Alleged Bribery

Mr. Randazza through his unrelentless pursuit to bring about the demise of Mr. Juravin bribed his previous counsel Cynthia Koroll to provide confidential and privilege information communication From Mr. Juravin in exchange for free legal representation. This fraudulently obtained information was used against Mr. Juravin to his detriment.

Ms. Koroll has been subject to discipline by her state bar. However, Mr. Randazza has yet again evaded justice and will continue to do so until the Florida Bar holds him accountable for all his violations of the ethical rules. He has continuously acted in bad and to the detriment of everyone who he deems an adversary. His unrelentless and auspicious record of success evading justice and the rule of law encourages him to continue to break the ethical rules as there have been no determinative consequences for his bad actions.

The bribery that occurred with Cynthia Koroll is no different than the one that he committed previously. Given the bribery allegations that were substantiated against a member of the Pissed Consumer Legal Group (see attached Exhibit G, Arbitration award which found among other things that Mr. Randazza negotiated a $75,000 bribe), Mr. Juravin is certain that this repeated pattern of bribery and its recurrence will persists not only against him but against member of the public at large who the Florida Bar has sworn to protect and serve.

Don Juravin files this Complaint against Marc Randazza based upon egregious misconduct under the ethical rules and personal persecution of Don Juravin under the guise of the law. His improper actions were not authorized or sanctioned by the law and are in direct violation of the Florida Bar Ethical Rules. “The commission by a lawyer of any act that is unlawful or contrary to honesty and justice, whether the act is committed in the course of the attorney's relations as an attorney or otherwise may constitute cause for discipline.” (Florida Bar Rule 3-4.3)

Applicable Florida Bar Rules

4–3.3(a) (“A lawyer shall not knowingly: (1) make a false statement of fact or law to a tribunal; (2) fail to disclose a material fact to a tribunal when disclosure is necessary to avoid assisting a criminal or fraudulent act by the client; (3) fail to disclose to the tribunal legal authority in the controlling jurisdiction known to the lawyer to be directly adverse to the position of the client and not disclosed by opposing counsel; or (4) permit any witness, including a criminal defendant, to offer testimony or other evidence that the lawyer knows to be false. A lawyer may not offer testimony that the lawyer knows to be false in the form of a narrative unless so ordered by the tribunal. If a lawyer has offered material evidence and thereafter comes to know of its falsity, the lawyer shall take reasonable remedial measures.”).

4 4–3.4(a) (a lawyer shall not unlawfully obstruct another party's access to evidence);

4–3.4(b) (a lawyer shall not fabricate evidence); 4–3.4(c) (a lawyer shall not knowingly disobey an obligation under the rules of a tribunal); 4–3.4(d) (a lawyer shall not make a frivolous discovery request or intentionally fail to comply with a legally proper discovery request);

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 in conduct in connection with the practice of law that is prejudicial to the administration of justice).

4-4.4 (a) In representing a client, a lawyer may not use means that have no substantial purpose other than to embarrass, delay, or burden a third person or knowingly use methods of obtaining evidence that violate the legal rights of such a person.

Rule 4-8.4 (a-b) A Lawyer shall not: (a) violate or attempt to violate the Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another; (b) commit a criminal act that reflects adversely on the lawyer's honesty, trustworthiness, or fitness as a lawyer in other respects.

Rule 4-8.4(d) A lawyer shall not. engage in conduct in connection with the practice of law that is prejudicial to the administration of justice, including to knowingly, or through callous indifference, disparage, humiliate, or discriminate against litigants, jurors, witnesses, court personnel, or other lawyers on any basis, including, but not limited to, on account of race, ethnicity, gender, religion, national origin, disability, marital status, sexual orientation, age, socioeconomic status, employment, or physical characteristic.

Rule 4-1.5 An attorney shall not enter into an agreement for, charge, or collect an illegal, prohibited, or clearly excessive fee or cost, or a fee generated by employment that was obtained through advertising or solicitation not in compliance with the Rules Regulating The Florida Bar. A fee or cost is clearly excessive when: (1) after a review of the facts, a lawyer of ordinary prudence would be left with a definite and firm conviction that the fee or the cost exceeds a reasonable fee or cost for services provided to such a degree as to constitute clear overreaching or an unconscionable demand by the attorney; or (2) the fee or cost is sought or secured by the attorney by means of intentional misrepresentation or fraud upon the client.

Rule 4-3.1(A lawyer shall not bring or defend a proceeding, or assert or controvert an issue therein, unless there is a basis in law and fact for doing so that is not frivolous, which includes a good faith argument for an extension, modification, or reversal of existing law.