Lively Bar Complaint Chronology

March 4, 2008

 

 

The following is a chronology of events related this bar complaint. Copies of the invoices for each of the costs are available upon request.

    1. Feb 15, 2006 Ð Mr. Krivok receives copy of a homeownersÕ lawsuit naming him as a defendant.
    2. Feb 15, 2006 Ð Mr. Krivok faxes response letter to homeownersÕ attorney Cathy Lively regarding the above lawsuit naming him as a defendant indicating his intent to file a bar complaint against Cathy Lively.
    3. Feb 17, 2006 Ð Mr. Krivok faxes letter to homeownersÕ attorney Cathy Lively stating ÒSince you have not advised me that you intend to withdraw as counsel for the homeowners, I will be following through on my promise to file the Bar complaint
    4. Feb 20, 2006 Ð Mr. Krivok sends letter to homeownersÕ attorney Cathy Lively via courier stating ÒPerhaps if you are forced to defend yourself before the Florida Bar, you will learn of the professionalism amongst attorneys that is expected. I therefore stand firm on the decision I made last Friday, which has been communicated to you.Ó
    5. Feb 20, 2006 Ð Mr. Krivok sends another letter to homeownersÕ attorney Cathy Lively stating ÒI have already advised you how I intend to deal with your conduct.Ó and enclosing a copy of a lawsuit and indicating that he was Òprepared to commence suit against each of the clients that you represent in the Amero lawsuit.Ó
    6. Feb 22, 2006 Ð Mr. Krivok charges $560 for among other things to ÒRESEARCH FLA RULES OF PROFESSIONAL CONDUCT IN CONNECTION WITH PREPARATION OF LETTER TO ATTY LIVELY; REVIEW EXPAND AND EDIT LETTER TO LIVELY RE: BAR COMPLAINT FORTHCOMING FROM BOARD EXPLAINING REASONS FOR THE COMPLAINT AND ETHICAL RAMIFICATIONS OF CONTINUING HER REPRESENTATION; TEL CONFS W/PRES TSACNARIS RE: SAMEÓ [Note: The previous four (4) items indicate that Mr. Krivok would be filing the bar complaint not the Association but it appears that Mr. Krivok changed his mind and convinced Al Tsacnaris to get the Association to reimburse Mr. Krivok for filing this bar complaint.]
    7. Feb 23, 2006 Ð Mr. Krivok charges $140 for among other things ÒTEL CONF W/PRES TSACNARIS RE: LETTER TO LIVELY ABOUT BOARDÕS BAR COMPLAINT AND DISCUSSION OF SAME AT LAST NIGHTSÕ BOARD MEETING.Ó
    8. Feb 26, 2006 Ð Mr. Krivok charges $700 to ÒWORK ON PREPARATION OF BAR COMPLAINTÓ
    9. Feb 27, 2006 Ð Mr. Krivok charges $200 to ÒCONTINUE WORK ON PREPARATION OF BAR COMPLAINT.Ó
    10. Mar 15, 2006 Ð Mr. Krivok charges $190 to ÒWORK ON REVISIONS TO DRAFT BAR COMPLAINT AGAINST ATTY LIVELY; TEL CONF W/PRES TSACNARIS.Ó
    11. Apr 12, 2006 Ð Mr. Krivok charges $80 to among other things ÒTC WITH PRES TSACNARIS . . . DISCUSS TATUS OF BAR COMPLAINT; REVISE BAR COMPLAINT LETTER; EMAIL TO TSACNARIS.Ó
    12. May 1, 2006 Ð Mr. Krivok charges $38 to ÒMAKE CHANGES TO BAR COMPLAINT LETTER; PREPARATION OF LETTER TO PRES TSACNARIS.Ó
    13. May 18, 2006 Ð Mr. Krivok charges $76 for among other things ÒTEL CONF W/PRESIDENT (TSACNARIS) . . . DISCUSS REVISED BAR COMPLAINT LETTER; LETTER TO PRES (TSACNARIS)Ó. [Note: It appears from the legal invoices that this bar complaint was never filed.]

 


Last Updated: March 4, 2008