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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 1:22-cv-24156-Bloom

RENÉ GARCIA, JAVIER FERNÁNDEZ,

CRYSTAL WAGAR, MACK BERNARD

and WILLIAM PROCTOR,

Plaintiffs,

vs.

KERRIE J. STILLMAN, EXECUTIVE DIRECTOR,

FLORIDA COMMISSION ON ETHICS, in her official

capacity; JOHN GRANT, CHAIRMAN, FLORIDA

COMMISSION ON ETHICS, in his official capacity; 

GLENTON “GLEN” GILZEAN, JR., VICE CHAIRMAN, 

FLORIDA COMMISSION ON ETHICS, in his official 

capacity; MICHELLE ANCHORS, COMMISSIONER, 

FLORIDA COMMISSION ON ETHICS, in her official 

capacity; WILLIAM P. CERVONE, COMMISSIONER, 

FLORIDA COMMISSION ON ETHICS, in his official 

capacity; DON GAETZ, COMMISSIONER, FLORIDA 

COMMISSION ON ETHICS, in his official capacity; 

WILLIAM “WILLIE” N. MEGGS, COMMISSIONER, 

FLORIDA COMMISSION ON ETHICS, in his official 

capacity; ED H. MOORE, COMMISSIONER,

FLORIDA COMMISSION ON ETHICS, in his official

capacity; WENGAY M. NEWTON, SR., COMMISSIONER,

FLORIDA COMMISSION ON ETHICS, in his official capacity; 

JIM WALDMAN, COMMISSIONER, FLORIDA COMMISSION

ON ETHICS, in his official capacity; ASHLEY MOODY, 

ATTORNEY GENERAL, STATE OF FLORIDA, in her official 

capacity; and JIMMY PATRONIS, CHIEF FINANCIAL

OFFICER, STATE OF FLORIDA, in his official capacity,

Defendants.

_________________________________/

RENEWED MOTION FOR PRELIMINARY INJUNCTIVE RELIEF

WITH NOTICE, WITH INCORPORATED MEMORANDUM OF LAW; 

REQUEST FOR EXPEDITED RELIEF; REQUEST FOR HEARING

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Plaintiffs renew their motion for preliminary injunctive relief in 

accordance with this Court’s Order (DE7) denying the motion without 

prejudice with leave to renew after the defendants have been served. 

The defendants have been served (DE8-17). Accordingly, plaintiffs 

seek entry of a preliminary injunction with notice to the defendants 

pursuant to Rule 65(a) of the Federal Rules of Civil Procedure. The 

relief requested is a temporary injunction to be made permanent that 

precludes enforcement, effective December 31, 2022, of Article II, § 

8(f)(1)-(3) of the Florida Constitution and Fla. Stat. § 112.3122 

(collectively referred to as the “Anti-Lobbying Amendment”) against 

plaintiffs and others similarly situated during the pendency of this 

case. Plaintiffs seek a hearing for one (1) hour on the motion.

Because the Anti-Lobbying Amendment is effective on 

December 31, 2022, expedited consideration and decision are 

consistent with the interests of justice. Preliminary injunctive relief 

is needed during the pendency of this litigation because enforcement 

of the Anti-Lobbying Amendment will cause immediate and 

irreparable harm to the plaintiffs, all other similarly situated persons, 

and the citizens of the State of Florida through the quashing of 

protected core First Amendment political speech. Plaintiffs have no 

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adequate remedy at law to obtain the immediate and effective 

protection of their First Amendment rights. Plaintiffs have a 

substantial likelihood of prevailing on the merits. A preliminary 

injunction will not harm the defendants, the State of Florida, or the 

public. The granting of injunctive relief is in furtherance of and not 

adverse to the public interest. This motion is supported by the 

declarations appended to the motion.

REQUEST FOR HEARING

In accordance with Local Rule 7.1(b), plaintiffs ask the Court to 

schedule a one-hour hearing on this motion (in person or by Zoom). 

A hearing will be helpful to the Court in determining whether to grant 

a preliminary injunction to stay the Anti-Lobbying Amendment 

pending the outcome of this litigation. Significant First Amendment 

protections are at issue, resulting in a serious loss of allowable

political speech through the enforcement of the Amendment. Staying 

the effective date of the Florida law will promote the guarantee of free 

speech, will continue the status quo, does not harm the defendants 

or the public, and is consistent with the public interest in the 

broadest application of First Amendment freedoms. A hearing will 

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provide a meaningful opportunity to amplify the presentation of the 

plaintiffs’ claims and enable the Court to be fully informed.

INTRODUCTION

1. This litigation seeks to vindicate core First Amendment 

rights of free speech, freedom of association, and the right to petition 

the government for redress of grievances, all of which are infringed 

by the overbroad and burdensome provisions of Florida Constitution, 

Article 2, Section 8(f) and Section 8(h)(2), and certain enabling 

provisions of Florida Statutes, enacted as Section 112.3122, Fla. 

Stat. (2022). The Florida Constitutional provision is incorporated as 

Attachment A. The Florida Statute is incorporated as Attachment B.

2. The Anti-Lobbying Amendment imposes unprecedented 

restrictions on lobbying by current and former public officers, 

effective December 31, 2022. 

3. Article II, Section 8, prohibits all current Florida “public 

officers” from engaging in compensated lobbying in virtually every

capacity. This includes lobbying with “the federal government, the 

legislature, any state government body or agency, or any political 

subdivision of this state, during his or her term of office.” Fla. Const., 

Art. II, § 8(f)(2). This provision of the Florida Constitution defines a 

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“public officer” as “a statewide elected officer, a member of the 

legislature, a county commissioner, a county officer pursuant to 

Article VIII or county charter, a school board member, a 

superintendent of schools, an elected municipal officer, an elected 

special district officer in a special district with ad valorem taxing or 

other agency head of a department of the executive branch of state 

government.” Fla. Const., Art. II, § 8(f)(1).

4. These revisions to the Florida Constitution impose an 

unprecedented six-year prohibition for a public officer from lobbying 

his or her former agency after leaving office. Fla. Const., Art. II, §

8(f)(3). They extend the lobbying ban to include all Florida agencies 

in the case of a statewide or legislative officer or executive branch 

agency head. 

5. The Florida Legislature implemented these constitutional 

revisions by empowering the Florida Commission on Ethics to 

investigate potential violations of the Anti-Lobbying Amendment. 

Violations may result in career and reputational harm through 

penalties including (1) public censure and reprimand, (2) a civil 

penalty of up to $10,000, and (3) forfeiture of any pecuniary benefits 

received for conduct violating the Amendment. Fla. Stat. § 

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112.3122(4). These penalties may be imposed by the Governor, and 

both the Attorney General and the Chief Financial Officer are 

authorized to collect the financial penalties. Fla. Stat. § 112.3122(3) 

& (5). This statute also takes effect on December 31, 2022.

FACTUAL BACKGROUND/THE RESTRICTIONS

6. The impact of the lobbying restrictions profoundly and 

impermissibly constrains core First Amendment rights of current and 

former public officials. All plaintiffs are elected officials who will be 

severely impacted by the restrictions, despite that they served the 

public interest during their public service and are now foreclosed 

from engaging in constitutionally protected speech and, in some 

instances, from earning a living in the lawful and time-tested 

government relations profession. 

7. Incorporating paragraphs 9-13 of the Complaint (DE1), the 

plaintiffs currently are involved and intend to participate in allowable 

lobbying activities that will be dramatically curtailed or altogether 

eliminated once the Anti-Lobbying Amendment goes into effect. Each 

plaintiff will be stifled and unable to engage in protected political 

speech. The result of this termination and limitation is a significant 

loss in their freedoms guaranteed by the U.S. Constitution and 

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Florida’s Declaration of Rights.

8. As demonstrated in the Declarations attached to the 

motion, plaintiffs have real, practical, and fair needs to maintain the 

status quo pending the resolution of this constitutional challenge. 

9. Consider that Miami-Dade Commissioner Rene Garcia 

(Attachment C) has been elected to and has held municipal, county, 

and state offices. He has always observed Florida’s lobbying 

requirements. He has been able to carefully balance his duties as an 

elected official with his allowable First Amendment free speech in 

matters of governmental relations. He has never run afoul of any 

lobbying restrictions. As a part-time elected official, he works in the 

private sector as a business consultant whose services include 

lobbying and government affairs advisory services, offering guidance 

to both private individuals and entities as well as public institutions. 

His firm routinely engages in First Amendment protected speech in 

the form of lobbying as a mechanism to introduce important 

information to public officials and educate governments about 

matters within the scope of their responsibilities. He intends to 

continue that practice. Those allowable activities have not been the 

subject of restrictions that imperil Commissioner Garcia’s First 

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Amendment speech. The Anti-Lobbying Amendment will restrict his 

actions due to his current service to the public as an elected County 

Commissioner. That consequence is unfair, unreasonable, and 

inconsistent with the public interests served by reasonable lobbying 

restrictions.

10. Plaintiff Javier Fernandez (Attachment D) is similarly 

situated as a municipal mayor and former member of the Florida 

House of Representatives. As a lawyer with an active practice of 

representing clients in matters with government agencies, his ability 

to provide meaningful representation to his clients will be eviscerated 

by the Anti-Lobbying Amendment. Not only that, but his entire law 

firm could be required by application of the law to cease and desist 

its lobbying activities because of the broad application of the 

prohibition that imputes the work of lawyers in his firm to him for 

purposes of compliance. The Florida Commission on Ethics, in 

Opinion CEO 09-10 (June 17, 2009), explained that all lawyers in a 

law firm effectively represent every client, such that a County 

Commissioner’s law firm cannot engage in client representation in 

matters for which the commissioner would be prohibited from 

involvement. Accordingly, the government advocacy of Mayor 

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Fernandez and his law firm could be severely restricted in a manner 

that truncates his free speech and equal treatment under the law.

11. Crystal Wagar (Attachment E), a municipal elected official 

who earns $1 annually for her public service, is engaged fulltime with 

a respected lobbying and government affairs company providing 

representation to clients in Florida and federal matters. Council 

Member Wagar has long performed allowable lobbying activities 

within the meaning of the Anti-Lobbying Amendment. The new 

revisions to the Florida Constitution will not permit her to continue 

with her work for Southern Group while remaining on the Miami 

Shores Village, forcing her to either resign the position to which the 

public elected her or to cease and desist earning a living through 

constitutionally protected government advocacy as she continues to 

serve the public interest. The effect on plaintiff Wagar is immediate 

and dire, resulting in her continued elected service under a real 

threat of prosecution and punishment. 

12. Plaintiffs Mack Bernard (Attachment F) and William 

Proctor are equally adversely impacted by the Anti-Lobbying 

Amendment, causing both to fear engaging in allowable and 

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constitutionally protected political speech in ways that severely limit 

their decision making and careers.

ARGUMENT

To obtain a preliminary injunction, a plaintiff must establish (1) 

a substantial likelihood of success on the merits, (2) an irreparable 

injury will result unless the injunction issues, (3) that the threatened 

injury outweighs whatever damage the proposed injunction may 

cause a defendant, and (4) that the injunction is not contrary to the 

public interest. NetChoice, LLC v. Attorney Gen., Florida, 34 F.4th 

1196, 1209 (11th Cir. 2022) (internal citation omitted); United States 

v. Florida, 870 F. Supp. 2d 1346, 1348 (N.D. Fla. 2012) (citing Siegel 

v. LePore, 234 F.3d 1163, 1176 (11th Cir. 2000) (en banc)). “The 

purpose of a temporary restraining order, like a preliminary 

injunction, is to protect against irreparable injury and preserve the

status quo until the district court renders a meaningful decision on 

the merits.” Schiavo ex rel. Schindler v. Schiavo, 403 F.3d 1223, 1231 

(11th Cir. 2005). 

The movant (plaintiffs here) has the burden of persuasion on 

each of the elements. McDonald’s Corp. v. Robertson, 147 F.3d 1301, 

1306 (11th Cir. 1998). “Likelihood of success on the merits is 

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generally the most important factor.” NetChoice, 34 F.4th at 1209 

(internal citation omitted). To that end, a “substantial likelihood of 

success on the merits” requires “only likely or probable, rather than 

certain, success.” Schiavo ex rel. Schindler v. Schiavo, 403 F.3d at 

1232.

Applying these standards, entry of a preliminary injunction is 

fully warranted on or before December 31, 2022.

I. PLAINTIFFS HAVE A SUBSTANTIAL LIKELIHOOD OF 

SUCCESS ON THE MERITS.

A. Plaintiffs Are Substantially Likely to Prevail on 

Their First Amendment Infringement Claim.

The revisions to Florida’s Constitution are facially 

unconstitutional. As a result, plaintiffs are likely to succeed on their 

claims. Lobbying the government is protected political speech under 

the First Amendment. See F.T.C. v. Superior Court Trial Lawyers 

Ass’n, 493 U.S. 411, 426 (1990); see also Liberty Lobby, Inc. v. 

Pearson, 390 F.2d 489, 491 (D.C. Cir. 1967) (“every person or group 

engaged...in trying to persuade [government] action is exercising the 

First Amendment right of petition”); Autor v. Pritzker, 740 F.3d 176, 

182 (D.C. Cir. 2014) (“registered lobbyists are protected by the First 

Amendment right to petition”). Accordingly, restrictions on 

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government lobbying must not intrude upon the First Amendment 

rights of lobbyists. 

Here, the lobbying restrictions taking effect on December 31, 

2022, impermissibly infringe upon the First Amendment rights of the 

plaintiffs and other similarly situated public officials and must be 

deemed unenforceable.

The Anti-Lobbying Amendment, beginning with Article II, 

Section 8(f)(2) of the Florida Constitution, prohibits a public officer 

from lobbying “on issues of policy, appropriations, or procurement 

before the federal government, the legislature, any state government 

body or agency, or any political subdivision of this state, during his 

or her term of office.” Similarly, Section 8(f)(3) prohibits former public 

officers from lobbying for six years “on issues of policy, 

appropriations, or procurement.” These provisions are referred to 

throughout this motion as “Advocacy Restrictions.” They are 

undeniably content-based restrictions on speech, since they regulate 

speech based on the “issues” it addresses – i.e., the content of the 

speech. The Eleventh Circuit precedent on this very point is clear: “A 

content-based law is one that ‘applies to particular speech because 

of the topic discussed or the idea or message expressed.’” Otto v. City 

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of Boca Raton, Florida, 981 F.3d 854, 862 (11th Cir. 2020) (quoting 

Reed v. Town of Gilbert, Ariz., 576 U.S. 155, 163 (2015)).

The significance of this restriction cannot be overstated. The 

Supreme Court declared, “above all else the First Amendment means 

that government has no power to restrict expression because of its 

message, its ideas, its subject matter, or its content.” Police Dept. of 

City of Chicago v. Mosley, 408 U.S. 92, 95 (1972). The legal principle 

was aptly framed by the Eleventh Circuit: “Forbidding the 

government from choosing favored or disfavored messages is at the 

core of the First Amendment’s free-speech guarantee.” Otto, 981 F.3d 

at 862. For this reason, “regulations that are grounded in the content 

of speech, and that allow the government to discriminate on the basis 

of the content of that speech, cannot be tolerated under the First 

Amendment.” Id. Content-based speech restrictions such as those 

contained in the revisions to the Florida Constitution therefore “must 

receive strict scrutiny.” Id. at 861.1

Not only are the Advocacy Restrictions content-based 

1 Content-based restrictions on the right to petition the government are also 

subject to strict scrutiny. See Seum v. Osborne, 348 F.Supp.3d 616, 631 (E.D. 

Ky. 2018); Am. Civil Liberties Union of New Jersey v. New Jersey Election Law 

Enf’t Comm’n, 509 F. Supp. 1123, 1128-29 (D.N.J. 1981).

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proscriptions on speech, they specifically target “core political 

speech” that is entitled to the greatest protection under the First 

Amendment. “[I]nteractive communication concerning political 

change...is appropriately described as ‘core political speech.’” Meyer 

v. Grant, 486 U.S. 414, 422 (1988). Communications between the 

government and a lobbyist concerning “issues of policy, 

appropriations, or procurement” certainly meet the definition of “core 

political speech.” Regulations of “core political speech” also must 

withstand strict scrutiny. Weaver v. Bonner, 309 F.3d 1312, 1319 

(11th Cir. 2002).

Under a strict scrutiny analysis, “content based restrictions are 

presumptively unconstitutional.” Otto, 981 F.3d at 868 (citing Reed, 

576 U.S. at 163). Such restrictions can be “justified only if the 

government proves that they are narrowly tailored to serve 

compelling state interests.” Id. Few government regulations can meet 

this exceedingly high standard, id. at 868 n.6, and certainly the 

state’s lobbying restrictions do not.

The only government interest that could potentially be served 

by the Advocacy Restrictions is the prevention of quid pro quo 

corruption or the appearance of quid pro quo corruption. See 

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McCutcheon v. Fed. Election Com’n, 572 U.S. 185, 192 (2014) (“[a]ny 

regulation must...target what we have called ‘quid pro quo’ corruption 

or its appearance”). But that purpose does not empower a broadly 

worded prohibition that effectively shuts off all access to political 

speech. It is far from the narrowly tailored remedy that defines a 

prohibition that cuts to the core of corruption. The restriction sweeps

too broadly and impermissibly restricts substantial, legitimate First 

Amendment activity. Very plainly, it is a far cry from legislation that 

is tailored narrowly in its restrictions on political speech.

If the intent of the law is to prevent quid pro quo corruption or 

the appearance of quid pro quo corruption, as it most certainly must 

be to withstand strict scrutiny, professional lobbying cannot be 

restricted more severely than other lobbying or governmental 

advisory services. The carve-out in the definition of “lobbying for 

compensation” in the implementing statute states a private actor is 

not lobbying for compensation so long as he or she is not “principally 

employed for government affairs ...” That distinction without a 

material difference underscores the overbroad reach for the purpose 

of rooting out corruption. The Supreme Court said it best in 

McCutcheon, 572 U.S. at 192 (citing Citizens United v. Federal 

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Election Comm’n, 558 U.S. 310, 360, 130 S. Ct. 876 (2010)):

We have said that government regulation may not target 

the general gratitude a candidate may feel toward those 

who support him or his allies, or the political access such 

support may afford. “Ingratiation and access ... are not 

corruption.”

Because the Anti-Lobbying Amendment is not narrowly 

restricted to encompass only what is needed to accomplish its 

purpose, it does not withstand strict scrutiny. Accordingly, plaintiffs 

are substantially likely to prevail on the merits.

II. Plaintiffs Have a Clear Right to Relief Against the 

Defendants.

Plaintiffs, all public officials personally impacted by the AntiLobbying Amendment, have standing to seek relief. Their specific 

interest is personal, professional, and pecuniary. 

As addressed by the district court in Dream Defs. v. DeSantis, 

553 F. Supp. 3d 1052, 1071 (N.D. Fla. 2021), to establish standing, 

plaintiffs must show (1) that they have suffered an injury-in-fact that 

is (2) traceable to the defendants and that (3) can likely be redressed 

by a favorable ruling. See Lujan v. Defenders of Wildlife, 504 U.S. 555, 

560–61, 112 S. Ct. 2130 (1992); CAMP Legal Def. Fund, Inc. v. City of 

Atlanta, 451 F.3d 1257, 1273 (11th Cir. 2006) (emphasizing that 

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courts have an “independent obligation ... to ensure a case or 

controversy exists as to each challenged provision even in a case 

where the plaintiffs established harm under one provision of the 

statute”). 

Plaintiffs have standing to challenge the Anti-Lobbying 

Amendment due to its immediate application to each of them and its 

direct adverse impact on them. This lawsuit is germane to plaintiffs, 

whose duties and responsibilities include lobbying government 

interests in their private capacities. They are ideally suited to 

challenge the overbroad reach of the Anti-Lobbying Amendment.

Florida law embraces the right of citizens to sue when they are 

affected by statutory enactments. Sancho v. Smith, 830 So. 2d 856, 

864 (Fla. 1st DCA 2002) (“Citizens who are adversely affected by the 

exemption in section 101.161(1), Florida Statutes (2000) can make 

the argument for themselves.”). See also Crawford v. Gilchrist, 64 Fla. 

41, 59 So. 963, 967 (1912) (recognizing standing of Governor as 

citizen and elector, inter alia, in suit challenging proposed 

constitutional amendment).

III. Plaintiffs Are Irreparably Injured and Have No 

Adequate Remedy at Law.

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Absent prompt relief from this court, plaintiffs have no remedy 

whatsoever to vindicate their right to participate in the guarantee of 

freedom enshrined in the First Amendment. Just like every other 

citizen and organization in the United States, they have a right to 

engage in political speech so long as it does not interfere with any 

over-arching public policy. Even then, the restrictions must be far 

narrower than the broadside prohibition imposed by the AntiLobbying Amendment. 

Once deprived of their speech or required to resign their public 

offices or terminate their employment, the plaintiffs will have no 

effective remedy to restore them to the status they occupied before 

implementation of the unconstitutional restrictions. These rights and 

benefits, once lost, are gone forever, depriving them of any 

meaningful remedy and creating an irreparable injury to them and to 

all others similarly situated, as well as the citizens who have voted

them into office to serve the public interest. The concrete and 

substantial injuries to the plaintiffs cannot be undone. 

If Florida’s ethics and elected officials do not take the 

immediately available efforts to narrow and limit the Anti-Lobbying 

Amendment, the plaintiffs will lose their freedom to practice their 

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precious First Amendment guarantees. Subsequent monetary 

damages cannot compensate for their loss of the right to free speech. 

IV. The Balance of Equities Favors the Requested Relief.

The balance of equities likewise favors plaintiffs. All hardships 

and disabilities will be solely borne by the plaintiffs and all others 

similarly situated due to the immediacy of the Anti-Lobbying 

Amendment. No Florida interest is harmed by holding the 

Amendment in abeyance pending the outcome of this litigation. Nor 

will the public or the public interest suffer in any meaningful way 

during the pendency of this litigation. 

Above all, these plaintiffs have significant histories of serving 

the public interest with nary a blemish on their government records. 

That status as righteous holders of the public’s confidence 

undermines any speculation that harm will result if these officials 

are able to practice the broad, existing contours of free speech while 

continuing to discharge their obligations and duties to the 

Constitutions and laws of the United States and the State of Florida, 

as they committed when taking their oaths of office. Plainly, their 

interests outweigh any possible harm to the public.

V. The Public Interest Is Furthered.

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The public interest would benefit substantially by the issuance 

of the requested relief. Allowing all elected officials to enjoy the 

protections of free speech advances the public interest, and further 

solidifies the ability of good and decent public officials to continue in 

their elected positions. 

VI. No Bond Should Be Required.

No monetary bond is needed here as a condition of injunctive 

relief. Plaintiffs are public officials who have been called by the 

electors to serve the public interest. Their ability to function as public 

officials while continuing to earn a living provides no benefit to them 

different from the First Amendment freedoms enjoyed by all 

Floridians. If any bond is required, a modest bond of $1,000.00 

should protect the public interest. See, e.g., Tancogne v. Tomjai 

Enters. Corp., 408 F.Supp.2d 1237, 1252 (S.D. Fla. 2005) (court has 

discretion to waive bond requirement).

CONCLUSION

The interests of justice favor the granting of preliminary 

injunctive relief to stay enforcement of the Anti-Lobbying Amendment 

pending the outcome of this litigation. 

Dated: December 27, 2022.

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Respectfully submitted,

COFFEY BURLINGTON, P.L.

2601 South Bayshore Drive

Penthouse One

Miami, FL 33133

Tel: (305) 858-2900

Fax: (305) 858-5261

By: /s/ Kendall Coffey

 Kendall Coffey

Florida Bar No. 259861

Scott Hiaasen

Florida Bar No. 103318

kcoffey@coffeyburlington.com

shiaasen@coffeyburlington.com

lperez@coffeyburlington.com

service@coffeyburlington.com

KUEHNE DAVIS LAW, P.A.

Miami Tower, Suite 3105

100 S.E. 2 Street

Miami, FL 33131-2154

Tel: (305) 789-5989

Fax: (305) 789-5987

By: /s/ Benedict P. Kuehne

Benedict P. Kuehne

Florida Bar No. 233293

ben.kuehne@kuehnelaw.com

efiling@kuehnelaw.com

RONALD L. BOOK, P.A.

4000 Hollywood Blvd., Suite 677-S

Hollywood, FL 33021-6751

Tel: (305) 935-1866

By: /s/ Ron Book

Ronald L. Book

Florida Bar No. 257915

ron@rlbookpa.com

RHF LAW FIRM, LLC

2600 S. Douglas Road, Suite 305

Coral Gables, FL 33134

Tel: (305) 501-5011

By: /s/ Robert Fernandez

Robert H. Fernandez

Florida Bar No. 91080

rfernandez@rhflawfirm.com

CERTIFICATE OF SERVICE

I certify on December 27, 2022, I electronically filed this 

document with the Clerk of the Court using CM/ECF. I also certify 

this document is being served this day on all counsel of record either 

via transmission of Notices of Electronic Filing generated by CM/ECF 

or in another authorized manner for those counsel or parties not 

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authorized to receive electronically Notices of Electronic Filing.

By: S/ Benedict P. Kuehne

BENEDICT P. KUEHNE

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SERVICE LIST

Kendall Coffey

Florida Bar No. 259861

Scott Hiaasen

Florida Bar No. 103318

kcoffey@coffeyburlington.com

shiaasen@coffeyburlington.com

lperez@coffeyburlington.com

service@coffeyburlington.com

COFFEY BURLINGTON, P.L.

2601 South Bayshore Drive

Penthouse One

Miami, FL 33133

Tel: (305) 858-2900

Fax: (305) 858-5261

Benedict P. Kuehne

Florida Bar No. 233293

ben.kuehne@kuehnelaw.com

efiling@kuehnelaw.com

KUEHNE DAVIS LAW, P.A.

Miami Tower, Suite 3105

100 S.E. 2 Street

Miami, FL 33131-2154

Tel: (305) 789-5989

Fax: (305) 789-5987

Ronald L. Book

Florida Bar No. 257915

ron@rlbookpa.com

RONALD L. BOOK, P.A.

4000 Hollywood Blvd., Suite 677-S

Hollywood, FL 33021-6751

Tel: (305) 935-1866

Robert H. Fernandez

Florida Bar No. 91080

rfernandez@rhflawfirm.com

RHF LAW FIRM, LLC

2600 S. Douglas Road, Suite 305

Coral Gables, FL 33134

Tel: (305) 501-5011

Steven J. Zuilkowski

Florida Commission on Ethics

Building E, Suite 200

325 John Knox Road

Tallahassee, FL 32302-4113

zuilkowski.steven@leg.state.fl.us

Michael B. Dobson

Florida Department of Financial 

Services

200 E Gaines Street

Tallahassee, FL 32399-6502

michael.dobson@myfloridacfo.com

Henry C. Whitaker

Florida Solicitor General

PL-01, The Capitol

Tallahassee, FL 32399-1050

henry.whitaker@myfloridalegal.

Case 1:22-cv-24156-BB Document 19 Entered on FLSD Docket 12/27/2022 Page 23 of 23