TIKD Services LLC v. The Florida Bar et al

Filing 1

COMPLAINT For Damages and Injunctive Relief against All Defendants. Filing fees $ 400.00 receipt number 113C-10173266, filed by TIKD Services LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Civil Cover Sheet, #9 Summon(s) The Florida Bar, #10 Summon(s) Michael J. Higer, #11 Summon(s) John F. Harkness, #12 Summon(s) Lori S. Holcomb, #13 Summon(s) Jacquelyn P. Needelman, #14 Summon(s) Gold and Associates, P.A., #15 Summon(s) Mark S. Gold, #16 Summon(s) Ted L. Hollander, #17 Summon(s) Robert Azcano, #18 Summon(s) Jeffery R. Lotter, #19 Summon(s) Robert R. Willhoit)(Abadin, Ramon)

EXHIBIT 4

AT T O R N E Y S AT L AW

O N E B IS C A YN E T OW E R S U IT E 1500 TW O S O UT H B IS C A YN E B LV D . MIA MI , FL O R ID A 3313 1 -1822

www.sedgwicklaw.com

305. 670 . 4777

phone

877-540-6 951

Ramón A. Abadin
305.671.2124
[e-mail]

September 28, 2017
Via Email
Kellie Scott, Esq.
Chair, Unlicensed Practice of Law Standing
Committee
KD Scott Law
230 Sinclair Road
Tallahassee, FL 32312-2712
E-Mail: [e-mail]
Re: Unlicensed Practice of Law Investigation of Christopher Riley/TIKD.com
The Florida Bar Case No. 20174035(11B) & 20144045(11B)
Dear Ms. Scott:
Along with Gregory Coleman from the law firm of Critton Luttier Coleman, LLP, we represent
Christopher Riley and Tikd Services LLC (“Tikd”) in connection with the above-referenced UPL
complaints. Please direct all future communications regarding this matter to the attention of Mr.
Coleman and me.
The Florida Bar’s (the “Bar”) Eleventh Circuit UPL Committee B held a meeting regarding this
investigation on April 25, 2017. Thereafter, following the Bar’s UPL Standing Committee’s discussion
of this matter at its meeting in June 2017, the local committee recommended further proceedings. We
understand the UPL Standing Committee will take up consideration of these complaints against Tikd at
its meeting on October 13, 2017.
Although Mr. Riley appeared at the April meeting, it is not clear to us what facts and authorities will be
available to and considered by the Standing Committee at its upcoming meeting. As I am sure you
appreciate, Tikd takes these complaints and the Bar’s UPL investigative process very seriously. It is
critical to Mr. Riley and Tikd that the Standing Committee receive a complete and accurate picture of
Tikd’s business and fully understands Tikd’s position as to why it is not practicing law or fee-splitting. I
am also sure the Bar shares our interest in having as full and complete of an airing of the facts and
arguments as possible before the Standing Committee makes any recommendations with respect to this
investigation.
Therefore, we ask that Tikd be allowed to participate in the October 2017 meeting in the following
ways:
•

Mr. Riley appear in person to explain Tikd’s business;

fax

Kellie Scott, Esq.
Re: Unlicensed Practice of Law Investigation of Christopher Riley/TIKD.com
September 28, 2017
Page 2
•

Tikd’s counsel address the Standing Committee to explain why Tikd’s operations are not
the practice of law or fee-splitting; and

•

Tikd’s counsel cross-examine any person presenting evidence or argument against Mr.
Riley or Tikd.

The Bar’s investigation, prompted by a law firm perceiving unwelcome competition in its niche market,
has already caused substantial damage to Tikd’s relations with its customers and the independent Florida
licensed attorneys that provide services to those customers. However, so long as the Standing
Committee receives full and accurate information, we are confident the committee will agree that Tikd is
not practicing law or fee-sharing.
Please let us know by October 5, 2017, whether you will agree to allow Mr. Riley and Tikd to appear
and participate in the October meeting, so that we may have adequate time to prepare.
Thank you for your consideration of this request.
Very truly yours,
/s/ Ramón A. Abadin
Ramón A. Abadin
Sedgwick LLP
/s/ Gregory W. Coleman
Gregory W. Coleman
RAA/imc
cc:
John F. Harkness, Jr., Executive Director, The Florida Bar
Joshua E. Doyle, Executive Director Designee, The Florida Bar
Lori S. Holcomb, Division Director for Ethics and Consumer Protection, The Florida Bar
William A. Spillias, Unlicensed Practice of Law Counsel, The Florida Bar
Adam Rabinowitz, Board Liaison, Unlicensed Practice of Law Standing Committee
Manohar Athavale, Member, Unlicensed Practice of Law Standing Committee
Dwayne L. Dickerson, Member, Unlicensed Practice of Law Standing Committee
Gilbert J. Alba, Member, Unlicensed Practice of Law Standing Committee
Samuel H. Applebaum, Member, Unlicensed Practice of Law Standing Committee
Adrian N. Arkin, Member, Unlicensed Practice of Law Standing Committee
Amy D. Envall, Member, Unlicensed Practice of Law Standing Committee
Jose L. Estrada, Member, Unlicensed Practice of Law Standing Committee
Joel D. Fritton, Member, Unlicensed Practice of Law Standing Committee
Jerry R. Hall, Member, Unlicensed Practice of Law Standing Committee
Yolando Ann-Marie Hewling, Member, Unlicensed Practice of Law Standing Committee

Kellie Scott, Esq.
Re: Unlicensed Practice of Law Investigation of Christopher Riley/TIKD.com
September 28, 2017
Page 3
N. Abraham Issa, Member, Unlicensed Practice of Law Standing Committee
Paulita E. Kundid, Member, Unlicensed Practice of Law Standing Committee
Rupasri S. Lloyd, Member, Unlicensed Practice of Law Standing Committee
Susanne McCabe, Member, Unlicensed Practice of Law Standing Committee
Susan Papagikos, Member, Unlicensed Practice of Law Standing Committee
Paul Pelton, Member, Unlicensed Practice of Law Standing Committee
Jill K. Press, Member, Unlicensed Practice of Law Standing Committee
Linjé E. Rivers, Member, Unlicensed Practice of Law Standing Committee
Brian M. Rubright, Member, Unlicensed Practice of Law Standing Committee
Rosanna M. Schachtele, Member, Unlicensed Practice of Law Standing Committee
Joseph C. Simmons, Member, Unlicensed Practice of Law Standing Committee
Brendan A. Sweeney, Member, Unlicensed Practice of Law Standing Committee
Gary Van del Laan, Member, Unlicensed Practice of Law Standing Committee
André T. Young, Member, Unlicensed Practice of Law Standing Committee