Category: Florida Law Blog

Florida Wrongful Eviction Statute

Florida Wrongful Eviction Statute

Florida Wrongful Eviction Statute

The Florida Wrongful Eviction Statute 83.67, informs Florida residents of the acts the Florida courts consider to be “prohibited practices” in landlord-tenant law. This article will highlight some commonly litigated aspects of the Statute. One major component of the Florida Wrongful Eviction Statute is that according to Florida law, a landlord may not directly or indirectly (there are always clever albeit questionable means of achieving a cessation of utilities within a dwelling) cause a disruption or a termination of utility services provided to the tenant. This rule applies even if the landlord is the party responsible for payment of the utilities. The list of prohibited stoppages provided by the Statute (it is not an exhaustive list) is water, heat, electricity, garbage collection, etc. Illegal eviction in Florida is a serious matter that should be addressed by a Florida court for a proper remedy to be granted.

Florida Wrongful Eviction Statute 83.67

Next, in the Florida Wrongful Eviction Statute , the Florida Legislature proscribes the conduct of a landlord that prevents a tenant from gaining “reasonable access” to his/her rental residency. Often, landlords will simply change the locks on the door(s) and cause the tenant to be excluded from the premises. This can leave a tenant without access to food, water, clothing, or shelter, and is therefore outlawed. To this point, a landlord a landlord may not leave a dwelling in disrepair by taking off the roof, removing walls, or otherwise even if for purposes of maintenance because it could leave a tenant exposed and in a tenuous position. The exception is when an eviction has occurred or there has been a surrender, abandonment, or other recovery of possession of the residency.

Illegal Eviction in Florida

Illegal Eviction in Florida

The good news for a tenant finding him or herself in a similar predicament as proscribed by the Florida Wrongful Eviction Statute, is the tenant could be entitled to three (3) months’ rent and a Statutory award of attorney’s fees for having to bring such an action against a landlord acting in bad faith in contravention of Florida law. More good news for a victimized tenant suffering from an illegal eviction in Florida is that he or she may sue the landlord for 3 months’ rent for each separate violation committed by the landlord. For example, if a landlord has both locked a tenant out and seized the tenant’s possessions without having gone through the official and lawful eviction process through the courts, the tenant may sue for 6 months’ rent.

Notice of Nonrenewal of Lease by Tenant in Florida

Notice of Nonrenewal of Lease by Tenant in Florida

Notice of Nonrenewal of Lease by Tenant in Florida

Regarding a Notice of Nonrenewal of Lease by Tenant in Florida, Florida Statute 83.46 provides information about when a renter’s payments are due to the landlord or management company operating as the agent for the landlord. On account of the fact that a large number of the calls to my law office are from renters seeking to remain in their apartments, or from landlords seeking to evict tenants, this blog post represents a great opportunity to interpret the Statutes for potential clients, but is not intended to be legal advice, it is simply an interpretation of what the Statutes could mean to a court if litigated.

To start analyzing a Notice of Nonrenewal of Lease by Tenant in Florida, we must interpret F.S. 83.46(2), which states: “If the rental agreement contains no provision as to duration [length] of the tenancy [your lease], the duration is determined by the periods for which the rent is payable [first of the month, end of the month, or 15th of the month]. If the rent is payable weekly [rent is due on Friday], then the tenancy is from week to week; if payable monthly, tenancy is from month to month; if payable quarterly [rent is due every three months], tenancy is from quarter to quarter; if payable yearly [pay on January 1st for the whole year], tenancy is from year to year.” Without an understanding of this precursor Statute, it is easy to misinterpret the key Statute 83.57.

Notice of Nonrenewal of Lease by Tenant in Florida: What is the Time?

Florida Statute 83.57 governs the “Termination of tenancy without specific term.” This Statute is often litigated, or at least used to make legal arguments, when a lease has expired and a tenant and their landlord continue the rental agreement without signing a new lease agreement. In this manner, the courts may look to when (how often) rent is paid as opposed to how the rental agreement, when it was active, governed the parties’ arrangement. Read carefully the language of the Statute, with my inserts included.

Florida Statute 83.57 provides that; “A tenancy without a specific duration, as defined in s. 83.46(2) or (3) [clearly explained above], may be terminated by either party giving written notice [written notice is vital to the strength of an eviction lawsuit for both parties] in the manner provided in s. 83.56(4), as follows:

(1) When the tenancy is from year to year, by giving not less than 60 days’ notice prior to the end of any annual period; [recall that the court is not referring to the lease agreement itself, in the absence of a new signed written agreement, the court is looking at how often rent is paid]

(2) When the tenancy is from quarter to quarter, by giving not less than 30 days’ notice prior to the end of any quarterly period;

(3) When the tenancy is from month to month, by giving not less than 15 days’ notice prior to the end of any monthly period; and [careful, 30 days’ notice may be most appropriate to avoid a misinterpretation of the law!)

(4) When the tenancy is from week to week, by giving not less than 7 days’ notice prior to the end of any weekly period.

Florida Statute 83.56(4) explains the written notice requirement for terminating a lease in Florida. The Statute states that, “The delivery of the written notices…shall be by mailing or delivery of a true copy thereof or, if the tenant is absent from the premises, by leaving a copy thereof at the residence. The notice requirements of subsections (1), (2), and (3) may not be waived in the lease.” This last part relating to a Notice of Nonrenewal of Lease by Tenant in Florida is of particular importance. A landlord may not disclaim the Statutory requirement in a lease. This is largely because in most cases the landlord writes the lease, and therefore to protect the tenant’s rights, cannot thwart Florida law and foist a violative lease on an unsuspecting renter.

Jonathan Jacobs is a breach of contract attorney Orlando FL that offers consultations with clients where he will explain to you the elements of a breach of contract in Florida to help you resolve your legal issues. Call the Jacobs Law Firm today for a consultation in your contract dispute case, (407) 310-5636, or e-mail us to schedule an appointment: Jonathan@JJLawFL.com.

Do I have to File a Financial Affidavit in Florida Divorce Cases

Do I have to file a financial affidavit in Florida divorce cases

Do I have to File a Financial Affidavit in Florida Divorce Cases?

Do I have to file a financial affidavit in Florida divorce cases? In Daniel v. Daniel, 922 So.2d 1041 (4th DCA 2006), the Court heard arguments from the husband’s attorney regarding whether requiring him to fill out a financial affidavit violated his right to privacy. This was a divorce, non-simplified dissolution of marriage case; involving a marriage of sixteen years. The spouses had no antenuptial (prenuptial) agreement, wife’s petition requested permanent financial relief (permanent alimony), and the wife objected to husband’s attempt to avoid filing financial affidavit.

It is important to note that in almost every divorce case, a financial affidavit is a basic requirement under mandatory disclosure, and both parties must comply. The only circumstance wherein a party, or both parties, may avoid providing the court with a financial affidavit is where there is a marital settlement agreement in a simplified dissolution of marriage case that is private, and the parties mutually agree to not notify the court. Not every court will countenance this sort of arrangement and may require the marital settlement agreement and financial affidavits be filed despite the wishes/request of the parties. Now, back to Daniel v. Daniel, and our original question, do I have to file a financial affidavit in Florida divorce cases?

In Daniel, the Court decided that a husband MUST (mandatory disclosure) file financial affidavit in non-simplified dissolution proceeding involving request for permanent financial relief, and further ruled that such a discovery request did not violate the husband’s right to privacy. The Court’s rationale was that a financial affidavit is essential when the Court is trying to do justice and equity in a Florida divorce case. The Court will likely hear arguments from both sides concerning property divisions, alimony, and a final decree may turn on financial condition of parties. The Court decided that any Florida family law court could not do right thing without sufficient information about parties’ finances. Family Law Rules of Proc., Rule 12.285(d). When you ask yourself, do I have to file a financial affidavit in Florida divorce cases, consider the Court’s decision in Daniel, and engage in best practices for openness and judicial equity.

Jonathan Jacobs is a Divorce Attorney In Clermont Florida, a Divorce Attorney in Orlando Florida, and helps his clients in the surrounding counties.

 

Petition for Relocation Florida Statute

Petition for Relocation Florida Statute

Petition for Relocation Florida Statute

A recent family law decision rendered by the Fourth District Court of Appeals (in Florida) has helped to clarify a key point of contention in relocation hearings and trials involving minor children. The case explores the evidentiary burden of proof required under the Petition for Relocation Florida Statute.

This important decision is Solomon v. Solomon, 221 So.3d 652 (4th DCA, 2017), wherein the Court decided that “A court may not consider potential future, or even anticipated, events as a substitute for evidence.” This means that if a Wife petitions the family law Court for relocation, the Court may not treat the husband’s promises of better conduct in the future as evidence to rebut wife’s evidence that it is in the best interest of the children to relocate to a different state. In Solomon, the husband did not prove by a preponderance of the evidence that it was in the children’s’ best interest to stay in Florida, specifically in the Palm Beach area.

Here, the husband had mental health issues caused by substance abuse problems. These afflictions caused the family to lose its structural integrity and led to a host of hardships. The wife met her burden of proof by showing the Court by a preponderance of the evidence that the children’s best interest was served by moving to Virginia. The husband could not overcome the proof provided/shown to the court by the wife.

Petition for Relocation Florida Statute

Florida Statute 61.13001: Petition for Relocation Florida Statute

Florida Statute 61.13001(8), the Petition for Relocation Florida Statute, governs the burden of proof for rulings on relocation and provides as follows: “The parent or other person wishing to relocate has the burden of proving by a preponderance of the evidence that relocation is in the best interest of the child. If that burden of proof is met, the burden shifts to the nonrelocating parent or other person to show by a preponderance of the evidence that the proposed relocation is not in the best interest of the child.” This burden of proof can be met in multiple ways, and there is no one showing of proof that applies to all family law cases.

In addition to the Petition for Relocation Florida Statute, in Solomon, the Court relied on a Florida Supreme Court case, Arthur v. Arthur, 54 So.3d 454 (Fla. 2010), wherein the Supreme Court of Florida rejected a “prospective based” analysis concerning petitions for relocation, stating: Indeed, a trial court is not equipped with a “crystal ball” that enables it to prophetically determine whether future relocation is in the best interests of a child.” Essentially, a family law litigant opposing relocation must rely on past conduct/behavior, and may not present prospective good intentions and expectations of better relations to the Court as evidence to rebut a petition for relocation.

Jonathan Jacobs is a Divorce Attorney In Clermont Florida, a Divorce Attorney in Orlando Florida, and helps his clients in the surrounding counties.

Motion to Compel In a Florida Family Law Case

Motion to Compel In a Florida Family Law Case

A Motion to Compel In a Florida Family Law Case

A motion to compel in a Florida family law case may be made when one party (the petitioner or the respondent) has failed to abide by a lawfully propounded discovery request. There are many different types of and reasons for filing a motion to compel, but this article specifically relates to a narrow discovery issue involving noncompliance. In most cases, the parties make a discovery request of/from one another. In complex family law litigation relating to alimony, property distribution, and asset and liability distribution, discovery requests can be extensive and take a long time to piece together. In many other cases without such extensive discovery needs, the parties often ask for some bank records, W-2 statements, tax returns, and credit card statements. This sort of discovery is more likely than not obtainable via compliance with mandatory disclosure. Of course, any request for documents in a Florida family law case are subject to objection. When a fairly unchallenging discovery request has been made, by Rule, the party upon whom the request has been made has approximately 30 days to respond. The party responding to the request may make a request for an extension with good cause and in good faith, while the converse is also true, the party propounding discovery may offer an extension upon a showing the other side is getting their documents together and needs a little more time to do so.

This is where/when a motion to compel in a Florida family law case may become vital to the stability of your case. If 30 days have passed, consider sending a reminder to the other side that discovery is due. Consider offering a small extension (the standard time is 10 days) to incentivize the production of the documents requested. If the other party fails to furnish the documents (provided you are in compliance with discovery), and you can certify to the court that you have made multiple good faith efforts to communicate with the non-compliant party (and have been stonewalled or outright ignored), you may then consider filing a motion to compel in a Florida family law case.

Motion to Compel In a Florida Family Law Case

When to File a Motion to Compel In a Florida Family Law Case

If a motion to compel discovery states to the court that the other side has completely failed to respond or object to a good faith and reasonable discovery request, generally, the court will order compliance with discovery to be made within 10 days (20 in some cases). If discovery is still not provided, the court may in some cases award (provided the motion and the attorney ask for it) attorney’s fees to be paid by the noncompliant party. After all, the party acting in good faith should not be made to bear the burden of paying additional legal fees for the other side’s failure to act in good faith.

Jonathan Jacobs is a Divorce Attorney In Clermont Florida, a Divorce Attorney in Orlando Florida, and helps his clients in the surrounding counties. Call the Jacobs Law Firm today for a consultation in your family law case.

Elements of a Contract in Florida

Elements of a Contract in Florida

Elements of a Contract in Florida

In our State, the party seeking to prove the existence of a contract will need to prove the existence of the elements of a contract in Florida. According to the Florida Supreme Court’s jury instructions (in tandem with our lawyerly understanding of contract law), there are three elements of a contract in Florida that altogether, if proven, demonstrate formation. First, the terms of the contract must be definite and certain (unequivocal, unambiguous). Plainly stated, the terms of the agreement must have been clear enough to both parties as reasonable parties, so as to have enabled them to comprehend the terms of the agreement when entering into it to be bound by it.

For example, a simple contract might be for the sale of a car in exchange for a one-time lump sum payment of $5,000.00. Another example is a contract for the sale of vacant land in exchange for 4 installment payments of $15,000 each, due on the first of every month. Of course, there are generally a number of conditions and prerequisites built into every contract, but as long as the terms are clear and certain, element 1 can be proven before the court.

The second of three elements of a contract in Florida is the parties must have agreed to give each other something of legal value. This is often seen as the conferral of a benefit on one party to the detriment of the other (“a benefit to the promisor or a detriment to the promisee”). By way of example, if party A forgoes traveling abroad and chooses instead to go to college here in the United States, and in exchange their benefactor (let’s call her a rich aunt party B) agrees to pay party A’s entire college tuition, a bargain has been struck, and likely a contract has been made/formed. One party (party A) has conferred a benefit, and there is a detriment of sorts to the other party (party B paying $100,000 in tuition).

The third of the three elements of a contract in Florida involves a reasonable person objective standard test. Based on the conduct and representations of the parties, the court asks, “would a reasonable person, similarly situated, have agreed to the terms of the contract and understood them in the same way?” This element is based on the evidence, not the subjective or hidden intentions of the parties. The court prefers to be objective, not to involve itself in the independent biases of the parties. There must be clear manifestations based on a reasonable person standard.

Now you should have a general idea of the elements of a breach of contract in Florida. If you are involved in litigation over a breach of contract, and need to prove the formation of a contract, call the Jacobs Law Firm. We want to hear from you.

Is Alimony Taxable in Florida

Is Alimony Taxable in Florida

Is Alimony Taxable in Florida?

To best answer the question of “is alimony taxable in Florida,” we need to look ahead to some significant changes in the U.S. Tax Code courtesy of the Administration’s Tax Cuts and Jobs Act.  Currently, and for many years, alimony has been taxable against the payee/recipient, and has been a major tax deduction for the payor (person paying alimony due to an income disparity and a host of other statutory family law factors). There is still an alimony tax deduction in Florida, but be on the alert for changes.

The question that many attorneys are asking is whether the modifications to the Tax Code will have a grandfather clause allowing for divorce and alimony settlements made prior to the start of 2019, to remain under the old Tax Code laws regarding alimony. When more light is shed on that subject, we will let you know the relevant changes, if any. If all divorcees are affected, anticipate a deluge of cases flooding the Florida family law courts when payors seek downward alimony modifications.

For now, to continue answering if alimony is taxable in Florida, the current law, such as it has been for years is that if you are ordered to pay alimony, you may deduct the amount paid to your former spouse from your taxes. If you have been a recipient of alimony, you will continue paying taxes on all alimony amounts received, unless you have a clever accountant and financial planner and have certain tax deductions, breaks, or deferments scheduled to reduce the impact/burden of taxation.

Alimony Tax Deduction in Florida

Alimony Tax Deduction in Florida

Moving forward, one of the most fascinating trends to watch will be the impact of the Tax Code changes, vis a vis the Tax Cuts and Jobs Act, to how Florida family law courts award alimony at trial. Currently, the courts take into consideration how much the recipient will be taxed in making an award of alimony. However, if alimony is non-taxable, the payee/recipient will receive more money, and therefore the courts may choose to award less in alimony upfront, but close to the amount he/she would have received had their alimony been taxed on the backend. The alimony tax deduction in Florida may not be here for long.

There are a lot of exciting changes coming to family law courts in Florida and around the country. In the meantime, we hope that your question of “is alimony taxable in Florida,” has been answered to your satisfaction.

Jonathan Jacobs is a Divorce Attorney In Clermont Florida, a Divorce Attorney in Orlando Florida, and helps his clients in the surrounding counties. Call the Jacobs Law Firm today for a consultation in your family law case.

Florida is a No Fault Divorce State

Florida is a No Fault Divorce State

Florida is a No Fault Divorce State

It is a daily occurrence in many family law attorney offices across Central Florida. A client walks in for a consultation, woman or man (gender is irrelevant), and starts the dialogue with a harsh and ostensibly disappointing accusation, “My spouse has been cheating on me.” This is followed by a demand for a divorce from the partner engaging in what the client spouse claims is illicit and inappropriate or immoral behavior. In my law practice, it is common that clients are unaware that Florida is a no fault divorce state. Informing clients that have been emotionally hurt of this fact is difficult, but necessary. No fault divorce in Florida means that obtaining a divorce is less complicated, provided there are no minor children to the relationship, and the party at fault has not exposed the kids to behaviors that are detrimental to their best interests. Divorces can potentially have layer upon layer of complex issues, and rarely if ever are two divorces alike.

What readers really want to know is because Florida is a no fault divorce state, how does or will that impact their dissolution of marriage case? No fault divorce in Florida means that one or both parties need only tell the court their marriage is “irretrievably broken,” which is similar to what other jurisdictions phrase as irreconcilable differences. Irretrievably broken is the standard. One does not need to prove adultery. A spouse might strongly dislike the other spouse’s neck ties, dresses, shoes, breath, eyebrows, personality, television habits, over-cleanliness or lack of cleanliness. The list of potential reasons is endless. The point is that this is a low standard that can only be rebutted upon a rare showing (rarely granted by the court) that marriage counseling for 90 days would somehow take away the problems in a deeply troubled marriage.

No Fault Divorce in Florida

No Fault Divorce in Florida

Florida is a no fault divorce state for many reasons; one primary culturally relativistic reason is that our population is one of the most diverse in the entire nation, and value systems are often different. Another reason there is no fault divorce in Florida is a reduction in compelling the parties to bring their private lives into the public purview. By not forcing litigants to divulge their dirty laundry, the State of Florida allows family law litigants a measure of privacy and personal relief. It is not the job of the Florida family law court to assign blame as pertains to dissolution of marriage. If the reasons for the divorce (gambling, bankruptcy, child abuse, substance abuse, domestic abuse) are more serious than simply falling out of love and seeking greener pastures, and if there are minor children born to the marriage, then the parties are welcome to present testimony about parental fitness. If the parties have no minor children, or if there already is a parenting plan in place, the fact that Florida is a no fault divorce state may preclude any significant probing into the personal lives of the parties.

Jonathan Jacobs is a Divorce Attorney In Clermont Florida, a Divorce Attorney in Orlando Florida, and helps his clients in the surrounding counties. Call the Jacobs Law Firm today for a consultation in your family law case. (407) 310-5636, or e-mail us to schedule an appointment. Jonathan@JJLawFL.com

Motion to Deviate From Child Support Guidelines in Florida

Motion to Deviate From Child Support Guidelines in Florida

Motion to Deviate From Child Support Guidelines in Florida

Did you know that according to Florida Statute 61.30(11)(a), upon motion from counsel or a pro se litigant, the court may agree to increase or lower the amount of child support owed by one or both parties? This motion is known as a Motion to Deviate from Child Support Guidelines in Florida. Similar to other aspects of Florida family law, the circuit court will base its decision to deviate upon arguments from counsel and/or the litigants by relying on the statutory factors. In a Herculean effort to make these factors the court considers more understandable, I will paraphrase them and provide examples where appropriate. This is not an exhaustive list, and there are many other scenarios where a motion to deviate from child support guidelines in Florida may be appropriate for you. This article is only part one in the series, and specifically covers Florida Statute 61.30(11)(a)(1).

The first reason the court may decide adjust the child support amount owed, specifically by increasing the minimum amount owed, is when there are “extraordinary” medical, dental, educational, or psychological expenses. For example, if the minor child requires corrective jaw surgery, orthodontic braces (Invisalign, etc.), or needs significant tooth intervention because of gum decay or cavities, the court will likely see this as a necessary ongoing expense and order the support amount increased upon a showing of medical estimates or bills and orthodontic evaluations.

Motion to Deviate From Child Support Guidelines in Florida

Motion to Deviate From Child Support Guidelines in Florida: Medical and Dental

If the minor child has a serious medical condition such as a heart condition, asthma, bone disorders, or some other rare disease, medical expenses may increase causing the court to order the child support to be increased. Who would want to file this particular motion to deviate from child support guidelines in Florida by asking for the support amount to be increased? The parent that pays for health and/or dental insurance and will be responsible for paying the health care provider(s) for the additional costs associated with medical or dental, or psychological care will ask the court for this baseline increase. Child support in Florida is based on shared responsibility, which is why the court generally requires the Child Support Guidelines Worksheet itself to include medical and dental insurance and uncovered medical and dental costs.

As pertains to education, arguments are frequently heard by the court regarding the alleged necessity of private or charter schools, and regarding the alleged necessity of private tutoring for the minor child. For instance, is the public school in your child’s district rated an F? Is there a nearby charter or private school available at a reasonable cost? Is attendance at that school affordable for the parties and in the best interests of the minor child? Again, this is a question of fact.

When psychological issues are involved, those can range from (and are NOT limited to) depression (sometimes resulting from the parents’ own behavior and arguing), anti-social behavior, etc. Whether the support amount should be increased under the aforementioned circumstances is a question of fact presented by the parties and/or their family law attorneys, and factors applied by the court. Thank you for reading part 1 of this ongoing series, Motion to Deviate From Child Support Guidelines in Florida.

For more information please continue reading.

Jonathan Jacobs is a Divorce Attorney In Clermont Florida, a Divorce Attorney in Orlando Florida, and helps his clients in the surrounding counties. Call the Jacobs Law Firm today for a consultation in your family law case. (407) 310-5636, or e-mail us to schedule an appointment. Jonathan@JJLawFL.com

 

Is daycare included in child support in Florida

Is Daycare Included in Child Support in Florida

Is Daycare Included In Child Support In Florida?

Often during pre-mediation marital settlement or paternity negotiations, or at mediation, one party will ask for day care expenses to be kept off the Child Support Guidelines Worksheet. This is generally not the optimal approach. To best answer “is daycare included in child support in Florida,” it is important to note that in a majority of cases the court requires the parties to exchange Child Support Guidelines Worksheets to ensure the math calculations are accurate and truly represent the information provided on the Financial Affidavits, pay stubs, tax returns, etc. Statutorily, as stated concisely in Florida Statute 61.30(7), child care costs such as daycare incurred as a direct result of one or both parties working (career necessities), looking for work, or obtaining an education with the intend of becoming employed or earning a promotion, MUST be added to the Worksheets. The one caveat the Statute offers is that “Child care costs may not exceed the level required to provide quality care from a licensed source.” In a sense, the Statute encourages parents to find a reputable and licensed child care/daycare provider to look after their child(ren). Mostly, the Florida Legislature and the courts are seeking to compel the parents to find a reasonably-priced day care that does not overburden their finances, nor cause significant disagreements about the provider’s quality.

Is daycare included in child support in Florida

Is Daycare Included In Child Support In Florida? A Short Hypothetical

Hypothetically speaking, if there are two day care facilities and one costs $170 per month for an infant, the other costs $230 a month, both parties should consider finding a middle ground. Find a day care that is relatively nearby, which costs $200 a month and has the option of a camera to observe your child(ren) while they are being cared for.

“Is daycare included in child support in Florida?” Judges prefer when the parties do their best to compromise. Break ups are often full of bitterness and they often cause distrust. Just because the parties are no longer “together,” does not make them bad parents or incapable of making rational adult decisions in the best interest of their child(ren). Think carefully about whether your actions represent the best interest of your child(ren), or are a reaction to the breakdown of your relationship. Daycare is vital to the health and security of children when parents work full time and there are no other family members available to help with child care.

For more information please continue reading.

Jonathan Jacobs is a Divorce Attorney In Clermont Florida, a Divorce Attorney in Orlando Florida, and helps his clients in the surrounding counties. Call the Jacobs Law Firm today for a consultation in your family law case. (407) 310-5636, or e-mail us to schedule an appointment. Jonathan@JJLawFL.com