COMPLAINT AGAINST THOMAS M. WOODRUFF, ESQ.

Attorney THOMAS M. WOODRUFF, ESQ. (FL Bar No. 121693) has

abused his role as attorney, his powers of Subpoena, and the filing and
scheduling of legal proceedings for purposes of intimidation, harassment,
and to create an unnecessary burden and NOT to forward any compelling
legitimate need of his client and in so doing has failed to uphold his duty “to
use the law’s procedures only for legitimate purposes and not to harass or
intimidate others” (Rules Of Professional Conduct For
Florida Lawyers, Preamble). Mr. Woodruff has intentionally
joined with his client, a convicted spouse abuser and child abuser, to file a
Complaint consisting of baseless allegations for the sole purpose of using
our legal system to continue his client’s spousal abuse.
1. STEVEN T. FLAX was served a copy of the Complaint on
5/4/2009 for a new Civil Legal Action written and signed by Mr.
Woodruff. Please see “Exhibit A.” The Complaint was served on
Mr. Flax on the fourth floor of the Edgecomb Courthouse as Mr.
Flax entered Judge Fernandez’s Courtroom for the beginning of his
divorce trial with the apparent goals (1) of harassing and
intimidating Mr. Flax as he was about to give testimony and (2) of
generally disrupting a legal proceeding that is unrelated to Mr.
Woodruff’s Complaint. Mr. Woodruff and his client, LINDA
HART FLAX, were fully aware of Mr. Flax’s home and office
addresses and that Mr. Flax was represented by Counsel who was
available to receive service of Complaint. Mr. Woodruff had
attended Mr. Flax’s wedding six (6) years earlier and employs the
father of his client.

2. Mr. Woodruff’s 5/4/2009 Complaint alleged multiple causes of

action including allegations that are not recognized under Florida
law and are outrageous. Mr. Woodruff knew or should have known
that the numerous claims he raised are not supported by the
material facts necessary to establish the same or would not be
supported by the application of the existing law to those material
facts. The allegations raised in the Complaint were false. Mr.
Woodruff failed to perform rudimentary reasonable investigation
of the Complaint’s multiple causes of action prior to filing. Mr.
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Woodruff filed his complaint with the sole purpose of using the
judicial system and his role as officer of the court to INTIMIDATE
and HARASS, and to compel Mr. Flax to spend funds to defend
himself from Mr. Woodruff’s frivolous litigation.

3. Mr. Woodruff knew or should have known his client is an admitted

alcoholic, drug abuser, and convicted criminal who was arrested
and convicted for abusing her disabled spouse, Mr. Flax, the
Defendant. Mr. Woodruff knew or should have known his client
had abused the Defendant for a period of years and attempted to
murder the Defendant with a loaded handgun. Mr. Woodruff knew
or should have known his client was arrested twice for DUI, twice
for violations of Injunction For Protection From Repeat Domestic
Violence and was arrested again for physically abusing
Defendant’s fourteen-year-old daughter. Mr. Woodruff knew or
should have known that his client was engaged in a divorce and
was in an agitated emotional state, frequently intoxicated, and
otherwise incapable of providing reliable information or making
sound judgments.

4. On 5/13/2009, Mr. Woodruff had Mr. Flax served with a

SUBPOENA FOR TAKING DEPOSITION on 6/2/2009 (“Exhibit
B”). Mr. Flax had long standing plans for foreign travel at that
time for the purpose of retrieving foreign bank statements required
in the divorce proceeding that Ms. Flax refused to produce. Mr.
Flax sent letters and faxes and placed phone calls to Mr. Woodruff
notifying him of the scheduling conflict and requesting a
rescheduling of his deposition, offering five alternative dates.
(Copies of these letters and faxes and a log of phone calls will be
sent upon your request.) Instead of rescheduling the deposition,
Mr. Woodruff insisted Mr. Flax honor his subpoena (“Exhibit C”).
Mr. Flax believes that Mr. Woodruff was informed of Mr. Flax’s
foreign travel plans to recover Ms. Flax’s Cayman Island bank
statements and Mr. Woodruff specifically scheduled the date and
time of taking Mr. Flax’s deposition for purposes of intimidation
and harassment and to specifically interfere with an unrelated legal
proceeding. By these actions, Mr. Woodruff has abused his
subpoena powers and the Florida Bar’s Rules of Professional
Conduct and should be sanctioned.

5. Mr. Woodruff’s Complaint alleges that Mr. Flax committed torts

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against Ms. Flax by his communication of truthful and accurate

information about Ms. Flax’s six (6) arrest reports that are posted
on the Internet by the Hillsborough County Sheriff’s Office and are
public record. The truthful communications alleged by Mr.
Woodruff are, in fact, victim impact statements from the victim of
four (4) years of domestic violence and the statements were made
to the State Attorney’s Office and to two Florida Judges. Mr.
Woodruff has abused his role as officer of the court to create a
chilling effect for the purpose of restricting Mr. Flax’s First
Amendment right to Free Speech and for the purpose of
undermining the legal process as it prosecutes a dangerous
convicted criminal.

6. On August 20, 2009, the Honorable Judge Cook dismissed all

counts of Mr. Woodruff’s Complaint (“Exhibit D”) and gave Mr.
Woodruff thirty (30) days to submit an Amended Complaint. On
September 9, 2009, Mr. Woodruff dismissed his own Complaint
“Without Prejudice” (“Exhibit E”). Clearly, Mr. Woodruff was
well aware that his complaint was frivolous, without merit, and had
no basis in Florida law. Nevertheless, Mr. Flax, a disabled
physician on a fixed income, incurred over $3,000.00 in legal fees
and costs and experienced severe emotional distress as a direct
result of Mr. Woodruff’s frivolous Complaint. Mr. Flax is seeking
to have Mr. Woodruff sanctioned for his abuses and to have Mr.
Woodruff reimburse Mr. Flax’s legal fees and costs that are the
direct result of Mr. Woodruff’s frivolous civil Complaint.

In conclusion, I respectfully request that you read Mr. Woodruff’s frivolous

Complaint and consider that his client was arrested six (6) times, convicted
(3) times, is an admitted substance abuser, while the Defendant has never
been arrested, is disabled, and has been the victim of years of spousal abuse.
I respectfully request that you consider that Mr. Woodruff is a close friend
and the employer of Plaintiff’s father. I respectfully request that you (1)
severely sanction Mr. Woodruff for his violations of the Rules Of
Professional Conduct For Florida Lawyers, (2) order Mr.
Woodruff to reimburse Mr. Flax for his costs and fees, and (3) impose any
other sanctions that you deem appropriate.