Lawsuit filed by Jason Roe against Paige Kreegel

IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUITIN AND FOR CHARLOTTE COUNTY, FLORIDA

REVOLVIS CONSULTING, INC.;

Plaintiff,

vs. Case No. 12-3795-CA

PAIGE V. KREEGEL, M.D. d/b/aKREEGEL FOR CONGRESS;

Defendant,/

SECOND AMENDED COMPLAINT

Plaintiff, REVOLVIS CONSULTING, INC. (the "Plaintiff'), sues Defendant PAIGE V.

KREEGEL, M.D. d/b/a KREEGEL FOR CONGRESS (the "Defendant") and as causes of

action alleges:

GENERAL ALLEGATIONS

1. At all times material to the matters alleged herein, Plaintiff, was and is a foreign

corporation conducting business in this state and was conducting business in Charlotte County,

Florida.

2. The Defendant, PAIGE V. KREEGEL, M.D., is a natural person, sui juris and, based

upon information and belief, is a resident of Charlotte County, Florida, doing business as

KREEGEL FOR CONGRESS, an unincorporated entity.

3. The Plaintiff and the Defendant entered into a written agreement (the "Agreement")

wherein the Plaintiff would provide campaign consulting services (the "Services") to the

Defendant in exchange for the Defendant's payment for said services; a true and correct copy of

the unexecuted contract is attached hereto as Exhibit "I" and incorporated herein by reference.

Page 1 of5

4. The Plaintiff fully performed its obligations under the Agreement.

5. The Defendant failed to remit payment in full pursuant to the Agreement.

6. Venue is appropriate in Charlotte County, Florida.

7. All conditions precedent to the filing of this action have been satisfied or otherwise

waived.

8. Plaintiff has retained the law firm of Fowler White Boggs P.A to represent it in this

action and has agreed to pay a reasonable fee for their services. Plaintiff is entitled to recover

these fees from the Defendant pursuant to the terms of the Agreement.

COUNT I: BREACH OF CONTRACT

9. This is an action for damages that exceed $15,000.00 exclusive of interest and costs.

10. The Plaintiff realleges and incorporates by reference the allegations of Paragraphs 1

through 8 as if set forth fully herein.

11. The Plaintiff and the Defendant entered into the Agreement whereby the Plaintiff

provided the Services to the Defendant and the Defendant agreed to pay for the Services.

12. The Defendant breached the Agreement by failing to remit payment in full for the

Services as evidenced by the invoices (the "Invoices") that are attached hereto as Exhibit "2"

and incorporated herein by reference.

13. The Plaintiff has been damaged by the Defendant's breach of the Agreement.

14. The Defendant owes the Plaintiff the sum of $52,262.63 that is the unpaid balance due

under the Agreement for the Services.

15. The Plaintiff has performed all conditions precedent to be performed by the Plaintiff, and

any conditions not performed were waived by agreement of the parties or prior breach by the

Defendant.

Page 2 of5

WHEREFORE, Plaintiff, REVOL vis CONSULTING, INC. respectfully requests this

Court enter Judgment against Defendant, PAIGE V. KREEGEL, M.D. d/b/a KREEGEL FOR

CONGRESS, for:

i) Damages plus interest thereon;

ii) Costs and reasonable attorneys' fees for this action; and

iii) Such further relief as the Court may deem just and proper.

COUNT II: ACCOUNT STATED

16. This is an alternative action for damages that exceed $15,000.00, exclusive of interest and

costs.

17. The Plaintiff realleges and incorporates by reference the allegations of Paragraphs 1, 2,

and 4 through 7 as if set forth fully herein.

18. Before the institution of this action, the Plaintiff and the Defendant had business

transactions that include, but are not limited to, the months of July 2012 through August, 2012.

19. The Plaintiff rendered letters (the "Notice Letters") regarding the outstanding account

statementlinvoices to the Defendant; a true and correct copy of the letters are attached hereto as

Exhibit "3" and incorporated herein by reference.

20. Defendant did not object to the amount stated in the Notice Letters.

21. Defendant owes Plaintiffthe agreed upon sum of$52,262.63.

WHEREFORE, Plaintiff, REVOLVIS CONSULTING, INC. respectfully requests this


CONGRESS, for:

i) Damages; and

ii) Such further relief as the Court may deem just and proper.

Page 3 of5

COUNT III: OPEN ACCOUNT


costs.



24. The Defendant requested and Plaintiff agreed to provide the Services to the Defendant.

25. The Plaintiff did provide the Services requested by the Defendant.

26. The Defendant owes the Plaintiff the agreed upon sum of $52,262.63 according to the

Invoices attached hereto as Exhibit "2."



CONGRESS, for:

i) Damages; and

ii) Such further relief as the Court may deem just and proper.

COUNT IV: UNJUST ENRICHMENT


costs.



29. The Plaintiff provided the Services to the Defendant.

30. The Defendant had actual or constructive knowledge that the Plaintiff was providing the

Services and never objected to the Plaintiff.

Page 4 of5

31. The Defendant received a benefit from the Plaintiffs Services but has not paid in full for

them.

32. The Plaintiff did not provide the Services gratuitously, and the Defendant had actual or

constructive knowledge of that fact.

33. The Defendant shall be unjustly emiched if allowed to benefit from the Plaintiffs

Services without paying for them.

34. The Plaintiff has no prompt, sufficient, and adequate and complete remedy at law that

would promote the ends of justice as an action in equity.



CONGRESS, for:

i) Damages in the amount equal to the costs of the Services; and

ii) Such other and further relief as the Court may deem as just and equitable.

FOWLER WHITE BOGGS P.A.P.O. Box 1567Fort Myers, FL 33902(239) 334-7892Fax No: (239) 334-3240

~~-&~By:---~Corris L. McIntosh, Jr.Florida Bar No: [email protected]

45144827

Page 5 of5

~".'..', "'-VOiVIS~

Proposal for Consulting Services

Revolvis Consulting, having its principal place of business at 1029 K Street, Suite 44, Sacramento, CA95814 (hereinafter "RevolvisU), appreciates the opportunity to submit a proposal to provide campaignconsulting services to Paige Kreegel for Congress (hereinafter "Client") for the 2012 election cycle. Theentire team of Revolvis is available to advance your interests and is committed to providing the highestlevel of service in furtherance of your goals. This proposal will describe the terms under which thatrepresentation would occur.

1. Scope of work. Revolvis shall, as an independent contractor, at the general direction and withthe approval of Client and for the direct benefit of campaign on behalf of Client:

a. Prepare and implement a political campaign plan and campaign budget;b. Provide primary consultative supervision of the organization, management and direction of

the campaign, in conjunction with the manager, consulting team and Client;c. Write, design and produce all direct mail, television, radio, print, and online voter contact;d. Select and supervise vendors of goods and services to the campaign;e. Perform or oversee other services which may include, but not be limited to, any or all of the

following: strategy development; research (including opposition research); polling; coalitionbuilding; supervise press officer and operations; provide where appropriate, direct presscontact; develop advertising concepts; if requested, produce and place with appropriatemedia all electronic communications;

f. Comply with the requirements of appropriate campaign reporting practices and law asdefined in paragraph 2(b) of this agreement.

Z. Obligations of Client. In addition to all the terms and conditions of this agreement, Clientspecifically notes the provisions and agreements contained in a) and b) below:

a. Client acknowledges that it has been advised to seek the assistance of an attorney or otherqualified professional to ensure compliance with the requirements of campaign reportingpractices and law, as defined hereinafter.

b. As used in this agreement, the phrase "campaign practices and law" means any law, statute,regulation, ordinance, rule, resolution, other enactment, advisory opinion, judicial ruling orother action by any federal, state or local government unit, agency or political subdivisionthat, on its face or as applied, requires the reporting or disclosure of campaign contributionsor expenditures, or both, or that regulates the campaign practices for any elective office ormeasure, of political committees or of other persons or entities engaged in political activity,or any liability sought to be imposed by any governmental unit, agency or politicalsubdivision, or by any person for libel, slander, defamation, invasion of privacy or any otherconduct under the statute or case law of any United States state, district, territory,commonwealth or other jurisdiction.

3. Fees. In exchange for these services, Client agrees to pay Revolvis:

a. Retainersi. Revolvis will send an invoice on the first of each month and payment is due by the

end of each month. C to the performance of this work will

_.'-'- -

"ÊVOlVIS~

be billed in addition to the monthly retainer, and these costs may include travel andother expenses incurred on Client's behalf. No monthly costs that in the aggregateexceed $500 will be incurred without prior approvaL.

i. $2,500 per month beginning January 1, 2012.b. Commissions

i. Revolvis will receive 10% commission on direct mail, electronic media, and othervoter contact produced on behalf of Client.

c. Performance bonusesi. If Client wins Republican nomination, Client agrees to pay Revolvis a $20,000 bonus

payable within 60 days of election;ii. If Client is elected to office, Client agrees to pay Revolvis a $10,000 bonus payable

within 90 days of election.d. Opportunity costs

i. If Client drops out of the race prior to the filing deadline, Client will pay Revolvis$5,000 in opportunity costs;

ii. If Client drops out of the race after the filing deadline, Client will pay Revolvis$10,000 in opportunity costs;

e. Terminationi. This agreement would proceed on a month-to-month basis and may be terminated

by either party with 30 days written notice;ii. Client and Revolvis agree that contract automatically terminates upon the Clients

election or defeat.

4. Vendor costs and payments. Based upon the budget approved by Client, Revolvis may contractwith vendors for goods and services for Client's campaign.

5. Consultant's diligence; no warranty of success. Revolvis shall use best efforts and diligence inperforming the services required by this agreement. Revolvis makes no warranty, expressed orimplied, as to the results of the services provided or any future services that may be contracted.

6. Itemization of expenditures. Revolvis and its agents shall furnish Client full itemization of allexpenditures, including copies of original receipts if requested by Client, made and accrued withrespect to this agreement, in a timely fashion consistent with relevant campaign reportingprocedures and deadlines. Neither Revolvis nor its agents shall assume any liability for Client'sobligation to properly comply with relevant campaign reporting and practices laws.

7. Indemnification. Client and Revolvis, their agents and employees, shall hold each otherharmless from any and all liability arising from or related to the campaign or any and all liabilityarising from any act or omission, including active or passive negligence, or related to anyrequirements imposed on the Client or Revolvis, by any campaign reporting and practices laws,which arises from any act or omission, including active or passive negligence.

8. Simultaneous services by Revolvis to other campaigns. Client acknowledges its understandingthat Revolvis is engaged in the business of political campaign consulting and public relations andduring the performance of this agreement Revolvis may be actively involved in furnishingservices similar to those provided by this agreement in political campaigns for other candidates

Page 2 of4

~E~VO-lVIS;

and issues. Revolvis shall not be limited in any way in performing services for other clients thatare not in direct conflict with the discharge of its obligations under this agreement.

9. Termination. Revolvis and Client have the right to terminate this agreement on thirty (30) dayswritten notice, except that Client may only terminate this agreement upon payment andsettlement of all fees, vendor and service invoices currently due and provision settlement ofremainder fees per Section 4 above. Commissions are deemed to have been earned, due andpayable as of the date Revolvis contracted or ordered with any vendor to provide goods orservices pursuant to this agreement or, in the case of media and slate commissions, as of thedate the media was placed or slate reserved, as those phrases are known and understood in theadvertising industry.

10. Attorney's Fees. Prevailing party on any legal action to enforce the contract will be entitled totheir reasonable attorney's fees and costs.

11. Ownership of work product; limited license to use. All work of Revolvis, including but notlimited to print copy, audio copy, audio and video tapes, any and all lists and data filesdeveloped or created, themes, designs, slogans, and any and all other creative products ofRevolvis, its agents or employees, are and shall be the joint property of Revolvis and Client.

12. Confidentiality. Revolvis agrees to maintain the confidentiality of Client's information, includingbut not limited to research conducted by Revolvis or a vendor of Revolvis on Client.

13. Complete Agreement. This Agreement is the complete agreement of the parties and supersedesany previous agreements, whether written or oral, between the parties. No agreement orunderstanding, oral or written, in any way modifies the terms and conditions set forth herein,unless noted as an addendum to this contract, dated after this contract, and signed by a partnerof Revolvis.

14. Jurisdiction and Governing law. Any action for break of this Agreement, for enforcement of thisAgreement, or for any cause of action purported to arise out of this Agreement must becommenced in a court of competent jurisdiction in the state of California. Each party agrees thatCalifornia is the proper forum state for the commencement of any legal action by any party tothe Agreement. Each party further agrees to submit to the in-person am jurisdiction of the courtin which an action is commenced.

Page 3 of4

f~iiFORMAnON

-4

Revolvis Consulting, Inc.7185 Navajo Road, Suite PSan Diego, CA 92119

Bill To:

Paige Kreegel for Congress

InvoiceDate

08/22/12

Invoice No.

R12-08-107

305.39Description

VOIP Minutes Used: July - August 15- 8,725.3 minutes used @ $.035 per minute

Please include the invoice number on your check. Tha

Amount

Total $305.39

InvoiceRevolvis Consulting, Inc.7185 Navajo Road, Suite PSan Diego, CA 92119

Data

08/13/12

Invoice No.

R12-08-058

BmTo~


Ðe$cription Amount PK08 "Illegal Immigration" Design Only 825.00

c

Please include the invoice number on your check. Thank you. Total' $ßZ!.)\Oô


Date

08/07/12

Invoice No.

R12-08-050

Siiitø,Paige Kreegel for Congress

.

pescription . Amount August 4, 2012 TeleForum: 3,480.60- 49,405 Dials

- 608 Inbound Minutes

Please include the invoice number on your check. Thank you. itötal' $3,4.80.00


Date

08/07/12

Invoice N\).

R12-08-049

Bill To:


D~scri!Jtion Amount

PK10 "Jllegals" (ihcludes printing and design) 7,976.07Quantity: 52,010

Postage = $12,076.61

Total cost of piece = $20,052.68

Please include the invoice number on your check. Thank you. Total $1;916,(1),1


Date

08/07/12

Invoice No.

R12-08-048

Bill To:


.- l)èsgi;jptron f\,mmmt

PK09 "Debt Clock" (includes printing and design) 8,291.29Quantity: 55,000

Postage = $12,076.61 PAID DIRECTLY TO MAIL HOUSE


Please include the invoice number on your check. Thank you. Total $$.,291.29


Date

08/01/12

Invoice No.

R12-08-010

Bill To:


Description . Artiount Consulting Fee - August 2,500.00

Please include the invoice number on your check. Thank you. votal $2,500.00


Date

08/22/12

Invoice No.

R12-08-113

Billra:


Description Amount

FL CD 19 Polling: July 23, July 24, July 26 1,148.99FL CD 19 Polling: July 30, July 31, Aug, 1 and Aug 2 1,530.64FL CD 19 Pollíng: Aug 6, Aug 7 and Aug 8 1,217.65

Please include the invoice number on your check. Thank you. ..1tòtal' . $Ør,ä91.2g~d .,','"'

InvoiceRevolvis Consulting, Inc.7185 Navajo Road, Suite PSan Diego, CA 92119 12/13/12

Ihvoice NO.

R12-12-015


Television and Radio Production Services Provided by Magma Creative Pnmary Election2012- Project: 1 x :60 WEB AD campaign piece-Project: 1 x :30 lV campaign piece- Project: 1 x :30 lV Kreegel Spot 2 "Experienced Leader"- Project: 1 x :30 lV Kreegel Spot 3 "Send a Grown Up to Washington"- Project: 1 x :30 Kreegel Radio campaign piece; utilizing stock & editing audio

5,955.00

7,974.007,405.001,555.002,098.00

***DUE UPON RECEIPT***

Please include the invoice number on your check. Thank you.

Certified Article Number

FOWLEReAttorney,arL.1v "\Vr' ITE BOGGSESTI943 wH

SENDERS RECORD7196 9008 9111 3099 0799

November 30, 2012

CERTIFIED MAiV'RETURN RECEIPT REQUESTED

Paige V. Kteege1, M.D. d/b/aKreegel for Congress3821 B Tamiami Traìl, No. 321Port Charlotte, FL 33952

Re: IO-Day Demand Letter for Collection of Unpaid InvoicesCreditor: Revolvis Consulting, Inc.Debtor: Paige V. Kreegel, M.D. d/b/a Kreegel for Congress

To whom it may concern:

Please be advised that this firm represents your creditor, REVOL vis

CONSULTING, INC. ("REVOLVIS"), with respect to its business transactions with

you, Paige V. Kreege1 d/b/a Kreegel for Congress (the IiDebtor") and the collection of

the unpaid invoices (collectively, the "Invoices" and attached hereto as Exhibit "A")

that were billed to an account (the" Account") issued to the Debtor.

The amount due on the Account has not been paid despite repeated requests. As

of the date of this letter, the open balance for the lnvoices is $24,775.63. It has come to

my attention that you have not denied the above-stated amount that is due and owning,

but rather requested my client settle for less by accepting the remaining funds left in the

account for the campaign (as stated in the correspondence attached hereto as Exhibit

liB").

FOWLER WHITE BoGGS P.A.TAMP A . FOR T Jvf Y £ Il S . TAL L A HAS S .E E . J A C lOON V i L L E . F OR T LA U D E R D A L .£

2235 FIRST STREET. FORT MYERS, FL 3390 I . P. O. Box t 567 . f:ORT MYERS, FL 33902TELEPHONE (139) 334-7B92 . FAX (239) 334.3240 . www.fowlerwhite.com

REVOL vis CONSUL TINC, INC.Page 2

PLEASE BE ADVISED that demand is hereby made for payment in full of said

amount. If the outstanding balance is not paid within TEN (10) days of receipt of this

letter, I will have no altemative but to initiate appropriate actions to collect funds due

and owing.

If you agree to resolve the matter, remit the amount due of $24,775.63 in certified

funds payable to Fowler White Boggs P.A. Trust Account. Upon receipt and clearance,

a release will be provided. In the event I do not timely receive payment, my client has

instructed me to seek any and all remedies available to it at law and equity to collect the

outstanding balance on the Account.

PLEASE GOVERN YOURSELVES ACCORDINGLY.

Yours trulyi

Fowler White Boggs P.A.

~vl!$L ~

Corris L. McIntosh, Jr., Esq.

CLMJ/chEnclosures as statedcc: Regular Mail/Client/2081 Sandy Pines Dr., Pwita Gorda, FL 33982

45085583

FOWLER WliiTE BOGGS P.A.TAMPA. FORT MYERS. TALLAHASSEE. JACKSONVILLE. FORT LAUDERDALE


!Date InyoieeNID',

R12-08-10708/22/12

,BiUTC?,


;1J~~~i~~jeJtt Amount VOIP Minutes Used: July - August 15 305.39- 8,725.3 minutes used @ $.035 per minute

... EXHIBIT ,..... ._-. Please include the invoice number on your check. .~, ~ fQtt¡i~ $'3t1.11!~3$~ - _.. .. --...¡g

~

~


Date

08/13/12

Invoice No.

R12-08-058

¡6m"1fiøi


'~~S~~P11~ia Amø(,l!\it PK08 KlIlagal Immigration" Design Only 825.00

-

~-,-" -' --";-'. .

Please include the invoice number on your check. Thank you. ~ . ",'t .":1f:.Qf!tW--: *tl~~ø.(¡1;_.._"c.,'_..."'.d'- . .". ~ --


Qat~08/07112

Invoice Ní1l.

R12-08-050

. ....'lBilVt:r¡lf .,; ..... . . ..Paige Kreegel for Congress

" .' .-

,@~ø,lji~1i;~lit i -Ärn(i)lJimt -- ., -, .. --,' ...:.. ....... .." August 4, 2012 TeleForum: 3,480.60- 49,405 Dials

- 608 Inbound Minutes

Please include the invoice number on your check. Thank you. ., n;:'Qtt;lß $$,.4aø',øt)f,..... -.


Date

08/07/12

;lnvoiCe Nø........ -. ..R12-08-049

:l!liJnfl~. ,


,.. '. Amount

êroe~l!i@tj(¡)h , .

PK10 "I!legals" (includes pnnting and design) 7,976.07Quantity: 52,010

Postage ~ $12,076.61


Please include the invoice number on your check. Thank you. i;itrif .$!1',9;7:@,Ø;1'..'


Datè

08/07112

ItwôiceNo.

R12-08-048

if3i11lat ..


;f!l~iile;;ilj~'lfØP_ Arrioi,mt -. ~ .

PK09 "Debt Clock" (includes printing and design) 8,291.29Quantity: 55,000

Postage = $12,076.61 PAID DIRECTL Y TO MAIL HOUSE


Please include the invoice number on your check. Thank you. tøt~i: '$lil.~29'~;~$f--,.


Date

08/01/12

ItivoiGe NÐ.

R12-08-010

;IBIII '1fGJl


-. DèSSIìi~üø¡¡¡,. Ameant. ~ .". _ ~,r .-"~",.':\ ".:-:.~-..- . '... Consulting Fee - August 2,500.00

Please include the invoice number on your check. Thank you. 11'ørat $-2,ØØOJilO.. - --


Date

08/22/12

Invoioe No.

R12-08-113

:am\illÖi: "~,'i';. .,.'. .,i~:---:" ,. ."


.' " llir:tlØiJin~

;1rl~e~Jll¡qm' " .' ., .. FLCD 19 Polling: July 23, July 24, July 26 1,148.99FLCD 19 Polling: July 30, July 31, Aug, 1 and Aug 2 1,530.64FLeD 19 Polling: Aug 6, Aug? and Aug 8 1,217.65

". ,....'. "-,,.

Please include the invoice number on your check. Thank you. i:'~:Cf. , ., ;$~~~7c;\~'$'. Altãtäli~:. ' - ...:.", ;'-:'. -.,. ".... '-~,."".-.' . .:-".

~han H. Andranian. Esq.

From:Sent:To:Subject:

Jason (abel Roe ..:[email protected]:::.Thursday, September 06, 20124:41 PMAndranian StephanFwd: Kreegel Aging as of 8/30

Jason Cabel Roe I Revolvis Consulting(800) 916-1770 I www.revolvis.com

Begin forwarded message:

From: Valerie Ashurst Dichiara -=:::[email protected]~Subject: Fwd: Kreegel Aging as of 8/30Date: September 5,20125:13:16 PM PDTTo: jroe Roe -=:::jroe@ iroe.org~

Valerie Ashurst Dichiara I Revolvis Consulting I PartnerSacramento l San Diego I Seattle I Washington, DCC: 916-997-5029 I E: [email protected] I W: www.revolvis.com

Begin forwarded message:

From: Paige Kreegel c::::[email protected]:::o-Subject: Fw: Re: Kreegel Aging as of 8/30Date: September 5,20125:10:23 PM PDTTo: [email protected], DarolCarr c::::[email protected]~Cc: [email protected]

Valerie,

This seems to be a good time to address this issue, as there are vastly more invoices "generated" by Revolvisand their associated media companies than there is cash in the campaign account to pay for them.

There is about seven-thousand and change in the account.

While I fully expect Jason to have some different point of view, at the end of the day, the only question to me is,how would you like to have that amount dispensed? EXHIBIT

,,\ R,H'-.J .1 ¡

~w

The usual matter of releases, etc. would need to be addressed.

I have forwarded a copy of this to my attorney Darol Carr ([email protected]) and a copy to Vickie as welL.

Paige

--- On Wed, 9/5/12, Michael & Vickie Potts [email protected]~ wrote:

From: Michael & Vickie Potts [email protected]~Subject: Re: Kreege1 Aging as of 8/30To: "Valerie Ashurst Dichiara" [email protected]/Cc: "Kreegel" [email protected]?Date: Wednesday, September 5, 2012, 10:53 PM

Valarie;I forwarded your request to Paige Kreege1

----- Original Message -----From: Valerie Ashurst Dichiara [email protected]/To: Vickie Potts [email protected]~Cc: Matt Dobler [email protected]:::=--, jroe Roe [email protected]:::=--Sent: Wed, 05 Sep 2012 15:34:50 -0400 (EDT)Subject: Re: Kreegel Aging as of 8130

Hi Vickie,Can you give me a status update on payment?

Thank you,

Valerie Ashurst Dichiara I Revolvis Consulting I PartnerSacramento I San Diego I Seattle I Washington, DCc: 916-997-5029 I E: [email protected] I W: www.revolvis.com

On Aug 30,2012, at 3:03 PM, Valerie Ashurst Dichiara wrote:

Hi Vickie,Attached is the aging report for Kreege1. Please give me a status update on payment. Ifyou need any of the invoices resent please let me know.

Thank you,

-cKreege1 Aging as of 8:30.xIsx/

Valerie Ashurst Dichiara I Revolvis Consulting I PartnerSacramento I San Diego I Seattle I Washington, DCC; 916-997-5029 I E: valerie@revolvís.com I W: www.revolvís.com

2

-- Vickie Potts(cell) [email protected]

3

" 111111 III/ ""11111'" Ic. Signaturex~,-D. I. delivery address different from ¡Iem 1?

li VES, enler delivery address below:

DAgentDAddresseeDVesDND

7196 9D08 9111 3099 D799lt3"

¡ ~:Service Type CERTIFIED MAILTM

i~,i:ieslr¡cted Delivery? (Extra Fee)1. Article Addressed to:

DYes

Reference InformationPaige V. Kreegel, M.D. d/b/aKreegel for Congress3821 B Tamiami Trail, No. 32 iPort Charlotte, FL 33952

7120237

Carris L. McIntosh, Jr.

PS Form 3811, January 2005 Domestic Return Receipt

Certified Article NiiinberFOWLER_A"o,",~~'i~\; WHITE BOGGS

7196 9008 9L11 3099 0829SENDERS RECORD December 17, 2012

CERTIFIED MAIL/RETURN RECEIPT REQUESTED 71969008911130990829

Paige V. Kreegel, M.D. d/b/aKreegel far Congressc/a Daral H.M. Carr, Esq.99 Nesbit StreetPunta Gorda, FL 33950

Re: 10-Day Demand Letter for Collection of Unpaid Invoices

Dear Mr. Carr,

Please be advised that this firm represents REVOL vis CONSULTING, INC.

("REVOL ViS"), with respect to its business transactions with your client, Paige V.

Kreegel d/b/a Kreege1 for Congress ("Kreegel") and the collection of the unpaid

invoice (the "Invoice"; attached hereto as Exhibit II A") that was billed to an account (the

"Account") issued to Kreegel.

The Invoice amount has not been paid despite repeated requests. As of the date

of this letter, the open balance for the Invoice is $24,987.00. This amount is in addition

to the unpaid balance stated in my letter to Kreegel dated November 30, 2012.

PLEASE BE ADVISED that demand is hereby made for payment in full of said

amount. If the outstanding balance is not paid within TEN (10) days of receipt of this

letter, I will have no alternative but to initiate appropriate actions to collect funds due

and owing.

FOWLER WHITE BOGGS P.A.TAMPA. FORT MYERS. TALLAHASSEE. JACKSONVILLE. FORT LAUDERDALE

2235 FIRST STREET. FORT MYERS. FL 33901. P.O. Box 1567. FORT MYERS, FL 33901TELEPHONE (239) 334,7892 . FAX (239) 334.3240 . www.fowlerwhite.com

REVOL vis CONSULTING, INC.Page 2

If you agree to resolve the matter, remit the amount due of $24,987.00 in certified

funds payable to Fowler White Boggs P.A. Trust Account. Upon receipt and clearance,

a release will be provided. In the event I do not timely receive payment, my client has

instructed me to seek any and all remedies available to it at law and equity to collect the

outstanding balance on the Account.

PLEASE GOVERN YOURSEL VES ACCORDINGLY.

Yours truly,

Fowler White Boggs P.A.

~rCorris L. McIntosh, Jr., Esq.

CLMJ/chEnclosures as statedcc: Regular Mail/Client

45116499

FOWLER WHITE BOGGS P.A.TAMPA. FORT MYERS' TALLAHASSEE' JACKSONVILLE. FORT LAUDERDALE

Revolvis Consulting, Inc.7185 Navajo Road, Suite PSan Diego, CA 92119

InvoiceDate

12/13/12Invoice No.

R12-12-015

Bill To:


Description

Television and Radio Production Services Provided by Magma Creative Pnmaiy Election2012- Project: 1 x :60 WEB AD campaign piece-Project: 1 x :30 TV campaign piece- Project: 1 x :30 TV Kreegel Spot 2 "Experienced Leader"- Project: 1 x :30 TV Kreegel Spot 3 "Send a Grown Up to Washington"

- Project: 1 x :30 Kreegel Radio campaign piece; utilizing stock & editing audio

Amount

5,955.00

7,974.007,405.001,555.002,098.00

"""DUE UPON RECEIPT......

i eXHIBIT

"A."~~

Please include the invoice number on your check. Thank you. Total$24,987.00 I

Documents

Lawsuit filed by Jason Roe against Paige Kreegel