Electronically Filed 11052013 092911 AM ET

RECElVED 1152013 093337 John A Tomasino Clerk Supreme Court

BEFORE THE FLORIDA JUDICIAL QUALIFICATIONS COMMISSION STATE OF FLORIDA

SC13-1333 INQUIRY CONCERNING A JUDGE No 12-613

LAURA M WATSON

JUDGE LAURA M WATSONS RESPONSE TO THE JUDICIAL QUALIFICATIONS COMMISSIONS

FIRST REQUEST FOR PRODUCTION

The Honorable Laura M Watson pursuant to Rule 12 of the FJQCR

adopting Florida Rules of Civil Procedure 1350 hereby files her response to the

Judicial Qualifications Commissions (JQC) First Request for Production of

Document served on October 7 2013 The responses are set forth on the attached

page

Respectfully submitted

The Honorable Laura M Watson Circuit Judge 17th JudiCial CirCuit Room 1005B 201 SE 6th Street Fort Lauderdale Florida 33301 Tel (954) 831-6907 jwatsonl 7thficourtsorg

s Laura M Watson LAURA M WATSON Florida Bar No 476330

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was

furnished by email to Miles A McGrane III Esq milesOmcaranelawcom

lisamcaranelawcom The McGrane Law Firm Special Counsel One Datran

Center Ste 1500 9100 South Dadeland Boulevard Miami Florida 333156 Lauri

Waldman Ross Esq RossGirtenLaurilawcom Counsel to the Hearing Panel of

the JQC Ste 1612 9100 South Dadeland Boulevard Miami Florida 333156

Michael L Schneider Esq mschneiderfloridaiaccom General Counsel 1110

Thomasville Road Tallahassee Florida 32303 Robert A Sweetapple Esq and

Alexander D Varkas Jr pleadingssweetapplelawcom Sweetapple Broeker amp

Varkas PL 165 East Boca Raton Road Boca Raton Florida 33432 this 5 day of

November 2013

Pursuant to FJQCR Rule 10(b) a copy is furnished by email to The

Honorable Kerry I Evander evanderkficourtsorg Chair of the JQC 300 S

Beach Street Daytona Beach FL 32114

s Laura M Watson LAURA M WATSON

JUDGE LAURA M WATSONS RESPONSE TO THE JUDICIAL QUALIFICATIONS COMMISSIONS

FIRST REQUEST FOR PRODUCTION

1 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore there are no contingency fee contracts for the representation of any insurance claims against Progressive Insurance Company that exist between Laura M Watson and the persons corporations or other entities identified in the request

To the extent that the JQC seeks contingency fee contracts between Laura M Watson PA dba Watson and Lentner these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

3

2 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore there are no contingency fee contracts for the representation of any claims or actions for bad faith unfair claims practice improper claims handling fraud andor unjust enrichment in connection with any insurance claims against Progressive Insurance Company that exist between Laura M Watson and the persons corporations or other entities identified in the request

To the extent that the JQC seeks contingency fee contracts between Laura M Watson PA dba Watson and Lentner these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalfof these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

3 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore there are no closing statements for the representation of these persons corporations or other entities in

4

connection with any insurance claims against Progressive Insurance Company that exist between Laura M Watson and the persons corporations or other entities identified in the request

To the extent that the JQC seeks closing statements between Laura M Watson PA dba Watson and Lentner for the representation of the persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

4 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore there are no closing statements for the representation of these persons corporations or other entities in connection with any insurance claims or actions for bad faith unfair claims practice improper claims handling fraud and or unjust enrichment against Progressive Insurance Company that exist between Laura M Watson and the persons corporations or other entities identified in the request

To the extent that the JQC seeks closing statements between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalfof a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without

compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla l DCA 1978)

5 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-17(a) and (b) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This

6

rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

6 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-17(a) and (b) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an

7

opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Ass n of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

7 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-18(g) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of

8

the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Ass n of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla l DCA 1978)

8 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-18(g) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300

9

(Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

10

2 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore there are no contingency fee contracts for the representation of any claims or actions for bad faith unfair claims practice improper claims handling fraud andor unjust enrichment in connection with any insurance claims against Progressive Insurance Company that exist between Laura M Watson and the persons corporations or other entities identified in the request

To the extent that the JQC seeks contingency fee contracts between Laura M Watson PA dba Watson and Lentner these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalfof these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

3 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore there are no closing statements for the representation of these persons corporations or other entities in

4

connection with any insurance claims against Progressive Insurance Company that exist between Laura M Watson and the persons corporations or other entities identified in the request

To the extent that the JQC seeks closing statements between Laura M Watson PA dba Watson and Lentner for the representation of the persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

4 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore there are no closing statements for the representation of these persons corporations or other entities in connection with any insurance claims or actions for bad faith unfair claims practice improper claims handling fraud and or unjust enrichment against Progressive Insurance Company that exist between Laura M Watson and the persons corporations or other entities identified in the request

To the extent that the JQC seeks closing statements between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalfof a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without

compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla l DCA 1978)

5 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-17(a) and (b) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This

6

rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

6 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-17(a) and (b) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an

7

opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Ass n of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

7 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-18(g) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of

8

the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Ass n of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla l DCA 1978)

8 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-18(g) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300

9

(Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

10

connection with any insurance claims against Progressive Insurance Company that exist between Laura M Watson and the persons corporations or other entities identified in the request

To the extent that the JQC seeks closing statements between Laura M Watson PA dba Watson and Lentner for the representation of the persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

4 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore there are no closing statements for the representation of these persons corporations or other entities in connection with any insurance claims or actions for bad faith unfair claims practice improper claims handling fraud and or unjust enrichment against Progressive Insurance Company that exist between Laura M Watson and the persons corporations or other entities identified in the request

To the extent that the JQC seeks closing statements between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalfof a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without

compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla l DCA 1978)

5 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-17(a) and (b) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This

6

rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

6 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-17(a) and (b) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an

7

opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Ass n of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

7 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-18(g) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of

8

the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Ass n of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla l DCA 1978)

8 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-18(g) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300

9

(Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

10

To the extent that the JQC seeks closing statements between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalfof a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without

compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla l DCA 1978)

5 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-17(a) and (b) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This

6

rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

6 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-17(a) and (b) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an

7

opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Ass n of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

7 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-18(g) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of

8

the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Ass n of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla l DCA 1978)

8 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-18(g) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300

9

(Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

10

rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

6 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-17(a) and (b) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an

7

opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Ass n of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

7 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-18(g) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of

8

the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Ass n of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla l DCA 1978)

8 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-18(g) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300

9

(Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

10

opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Ass n of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

7 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-18(g) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of

8

the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Ass n of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla l DCA 1978)

8 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-18(g) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300

9

(Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

10

the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300 (Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Ass n of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla l DCA 1978)

8 Laura M Watson never represented any of the persons corporations or other entities identified in paragraphs (a) through (tt) and therefore does not have any of the documents requested in this paragraph

To the extent that the JQC seeks any and all documents as defined and required by Rule 4-18(g) of the Rules of Professional Responsibility between Laura M Watson PA dba Watson and Lentner for the representation of persons corporations or other entities identified in the request these entities are not parties to this action and such documents must be sought pursuant to Rule 1351 for production of documents and things from a person who is not a party by issuance of a subpoena directing the production of the documents or things This rule provides the exclusive procedure for obtaining documents or things by subpoena from nonparties without deposing the custodian or other person in possession of the documents or things pursuant to rule 1310 FlaRCivP 1351(a) The procedure set forth in the rule requires notice to the parties and an opportunity to object to the issuance of the subpoena Once the subpoena is served the nonparty then also has an opportunity to object

Once Laura M Watson became a judge she was no longer permitted to act as an attorney on behalf of a corporation or other entity A judge shall not practice law Notwithstanding this prohibition a judge may act pro se and may without compensation give legal advice to and draft or review documents for a member of the judges family Canon 5 (G) Code of Judicial Conduct Judge Watson does not represent Laura M Watson PA dba Watson and Lentner and is precluded from responding on behalf of these entities A corporation may not represent itself through non-lawyer employees officers or shareholders This rule applies even where the non-lawyer purporting to represent the corporation is the sole shareholder of the corporation Richter v Higdon Homes Inc 544 So2d 300

9

(Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

10

(Fla 1 DCA 1989) citing Nicholson Supply Co v First Federal Savings and Loan Assn of Hardee County 184 So2d 438 (Fla 2d DCA 1966) and Southeastern Associations Inc v First Georgia Bank 362 So2d 967 (Fla 1 DCA 1978)

10