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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

TALLAHASSEE DIVISION

KIMBERLY GRIPPA, CASE NO. 4:20-cv-00457-MW-MAF

Plaintiff,

v.

RONALD RUBIN,

Defendant.

_____________________/

PLAINTIFF’S RESPONSE TO ORDER REQUIRING SUPPLEMENTAL 

RESPONSE ON ISSUE OF FUTILITY

Plaintiff, KIMBERLY GRIPPA, files this Response to Order Requiring 

Supplemental Response on Issue of Futility and states:

CONTEXTUAL BACKGROUND – RUBIN’S STRATEGY

On May 10, 2019, a female employee of the Office of Financial Regulation 

(OFR) filed a formal complaint about improper conduct by Ronald Rubin. On 

May 13, 2019, Kim Grippa filed a complaint with OFR detailing improper conduct 

by Ronald Rubin during a luncheon they had in March, 2019. 

After these and other complaints by females within OFR were made public 

and Chief Financial Officer Jimmy Patronis began publicly denouncing Rubin, 

Rubin turned on the offensive and hired Seth Gordon, a publicist. The counter 

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offensive email, Exhibit 144, filed herewith, summarizes Rubin’s attempt to 

maneuver through the press to fight back against not only Kim Grippa, but another 

person he falsely targeted as causing his demise, Paul Mitchell. Examples of the 

articles that were instigated by Seth Gordon, who was paid by Rubin’s father [see 

Exhibit 1a] include Exhibits 145, 146, 147, and 246. Kendall Coffey was 

representing Rubin at the beginning of this façade. The Tein Malone firm took 

over where Coffey and Gordon left off. 

The “client”, Ronald Rubin, is the common denominator, the ultimate arbiter 

of the actions taken by his agents on his behalf, and has remained the same, 

whether he was represented by Kendall Coffey, assisted by Seth Gordon, or by the 

Tein Malone firm. The ball started rolling with Seth Gordon and there has been a 

consistent counter offensive through the actions of Gordon through Tein Malone. 

Gordon’s documents, Plaintiff believes, will show a consistent plan of attack 

by Gordon that was adopted and perpetuated by Michael Tein through his letters

written on behalf of Ronald Rubin [see ECF 4-3] against Kimberly Grippa and his 

attack on Paul Mitchell and others, including Grippa, in Rubin’s Complaint filed 

on June 24, 2019, by Michael Tein. [See Exhibit 1b]. 

Whether Gordon ceased his role in the counter offensive attack in June 2019 

or not, his emails and other communications in May and June, 2019, are expected 

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to show the level of malevolence by Rubin and his “team” to destroy everyone, 

mostly Kim Grippa and Paul Mitchell, who crossed him.

Interestingly, although Rubin may (and is) attempting to distance himself 

from Gordon and Michael Tein in his filings of late, there is not one iota of 

evidence that Rubin ever told Tein, or Gordon for that matter, to stop the counter 

offensive through the media, letters, and the lawsuit the Tein Malone firm filed 

against Paul Mitchell that references the supposed criminal enterprise, of which 

Kim Grippa is a named coconspirator. He claims now in his summary judgment 

filings that he did not “author, contribute, direct or approve the June 21, 2019 

letters that Michael Tein sent to Governor DeSantis and Inspector General 

Miguel.” Rubin has never disavowed the statements in those letters that were 

made on his behalf.

Rubin’s new-found position is belied by his adoption of the counter 

offensive letter that Gordon sent on May 30, 2019 (Rubin is copied), his approval 

of the complaint that was filed by Tein on his behalf on June 24, 2019 naming 

Grippa as a coconspirator, and his tacit approval of all of the articles that Gordon 

orchestrated on his behalf (recall that Gordon was paid by Rubin’s father for 

services for Rubin). 

Plaintiff has no doubt that the Gordon documents will show that Rubin 

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intended to destroy Kim Grippa and Paul Mitchell, and that his proxies devoted 

time and money doing so, leading to hiring the Tein Malone firm to file the lawsuit

on facts and a narrative that were initially developed by Gordon. One can hardly 

characterize the attempt to discover those documents as “futile” at this stage of the 

proceedings. Rubin is simply replaying a hand he has played throughout this case: 

to try and maintain a monopoly on the storehouse of relevant information and to 

prevent it from ever seeing the light of day, because doing so would expose his 

charade in full. 

Respectfully submitted,

/s/ Marie A. Mattox

Marie A. Mattox [FBN 07396875]

MARIE A. MATTOX, P.A.

203 North Gadsden Street

Tallahassee, FL 32301

Telephone: (850) 383-4800

ATTORNEY FOR PLAINTIFF

CERTIFICATE OF WORD COUNT AND FONT

I HEREBY CERTIFY that this document contains 796 words and has been 

typed in 14-point font. 

/s/ Marie A. Mattox

Marie A. Mattox

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CERTIFICATE OF SERVICE

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

furnished to all counsel of record by CM/ECF this 10th day of March 2022.

/s/ Marie A. Mattox

Marie A. Mattox

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