The Florirle Bar

In quiry/C
o mptrint Form
PART oNE (see Page r,
paRT
oIyE
-
comprainart rnformation.):
YourName,
kooL
(rr.,
Organization:
Address:
City, State, Zip
eode;
Telqrhone:
_+
o
ACAP Reference No.:
Ilave you
ever filed a complaint against a member of The Florida Bar:
yes
=
N-=
If yes, howmany complaints have you filed?
Does this complaint pertain
to a matter currently in litigation?
yes
=
No
fl
PART TWO (See Page 1, PART TWO
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Attorney Information.):
Attomey's
Name: [l, wi
e
L
A* J,
i nvc?
-*s
787
00
zs4
Address:
City, State, Zip_Code:
l*
Telephone:3oS
11
PART TEREE (see Page 1, PART TEREE
-
Facts/Arlegations.):
am complaining
about are: (attach additional sheets as ntessaryy
(Note
that this field maxes out at 1800 characters - attach additional sheets as necessary)
5""
P*S*
3
The specific thing or things I
l
N
E.
Vg*
+
23
PART F0UR (See
Page 1, PART FOUR
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Witnesses.):
The witnesses in support of my
allegations
are:
[see
attached sheet].
PART myE (see
Page 1, PART rrrE- signature.):
under penalties
of perjury,
r declare that
the foregoing facts are truen correct and complete.
*k
df
9"."e
P^l" o+ z3
I
This.Bar complaint against Roniel Rodriguez, IV (FBN 544787) is a companion to one I filed
agairist Larry Weisberg (FBN 962198) o, Jurrury )otq. These fwo attorneys acted as co-counsel
to me in the same case. I described this case in my first complaint and shall elaborate on it here. I
believe both of them behaved unethically and I was their viciim. Mr. weisberg referred me to Mr.
Rodriguez whom he recommended as a litigation attorney. As explained in my complaint against
Mr' Weisberg, he failed to convey an offer of settlement from tire plaintiff
s attomey to rie on
August 30,2013.
I contacted Mr Roniel Rodriguez IV due to a referral from another lawyer, my first contact with
him was thru an email where this another lawyer sent to both of us (Mr Roniet and I). In those
emails we set up a meeting.
Orr Friday August 30'h 2013,I met with Mr Roniel Rodriguez tV in an office located at 150 W
Flagler in Miami (Not sure if that is his office, since he is registered at the bar with a different one,
the one I appointed at the Attorney Information
-
pART
Twb- on this inquiry).
At that meeting Mr Roniel Rodriguez presented
to me an "agreement
for collection representation,,
(Hereafter
known as the agreement) I said to him that I could not accept that agreement before
talking to another person first. I left that meeting with Mr Roniel Rodriguez iV offer in my hand
and without singned it as show in Exhibit A.
Then, on Monday September 2od 2013 (Just a reminder that September 2nd 2013 was a holiday
commonly known as labor day) and after consulting another persons I sent an email to Mr Roniel
Rodriguez IV a modified version of the same agreement (Hereafter
known as the modified
agreement) as show in Exhibit B.
The same day (Septemli:r
2"d 2ol3) Mr Roniel Rodriguez IV replied to me also in an email saying
"I have no problem
with the agreement as modified as long as you understand that I will not be
advancing any costs in this litigation,,.
The same day (September
2"d 2or3) I replied Mr Roniel Rodriguez IV answer saying that for now
I can not commit to that as it is (Refering
to his posture of nof advancing the costs) Copy of that
email conversation
is attached here as Exhibit C.
After some minutes of making clear that if he is not advancing the costs under the modified
agreement
and after I also made clear that I can not accept that condition, I sent to Mr Roniel
Rodriguez another email asking if his offer is still availaile under the original agreement (His
initial agreement, attached here as Exhibit A). I got no answer about that evei again. That email is
at&ached here as Exhibit D.
1!o,
the same day (September
2n 2013) and after about more than 5 hours Mr Roniel Rodriguez
fV sent me an email from another conversation related to the same case, in which Mr Roniel
Rodriguez fV encouraged me to hire another law firm and wishing me the best of luck in the
litigation- Certainly that is not the position and those are not the words of an attorney who thinks it
hadbeing retained. That email is attached here as Exhibit E.
on Sptmber 3d 2013, Mr Roniel Rodriguez IV introduced me to a third person interested in
adrmcing the costs of the litigation. Mr R.oniel Rodriguez IV told me in an email to be in this
,l
P-s.
3 -+ L3
place (150 W Flagler in Miami) to meet with this person. Mr Roniel Rodriguez IV told me that in
an email attached here as Exhibit F.
In that meeting this person accepted to cover the costs of the litigation.
I transfered the property on dispute to this third person's entity as a part of covering these costs.
And Mr Roniel Rodriguez IV became (Or I thought) became the lawyer to represent my case and
my best interest in the case.
Then, the next day on September 4th 20L3 due to new information I received about the case, I sent
to Mr Roniel Rodriguez fV an email saying that I did not want to fight the case and that I want him
to drop the case.
Mr Roniel Rodriguez IV answered to me in an email, that due to the transfer of the property to that
third person's entity and due to his retention by this third person's entity what I am asking to him
"it is not possible" and that I needed to contact this third person.
That email is attached here as Exhibit G.
What I understood for that answer from Mr Roniel Rodriguez IV, it may be not clear, but that let
me the impression that Mr Roniel Rodriguez IV was suggesting that he was not my lawyer, but
also, if he was not suggesting that, what it was clear it was that Mr Roniel Rodriguez IV was not
acting in my best interest (If he was representing me) and that Mr Roniel Rodriguez was acting in
the best interest of the person paying the costs.
Then, the same day of that response from Mr Roniel Rodriguez IV, I contacted this third person,
this third person among other things, replied to me in an email that he already paid to Mr Roniel
Rodriguez IV "his non-refundable initial retainer of US $50,000.00".
This email is attached here as Exhibit H.
After that, I
just
decided to contact a new lawyer, somebody who really could represent my best
interest. I did, and I am trying to drop the case.
On September 2}th 2013, comes that Mr Roniel Rodriguez fV is claiming that he needs to be paid
for his services on court for acting in bahalf of the case- This really got me as a surprised and also
created a little confusion. Such claim sent to me in an email is attached here as Exhibit I (r-1 to
r-3).
It was my understanding that Mr Roniel Rodriguez fV was already paid his initial non refundable
retainer of $50,000.00 as the third person said-
AIso, it was my understanding according to Mr Roniel Rodriguez IV himself, that this third
person's entity already paid for his retention.
In top of that it was my understanding that Mr Roniel was not my lawyer, but that was only my
understanding- But, I
am
sure at least, that he was not acting in my best interest if I ever was his
client (Or considered as his clien! even when I was not the one paying him for the representation
on the case).
F-1. + a( 23
Mr Roniel Rodriguez IV allegations
of unpaid fees are based in the modified agreement (Attached
here as Exhibit B) rhe one I modified, sent to him in an email, he told me that he is oK with
that as long as I understand
that he will not advancing
trre costs, and I told him that for now I can
not commit to that as it is' And then, never ever takeJ again about that agreement since Mr Roniel
Rodriguez
IV himself found a third person to cover the iosts, as I already explained in the course
of this inquiry.
Mr Roniel Rodriguez
IV signed that modified agreement
and sent it in an email to me, and to my
new lawyer' This modified agreement
signed by Mr Roniel Rodriguez rv is attached here as
Exhibit
J.
And after that, it curious to me that Mr Roniel Rodriguez rv signature marks are different in
August and September. (See
Exhibit A and Exhibit H).
And I am attaching the differences
as Exhibit K.
on october
gth
2013, the third party introduced
to me by Mr Roniel Rodriguez IV and the same
person
who told me that he has been covered Mr Roniel Rodriguez IV i"nitial non refundable
retainer
of uS $ 50,000.00
sent an email to Mr Roniel Rodriguez IV giving
him instructions
referring
to the case JVIr Roniel Rodriguez IV claim he is being Ly attorriey, which comes to re-
affirm that Mr Roniel Rodriguez IV was never my attorney or representing
my best interests. This
email
which inskuctions
is attached here as Exhibit L.
Then, on october l6h 2013 r got a called from Mr Roniel Rodriguez
IV that phone
call went to
yo.ice message and MrRoniel Rodriguez
was giving me a kind oruloate oo tt. case .
It is important
to mention that this phor. call happined after I mad-e clear to Mr Roniel Rodriguez
rv that he was not my lawyer anymore in the tus", und he was notified about that by my new
lawyer. This voice message on my cellphone
can be heard in the following
link:
It is strange to me that Mr Roniel Rodriguez
IV acted like he was not my lawyer when I thought he
was (I even don't know if he was o. noi-y lawyer at anypoint)
And, when he clearly was not my
lawyer anymore
he acted as he was my lawyer trnng,o-'giriog
me a kind of update on the case. I
haye a lawyer, I am not sure what kind oi hrormition
Mr Roniel Rodriguez IV was trying to
provide
me in that phone
call. I already had been informed that the tlira"furty
who Mr Roniel
Rodriguez
rv introduced
to, made an_ agreement
apparently with *o*" tiia of sum of money
involved,
so the case could resolved, uui ur nonief Rodriguez
rv i. .,iir ,iril;;1"";'r"ili
lawyer and is still looking for compensation.
Finally, about Mr Roniel Rodriguez
tV:
Sce'nario
l: If he *T-
-y
lawyer why he made me transfer the property
to this third party brought
by himl
why he told me he could not do why I asked? why he told me u.rorh.. person paid his
retainer?
why he is still claiming I have to payhim
after telling me somebody
else paid him?
scenario 2: rf he w-as
-not
my lawyer why he made me signed the property
over a third party
brought by him? while knowledge
that I hai another ru*y".2 and then i triiea u o"r" lawyer to drop
the case' If he was not my lu*yo why he wants to g.i paid?
If he was not my lawyer why he
F"l"
S
,(
Lj
I
called me when the case was done if he was not my lawyer, but knowing that I already have a
lawyer? He should it talked to my lawyer, right?
Both scenarios, are contradictories.
After all those evidence I submitted, I request to this bar to take actions about Mr Roniel
Rodriguez IV contradictory
behavior.
Hoping that this inquiry get the treatment and the importance that deserves, a Miami-Dade website
visual record showing the value of the property (US
$ 1,336,248)is attached here as Exhibit M.
As I said before, I believed with good reason that Mr. Weisberg remained my attorney even after
he referred me to Mr. Rodriguez to handle the litigation. Mr. Weisberg was not a litigator, but he
and Mr' Rodriguez jointly
advised me in this matter. As a result of their ethical violations, I lost
my claim to the subject property
when, at the suggestion of both of my attomeys, I transferred it to
a company belonging_to
a shrewd, litigious client and cohort of Mr. Rodriguez named Stuart Kalb.
I vaguely understood that the apparent purpose
of this fansfer of my"property to Mr. Kalb,s
company was twofold. First, it was a litigation strategy to tie up the pioperty
in bankruptcy and
second, it was a means to obtain financing for the out-of-pocket iosts of tfr" liiigation, costs which
Mr' Rodriguez refused to advance when he agreed to tak; the case on contingency. In the end, Mr.
Rodriguez and Stuart Kalb profited to the tune of $60,000 at my
"*i.rr...
Through their
machinations,
they recovered this sum for themselves as a settlement ;f *le claim to the subject
property
which I had transferred to JRS for purposes of advancing my interests in the litigation.
on or about January 28,2013, a Florida company named This Faro Intemational, Inc. (transferred
an apartment building to my nonprofit corporation, Peace City, Inc. at no cost with the intention
that it be developed as a shelter for homeiess people. This entire transaction was conceived and
carried out without the advice or involvement
of any attorneys. on April 2013, Faro sued
peace
City alleging that the kansfer was made by an alienaLd and emotionally disturued family member
of the owners of Faro who did not hold any position
with Faro nor have any authority from Faro to
give away an apartment building even though it needed substantial renovations and was facing a
demolition
order by the city.
Mr' Rodriguez had agreed to represent me in the suit filed by Faro seeking the rescission of
transfer of the prop-erty
to my company. He agreed to defend *" io this lawsuit for a contingency
fee equal to 35o/o of the value of the property,
but he would not agree to advance the litigation costs
or to pay them if we lost. I did not have the ability to pay or advilce the litigation costs which Mr.
Rodriguez indicated would be substantial, owing to tie many anticipated d-epositions in the case.
The solution would be financing from a third-party, namely Stuart Kalb. Through some
arrangement
that was never adequately ex-plained to me, the plan Mr. Rodriguez suggested was for
P"Jo
kansfer the properfy to Mr. Kalb/s company, lRS, which was banfrupt or would file for
bankruptcy.
Once in bankruptcy the property
would be renovated
with funds from a court-
approved investor expected to be Mr. Weisberg, and the money to cover the litigation costs would
be advanced by Mr- Kalb- This was the so-called Sbankruptcy
solution
@whichmy
attorneys had
conceived
F"J" L
+
Z3
i
I
So at the urging of my two attorneys,
Mr.-weisberg
and Mr. Rodriguez,
I conveyed
my company,s
interest
in the p-t9P"II
to an entity called
JRS, wiich was owned and controlled
by Mr. Kalb, on
September
3' 2013' They sent *" to Mr. Katb's office alone and it was there that I signed the quit
claim deed' It seems that after that point,
nothing
my attorneys
did or said to me made sense. Mr.
Rodriguez
seemed to be acting directly
contrary
io my uest inierests
as his client. It seemed he had
abandoned
me' when I pressed
him for u, .^pturution,
I got the runaround instead of a straight
answer'
The details and the mechanism
of the alrangement
involving
the transfer
of my property
to
Mr' Kalb's company
were never p"l.i1writing
o. ia"qrutely
explained
to me. when I asked Mr.
Kalb about the next step in the so-called plan
,J *r"
-i
property
through bankruptcy,
he told me I
was "stressed-out"
and advised
me "to go home urra r.rt foi a month,,-whro
I demanded
that the
agreement
be put in writing,
he and ui. Rodriguez together
then escorted
me out of the office
building'
In frustration,
I drove
to Mr. weisberg;s
Bocl Rrto, office when I could not reach him
by phone'
Mr' weisberg
told me the transferii
*y p.op".ty
to JRS could be reversed.
I felt
confused
and wanted to c-ancel this plan.
Mr. weisblig p.o-ired
to speak to Mr. Rodriguez
about
the matter and then to call me in two hours.
e )
I never received
the promised
call. I drove to Mr. weisberg's
office the next day to complain.
when I arrived'
Mr' weisberg
made me leave his office so he could speak to Mr. Rodriguez
privately'
I then overheard
Mr. weisberg
telling
u.. n"a.ig, ez thatt
-as'a
.,key
witness,,.
Their
conspiratorial
behavior,
failure to explain, and"less
than forthright
attitude toward
me led me to
conclude
at this point
that I had somehow
been victimized
by my own attorneys.
I had further
reason to mistrust my attorneys,
Mr' weisberg
and Mr. Rodriguez,
*t *o a couple of days after the
transfer
they counseled
me to make, I learneJfrom
a direct conversation
I had with one of Faro:s
officers that Faro wanted to settle the case and had so informed
Mr. weisberg, but he had failed to
inform
me of this vital communication.
I felt betrayed
b; ;;;;;
ffi#; and contused
about
what course of action was most advantageous
to take in the pending
lawsuit. I decided to seek out
new counsel
and found the firm of Kravitz
& Guerra.
After my initial consultation
with Kravitz
& Guerra, during which we discussed
the possibility
of
settling the suit by returning-
the property
to Faro, I tried again to have a meaningful
conversation
with my two attorneys'
on septemblr 4,2013,I
contactedloth
Mr. weisberg and Mr. Rodriguez
and advised them I wanted to consider
settling the case by returning
the property
to Faro. I was
disillusioned
and discouraged
by the apparent
neglect,
self-dealing,
and misadvise
of these
attorneys
and I felt confused
about the state of *y
"url
and what steps t"o tuil" r"xt. I just
wanted to
be rid of what had come to be source of great
Airir"r, fo, _".
In response
to my reasonable
concerns
about the stafus of my case, my attorneys
continued
to give
me unsatisfactory
explanations,
if not downright
*r" r* uru.-.
wh"o I wanted to discuss the
option of settling the case.by.restoringth"
p.op-".ty
to
pu*,
Mr. Rodriguez
informed
me I could no
longer
consider
that possibility
since"l had transferred
my property
to JRS and JRS had retained
him'
He also claimed to know-nothing
,u"",-rn"
orri".
"r-,
property
to JRS which he and Mr.
Weisberg
had advised
me to make.
I was rightfully
shocked
to hear that my attorney,
Mr. Rodrigu ez, had.not only switched
sides but
disavowed
the advice he
hadjust given
me just
before dri,,g;;. ;i. f"lb.*;ii.
*orr.r. After this
Benedict
Arnold agrged to represelt
-: grr.u
contingency
fie basis with the o.,t-of-po.ket
costs to
be advanced
by Mr' Kalb's
9o*puoy,
JRS, in .*.rrurig.
6, the transfer my property,
he tells me he "had
nothing to do
Ttr F.
u.,rog"*"nt
with JRs and_ Kalb,,, that JRS paid
him a $50,000 "retainet'',
and that I should "contact'Mr.
Kalb,, to discuss the matter further.
fl"g
- o{ L\
Well isn't that rich!. My attorney comes up with a scheme to save my property and to finance
$50,000
of anticipated deposition costs by having me transfer my property to his crony' Stuart
Kalb then pays Mr. Rodriguez not the ,g.t.d-rrpon $50,000
cost advance, but a $50,000
nonrefundable retainer, at w*ch point Mr. Roariguez throws me under the bus and becomes Mr'
Kalb,s attomey. This sordid mess has to be involve multiple violation of the Bar's canon of ethics'
While I certainly had good reason to doubt Mr. Rodriguez was still acting as my attorney based
upon his conduct, his imarks, and his otherwise
general lack of meaningful communication
with
me, he later took the position he had in fact remained my attorney throughout the subject lawsuit'
After I discharged him, retain ed, Kravitz & Guerra, and with their help settled the suit by
conveying all my interest in the subject property back to Faro, he filed a charging lien against me
on Seitemb er 2A,2013 seeking to enfoice iris iontingency fee agreement even though he knew I
had transferred the property *t i.fr was the source of his contingency
fee to JRS' After initially
refusing to sign a stipiation of substitution of counsel with Kravitz & Guena, he filed his own
motion to withdraw as my attorney on September23,2013'
On the same day, he also filed a
Motion to Intervene on behalf of JRS. His purpose was now to act officially as attomey for JRS to
enforce its claim to the property which he iounseled me to give to JRS for what purpose has still
never been made clear to me or put in writing-
On Octobe r 16, ZOl3,Mr. Rodriguez attended a hearing to confirm the settlement agreement I had
reached with Faro in the subjectlawsuit. In what capacrty he appearcd,I am not Sure' since I was
represented by Kravitz & Guerra at this hearing. The day before, he negotiated a settlement with
Faro on behalf of JRS. He and JRS receiveo $6o,ooo
from Faro for the release of their claim to the
property, a claim they only had because I transferred my property to JRS on the advise of Mr'
ifoO.igo", and Mr. Weisberg. This can't be right. My purpose in deeding the property to JRS was
never-entirely clear to me, but I always believid it was never to sell or give the property away' It
was suppos"d to b. a means of financing the costs of the litigation and obtaining funds to renovtte
the property while making it harder foiFaro to recover it, as far as I could tell then or now' But
how this arrangement, which was conceived and recofllmended to me by my own afforneys, could
have ended upputtin! $60,000
in their pockets is a mystery to me. If I wasn:t defrauded by Mr'
Rodriguez, ne at leai failed to adequatlly communicate with me about my case, failed me in his
duty Jf loyalty by representing or appearing to represent opposing interests, and failed in his duty
of care Uynegtecting to take proper steps to protect my interests by a written agreement covering
the purpose, terms, ind conditions of my transfer of the property to JRS and by abandoning me
after the transfer. Mr. Weisberg was my also my attomey throughout this whole affair and shares
some of the blame. Both should be disciplined by the Bar for their violations.
Thanks.
Karel Soucre
Industrial Engineer
Peace City, [nc. - President
[.,
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x14,tlf
RE:
Modified
Agreement
Sigued
From:
I(EreI
Soucre
(karelsoucre@hohailcom)
Sent
Mon
giOAB
lZ:A4
pM
To:
Roniel
Rodriguezrv, p_4'
(roa.@jrfirn.com)
[illffiffi::::::i-0".d
with
Mr' rawrence
thru
e-rnail
He is not in ofice
today.
r have nottark
:*m:*iI[f#*#::ffi
"#r:;"1,#",*::*:,"xtilj{*;*,T*.#
Thanks,
Frcm:
Ron@RiRfirm.corn
f
ubiect:
Re;
Modified
Agrement
Signed
3rT.
*ton,
2Sep
2O13
1151:16
;rfr'
To : ka relso
ucre
@ hotma
il-com
I have
no problem
with the agreelnent
athrancirqga*
** in this litigatbn.
as modifred
as long
as you
understand
that r will not be
Regards,
Ron
Rodr{guez
IV
Roniel
noOrtgrez
w,
pe,
Direct
Fns (305)
T7-?-4S7S
:-l=r!
Ron@
RJ Rfi rm.
ccnn
;ffi";ffi
ffielffi:ffi&:nerated
on a mobile
device
and
mrycontain
ftEccucrcies
due to formatring
On Sep 2, ZOa3,
at !O:46AM,
IGrel
Soucre <%
wrote:
Mr- Rorl
I respectfulf
modifred
the agreement
and
signed
iL
\
fl*3.
tt
.o+
2-\
fxhitit
RE:
Dtodified
Agreemenr
Sigued
Froetr(ertrsoucrer%
Se*
&ton
gtgzJt3
lU;=ZFl3rt
v-
To:
nsri*noerigrqfy,p;1
(rw@drfie-coe)
tf I stsn
10ur ordgfnal
agrEefne4
win pu
be s,,lt advancirqg
atl os-
ofrt* ritia60n?
i
*\
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L
/
?nu
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23
e
xiti t
IT-t
Ron@RJRfirm.com
subJect:
Re: Meeting
Date:
Mon,ZSep
2013 tt:22:31-O4m
To: karelsoucre@
holma il.com
l(arel-
I have nevef
seen a lawyer
state that they are a t@g|certain
of a win. Eased upon trc eleectations
already
set by ttrai trm I arn no longer
inhrested
in this case.
your
case is not ilt certain
and ctearcut as that t.m r,.taivr*J
1ou- There nras crearry
a lack
of orporate
furmalitythat
is ."quioo
when
airpoJ"gof
alt orsubstantially
all of a corporation's
aasets'
rhere is also serlcus issues r"g"itrg,he
demolition
notices.
tf that firm
believes you
have a L0o?6percent
ch"n""
of p.rairing
wfth your
suit, you
should
hire them.
Best
of luck with the lftigation.
Regards,
i)
Ron Rodriguez
tV
?*.
t3
rrEm:
ffDrtg,R
Rfirm-com
fubjece
Re: Meeting
9*=
Ttre,
3 Sep ZO13 OgS4:57
-O4OO
To : karebouee@
hotmail-com
tt.i[
be back
at my sfHce
at 11:3oam-
we can disc,ss
at tfiattime
the possibiritgof
a third party
@reringa{I
sf the ritigau:on
costs
and fees to be incurrea
tiro,gh
triar-
negards,
bn Rodrig,uz
lV
RoniE{
Rodriguez
fV,
p.A
DirEct llnq (305)
T7W7S
o+
23
E=
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E*na il: Ron
@ &lRfirm
- corr:
7n5.
| +
5xhiLil
RE:
I,lsetirg
3T'3::rqoorT=r*o*@
To:
#iffi'#tr#;
ruis
senderis
ruvorrsaf,e
rist
t haverrottring
br
ffi#ffirrT
:*
.&s
arr,
iE,
ri3
sarac
re
:b;;"G;:M$
ectcr:
ar:c
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conracr
;#i#ffi,*#ffir#*,
eestqarus_
nqr
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Rorrie{R"argnr*Iv,
tl-
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ffi*,
(s54,
f*{91sBruurarc
(soq
5q.r25e
rrcare
(3o5)
3S9_O1S
rforrce
fuirrde
f5c1) 4Sr1
65Sl
rum
Bc*r
Facsir:rf,e
E-rrr*
Prlra:/:
Secoedar/:%"*==
-
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"+
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t-xhrti
T
H
I.T
t sr*afb@mirtegalcom
r o : ka relsoucre@
hotmail.co
m
Subject peace
Crtyto
JRS
Date:
we4
4Sep
2013
u)fr725+@
l(arel,
I am not
a'railable
for
ttre rest
of this week'
However,
the Ansrrrer
and Affirmatirre
Defenses
ha,e beeo
fified'
while
I am interested
in any inforrnation
p,
-"y-rr"o, *"r
1,
no u,gn.y
since
we harre not yet
comrnenced
disevery'
I have
some
time
at the end orf nerrt
reek if yrcu
wirdei
rfte
to meet
More
ffifEft[::#"*-;;;ilJr,-*no"ore
initiai-retai,nerof
S5o,ooo{}o,
so*ris
matrerwitr
Regards,
SArart
IL
E-
?*2"
1-
o+
L
5
x1,.;1,',f
THIS
FARO
INTERNATIONAL,
LLC,
I
Plaintiff,
tl!.JlE
ctRCUtr
couRr
oF rHE
lrtn
lypr:cnL
crRcur
ru aiiolon
irr]erur-
DADE
GOUNTY,
rr_onroe
'.
Yrr r!!r,
ctvtl
DtvtstoM
CASE
NO. 13-7628
CA 01
PEACE
CtTy
tNC.,
er at.,
Defendants.
/
The
undersigned
counset,
Ronier
Rodriguez
rv, Esq.
of Ronier
Rodr(]uez
tv,
p.A.
(hereinafter
referred
to as 'Defendanfs
counser),
henaby
fires this
Notirre
of Attorney,s
Charging
tien,
and
as grounds
herefore,
states
as follows:
1'
The
Defendant'
Peace
city,
lnc. (hereinafter
refered
to as
,,the
Defendanf,),
entered
into
an agreement
with
Defendant's
counser
("Representation
Agreement
),
whereby
he Defendant
retiained
the
legal
services
of the
Defendantls
Attonrey
to represent
its interests
in the above
captioned
matter-
A true
and correc{
copy
of the
Representation
Agreement
is attached
hereto
as Exhibit
?,,.
2'
As part
of the
Representation
Agreement,
the Defendant
agreed
to pay
the
"T"JJfs
counsel
the
sum
of 3sa/o
of any
recovery
whether
by setflement,
sare or
3'
The
tireless
efforts
by the
Defendarrfs
counsel
resulted
in a number
of well founded
legal
theories
fn f-avor
of the Defendant-
There
can be riftre doubt
ihat
the efforts
of tfte
Defendant's
counsel
resulted
in the
Defendant
entering
into a r"rorot"
set
ement
with fte Plaintiff
in
the instiant
action.
4-
Pursuant
to
the terms
of the
Representation
Agreement
the
Defendant,s
L
iii,i5i:i#"U"lflfxtt}3
iHai[.i:[lTffi"illrry
Fs.
t7
'+
z3
I
I
!
I
I
i
xL.,til
l--2-.
counselis
entitled
to the contracted
contingencypayment.
unfortunately,
the Defendant
has
been
working
with others,
including
counsel
for the
plaintiff,
in a concerted
effort to thwart
and eviscerate
its contractual
obligations
to the Defendant,s
counsel.
To date, the
undersigned
has not
been provided
with any of the signed
setflement
documents
or been
apprised
of the specific
terms.
5'
Florida
law states that a charging
Lien is an equitable
right of an attorney
to
have
costs and fees due to the attorney for
services rendered
in a legal
matter secured
to
hirn in the recovery
in that particular
suit, and that said liens
serve to protect
the rights
of the
attorney'
vazguez
vs- vazquez,
512 so.2nd lo4s(Fla.
3d DcA 1ggil,.
see a/so sinc/ari
rrs.
Eaucom,
428 so.Znd
1ggs(Fra.
1gg3);
Dowda
& Fietds,
p.A.
vs. cobb, 452 so.Znd
1140
(Fla'
1984)'
The
equitable
enforcement
of charging
Liens in the proceeding
in which they
arise best serves
to protect
the attome/s
rights for payment
of services
rendered
whire
pmtecting
the confidential
nature
of the attomey/client
relationship.
ln re:
wamefsEsfafe,
35 So.2nd
296 (Fla.
1S4B).
7'
The
undersi'gned
Attorney
has complied
with
all conditions precedent
to the
filtrrg of this
Notice
of Attorneys
charging
Lien, if any. Further,
it is undisputed
that the
unders(7ned
attorney
may recover
his/its
outstanding
attorney,s
fees
and costs from
any
cornueration
or money received
by the Defendant
or any agent
acting on its behalf in this
cixie.
WHEREFoRE,
Ronier
Rodriguez
IV, Esq of RonierRdriguez
rv,
p.A.,
requests
the
charging
Lien be imposed
on any proceeds
to be paki/received
by ffre
parties
to this astion,
to the extent
of the amount
due to the undersigned
Attomey, ptus
legal interest,
and for any
furlfrer rellef
as may deemed proper.
F"s"
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