THE SUPREME COURT FLORIDA AMENDED RESPONSE TO MOTION FOR MORE DEFINITE STATEMENT. Special Counsel to the Judicial Qualifications Commission

Similar documents
BEFORE THE JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA CASE NO

BEFORE THE JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA. N. JAMES TURNER JQC Case No.: /

RESPONSE TO JQC S REQUEST FOR ADMISSIONS

AMENDED NOTICE OF FORMAL CHARGES. YOU ARE HEREBY notified that the Investigative Panel of the Florida Judicial

BEFORE THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA

IN THE SUPREME COURT OF FLORIDA CASE NO. SC INQUIRY CONCERNING A JUDGE No LAURA M. WATSON

RESPONDENT S MOTION FOR PARTIAL SUMMARY JUDGMENT AND MEMORANDUM OF LAW IN SUPPORT THEREOF

IN THE SUPREME COURT OF FLORIDA BEFORE THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION

BEFORE THE JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA. The Honorable Judge Terri-Ann Miller, by and through undersigned

BEFORE THE JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA JUDGE ALEMAN S AMENDED WITNESS LIST (PLEASE SEE PAGE 6.

BEFORE THE JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA INQUIRY CONCERNING A JUDGE, RE: JUDGE DALE C. COHEN CASE NO.

BEFORE THE JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA JQC S WITNESS LIST

BEFORE THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA

PREVIOUSLY FILED MOTION TO STRIKE THE JUDICIAL QUALIFICATION'S BRIEF FOR INCLUSION OF EXTRA-RECORD MATERIAL AND MOTION FOR SANCTIONS

BEFORE THE JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA. INQUIRY CONCERNING A JUDGE, : No , CHERYL ALEMAN : CASE NO.

RESPONDENT'S RESPONSE TO REQUEST FOR PRODUCTION

BEFORE THE JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA CASE NO: 07-64

BEFORE THE JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA INQUIRY CONCERNING A JUDGE NO , JUDGE JOHN RENKE, III

BEFORE THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA

IN THE SUPREME COURT OF FLORIDA. Case No. SCO LYNN HILLMAN, MARY PATRICIA BOSNER and ROBERTA JAMES, Petitioners,

BEFORE THE JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA INQUIRY CONCERNING A JUDGE NO , JUDGE JOHN RENKE, III

BEFORE THE INVESTIGATIVE PANEI. OF TIIE FI ORIDA JUDICIAL QUAl IFICATIONS COMMISSION STATE 01 Fl.ORIDA

BEFORE THE JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA RESPONDENT S MOTION FOR SUMMARY JUDGMENT

STATE OF FLORIDA ADMINISTRATION COMMISSION

IN THE SUPREME COURT OF FLORIDA ON PETITION FOR REVIEW FROM A DECISION OF THE SECOND DISTRICT COURT OF APPEAL, STATE OF FLORIDA CASE NO.

BEFORE THE INVESTIGATIVE PANEL OF THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA MOTION FOR PARTIAL SUMMARY JUDGMENT

Before the Florida Judicial Qualifications Commission State of Florida PRETRIAL MEMORANDUM OF THE HONORABLE JOHN R. SLOOP

IN THE SUPREME COURT OF FLORIDA CASE NO. SC

Supreme Court of Florida

BEFORE THE JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA. INQUIRY CONCERNING A JUDGE, ] No , DENNIS MALONEY ] Case No.

STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION DIVISION OF FLORIDA CONDOMINIUMS, TIMESHARES AND MOBILE HOMES

IN THE SUPREME COURT OF FLORIDA. Petitioner, DCA CASE No. 5D v. CASE NO. SC ON DISCRETIONARY REVIEW FROM THE FIFTH DISTRICT COURT OF APPEAL

IN THE DISTRICT COURT OF APPEAL THIRD DISTRICT CASE NO.: 3D LT. CASE NO.: CA-13

IN THE SUPREME COURT OF FLORIDA TALLAHASSEE, FLORIDA

IN THE SUPREME COURT OF FLORIDA CASE NO: SC BEVERLY ROGERS, et. al. v. THE ELECTIONS CANVASSING COMMISSION OF THE STATE OF FLORIDA, et al.

BEFORE THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION SPECIAL COUNSEL'S WITNESS AND EXHIBIT LISTS CERTIFICATE OF SERVICE

SUPREME COURT OF FLORIDA

NOT FINAL UNTIL TIME EXPIRES TO FILE REHEARING MOTION AND, IF FILED, DETERMINED OF FLORIDA SECOND DISTRICT

BEFORE THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION NOTICE OF FORMAL CHARGES

NOTICE OF FILING SUPPLEMENTAL AUTHORITY

BEFORE THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION SIXTH AMENDED WITNESS AND EXHIBIT LIST WITNESS LIST. 1. Honorable Charles W.

BEFORE THE JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA

SUPREME COURT OF FLORIDA

OB,lECTION TO SCOPE OF STATUS CONFE R ENCE AND R ENEWED MOTION FOR EXTENSION OF TIME PURSUANT TO RULE 17 AND RULE 1.090(b) FLA. R. CIV. PRO.

IN THE SUPREME COURT OF FLORIDA CASE NO.: SC05-54 L.T. NO. 2D

FLORIDA SUPREME COURT. Case No.: SC nd DCA Case No.: 2D Lower Tribunal Case No.: G Hillsborough County, Florida Circuit Court

BEFORE THE FLORIDA PUBLIC SERVICE COMMISSION. Cost Recovery Clause with Generating Performance Incentive FILED: September 13, 2006 Factor /

IN THE SUPREME COURT OF FLORIDA ANSWERS AND OBJECTIONS TO RESPONDENT S EXPERT AND WITNESS INTERROGATORIES GENERAL OBJECTIONS

IN THE SUPREME COURT OF FLORIDA. INQUIRY CONCERNING A ) Supreme Court. JUDGE, NO ) Case No. SC

IN THE SUPREME COURT OF FLORIDA CASE NO. SC IN RE: THE ESTATE OF MARY T. OSCEOLA, Petitioners, vs. PETTIES OSCEOLA, SR.

IN THE SUPREME COURT OF FLORIDA TALLAHASSEE, FLORIDA RESPONDENTS ENGLEWOOD COMMUNITY HOSPITAL AND RSKCO S ANSWER BRIEF ON JURISDICTION

v TR A-O 2012-TR A-O

BEFORE THE INVESTIGATIVE PANEL OF THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA NOTICE OF FORMAL CHARGES

SUPREME COURT OF FLORIDA. CASE NO. SCl3-1934

Case 8:04-cv SCB-TBM Document 32 Filed 10/07/2005 Page 1 of 6

STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION DIVISION OF FLORIDA LAND SALES, CONDOMINIUMS, AND MOBILE HOMES

IN THE SECOND DISTRICT COURT OF APPEAL STATE OF FLORIDA. Appellant, CASE NO: 2D

IN THE SUPREME COURT OF FLORIDA. A JUDGE NO No.: SC

IN THE SUPREME COURT OF FLORIDA MOTION FOR EXTENSION OF TIME TO FILE ANSWER BRIEF. THE STANDING COMMITTEE on the Unlicensed Practice of Law of The

IN THE SUPREME COURT OF FLORIDA RESPONDENT, CITY OF LARGO, ANSWER BRIEF ON JURISDICTION IN RESPONSE TO PETITIONER'S AMENDED BRIEF

BEFORE THE INVESTIGATIVE PANEL OF THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA \, NOTICE OF FORMAL CHARGES

IN THE SUPREME COURT OF FLORIDA CASE NO. SC L.T. CASE NOS. 5D

BEFORE TIIE INVESTIGATIVF PANEI OF Till FI ORIDA Ji'DICIAI QUAl IFICATIONS COMMISSION STATE OF FLORIDA

IN THE FLORIDA SUPREME COURT

IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA

IN THE SUPREME COURT OF FLORIDA TALLAHASSEE, FLORIDA

IN THE SUPREME COURT OF FLORIDA

IN THE SUPREME COURT OF FLORIDA

IN THE SUPREME COURT OF FLORIDA CASE NO. SC CHRISTINE BAUER and THOMAS BAUER, Petitioners, ONE WEST BANK, FSB, Respondent.

BEFORE THE INVESTIGATIVE PANEL OF THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA AMENDED NOTICE OF FORMAL CHARGES

IN THE SUPREME COURT OF FLORIDA

IN THE SUPREME COURT OF FLORIDA

BEFORE THE INVESTIGATIVE PANEL OF THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA NOTICE OF FORMAL CHARGES

SUPREME COURT OF FLORIDA JAMES LEVOY WATERS, Petitioner, SHERIFF, ESCAMBIA COUNTY FLORIDA, Respondent. CASE NO. SC

IN THE SUPREME COURT OF THE STATE OF FLORIDA

STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION DIVISION OF FLORIDA CONDOMINIUMS, TIMESHARES AND MOBILE HOMES

BEFORE THE JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA CASE NO.: 06-52

SUPREME COURT OF FLORIDA. Case No. SC04- L.T. Case No. 3D CITY OF MIAMI. Petitioner. vs. SIDNEY S. WELLMAN, ET AL.

IN THE SUPREME COURT OF FLORIDA CASE NO.

SUPREME COURT OF FLORIDA INQUIRY CONCERNING A JUDGE NO CASE NO. 91,325

IN THE SUPREME COURT OF FLORIDA CASE NO. SC THIRD DISTRICT CASE NO. 3D PROFESSIONAL MEDICAL GROUP, INC., A/A/O MARVELIS BAUZA, Petitioner,

IN THE SUPREME COURT OF FLORIDA. Case No. SC12- ON DISCRETIONARY REVIEW FROM THE DISTRICT COURT OF APPEAL, FIRST DISTRICT

Before the Education Practices Commission of the State of Florida

IN THE SUPREME COURT OF THE STATE OF FLORIDA. ELIAS AND DAHLIA MORALES, Appellants, Case No.: SC DCA Case No.: 5D vs.

IN THE SUPREME COURT OF FLORID CASE NO. SC L.T. CASE NOS. 5D KARA SINGLETON ADAMS, LAURA BARKMAN and RANDALL HOBBS,

STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION DIVISION OF FLORIDA CONDOMINIUMS, TIMESHARES AND MOBILE HOMES

IN THE SUPREME COURT STATE OF FLORIDA. Case No. SC Lower Tribunal Case No.: 08-1 THE STATE OF FLORIDA. Appellant/Petitioner,

IN THE SUPREME COURT OF THE STATE OF FLORIDA CASE NO.: SC LOWER COURT NO.: 4D JACK LIEBMAN. Petitioner. vs.

IN THE SUPREME COURT OF FLORIDA (Before a Referee)

BEFORE THE INVESTIGATIVE PANEL OF THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA NOTICE OF FORMAL CHARGES

IN THE SUPREME COURT STATE OF FLORIDA CASE NO. SC DCA CASE NO. 1D AMENDED ANSWER BRIEF OF RESPONDENT BOBBY FLOYD

IN THE SUPREME COURT OF FLORIDA

Return form to: THE FLORIDA BAR Fee Arbitration Program 651 East Jefferson Street Tallahassee, FL

IN THE SUPREME COURT OF FLORIDA CASE NO. SC Lower T.C. No. 3D Florida Bar No

IN THE SUPREME COURT STATE OF FLORIDA. CASE NO. SC08- Fourth District Court of Appeal Case No. 4D JAN DANZIGER, Petitioner,

IN THE SUPREME COURT OF FLORIDA CASE NO: SC04- EDNA DE LA PENA, Petitioner, vs. SUNSHINE BOUQUET COMPANY and HORTICA, Respondents.

STATE OF FLORIDA DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION DIVISION OF FLORIDA CONDOMINIUMS, TIMESHARES AND MOBILE HOMES SUMMARY FINAL ORDER

IN THE SUPREME COURT OF FLORIDA

IN THE DISTRICT COURT OF APPEAL THIRD DISTRICT, STATE OF FLORIDA

IN THE SUPREME COURT OF FLORIDA (Before a Referee) THE FLORIDA BAR, CASE NO. SC [TFB no ,424(05B)(CRE)] REFEREE REPORT

Transcription:

THE SUPREME COURT FLORIDA INQUIRY CONCERNING JUDGE No.: 06-425, JUDGE JAMES C. HAUSER / CASE NO.: SC07-983 AMENDED RESPONSE TO MOTION FOR MORE DEFINITE STATEMENT Special Counsel to the Judicial Qualifications Commission files this Response to Judge Hauser s Motion for more Definite Statement and states as follows: 1. Rule 6(g), F.J.Q.C. indicates that a Notice of Formal Charges shall be issued in the name of the Commission and specify in ordinary and concise language the essential facts upon which such charges are based. Paragraph 3 of the Notice of Formal Charges complies with this pertinent provision of the Rule. Nevertheless, undersigned special counsel provides the following additional information. In 1997-1999, when Judge Hauser was assigned to the marital bench, Chief Judge Perry received complaints about Judge Hauser s conduct in a variety of areas, including Judge Hauser s attempts to interview clients without their lawyers present and ex parte communications with litigants and experts. Some of the complainants during this time period included the following: Stanton L. Cobb, Esq. 3319 Maguire Blvd, Suite 120 Orlando, FL 32803 Fried v. Fried, DR95-6352 1

Copies of Mr. Cobb s complaint and identifying documents have been located and are being provided simultaneously, and identified as JQC Prod. 195-280. Subsequently, Judge Hauser s attempted ex-parte communication with a litigant was reported in an appellate decision. See Klapper-Barrett v. Nurell, 742 So. 2d 851 (Fla. 5 th DCA 1999). Barbara Nolte Kinzel, Esq. is a witness with information pertaining to this case and her address will be provided. Judge Hauser returned to the marital bench during the years 2003-2005, when all of the same problems again resurfaced. Chief Judge Perry held two meetings with lawyers and discussed these problems again with Judge Hauser, who apologized for his conduct. Chief Judge Perry did not keep a list of the complaints, and did not request specific case names or numbers. However, we have been able to determine the names of some of the complainants and cases in response to Judge Hauser s request, which names include the following: The following witnesses may be called to discuss identifiable events which fall into this pattern. They are detailed as follows: 2

1. Gail Golda, Esq. G.L. Golda, P.A. 636 W. Yale Street Orlando, FL 32804 Thompson v. Ramos, DR 97-4286 Sanchez v. Sanchez, DR 04-580 2. Mercedes Wechsler, Esq. Mercedes Wechsler, P.A. 545-6 Delany Avenue Orlando, FL 32801 Neusch v. Neusch, 48-1996-DR-7302-O Hunter v. Hunter, DR00-13256-31 Erickson-Speaks v. Speaks, 48-2004-DR-145 3. Neva Kelaher, Esq. Law Offices of Neva Kelaher, P.A. 1177 Louisiana Avenue, Suite 100 Winter Park, FL 32789 Patel v. Patel, DR02-13249-31 4. Lisa Franchina, Esq. Law Offices of Lisa A. Franchina, P.A. 209 East Ridgewood Street Orlando, FL 32801 5. Linda Schoonover, Esq. Linda Schoonover, P.A. 1301 S. International Parkway Lake Mary, FL 32746 Curran v. Hopkins, DR-00-12567 6. James Cheney Mason, Esq. 390 N. Orange Avenue, Ste 2100 Orlando, FL 32601-1642 Morgan v. Morgan, DR03-3196 Respectfully Submitted: 3

By: Lauri Waldman Ross, Esq. Florida Bar No. 311200 LAURI WALDMAN ROSS, P.A. Two Datran Center, Suite 1612 9130 South Dadeland Blvd. Miami, Florida 33156-7818 (305) 670-8010 (phone) (305) 670-2305 (fax) SPECIAL COUNSEL FOR THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION -and- Marvin Barkin, Esq. TRENAM, KEMKER, SCHARF, BARKIN, FRYE, O NEILL & MULLIS, P.A. 101 Kennedy Blvd., Suite 2700 Tampa, FL 33602 INTERIM GENERAL COUNSEL FOR THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION -and- Michael L. Schneider, Esq. JUDICIAL QUALIFICATION COMMISSION 1110 Thomasville Road Tallahassee, FL 32303-6224 ASSOCIATE GENERAL COUNSEL FOR THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION 4

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by mail, this day of August, 2007 to: Keith R. Mitnik, Esq. Counsel for Judge Hauser Morgan & Morgan, P.A. 20 N. Orange Avenue, 16 th Floor Orlando, FL 32802-4979 John Beranek, Esq. General Counsel to the FJQC Hearing Panel Ausley & McMullin, P.A. P.O. Box 391 Tallahassee, FL 32302 LAURI WALDMAN ROSS, ESQ. 5