I The Florida Bar

Inquiry/Complaint Form

PART ONE (See Page 1, PART ONE- Complainant Information.):

Your Name: -----------------------------------------------------------------

Organization: -------------------------------------------------------------Address:

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City, State, Zip Code: ------------------------------------------------------Telephone: -----------------------------------------------------------------E-mail:

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ACAP Reference No.: Have you ever filed a complaint against .a member of The Florida Bar: Yes L No C If yes, how many complaints have you filed? __ _ Does this complaint pertain to a matter currently in litigation? Yes C No L PART TWO (See Page 1, PART TWO -Attorney Information.):

~~'sN~=--~~o-~_e~l--~~~J~n_'~~~~~~~~-~\_V ____ _ Address:

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City, State, Zip Code:-----------------------------------------------Telephone:

PART THREE (See Page 1, PART-THREE- Facts/Allegations.): The specific thing or things I am complaining about are: (attach additional sheets as necessary)

(Note that this field maxes out at 1800 characters- attach additional sheets as necessary)

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PART FOUR (See Page 1, PART FOUR- Witnesses.): The witnesses in support of my allegations are: [see attached sheet].

PART FIVE (See Page 1, PART FIVE- Signature.): Under penalties of perjury, I declare that the foregoing facts are true, correct and complete.

Print Name

Signature

Date

2

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 Roniel and I). In those emails we set up a meeting.

On Friday August 30th 2013, I met with Mr Roniel Rodriguez IV 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 TWO- 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 2nd 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 (September 2nd 2013) Mr Roniel Rodriguez IV replied to me also in an email saying "I have no problem with the agreement as modified as long as you understand that I will not be advancing any costs in this litigation".

The same day (September 2nd 2013) 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 not 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 available under the original agreement (His initial agreement, attached here as Exhibit A). I got no answer about that ever again. That email is attached here as Exhibit D.

On September 3rd 2013, Mr Roniel Rodriguez IV introduced me to a third person interested in advancing the costs of the litigation. Mr Roniel Rodriguez IV told me in an email to be in this 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 E.

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 2013 due to new information I received about the case, I sent to Mr Roniel Rodriguez IV an email saying that I did not want to fight the case and that I want him to drop the case.

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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 F.

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 $50,000.00". This email is attached here as Exhibit G.

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.

Now comes, that Mr Roniel Rodriguez IV 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.

It was my understanding that Mr Roniel Rodriguez IV was already paid his initial non refundable retainer of $50,000.00 as the third person said.

Also, it was my understanding according to Mr Roniel Rodriguez IV himself, that this third person's entity already paid for his retention.

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 client, even when I was not the one paying him for the representation on the case).

Mr Roniel Rodriguez IV allegations of unpaid fees are based in the modified agreement (Attached here as Exhibit B) The 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 the costs, and I told him that for now I can not commit to that as it is. And then, never ever talked again about that agreement since Mr Roniel Rodriguez IV himself found a third person to cover the costs, 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 IV is attached here as Exhibit H.

And after that, it curious to me that Mr Roniel Rodriguez IV signature marks are different in August and September. (See Exhibit A and Exhibit H). And I am attaching the differences as Exhibit I.

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Also, on Octuber 16th 2013 I got a called from Mr Roniel Rodriguez IV that phone call went to voice message and Mr Roniel Rodriguez was giving me a kind of update on the case (This voice message or the transcript of that voice message can be provided upon request). It is important to mention that this phone call happened after I made clear to Mr Roniel Rodriguez IV that he was not my lawyer anymore in the case, and he was notified about that by my new lawyer. A visual record of my cellphone history with Mr Roniel Rodriguez phone number is attached here as Exhibit J.

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 or not my lawyer at any point) And, when he clearly was not my lawyer anymore he acted as he was my lawyer trying to giving me a kind of update on the case. I have a lawyer, I am not sure what kind of information Mr Roniel Rodriguez IV was trying to provide me in that phone call. I already had been informed that the third party who Mr Roniel Rodriguez IV introduced to, made an agreement apparently with some kind of sum of money involved, so the case could resolved, but Mr Roniel Rodriguez IV is still claiming he was my lawyer and is still looking for compensation.

Finally, about Mr Roniel Rodriguez IV:

Scenario 1: If he was my lawyer why he made me transfer the property to this third party brought by him? Why he told me he could not do why I asked? Why he told me another person paid his retainer? Why he is still claiming I have to pay him after telling me somebody else paid him?

Scenario 2: If he was not my lawyer why he made me signed the property over a third party brought by him? while knowledge that I had another lawyer? (An email from my current lawyer at that time to the plaintiffs' lawyer refering to me as his client is attached here as Exhibit K) and then I hired a new lawyer to drop the case. If he was not my lawyer why he wants to get paid? If he was not my lawyer why he called me when the case was done if he was not my lawyer, but knowing that I already have a lawyer? He should it talked to my lawyer, right?

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 L.

Thanks.

Karel Soucre Industrial Engineer Peace City, Inc.- President

A -i) L

xhi brt A RONIEL RODRIGUEZ IV, PaA2

ATTORNEYS AT LAW AGREEMENT FOR COLLECTION REPRESENTATION

This Agreement for col1..oction representation (hereinafter the .. Agreement") is enter~d into by Roniel Rodriguez IV. P .A. (hereina..-llertb.e ~llector") an4 Peace City Inc (the ""Client"). SCOPE OF REP~'TATION:

The representation shall incillde representation ,..of Client in the action filed against it by The F&"' International LLC , ease number 13-7628 Ci\,M. attempting to quiet title and eject the Client from rela property the Client claims to own. '2. 4--FEE:

The fee due to the Collector from Client under this ~ sba1l be on a contingency basis. If the Client prevails by way of trial, settlement, sale of the property, merits, resolution, agreement, or otherwise~ then the Collector shall receive 35% of any sums al\'mded to the Client:, by way of agreement, order or ~ise. If the Client shall elect to maintain the property Subject of this above referenced action, the Client agrees that the Collector sbal1 receive 35% of the real property by way of a deed representing a conveyance of 35% interest in the real property. IF THE CI..IElii"'T

1 SO:~~ NO!_PREV~ ~eS ~N~SATION. --~ 1 The Collector snan be tennbt~iiCt=;m;:costS ~ ~ced < e:g:ffililgees;Ie'iii'ffiDi 1 ~=~levying,

....

ROSIEL RODRIGUEZ IV, PaA. ATTORNEYS AT LAW AGREL~'T FOR COLLECilON REPRESENTATION

This Agreemept for oollectioo representation (hereinafter the "Agreement"} is enrer-:d !nw by Ronie! Rodriguez IV, PA. {hereinafter tile~) md Peace City Inc {tbe '"Client"}

SCOPE OF REPRESENTATION:

'The representation shall inc.fnde representation 3f Client in the action filed against it by The Faro International LLC. ~number B-7621 CA~~ to quiet We and eject ti"l Client from rela property the Client claims to own.. -z.. 4r' FEE:

AGREED TO~~"" ACCEPTED BY: PEACE CITY, INC.

RONIEL RODRIGlJEZ IV, P -~

: ~.

by-'j

I

I _/

..._ ..

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RE: Modified Agreement Signed

From: Karel Soucre (karelsoucre@hotmail.com) Sent: Mon 9/02/13 12:04 PM To: Roniel Rodriguez IV, P.A. (ron@rjrfirm.com) I only have been communicated with Mr. lawrence thru e-mail. He is not in office today, I have not talk to him by phone or in person since we got the 3 days notice. The only way this can work if that Mr lawrence is for sure loan the money to fix the building. For now, I need some more time, I can not commit to that as it is for now.

Thanks.

From: Ron@RJRfirm.com Subject: Re: Modified Agreement Signed Date: Mon, 2 Sep 2013 11:31:16 -0400 To: karelsoucre@hotmail.com

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

Regards,

Ron Rodriguez IV Roniel Rodriguez IV, P.A. Direct Hne: {305} 773-4875 E-mail: Ron@RJRfirm.com E-Service: Service@RJRfirm.com Secondary: Pleadings@RJRfirm.com

NOTE: this message was generated on a mobile device and may contain inaccuracies due to formatting and software compatibility.

On Sep 2, 2013, at 10:46 AM, Karel Soucre wrote:

Mr. Ron, I respectfully modified the agreement and signed it.

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RE: Modified Agreement Signed

Frorn; Karel &uen, {kareJsoUCre@ho1lnail.com) Sent: }vfon 9!02113 12:52 P~I

D - - - - -- --

To: RooieJ Rodrig,.,z IV; PA (lU!l@zjrfum.com)

If I sign Your Origfnal-ment, Will you be stt11adY..ndng all costs of the litigaoo.,?

\D )B

r-rom: ROn@RJRnrm.com Subject: Re: Meeting Date.: Tue, 3 Sep 2013 09:54:57 -()4()() To: karelsoucre@hotmail.com

E

I ~re~ \ \ \ I \1 i l will be back at my office at 11:30am. We can discuss at that time the possibility of a third party ,

~~ covering all of the litigation costs and fees to be incurred through trial. Regards, ji ~-~:=~----------~~----------------------------====--------

Ron Rodriguez IV

Roniel Rodriguez IV, P.A.

Direct line: (305) 773-4875

\ \ \9 E-mail: Ron@RJRfirm.com 2 3 L

RE: Meeting

From: Ron Rodriguez I\' (Ron@RJRfum.com) This s....=nder is in your safe list. Sent: Wed 9/04/13 2:13PM To: 'Karel Soucre' (karelsoucre-@ho1mail...com)

l have nothing to do with your arrangement with JRS and its principal Stuart Ka!b. As you know he can be reached directly at (305) 373~300. i am not available tomorrow as it is a Jewish hofiday and I am Jewish. Also, given your transfer of the propert'f and my retention by Me Kafb's entity what you are requesting of me is not possible. As you are also aware, f have already fiied an answer and defenses to the instant action and noticed tt.e case for triaL Please contact Mr_ Kafb to dlse4"SS this matte"" further.

Best regards, Ron Rodriguez IV Roniel Rodriguez IY, P .A.

Aventura Mailing Address: 20533 Biscayne Bivd., 1243 Aventura, Florida 33180 (305) n3-4875 Dade/Direct mat

(954) 769-0919 Broward

{315) 600-1254 Monroe

(305) 359-5196 Monroe Facsimile

(561} 491-6581 Palm Beach Facsirru1e

E-mait Ron@RJRfirm.com

Plifi'.ary: Sefvi.ce@RJRfirm.com

Secondary: Pleadings@RJRfirrp.com

\L

~

t From: srkalb@mirlegal.com To: karelsoucre@hotmail.com Subject: Peace City to JRS Date: Wed, 4 Sep 2013 19:01:25 +0000

Karel,

I am not available for the rest of this week. However, the Answer and Affirmative Defenses have been filed, while I am interested in any information you may have, there is no urgency since we have not yet commenced discovery. I have some time at the end of next week if you would like to meet. More importantly, I paid Mr. Rodriguez his non-refundable initial retainer of $50,000.00, so this matter will need to take its course.

Regards,

Stuart

a a 11

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RONIEL RODRIGUEZ IV, P.A. ATTORNEYS AT LAW

AGREEMENT FOR COLLECTION REPRESENTATION

This Agreement for collection representation (hereinafter the "Agreemen:f') is ~ter~ into by Roniel Rodriguez IV. P.A. (hereinaft..er the "CoUector} a.n4 Peace City Inc (the "Client}. r j - .; t

l c+ -:: ~ i~ SCOPE OF REPRESENTATION:

i , v .... - .e_

The representation shaD include representatioc op Client in the action filed against it by The 0 ~ Faro International LLC, case number 13-7628 CAKmempting to quiet title and eject the Client 1 . , t-L..e. from reJa property the Client claim~ to own. -z_ +- )! :; *- [ FEE: f ....-o f:J

AGREED TO A.~ ACCEPTED BY: PEACE CITY, INC.

rr::=-~ By: ~, / -~--------

Florida D BY: ED TO A.~ ACCEPTE AGRE

I RO~'JEL RODRIGUEz IV, P -A.

By:=' Roniel Rodriguez IV, Partner

/ 4 ~-"J ~ ~vr.e

Av~;,ST ke.. v~ ed ()"- : :?.o-R 2 or~

INC.

I'EACE ?~ By: . IV. PartDer 4--b.- -R.odriguez

).Q

Mariely Letona, Esq

From: Sent: To: Subject: Attachments:

Larry Weisberg [Larry@weisberglegal.com] Thursday, August 01, 2013 10:46 PM Mariely Letona, Esq Re: Faro vs Peace City image001.png; image002.png; image003.png

FOR NEGOTIATION PURPOSES ONLY

k

I have had an opportunity to discuss the matter and review it at length with my client. Unfortunately I believe the attempt to discuss via face to face meeting was not very beneficial. As such, it appears there may be no option but to litigate. To the extent that there is no alternative it may be helpful to schedule depositions early on to get to the bottom of what happened.

I can however suggest two prospective options.

First, my client owns the property and it remains that way. In exchange my client would agree to execute a $400,000 mortgage infavor of your client but it use remain in position behind a $600,000 first private mortgage which will be used to repair the building.

Second, the property is sold to the buyer and at closing my client receives the sum of $150,000. But the property met be taken out of the name of the not for profit.

This is no way should be considered an acknowledgement of wrongdoing on the part of my client. While I do believe that a very reasonable outcome is that your claim will fail and you will end up with nothing, we are willing to resolve in a matter that eliminates your clients risk for an extremely reasonable sum.

Please advise accordingly,

Lawrence M. 'Weisberg, Esi}. Weisberg & Associates, P A ltianaging Partner (561) 362-7355 (Otiice) (561) 853-1583 (Direct) (561) 880-6570 (Fax) L Weisberg@ WeisbergLegaLcom www.WeisbergLegal.com i www.OasisTitleCompanv.com

21301 Pov,erline Road, Suite 100, Boca Raton. FL 33433

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'feel:

Land Value:

!IN Market Value: aaesiitj1fiiW:.

County:

City:

.. $392,700 .. Jjf&

st, 336.248 sf~w. ',,~

Assessment Information

Jlu: $392.700

.,,.j81 $1,400.581 $it .-

at1 $207.900

$1.-A'Jt Sl.215,781

..... ~)&1

Taxable Value Information

$OJ st . 336.248

. -..... $01

$1.336.248

-$1~

f]llinllpll:tiilf T~VIIiae

$01 $1,337,359

-~~ $01

$1,337,359

-$1,337,359

~' Taallfe-v-.e $OJ

$1.215.781 .. M,i~tl,i&t

$01 st ,2ts, 781

-$1,215,.781

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