Lisa Epstein

607 Gazetta Way

West Palm Beach, FL 33413

August 9, 2010

Heather Slager
Notary Education Coordinator
Executive Office of the Governor
Notary Section
The Capitol
Tallahassee, FL 32399-0001

Further Comment and Additional Information RE: Erin Cullaro and Lisa Cullaro Notary
Complaints

On July 21, 2010 and July 23, 2010, I received from your office Ms. Erin Cullaro’s and Ms. Lisa Cullaro’s
respective responses to my complaints through their attorney Mr. Ricardo A. Roig. The following is my
timely response, including further comment and additional information.

In Florida, notaries are public officers appointed by the Governor at his discretion as directed by the
Florida Constitution and Florida Statutes. Therefore, it is not only my right but also my solemn duty to
report public official misconduct whenever observed.

In an effort to distract from the allegations in my complaint, the two Ms. Cullaros and their attorney,
Mr. Roig, allege that the multiple complaints regarding the two Ms. Cullaros’ possible misconduct
are a coordinated effort between the complainants. In their attempts to deflect attention from the
issues of my original complaint, they use accusatory language towards me, maligning my character and
calling into question my motives for filing a complaint. By claiming that my complaint is an abuse of
the complaint process, the respondents question if my complaint is “genuine” and state that they “do
not appear to be bona fide complaints”. For the record, Ms. Theresa Pursino’s name and person is
wholly unknown to me despite Respondents’ assertions that she is “an apparent relative” of mine.
Furthermore, they call upon this administrative body to dismiss my complaint in its entirety justifying
their request by simultaneously offering conflicting rationale that; 1) I have not “been aggrieved by any
alleged impropriety complained of” and 2) I “have a personal vested interest in attacking the attorney
fee affidavits notarized by the Cullaros” . What is offered in refute of the documentary evidence
showing wide variations of the two Ms. Cullaros’ signatures on public record documents executed
based on their authority and capacity as attorneys and/or notaries? Ludicrous allegations that I have
a "score to settle" with Ms. Erin Cullaro and some vague “legal strategy” are not only baseless, but are
completely irrelevant to the issues raised in my complaint. Ad hominem attacks on me as a complainant
notwithstanding, the Cullaro sisters-in-law still have signed legal documents with signatures that vary
to such a degree that any reasonable person would question their authenticity. Resorting to such a
transparent strategy when faced with clear and convincing signs of possible misconduct reflects poorly

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on the respondents, is not helpful to the fact finding process, and most telling, does not address the
simple question “Did you sign each of these documents?”

The administrative body is urged to focus on the substance of the allegation as proven by a myriad of
evidence: that the Cullaro sisters-in-law conspired and collaborated to misuse the notarization process.
The effect of that misuse, as Respondent noted, is currently subject to adjudication in several Circuit
Court proceedings across the state of Florida. The Cullaro sisters-in-law are vigorously objecting to all
deposition requests wasting judicial resources and adding layers of expense in order for this matter
to “be resolved in that forum” as Respondents suggested (see exhibit A). Conversely, jurisdiction of the
regulation and notarization process vests solely with this administrative agency.

Respondents materially misstate and mislead the administrative body in their cite of House of Lyons.
The substance of House of Lyons is whether the notary stamp is valid as to the core affidavits, not
whether the notary is allowed to purposefully, and with willful intent, misuse her stamp, as may be the
case here. House of Lyons clarifies, "The notary who took the acknowledgment identified the named
individuals as the persons 'described in and who executed the foregoing instrument." House of Lyons,
at 36. In other words, there is no question that the notary in House of Lyons was the notary who signed
and sealed the document. The Cullaro sisters-in-law may have abused their position as notaries. If
House of Lyons has any relevance whatsoever it is only that the Supreme Court did not envision a notary
giving her stamp away, which may have been the case here, because to do so defeats the purpose of the
notarization process.

While not directly involving Ms. Erin Cullaro, which is the reason I did not present the following pieces
of information in my original complaint, I am now compelled to widen the scope of my complaint
and will comply with the request for additional information. After reviewing Ms. Erin Cullaro’s and
Ms. Lisa Cullaro’s response through their attorney Mr. Roig, I am increasingly concerned over of a
systemic process of wrongdoing involving the work product, including sworn affidavits, submitted by
the hundreds of thousands into court files across the state of Florida by the law firm Florida Default
Law Group (FDLG). Several circuit court judges across the state of Florida have verbalized the same
concerns from the bench (exhibits B, C, D, E). Federal Judge John K Olson sanctioned Florida Default Law
Group for filing false affidavits in federal Court (exhibit F). In April 2010, the Florida Attorney General
Office opened a civil investigation into FDLG (Exhibit G). Mr. Anthony Woodward was the prior affiant on
the same types of affidavits of reasonable attorney fees for FDLG as were the task of the Cullaro sisters-
in-law. He was sanctioned by the Florida Supreme Court for misconduct surrounding his professional
actions as the attorney affiant on the same type of documents (exhibit H).

The questionable signatures of the Cullaro sisters-in-law on the affidavits of reasonable attorneys’ fees,
were for many years, submitted as evidence in thousands of FDLG lawsuits across the state of Florida
monthly. Ms. Erin Cullaro was the affiant on the types of affidavits that are the subject of my complaint,
until her employment began at Florida’s Office of The Attorney General (exhibit I), at which point she
became the notary. During the time when Ms. Erin Cullaro was the attorney affiant, the notary on these
documents was her sister-in-law, Lisa Cullaro, Esq. When Ms. Erin Cullaro stopped acting in the role of
attorney affiant and became the notary, Ms. Lisa Cullaro ceased acting as the notary and became the

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attorney affiant. Ms. Erin Cullaro was at one point an attorney at Ecchevarria and Associates, whose
principal is Michael Ecchevarria, Esq. who is also the managing partner of FDLG.

Ms. Erin Cullaro’s signature varies wildly and at times appears to be an exact replica of her sister-in-
law’s signature. Ms. Lisa Cullaro’s signature has been noted to show questionable variation as well.
The response submitted on behalf of Ms. Erin Cullaro directs the reader to logically conclude that the
signatures are undoubtedly Ms. Erin Cullaro’s by virtue of the presence of Ms. Erin Cullaro’s notorial
stamp. If a notorial stamp were the sole determinant of the presence and witness of the named notary,
then one wonders why notaries are required to sign documents that bear their notorial stamps. The
Respondents present preposterous logic that the authenticity of the signature of a notary is irrelevant
if there is a notorial stamp which controls over any requirement for an authentic notarial signature
that is genuinely penned by the person named on the notarial stamp. Clearly, the sole purpose of the
notarization process is that a third party verify the signors of a document are who they allege to be.

In summary neither of the Respondents or their counsel addressed the basic fact in my complaint: that
their signatures vary to a degree that would cause any reasonable person to question the authenticity
of said signatures. Additionally, it appears that neither of the Respondents’ furnished “a sworn written
response to the allegations contained in” the complaints as directed by the Office of The Governor. This
administrative body has the sole authority to demand from each of the Ms. Cullaros an answer, signed
and sworn to under penalty of perjury, to simple questions, “Did you sign all of these documents? Did
you ever sign for each other?” (Exhibit J). Petitioner respectfully requests this agency to query Ms.
Erin Cullaro and Ms. Lisa Cullaro and to protect the integrity of the notarization process pursuant to its
mandate by and through the laws of the State of Florida.

Thank you for the opportunity to continue this dialogue.

Sincerely,

Lisa Epstein

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Exhibits

Exhibit A: Motion for Protective Order by John Cullaro, Esq (Erin Cullaro’s husband, Lisa Cullaro’s
brother) and Florida Default Law Group

Exhibit B: FL Circuit Court Judge J Michael Traynor’s order RE: US Bank v McLeod

Exhibit C: FL Circuit Court Judge Jennifer Bailey transcript RE: HSBC Bank USA v Eslava

Exhibit D: FL Circuit Court Judge Clyde Wolfe order RE: Deutsche Bank National Trust v Lippi

Exhibit E: Patterson, Steve. “Foreclosure foul-up could cause penalties for lawyers.” Jacksonville.com 25
May 2010
http://jacksonville.com/news/metro/2010-05-25/story/foreclosure-foul-could-cause-court-
penalties-lawyers

Exhibit F: Federal Judge John K Olson Sanction Order

Exhibit G: Announcement of Florida Attorney General Civil regarding Investigation into Florida Default
Law Group

Exhibit H: Anthony Woodward Complaint and Sanctions

Exhibit I: Behnken, Shannon and Sasso, Michael. “State AG Investigates Its Own.” TBO.com Tampa Bay
Online 01 May 2010
http://www2.tbo.com/content/2010/may/01/bz-state-ag-investigates-its-own/

Exhibit J: Multiple examples of further attorney fee affidavits signed by Ms. Erin Cullaro and Ms. Lisa
Cullaro as either a Florida notary or a Florida attorney affiant.

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