Phillip Bleicher – A Man Who Stole $3 Million from Public Schools, Intentionally Exposes Employees to Aids, Operates Brothels in Residential Homes, Fabricates Evidence in Court, and Evades Taxes
In November 2015, I responded to a Craigslist ad from a company looking for an attorney to assist in its litigation for alleged infringements of its intellectual property. The ad was posted by the world-class scumbag and career-criminal Phillip Bleicher. For about one month, I worked on one of Mr. Bleicher’s numerous frivolous lawsuits, in which he extorts money out of innocent parties by threatening excessive litigation. After I had already done the work, Mr. Bleicher refused to pay me the $500 I billed him (a ridiculously small amount for a month’s worth of work). In addition to refusing to pay me anything, it became clear to me that Mr. Bleicher was using my services, and the services of other attorneys via Craigslist, to assist in his ongoing criminal activities. Consequently, I terminated my representation of Mr. Bleicher.
That is when shit got real. Mr. Bleicher attempted to blackmail me, demanding several thousand dollars otherwise he threatened file a bogus bar complaint against me, as well as, defame my name on the internet with slanderous and false allegations.
I made the following counter-offer to Mr. Bleicher: “go fuck yourself and pay me for the work I did.” Mr. Bleicher then filed a bar complaint against me. The complaint was dismissed after I submitted the following response to the Florida Bar with copies to several news organizations and government agencies.
How Mr. Bleicher is not in prison is mind-boggling. The public must be made aware of this man and in order to do so, I reproduce my response here verbatim with links to the exhibits supporting my claims against this monster:
Response to Mr. Bleicher’s False Complaint and Revelation of His Transgressions
March 17, 2016
Maura Canter, Esquire
The Florida Bar
Attorney Consumer Assistance Program
651 East Jefferson Street
Tallahassee, FL 32399-2300
Re: Florida Bar File No. 2016-50,697(17E)
Response to Phillip Bleicher’s False and Slanderous Allegations and Open Letter to Governmental Agencies Regarding Mr. Bleicher’s Ongoing Illegal Activities
Dear Ms. Canter:
I was overwhelmed with sadness to learn that the Florida Bar would entertain the obviously false and slanderous allegations made by Phillip Bleicher (“Mr. Bleicher”). In actuality, the defamatory “complaint” brought by Mr. Bleicher is the culmination of his failed attempt to blackmail and fraudulently extort three Florida attorneys, including myself. See Bleicher’s Blackmail attached as Exhibit A. Mr. Bleicher’s attempted blackmail included a copy of the instant complaint, a “press release” in which Mr. Bleicher makes libelous statements about me, and a hastily put together and facially dismissible proposed “malpractice” complaint. Id. These documents were accompanied with a letter, which unlawfully demanded $10,000 hush money in exchange for not filing the frivolous Bar complaint and “malpractice” lawsuit. Id. Mr. Bleicher made identical blackmail attempts against fellow Florida attorneys Ursula Jackson (“Ms. Jackson”) and Matthew Zukowsky (“Mr. Zukowsky”). Id.
Mr. Bleicher’s real issue with me is that I did what I was ethically and legally required to do rather than the unethical and illegal actions he wanted me to take to assist in his ongoing crimes and fraud. Additionally, Mr. Bleicher is motived by revenge. After he refused to pay me $500 for my two months’ of work, I filed a charging lien on his case. See Charging Lien attached as Exhibit B. Before quickly dispatching with his ridiculous character assassination attempt, it is important that the Bar consider the background to this matter, which Mr. Bleicher conveniently omits from his perjurious statements. Before doing so, I address the disclosure of confidential information that I must make to clear my good name.
I. Mr. Bleicher’s Actions Require or Allow Disclosure of Confidential Information
Florida Rule of Professional Conduct 4-1.6 provides that “[a] lawyer shall not reveal information relating to representation of a client except as stated . . . .” Fla. R. Pro. Cond. 4-1.6(a). However, “[a] lawyer shall reveal such information . . . necessary to prevent a client from committing a crime.” Id. at (b)(1) (emphasis added). Additionally, “[a] lawyer may reveal such information . . . necessary to establish a claim or defense on behalf of the lawyer in a controversy between the lawyer and client; to respond to allegations in any proceeding concerning the lawyer’s representation of the client; or to comply with the Rules of Professional Conduct.” Id. at (c)(2); (4); (5) (emphasis added).
Alas, in addressing Mr. Bleicher’s outrageously slanderous filth, I have no choice but to dismantle his revenge fantasy with truth, logic, and the disclosure of his multitude of ongoing criminal activities. Considering he is swindling the IRS, committing perjury in Federal Court, and violating numerous State and Federal laws, it is quite odd Mr. Bleicher would want to make this a matter of public record. Nevertheless, the disclosures that follow are permissible under the above-cited rules.
II. Open Letter to Governmental Agencies Concerning Mr. Bleicher’s Illegal Activities
Before I vindicate myself, I must advise you of the character of the man who has levied these false claims against me. Mr. Bleicher is a snake oil peddling conman. In the words of one of his many outspoken critics, “Bleicher and his company are also well-known for frivolous lawsuits against detractors or, against those who amplify outside findings and facts, and using underhanded moves, abusing the law . . . .” See Gonzalez, Jagged Press attached as Exhibit C (emphasis added). Although his falsified tax returns fooled the IRS otherwise for several years, Mr. Bleicher makes a very comfortable living in the production and distribution of homosexual pornography through his various companies.
Mr. Bleicher is the CEO of Flava Works, Inc. (“Flava Works”). Flava Works is a Florida and Illinois corporation, which produces homosexual pornography featuring African-American and Hispanic men. Flava Works produces a quarterly magazine, FlavaMen, which showcases its models and contains editorials from contributing writers. See FlavaMen attached as Exhibit D. Flava Works also operates several websites offering pornographic images and videos, including Cocodorm.com, PapiCock.com, ThugBoy.com, CocoBoyz.com, RawRods.com, MixItUpBoy.com, TopThugs.com, FlavaCams.com, and FlavaMen.com. Thugsforsex.com is Flava Work’s online dating portal for men of color. However, most of the controversy surrounding Flava Works has to do with Cocodorm, a live interactive residence where models are hired to live together in a dorm-like environment.
A. Mr. Bleicher Intentionally Exposes Unwitting Performers to HIV and Exploits Minorities – or as the Chicago Department of Public Health calls it – Borderline “Illegal Servitude”
Mr. Bleicher forbids performers from using condoms. He also does not believe in testing his performers for HIV or informing performers that co-performers are HIV positive before “performances.” In November 2005, the Chicago Department of Public Health (the “CDPH”) received reports of the transmission of HIV occurring in a resident of a Chicago apartment reported as a non-adherent carrier. The CDPH’s investigation revealed the interworking of Mr. Bleicher’s operations. See CDPH, Investigation of a Cluster of Syphilis and HIV Infections associated with an Internet Pornography Website attached as Exhibit E.
As the CDPH found, Mr. Bleicher’s internet-based pornography business featured young Black and Latino men. See Ex. E. These men were employed as “models” and lived together at a residential apartment, which was referred to as a “dormitory.” Id. In exchange for room, board, and modest wages, the “models” allowed Mr. Bleicher to videotape and photograph them having sex with each other in the “dormitory.” Id. Mr. Bleicher’s website featured free previews, members only services, photos, live webcams, live video chat, streaming video, stories, and web logs. Id. The website also sold porno magazines, calendars, and DVDs. Id. Additionally the website broadcast live daily sex acts. Id. Mr. Bleicher also doubled as a pimp, using his “models” in a private male escort service. Id. The CDPH identified nineteen “models” from Mr. Bleicher’s business. See Ex. E. All were African-American. Id. Nine of the “models” (47%) had HIV. Id. Another nine of the “models” (47%) had syphilis. Id. Three of the “models” had both HIV and syphilis. Id.
Unfortunately, the CDPH’s investigation was hampered by Mr. Bleicher’s interference. Id. He forbid employees and “models” from speaking with the CDPH. Id. He was also non-responsive to CDPH’s requests to work with them to jointly develop a corrective action plan. Id. This prompted the issuance of a Notice of City Inspection to assess Mr. Bleicher’s brothel for compliance with health, safety, business, and licensing codes. Id. Additional concern was raised over Mr. Bleicher’s apparent exploitation of his “models,” and the nature of their work. Id. The CDPH’s claimed that Mr. Bleicher’s company was practicing what bordered on “illegal servitude.” Id. “[P]rominent African-American leaders have also been critical of Bleicher, who is white, for what they call the exploitation of young black and Latino men.” See Ex. C. “Most of them are reportedly at-risk youths, runaways, homeless and easily manipulated.” Id. On April 20, 2006, the CDPH issued a cease and desist order prohibiting Flava Works from operating in Chicago. See Cease and Desist Order attached as Exhibit F.
B. Mr. Bleicher’s Fraudulent Charity Stole more than $3 Million from Schools Nationwide
In January 2006, the Illinois Attorney General filed a civil suit against Mr. Bleicher charging him with operating a fraudulent charity that bilked schools nationwide out of millions of dollars. See Fraudulent Charity Allegedly Collected More Than $3 Million; Used Proceeds to Make Purchases for International Travel and at a Liposuction Clinic attached as Exhibit G. Mr. Bleicher was the founder of the now-defunct charity, Student Leadership Network (the “Network”), which was promoted as offering conferences and leadership programs for student council members. Id. Through the Network, Mr. Bleicher contacted schools across the Country and persuaded some to sign up for the program. Id.
Mr. Bleicher then sent fraudulent invoices to the schools and, in addition to cashing those checks, created forged copies of the checks to withdraw additional funds from the schools’ bank accounts. See Ex. G. Mr. Bleicher successfully cashed many of the checks before the schools and banks realized what happened. Id. Mr. Bleicher and his co-conspirators collected more than $3 million dollars for goods and services that they never delivered. Id. The civil suit against Mr. Bleicher was later dropped when officials decided to pursue Federal criminal charges instead. Id.
C. Fun in the Sun: Mr. Bleicher Flees to Miami
In May 2006, Mr. Bleicher fled to Miami to avoid the civil and criminal repercussions of the above-referenced matters. Once in Miami, Mr. Bleicher resumed operations and launched a new homosexual brothel based out of a residential home. According to the Miami Herald, “CocoDorm offers its young, muscular males $1,200 a month along with free room and board while requiring they masturbate and have group sex in front of cameras.” See Miami Herald Articles attached as Exhibit H. The City began receiving complaints from the brothel’s neighboring residents, mostly families with young children. Id. In May 2007, the Miami Department of Code Enforcement visited the residence and imposed citations for: (1) illegal rooming house; (2) adult entertainment not permitted in C-1 zone property; (3) failure to maintain exterior of property; (4) failure to maintain lot in safe, clean condition and prevent the accumulation of debris, trash or dense growth of grass; and (5) illegally operating a business in a residential zone. Id. (emphasis added).
Miami eventually ruled that Flava Works was “illegally running an adult entertainment business out of a single-family home . . . and ordered that those operations cease.” See Ex. H. Not one to comply with the law voluntarily, Mr. Bleicher sued Miami in Federal Court and in an admittedly brilliant maneuver, reframed the argument as a First Amendment issue rather than the zoning issue it was. Id. Flava Works also argued that it was not running an adult-oriented business out of the house and that its “business transactions” did not “take place” in the residential neighborhood, but rather in “virtual space.” Id.
In January 2009, the Southern District ruled in its favor, “[b]ecause the public offering by Flava Works, Inc. occurs via cocodorm.com in cyberspace, and not in a particular geographic location, the City of Miami zoning ordinance cannot be applied to the 503 residence.” However, in June 2010 the Eleventh Circuit reversed, holding that regardless of whether Flava Works was an adult entertainment establishment, it was a business operation, and Miami’s zoning ordinances forbid operating a business in a residential zone. Mr. Bleicher did not let this set back faze him. He continued to illegally operate Flava Works in Miami for several more years. According to Mr. Bleicher, Flava Works returned to Chicago in October 2014. If this is true, he is operating in violation of the CDPH’s cease and desist order still in effect. See Ex. F.
D. Mr. Bleicher Manufactured Evidence in Federal Court
Always itching to employ his forgery skills, Mr. Bleicher did so in, Flava Works, Inc. v. Momient, 11-cv-06306 (Ill. N.D. 2011). There, the Northern District of Illinois determined that Mr. Bleicher forged the defendant’s signature on a contract in order to win a pending lawsuit. See Order attached as Exhibit I. Mr. Bleicher then had his attorney submit the forgery to the Court as evidence. Id. Referring to Mr. Bleicher’s conduct, the Court stated, “[w]hat we have, then, is the most egregious fraud on the court that this Court has encountered in its nearly 33 years on the bench.” Id. (emphasis added). “Fortunately courts are rarely called upon to consider fraud on-the-court conduct of the type engaged in by Flava.” Id. (emphasis added). “What, then, is the appropriate judicial response to such an egregious abuse of the judicial system by such a blatant fraud on the Court?” Id. The response was dismissal of Mr. Bleicher’s action. Id.
E. Mr. Bleicher Evades State and Federal Income Taxes
Mr. Bleicher does not believe in giving Uncle Sam his cut. Throughout the above-described incidents, Mr. Bleicher has evaded and continues to evade State and Federal income taxes. Through falsified tax returns, Mr. Bleicher has deprived both State and Federal governments out of millions in tax revenue. For example, in 2014 Flava Works generated in excess of $423,000 in income. See 2014 Tax Return attached as Exhibit J. However, this income was conveniently offset by nearly $433,000 in expenses. Id. With gross income of about -$10,000, Flava Works did not pay any taxes for 2014. Id. According to its tax returns, Flava Works runs at or near a deficit every year yet somehow the company has managed to stay in business for over a decade. The IRS and State agencies eventually caught on. In April 2015, Mr. Bleicher entered into a settlement agreement with the IRS. He is currently on a payment plan with them for over $500,000 in unpaid back taxes. However, it is clear the IRS is unaware of the full extent of Mr. Bleicher’s tax avoidance.
Although Mr. Bleicher was advised numerous times, by prior attorneys and I, to simply pay the judgment described below, he steadfastly refused with no apparent legal justification. This was odd since the $30,000 judgment is pocket change to his company. See Ex. J. I now know that Mr. Bleicher cannot satisfy the judgment because he has and is continuing to commit tax fraud as well as other Federal and State crimes. Since Mr. Bleicher professes poverty to the outside world, if he paid a $30,000 (now $40,000) judgment, it could potentially alert governmental agencies, particularly the IRS, to take a closer look at Flava Works. Mr. Bleicher believes he cannot take that risk. He knows he would not fare well in Federal prison.
F. Mr. Bleicher Fraudulently Concealed and Continues to Fraudulently Conceal Assets
In order to avoid service in the declaratory action mentioned below, Mr. Bleicher administratively dissolved Flava Works in Florida in October 2015. Additionally, in order to avoid payment of the judgment discussed below, Illinois attorney Juneitha Shambee (“Ms. Shambee”) advised Mr. Bleicher to fraudulently conceal most of Flava Work’s assets by moving them into various shell corporations he also owns. Flava Works is only one of a dozen dummy corporations Mr. Bleicher uses to facilitate his crimes. These entities include, at least, Flavaworks, Flava Works Worldwide, Blactino Media, Tube Media Labs, and Lukebaby Productions. However, the difference is in name only, each including Flava Works is the alter ego of Mr. Bleicher.
III. Flava Works, Inc. v. A4A Reseau, Inc. – a Procedural History
I was the fourth Florida attorney, and fifth attorney overall, in less than two years to be involved in Mr. Bleicher’s lawsuit, Flava Works, Inc. v. A4A Reseau, Inc., No. 14-cv-23208 (Fla. S.D. 2014), which is currently pending in the Southern District of Florida (the “Lawsuit”). See Docket attached as Exhibit K (individual docket entries will be referred to by docket number.
Ms. Jackson, the first Florida attorney Mr. Bleicher used in the Lawsuit, filed a one-count complaint for copyright infringement in February 2014. On January 16, 2015, the defendants, represented by John Bradley (“Mr. Bradley”) filed an answer. See Doc. No. 21. Four days after the answer was filed, Mr. Bleicher instructed Ms. Jackson to file a voluntary dismissal. See Doc. No. 22. Mr. Bleicher falsely stated to the Court that he fired Ms. Jackson the same day. See Doc. No. 36. However, I was told by Mr. Bleicher that Ms. Jackson “disappeared.” I believe this was likely after she encountered the same or similar issues with him as I did.
Throughout the Lawsuit, Mr. Bleicher has been assisted in his fraudulent conduct by Ms. Shambee, who was recently admitted to the Florida Bar. On January 21, 2015, Ms. Shambee committed gross malpractice by using the identical complaint to initiate a new action based on the same claims against the same defendants in Illinois, Flava Works, Inc. v. A4A Reseau, Inc., 15-cv-00610 (Ill. N.D. 2015). See Complaints attached as Exhibit L. Ms. Shambee negligently or intentionally disregarded Federal Rule of Civil Procedure 41, which provides “[i]f a plaintiff who previously dismissed an action in any court files an action based on or including the same claim against the same defendant, the court: (1) may order the plaintiff to pay all or part of the costs of that previous action; and (2) may stay the proceedings until the plaintiff has complied.” Fed. R. Civ. Pro. 41(d) (emphasis added). This error was compounded by Ms. Shambee’s additional failure to review controlling case law in the Eleventh Circuit, which holds that attorney fees are recoverable as “costs” under Rule 41(d). Ms. Shambee’s actions cost Mr. Bleicher $30,000. See Doc. No. 36. It is Ms. Shambee’s negligence that Mr. Bleicher has attempted to pin on each of the Florida attorneys mentioned in this response and ultimately lead to his blackmail attempts and bar complaints. See Ex. A.
Immediately, Mr. Bradley pounced on Ms. Shambee’s blunder and, pursuant to Rule 41(d), sought a stay of the newly filed Illinois action and recovery of his client’s costs, including attorney fees in the Lawsuit. See Doc. No. 24. Mr. Bradley also filed a declaratory judgment action in the Southern District, solely for the purpose of keeping the matter in Miami. See A4A Reseau, Inc. v. Flava Works, Inc., Phillip Bleicher, No. 15-cv-20245 (Fla. S.D. 2015). Mr. Bradley also appeared in the Illinois lawsuit and successfully had the action transferred to Miami. Upon transfer, the matter was assigned case number 15-cv-21592. Mr. Bleicher then attempted to file a pro se motion for an extension of time to respond to Mr. Bradley’s motion. See Doc. No. 25. On February 25, 2015, the Court struck Mr. Bleicher’s filing since corporations must be represented by counsel. See Doc. No. 26. The Court gave Mr. Bleicher until March 4 to find replacement counsel and to respond to Mr. Bradley’s motion. Id.
Mr. Bleicher failed to comply with the Court’s order. See Doc. No. 27. Consequently, on March 5, 2015, the Court granted Mr. Bradley’s motion as to the entitlement to attorney fees. See Doc. No. 28. The Court requested supporting material as to the amount to be awarded. Id. Mr. Bleicher’s second Florida attorney was Mr. Zukowsky. Mr. Zukowsky filed a motion for Ms. Shambee to appear pro hac vice on March 6. See Doc. No. 34. The motion was denied because, among other reasons, Ms. Shambee did not comply with the Local Rule requiring certification that she has studied the Court’s Local Rules. See Doc. No. 35.
Ms. Shambee or Mr. Zukowsky filed a response opposing Mr. Bradley’s already granted motion for attorney fees, as well as, a motion to vacate the order itself. See Doc. No. 29; 33. The Court denied the motion to vacate stating:
On March 5 . . . after the Court had entered its Order Granting Defendants’ Motion for Attorneys’ Fees, Plaintiff filed a Motion to Vacate that Order pursuant to Rule 60(b) . . . . Rule 60(b) also contains a “catch−all” provision allowing reconsideration for “any other reason that justifies relief.” Plaintiff appears to invoke this “catch−all” provision, arguing that it should be entitled to relief because: (1) it “has attempted profusely to retain an attorney,” which it finally did on March 4, 2015, the day the Response was due; and (2) new counsel attempted to file a Response, but could not do so because he is not authorized to file through CM/ECF. The Court finds that Plaintiff has not satisfied the Rule 60(b) standard for relief from the Court’s Order. . . . Plaintiff had a full month between the date on which Defendants filed their Motion for Attorneys’ Fees . . . and the extended deadline to file a Response . . . to secure an attorney who could timely file a Response. Plaintiff’s alleged inability to secure an attorney within that period that could timely file a Response does not constitute an “extraordinary circumstances” entitling it to relief.
See Doc. No. 36 (emphasis added) (grammatical alternations made). Mr. Bradley then filed a motion seeking $43,566.75 in fees, to which Mr. Zukowsky filed a response. See Doc. No. 39; 44; 45. The Court determined that the reasonable amount of attorney fees was $28,060.57 and entered a judgment for that amount against Flava Works (the “Judgment”). See Doc. No. 46.
Mr. Bleicher than began a series of maneuvers with the sole purpose of eluding his court ordered obligation to pay the Judgment. Mr. Bleicher’s primary argument, which I later learned was patently false, was that his company was broke and no money was coming in due to the defendants’ alleged ongoing copyright infringement. First, Mr. Bleicher failed to complete a judgment debtor worksheet without legal justification. This forced Mr. Bradley to file a motion to compel, which the Court granted. See Doc. No. 51; 58. Mr. Bradley then sought discovery to aide collection on the Judgment. See Doc. No. 60; 61. Among other things, Mr. Bradley sought Flava Works bank statements, which would support of refute Mr. Bleicher’s claim of insolvency. Mr. Bleicher neither provided the discovery nor objected to it within the applicable time limits. This forced Mr. Bradley to file a motion to compel the discovery. See Doc. No. 60.
Mr. Zukowsky subsequently withdrew. See Doc. No. 76; 77. Mr. Bleicher’s third Florida attorney was Joshua Sheskin (“Mr. Sheskin”). See Doc. No. 59. At Mr. Bleicher’s insistence, Mr. Sheskin filed another motion seeking to vacate the order granting attorney fees. See Doc. No. 63. Although the Court ordered Mr. Bleicher to complete the worksheet by July 9, he did not do so until September 2. See Doc. No. 71. Mr. Sheskin withdrew on October 8, 2015. See Doc. No. 78. Although I originally responded to his misleading Craigslist ad in July, I was not hired by Mr. Bleicher until October 9. See Doc. No. 79. At the time of my appearance, Mr. Bleicher had not paid the Judgment and Mr. Bradley’s discovery requests were still outstanding. The second motion to vacate the order awarding attorney fees was also pending.
Mr. Bleicher is a pathological liar and quite good at it. Prior to entering my appearance, I participated in a conference call with Mr. Bleicher and Ms. Shambee. My sole mistake in this matter was taking their false explanation of the proceedings and finger pointing as the truth. Both feed me false stories that Mr. Bradley was a “bully” who “intimated” the prior attorneys into quitting out of frustration. Both claimed Ms. Jackson, Mr. Zukowsky, and Mr. Sheskin had committed malpractice. I know what you are thinking, “three lawyers in a row committed malpractice?” Yes, Mr. Bleicher is that convincing of a liar. Mr. Bleicher was insistent that I needed to immediately file a motion to substitute myself into the case and remove Mr. Sheskin. I later came to learn that Mr. Bleicher fired Mr. Sheskin to prevent him from turning over discovery, including Flava Works’ bank records, which Mr. Sheskin had received the day before. I also later came to learn that Mr. Bleicher never had any intention of complying with any of the Court’s orders.
During my conversation with Mr. Bleicher and Ms. Shambee, they did not even seem cognizant of the need to provide discovery. Rather, their sole concern was having the Judgment overturned. However, I advised them that I could not argue the second motion to vacate in good faith because (1) the Court already denied an identical motion to do so (Doc. No. 33; 36); and (2) either no new grounds were being raised or the new grounds were irrelevant. I advised them the deadline to appeal the Judgment had already passed when they contacted me. However, I specifically asked why, if they believed the Judgment was incorrect and a motion to vacate had already been denied, had they not appealed to the Circuit Court. Neither provided an intelligible answer.
I also specifically asked them why the case was dismissed in Florida and then re-filed in Illinois the next day. Neither provided an intelligible answer. However, Ms. Shambee admitted that before refilling in Illinois, she failed to research the controlling case law in the Eleventh Circuit that subjected her client to the Judgment. Mr. Bleicher’s selling point to his attorneys is a 25% share of any judgment. I have since come to learn that Ms. Shambee’s motivation in dismissing and refilling the action in Chicago was to ensure herself a larger portion of the potential recovery by cutting out any Florida attorney.
Moments after appearing in the case, Mr. Bradley peppered me with several strongly worded emails seeking agreement on a hearing date for his pending second motion to compel. On October 19, after we could not reach agreement, the Court held a telephonic conference for the sole purpose of scheduling a hearing on Mr. Bradley’s motion. See Doc. No. 81; 82. During the conference, the Court expressed great displeasure with Mr. Bleicher’s antics and set the matter for hearing on November 20. See Doc. No. 83. However, the Court specifically stated to me that if Mr. Bleicher did not provide the discovery thereby obviating the need for a hearing, the Court would enter additional sanctions against Flava Works and maybe even against me personally.
Immediately following the phone conference, I informed Mr. Bleicher of the Court’s statements. Therefore, Mr. Bleicher had an entire month to provide the outstanding discovery, which again consisted of bank statements, tax returns, and internal corporate documents. Mr. Bleicher maintained throughout both Mr. Sheskin’s representation and mine that he was encountering great difficulty in obtaining the statements for his own bank accounts. This of course is strange since it is possible to obtain bank statements online in a matter of minutes.
As the November 20 hearing approached, I become increasingly concerned over Mr. Bleicher’s “inability” to obtain copies of his own bank statements. However, in an epiphany, I thought of an obvious solution to his difficulties: subpoena the records. Therefore, I prepared subpoenas for each bank and the IRS and sent them off. See Subpoenas attached as Exhibit M. I thought Mr. Bleicher would be delighted by my ingenious approach. However, when he learned about the subpoenas, Mr. Bleicher was unusually outraged. I know now he had this reaction because of his ongoing tax evasion and fraudulent concealment of assets.
In any event, my efforts were largely successful and most of the previously “unobtainable” bank records were obtained prior to the hearing. Shortly before the hearing date, Mr. Bleicher and Ms. Shambee insisted that I file a motion for protective order and that the bank records be heavily redacted and marked as “for attorney’s eyes only,” despite my advice that there were no grounds for doing so. As I told them, the discovery had been outstanding for months and the failure to timely object to the requests acts as a waiver of any non-privilege objections. In addition, the names of individuals on the bank statements were not “trade secrets.”
On November 19, 2015, I filed a motion to withdraw for the ethical and legal reasons discussed below. See Doc. No. 91. The motion was denied by the Court. See Doc. No. 92. Thus, I was required to attend the hearing on November 20. The details of what transpired at the hearing are discussed below. At the conclusion of the hearing, the Court granted Mr. Bradley’s motion and awarded him an additional $10,000 in attorney fees. Mr. Bleicher was ordered to provide the outstanding discovery by November 30 and to pay the $10,000 by December 10.
As we exited the courthouse, Mr. Bleicher thanked me and assured me that a check for my services had been placed in the mail. He further indicated that he alone would be obtaining the outstanding discovery. A few days after the hearing, Mr. Bleicher sent me an email asking if the order had been “entered” yet. As stated, the Court announced its ruling at the hearing. Although Mr. Bleicher was present at the hearing and took copious notes during it, including the deadlines, he professed confusion over the ruling and appeared angered that I had not immediately forwarded him the PDF version of the ruling announced orally at hearing. I apologized for not getting it to him but as I explained: (1) the Order was entered the day before Thanksgiving; (2) I came down with a cold on Thanksgiving and sat at the dinner table wrapped in a blanket; and (3) the PDF order did not differ in any way from the Court’s oral ruling, which he had taken notes on.
Following the hearing, Mr. Bleicher failed to pay the $10,000 sanction. He also failed to timely provide the outstanding discovery. Meanwhile, I still had not received payment despite Mr. Bleicher’s claim that a check had been mailed. Finally, on December 15, after Mr. Bleicher failed to respond to my follow-up request for payment, I filed a charging lien. See Ex. B. This ended my involvement with this matter or so I thought until receiving Mr. Bleicher’s blackmail demands. See Ex. A. I was baffled to learn that Mr. Bleicher was not satisfied with my work. If I did not request the statements directly from the banks myself, the November 20 hearing would have been very different. In other words, but for my unilateral efforts to obtain and provide outstanding discovery, without Mr. Bleicher’s assistance and as I now know active resistance, a larger judgment would have been entered against Flava Works.
Simultaneously with Mr. Bleicher’s extortion attempt, his co-conspirator Ms. Shambee requested my consent to removal from the notice list. After indicating that I would not, Ms. Shambee filed a motion to remove Ms. Jackson and myself from the docket. See Doc. No. 108. I filed a response in opposition. See Doc. No. 113. The Court granted the request to remove Ms. Jackson but denied the request to remove me from the docket. See Doc. No. 115. The baseless filings did not end there. Ms. Shambee filed a motion to reconsider the order denying her request to remove me from the docket. See Doc. No. 116. I again filed a response and the Court denied the motion. See Doc. No. 117; 121.
IV. Mr. Bleicher’s Complaint is Part of a Failed Attempt, Conspired with Ms. Shambee, to Extort and Blackmail Three Florida Attorneys including Myself
Finally, I will refute Mr. Bleicher’s inventive but false allegations against me. I note several of the “exhibits” referenced to in Mr. Bleicher’s complaint were not attached to the copy I received.
A. I Never Failed to Communicate with Mr. Bleicher or his Co-Conspirator Ms. Shambee. Conversely, Mr. Bleicher’s Unbearable Oversight Impairs the Professional Judgment of the Attorney’s he Hires
Florida Rule of Professional Conduct 4-1.4, provides “A lawyer shall keep a client reasonably informed about the status of a matter and promptly comply with reasonable requests for information.” Fla. R. Pro. Cond. 4-1.4(a). See also Fla. R. Pro. Cond. 4-1.13(a) (emphasis added) (“[a] lawyer employed or retained by an organization represents the organization acting through its duly authorized constituents.”). However, “[a] lawyer shall not permit a person who recommends, employs, or pays the lawyer to render legal services for another to direct or regulate the lawyer’s professional judgment in rendering such legal services.” Fla. R. Pro. Cond. 4-5.4(d) (emphasis added). Initially I note that Mr. Bleicher’s extensive oversight of the attorneys he hires plainly violates Rule 4-5.4(d), which prohibits a non-attorney from impairing the independent professional judgment of an attorney.
Either way, Mr. Bleicher falsely alleges that I did not communicate with him during the two months I represented his seedy business. However, he does not point to a single instance in which I failed to do so. He does not because his allegations are imaginary and contrary to reality. Mr. Bleicher or Ms. Shambee was included on every significant communication I sent in this matter. It is true that Mr. Bleicher was not included on selected communications with opposing counsel or the Court, this was done because I felt it would have been improper to do so on these specific communications. However, even where Mr. Bleicher was not directly included, Ms. Shambee was. Therefore, Mr. Bleicher’s claims that I failed to communicate with him are without merit.
B. There was no Improper Judicial Communication, Mr. Bleicher either Misunderstands or, more likely, takes a Docket Entry out of Context
Mr. Bleicher is referencing docket entry 89. However, he does so out of content. He also neglects to mention the procedures established in the Lawsuit, which state “[t]he Discovery Procedures . . . in this matter require that source materials for discovery hearings be delivered via handdelivery or through a document that is emailed to the [Magistrate’s] CM/ECF mailbox . . .” See Doc. No. 68 (emphasis added).
On October 23, in accordance with those discovery procedures, I emailed source material for the upcoming November 20 discovery hearing to the Magistrate’s email. Specifically, I sent copies of the subpoenas I propounded to rebut Mr. Bradley’s assertion that we were not even attempting to provide discovery. This prompted the following docket entry from the Court:
On October 23 . . . Plaintiff’s counsel emailed the Chambers’ e-file inbox, copying all other counsel, stating that certain subpoenas had been issued (and attaching the subpoenas) that would obviate the need for a hearing. If, indeed, these subpoenas moot the need for a hearing . . . then opposing counsel . . . may cancel the hearing (and/or withdraw the pending discovery motion) with an official, on-the-record filing, or, if not satisfied fully, may file an amended notice of hearing that indicates certain issues (but not all) have been resolved. If Plaintiff’s counsel is merely providing additional source material for the hearing, then submission of these to the e-file inbox is fine.
See Doc. No. 89 (emphasis added). Mr. Bleicher makes the ridiculously hilarious, and false, assertion that this “severely prejudiced us and made us look unprofessional.” Mr. Bleicher was “severely prejudiced” by Ms. Shambee’s malpractice and was made to look “unprofessional” by his own dilatory tactics and false testimony not by my submission of source material to the Magistrate in accordance with the discovery procedures in place. Therefore, Mr. Bleicher’s allegations regarding an “improper” communication with a judge are without merit.
C. I did not Fail to Address “Other Litigation,” I advised Mr. Bleicher of his Options, he did not Affirmatively Request any Action, and the Lawsuit was Stayed Until he Paid the Judgment, which he Cannot do Without Raising the IRS’s Suspicion
Mr. Bleicher claims I did not take action based on his November 4, 2015 email, asserting new copyright infringements. In his email, Mr. Bleicher rants:
Adam4Adam is up to it again. They are using more copyrighted images to promote and link to products which are not Flava Works. I want to get an injunction against them filed and also go after their web host Soft Layer. Now they are just fucking with us. In our face!
Like all of Mr. Bleicher’s slanderous assertions, this allegation is false and contradicted by evidence. To begin with, Mr. Bleicher never asked me to take specific action regarding these alleged new infringements. Additionally, Mr. Bleicher does not state what hypothetical action I should have voluntarily done. Nevertheless, although I did not respond to this particularly delightful email, I did have a specific phone conversation with Mr. Bleicher about the matter and his options. In what turned out to be more free legal services that unjustly enriched this con artist, I told him that if his allegations were true, they could constitute a separate cause of action. I told Mr. Bleicher that meant he could file a separate lawsuit seeking recovery based on these alleged new copyright infringements. However, I told him that the defendants might seek a stay if he did file a new action.
Alternatively, assuming any of Mr. Bleicher’s copyright allegations have factual merit, I told him it was possibly a continuation of pre-existing copyright violations. In which case, I advised Mr. Bleicher an injunction or temporary restraining order might be available in the existing actions. However, given the fact that the he voluntarily dismissed the Lawsuit filed in Florida, the re-filed action in Illinois was stayed until he paid the Judgment, and that his dilatory tactics were wearing thin with the Court, I advised Mr. Bleicher that it would likely better to seek a remedy in a separate action. Finally, Mr. Bleicher had yet to pay me for two months’ worth of work and has since balked at my “unreasonable” $500 invoice. What additional free legal work does Mr. Bleicher suggest I should have done for his porn empire? Mr. Bleicher’s “models” might be indentured servants exploited for his profit but at least they get modest wages. Therefore, Mr. Bleicher’s allegation that I failed to address “other litigation” is without merit.
D. Mr. Bleicher Complains but does not Cite Anything “Erroneous” in my $500 Invoice, which he has Unreasonably and Spitefully Refused to Pay
Mr. Bleicher claims that I had “concerns and reservations about attending a hearing in front of Judge Goodman.” Mr. Bleicher then states my “concern and reservation” was due to the fact that he never paid me. Although it is true Mr. Bleicher did not pay me, I never said, “why should I attend when I haven’t even been paid yet?” Rather, my “concerns and reservations” about attending the hearing were solely due to the fact that the Magistrate specifically stated during the October 19 telephonic conference that he would impose sanctions against both Mr. Bleicher and myself if we did not provide the outstanding discovery. Although Mr. Bleicher had yet to pay me for my two months’ worth of work, my concern, communicated to him on several occasions prior to the hearing was that I could not afford sanctions imposed against me and my reservation, also communicated to him on several occasions prior to the hearing was seeing additional sanctions imposed against him.
Mr. Bleicher calls for a forensic audit of my $500 invoice. He claims my one page invoice, requesting only $500 for two months of work, was “vague and riddled with numerous errors and untruths.” However, Mr. Bleicher does not point to a single error. I did attend the November 20 hearing, which was necessitated by Mr. Bleicher’s continued obstinacy and intentional failure to comply with multiple court orders. Further, Mr. Bleicher faults me for not billing in fractional hourly increments. First, Mr. Bleicher never stated this was a requirement. Second, he was only paying $25 an hour not $250. Flava Works had over $423,000 in income in 2014. See Ex. J. This begs the question, why would a company that generates nearly $500,000 a year actively seek young or recently admitted attorneys at $25 an hour, assuming unlike me they are actually paid, to protect its intellectual property and prosecute highly complex cases alleging copyright violations? Because Mr. Bleicher believes those attorneys are more easily manipulated and less likely to question his crimes.
Mr. Bleicher alleges “[I] submitted a false statement . . . claiming [I] was owed $1,000.” Presumably, Mr. Bleicher is referring to my charging lien. See Ex. B. However, I did in fact perform at least $1,000 worth, probably more, of legal services for Mr. Bleicher. Mr. Bleicher was intimately involved in every aspect of the case during the entirety of my representation. He is fully aware of the work I did. Even if he was not, the work is documented. Admittedly, I did not keep extensive contemporaneous time records. In recognition of this, I was willing to reduce my fee by half as a compromise. That is why I only requested $500. Mr. Bleicher’s attempt to use my kindness against me is an excellent example of his unsavory and malicious character. However, after he stiffed me on $500, despite being in the top 1% of wage earners himself, I demanded payment in full. Consequently, to ensure payment I filed a charging lien seeking $1,000. See Ex. B.
Mr. Bleicher commits further perjury by stating I “was asked to submit a detailed and corrected invoice.” Mr. Bleicher never made any such request. Interestingly, Mr. Bleicher submits my $500 invoice as an exhibit to his slanderous complaint but does not include the alleged correspondence asking me to resubmit it. Mr. Bleicher’s actual response to receipt of my invoice is another example of his propensity to falsify the truth: “our accountant will take care of it.”
Finally, Mr. Bleicher’s bait and switch Craigslist ad belies his frugal arguments. The ad states Flava Works would pay $25 an hour for ten to twenty hours per week. I worked two months for Mr. Bleicher’s pornographic slave-ring. According to his own ad, Mr. Bleicher would have expected to pay for 100 to 200 hours of work during that time. However, my $500 reduced invoice equates to only 20 hours of work, while my $1,000 actual invoice equals 40 hours. The truth of the matter is that Mr. Bleicher thought he could take advantage of me, as he does with his “models.” However, as this response demonstrates, Mr. Bleicher has seriously miscalculated the situation. Therefore, Mr. Bleicher’s allegations regarding my $500 invoice are without merit.
E. I was Required or Allowed to Withdraw Representation Without Mr. Bleicher’s “Knowledge” or “Permission” for Half a Dozen Reasons, including his Use of My Services to Perpetrate a Crime or Fraud
Mr. Bleicher states “unbeknownst to me and without permission,” I filed a motion to withdraw. This is the only true statement contained in Mr. Bleicher’s complaint. However, neither advance notice nor “permission” were required. Mr. Bleicher is not familiar with Florida Rule of Professional Conduct 4-1.16, which requires an attorney to “withdraw from the representation of a client if the representation will result in violation of the Rules of Professional Conduct or law.” Fla. R. Pro. Cond. 4-1.16(a)(1). Rule 4-1.16 also permits an attorney to withdraw if:
(1) the client persists in a course of action involving the lawyer’s services that the lawyer reasonably believes is criminal or fraudulent; (2) the client has used the lawyer’s services to perpetrate a crime or fraud; (3) a client insists upon pursuing an objective that the lawyer considers repugnant or imprudent; (4) the client fails substantially to fulfill an obligation to the lawyer regarding the lawyer’s services . . . ; (5) the representation will result in an unreasonable financial burden on the lawyer or has been rendered unreasonably difficult by the client . . . .
Fla. R. Pro. Cond. 4-1.16(b)(1–6) (emphasis added). However, “[w]hen ordered to do so by a tribunal, a lawyer shall continue representation.” Fla. R. Pro. Cond. 4-1.16(c).
I was ethically required to withdraw because my continued representation would have resulted in violation of the Rules of Professional Conduct and the law. Additionally, I was permitted to withdraw for several reasons. First, Mr. Bleicher persisted in a course of action involving my services that I reasonably believed was criminal and fraudulent. Second, Mr. Bleicher used my services to perpetrate a crime and fraud. Third, Mr. Bleicher insisted on pursuing an objective that I considered imprudent. Fourth, Mr. Bleicher failed substantially to fulfill his obligations to me in regards to my services. Fifth, continued representation had been rendered unreasonably difficult by Mr. Bleicher and continued representation without pay would have caused me to suffer an unreasonable financial burden. Unfortunately, the Court denied my motion to withdraw. See Doc. No. 92. Consequently, I was still required to attend and did attend the November 20 hearing.
Mr. Bleicher also takes issue with the substantive statements in my motion to withdraw. He actually claims my statement that he refused to follow my advice is false. He also claims I “offer[] (and cannot prove) no emails [sic] or phone communications where we refused to follow his advice . . . .” He also cites a lack of evidence to support my claim that “a conflict of interest” precluded further representation. However, at the time, I felt it would not have been proper to “offer” the above details. Once again, Mr. Bleicher attempts to use my kindness against me. Now however, I am more than happy to shed light on Mr. Bleicher’s criminal and unethical behavior.
Mr. Bleicher asked me to take actions intended solely to disrupt the tribunal. See Fla. R. Pro. Cond. 4-3.5(c) (“A lawyer shall not engage in conduct intended to disrupt a tribunal.”). Mr. Bleicher and Ms. Shambee asked me to engage in dilatory practices that would have brought “the administration of justice into disrepute” for “the purpose of frustrating an opposing party’s attempt to obtain rightful redress or repose.” Fla. R. Pro. Cond. 4-3.2 (emphasis added). As I explained to them, “[r]ealizing financial or other benefit from otherwise improper delay in litigation is not a legitimate interest of the client.” Id. (emphasis added).
Rule 4-3.3 requires candor towards tribunals and proscribes attorneys from taking many of the actions Mr. Bleicher requested or expected me to do. These included, “mak[ing] a false statement of material fact or law to a tribunal,” “fail[ing] to disclose a material fact to a tribunal when disclosure is necessary to avoid assisting a criminal or fraudulent act by the client,” and “permit[ing] any witness . . . to offer testimony or other evidence that the lawyer knows to be false.” Fla. R. Pro. Cond. 4-3.3(a)(1); (2); (4). Mr. Bleicher does not understand, “[a] lawyer may refuse to offer evidence that the lawyer reasonably believes is false.” Fla. R. Pro. Cond. 4-3.3(c).
Mr. Bleicher asked me to take actions contrary to Rule 4-3.4, which requires attorneys to deal fairly with opposing counsel. To that end, “[a] lawyer shall not unlawfully obstruct another party’s access to evidence or otherwise unlawfully alter, destroy, or conceal a document or other material that the lawyer knows or reasonably should know is relevant to a pending . . . proceeding; nor counsel or assist another person to do any such act.” Fla. R. Pro. Cond. 4-3.4(a) (emphasis added). “A lawyer shall not fabricate evidence, counsel or assist a witness to testify falsely . . . .” Fla. R. Pro. Cond. 4-3.4(b) (emphasis added). “A lawyer shall not knowingly disobey an obligation under the rules of a tribunal . . . .” Fla. R. Pro. Cond. 4-3.4(c) (emphasis added). “A lawyer shall not intentionally fail to comply with a legally proper discovery request by an opposing party.” Fla. R. Pro. Cond. 4-3.4(d) (emphasis added).
Finally, Mr. Bleicher asked me to take actions contrary to Rule 4-4.1, which requires attorneys to be truthful in statements made to others. Consequently, a lawyer shall not knowingly “make a false statement of material fact or law to a third person” or “fail to disclose a material fact to a third person when disclosure is necessary to avoid assisting a criminal or fraudulent act by a client . . . .” Fla. R. Pro. Cond. 4-4.1(a); (b). Therefore, Mr. Bleicher’s assault on my motion to withdraw is without merit.
F. The November 20, 2015 Hearing: Mr. Bleicher Commits Perjury with Reckless Abandon
Mr. Bleicher states he “was requesting to review what [I] was going to discuss with Judge Goodman and to make sure he was prepared for the hearing.” The fact Mr. Bleicher admits he wanted to “review” my in-court oral arguments is in line with his obsessive oversight and interference with the professional opinion of the attorneys he hires. See Fla. R. Pro. Cond. 4-5.4(d). To begin with, contrary to Mr. Bleicher’s assertions, he attends most if not all hearings in his cases. In any event, since I did not want to be sanctioned and (at the time) I did not want Mr. Bleicher to be sanctioned, my main goal following the October 19 telephonic hearing was to obtain the outstanding discovery, provide it as required by court order, and in doing so avoid the November 20 hearing.
Mr. Bleicher knew about the possibility of the November 20 hearing via correspondence from me on October 19. Mr. Bleicher stated to me during a conversation that he would personally attend the hearing if it went forward. I now know Mr. Bleicher never had any intention of providing discovery, so he knew since October 19 that the hearing would be taking place. Even assuming Mr. Bleicher bought a plane ticket “last minute,” he does not submit anything to support it, that decision was intentional. I have since come to learn that Mr. Bleicher lives an extravagant lifestyle and routinely spends thousands of dollars on a daily basis. In addition to being false, it is absurd that this wealthy individual, who stiffed me out of $500, was in any way damaged by purchasing a plane ticket to perjure himself in Federal Court. Finally, Mr. Bleicher intentionally filed the Lawsuit in Florida. Mr. Bleicher’s feigned outrage over being required to travel to Florida to prosecute a case he filed in Florida defies belief.
Mr. Bleicher’s recitation of the November 20 hearing is pure fiction in its entirety. This includes the false and wildly implausible allegations regarding statements made by the Court and myself. At no point did I say I was unfamiliar with the case. Rather, I recall saying something to effect that “I did not know what I was getting into.” As stated, the “what” I was referring to was a client that not only would refuse to follow my advice but also seek to use my services to perpetuate a crime and fraud. At no point was I “chastised” by the Magistrate, nor did he ever state my “actions border on malpractice.” I also urge you to obtain the transcript.
Of the multitude of blatantly false, defamatory, and imaginary allegations spewed by this hateful man, Mr. Bleicher’s claim that I “was ill-prepared” for the hearing might bother me the most. Preparedness was not the problem; rather there was no valid legal reason for not providing the discovery, consisting largely of bank statements and internal company documents, which had been outstanding for several months by the date of the hearing. See Fla. R. Pro. Cond. 4-3.1 (“A lawyer shall not bring or defend a proceeding, or assert or controvert an issue therein, unless there is a basis for doing so that is not frivolous . . . .”) (emphasis added). Again, Mr. Bleicher was told this multiple times in advance of the hearing.
Mr. Bleicher did do a lot of speaking at the hearing. However, he did so on his own volition and because he fancies himself an attorney. I believe hijacking the hearing was Mr. Bleicher’s intention all along. If I had known this in advance, I would have told him not to offer false testimony. Quite frankly, if I had known in advance that he intended to steal the microphone,“Kanye West” me, and perjure himself in open court, I would not have driven down to Miami and wasted half a day for a fraudulent shyster like Mr. Bleicher. I again note that the Court stated in advance that sanctions would be imposed against both Mr. Bleicher and I as counsel if it ruled in Mr. Bradley’s favor. At the conclusion of the hearing, the Court followed through and once again sanctioned Mr. Bleicher. See Doc. No. 94. Interestingly, the Court did not sanction me. Id.
G. Mr. Bleicher has Confused My Certificates of Service with his Tax Returns but Unlike his Falsified Returns, my Certificates hold up to an Audit
For someone who has cheated the IRS out of millions of dollars in taxes, tricked schools out of millions of dollars in funds, infected dozens of people with HIV, and fabricated evidence in Federal Court, Mr. Bleicher is surprisingly liberal with his use of the word “fraud” and referring to things as “false.” Federal Rule of Civil Procedure 5(a)(1)(d) provides that “a written motion,” “must be served on every party.” Rule 5(b)(1) provides in turn, “[i]f a party is represented by an attorney, service under this rule must be made on the attorney unless the court orders service on the party.” Rule 5(b)(2) states “[a] paper is served under this rule by . . . sending it by electronic means if the person consented in writing . . . .” Finally, anyone registered with a CM/ECF account must consent in writing to service by electronic transmission.
First, the Court did not order service be made on Mr. Bleicher directly. Second, Mr. Bleicher has been repeatedly made aware by several courts in different states that a corporation must be represented by counsel. Third, Mr. Bradley represents the defendants. Fourth, Mr. Bradley is registered with a CM/ECF account thereby consenting to electronic service. Consequently, the only individual entitled to notice in the Lawsuit at the time of any of my filings was Mr. Bradley. Moreover, service was allowed, and made, by electronic means. Finally, even if we assumed Mr. Bleicher were correct, which the above conclusively demonstrates is not the case, he neither alleges nor has he suffered any prejudice by the alleged failure to serve him with copies of pleadings. Therefore, Mr. Bleicher’s attack against the validity of my certificate of services is without merit.
H. Mr. Bleicher Mistakenly Believes that a Prior Counsel’s Continued Inclusion on a Service List Triggers an “Obligation to Notify the Bar of Ethical Issues with Other Attorneys”
Florida Rule of Professional Conduct 4-8.3 states, “[a] lawyer having knowledge that another lawyer has committed a violation of the Rules of Professional Conduct that raises a substantial question as to that lawyer’s honesty, trustworthiness, or fitness as a lawyer in other respects shall inform the appropriate professional authority.” Fla. R. Pro. Cond. 4-8.3(a). Contrary to Mr. Bleicher’s delusions otherwise, other than Ms. Shambee, no Florida attorney involved in the Lawsuit did anything to justify such action.
For a man who habitually avoids his obligations and then blames others for the consequences that result, Mr. Bleicher is obsessed with the supposed “obligations” of others. Mr. Bleicher’s final perjurious allegation is that I failed my “obligation to notify the bar of ethical issues with other attorneys.” What is the supposed “ethical issues with other attorneys” Mr. Bleicher speaks of? Ms. Jackson’s “failure” to remove herself from the Lawsuit’s service list after being “fired.” In other words, Mr. Bleicher is upset that Ms. Jackson continued to receive electronic notifications regarding court filings after representation was terminated. Once again, Mr. Bleicher neither alleges nor has he suffered any prejudice by Ms. Jackson’s continued receipt of electronic service. However, more importantly, Ms. Jackson’s continued receipt of filings is not an ethical violation. Therefore, Mr. Bleicher’s allegations that I did not notify the Bar of “ethical issues” with other attorneys is without merit.
In conclusion, it should be abundantly clear that Mr. Bleicher is either (1) lying under oath or (2) delusional. I respectfully submit that given his well-documented history of fraud, deceit, and deception, the former is the correct proposition. Like me, you are probably wondering why Mr. Bleicher is not currently in a Federal penitentiary. I hope that one of the agencies included in this correspondence can correct that. In full disclosure, since he forced me to do the necessary investigation and compile the facts and evidence needed to do so, once these slanderous allegations are dispatched with, I will be filing suit against Mr. Bleicher and Ms. Shambee. Regardless, please do not hesitate to contact me with other questions concerning this matter. Thank you for your attention.
Sincerely,
s/ Michael Gulisano
Michael Gulisano, Esquire
enc.
cc: Flava Works, Inc. c/o Philip Bleicher, Juneitha Shambee
John Francis Bradley, Esquire
Ursula Jackson, Esquire
Matthew Zukowsky, Esquire
Joshua Sheskin, Esquire
Chicago Department of Public Health (under separate cover)
Rahm Emanuel, Major of Chicago (under separate cover)
Miami Department of Code Enforcement (under separate cover)
Tomas Regalado, Major of Miami (under separate cover)
Federal Bureau of Investigations (under separate cover)
Internal Revenue Service (under separate cover)
D.L. Campbell, Revenue Officer, Internal Revenue Service (under separate cover)
United States Department of Justice (under separate cover)
Loretta Lynch, United States Attorney General (under separate cover)
Lisa Madigan, Illinois Attorney General (under separate cover)
Pamela Bondi, Florida Attorney General (under separate cover)
Jamie Alistair Gonzalez, JAGGED Press (under separate cover)
Miami Herald (under separate cover)
Chicago Sun-Times (under separate cover)
2024 Update
In 2024, eight years after my run-in with conman Mr. Bleicher, he attempted to file another bar complaint against me. This time on the basis that the above article, substantiated by citation to numerous supporting authorities, “defames” him! Luckily, Mr. Bleicher’s complaint was once again dismissed.
I have received dozens of phone calls and emails from Mr. Bleicher’s victims since posting this article back in 2016. However, if you are one of Mr. Bleicher’s countless victims, I respectfully request that you not contact me. This article states everything I know and I am not willing to discuss issues with Mr. Bleicher.
For anyone being subjected to Mr. Bleicher’s harassment as of June 2024, he allegedly can be directly contacted by mail at: 2705 West Fulton St., Chicago, IL 60612-2003; by phone at: 312-498-5815; and by email at: .