Filing # 144996718 E-Filed 03/03/2022 01:03:14 PM

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT

IN AND FOR PINELLAS COUNTY, FLORIDA

MARK P. STOPA,
Plaintiff
CASE NO: 2019-CA-8558-CI
v.

MFI-MIAMI HOLDINGS, LLC and

STEPHEN J. DIBERT,
Defendants.
______________________________/

NOTICE OF FILING EMAIL FROM ABUSIVE PLAINTIFF & NOTICE THAT ALL
FUTURE TELEPHONE CALLS TO UNDERSIGNED COUNSEL WILL BE RECORDED

COMES NOW, Defendants, MFI-MIAMI HOLDINGS, LLC., and STEPHEN J.

DIBERT, by and through undersigned counsel and files with this Notice a series of

emails from abusive Plaintiff, MARK P. STOPA.

This correspondence is being filed with the court to advise the judiciary regarding the

unprofessional conduct and abuse heaped upon undersigned counsel during a

telephone call with Plaintiff, Mark P. Stopa, that took place after the telephonic case

management conference on Thursday, March 3, 2022. See attached Exhibit A.

By this Notice, undersigned counsel is advising the Plaintiff and this Honorable

Court, that all future telephone calls received by Plaintiff, Mark P. Stopa, will be

recorded by her office for use in this case and by calling counsel, Plaintiff, Mark

Stopa has been placed on notice that all telephone calls are being recorded to

ensure no additional abuse occurs. Alternatively, she will accept emails for future

correspondence to prevent any further abuse from occurring.

Undersigned counsel further requests that Plaintiff, Mark P. Stopa, place the correct

email into his certificate of service to ensure that counsel is receiving court filed

***ELECTRONICALLY FILED 03/03/2022 01:03:14 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
documents. For reference, the correct email addresses to be used are contained in the

court-filed notice of appearance and designation of email and are

stevinslawfim@gmail.com and vickistevins@gmail.com

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been

electronically filed via the E-portal and served via email to this

3rd day of March 2022.

e-mail: stevinslawfirm@gmail.com
Co-counsel for Jeffrey Feld
2681 Airport Road South, Suite C-104
Naples, Florida 34112
Phone (239) 300-4417
Fax (239) 304-8424
3/3/22,12:40 PM Gmail -
Stopa v. MFI Miami - improper tenor and tone of conversation after court today

Hl Gmail Samantha Stevins <stevinslawfirm@gmail.com>

Stopa v. MFI Miami - improper tenor and tone of conversation after court today
4 messages

Samantha Stevins <stevinslawfirm@gmail.com> Thu, Mar 3, 2022 at 11:55 AM

To: Mark Stopa <markpstopa@gmail.com>

Dear Mr. Stopa -

Please allow this email to serve as notice to you that I will not tolerate being yelled at, berated or talked down to on
the phone by you.

During our conversation today after court, I advised you on no less than 4 separate occasions, that I will not remain on
the phone with you if you continue being loud, obnoxious, and verbally abusive. I hung up on you, after warning, because
you were conducting yourself in a manner unbecoming a person.

Ialso repeatedly told you that the email I was referring to is located in the court file. Sir, I am not answerable to you,
although as a fully licensed attorney, I will do my best to maintain patience with you.
I realize that you are representing yourself in this matter, so that your passions may be inflamed. I, however, have no
pony in your fight with Mr. Dibert or MFI Miami.
I told you the motion and documents that you seek are contained in the court file.with the motion to set aside. Not sure
what more you want me to tell you.

Because of your unprofessional, rude, attacking, verbally abusive and condescending tone, I will not speak with you by
phone on this matter.
From this point forward, you will need to send me any requests you have in writing by email.

Govern yourself accordingly.

2681 Airport Road South, UnitC-104

Naples, Florida 34112
Phone (239) 300-4417
E-mail: StevinsLawFirm@gmail.com

All electronic mail messages and attachments sent to or from the Firm may contain confidential information belonging to
the sender which is protected by the attorney-client privilege. This information is intended only for the use of the individual
or entity in the electronic communication. If you are not the intended recipient, you are hereby notified that any disclosure,
copying, distribution (electronic or otherwise), forwarding or the taking of any action in reliance on the contents of this
information is strictly prohibited. If you have received any electronic transmission in error, please immediately notify us by
telephone, facsimile, or email to stevinslawfirm@gmail.com to arrange for return of the electronic email, attachments, or
documents.

Mark Stopa <markpstopa@gmail.com> Thu, Mar 3, 2022 at 12:02 PM

To:Samantha Stevins <stevinslawfirm@gmail.com>

Do not lie in an effort to misrepresent the record, Ms. Stevens.

I called you with a simple request: to show me where the alleged email is that purports to be a "paper" prior to entry of
the default.
Even now, you have yet to answer the question.

Instead, you went on a rampage against me by phone, continuing to talk about how you have a law license and I do not,
and you now misrepresent the nature of our conversation by email.

https://mail.google.com/mail/u/0/?ik=3ddf51dc02&view=pt&search=all&permthid=thread-a%3Ar2395153462120076032&simpl=msg-a%3Ar167394297... 1/2
3/3/22, 12:40 PM Gmail - Stopa v. MFI Miami - improper tenor and tone of conversation after court today

You also accused me of being aggressive.

Let's be clear. Without even appearing as counsel in this case, you threatened me with sanctions.
You then filed a 57.105, sham pleading motion, and vexatious litigant motion.

It's clear to me that you did this in an effort to intimidate me into dropping the case.
Your effort failed.
Regardless, you are in no position to complain about me trying to prosecute a case in a normal way when you acted like
you have from the outset.

I again invite you to make specific mention of the email. Failing that, I stand behind the email that I sent you this
morning.

Good day.
Mark
[Quoted text hidden]

Samantha Stevins <stevinslawfirm@gmail.com> Thu, Mar 3, 2022 at 12:06 PM

To: Mark Stopa <markpstopa@gmail.com>

Mr. Stopa -

You can't even spell my name right. Your behavior and attitude stink. I'm filing appropriate paperwork on behalf of my
client that will need to be addressed by the court. These matters will be addressed by the judge.

Have a great day!

[Quoted text hidden]

Mark Stopa <markpstopa@gmail.com> Thu, Mar 3, 2022 at 12:10 PM

To: Samantha Stevins <stevinslawfirm@gmail.com>

My behavior and attitude have been fine.

Your client has been unhinged in every single interaction ... not to mention the offensive posts on his website.

I suggest you direct these responses to your client.

[Quoted text hidden]

https://mail.google.com/mail/u/0/?ik=3ddf51dc02&view=pt&search=all&permthid=thread-a%3Ar2395153462120076032&simpl=msg-a%3Ar167394297… 2/2