D OUGLAS L AW F IRM
Charles T. Douglas, Jr. A TT O R N E Y S AND C O U N S EL O R S AT LAW John Schaller
Jeremiah Blocker R. Kevin Sharbaugh
Christopher W. LoBianco 117 N. 2ND STREET, PALATKA, FL 32177 Carol Simpson
Jason Odom John P. Steinmetz
124 N. 5TH AVENUE, JACKSONVILLE BEACH, FL 32250
Morgan Peacock Ian Pickens
Marcus Duffy 309 KINGSLEY LAKE DRIVE, STE.903, ST. AUGUSTINE, FL 32092
Patrick Kennedy
Rory Diamond Of Counsel 100 SOUTHPARK BLVD., STE 414, ST. AUGUSTINE, FL 32086 Lisa Miles
Cindy Marvin Of Counsel 110 N MAGNOLIA AVE, OC ALA, FL 34475 S. Garrett Lee
Holly Southworth
Telephone: (800) 705.5457 Fax: (386)385.5914 www.DHClawyers.com
February 20, 2025
Board of Directors
St. Johns County Airport Authority
4796 US 1 North
St. Augustine, FL 32095
Dear Board members,
This letter is to inform the Board that the Douglas Law Firm will be withdrawing as legal
counsel to the Airport Authority. Our withdrawal is based on ethical obligation under
Florida Bar rules to withdraw when there is a clear legal and ethical conflict. The Florida
Professional Conduct rules that apply include the following: Duty to the Client (Rule 4-
1.13), Duty to Avoid Assisting Illegal Conduct (Rule 4-1.2(d)) and Duty to Withdraw
(Rule 4-1.16).
The legal and ethical conflict involves a pattern of violations of Florida Sunshine Law,
failure to disclose conflicts of interest and other ethical violations by the Chairman of the
Board, Reba Ludlow, and an individual board member, Len Tucker. These violations have
been ongoing and continuous necessitating our withdrawal.
Incidents of direct and knowing violations of the Florida Statute carrying criminal penalties
has been brought to our attention as attorneys. Specifically, violations of Florida Statute
286.011 “Public Meetings and Records”. Additionally, issues involving Florida Statute
112.3143(3)(a) “Voting Conflicts” have been identified.
These violations are alarming, concerning, and have created a conflict of interest that
prevents our firm from continuing to represent the Airport Authority as legal counsel.
Pursuant to Florida Statute 112.3142, each person elected to public office must complete
four (4) hours of required ethics training each calendar year. All Board members have
received training on the required training on Florida’s Sunshine Law, Florida’s Code of
Ethics for Public Officials, Public Records and Public Meetings. Board members are
required to certify on their financial disclosures that they have received this training.
In effort to protect the Airport Authority and the Board, we have made good faith and
reasonable efforts to advise these individual board members to refrain from the perceived
1
and real violations. Specifically, these board members have been informed of the identified
legal issues that violate the Sunshine Law, undisclosed conflicts of interest in voting and
other ethical issues. Our firm has repeatedly advised of the consequences that could
endanger the Airport Authority.
Those warnings and legal advice have been ignored. As a result, our ability to advise the
Board has been impeded, compromised and obstructed. In addition, individual board
members have engaged in what is perceived as retaliatory behavior against our attorneys
for raising legal concerns about potential violations of Florida statutes. This has created a
perception of a hostile environment for our legal professionals.
Because of the conduct of these board members, we are ethically required to withdraw
from representation and notify the Board of our reasons. Furthermore, we may have an
obligation under Florida Bar rules to report potential crimes and illegal conduct to the
appropriate law enforcement agency.
Our firm will continue to be available to staff and the Board by phone or email until the
Airport Authority is able to retain new counsel under these circumstances.
Sincerely,
Jeremiah R. Blocker
