21 Corrupt Attorney Marc Randazza Florida Bar Bribery Accusations

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13. Between August 7, 2012 and August 13, 2012, Respondent and Oron continued discussions regarding reducing the teams of the Settlement Letter and the Judgment into a more definitive written agreement although the District Court had already enforced the settlement and reduced the $550,000.00 settlement amount ("Settlement Amount") to judgment ("Post-Judgment Discussions").

14. During the Post-Judgment Discussions, Oron informed Respondent that it wanted to enter into an agreement to retain Respondent for bona fide legal services, which would have the practical effect of potentially conflicting off Respondent from ever representing a client in litigation against Oron in the future.

15. Subject to the agreement of Liberty and Liberty's execution of a written agreement, Respondent negotiated a separate agreement with Oron whereby $75,000 of Oran's frozen funds would be released to Oron's counsel with the understanding, but no guarantee, that such funds would be used to retain Respondent as counsel for Oron for the payment o f $75,000, which would have the practical effect of potentially conflicting Respondent off any future litigation against Oron ("Post-Judgment Agreement").

16. On or about August 13, 2012, Respondent informed Liberty of the proposed Post- Judgment Agreement by presenting a copy thereof to Liberty's CEO Jason Gibson for his review, approval and signature. The Post-Judgment Agreement encompassed the payment of the $550,000 Settlement Amount and Judgment by Oron to Liberty as well as the release of $75,000 of Oron's frozen funds to Oron's counsel.

17. On or about August 13, 2012, Respondent and Jason Gibson discussed the proposed unfreezing of$75,000 of Oron's funds. Jason Gibson expressed concerns to Respondent about the disposition o f that $75,000 and did not consent to such unfreezing.

18. As a result of the August 13, 2012 discussion between Jason Gibson and Respondent, the Post-Judgment Agreement was not executed. Oran's frozen funds were not

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