Answer of Kleinman in Figueroa v. Szymoniak

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Case No. 0:13-Civ-61020-Cohn/Seltzer

IGNACIO DAMIAN FIGUEROA,

Plaintiff, vs. LYNN SZYMONIAK, ESQUIRE, individually and as a shareholder/member/owner of The Szymoniak Firm, P.A.; THE SZYMONIAK FIRM, P.A., a Florida professional association; HAL J. KLEINMAN, ESQUIRE, individually; JANET, JENNER & SUGGS, LLC,

Defendants. /

DEFENDANTS HAL J. KLEINMAN, ESQ. AND JANET, JENNER & SUGGS, LLC’ S ANSWER AND AFFIRMATIVE DEFENSES

COMES NOW, the Defendants, HAL J. KLEINMAN, ESQUIRE, individually, and

JANET, JENNER & SUGGS, LLC, (hereby collectively referred to as the “Janet Defendants”)

by and through their undersigned counsel and file this their Answer and Affirmative Defenses to

the Plaintiff’s claim, and in response thereto state as follows:

PARTIES AND JURISDICTION

1. The Janet Defendants deny that they are liable to the Plaintiff and therefore deny

Plaintiff is entitled to any damages.

2. The Janet Defendants are without knowledge as to the allegations in paragraph 2

of the Complaint and therefore neither admit nor deny same and leave Plaintiff to his proofs.

3. As the allegations in paragraph 3 of the Complaint are directed to a Co-

Defendant, the Janet Defendants neither admit nor deny same.

Case 0:13-cv-61020-JIC Document 18 Entered on FLSD Docket 05/08/2013 of 23


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6. Defendant Kleinman admits he is an attorney licensed in the State of Illinois and

Pennsylvania to practice law. Defendant Kleinman denies he was retained by or entered into an

attorney-client relationship with the Plaintiff.

7. Defendant Janet Jenner & Suggs, LLC admits only that it is a Maryland Limited

Liability Company. Defendant Janet Jenner & Suggs LLC denies that it represented or had an

attorney-client relationship with the Plaintiff and further denies the remaining allegations of

paragraph 7 of the Plaintiff’s Complaint.

8. Defendants Janet admit only that Defendant Kleinman was an employee of

Defendant Janet Jenner & Suggs. The Janet Defendants deny that they represented or had an

attorney-client relationship with the Plaintiff.

9. The allegations in paragraph 9 of the Plaintiff’s Complaint are denied.


GENERAL ALLEGATIONS









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The Janet Defendants deny that they had an attorney-client relationship with the Plaintiff.











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26. Defendants deny that they had an obligation to undertake the activities set forth in

the allegations of the Plaintiff’s Complaint as they did not represent or have an attorney-client

relationship with the Plaintiff.

(a) Defendants deny that they had an obligation to undertake the activities set forth in the allegations of the Plaintiff’s Complaint as they did not represent or have an attorney-client relationship with the Plaintiff.

(b) Defendants deny that they had an obligation to undertake the activities set forth in the allegations of the Plaintiff’s Complaint as they did not represent or have an attorney-client relationship with the Plaintiff.

(c) Defendants deny that they had an obligation to undertake the activities set forth in the allegations of the Plaintiff’s Complaint as they did not represent or have an attorney-client relationship with the Plaintiff.

(d) Defendants deny that they had an obligation to undertake the activities set forth in the allegations of the Plaintiff’s Complaint as they did not represent or have an attorney-client relationship with the Plaintiff.

(e) Defendants deny that they had an obligation to undertake the activities set forth in the allegations of the Plaintiff’s Complaint as they did not represent or have an attorney-client relationship with the Plaintiff.

27. The allegations in paragraph 27 of the Plaintiff’s Complaint are denied as phrased.






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30. The Janet Defendants deny that the Plaintiff had a belief that the Janet Defendants

represented or had an attorney-client relationship with the Plaintiff. Remaining allegations are

denied.



denied.


represented or had an attorney-client relationship with the Plaintiff or that he was assisting them

with a Qui Tam action. Remaining allegations are denied.



denied. Remaining allegations are denied.

34. Defendant Kleinman admits that he received a copy of the Plaintiff's deed and that

he spoke with Plaintiff and Co-Defendant Szymoniak generally regarding a class action that was

pending in Florida. At no time did Defendant Kleinman undertake to represent the Plaintiff and

did not offer any specific advice with regard to the Plaintiff's circumstances

35. Defendant Kleinman admits that he received a copy of the Plaintiff's deed and that

he spoke with Plaintiff and Co-Defendant Szymoniak generally regarding the class action that

was pending in Florida. At no time did Defendant Kleinman undertake to represent the Plaintiff



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and did not offer any specific advice with regard to the Plaintiff's circumstances. Defendant

Kleinman did not discuss a Qui Tam Action with the Plaintiff during that call.

36. The Janet Defendants deny that the Plaintiff had a belief he was or would be

represented by the Janet Defendants in a Qui Tam action in which he would be the relator. The

Janet Defendants further deny that they represented the Plaintiff. The remaining allegations of

paragraph 36 are denied.



















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42. The Janet Defendants are without knowledge as to the allegations in paragraph

42 of the Complaint and therefore neither admit nor deny same and leave Plaintiff to his proofs.







(d) Defendants deny that they had an obligation to undertake the activities set forth in the allegations of the Plaintiff’s Complaint as they did not represent or have an attorney-client relationship with the Plaintiff.

(e) Defendants deny that they had an obligation to undertake the activities set forth in the allegations of the Plaintiff’s Complaint as they did not represent or have an attorney-client relationship with the Plaintiff.









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49. Admitted.

50. Admitted.



Janet Defendants further deny that they represented the Plaintiff. The Janet Defendants deny that

they had an obligation to undertake the activities set forth in the allegations of the Plaintiff’s

Complaint as they did not represent or have an attorney-client relationship with the Plaintiff.



Janet Defendants further deny that they represented the Plaintiff. The Janet Defendants deny that

they had an obligation to undertake the activities set forth in the allegations of the Plaintiff’s

Complaint as they did not represent or have an attorney-client relationship with the Plaintiff



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paragraph 53 regarding settlement figures are denied as phrased.




paragraph 54 are denied as phrased.

55. The Janet Defendants deny that they were retained by Plaintiff to represent him as

a relator in a Qui Tam. Since the Janet Defendants did not represent Plaintiff in the Qui Tam

action they therefore had no duty to withdraw from such representation. The remaining

allegations of paragraph 55 are denied.

COUNT I LEGAL MALPRACTICE AS TO DEFENDANTS,

LYNN SZYMONIAK, ESQUIRE & THE SZYMONIAK FIRM, P.A.

56. The Janet Defendants reassert and restate their responses to paragraphs 1 through

55 of the Plaintiff’s Complaint as if fully set forth herein.

57. As the allegations in paragraph 57 of the Plaintiff’s Complaint are directed to Co-

Defendant and not the Janet Defendants, the Janet Defendants neither admit nor deny same and

leave Plaintiff to his proofs. To the extent that the allegations are construed as asserting a claim

against the Janet Defendants, they are denied.





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(a) As the allegations in paragraph 59(a) of the Plaintiff’s Complaint are directed to Co-Defendant and not the Janet Defendants, the Janet Defendants neither admit nor deny same and leave Plaintiff to his proofs. To the extent that the allegations are construed as asserting a claim against the Janet Defendants, they are denied.

(b) As the allegations in paragraph 59(b) of the Plaintiff’s Complaint are directed to Co-Defendant and not the Janet Defendants, the Janet Defendants neither admit nor deny same and leave Plaintiff to his proofs. To the extent that the allegations are construed as asserting a claim against the Janet Defendants, they are denied.

(c) As the allegations in paragraph 59(c) of the Plaintiff’s Complaint are directed to Co-Defendant and not the Janet Defendants, the Janet Defendants neither admit nor deny same and leave Plaintiff to his proofs. To the extent that the allegations are construed as asserting a claim against the Janet Defendants, they are denied.

(d) As the allegations in paragraph 59(d) of the Plaintiff’s Complaint are directed to Co-Defendant and not the Janet Defendants, the Janet Defendants neither admit nor deny same and leave Plaintiff to his proofs. To the extent that the allegations are construed as asserting a claim against the Janet Defendants, they are denied.

(e) As the allegations in paragraph 59(e) of the Plaintiff’s Complaint are directed to Co-Defendant and not the Janet Defendants, the Janet Defendants neither admit nor deny same and leave Plaintiff to his proofs. To the extent that the allegations are construed as asserting a claim against the Janet Defendants, they are denied.

(f) As the allegations in paragraph 59(f) of the Plaintiff’s Complaint are directed to Co-Defendant and not the Janet Defendants, the Janet Defendants neither admit nor deny same and leave Plaintiff to his proofs. To the extent that the allegations are construed as asserting a claim against the Janet Defendants, they are denied.

(g) As the allegations in paragraph 59(g) of the Plaintiff’s Complaint are directed to Co-Defendant and not the Janet Defendants, the Janet Defendants neither admit nor deny same and leave Plaintiff to his proofs. To the extent that the allegations are construed as asserting a claim against the Janet Defendants, they are denied.



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(h) As the allegations in paragraph 59(h) of the Plaintiff’s Complaint are directed to Co-Defendant and not the Janet Defendants, the Janet Defendants neither admit nor deny same and leave Plaintiff to his proofs. To the extent that the allegations are construed as asserting a claim against the Janet Defendants, they are denied.









COUNT II BREACH OF FIDUCIARY DUTY AS TO DEFENDANTS,

LYNN SZYMONIAK, ESQUIRE & THE SZYMONIAK FIRM, P.A.

61. The Janet Defendants re-assert and restate their responses to paragraphs 1 through






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(e) As the allegations in paragraph 63(e) of the Plaintiff’s Complaint are directed to Co-Defendant and not the Janet Defendants, the Janet Defendants neither admit nor deny same and leave Plaintiff to his proofs. To the extent that the allegations are construed as asserting a claim against the Janet Defendants, they are denied.

(f) As the allegations in paragraph 63(f) of the Plaintiff’s Complaint are directed to Co-Defendant and not the Janet Defendants, the Janet Defendants neither admit nor deny same and leave Plaintiff to his proofs. To the extent that the allegations are construed as asserting a claim against the Janet Defendants, they are denied.

(g) As the allegations in paragraph 63(g) of the Plaintiff’s Complaint are directed to Co-Defendant and not the Janet Defendants, the Janet Defendants neither admit nor deny same and leave Plaintiff to his proofs. To the extent that the allegations are construed as asserting a claim against the Janet Defendants, they are denied.



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(h) As the allegations in paragraph 63(h) of the Plaintiff’s Complaint are directed to Co-Defendant and not the Janet Defendants, the Janet Defendants neither admit nor deny same and leave Plaintiff to his proofs. To the extent that the allegations are construed as asserting a claim against the Janet Defendants, they are denied.

(i) As the allegations in paragraph 63(i) of the Plaintiff’s Complaint are directed to Co-Defendant and not the Janet Defendants, the Janet Defendants neither admit nor deny same and leave Plaintiff to his proofs. To the extent that the allegations are construed as asserting a claim against the Janet Defendants, they are denied.

(j) As the allegations in paragraph 63(j) of the Plaintiff’s Complaint are directed to Co-Defendant and not the Janet Defendants, the Janet Defendants neither admit nor deny same and leave Plaintiff to his proofs. To the extent that the allegations are construed as asserting a claim against the Janet Defendants, they are denied.

(k) As the allegations in paragraph 63(k) of the Plaintiff’s Complaint are directed to Co-Defendant and not the Janet Defendants, the Janet Defendants neither admit nor deny same and leave Plaintiff to his proofs. To the extent that the allegations are construed as asserting a claim against the Janet Defendants, they are denied.


Defendant and not the Janet Defendant, the Janet Defendants neither admit nor deny same and



COUNT III UNJUST ENRICHMENT AS TO DEFENDANT, LYNN

SZYMONIAK, ESQUIRE











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COUNT IV FRAUD AS TO DEFENDANT, LYNN SZYMONIAK, ESQUIRE











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COUNT V LEGAL MALPRACTICE AS TO DEFENDANTS,

HAL J. KLEINMAN, ESQUIRE & JANET, JENNER & SUGGS, LLC




79. The allegations in paragraph 79 of the Plaintiff’s complaint are denied.


a relator in a Qui Tam action and further deny that that they had or breached a duty to the

Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet

Defendants. The remaining allegations of paragraph 80 are denied.

(a) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet Defendants. The remaining allegations of paragraph 80(a) are denied.

(b) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet Defendants. The remaining allegations of paragraph 80(b) are denied.

(c) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet Defendants. The remaining allegations of paragraph 80(c) are denied.

(d) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet Defendants. The remaining allegations of paragraph 80(d) are denied.

(e) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a



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duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet Defendants. The remaining allegations of paragraph 80(e) are denied.

(f) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet Defendants. The remaining allegations of paragraph 80(f) are denied.

(g) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet Defendants. The remaining allegations of paragraph 80(g) are denied.

(h) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet Defendants. The remaining allegations of paragraph 80(h) are denied.

81. The allegations in paragraph 81 are denied.

(a) The allegations in paragraph 81(a) are denied.

(b) The allegations in paragraph 81(b) are denied.

(c) The allegations in paragraph 81(c) are denied.

(d) The allegations in paragraph 81(d) are denied.

Un-numbered wherefore clause. The Janet Defendants deny that the Plaintiff is entitled to the requested relief and further denies any entitlement by the Plaintiff to costs, interest or any other damages claimed.

COUNT VI BREACH OF FIDUCIARY DUTY AS TO DEFENDANTS,

HAL J. KLEINMAN. ESQUIRE & JANET, JENNER & SUGGS, LLC






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a relator in a Qui Tam action and further deny that that they had or breached a duty to the

Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet

Defendants The remaining allegations of paragraph 84 are denied.

(a) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet Defendants. The remaining allegations of paragraph 84(a) are denied.

(b) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet Defendants. The remaining allegations of paragraph 84(b) are denied.

(c) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet Defendants. The remaining allegations of paragraph 84(c) are denied.

(d) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet Defendants. The remaining allegations of paragraph 84(d) are denied.

(e) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet Defendants. The remaining allegations of paragraph 84(e) are denied.

(f) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet Defendants. The remaining allegations of paragraph 84(f) are denied.

(g) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was



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represented by the Janet Defendants. The remaining allegations of paragraph 84(g) are denied.

(h) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet Defendants. The remaining allegations of paragraph 84(h) are denied.

(i) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet Defendants. The remaining allegations of paragraph 84(i) are denied.

(j) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet Defendants. The remaining allegations of paragraph 84(j) are denied.

(k) The Janet Defendants deny that they were retained by Plaintiff to represent him as a relator in a Qui Tam action and further deny that that they had or breached a duty to the Plaintiff. The Janet Defendants deny that Plaintiff had a belief he was represented by the Janet Defendants. The remaining allegations of paragraph 84(k) are denied.

85. The allegations in paragraph 85 are denied.

(a) The allegations in paragraph 85(a) are denied.

(b) The allegations in paragraph 85(b) are denied.

(c) The allegations in paragraph 85(c) are denied.

(d) The allegations in paragraph 85(d) are denied.

Un-numbered wherefore clause. The Janet Defendants deny that the Plaintiff is entitled to

the requested relief and further denies any entitlement by the Plaintiff to costs, interest or any

other damages claimed.

WHEREFORE, Defendants, HAL J. KLEINMAN, ESQUIRE, individually, and

JANET, JENNER & SUGGS, LLC, respectfully request that the Court enter judgment in their



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favor, dismiss the Plaintiff’s Complaint with prejudice and award said Defendants such other or

further relief as the Court may deem just and appropriate.

AFFIRMATIVE DEFENSES APPLICABLE TO ALL COUNTS OF THE PLAINTIFF’S COMPLAINT

FIRST AFFIRMATIVE DEFENSE

If the Janet Defendants did not owe a duty to Plaintiff, then the Janet Defendants cannot

be held liable for the breach of said duty.

SECOND AFFIRMATIVE DEFENSE

To the extent Plaintiff has failed to mitigate its damages, Plaintiff’s recovery, if any,

should be reduced by the amount that Plaintiff could have lessened his claimed damages.

THIRD AFFIRMATIVE DEFENSE

The transactions alleged in Plaintiff’s Second Amended Complaint fall within the

provisions of the “Tort Reform and Insurance Act of 1986” which said Act specifically

addresses, but is not limited to: Fla. Stat. §768.76, collateral sources of indemnity; Fla. Stat.

§768.78, alternative methods of payment of damage awards; §768.81, comparative fault. The

Janet Defendants plead all of the defenses available to them under said Act, specifically

including, without limitation, §768.81(3), abolishing joint and several liability, and requiring that

judgment be entered against each party liable on the basis of such party’s percentage of fault.

FOURTH AFFIRMATIVE DEFENSE

Plaintiff has failed to state a cause of action for legal malpractice as the Plaintiff did not

retain nor did the Janet Defendants undertake to represent the Plaintiff in a Qui Tam action.



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FIFTH AFFIRMATIVE DEFENSE

The Janet Defendants state that the damages alleged in Plaintiff’s Complaint were

proximately caused by the activities of Plaintiff or his agent/representative and the Defendants

bear no legal liability therefore.

SIXTH AFFIRMATIVE DEFENSE

Plaintiff’s claims are barred by the applicable Statute of Limitations.

SEVENTH AFFIRMATIVE DEFENSE

If Plaintiff was damaged either as alleged in the Complaint or at all, such damages were

directly and proximately caused by the negligence or wanton action of Plaintiff or others over

whom Defendants had no control and Plaintiff’s recovery, if any, should be reduced in

proportion to the amount of fault attributable to each.

EIGHTH AFFIRMATIVE DEFENSE

Plaintiff has failed to demonstrate a nexus between the conduct alleged in the Complaint,

Plaintiff’s alleged injuries and the acts of alleged omissions of the Janet Defendants.

Furthermore, the damages claimed by Plaintiff were not proximately caused by the Janet

Defendants herein.

NINTH AFFIRMATIVE DEFENSE

That at the time and place under the circumstances referred to in the Complaint, the

Plaintiff conducted itself in a negligent and careless manner and way and that his said negligence

and carelessness contributed to the happenings described therein and to the injuries and damages

complained of. Therefore, Plaintiff is either barred from recovery against the Janet Defendants

or his recovery should be comparatively reduced against the Janet Defendants.



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TENTH AFFIRMATIVE DEFENSE

The damages claimed by Plaintiff were not proximately caused by the Janet Defendants

herein. Specifically, the Plaintiff did not qualify as a relator under the terms of the applicable

Federal Statutes and therefore could not have been the party to bring the law suit that resulted in

the settlement referenced herein.

ELEVENTH AFFIRMATIVE DEFENSE

The damages complained by the Plaintiff, including those for loss of a potential

settlement is speculative since there is no competent evidence that Plaintiff would have been

qualified as a relator in the underlying or any Qui Tam action.

TWELFTH AFFIRMATIVE DEFENSE

The Plaintiff did not have an attorney-client relationship with the Janet Defendants and

accordingly cannot establish the elements necessary to establish the elements of that claim,

namely duty, breach of duty or proximate cause.

THIRTEENTH AFFIRMATIVE DEFENSE

The Court lacks jurisdiction over the persons of the Janet Defendants in that (a) the

Plaintiff has not alleged and cannot allege any conduct by the Janet Defendants that would

constitute the commission of a tortious act in the state of Florida, and (b) the Janet Defendants do

not possess sufficient minimum contacts with the state of Florida to satisfy due process

requirements. In the alternative and as set forth in the Notice of Removal, this case should be

transferred.

WHEREFORE, Defendants, HAL J. KLEINMAN, ESQUIRE, individually, and

JANET, JENNER & SUGGS, LLC, respectfully request that the Court enter judgment in their

favor, dismiss the Plaintiff’s Complaint with prejudice and award said Defendants such other or

further relief as the Court may deem just and appropriate



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HINSHAW & CULBERTSON, LLP 100 S. Ashley Drive, Suite 500 Tampa, Florida 33602 Telephone: 813-276-1662 Facsimile: 813-276-1956

Respectfully submitted,

s/James H. Wyman____________________ James H. Wyman Florida Bar No. 117692 [email protected] HINSHAW & CULBERTSON, LLP 2525 Ponce de Leon Blvd., 4th Floor Coral Gables, FL 33134 Telephone: 305-358-7747 Facsimile: 305-577-1063 Attorneys for Defendants HAL J. KLEINMAN, ESQUIRE, individually; JANET, JENNER & SUGGS, LLC

Certificate of Service

I hereby certify that a true and correct copy of the foregoing was served, via transmission

of Notices of Electronic Filing generated by CM/ECF, on May 8, 2013, on all counsel or parties

of record on the Service List below.

s/James H. Wyman

SERVICE LIST

Eric M. Bradstreet, Esq. [email protected] St. Denis & Davey, P.A. 1300 Riverplace Boulevard, Suite 401 Jacksonville, Florida 32207 Attorneys for Plaintiff G. Michael Keenan, Esq. [email protected] G. Michael Keenan, P.A. 1700 Old Okeechobee Rd., Suite 103 West Palm Beach, FL 33409 Attorneys for Defendants, Lynn Szymoniak, Esquire and The Szymoniak Firm, P.A.

Mark A. Cullen, Esq. [email protected] The Cullen Law Firm, P.A. 2090 Palm Beach Lakes Blvd., Suite 500 West Palm Beach, FL 33409 Attorneys for Defendants, Lynn Szymoniak, Esquire and The Szymoniak Firm, P.A.


Answer of Kleinman in Figueroa v. Szymoniak

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Transcript of Answer of Kleinman in Figueroa v. Szymoniak