The Florirle Bar

In quiry/C o mptrint Form

PART

oNE

(see Page

YourName,

r, paRT oIyE - comprainart rnformation.):

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:
If yes, howmany complaints have you filed?
Does this complaint pertain to a matter currently in litigation? yes

PART TWO (See Page

Attomey's

Name:

1,

[l,

PART TWO

wi e L

Address:

City, State, Zip_Code:

Telephone:3oS

yes

N-=

No fl

- Attorney Information.):

A* J, i nvc?

-*s

l*

11

00

PART TEREE (see Page 1, PART TEREE Facts/Arlegations.):

The specific thing or things
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

Vg*
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E.

787

+ 23

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PART F0UR (See Page 1, PART FOUR

allegations are: [see attached sheet].

Witnesses.): The witnesses in support of my

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

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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
have no problem with the agreement as modified as long as you understand
that I will not be
advancing any costs in this litigation,,.

"I

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.

the same day (September 2n 2013) and after about more than 5 hours Mr
Roniel Rodriguez
1!o,
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

P-s. 3

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L3

,l

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 saidAIso, it was my understanding according to
person's entity already paid for his retention.

Mr Roniel Rodriguez IV himself, that this third

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
August and September. (See Exhibit A and Exhibit H).
And I am attaching the differences as Exhibit K.

rv signature marks are different in

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 reaffirm 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
yo.ice message and

l6h

2013

r got a called from Mr Roniel Rodriguez IV that phone call went to

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
lawyer and is still looking for compensation.

,iril;;1"";'r"ili

Finally, about Mr Roniel Rodriguez tV:

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
Sce'nario

else paid him?

scenario 2: rf he w-as
my lawyer why he made me signed the property over a third party
-not
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

called me when the case was done if he was not my lawyer, but
knowing that
lawyer? He should it talked to my lawyer, right?

already have a

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
Through their
machinations, they recovered this sum for themselves as a settlement
"*i.rr...
;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 courtapproved 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

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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. weisblige p.o-ired to speak to Mr. Rodriguez about
the matter and then to call me in two hours.
)

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
.,key
telling u.. n"a.ig, ez thatt
witness,,. Their
-as'a
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
and what steps t"o tuil" r"xt. I just wanted
to
be rid of what had come to be source
"urlfo, _".
of great Airir"r,
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 pu*,
to
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".
property to JRS which he and Mr.
Weisberg had advised me to make.
"r-,

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
u.,rog"*"nt with JRs and_ Kalb,,, that JRS paid him
Ttr F."contact'Mr.
a $50,000
"retainet'', and that I should
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
property to his crony' Stuart
$50,000 of anticipated deposition costs by having me transfer my
Kalb then pays Mr. Rodriguez not the ,g.t.d-rrpon $50,000 cost advance, but a $50,000
and becomes Mr'
nonrefundable retainer, at w*ch point Mr. Roariguez throws me under the bus
canon of ethics'
Kalb,s attomey. This sordid mess has to be involve multiple violation of the Bar's

based
While I certainly had good reason to doubt Mr. Rodriguez was still acting as my attorney
with
communication
upon his conduct, his imarks, and his otherwise general lack of meaningful
the subject lawsuit'
me, he later took the position he had in fact remained my attorney throughout
the suit by
settled
help
their
with
After I discharged him, retain ed, Kravitz & Guerra, and
lien against me
conveying all my interest in the subject property back to Faro, he filed a charging
though he knew I
on Seitemb er 2A,2013 seeking to enfoice iris iontingency fee agreement even
After initially
to
JRS'
had transferred the property *t i.fr was the source of his contingency fee
he filed his own
refusing to sign a stipiation of substitution of counsel with Kravitz & Guena,
he also filed a
motion to withdraw as my attorney on September23,2013' On the same day,
for JRS to
attomey
Motion to Intervene on behalf of JRS. His purpose was now to act officially as
what purpose has still
enforce its claim to the property which he iounseled me to give to JRS for
never been made clear to me or put in writing-

On Octobe

had
r 16, ZOl3,Mr. Rodriguez attended a hearing to confirm the settlement agreement II was

am not Sure' since

reached with Faro in the subjectlawsuit. In what capacrty he appearcd,I
a settlement with
represented by Kravitz & Guerra at this hearing. The day before, he negotiated
of
their claim to the
release
the
for
Faro on behalf of JRS. He and JRS receiveo $6o,ooo from Faro

Mr'
property, a claim they only had because I transferred my property to JRS on the advise of
was
ifoO.igo", and Mr. Weisberg. This can't be right. My purpose in deeding the property to JRS
It
away'
property
the
give
or
never-entirely clear to me, but I always believid it was never to sell
renovtte
funds to
was suppos"d to b. a means of financing the costs of the litigation and obtaining
or now' But
then
tell
I
could
as
far
as
the property while making it harder foiFaro to recover it,
could
afforneys,
how this arrangement, which was conceived and recofllmended to me by my own
by Mr'
have ended upputtin! $60,000 in their pockets is a mystery to me. If I wasn:t defrauded
in his
me
failed
case,
my
me
about
Rodriguez, ne at leai failed to adequatlly communicate with
duty
his
in
duty Jf loyalty by representing or appearing to represent opposing interests, and failed
covering
of care Uynegtecting to take proper steps to protect my interests by a written agreement
me
abandoning
by
and
to
JRS
the purpose, terms, ind conditions of my transfer of the property
shares
and
after the transfer. Mr. Weisberg was my also my attomey throughout this whole affair
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)
with Mr' rawrence thru e-rnail
He is not in ofice today.
r have nottark

[illffiffi::::::i-0".d

:*m:*iI[f#*#::ffi "#r:;"1,#",*::*:,"xtilj{*;*,T*.#
Thanks,

Frcm: Ron@RiRfirm.corn
ubiect: Re; Modified Agrement

Signed

*ton, 2Sep 2O13 1151:16

3rT.
;rfr'
To : ka relso
ucre @ hotma il-com

I have no problem
with the agreelnent as modifred
as long as you understand
athrancirqga* ** in
that r will not be
this litigatbn.

Regards,
Ron Rodr{guez IV

Roniel noOrtgrez w, pe,

Direct Fns (305) T7-?-4S7S

;ffi";ffi
:-l=r!

Ron@

RJ

Rfi rm. ccnn

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

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fxhitit
RE: Dtodified Agreemenr
Sigued

Froetr(ertrsoucrer%
v-

Se* &ton gtgzJt3 lU;=ZFl3rt

To: nsri*noerigrqfy,p;1 (rw@drfie-coe)
tf I stsn 10ur ordgfnal
agrEefne4 win

pu

be s,,lt advancirqg atl os-

ofrt* ritia60n?

?nu

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Ron@RJRfirm.com
IT-t
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
eleectations already set by ttrai trm
I arn no longer inhrested in this
case. your

trc

case is not ilt certain and ctearcut

as that
lack of orporate furmalitythat
a corporation's aasets'

is

t.m r,.taivr*J 1ou- There nras crearry

."quioo when airpoJ"gof alt orsubstantially a
all of

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,

Ron Rodriguez tV

?*.

t3

rrEm: ffDrtg,R Rfirm-com

fubjece Re: Meeting
Ttre, 3 Sep ZO13 OgS4:57
9*=
To : karebouee@ hotmail-com

-O4OO

tt.i[

be back at my sfHce at 11:3oamwe can disc,ss at tfiattime the possibiritgof

@reringa{I sf the ritigau:on costs
and fees to be incurrea tiro,gh
triar-

third party

negards,

bn Rodrig,uz lV
RoniE{ Rodriguez fV, p.A

DirEct

llnq (305) T7W7S

E*na il: Ron @ &lRfirm - corr:

E=

b-

7n5. |

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I.T
o : ka relsoucre@
r

hotmail.co m

Subject peace Crtyto JRS

Date: we4 4Sep 2013
u)fr725+@
l(arel,

am not a'railable for ttre

rest of this week' However,
fified' while I am interested
the Ansrrrer and Affirmatirre
in any inforrnation p,
Defenses ha,e beeo
comrnenced disevery'
-"y-rr"o, *"r 1, no u,gn.y since we harre not
I have some time
yet
at the end orf nerrt reek
if yrcu wirdei rfte to meet
More
initiai-retai,nerof S5o,ooo{}o,
so*ris matrerwitr
I

ffifEft[::#"*-;;;ilJr,-*no"ore
Regards,

SArart

?*2"
E-

IL

o+ 1-L 5

x1,.;1,',f

tl!.JlE ctRCUtr couRr oF

rHE lrtn
crRcur ru aiiolon
lypr:cnL
irr]erur'. Yrr r!!r,
DADE

THIS FARO INTERNATIONAL,

LLC,

GOUNTY, rr_onroe

ctvtl DtvtstoM

Plaintiff,

CASE NO. 13-7628 CA

01
PEACE CtTy tNC., er
at.,

iii,i5i:i#"U"lflfxtt}3

Defendants.

iHai[.i:[lTffi"illrry

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
he Defendant retiained the
), whereby
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'

"T"JJfs

As part of the Representation

Agreement, the Defendant
agreed to pay the
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
founded legal theories
well
fn f-avor of the DefendantThere 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

Fs.

t7 '+ z3

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'

!
I

I
i

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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AGREEI' TO AJI'D ACCEfITTiD

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RO}IIEL R{}DRIGUEZ f}-, P.A.

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