Unfortunately, our profession has its share of overly aggressive counsel who sometimes skirt the edges of "zealous representation," resulting in potential sanctions under Fla. Stat. Sect. 57.105.

Please click below to review a form of Safe Harbor Letter and proposed sanctions motion which I prepared. 

This case was particularly egregious because of (i) the utter fallacy of the claim and (ii) the attempt to create a class, which if certified and was successful, could have cost the client an extraordinary amount of potential damages. The potential for industry wide ramifications was immense.

Fortunately, the frivolous complaint was withdrawn following the issuance of the Safe harbor letter.