Letter 170228 to Surovell .pdf
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HARRISON & JOHNSTON, PLC
Stephen L. Pettler, Jr.
21 South Loudoun Street Winchester, Virginia 22601
P.O. Box 809 Winchester, Virginia 22604
February 28, 2017
Scott A. Surovell, Esq.
Surovell, Issacs, Petersen & Levy, PLC
4010 University Drive, 2d Floor
Fairfax, Virginia 22030
Sea Bay Hotel, LLC, et al. v. Barry R. Gosnell, et al.
Fairfax County Circuit Court Case No. 2017-03034
Attached herewith please find a courtesy copy of the Complaint (without exhibits) which has been filed this
date. I have also enclosed copies of the discovery which is being served on Barry Gosnell, Randolph Palmer
and Scott Taylor contemporaneously with the Complaint in this matter.
Please advise if you will be representing any of the Defendants in this matter. If so, please contact me to
discuss acceptance of service. We are proceeding to have all Defendants served at this time in the event your
will not be representing any of the individuals.
Our last exchange occurred on October 13, 2016, at which time your client rejected Sea Bay’s reasonable
offer to sell its interests and remove itself and Don Wooden from the positions in which they currently find
themselves. Your clients’ assessment of my clients’ investment and exposure to liability, as communicated
in your letter, was grossly inaccurate and evidenced a lack of appreciation for the seriousness of my clients’
concerns. Due to your clients’ response, we were instructed to proceed with attached suit.
As you know, the hotel is still not completed. The United Bank loan is now in default under its terms. Our
clients intend to proceed to have IOOC, LLC and Inns of Ocean City, LLC dissolved in order to mitigate
mounting losses and liability exposure. We intend to hold your clients accountable for all losses incurred
by my clients as a result of their conduct. We also intend to move the Court for interim relief, including the
removal of Mr. Gosnell, Mr. Palmer and Mr. Taylor from management of the companies and the appointment
of a receiver, once the parties are at issue. We would like to coordinate the hearing of these matters at the
earliest opportunity, if you will be making an appearance in this matter.
We look forward to your reply. I am
Very truly yours,
//s// Stephen L. Pettler, Jr.
Stephen L. Pettler, Jr.
Sea Bay Hotel, LLC (via email)
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