Supreme Court of Florida ____________
No. SC2020-1602 ____________
THE FLORIDA BAR, Complainant,
vs.
BRUCE JACOBS, Respondent.
June 8, 2023
PER CURIAM.
Respondent, Bruce Jacobs, seeks review of a referee’s
amended report recommending that Jacobs be found guilty of
multiple violations of Rule Regulating The Florida Bar (Bar Rule) 4-
8.2(a) (Impugning Qualifications and Integrity of Judges or Other
Officers) and recommending that he be suspended from the practice
of law for 90 days. 1 Jacobs challenges the referee’s findings of fact
and recommendations as to guilt, arguing that while he did impugn
the integrity of members of the judiciary, his statements were
1. We have jurisdiction. See art. V, § 15, Fla. Const. neither dishonest nor made with reckless disregard for the truth
and therefore did not violate Bar Rule 4-8.2(a). The Bar asks this
Court to approve the referee’s findings of fact and recommendations
as to guilt but challenges the referee’s recommendation as to
discipline, urging this Court to instead impose a two-year
rehabilitative suspension. For the reasons discussed below, we
approve the referee’s findings of fact and recommendations as to
guilt, but we disapprove the referee’s recommendation as to
discipline and instead impose a 91-day rehabilitative suspension.
BACKGROUND
Jacobs, a veteran foreclosure defense attorney, has developed
a set of legal theories that he has often argued on behalf of clients.
His theories are based on the premise that a party seeking to
foreclose on a defaulted mortgage should not be able to collect an
equitable remedy if it came to the court with unclean hands. More
specifically, Jacobs’ theory is that in cases where a homeowner who
borrowed money to purchase a home is now in default on
payments, the holder of the note should not be allowed to enforce
the note or foreclose on the mortgage if any faulty or defective
assignments occurred after the closing on the note and mortgage.
-2- Relevant to this case, Jacobs attempted to assert his theory in
three separate foreclosure proceedings below, but his arguments
were rejected. Jacobs then filed in those cases motions that
included negative comments and accusations about courts and
specific judges. This resulted in the Bar filing a three-count
complaint against Jacobs alleging that he had impugned the
qualifications or integrity of members of the judiciary. The Bar
complaint was referred to a referee, who held hearings on both guilt
and discipline and then submitted an amended report with the
following findings and recommendations.
Count I
Jacobs represented the defendant in a foreclosure action in
HSBC Bank USA, National Association v. Aquasol Condominium
Association, Inc., No. 2013-29724-CA-01 (Fla. 11th Cir. Ct.). After
the circuit court entered a final judgment of foreclosure in favor of
the plaintiff bank, Jacobs filed an appeal in the Third District Court
of Appeal. Jacobs argued that the bank had no standing to
foreclose because it was not both holder and owner of the note.
Although Jacobs was aware of binding Third District case law
stating that a party has standing in a foreclosure suit if it is either
-3- the holder or the owner of the note, he did not cite this authority in
his appeal.
When the Third District affirmed the judgment of foreclosure,
Jacobs moved for rehearing en banc. In that motion, Jacobs made
“numerous comments impugning the integrity of the judiciary,”
including:
This Court’s insistence on ignoring established Florida Supreme Court law to benefit bad corporate citizens is certain to cause chaos. .... Ownership controls the right to enforce the mortgage. This Court is acting illegally by instructing the law is otherwise. .... This is a biblical, spiritual journey for me. I have faith I will be protected because I am acting so clearly within the law and this Honorable Court is not. .... Banks have all the resources to do it right but made business decisions to do it fraudulently. It’s as if they knew the Courts would always let them get away with it. . . . I call those judges traitors to the constitution. .... I’ve had to warn [clients] this broken system is riddled with fraud and perjury. The judges decide the rule of law, and whether any rule of law exists. Maybe the rule of law only applies to the rest of us. .... Any court that protects the monopoly over the rule of law is a traitor to the constitution and should be tried for treason.
-4- After issuing an order directing Jacobs to show cause why he
should not be sanctioned, the Third District issued an order
declaring that Jacobs had filed a frivolous bad faith motion and had
impugned the qualifications or integrity of the judiciary in violation
of Florida Rule of Appellate Procedure 9.410(a). The Third District
referred the matter to the Bar for consideration of discipline.
Aquasol Condo. Ass’n, Inc. v. HSBC Bank USA, Nat’l Ass’n, 43 Fla.
L. Weekly D2699 (Fla. 3d DCA Dec. 5, 2018).
Count II
Bank of New York Mellon v. Atkin, No. 2009-87096-CA-01 (Fla. 11th
Cir. Ct.). During the proceedings, Bank of America, a named
subject in matters raised in that case, filed a petition for writ of
prohibition in the Third District, which prompted a response from
Jacobs along with a motion to disqualify the Third District. See
Bank of Am., N.A. v. Atkin, 303 So. 3d 583, 586 (Fla. 3d DCA 2018).
In his response to the bank’s petition, Jacobs made several negative
comments about the Third District and circuit court judges,
-5- [T]his Court violated the standard of review, ignored Florida Supreme Court precedent, and falsified the facts in contradiction to the record. .... The impartiality of this Court is objectively questioned and it cannot issue a ruling with integrity in this case. .... A named circuit court judge acted with “blatant disregard for the rule of law and the client’s constitutional rights” in an unrelated case and was upheld by this Court. .... A different, unnamed circuit court judge changed a favorable ruling because opposing counsel “threw a fundraiser for the new judge who rotated into the division.”
The Third District concluded that Jacobs’ statements, together
with statements he made in a brief filed in the United States
Supreme Court, impugned the qualifications and/or integrity of
members of the judiciary. After issuing an order to show cause, the
Third District entered an opinion referring Jacobs to the Bar for
consideration of discipline. Bank of Am., N.A. v. Atkin, 271 So. 3d
145, 147 (Fla. 3d DCA 2019).
Count III
Bank of New York Mellon v. Atkin. During the proceedings, Jacobs
filed a motion for judicial disqualification in which he made several
-6- negative comments about the circuit court and about the presiding
circuit court judge, Judge Michael Hanzman, including:
Judge Hanzman Has Repeatedly Ignored Obvious Fraud on the Court by Large Financial Institutions in Foreclosures While Abusing His Power to Chill Defense Counsel’s Zealous Advocacy Against Those Financial Institutions[.] .... Judge Hanzman has made repeated statements on the record and off the record that reflect his indifference to large financial institutions presenting false evidence to the court to obtain the equitable relief of foreclosure. His personal finances appear to be heavily invested in the financial services sector which gives Mr. Atkin a reasonable fear Judge Hanzman will not be fair and impartial because it will negatively impact his significant personal financial holdings. .... [The court] has allowed the most rich and powerful segment of our society, the financial sector in which he is personally heavily invested in, to engage in felony misconduct and walk away without any punishment . . . .
The circuit court dismissed Jacobs’ motion to disqualify for
being untimely and legally insufficient. Later, in an order denying a
motion for attorney’s fees, Judge Hanzman noted Jacobs’ repeated
failure to cite adverse controlling authority and mentioned Jacobs’
“scurrilous motion to disqualify this Court.” Judge Hanzman
declared that Jacobs “is unrepentant, undeterred, and continues to
-7- engage in the exact same behavior he was sanctioned for and which
is now presumably being investigated by the Bar.”
The referee ultimately found as to all three counts that Jacobs
made statements that impugned the qualifications or integrity of
members of the judiciary and that he did so intentionally as a
litigation tactic to obtain relief when he was unable to obtain relief
without such attacks. The referee recognized that attorneys have
an obligation to advocate zealously on behalf of clients but found
that Jacobs’ actions crossed a line into name-calling and violated
Bar Rule 4-8.2(a). The referee further found that Jacobs did not
provide an objectively reasonable factual basis for making any of his
statements impugning the integrity of the judiciary.
Jacobs asserted a selective prosecution defense in the
disciplinary proceeding, but the referee rejected the defense, finding
that the presented evidence did not establish the elements of
selective prosecution articulated in Thompson v. Florida Bar, 526 F.
Supp. 2d 1264 (S.D. Fla. 2007). The referee explained that the
conduct of other attorneys described by Jacobs was not the same
type of conduct Jacobs had been charged with and that “the case
law is replete with lawyers from assorted and various practice areas
-8- who have been prosecuted and disciplined for the same rule
violations as those which have been alleged against respondent
herein.” The referee also found that Jacobs had been afforded due
process at every stage.
Jacobs asserted other defenses as well, based on his history of
mental health issues, his expressions of remorse, and his
subsequent corrective behavior. The referee rejected these
defenses, finding that they did not negate guilt, but she noted that
the underlying facts could serve as potential mitigation when
determining the appropriate discipline.
Based on these findings, the referee recommends that Jacobs
be found guilty of three counts of violating Bar Rule 4-8.2(a).
However, the referee found that the Bar failed to prove that Jacobs
violated Bar Rule 4-3.3(a)(3) (False Evidence; Duty to Disclose) and
so recommends that Jacobs be found not guilty of violating that
rule. Neither party challenges the referee’s findings or
recommendation as to Bar Rule 4-3.3. For discipline, the referee
recommends that Jacobs be suspended from the practice of law for
90 days.
-9- ANALYSIS
A. The Referee’s Findings of Fact and Recommendations as to Guilt.
Jacobs challenges the referee’s findings of fact and
recommendation that he be found guilty of violating Bar Rule 4-
8.2(a). When we review a referee’s findings of fact, our review is
limited; when a referee’s findings are supported by competent,
substantial evidence in the record, we will not reweigh the evidence
and substitute our own judgment for that of the referee. See Fla.
Bar v. Alters, 260 So. 3d 72, 79 (Fla. 2018) (citing Fla. Bar v.
Frederick, 756 So. 2d 79, 86 (Fla. 2000)). When reviewing 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). Ultimately, the party challenging a referee’s findings of fact
or conclusions as to guilt has the burden to demonstrate that there
is no evidence in the record to support the referee’s findings or that
the record evidence clearly contradicts the referee’s conclusions.
Fla. Bar v. Germain, 957 So. 2d 613, 620 (Fla. 2007).
- 10 - The case before us concerns Bar Rule 4-8.2(a), which provides:
“A lawyer shall not make a statement that the lawyer knows to be
false or with reckless disregard as to its truth or falsity concerning
the qualifications or integrity of a judge . . . .” Although the
language of Bar Rule 4-8.2(a) invites comparison to civil defamation
standards, we have held that the defamation test articulated in New
York Times Co. v. Sullivan, 376 U.S. 254 (1964), does not apply in
these circumstances. See Fla. Bar v. Ray, 797 So. 2d 556, 559 (Fla.
2001). Instead, we use an objective test, asking if the lawyer had
“an objectively reasonable factual basis for making the statements.”
Id. Thus, once the Bar presents evidence establishing that a lawyer
made statements concerning the qualifications or integrity of a
judge, the burden shifts to the respondent to provide an objectively
reasonable factual basis for making the statements. Id. at 558 n.3.
Here, we approve the referee’s findings of fact on the charged
violations of Bar Rule 4-8.2(a). Addressing Count III first, Jacobs
filed a motion in Bank of New York Mellon v. Atkin in which he made
several assertions about circuit court judge Michael Hanzman,
including that Judge Hanzman “repeatedly ignored obvious fraud
on the court by large financial institutions in foreclosures” and
- 11 - “made repeated statements on the record and off the record that
reflect his indifference to large financial institutions presenting false
evidence to the court.” Jacobs further asserted that Judge
Hanzman “has allowed the most rich and powerful segment of our
society, the financial sector in which he is personally heavily
invested in, to engage in felony misconduct and walk away without
any punishment in violation of the Judicial Canons and the rule of
law.”
These remarks (and others made in Jacobs’ motion) clearly
comment on the integrity of a member of the judiciary. In fact,
Jacobs admits that his statements impugned Judge Hanzman’s
integrity; he only denies that his statements were false or made
with reckless disregard for the truth. However, Jacobs did not
establish that he had an objectively reasonable basis for making the
offending statements. He did not introduce at the disciplinary
hearings any documents that were “obviously” fraudulent on their
face but admitted into evidence by Judge Hanzman. Nor did he
present evidence showing that Judge Hanzman’s personal finances
would have been substantially impacted by the outcome of Atkin
such as to potentially establish an objectively reasonable basis to
- 12 - accuse the judge of allowing banks to commit felony misconduct to
protect his own financial interests. And while some witnesses who
testified at the disciplinary hearings endorsed Jacobs’ legal theories
about foreclosure defense, no witness testified that Judge Hanzman
(or any judge) had knowingly accepted fraudulent evidence or
colluded with financial institutions.
However firmly held Jacobs’ interpretations of foreclosure law
may be, his specific legal theories about facts that purportedly
establish unclean hands are not supported by case law out of the
Third District. Even so, while the testimony elicited at the
disciplinary hearings might suggest that Jacobs had a basis to
believe his interpretations of foreclosure law and unclean hands
were legally correct, the question before us is not whether Jacobs
was right that the Third District misinterpreted foreclosure law.
The question is whether Jacobs was entitled to impugn the integrity
of judges who ruled against him. In the absence of evidence
showing misconduct, collusion, or defiance of established law,
Jacobs has not demonstrated that he had an objectively reasonable
factual basis to accuse Judge Hanzman of allowing banks to
commit felony misconduct to benefit his own financial interests,
- 13 - especially when Judge Hanzman’s actions could be explained as
simply following controlling case law out of the Third District.
As to Counts I and II, our analysis is largely the same. The
Bar introduced motions in which Jacobs accused both named and
unnamed judges of acting outside the law, allowing banks to
perpetrate fraud with impunity, and betraying the Constitution to
protect the interests of financial monopolies.
There is no dispute that Jacobs made the statements
identified by the referee, and those statements clearly concerned the
qualifications or integrity of members of the judiciary. Thus, the
burden shifted to Jacobs to show that he had an objectively
reasonable factual basis for making the offending statements. As
with Count III, Jacobs did not introduce any documents that were
either proven or obviously fraudulent/falsified, nor did he elicit any
testimony that actions taken by a criticized court were illegal or
done to shield a financial institution from consequences.
Instead, Jacobs elicited testimony from attorneys and judges
who spoke of Jacobs as a true believer, a man whose legal theories
had been met with some success at the trial court level. These
witnesses testified that some courts had been receptive to Jacobs’
- 14 - unclean hands defense while other courts had rejected it. These
witnesses essentially testified that there was legal support for
Jacobs’ unclean hands defense, and they opined that Jacobs’
arguments were made in good faith.
However, if Jacobs’ legal theories on foreclosure defense were
embraced by controlling case law, he could have presented copies of
relevant appellate decisions and trial court rulings that might show
he had a reasonable basis to criticize judges who refused to follow
that controlling law. But Jacobs did not present any evidence
showing that a circuit or district court judge had defied established
law to benefit a financial institution or that any judge’s finances
would have been substantially affected by the outcome of a case
such that he or she was required to be disqualified from it.
Accordingly, Jacobs did not meet his burden of establishing that he
had an objectively reasonable factual basis to make his statements
which impugned the integrity of those judges.
Ultimately, the record clearly supports the referee’s finding
that Jacobs made statements in three separate legal proceedings
that impugned the integrity of members of the judiciary, and Jacobs
has failed to show that he had an objectively reasonable factual
- 15 - basis for making the statements. Because the record evidence does
not clearly contradict the referee’s recommendation that Jacobs be
found guilty of three violations of Bar Rule 4-8.2(a), we approve the
referee’s findings of fact and recommendations as to guilt.
We also find no merit in Jacobs’ challenge to the referee’s
rejection of his selective prosecution defense. Jacobs argues that
the Bar failed to prosecute bank attorneys who purportedly
committed various Bar Rule violations, but even assuming those
bank attorneys did violate Bar Rules, their conduct does not excuse
misconduct by Jacobs, and their alleged violations are not the same
type of misconduct Jacobs is charged with here such as to suggest
a selective prosecution. Moreover, Jacobs does not address the
many attorneys in various practice areas who have been brought up
on similar disciplinary charges to those raised against Jacobs in
this case. We therefore approve the referee’s rejection of Jacobs’
selective prosecution defense.
B. The Referee’s Recommendation as to Discipline.
In reviewing a referee’s recommended discipline, this Court’s
scope of review is broader than it is when we review a referee’s
findings of fact, for it is ultimately this Court’s responsibility to
- 16 - order the appropriate sanction. Fla. Bar v. Kinsella, 260 So. 3d
1046, 1048 (Fla. 2018); Fla. Bar v. Anderson, 538 So. 2d 852, 854
(Fla. 1989); see also art. V, § 15, Fla. Const. Prior to making a
recommendation on discipline, a referee must consider this Court’s
existing case law and the Florida Standards for Imposing Lawyer
Sanctions (Standards), which are subject to aggravating and
mitigating circumstances. See, e.g., Fla. Bar v. Abrams, 919 So. 2d
425, 430 (Fla. 2006); Fla. Bar v. Temmer, 753 So. 2d 555, 558 (Fla.
1999).
From our review of the referee’s report, we do not find that the
referee’s recommended 90-day non-rehabilitative suspension is
reasonable under the facts and circumstances of this case.
However, we also reject the Bar’s recommended sanction of a two-
year rehabilitative suspension.
As to the Standards, the referee concluded that Standard
7.1(b) is applicable to this case. Standard 7.1(b) states that
suspension is appropriate when a lawyer knowingly engages in
conduct that is a violation of a duty owed as a professional and
causes injury or potential injury to a client, the public, or the legal
system. Fla. Std. Imposing Law. Sancs. 7.1(b). We agree that
- 17 - Standard 7.1(b) is applicable given the finding that Jacobs’ conduct
was a deliberate litigation tactic.
As to aggravation and mitigation, the referee found the
existence of three aggravating factors: a pattern of misconduct;
multiple offenses; and substantial experience in the practice of law.
See Fla. Std. Imposing Law. Sancs. 3.2(b)(3), (4), (9). The referee
also found the existence of three mitigating factors: absence of a
prior disciplinary record; personal or emotional problems; and
character or reputation. See Fla. Std. Imposing Law. Sancs.
3.3(b)(1), (3), (7).
Neither party challenges the referee’s findings on Jacobs’
substantial experience in the practice of law or multiple offenses as
aggravators. Moreover, the referee’s finding of a pattern of
misconduct is supported by the record, as evidence showed that
Jacobs engaged in similar tactics and used impugning language in
cases where judges rejected his theories of foreclosure defense.
The Bar argues, however, that the referee should have found
an additional aggravator under Standard 3.2(b)(7): refusal to
acknowledge the wrongful nature of the conduct. “Like other
factual findings, a referee’s findings of mitigation and aggravation
- 18 - carry a presumption of correctness and will be upheld unless
clearly erroneous or without support in the record. A referee’s
failure to find that an aggravating factor or mitigating factor applies
is due the same deference.” Germain, 957 So. 2d at 621 (internal
citation omitted).
We find that the referee’s rejection of “refusal to acknowledge
the wrongful nature of the conduct” as an aggravating factor is not
without record support, even though the referee rejected “remorse”
as a mitigating factor. Essentially, the Bar treats the absence of the
existing mitigating factor of remorse as being equivalent to the
existence of the aggravating factor of refusal to acknowledge the
wrongful nature of one’s conduct. But during the final hearing and
in his briefs on review, Jacobs admitted to behaving disrespectfully
by using strong and offensive language against judges, and he
testified that he has apologized to those judges and has sought
treatment for his anger. Thus, while the record supports that
Jacobs is not remorseful about violating Bar Rule 4-8.2(a) (because
he believes he did not violate the rule as worded), the record also
supports a finding that Jacobs has not refused to acknowledge “the
wrongful nature” of his conduct. Accordingly, the Bar has not
- 19 - shown that the referee’s rejection of this additional aggravating
factor was clearly erroneous or without record support.
As to mitigation, the Bar only challenges one of the found
mitigators: the existence of personal or emotional problems. The
Bar argues that if Jacobs’ long-term emotional problems were the
cause of his misconduct, then they should not be deemed a
mitigating factor. However, the referee did not find that Jacobs’
emotional problems were the cause of his behavior; she found that
Jacobs’ behavior was a tactical decision employed to frustrate
judges into disqualifying themselves. Because the Bar’s argument
is based on facts not found by the referee and because multiple
witnesses testified that Jacobs has a history of emotional issues,
the record supports the referee’s finding of this mitigating factor.
Turning to existing case law, the referee cited Florida Bar v.
Norkin, 132 So. 3d 77 (Fla. 2013), where this Court rejected a
recommended 90-day non-rehabilitative suspension and instead
imposed a two-year suspension, which required the attorney to
demonstrate rehabilitation. Norkin does indeed bear many
similarities to the present case. The respondent in Norkin was
disciplined for (among other offenses) impugning the integrity of
- 20 - members of the judiciary, and the referee there found that the
respondent acted as he did to obtain judicial disqualifications that
he was unable to obtain otherwise. Id. at 80-81. In our decision in
Norkin, we compared the circumstances of that case to those in
Florida Bar v. Abramson, 3 So. 3d 964 (Fla. 2009), where similar
unprofessional behavior required a rehabilitative suspension. 132
So. 3d at 91. Notably, the referee in Norkin also found the existence
of multiple aggravating factors—including multiple offenses and
pattern of misconduct, both of which were found in this case. Id. at
87. We approved the referee’s findings and recommendations as to
guilt in Norkin, but we rejected the recommended 90-day non-
rehabilitative suspension and instead suspended the respondent for
two years. Id. at 93.
The Bar urges us to sanction Jacobs with a similarly lengthy
period of suspension in this case. However, it is important to note
why a two-year suspension period was appropriate in Norkin. While
some of the aggravators found in Norkin were also found in this
case, the referee in Norkin found four additional aggravators as well,
including that the respondent had previous disciplinary offenses.
Id. at 91. The referee here, by contrast, found that the absence of
- 21 - any prior disciplinary record was a mitigating factor for Jacobs.
Thus, while we agree with the Bar that Jacobs’ misconduct is of
such nature that a demonstration of rehabilitation is needed before
he is readmitted, particularly in light of his multiple offenses and
pattern of misconduct, we do not agree that two years is the
appropriate period of suspension.
The Bar directs this Court to other, more recent cases such as
Florida Bar v. Patterson, 330 So. 3d 519 (Fla. 2021), where we
imposed a two-year suspension on an attorney who violated Bar
Rule 4-8.2 and other Bar Rules. But like the attorney in Norkin, the
attorney in Patterson had significant prior disciplinary action; in
fact, we expressly declared that the appropriate sanction in
Patterson “turn[ed] largely on the relationship between th[at] case
and Patterson’s previous disciplinary proceeding . . . .” Id. at 521.
Recall that the absence of a prior disciplinary record in this case
was found to be a mitigating factor.
Accordingly, we find that the circumstances of this case,
including the relevant aggravation and mitigation, require that
Jacobs demonstrate rehabilitation before he is readmitted, but we
find that a two-year suspension is inappropriate in light of Jacobs’
- 22 - absence of previous disciplinary offenses. We therefore reject the
referee’s recommended 90-day non-rehabilitative suspension and
instead impose a 91-day rehabilitative suspension.
CONCLUSION
For the reasons discussed above, we approve the referee’s
report as to the findings of fact and recommendations as to guilt
but disapprove as to the recommended discipline. Bruce Jacobs is
hereby suspended from the practice of law for 91 days. The
suspension will be effective thirty days from the filing of this opinion
so that Jacobs can close out his practice and protect the interests
of existing clients. If Jacobs notifies this Court in writing that he is
no longer practicing and does not need thirty days to protect
existing clients, this Court will enter an order making his
suspension effective immediately. Jacobs shall fully comply with
Rules Regulating The Florida Bar 3-5.1(h) and 3-6.1, if applicable.
In addition, Jacobs shall accept no new business from the date this
order is filed until he is reinstated. Jacobs is further directed to
comply with all other terms and conditions of the report.
Judgment is entered for The Florida Bar, 651 East Jefferson
Street, Tallahassee, Florida 32399-2300, for recovery of costs from
- 23 - Bruce Jacobs in the amount of $10,671.75, for which sum let
execution issue.
It is so ordered.
MUÑIZ, C.J., and CANADY, LABARGA, COURIEL, GROSSHANS, and FRANCIS, JJ., concur. SASSO, J., did not participate.
THE FILING OF A MOTION FOR REHEARING SHALL NOT ALTER THE EFFECTIVE DATE OF THIS SUSPENSION.
Original Proceeding – The Florida Bar
Joshua E. Doyle, Executive Director, The Florida Bar, Tallahassee, Florida, Patricia Ann Toro Savitz, Staff Counsel, The Florida Bar, Tallahassee, Florida, and Tonya L. Avery, Bar Counsel, The Florida Bar, Miami, Florida; and Chris W. Altenbernd of Banker Lopez Gassler P.A., Tampa, Florida,
for Complainant
Bruce Jacobs of Jacobs Legal, PLLC, pro se, Miami, Florida,
for Respondent
- 24 -