Exhibit 2 

Case 19-18585-MAM Doc 382-2 Filed 12/21/20 Page 1 of 4
1

Samantha Powell (7663)

From: Caroline Catchpole Spradlin (7672)

Sent: Friday, December 4, 2020 10:40 AM

To: 'Dana Kaplan'

Cc: Bret Feldman (7879); Caroline Catchpole Spradlin (7672)

Subject: RE: Meridian Marina Bankruptcy | Case no.: 19-18585-MAM | Objection to Claim No. 11

Dana, 

We appreciate your revised settlement offer and we will present it to our client for their consideration. However, in the 

meantime, as it appears you have confirmed that the representation that the parties have reached an agreement is not 

correct, please withdraw the objection as it contains a confirmed misrepresentation. 

We will get back to you once we have discussed with our clients. 

Thank you, 

Caroline 

_____________________________

Caroline Catchpole Spradlin

Associate 

Phelps Dunbar LLP 

100 South Ashley Drive 

Suite 2000 

Tampa, FL 33602 

Telephone: 813-222-7672 

Fax: 813-472-7570 

Email: caroline.spradlin@phelps.com 

CONFIDENTIALITY NOTICE - This e-mail message, including any attachments, is private communication sent by a law 

firm, Phelps Dunbar LLP, and may contain confidential, legally privileged information meant solely for the intended 

recipient. If you are not the intended recipient, any use, distribution, or copying of this communication is strictly prohibited. 

Please notify the sender immediately by replying to this message, then delete the e-mail and any attachments from your 

system. Thank you.

From: Dana Kaplan 

Sent: Thursday, December 3, 2020 5:59 PM 

To: Caroline Catchpole Spradlin (7672) 

Case 19-18585-MAM Doc 382-2 Filed 12/21/20 Page 2 of 4
2

Cc: Bret Feldman (7879) 

Subject: RE: Meridian Marina Bankruptcy | Case no.: 19-18585-MAM | Objection to Claim No. 11 

Caroline 

I spoke to my client about the matter. My client has given me authority to offer the sum of $38,000.00 in full and final 

satisfaction of the claim. All allowed claims will be paid in full in this case upon the effective date or sooner. Please 

advise if the foregoing is acceptable. If we cannot come to a resolution of the claim, the full amount of the claim will be 

held in escrow until a trial on the claim is held by the court and the court rules on same. 

Dana 

Dana Kaplan, Esquire

Kelley, Fulton & Kaplan, P.L. 

1665 Palm Beach Lakes Boulevard, Suite 1000 – The Forum 

West Palm Beach, FL 33401 

561-491-1200 x111 

Please visit our website at: www.kelleylawoffice.com

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strictly prohibited. If you are not the intended recipient, please contact us immediately at (561) 491-1200. THANK YOU. 

From: Caroline Catchpole Spradlin (7672) <Caroline.Catchpole@phelps.com> 

Sent: Wednesday, November 25, 2020 1:16 PM 

To: Dana Kaplan <dana@kelleylawoffice.com> 

Cc: Bret Feldman (7879) <Bret.Feldman@phelps.com>; Caroline Catchpole Spradlin (7672) 

<Caroline.Catchpole@phelps.com> 

Subject: Meridian Marina Bankruptcy | Case no.: 19-18585-MAM | Objection to Claim No. 11 

Importance: High 

Case 19-18585-MAM Doc 382-2 Filed 12/21/20 Page 3 of 4
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Ms. Kaplan, 

Our firm represents Progressive Environmental Services Inc. with respect to its claims against Meridian Marina & Yacht 

Club of Palm City, LLC. I am writing in regards to the objection to Progressive’s claim in the pending bankruptcy which was 

filed on November 19, 2020. I have attached a copy of the objection which we received from our client this afternoon. 

The objection represents that “the correct amount of this claim is $32,000.00 per agreement of the parties.” However, 

while a proposal was made by counsel Robert Lewis for such a reduction, no agreement has been reached, and we do not 

expect that our client will agree to the proposal. As a result, the objection is incorrect, and our claim stands as originally 

stated. We respectfully ask that you withdraw the objection and correct this error, as there is no agreement to such a 

reduction. We would appreciate confirmation from you once this has been corrected. 

Please feel free to call me if you would like to discuss or have any questions regarding this matter. My cell number is 803-

617-8539, you are welcome to call me at your convenience. Thank you for your time and attention to this issue. 

Best, 

Caroline 

_____________________________

Caroline Catchpole Spradlin

Associate 

Phelps Dunbar LLP 

100 South Ashley Drive 

Suite 2000 

Tampa, FL 33602 

Telephone: 813-222-7672 

Fax: 813-472-7570 

Email: caroline.spradlin@phelps.com

CONFIDENTIALITY NOTICE - This e-mail message, including any attachments, is private communication sent by a law 

firm, Phelps Dunbar LLP, and may contain confidential, legally privileged information meant solely for the intended 

recipient. If you are not the intended recipient, any use, distribution, or copying of this communication is strictly prohibited. 

Please notify the sender immediately by replying to this message, then delete the e-mail and any attachments from your 

system. Thank you.

Case 19-18585-MAM Doc 382-2 Filed 12/21/20 Page 4 of 4