES. This Proposal for Settlement resolves all damages that would otherwise be awarded in a final judgment in the above-styled action, subject to Rule 1.442(c)(2)(F) of the Florida Rules of Civil Procedure.5. RELEVANT CONDITIONS. Plaintiff states that if Defendant, RANDY GLENN SPELL, accepts this Proposal for Settlement, Plaintiff, CODY MCMASTERS will dismiss this case with prejudice. 6. PROPOSED SETTLEMENT AMOUNT. Plaintiff CODY MCMASTERS, proposes to settle all damages against Defendant RANDY GLENN SPELL for a total sum of thirty thousand ($30,000.00). 7. PROPOSED AMOUNT FOR PUNITIVE DAMAGES, IF ANY. Plaintiff states that $0.00 dollars have been allocated to any punitive damages claim Plaintiff, CODY MCMASTERS has or may have against Defendant, RANDY GLENN SPELL. Acceptance of this Proposal for Settlement will settle any punitive damages in this action that Plaintiff, CODY MCMASTERS might otherwise be awarded against Defendant, RANDY GLENN SPELL in the final judgment in this action. 8. ATTORNEYS’ FEE CLAIM: Plaintiff, CODY MCMASTERS states that attorneys’ fees are not included in this Proposal for Settlement. Attomeys’ fees are not a part of Plaintiff, CODY MCMASTERS’s legal claim against Defendant, RANDY GLENN SPELL. [Certificate of Service on the following page]CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 4" day of March, 2021, I forwarded the foregoing via electronic mail to the following: Andrew J. Leeper, Esquire, Leeper & Associates, P.A., 218 Annie Street, Orlando, FL 32806 [legalservice@\hlaworlando.com; nochoa@hlaworlando.com; nashmore@|hlaworlando.com}. ésl Adrienn N. Toth ADRIENN N. TOTH, ESQUIRE Florida Bar Number 1002866 Morgan & Morgan, P.A. 20 N. Orange Avenue Suite 1600 Orlando, FL 32801 Telephone: (407) 420-1414 Facsimile: (407) 245-3485 Primary email: atoth@forthepeople.com Secondary email: emilysmith@forthepeople.com; vanessac@forthepeople.com Attormeys for Plaintiff