The Florida Bar

Inquiry/Complaint Form
PART ONE: (Read instructions on reverse side.)
Your Name: Leonardo Gomez Attorney's: Name: Jorge J. Perez
Address: 2415 SW 102 Place Address: Tew Cardenas LLP
1441 Brickell Ave Fl 15
City: Miami State: Florida City: Miami State: Florida
Phone: 305-772-3848 Zip Code: 33165 Phone: (305)536-1112 Zip Code: 33131
ACAP Reference No. 09-21636 E-Mail: jjp@tewlaw.com

PART TWO: The specific thing or things I am complaining about are:

This bar Complaint is against attorney Jorge J. Perez of the firm Tew Cardenas
LLP in Miami, Bar ID Number: 779334. Mr. Perez is an attorney and a formerly
appointed circuit court Judge who is now also trying to act as a receiver.
In a Condominium Development foreclosure case in which I am the Defendant,
case #2007-42605-CA-15, Mr. Perez was allegedly appointed as the receiver to protect
the real estate property. We would later learn that this would be Mr. Perez’s first every
receivership. The case was originally assigned to Judge Mindy Glazier of Division 15 of
the 11th Judicial Circuit Court, who then left for labor leave and Senior Judge Herbert
Stettin temporary replaced her while on leave. Judge Glazier was then replaced by Judge
Jeri B. Cohen who took over Judge Glazier’s Division 15 and relieved Senior Judge
Stettin of the foreclosure case #2007-42605-CA-15. The condominium association filed
a lawsuit, case #2008-6360-CA-15, against the actions of Mr. Perez who installed a fence
on the common areas of the association without any permit from Miami Dade County
Building Department or any authorization from the association. Mr. Perez and/or the
Plaintiff then moved to reassign the fence case #2008-6360-CA-15, to Senior Judge
Stettin by scheduling a hearing in front of the Administrative Judge Stuart Simons, which
was granted. Mr. Perez and/or the Plaintiff never moved to reassign the Foreclosure
case #2007-42605-CA-15 to Senior Judge Stettin. Mr. Perez and/or the Plaintiff
continued to schedule all hearings of the Foreclosure case in front of Senior Judge
Herbert Stettin, although Judge Jeri B. Cohen was the Judge assigned to the case.
On April 16, 2008, at one of many hearings scheduled by Mr. Perez and/or the
Plaintiff before Senior Judge Stettin instead of Judge Cohen, it became evident to Judge

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Stettin that he did not have any assignment of the Foreclosure case #2007-42605-CA-
15 from the Administrative Judge Stuart Simons assigning this case to him. ( pg 15 lns
14-20) The Senior Judge stated that the “only way within the system that I have a right to
hear these things” (case) “is when it is assigned to me and normally that requires an order
from the division chief and would be Judge Simons,” (pg 15 & 16(19) lns 1-8) Mr. Perez
immediately stated that to his “understanding specifically that Judge Cohen assigned the
case to you,” (Judge Stettin) (pg 18 lns 4-5). The Senior Judge specifically pointed out to
Mr. Perez and/or the Plaintiff that the for Summary Judgment for the Foreclosure case
#2007-42605-CA-15 was scheduled for May 7, 2008, ( pg 17(20) lns 7-9) and that in
order for him to proceed with that motion the Judge Stettin stated “ You need an order
from Judge Simons.” (pg 17(21) lns 5-10)
The plaintiff’s attorney on this case is Paul D. Friedman, who has been previously
sanctioned by the Florida Bar in the Florida Supreme Court Case Number: SC02-2430,
“THE FLORIDA BAR vs. PAUL D. FRIEDMAN”, which resulted in an admission of
guilt and of lying by Mr. Friedman. The Bar gave Mr. Friedman a “judgment in which
Respondent Friedman agreed to accept a suspension of 90 days, pay restitution to the
firm’s clients in the amount of $910,000.00 and pay the Bar’s costs in the amount of
$7162.36.” The order was “entered on April 23, 2004. Lower Tribunal Case(s): 2001-
00,358(8B).”
Mr. Friedman later at the same April 16, 2008 hearing, asked Senior Judge Stettin
for any suggestions on how he could get a hearing before Administrative Judge Simons
when the Summary Judgment Motion was a couple of days away. (pg 22(26) lns 8-11)
Judge Stettin suggested to Mr. Friedman that he “go down to Judge Cohen, see if she
would sign an order referring it to me”(Judge Stettin). Here, clearly Judge Stettin is
giving Mr. Friedman instructions to obtain an illegal ex parte order from Judge Cohen
assigning the case to himself. (pg 22(26) lns 12-14)
Apparently after the April 16, 2008 hearing concluded, Mr. Perez got together
with Mr. Friedman and decided that Mr. Perez would be the least likely to be harm by
obtaining this illegal ex parte assignment order from Judge Cohen, since Mr. Perez was
allegedly acting as a receiver. Mr. Perez, in fact, prepared the assignment order for Judge
Jeri B. Cohen and had ex parte communications with Judge Cohen to convince her to
assign the case to Judge Stettin. As a consequence of Mr. Perez’s illegal actions, Judge

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Cohen signed the assignment order allegedly assigning the complete Foreclosure case to
Senior Judge Stettin. This complete assignment of the case was done from Circuit Judge
to Circuit Judge without every having assignment order from Judge Simons or
scheduling a hearing with the same Administrative Judge. Recently in another
hearing on case #2008-6360-CA-15, Senior Judge Stettin would confirm that only a valid
assignment order from the Administrative Judge would legally assign a case to him and
not one signed by another Circuit Judge, which is exactly what transpired in this case.
This action is tantamount to “Judge Shopping,” by Mr. Perez, who is an attorney and
a former appointed circuit judge. Mr. Perez, as a former Circuit Judge, should know
something about being neutral or having ex parte communications with Judges.
The following day, an assignment order signed by Judge Jeri B. Cohen
transferring the entire Foreclosure case to Senior Judge Stettin was received in the offices
of my counsel from Mr. Perez. (pg 14) Also included in this assignment order was the
assignment of the fence case #2008-6360-CA-15 which had been assigned to Senior
Judge Stettin in an administrative hearing by the administrative Judge Simmons. (pg 14)
Apparently, Mr. Perez had even bungled this illegal ex parte order by forgetting that the
fence case #2008-6360-CA-15 had already been properly assigned to Judge Stettin by the
Administrative Judge. Currently, there are two assignment orders for case #2008-6360-
CA-15, one from Judge Simons and one from Judge Cohen. Also bungled by Mr. Perez
on the illegal ex-parte order, are the names of the Plaintiff and the Defendant of case
#2008-6360-CA-15, which are Galenus vs. Gibraltar and not Leonardo Gomez. During
the next hearing on April 25, 2008, Mr. Perez did not admit to having obtained the ex
parte assignment order when asked in open court by my counsel. (pg 23(7) lns 17-24)
Mr. Perez did not admit that he had written the assignment orders and taken them to
Judge Cohen to have her signed or having ex parte communication with Judge Cohen
without the presence of my counsel. To this day, there is no assignment order from the
Administrative Judge assigning case #2007-42605-CA-15 to Judge Stettin.
It was confirmed to us by the Administrative Assistant of Judge Jeri B. Cohen that
Jorge Perez took the assignment orders, that he wrote himself, and had ex parte
communications with the Judge Jeri. B. Cohen for her to sign the assignment orders.
This admission by the Administrative Assistant of Judge Jeri B. Cohen was made in front
of three witnesses including my counsel. Senior Judge Stettin would confirmed at the

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April 25, 2008 hearing that he had two assigned orders from Judge Cohen and not
from the administrative Judge Simons as the Senior Judge had first originally stated
was required for the case to proceed, but he proceeded anyways. (pg 23(7) lns 10-12)
Obviously, Mr. Perez is politically well connected having been appointed to a
Circuit Court Judicial position by a Governor. Also apparent is that Mr. Perez has many
friends in the judicial system, so I write this bar complaint with great reserve over future
retaliations that may come from Mr. Perez and/or his associates. However, it is my
great belief in the magnitude of the illegal actions committed by Mr. Perez that
overcomes all my fears and reservations that I may have had. Mr. Perez’s judicial
influences are also clearly evident to me by the fact that the Administrative Assistant of
Judge Jeri B. Cohen referred to him as “Judge Perez” and not Jorge Perez providing
further evidence to me of his judicial influences and prior contact and communications.
Mr. Perez has been personally attacking me and misrepresenting the record since
the inception of this litigation, which defies the logic of being a court appointed receiver
which should be a neutral party. I have no doubt that Mr. Perez will continue to do so in
his response to this complaint. Mr. Perez will probably reply to this complaint by stating
that it is retaliation for losing Summary Judgment. The fact is that the appeal of the
Summary Judgment is still pending in Third District Court of Appeals case # 3D08-1619.
Mr. Perez will also probably state that this issue is pending appeal by the 3rd DCA. This
is not correct. One of the issues on appeal in case # 3D08-1619 is whether Judge Stettin
had Jurisdiction of the case to award a Summary Judgment while not being properly
assigned to case. The appeal does relate to the illegal actions of Jorge J. Perez. Mr. Perez
will also likely state that a writ of certiorari, case # 3D08-949, on this issue was denied
by Third District Court of Appeal and that this justifies his illegal actions. This can be the
furthest from the truth since; obviously nothing justifies Mr. Perez’s illegal actions. It
could be that the 3rd DCA in case #3D08-949 felt that it did not meet the legal
requirement for a writ of certiorari. As one of the requirements for a writ certiorari is that
the “(2) resulting in material injury for remainder of trial; (3) that cannot be corrected on
postjudgment appeal.” The writ of certiorari was not denied based on its merits. The 3rd
DCA in case #3D08-949, did not gave any reason by not providing an authored opinion.
Mr. Perez has been vigorously avoiding the taking of his deposition for several
months now with various nonsensical motions and delay tactics. Obviously, Mr. Perez

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has something to hide. If not why is he so desperately trying to avoid the taking of
his testimony? If he did not have anything to hide and he did not commit any illegal acts,
then why would he be personally attacking me and avoiding the taking of his deposition?
The fact is the Mr. Perez has been comporting himself in the same manner as he did the
day after he got the ex parte order from Judge Cohen assigning the case to Judge Stettin
in an effort to cover-up and obstruct his illegal actions.
Mr. Perez obviously knows better than this type of conduct, after all, he has been
an attorney since 1988 and a former appointed circuit Judge. This illegal ex parte
communication was not accidental but premeditated, deliberate and calculated. Mr.
Perez’s ruthlessness and his adamant “win at all cost” mentality has no boundaries
including breaking the law. I have clearly been prejudice and have suffered harm as a
result of these actions. Mr. Perez’s conduct is shameful and unbecoming of a member of
the Florida Bar and deserving of sanctions.

PART THREE: The witnesses in support of my allegations are: [see attached sheet].
Rodolfo T. Gomez, George M. Evan. Esquire, Administrative assistant of Judge Jeri B.
Cohen. I have provided copies of documents and related deposition transcripts. All other
transcripts are available upon request.

PART FOUR: Under penalty of perjury, I declare the foregoing facts are true, correct and complete.

_______________________________________________
Signature Date

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