Sirs:
To hand reports that you intent to seek a declaration of rights and duties under the Lease and Purchase Agreement with Memorial Health Systems and related entities. This seems a reasonable step to take in light of the controversy. I understand that, when the cause commences, you will be represented by Counsel. I am providing a copy of this letter to your usual Counsel for that reason.
I would ask that, in the interest of legal economy, you would add me as a defendant in the matter rather than requiring me to file a separate case perhaps as early as this summer. This will save you from having to litigate the matter a second time, and will provide the taxpayers of West Volusia with a proper adversarial test of the Sunshine issue and certain other matters.
To contribute to the speedy, just, and inexpensive resolution of the matter, and in consideration of your efforts toward the same, I am willing to make certain procedural and substantive concessions, to wit: I will accept service by mail pursuant to Rule 1.070(i)(2), or in the alternative will accept personal service at your attorney’s offices, at your option; I will waive objection to your standing based on the required presumption of constitutionality.
I would expect to file counter claims for any issues not covered in your initial complaint, so that the entire matter may be handled at once. If you have questions or comments, drop a note in the fax (4-2116); the machine is programmed to notify me and let me review my in-coming faxes remotely.
Yours,
Tanner Andrews
CC: E. Channing Coolidge, Esq.
Posting of this letter is a paid political advertisement provided by Tanner Andrews, P.O. Box 1208, DeLand 32721, independent of any campaign or committee. This material is also on display at the offices of the West Volusia Hospital Authority. No candidate has approved this material.