July 26, 2020

Joshua E. Doyle
Executive Director APPENDIX B
The Florida Bar
651 E Jefferson St
Tallahassee, FL 32399-6584
Office: 850-561-5600

RE: Complaint Timothy Thomas McCourt, Bar Number: 44604

Mr. Doyle:

Mr. McCourt is the general counsel to the Marion County Sheriff’s Office (MCSO).

On or about January 31, 2013 - over seven years ago - an attorney named Danielle Parsons of
McCalla Raymer, claimed that I threatened her. The incident was investigated and closed, no
threat was made, see Exhibit 1, report #13003249 on February 2, 2013 by Michael Jablonski.
On information and belief, Ms. Parsons was terminated from McCalla Raymer for misconduct.

This complaint alleges that Mr. McCourt, or someone at his direction, included the following
words in two Incident Detail Reports on Jun-07-2020:

SUBJECT HAS ALSO MADE THREATS TO AN ATTORNEY IN 2013

See, Incident Detail Report 2006070064 Jun-07-2020 @ 3.46 AM (6-17)

See, Incident Detail Report 2006070101 Jun-07-2020 @ 6.58 AM (6-17)

Mr. McCourt did this to prejudice me in the reports and the incident, which resulted in my
wrongful arrest on June 13, 2020. Mr. McCourt violated the Rules of Professional Conduct,
including Rule 4-8.4 MISCONDUCT, see enclosed.

Rule 4-8.4 MISCONDUCT

A lawyer shall not:

(a) violate or attempt to violate the Rules of Professional Conduct, knowingly assist or
induce another to do so, or do so through the acts of another;

(b) commit a criminal act that reflects adversely on the lawyer’s honesty, trustworthiness,
or fitness as a lawyer in other respects;

(c) engage in conduct involving dishonesty, fraud, deceit, or misrepresentation, except

that it shall not be professional misconduct for a lawyer for a criminal law enforcement
agency or regulatory agency to advise others about or to supervise another in an
undercover investigation, unless prohibited by law or rule, and it shall not be professional
misconduct for a lawyer employed in a capacity other than as a lawyer by a criminal law
RE: Complaint Timothy Thomas McCourt, Bar Number: 44604

misconduct for a lawyer employed in a capacity other than as a lawyer by a criminal law
enforcement agency or regulatory agency to participate in an undercover investigation,
unless prohibited by law or rule;

(d) engage in conduct in connection with the practice of law that is prejudicial to the
administration ofjustice, including to knowingly, or through callous indifference,
disparage, humiliate, or discriminate against litigants, jurors, witnesses, court personnel,
or other lawyers on any basis, including, but not limited to, on account of race, ethnicity,
gender, religion, national origin, disability, marital status, sexual orientation, age,
socioeconomic status, employment, or physical characteristic;

Under penalties of perjury, I declare that the foregoing facts are true, correct and complete.

Thank you.

Sincerely,

eil J. lespie
8092 SW 115th Loop
Ocala, Florida 34481
Telephone: 352-854-7807
Email: neilgillespie@mfi.net

Enclosures
 The Florida Bar
Inquiry/Complaint Form
PART ONE (See Page 1, PART ONE – Complainant Information.):

Neil J. Gillespie
Your Name: _________________________________________________________________________
Justice Network
Organization: ________________________________________________________________________
8092 SW 115th Loop
Address: ____________________________________________________________________________
Ocala, Florida 34481
City, State, Zip Code: __________________________________________________________________
352-854-7807
Telephone: ________________________________ __________________________________________
neilgillespie@mfi.net
E-mail: ________________________________ _____________________________________________
none
ACAP Reference No.: _________________________________________________________________
Does this complaint pertain to a matter currently in litigation? Yes ______ No ______

PART TWO (See Page 1, PART TWO – Attorney Information.):

Attorney’s Name: Timothy Thomas McCourt

__________________________________________ 44604
 
 
Marion County Sheriff's Office
Address: ____________________________________________________________________________
Ocala, FL 34475-6638
City, State, Zip Code: __________________________________________________________________
352-369-6758
Telephone: __________________________________________________________________________

PART THREE (See Page 1, PART THREE – Facts/Allegations.): The specific thing or things I
am complaining about are: (attach additional sheets as necessary)

See attached sheet. This complaint alleges misconduct by the attorney named above for violation of the
RRTFB Chapter 4 Rules of Professional Conduct, and therefore should be disciplined. Art V, sec 15, Fla.
Const., Attorneys; admission and discipline.—The supreme court shall have exclusive jurisdiction to
regulate the admission of persons to the practice of law and the discipline of persons admitted.

My complaint does not ask anyone to intervene in any court case, or take action in any case.
My complaint does not ask anyone to act as the state attorney, or the attorney general.
My complaint does not ask anyone to investigate/discipline judges, or act as the JQC.
My complaint does not ask anyone to address any legal issues; only misconduct (ethics).

Rule 3-4.3, Misconduct and Minor Misconduct states:

The standards of professional conduct to be observed by members of the bar are not
limited to the observance of rules and avoidance of prohibited acts, and the enumeration
herein of certain categories of misconduct as constituting grounds for discipline shall not
be deemed to be all-inclusive nor shall the failure to specify any particular act of
misconduct be construed as tolerance thereof. The commission by a lawyer of any act
that is unlawful or contrary to honesty and justice, whether the act is committed in the
course of the attorney's relations as an attorney or otherwise, whether committed within
or outside the state of Florida, and whether or not the act is a felony or misdemeanor,
may constitute a cause for discipline.
PART FOUR (See Page 1, PART FOUR - Witnesses.): The witnesses in support of my
allegations are: (see attached sheet].

PART FIVE (See Page 1, PART FIVE - Signature.): Under penalties of perjury, I declare that
the foregoing facts are true, correct and complete.

Neil J. Gillespie
 Incident Report

MARION COUNTY SHERIFF'S OFFICE

1
Report Date / Time Report Number Report Case/CAD Number Reporting Officer Rank / ID Reporting Officer Name
2/1/2013 3:22:00 PM 13003249 (03) 13003249 / JABLONSKI, MICHAEL
1302010629
Originating Agency ORI Reported to Agency Date Occur Date Range Jurisdiction Status: CLOSED
2/1/2013 3:22:00 PM 01/31/2013 12:30:00 - Clearance:

Offense Description
3311

LOCATION(S)
County Location Type Location Description
INCIDENT LOCATION LOCATION
Street Number Street Apt/Lot/Bldg City State Zip Code Phone Number Ext.
8092 SW 115TH LOOP OCALA 34481

Person: REPORTING PERSON

First Name Middle Name Last Name Suffix Race Sex Height Weight Hair Eyes
CLERKS UNKNO UNKNO
COUNTY MARION
OFFICE WN WN
MNI # SSN Date of Birth Age Place of Birth Drivers License or other ID State ID Type
0 ,,
Addresses
• /0/

Person: SUBJECT
First Name Middle Name Last Name Suffix Race Sex Height Weight Hair Eyes
NEIL JOSEPH GILLESPIE WHITE MALE
MNI # SSN Date of Birth Age Place of Birth Drivers License or other ID State ID Type
MCSO98MNI017488 03/19/1956 56 ,,
Addresses
• / 8092 SW 115TH LOOP, OCALA, FL 34481 /

Person: SUBJECT
First Name Middle Name Last Name Suffix Race Sex Height Weight Hair Eyes
DANIELLE N PARSONS WHITE FEMALE
MNI # SSN Date of Birth Age Place of Birth Drivers License or other ID State ID Type
MCSO13MNI007820 08/27/1980 32 ,,
Comments: ATTORNEY FOR MCCALLA RAYMER
Addresses
• / 225 E ROBINSON ST SUITE 660, ORLANDO, FL 32801 /

Person: INVESTIGATOR / OFFICER

First Name Middle Name Last Name Suffix Race Sex Height Weight Hair Eyes
JOE H WRIGHT JR BLACK MALE

Incident Report Page 1 of 6

Report Date / Time Report Number Report Case/CAD Number Reporting Officer Rank / ID Reporting Officer Name
2/1/2013 3:22:00 PM 13003249 (03) 13003249 / JABLONSKI, MICHAEL
1302010629
Originating Agency ORI Reported to Agency Date Occur Date Range Jurisdiction Status: CLOSED
2/1/2013 3:22:00 PM 01/31/2013 12:30:00 - Clearance:

Offense Description
3311

MNI # SSN Date of Birth Age Place of Birth Drivers License or other ID State ID Type
0 ,,
Comments: LIEUTENTANT, ID 279
Addresses
• /0/

Charge
Counts Charge Arrest Offense Code Description
1 3311
Charge Degree Charge Level General Offense Code
COMMITTED
Charge Description
INFORMATION

Narrative: SUPPLEMENT
Narrative Date/Time Narrative Synopsis
2/1/2013 12:00:00 AM
Reporting Officer Officer Rank Officer ID No Officer Org/Unit
RAWLS IV, JOHN
Officer Signature Officer Agency
MCSO
FOLLOW UP

ON 020113 AT APPROXIMATELY 1740 HOURS, WRITER WENT TO THE RESIDENCE OF

SUBJECT NEIL GILLESPIE TO SPEAK WITH HIM REGARDING THIS INCIDENT. WRITER
RECEIVED NO ANSWER AT THE DOOR. THERE WERE NO LIGHTS ON IN SIDE OF THE
RESIDENCE AND THERE DID NOT APPEAR TO BE ANYONE AT HOME. WRITER WILL MAKE
ADDITIONAL ATTEMPTS THROUGHOUT THE REMAINING TOUR OF DUTY TO CONTACT
SUBJECT GILLESPIE.

CASE REMAINS PENDING ACTIVE.

TIME: 1856-1859//5340//ABS
Narrative: 3311
Narrative Date/Time Narrative Synopsis
PRELIMINARY INVESTIGATION REVEALED THAT ON THE ABOVE DATE AND
2/1/2013 3:22:00 PM
TIME, A INFORMATION REPORT WAS GENERAT
Reporting Officer Officer Rank Officer ID No Officer Org/Unit
JABLONSKI, MICHAEL

Incident Report Page 2 of 6

Report Date / Time Report Number Report Case/CAD Number Reporting Officer Rank / ID Reporting Officer Name
2/1/2013 3:22:00 PM 13003249 (03) 13003249 / JABLONSKI, MICHAEL
1302010629
Originating Agency ORI Reported to Agency Date Occur Date Range Jurisdiction Status: CLOSED
2/1/2013 3:22:00 PM 01/31/2013 12:30:00 - Clearance:

Offense Description
3311

Officer Signature Officer Agency

MCSO
ON 020113, WRITER WAS CONTACTED BY LIEUTENANT WRIGHT, ID 279, AND ADVISED TO
MAKE A REPORT IN REGARDS TO AN EMAIL RECEIVED BY THE REPORTEE, AT THE MARION
COUNTY CLERKS OFFICE. LIEUTENANT WRIGHT ADVISED THAT THE EMAIL MIGHT POSSIBLY
HAVE SOME THREATENING CONTENT TO IT AND PROVIDED WRITER WITH A COPY OF THREE
EMAILS.

WRITER THEN READ OVER THE FIRST EMAIL WHICH HAD BEEN SENT TO THE REPORTEE BY
SUBJECT NEIL GILLESPIE STATING THAT ATTORNEY DANIELLE PARSONS FAILED TO
PROVIDE HIM WITH A SERVICE LIST THAT SHOULD HAVE BEEN FILED WITH A NOTICE OF LIS
PENDENS. THE SUBJECT FURTHER STATED THAT HE ATTEMPTED TO CONTACT MS.
PARSONS BUT WAS UNABLE TO SPEAK WITH HER AND THAT HE LEFT A VOICE MAIL BUT HE
DID NOT EXPECT FOR HER TO CONTACT HIM IN A TIMELY MANNER ADVISING THAT THIS WAS
DUE TO HER PAST UNPROFESSIONAL CONDUCT. THE SUBJECT CONTINUED TO STATE THAT
MS. PARSONS HAD BEEN UNPROFESSIONAL AND THAT SHE WAS A DISCREDIT TO THE
LEGAL PROFESSION AND AT ONE POINT IN THE EMAIL, PROVIDED A LINK TO THE AMERICAN
BAR ASSOCIATION JOURNAL THAT HAD REPORTED AN ATTORNEY AND CLIENT BEING SHOT
AFTER A MEDIATION. THE SUBJECT THEN ADVISED THAT IN HIS EXPERIENCE EVERY PRO SE
LITIGANT HE HAD EVER SPOKEN WITH, OPPOSING COUNCIL SHOWED DISREGARD TOWARDS
THAT LITIGANT. THE SUBJECT CONTINUED TO STATE THAT THE SHOOTING WAS BOTH
UNLAWFUL, INAPPROPRIATE AND THAT VIOLENCE IS NEVER JUSTIFIED IN CIVILIZED
SOCIETY. THE SUBJECT THEN CONTINUES TO ASK WHAT HER SUGGESTION WOULD BE IN
DEALING WITH AN UNPROFESSIONAL ATTORNEY LIKE MS. PARSONS AND WHAT CAN THE
COURT DO IN RESPONSE
TO ATTORNEY MISCONDUCT TOWARD PRO SE LITIGANTS. THE SUBJECT THEN ADVISED HE
HOPED TO HEAR FROM HER SOON ABOUT THE SERVICE LIST THAT HAD NOT BEEN
PROVIDED TO HIM.

WRITER THEN WAS PROVIDED ANOTHER EMAIL WHICH WAS A RESPONSE TO MR. GILLESPIE
FROM MS. PARSONS ADVISING THAT THE CERTIFICATE OF SERVICE THAT HAD PREVIOUSLY
BEEN MENTIONED WAS A CLERICAL ERROR AND IS USUALLY USED FOR AMENDED
COMPLAINTS AND SHE APOLOGIZED FOR THE CONFUSION. SHE LATER ASKED IN THE EMAIL
THAT MR. GILLESPIE NOT THREATEN HER WITH ARTICLES SUCH AS THE ONE REFERENCED
IN THE PRIOR EMAIL.

WRITER THEN READ ANOTHER EMAIL IN RESPONSE FROM MR. GILLESPIE TO MS. PARSONS
ADVISING HER THAT HE HAD NOT THREATENED HER WITH THE ARTICLE AND THAT HE WAS
DISGUSTED THAT SHE MAKE THAT COMMENT. IT WAS ALSO STATED BY MR. GILLESPIE IN
THE EMAIL THAT IF SHE DID NOT LIKE STORIES PUBLISHED BY THE AMERICAN BAR
Incident Report Page 3 of 6
Report Date / Time Report Number Report Case/CAD Number Reporting Officer Rank / ID Reporting Officer Name
2/1/2013 3:22:00 PM 13003249 (03) 13003249 / JABLONSKI, MICHAEL
1302010629
Originating Agency ORI Reported to Agency Date Occur Date Range Jurisdiction Status: CLOSED
2/1/2013 3:22:00 PM 01/31/2013 12:30:00 - Clearance:

Offense Description
3311

ASSOCIATION, THAT SHE COULD KINDLY DIRECT HER IRE TOWARDS THEM.

WRITER WAS ADVISED BY THE MARION COUNTY CLERK'S OFFICE THEY WERE NOT CERTAIN
WHY THEY WERE RECEIVING CORRESPONDENCE BETWEEN MR. GILLESPIE AND MRS
PARSONS BUT WISHED TO MAKE THE SHERIFF'S OFFICE AWARE OF IT.
]
WRITER, AFTER READING THESE EMAILS, DID NOT FIND ANY DIRECT THREAT OF VIOLENCE
TOWARDS MS. PARSONS.

WRITER MADE CONTACT WITH ATTORNEY DANIELLE PARSONS, WHO ADVISED THAT MR.
GILLESPIE IS AN ANGRY PERSON AND THAT SHE IS AFRAID TO BE IN COURT WITH HIM, IF
SHE SHOULD HAVE TO RESPOND TO THE MARION COUNTY COURTHOUSE BUT SHE
REALIZED THAT THERE WAS NO ACTUAL THREATS MADE IN THE EMAIL TOWARDS HER BY
MR. GILLESPIE. WRITER ADVISED MS. PARSONS THAT AN INFORMATION REPORT WOULD BE
GENERATED DOCUMENTING THIS INCIDENT AND THAT IF SHE DID HAVE TO RESPOND TO
THE COURTHOUSE IN REGARDS TO MR. GILLESPIE'S LAWSUIT, A BAILIFF WOULD BE
PRESENT FOR HER SAFETY.

WRITER THEN PROVIDED MS. PARSONS WITH AGENCY'S CASE NUMBER AND ADVISED HER
IF SHE RECEIVED ANY THREATENING EMAILS OR CORRESPONDENCE FROM MR. GILLESPIE
TO CONTACT THE MARION COUNTY SHERIFF'S OFFICE. WRITER WAS ADVISED BY
LIEUTENANT WRIGHT TO HAVE THIS INFORMATION FORWARDED TO THE SOUTHWEST
DISTRICT OFFICE. WRITER WILL ATTEMPT TO CONTACT A SOUTHWEST ZONE UNIT DEPUTY
IN REGARDS TO THIS INCIDENT AND ATTEMPT TO MAKE CONTACT WITH MR. GILLESPIE.
WRITER REQUESTS THIS CASE REMAIN PENDING ACTIVE.

CASE PENDING ACTIVE.

TIME: 1627-1712 //BA// 5731

Narrative: SUPPLEMENT
Narrative Date/Time Narrative Synopsis
6/17/2013 12:00:00 AM
Reporting Officer Officer Rank Officer ID No Officer Org/Unit
SPATES, GREGORY
Officer Signature Officer Agency
MCSO

Incident Report Page 4 of 6

Report Date / Time Report Number Report Case/CAD Number Reporting Officer Rank / ID Reporting Officer Name
2/1/2013 3:22:00 PM 13003249 (03) 13003249 / JABLONSKI, MICHAEL
1302010629
Originating Agency ORI Reported to Agency Date Occur Date Range Jurisdiction Status: CLOSED
2/1/2013 3:22:00 PM 01/31/2013 12:30:00 - Clearance:

Offense Description
3311

FOLLOW-UP

ON 06/17/2013 WRITER MADE CONTACT WITH SUBJECT DANIELLE PARSONS BY TELEPHONE.

PARSONS WORKS FOR A LAW FIRM INVOLVED WITH LITIGATION AGAINST SUBJECT NEIL
GILLESPIE.

PARSONS ADVISED THAT THERE HAS NOT BEEN ANY FURTHER EMAILS OF CONCERN
INVOLVING GILLESPIE; HOWEVER, THE COURT CASE IS STILL ONGOING. PARSONS ADVISED
THAT SHE WOULD CONTACT THE COURTHOUSE PRIOR TO ANY HEARINGS WITH GILLESPIE
PRESENT. WRITER REQUESTS THIS CASE TO BE CLOSED BY EXCEPTION.

CASE STATUS: CLOSED BY EXCEPTION

GH499/1334 HRS
Officer: Approving Supervisor (Supplement 03)
Officer Name Officer Rank Officer ID No Officer Agency
CALHOUN, THOMAS MARION COUNTY SHERIFF'S OFFICE
Approval Date / Time Officer Signature
6/17/2013 1:34:24 PM
Officer Name Involvement On Report / Officer Agency
Sup # Rank / ID # Reporting Role Org/Unit
CURTIS, WAYNE MARION COUNTY SHERIFF'S OFFICE
01

HOPKINS, DAVID
02

JABLONSKI, MICHAEL REPORTING OFFICER / MARION COUNTY SHERIFF'S OFFICE

01
REPORTING OFFICER
RAWLS IV, JOHN MARION COUNTY SHERIFF'S OFFICE
02

SPATES, GREGORY
03

CALHOUN, THOMAS MARION COUNTY SHERIFF'S OFFICE

03 APPROVING SUPERVISOR

Incident Report Page 5 of 6

Report Date / Time Report Number Report Case/CAD Number Reporting Officer Rank / ID Reporting Officer Name
2/1/2013 3:22:00 PM 13003249 (03) 13003249 / JABLONSKI, MICHAEL
1302010629
Originating Agency ORI Reported to Agency Date Occur Date Range Jurisdiction Status: CLOSED
2/1/2013 3:22:00 PM 01/31/2013 12:30:00 - Clearance:

Offense Description
3311

The undersigned certifies and swears that he/she has just and reasonable grounds to believe that the above named Defendant,
committed violation(s), of law, on the below date(s) and time(s), as listed in the narratives associated with this report:
Officer: Reporting Officer (Supplement03)
Officer Name Office Rank Officer ID No Sworn and subscribed before me, the undersigned authority
JABLONSKI, MICHAEL This the ______ day of _________________, __________
DEPUTY OF THE COURT, NOTARY OR LAW ENFORCEMENT
Officer Agency
OFFICER
MARION COUNTY SHERIFF'S OFFICE

Officer Signature

Incident Report Page 6 of 6

lawyers assistance program; such an obligation, however, may be imposed by the rules of the
program or other law.

Amended July 23, 1992, effective Jan. 1, 1993 (605 So.2d 252); amended and effective Feb. 8, 2001 (795
So.2d 1); amended March 23, 2006, effective May 22, 2006 (933 So.2d 417); amended April 12, 2012,
effective July 1, 2012 (101 So.3d 807); amended November 9, 2017, effective February 1, 2018 (234 So.3d
632); amended January 4, 2019, effective March 5, 2019 (267 So.3d 891).

RULE 4-8.4 MISCONDUCT

A lawyer shall not:

(a) violate or attempt to violate the Rules of Professional Conduct, knowingly assist or
induce another to do so, or do so through the acts of another;

(b) commit a criminal act that reflects adversely on the lawyer’s honesty, trustworthiness,
or fitness as a lawyer in other respects;

(c) engage in conduct involving dishonesty, fraud, deceit, or misrepresentation, except that
it shall not be professional misconduct for a lawyer for a criminal law enforcement agency or
regulatory agency to advise others about or to supervise another in an undercover investigation,
unless prohibited by law or rule, and it shall not be professional misconduct for a lawyer
employed in a capacity other than as a lawyer by a criminal law enforcement agency or
regulatory agency to participate in an undercover investigation, unless prohibited by law or rule;

(d) engage in conduct in connection with the practice of law that is prejudicial to the
administration of justice, including to knowingly, or through callous indifference, disparage,
humiliate, or discriminate against litigants, jurors, witnesses, court personnel, or other lawyers on
any basis, including, but not limited to, on account of race, ethnicity, gender, religion, national
origin, disability, marital status, sexual orientation, age, socioeconomic status, employment, or
physical characteristic;

(e) state or imply an ability to influence improperly a government agency or official or to

achieve results by means that violate the Rules of Professional Conduct or other law;

(f) knowingly assist a judge or judicial officer in conduct that is a violation of applicable
rules of judicial conduct or other law;

(g) fail to respond, in writing, to any official inquiry by bar counsel or a disciplinary
agency, as defined elsewhere in these rules, when bar counsel or the agency is conducting an
investigation into the lawyer’s conduct. A written response shall be made:

(1) within 15 days of the date of the initial written investigative inquiry by bar counsel,
grievance committee, or board of governors;

(2) within 10 days of the date of any follow-up written investigative inquiries by bar
counsel, grievance committee, or board of governors;

RRTFB July 20, 2020