The Bar told Husband his complaint received "investigation by a Senior Staff Attorney" and two more reviews. Its counsel later told the family court "the Bar did not act on his complaint," and its appellate brief told the First District the file "was closed without further investigation."
Rule 3-7.3(b) required bar counsel to investigate Husband's sworn complaint, and Rule 3-7.3(d) permits dismissal "after complete investigation," with notice of the "reasons for dismissal." A Director of Intake who certifies an investigation and two reviews can show the work of each when asked, because the closed file is public under Rule 3-7.1(b). The Bar gives the complainant and the courts one account of what it did.
- Feb. 24, 2025: Bar Counsel Allie F. Huston closed the sworn complaint six days after filing. Davis was never asked to respond. The letter: "In addition to the submitted documentation, I also reviewed the underlying docket in Hillsborough County Case No. 2024-DR-1150." N-031, N-105
- Sept. 23 to 24, 2025: Alicia Gangi, Chair of Grievance Committee 13A, sustained the closure, copying Davis "so that the attorney is aware that an additional review of this matter has taken place." The next day Director of Intake Shanell M. Schuyler: "The review of your allegations against Mr. Davis included investigation by a Senior Staff Attorney, review of the closure by the undersigned as Director of Intake, and a review by the Chair of Grievance Committee 13A." And: "Further correspondence from you regarding this matter will be placed in the file without response." N-055, N-105Read them: Schuyler letter, Sept. 24, 2025, and Gangi letter, Sept. 23, 2025 (record on appeal pp. 641, 643) (link pending redacted copy)
- May 22 to June 30, 2026: the Bar's counsel to the family court: "the Bar did not act on his complaint." June 5: records of what the Bar did before those assurances "have been disposed of." June 30, its appellate brief: the file "was closed without further investigation," the review "limited to the submissions and court records." N-105, N-116, N-126, N-055Who was the Senior Staff Attorney, what did that investigation consist of, and what record of it did the Bar hold before reporting its records disposed of?
Bar Counsel Allie F. Huston (closure). Alicia Gangi, Chair, Grievance Committee 13A (Sept. 23 letter). Shanell M. Schuyler, Director of Intake (Sept. 24 letter). One sworn complaint, one file, three described reviews. Every duty here arises from the Bar's own rules on this file alone; no other card is needed to establish it.
Art. V, s. 15, Fla. Const. vests attorney discipline in the Supreme Court. Rule 3-7.3(b): bar counsel "must investigate" a sworn complaint. Rule 3-7.3(d) permits dismissal "after complete investigation." Art. I, s. 24(a) presumes the closed file open and puts the burden on the Bar.
The details are where it lives: full record, receipts, related cards
On 9/24/25 the Bar sustained its own closure. Its Director of Intake described three internal reviews of the closure: by a Senior Staff Attorney, by the Director of Intake, and by the Chair of Grievance Committee 13A. The letter stated: "While your disagreement with the outcome of the Bar's investigation is duly noted, there is no further review afforded to closed files and no right to appeal... Further correspondence from you regarding this matter will be placed in the file without response." A day earlier the Chair had made the same point in her own sustaining letter, copying Davis on it. A later public-records request for the file that review would have generated produced, from the closed file, one email about a typographical error (FNEW-B1). The Bar has never reconciled this account with its later, inconsistent statements about the same closure (N-105, N-116). [DENIED]
Three reviews were described in the 9/24/25 letter: a Senior Staff Attorney investigation, a Director of Intake review, and a Grievance Committee Chair review. A review that examined a closure leaves a record, and a closed file is public under the Bar's own rule. No product of any of the three appears in any Bar letter, filed paper or brief. Later Bar statements run against the letter: a filed paper said the Bar 'did not act' (N-105); its Deputy General Counsel said the file was 'disposed of' (N-116).
the Bar described three internal reviews of the closure but produced no record of what any of them did, and told the complainant that anything further he wrote would go in the file without response
- Schuyler letter 9/24/25, Leon ROA p. 641: also states "Extensive rules, procedures, and policies exist to ensure that bar complaints are fully aired, investigated, and reviewed at multiple levels," and "The review of your allegations against Mr. Davis included investigation by a Senior Staff Attorney, review of the closure by the undersigned as Director of Intake, and a review by the Chair of Grievance Committee 13A."
- Gangi letter 9/23/25, Leon ROA p. 641 vicinity and Bar file copy: "I am also copying Mr. Davis on my response so that the attorney is aware that an additional review of this matter has taken place and that I am sustaining the former decisions to close this file as proper and correct."
- Both filed by the Bar's own counsel as Composite Exhibit A to the 1/27/26 motion to dismiss, judicial notice requested at ROA p. 626.
- Answer Brief admissions at 1D2026-0728 Answer Brief p. 24 (PDF p. 30), filed 6/30/26, signed M. Hope Keating: file "was closed without further investigation" and review "limited to the submissions and court records."
- Huston letter 5/6/25, Doc 200 p. 1 (single-Director, up-to-60-days process). Standing Board Policy 15.75 gives complainant 30-day review windows and sets no time standard for the Bar's own reviews.
- "Three-level review" is NOT the letter's phrase and is barred, as are "three-layer," "three-stage," "three-tier"; name the letter's own three steps instead.
- Later inconsistent statements at N-105 (5/22/26) and N-116 (6/5/26). Produced set at FNEW-B1.
- Related decision points: N-126.