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)

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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 ramon.abadin@sedgwicklaw.com 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: kellie.scott@kdscottlaw.com 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

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