Asked yes or no whether the Bar had any communication with Davis about the complaint beyond his one typo email, its Deputy General Counsel replied: "This matter is closed. Thanks." The Bar's first answer came 57 days later, after Husband sued, in a paper to a judge.
Art. I, s. 24(a) puts the burden on the custodian, and the Bar's own filing concedes its records "are governed by" Rule 2.420. Asked whether any Davis correspondence existed beyond one email, the Deputy General Counsel answers yes or no; if yes, he names the rule that withholds it; if no, he confirms it in writing. The Bar proved the answer fit in one line: it gave one, to a court.
- Dec. 1, 2025: Husband's first question: "Apart from Mr. Davis's brief e-mail pointing out a typographical error, did the Bar receive any written or electronic communication from and/or send any written or electronic communication to Mr. Davis (or anyone on his behalf) in connection with this complaint?" If yes, which rule withholds it; if no, "will the Bar please confirm that in writing?" Fourth, a privilege index. FNEW-B2, N-077Read them: Husband's email, Dec. 1, 2025 (link pending redacted copy)
- Dec. 15, 2025, 9:15 AM: the reply, in full: "Mr. Hanson: As my correspondence dated November 24 stated, you have been provided the entire public record under Rule 3-7.1(b), Rules Regulating The Florida Bar. This matter is closed. Thanks." Dec. 17: Husband sued in Leon County. FNEW-B2Read them: Courtemanche email, Dec. 15, 2025 (petition exhibits p. 282) (link pending redacted copy)
- Jan. 27 to Feb. 9, 2026: the Bar's motion to dismiss: "Such records were not provided because they do not exist." Asked directly on Feb. 9, its counsel by email: "there are no comms with Mr. Davis at all withheld from public record production. There aren't any to withhold." N-077, FNEW-B2
Deputy General Counsel Rick Courtemanche (the Dec. 15 reply). John Londot, Greenberg Traurig, counsel for the Bar (the Jan. 27 motion; the Feb. 9 email). One records request, four written questions, one reply. Every duty here arises from Article I, section 24 and the Bar's own public-record rule on this request alone; no other card is needed to establish it.
Art. I, s. 24(a), Fla. Const. presumes the Bar's records open and puts the burden of any withholding on the Bar. Rule 2.420(m)(2) requires the basis for any denial in writing. Rule 3-7.1(b) makes correspondence "furnished to, served on, or received from the respondent" part of the closed-file public record.
The details are where it lives: full record, receipts, related cards
On 12/1/25 Husband put four written questions to the Bar's Deputy General Counsel about the production from the closed file: whether the Bar had sent or received any communication with Davis beyond the one produced email; if so, what rule provision took that correspondence outside the Rule 3-7.1(b) public record; if not, to confirm that in writing; and whether the Bar would provide a privilege or confidentiality index for anything in the file it treated as outside the public record. On 12/15/25 at 9:15 AM, eight minutes after his morning follow-up, the reply came back in full: "Mr. Hanson: As my correspondence dated November 24 stated, you have been provided the entire public record under Rule 3-7.1(b), Rules Regulating The Florida Bar. This matter is closed. Thanks." Two substantive sentences. Neither answers any of the four questions. The 11/24 correspondence it points back to had said something more: "the bar is not an investigative agency like law enforcement. Our investigative resources are limited. You need to have the court in the underlying litigation make an evidentiary finding that the attorney you complained about committed misconduct." Two days after that reply, on 12/17/25, Husband filed his mandamus petition in Leon County. Fifty-seven days after the questions were asked, the Bar answered the first one for the first time, in its motion to dismiss that suit: "Such records were not provided because they do not exist" (N-077). [REFUSED]
A custodian that withholds records states the basis. A privilege is asserted, not implied. The Bar's own filed paper concedes that Rule 2.420 governs its records, and that rule requires an identified basis for any withholding and a written basis for any refusal. Each of the four questions had a yes-or-no or a document as its answer. The Bar's later court filing proves the answer existed and could be stated in one line, because the Bar stated it in one line. The complainant got it only after he sued, and only in a document written to a court. The refusal was also pre-authorized: three months earlier the Bar had put in writing that further correspondence "will be placed in the file without response" (N-055).
four written questions, each answerable with a yes, a no, a rule citation, or an index; the entire reply was that he had already been given everything and that the matter is closed; the first real answer came 57 days later, in a paper addressed to a judge
The 12/15/25 response is an EMAIL, not a letter: from Richard Courtemanche, Deputy General Counsel, to Husband's personal email address with the ACAP mailboxes and one Bar address in copy, Monday December 15, 2025 at 09:15 AM EST, subject "RE: Christopher Hanson -Continue follow up Deficiencies in Public Records Response: W015656-111025." The only copy in the record is embedded at page 282 of 285 of the exhibit bundle to the Verified Petition for Writ of Mandamus, Filing #237979141, e-filed 12/17/2025 08:40:29 PM. It replies to Husband's own 9:07 AM follow-up that same morning, so it closes a chain rather than answering the 12/1/25 email standing alone. The 11/24/25 Courtemanche quote is at Leon ROA p. 44 (source spells "investigative"; the Bar's briefs render "investitive"). The 12/1/25 four questions are independently narrated inside N-077. The 1/27/26 statement is at Leon ROA p. 634 (motion internal p. 10), footnote 4 same page. Rule 2.420 concession at the same footnote. Rule 3-7.1(b) defines the closed-file public record to include reports, correspondence, papers, recordings, and transcripts of hearings furnished to, served on, or received from the respondent "or the complainant"; the full subdivision is quoted at FNEW-B1 from the current rule.