The Florida Bar v. Alexa Martinez

CourtSupreme Court of Florida
DecidedJune 19, 2025
DocketSC2023-0421
StatusPublished

This text of The Florida Bar v. Alexa Martinez (The Florida Bar v. Alexa Martinez) is published on Counsel Stack Legal Research, covering Supreme Court of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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The Florida Bar v. Alexa Martinez, (Fla. 2025).

Opinion

Supreme Court of Florida ____________

No. SC2023-0421 ____________

THE FLORIDA BAR, Complainant,

vs.

ALEXA MARTINEZ, Respondent.

June 19, 2025

PER CURIAM.

We have for review a referee’s report recommending that

Respondent, Alexa Martinez, be found guilty of professional

misconduct in violation of the Rules Regulating The Florida Bar and

that she be suspended from the practice of law for 10 days and

publicly reprimanded. Both The Florida Bar and Martinez have

petitioned for review, challenging the referee’s findings of fact,

recommendations as to guilt, and the recommended discipline.1

1. We have jurisdiction. See art. V, § 15, Fla. Const. For the reasons discussed below, we approve in part and

disapprove in part the referee’s recommendations as to guilt and

findings in mitigation and aggravation. We also disapprove the

referee’s recommended discipline and instead suspend Martinez

from the practice of law for 90 days.

BACKGROUND

Martinez was a member of the Bar for just two months when

she was hired in February 2017 as an associate by Silverberg Brito,

PLLC (Silverberg). Silverberg terminated her employment less than

four months later.

After her employment was terminated, Martinez retained

possession of a USB drive belonging to Silverberg. Silverberg

demanded Martinez return the USB drive. She stated she would

return it, but she did not do so initially. After multiple requests by

Silverberg, Martinez returned the USB drive, but the drive was

empty. The referee found that Martinez’s deletion of the contents of

the USB drive constituted violations of rules 4-3.4 (Fairness to

Opposing Party and Counsel), 4-8.4(c) (“A lawyer shall not engage in

conduct involving dishonesty, fraud, deceit, or

misrepresentation . . . .”), and 4-8.4(d) (“A lawyer shall not engage

-2- in conduct in connection with the practice of law that is prejudicial

to the administration of justice . . . .”).

Also, after her employment was terminated, Martinez

attempted to negotiate with Silverberg about the language for a joint

letter to be sent to Silverberg’s clients on whose cases she worked.

The letter would have informed the clients of Martinez’s departure

from Silverberg, and it would have advised the clients that they

could proceed with Martinez as their attorney, stay with Silverberg,

or hire new counsel. These negotiations broke down, and Martinez

acted unilaterally to inform the firm’s clients of her departure from

Silverberg and their options going forward.

Silverberg claimed that when unilaterally contacting the

clients, Martinez disparaged and defamed Silverberg and its

attorneys to the firm’s clients and otherwise interfered with the

relationships between the clients and the firm. Silverberg also

claimed that Martinez unilaterally filed notices of appearance in

cases involving Silverberg’s clients without first notifying Silverberg

and without presenting proof that the clients chose to have her

represent them.

-3- Regarding Martinez contacting the clients, the referee

recommends finding that Martinez engaged in minor misconduct in

violation of rule 3-4.3 (Misconduct and Minor Misconduct).

Additionally, the referee recommends finding Martinez guilty of

violating rule 4-8.4(d) because in at least one case, Martinez filed a

notice without proper client authorization and unreasonably

delayed her withdrawal for about one month.

Because Martinez delayed returning the USB drive and began

contacting and filing notices of appearance in Silverberg’s clients’

cases, Silverberg sought injunctive and civil relief against Martinez.

In that civil case, Martinez filed several notices of unavailability,

which the Bar argues were improper. However, the referee did not

recommend finding Martinez guilty of any rule violations for this

because he did not believe Martinez’s notices of unavailability

constituted dishonest conduct warranting discipline given her lack

of experience at the time and the confusion surrounding the proper

uses of notices of unavailability.

ANALYSIS

Our review of a referee’s findings of fact is limited, and if the

findings of fact are supported by competent, substantial evidence in

-4- the record, we will not reweigh the evidence and substitute our

judgment for that of the referee. Fla. Bar v. Alters, 260 So. 3d 72,

79 (Fla. 2018) (citing Fla. Bar v. Frederick, 756 So. 2d 79, 86 (Fla.

2000)).

As for a referee’s recommendations as to guilt, “the referee’s

factual findings must be sufficient under the applicable rules to

support the recommendations.” Fla. Bar v. Patterson, 257 So. 3d

56, 61 (Fla. 2018) (citing Fla. Bar v. Shoureas, 913 So. 2d 554,

557-58 (Fla. 2005)). Ultimately, the burden is on the party

challenging the referee’s findings of fact and recommendations as to

guilt to demonstrate “that there is no evidence in the record to

support those findings or that the record evidence clearly

contradicts the conclusions.” Fla. Bar v. Germain, 957 So. 2d 613,

620 (Fla. 2007).

The USB Drive

The referee found that Martinez violated rules 4-3.4, 4-8.4(c),

and 4-8.4(d) by returning an empty USB drive to Silverberg.

Martinez challenges the referee’s factual findings regarding this

issue, whereas the Bar asks the Court to uphold the referee’s

findings of fact and recommendations as to guilt.

-5- Rule 4-3.4(a) states that a lawyer shall not “unlawfully

obstruct another party’s access to evidence or otherwise unlawfully

alter, destroy, or conceal a document or other material that the

lawyer knows or reasonably should know is relevant to a pending or

a reasonably foreseeable proceeding.” There is competent,

substantial evidence in the record that the contents of the USB

drive were subject to litigation between Martinez and the firm, with

the firm believing Martinez saved confidential firm files to the drive.

Martinez knew the contents of the USB drive were in question and

relevant to the litigation between her and the firm. Yet, she delayed

returning the drive and deleted its contents before finally returning

it. Thus, we approve the referee’s recommendation that Martinez be

found guilty of violating rule 4-3.4(a).

We, likewise, approve the referee’s recommendation that

Martinez be found guilty of violating rules 4-8.4(c) and 4-8.4(d).

Rule 4-8.4(c) prohibits a lawyer from “engag[ing] in conduct

involving dishonesty, fraud, deceit, or misrepresentation.” The

record supports a conclusion that Martinez acted dishonestly and

deceptively when she delayed returning the USB drive and deleted

its contents before finally returning it. And rule 4-8.4(d) prohibits a

-6- lawyer from “engag[ing] in conduct in connection with the practice

of law that is prejudicial to the administration of justice.”

Martinez’s act in deleting the contents on the drive was

prejudicial to the administration of justice because the contents of

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Related

The Florida Bar v. Frederick
756 So. 2d 79 (Supreme Court of Florida, 2000)
The Florida Bar v. Anderson
538 So. 2d 852 (Supreme Court of Florida, 1989)
The Florida Bar v. Forrester
818 So. 2d 477 (Supreme Court of Florida, 2002)
The Florida Bar v. Germain
957 So. 2d 613 (Supreme Court of Florida, 2007)
The Florida Bar v. Shoureas
913 So. 2d 554 (Supreme Court of Florida, 2005)
Florida Bar v. Rotstein
835 So. 2d 241 (Supreme Court of Florida, 2002)
The Florida Bar v. Madsen Marcellus, Jr.
249 So. 3d 538 (Supreme Court of Florida, 2018)
The Florida Bar v. Kelsay Dayon Patterson
257 So. 3d 56 (Supreme Court of Florida, 2018)
The Florida Bar v. Jeremy W. Alters
260 So. 3d 72 (Supreme Court of Florida, 2018)

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