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COMPLAINT AGAINST THOMAS M. WOODRUFF, ESQ.

Attorney THOMAS M. WOODRUFF, ESQ. (FL Bar No. 121693) has abused his role as attorney, his powers of Subpoena, and the filing and scheduling of legal proceedings for purposes of intimidation, harassment, and to create an unnecessary burden and NOT to forward any compelling legitimate need of his client and in so doing has failed to uphold his duty “to use the law’s procedures only for legitimate purposes and not to harass or intimidate others” (Rules Of Professional Conduct For Florida Lawyers, Preamble). Mr. Woodruff has intentionally joined with his client, a convicted spouse abuser and child abuser, to file a Complaint consisting of baseless allegations for the sole purpose of using our legal system to continue his client’s spousal abuse. 1. STEVEN T. FLAX was served a copy of the Complaint on 5/4/2009 for a new Civil Legal Action written and signed by Mr. Woodruff. Please see “Exhibit A.” The Complaint was served on Mr. Flax on the fourth floor of the Edgecomb Courthouse as Mr. Flax entered Judge Fernandez’s Courtroom for the beginning of his divorce trial with the apparent goals (1) of harassing and intimidating Mr. Flax as he was about to give testimony and (2) of generally disrupting a legal proceeding that is unrelated to Mr. Woodruff’s Complaint. Mr. Woodruff and his client, LINDA HART FLAX, were fully aware of Mr. Flax’s home and office addresses and that Mr. Flax was represented by Counsel who was available to receive service of Complaint. Mr. Woodruff had attended Mr. Flax’s wedding six (6) years earlier and employs the father of his client.
2. Mr. Woodruff’s 5/4/2009 Complaint alleged multiple causes of

action including allegations that are not recognized under Florida law and are outrageous. Mr. Woodruff knew or should have known that the numerous claims he raised are not supported by the material facts necessary to establish the same or would not be supported by the application of the existing law to those material facts. The allegations raised in the Complaint were false. Mr. Woodruff failed to perform rudimentary reasonable investigation of the Complaint’s multiple causes of action prior to filing. Mr.

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Woodruff filed his complaint with the sole purpose of using the judicial system and his role as officer of the court to INTIMIDATE and HARASS, and to compel Mr. Flax to spend funds to defend himself from Mr. Woodruff’s frivolous litigation.
3. Mr. Woodruff knew or should have known his client is an admitted

alcoholic, drug abuser, and convicted criminal who was arrested and convicted for abusing her disabled spouse, Mr. Flax, the Defendant. Mr. Woodruff knew or should have known his client had abused the Defendant for a period of years and attempted to murder the Defendant with a loaded handgun. Mr. Woodruff knew or should have known his client was arrested twice for DUI, twice for violations of Injunction For Protection From Repeat Domestic Violence and was arrested again for physically abusing Defendant’s fourteen-year-old daughter. Mr. Woodruff knew or should have known that his client was engaged in a divorce and was in an agitated emotional state, frequently intoxicated, and otherwise incapable of providing reliable information or making sound judgments.
4. On 5/13/2009, Mr. Woodruff had Mr. Flax served with a

SUBPOENA FOR TAKING DEPOSITION on 6/2/2009 (“Exhibit B”). Mr. Flax had long standing plans for foreign travel at that time for the purpose of retrieving foreign bank statements required in the divorce proceeding that Ms. Flax refused to produce. Mr. Flax sent letters and faxes and placed phone calls to Mr. Woodruff notifying him of the scheduling conflict and requesting a rescheduling of his deposition, offering five alternative dates. (Copies of these letters and faxes and a log of phone calls will be sent upon your request.) Instead of rescheduling the deposition, Mr. Woodruff insisted Mr. Flax honor his subpoena (“Exhibit C”). Mr. Flax believes that Mr. Woodruff was informed of Mr. Flax’s foreign travel plans to recover Ms. Flax’s Cayman Island bank statements and Mr. Woodruff specifically scheduled the date and time of taking Mr. Flax’s deposition for purposes of intimidation and harassment and to specifically interfere with an unrelated legal proceeding. By these actions, Mr. Woodruff has abused his subpoena powers and the Florida Bar’s Rules of Professional Conduct and should be sanctioned.
5. Mr. Woodruff’s Complaint alleges that Mr. Flax committed torts

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against Ms. Flax by his communication of truthful and accurate information about Ms. Flax’s six (6) arrest reports that are posted on the Internet by the Hillsborough County Sheriff’s Office and are public record. The truthful communications alleged by Mr. Woodruff are, in fact, victim impact statements from the victim of four (4) years of domestic violence and the statements were made to the State Attorney’s Office and to two Florida Judges. Mr. Woodruff has abused his role as officer of the court to create a chilling effect for the purpose of restricting Mr. Flax’s First Amendment right to Free Speech and for the purpose of undermining the legal process as it prosecutes a dangerous convicted criminal.
6. On August 20, 2009, the Honorable Judge Cook dismissed all

counts of Mr. Woodruff’s Complaint (“Exhibit D”) and gave Mr. Woodruff thirty (30) days to submit an Amended Complaint. On September 9, 2009, Mr. Woodruff dismissed his own Complaint “Without Prejudice” (“Exhibit E”). Clearly, Mr. Woodruff was well aware that his complaint was frivolous, without merit, and had no basis in Florida law. Nevertheless, Mr. Flax, a disabled physician on a fixed income, incurred over $3,000.00 in legal fees and costs and experienced severe emotional distress as a direct result of Mr. Woodruff’s frivolous Complaint. Mr. Flax is seeking to have Mr. Woodruff sanctioned for his abuses and to have Mr. Woodruff reimburse Mr. Flax’s legal fees and costs that are the direct result of Mr. Woodruff’s frivolous civil Complaint.

In conclusion, I respectfully request that you read Mr. Woodruff’s frivolous Complaint and consider that his client was arrested six (6) times, convicted (3) times, is an admitted substance abuser, while the Defendant has never been arrested, is disabled, and has been the victim of years of spousal abuse. I respectfully request that you consider that Mr. Woodruff is a close friend and the employer of Plaintiff’s father. I respectfully request that you (1) severely sanction Mr. Woodruff for his violations of the Rules Of Professional Conduct For Florida Lawyers, (2) order Mr. Woodruff to reimburse Mr. Flax for his costs and fees, and (3) impose any other sanctions that you deem appropriate.