On June 16, 2021, Florida Governor Ron Desantis signed into law Senate Bill 56. The new law, which became effective July 1, 2021, requires homeowners associations and condominium associations to deliver, by first-class mail, a 30-day “Notice of Late Assessment” to owners delinquent in the payment of assessments and wait until the 30-day period expires before taking any collection action that will result in the imposition of attorney’s fees and costs against the delinquent owner.  The notice is deemed to have been delivered upon mailing.  When an association produces an affidavit by a board member, officer, manager or agent of the association attesting to the mailing of the notice, a rebuttable presumption is established that the association complied with the notice requirements.

In addition, the new law amends Chapter 718, Florida Statutes, which governs condominium associations, to extend from 30-days to 45-days the period a condominium association must wait, after providing notice to a delinquent owner, before the association may record a claim of lien for unpaid assessments (a “notice of intent to lien”) or before instituting an action to foreclose its claim of lien (a “notice of intent to foreclose”).  Florida law already requires HOAs to provide owners a 45-day notice prior to recording a lien and again before filing a lien foreclosure action.      

With the addition of this new 30-day “Notice of Late Assessment” requirement, there will be a further delay in the ability of a condominium or homeowners association to initiate an action to foreclose its claim of lien to collect a delinquent assessment.  As such, associations that did not previously act early to collect delinquent assessments may now find a need to accelerate the beginning of the collection process.  It may be advisable to now begin that process within a week of the date when an assessment first becomes delinquent.

Senate Bill 56 also establishes requirements that must be met before a homeowners or condominium association may change the method of delivery for assessment invoices and account statements.  The legislation states that invoices for assessments and account statements may be delivered via U.S. mail or by electronic transmission to an owner’s email address on file with the association.  However, before changing the method of delivery, an association must provide notice to the owner by first-class mail 30 days before the association sends the invoices or statements by the new method, and an owner must affirmatively acknowledge his or her understanding, either electronically or in writing, that the association will change its delivery method before the invoice can be sent by the association using the new delivery method.

If you have questions regarding your association’s compliance with these new laws, contact Shuffield, Lowman & Wilson’s community association legal team.

Planning for key employees is an important aspect of the growth of any business. Key employees can either drive value to your company or create a roadblock down the line when preparing for an exit transaction. This is why, as a business owner, it’s never too early to plan for ways to retain and reward key employees through the ultimate sale of your business.

Luckily, your first resort for keeping a key employee happy does not automatically mean giving up ownership. We have seen an uptick in companies using constructs like “phantom stock,” “equity participation shares” and other similarly named plans that, in essence, motivate an employee by enhancing their opportunity for participating in the growth of the company and giving them “skin in the game” all without selling actual shares in the company.

Why not actual stock?

Employees and employers alike are sometimes surprised to find out that issuing actual stock to an employee typically means that the employee must pay income and employment taxes on the value of the stock in the year in which they receive it (as if the stock was cash compensation). There are ways around this, such as requiring the employee to pay for the stock or issuing options to buy stock at a later date. But unless the employer is willing to give them the cash to pay for the stock, which additionally also triggers income and employment taxes, employees will rarely exercise their stock options until an exit transaction is imminent, and will have at that point already forfeited the potential tax benefits of stock ownership. In addition, employees holding actual stock in their employer have the rights to call owner meetings, inspect books and records, review financials, and exercise various other rights of a stockholder under state law. For pass-through entities in particular, employees will have to be issued K-1 statements that will hold up the filing of the employee’s own personal tax returns, and they may potentially have to pay taxes on “distributable” income of the company that they never actually receive. Further, once an employee holds actual stock, it is very difficult to get it back (in the event of a termination, for instance) without that employee’s sign-off. For all of these reasons, we are seeing more and more emerging and established companies steer clear of awarding actual stock to their key employees.

What is a Phantom Stock Plan? 

A phantom stock plan is a compensation plan that provides key employees the financial benefits of actual stock without the tax and other legal issues involved in ownership. This allows key employees to still participate in the growth and profitability of the company. 

Who are the Key Employees?

Key employees are typically those that meet the following criteria: they are highly compensated or they carry out management-level duties (as defined by the Department of Labor), and in either case, they must be able to negotiate their compensation packages. Employees that do not fall into one of these buckets are typically not eligible for phantom stock plans. 

How is a Phantom Stock Plan Structured?

The value of the phantom stock units can be measured by the value of the company stock. There are two main types of phantom stock plans: “appreciation” plans and “full value participation” plans. The full value participation plan pays both the value of the underlying stock and any appreciation in the value. The appreciation-only plan pays just the increase in value of the stock share going forward from the issuance of the shares. For either of these plans, employers will often pick a percentage of the company or a specific number of shares that are used as the basis of the calculation of the value of what is due to the key employee. 

The payout under the plan will often be based upon revenue, EBITDA, multiples and ultimately the value of the company upon exit.  

Further, the employer can choose to vest the plan benefit over a certain number of years, give vesting credit to certain employees for years served, or make the plans fully vested from inception.

When is the key employee paid?

A phantom stock plan will typically payout upon the occurrence of an exit transaction. The payment of the value accruing to the key employee will typically be structured to be contingent on them remaining with the company through at least until the end of the transaction and often up to one or two years after the completion of the transaction. Some plans also have other payment triggers, to the extent they occur prior to an exit transaction, such as the key employee’s death, disability, retirement, or termination of employment. Regardless of the payment trigger, the plan will specify if the payment will be made in one lump sum or as payment installments over time once one of the payment triggers occurs. 

At ShuffieldLowman, our corporate law and mergers & acquisitions team are here to advise clients on their options when looking to retain and reward key employees before, during, and after the exit transaction. If you have any questions, you can contact a member of our team directly or contact us through our website. Phantom stocks programs should be reviewed by an attorney to ensure it is drafted properly and meets the requirement as set by IRS code 409(a).  

On June 16, 2021, Governor DeSantis signed Florida SB 630, which will become effective on July 1, 2021.  The bill modifies certain provisions in the Florida Statutes that impact condominium associations and homeowners’ associations.  Among the changes made was one that restricts the right of a homeowner’s association to implement rental restrictions applicable to properties subject to the association’s governing documents.

Before this new legislation, the only limit on rental restrictions in the Florida Statutes, which pertained to community associations, related to condominium associations; there was no such limitation for homeowners’ associations.  For a condominium association, the limit on rental restrictions, found in Section 718.110(13), Florida Statutes, provides as follows: “An amendment prohibiting unit owners from renting their units or altering the duration of the rental term or specifying or limiting the number of times unit owners are entitled to rent their units during a specified period applies only to unit owners who consent to the amendment and unit owners who acquire title to their units after the effective date of that amendment.”

However, effective July 1, 2021, a declaration or other governing document of a homeowners’ association that has more than 15 parcel owners, or an amendment to a declaration or other governing document of such a homeowners’ association, that contains a prohibition or regulation as to rental agreements, “applies only to a parcel owner who acquires title to the parcel after the effective date of the governing document or amendment, or to a parcel owner who consents, individually or through a representative, to the governing document or amendment”.  This new statutory provision will be reflected in a new subsection “(h)”, to be added to Section 720.306 of the Florida Statutes. 

While this language closely mirrors the language found in Section 718.110(13), Florida Statutes, there are certain differences. Section 718.110(13), Florida Statutes states that the rental restriction applies to condominium owners “who acquire title to their units after the effective date of that amendment” and to those “who consent to the amendment”.  In contrast, Section 720.306(1)(h), Florida Statutes, will provide that the rental restriction will apply to a parcel owner “who acquires title to the parcel after the effective date of the governing document or amendment” and to a parcel owner “who consents, individually or through a representative, to the governing document or amendment”.  It is unclear what is meant by the reference to an owner who “consents to the governing document” as no vote of the parcel owners is taken at the time a declaration (the governing document) is first adopted.  A vote of the parcel owners is only taken when a declaration is amended.        

The new section “(h)” added to Section 720.306 of the Florida Statutes will also clarify that a rental prohibition or regulation that does not apply to a current title holder (because that owner did not consent to the amendment) also will not apply to a subsequent title holder following certain “ownership changes”. In particular, the rental prohibition or regulation will not apply to an heir who acquires the title as a result of the prior owner’s death or where title is transferred from the prior owner to an entity affiliated with a prior owner. Instead, the prohibition or regulation will only apply once the heir or affiliated entity transfers title to another party.

There will be an exception to the rule of limited application (to successor owners or owners voting for the amendment) as to certain rental prohibitions or regulations for those restrictions that are put in place on or after July 1, 2021.  However, those exceptions are limited to: (a) rental restrictions that prohibit or regulate lease terms which are less than 6 months; and (b) rental restrictions that prohibit rentals of a parcel more than three times in a calendar year.  Those restrictions, once adopted into an association’s governing documents, will apply to all owners in the association regardless of when or how the owner’s title was acquired and regardless of how that owner voted as to an amendment adopting said restrictions.

Again, the restrictions will not apply to rental restrictions that are in place prior to July 1, 2021.  As a result, HOA governing documents or amendments that were recorded prior to July 1, 2021, and which contained prohibitions or regulations as to rental agreements, remain binding as to all owners, regardless of the nature of those prohibitions or regulations.

For guidance as to how to prepare a proposed amendment  to your HOA declaration that complies with the new HOA rental restrictions or for guidance on additional changes resulting from Florida SB 630, you can reach out to our association law team.

I. What is partition?
Partition is the legal mechanism to force the sale or division of real property owned by multiple parties.  If co-owners of real property are in disagreement about the sale of jointly owned real property, or if one owner is unfairly bearing the burden of taxes, insurance, and maintenance, the parties can request that a court order the property to be sold or divided.  This article will focus on the remedy of a forced sale, and not the less common remedy of division.

II. What is the Uniform Partition of Heirs Property Act, and who does it apply to?
Prior to the enactment of the Uniform Partition of Heirs Property Act (the “Act”) effective  July 1, 2020, there was only one available process to partition real property: one or more co-owners files a lawsuit against the other co-owners and asks the court to determine the rights of the parties (e.g., what percentage interest does each co-owner own; how much are they owed for reimbursement of taxes, insurance, and maintenance; etc.) and to order that the property be sold.  The court has broad discretion under these “standard” partition laws to fashion an appropriate remedy.  In a “standard” partition case, the court does not make a determination as to the value of the property; rather, the value is simply the highest and best offer to purchase the property at public auction.

The Act outlines a new additional procedure for partition actions filed after July 1, 2020, to the extent the property requested to be partitioned qualifies as “heirs property.”  The Act defines “heirs property” as real property held in tenancy in common and

  1. there is no agreement in a record binding all the co-owners which govern the partition of the property, and
  2. one or more of the co-owners acquired title from a relative, whether living or deceased, and
  3. either 20% of more of the interests are held by co-owners who are relatives, or 20% or more of the interests are held by an individual who acquired title from a relative, whether living or deceased, or 20% or more of the cotenants are relatives.

The court is required to determine whether the property to be partitioned constitutes “heirs property,” and if so, the Act will apply unless all co-owners agree otherwise.

III. New Procedures Under the Act
The biggest difference between the procedure implemented under the Act and a “standard” partition procedure is that, under the Act, the Court is required to make an adjudication as the value of the property and provide co-owners with the right to buy out the parties requesting partition by sale.  

Unless all co-owners have agreed to the value of the property, the court must order an appraisal unless it determines that the cost of an appraisal outweighs its evidentiary value. The court will appoint a disinterested real estate appraiser to determine the fair market value assuming sole ownership of the fee simple estate, and the appraiser will file a sworn appraisal with the court. Within 10 days of the appraisal being filed, the court is required to give notice to the parties with the appraised value and notify the parties they have the right to object within 30 days. Regardless of whether an objection is filed or not, the court is required to conduct a hearing 31 or more days after the notice of appraisal is sent to the parties, and may consider the appraisal and other evidence to make a final determination of the value of the property. At the hearing, the court will also determine any equitable accounting (i.e., how much each party may be owed for taxes, insurance, maintenance, etc.) and appropriately adjust any price, purchase price, apportioned price, buyout, judgment, or partition granted based on the results of the equitable accounting. The court is required to send another notice to the parties after the determination is made.

The court is also required to notify the parties that any co-owner except a co-owner that requested partition by sale may buy all the interests of the co-owners that requested partition by sale.  A co-owner has 45 days to advise the court that he or she elects to buy out the interests of the co-owner that requested partition by sale. If one or more co-owners elects to purchase other interests in the property, the court will appropriately allocate interests and values and provide notice to the parties.  Then the co-owner who wishes to buy out another co-owner will have 60 days to pay the apportioned buy-out price into the court registry. The court will then enter a judgment of partition reallocating all the interests of the co-owners and disburse the amounts held as appropriate.

If there is not a complete buyout of co-owners’ interests, the court will order a sale of the heirs property on the open-market, unless the court finds that a sale by sealed bids or auction would be more economically advantageous and is in the best interest of the co-owners as a group. Unless the parties can agree on a real estate broker within 10 days of the order of sale, the court will appoint a broker to offer the property for sale in a commercially reasonable manner at a price no lower than the value of the property as determined by the court. The Act provides specific rules and notice procedures concerning any offers for purchase that are obtained by the broker.  Note that an existing co-owner may be the purchaser of the entire property and that purchaser is entitled to a credit against the price in an amount equal to his or her share of the proceeds.

IV. Attorneys’ Fees
Although the provisions in the Act do not expressly discuss the right to recover attorneys’ fees from the parties (either through judgment or from the net proceeds of the sale of the property), the Act incorporates the provisions of the “standard” partition laws to the extent they do not conflict with the Act. Thus, a strong argument could be made that recovery of attorneys’ fees is still available in an action to partition heirs property.

If you have questions about the Uniform Partition of Heirs Property Act, please contact our Fiduciary Litigation team to learn more.

What is Probate?

Probate is the court-supervised process for collecting the assets of an individual who has passed away (the “Decedent”), notifying creditors, paying the Decedent’s debts pursuant to law, and distributing the Decedent’s assets to their beneficiaries.  There are two different types of Florida probate administrations: formal administration and summary administration.  There are also four different types of non-court-supervised procedures that may allow you to avoid opening a formal or summary probate administration: disposition without administration, income tax refunds, payment to successor without court proceedings, and disposition without administration of intestate property in small estates.  Each of these methods have different advantages and only apply in limited circumstances.  

Issue Number 1 – Locating the Decedent’s Will.

A will is a document in which the Decedent names who they want to receive their probate assets.  The Decedent’s will may also name who they would like to nominate as personal representative.  In Florida, a personal representative is the individual who is appointed by the Court to administer the probate estate (also known as an executrix or administrator in other jurisdictions).

Once the Decedent’s original will is located, it needs to be filed with the Court in the county in which the Decedent was domiciled.  Under Florida law, the individual in possession of the Decedent’s will must deposit or file the will within 10 days of learning of the Decedent’s death.

What happens if you cannot find the Decedent’s original will?  There is a process in the Florida probate administration that allows a party to establish and probate the Decedent’s lost or destroyed will.

What happens if the Decedent did not have a will?  Someone who dies without a valid will dies “intestate.”  If the Decedent dies intestate, Florida Statutes list who is a beneficiary of the Decedent’s estate and how the Decedent’s Florida probate assets will be distributed.

Issue Number 2 – Determining Whether a Florida Probate Estate Should Be Opened.

The main considerations in determining whether a probate estate should be opened include:

A. Are There Probate Assets?

Not all of the Decedent’s assets are included in the probate estate, and many people develop estate plans to avoid the probate process.  The most common probate assets include:

  1. Bank account in the Decedent’s name alone with no payable on death beneficiaries;
  2. Life insurance policy, annuity, or individual retirement account payable to the Decedent’s estate or having no beneficiaries;
  3. Vehicle titled in the Decedent’s name alone;
  4. Real property titled in the Decedent’s name alone or as tenants in common; and
  5. Tangible personal property of the Decedent;
  6. Decedent’s homestead.

B. Does the Decedent’s Debt Outweigh the Probate Assets?

If the Decedent’s debt outweighs their probate assets, you may want to wait 2 years from the date of death to open the probate estate.  Florida’s probate process provides creditors with the means to file a claim against the Decedent’s estate and, if their claim is valid, the creditor will need to be paid before the probate assets are distributed to the Decedent’s beneficiaries.  However, all creditors must file their claims against the Decedent’s estate within two years of the Decedent’s death.  If a creditor fails to file their claim within this timeframe, the Decedent’s estate will not be required to pay them.  In addition, certain assets may be exempt from the claims of creditors.

Issue Number 3 – Locating Probate Assets.

Once a personal representative is appointed for the Decedent’s estate, the personal representative must locate all of the Decedent’s probate assets and list them in what is referred to as the Inventory.  The Inventory is a document informing the Court and the beneficiaries of all the Decedent’s probate assets and their approximate value.  There are many circumstances where probate assets may be difficult to find.  A skillful attorney can take advantage of legal tools to efficiently locate bank accounts, real property, tangible assets, and digital assets that the Decedent may have left behind. 

Issue Number 4 – Homestead.

In Florida, homestead property is granted certain protections by the Florida Constitution.  One major protection is that property determined to be homestead by the Court may be exempt from creditors’ claims.  This means that creditors cannot force certain beneficiaries to sell the home, or use proceeds from the sale of the home, to pay the creditors’ claims against the Decedent’s estate.  To receive Florida’s homestead protections, the Court must issue an Order determining the homestead status of the real property.

Bonus Issue – Taxes.

As Benjamin Franklin once wrote, “in this world nothing can be said to be certain, except death and taxes.” Benjamin Franklin, in a letter to Jean-Baptiste Le Roy, 1789.

Even in the event of death, the Decedent’s estate is still responsible to pay for various taxes that were owed by the Decedent, or that may subsequently be owed by the Decedent’s estate.  By accepting the position as personal representative, a personal representative assumes certain hidden liabilities in which the Internal Revenue Service or the State of Florida may collect taxes from the personal representative’s personal assets if the Decedent’s taxes are not paid properly.  Because of this assumption of risk, it is important for a personal representative to work closely with an experienced Florida probate attorney to ensure that they do not become personally liable for any of the Decedent’s taxes.

If you have questions about the probate process, contact the attorneys on our estate planning & probate team.

In an important decision issued April 7, 2021, the United States Court of Appeals for the 11th Circuit – which covers Alabama, Florida and Georgia – reversed a lower court decision and ruled that Winn Dixie’s website does not violate the Americans With Disabilities Act (“ADA”) with respect to its use by visually impaired people.

The Plaintiff in the lawsuit, Juan Gil, is legally blind and was a long-time Winn Dixie shopper.  He found that Winn Dixie’s website would not function with his screen-reading technology.  The website’s primary functions were to re-fill existing prescriptions for in-store pick-up and to link digital manufacturer coupons to the customer’s Winn Dixie rewards card so that the coupons are applied automatically upon check-out.  Gil obtained a summary judgment against Winn Dixie in the District Court for the Southern District of Florida, which held that since its website was incompatible with screen-reader software, Winn Dixie violated the ADA.  The District Court issued an injunction requiring Winn Dixie to make its website accessible to individuals with disabilities, specifically by conforming its website to the Web Content Accessibility Guidelines 2.0, and ordered other related relief.

In a 2-1 decision, a panel of the Atlanta-based Appeals Court ruled, first, that websites themselves – even if conjoined with a business that has brick and mortar facilities – is not a “public accommodation” under the ADA.  On this first issue, it disagreed with rulings of other circuit courts of appeal.

Second, the 11th Circuit declined to hold that a company website may provide a “nexus” to its brick and mortar facilities so as to be viewed as part and parcel of the same, at least under the facts of this case, so as to require that the website afford accessibility to the visually impaired under the ADA.

Last, the Court held that Winn Dixie’s website did not otherwise violate the ADA by presenting “intangible barriers” to the “equal access to the services, privileges and advantages of Winn Dixie’s physical stores”, which are places of public accommodation.  In reaching this, the Court emphasized that Winn Dixie’s website has only limited functionality and, most importantly, did not function as or allow points of sale.  The chief advantages of the website were that it allowed the refill of prescriptions (which still needed to be picked up in the store) and also allowed manufacturer coupons to be put on a Winn Dixie shopping card (although the redemption of such coupons still had to happen within a Winn Dixie store).  Gil’s inability to access these features, while sighted customers or users could, did not translate into an ADA violation. The Court distinguished other cases where sales actually occurred through the company website, and thus it may reach a different decision if presented with those facts.

As indicated above, the 11th Circuit decision is at odds with decisions of other circuit courts of appeal, thus setting up a conflict in the law which can only be resolved by the United States Supreme Court.  Until the same occurs, jurisdiction and venue (that is, the court and location where the action is held) will be extremely important to, if not determinative of, the outcomes in these cases.

ShuffieldLowman stands ready to assist companies and clients with respect to issues that may arise from ADA website compliance. For additional questions on ADA website accessibility, please contact our commercial and civil litigation or corporate law teams. Visit our contact page here

On March 17, the IRS  announced in Notice 2021-21, that the deadline for  filing your 2020 income tax return was extended, together with payment of any 2020 taxes, to May 17, 2021.

However, it also stated that it only applied to 2020 taxes, meaning that any filings or payments for the current  tax year, 2021, remain in place. According, the first estimated income tax payment for 2021 remains due on April 15, 2021.

On March 31, the IRS issued Notice 2021-67 which extends other deadlines relating to 2020, to May 17. These include contributions to IRAs and health savings accounts, claims for refunds and other matters. It should be reviewed to see if any of these extensions apply to you. They can be found at www.IRS.gov.

Notably, nothing contained in this notice changed the April 15 deadline for 2021 estimated taxes. Accordingly, if you are an individual required to make estimated tax payments, your first installment remains due on April 15.

If you need tax advice our tax attorneys can help. Visit our tax advice and controversy page to learn more. 

 

In Florida, there are a variety of deeds that serve to convey title to a property. The main difference between these types of deeds is the extent to which the seller promises or covenants certain facts with respect to the status of the property. Therefore, the type of deed which is executed impacts the level of protection the buyer receives. It is important to understand these differences to ensure the appropriate deed is executed based on each specific situation. From the most covenants to the least, the following is a brief discussion on general warranty deeds, special warranty deeds, and quitclaim deeds.

 

GENERAL WARRANTY DEED

This type of deed provides the buyer the highest level of protection because it contains covenants that certain facts are true. The following are the covenants of title contained within a general warranty deed:

Notably, these covenants are given by the seller on behalf of all the prior owners of the property.

 

SPECIAL WARRANTY DEED

This deed provides less protection to the buyer than a general warranty deed. Although a special warranty deed contains the same covenants as a general warranty deed the covenants only apply to the period of time in which the seller owned the property.

 

QUITCLAIM DEED

This deed conveys the property without the grantor providing any covenants, including whether the grantor has an ownership interest in the property at all. As this deed provides the least amount of protection for the grantee, it is typically used to transfer ownership between parties that have a prior relationship. Quitclaim deeds are commonly used to convey property to family members, to a revocable living trust, to a former spouse as part of a divorce settlement, and to a business entity.  They are also frequently used to cure title defects, such as to correct a scrivener’s error in the legal description of a property.

 

 

ShuffieldLowman’s real estate and banking & finance legal teams are here to help answer your questions regarding deeds and which one works best for your particular needs. For more information, visit our contact page HERE.

In honor of Women’s History Month, we are spotlighting our female attorneys throughout March. Today’s insights on what it means to be a woman in law are from Carleen Leffler-Nicastro. 

1. What do you love about law?
I love the peace of mind that the law can give to individuals. That sense of peace you have when you finally have an estate plan in place or finally have a solution to an ongoing problem.

2. What advice would you give the next generation of female lawyers?
Never give up. A cliché, I know, but female lawyers will hit roadblock after roadblock in their path to become a lawyer and then, again, in their path to be a successful lawyer. This is still a very male dominated field, but there a lot of successful female attorneys that are willing to lend a hand…. accept that hand. Also, don’t feel like you have to prove why you belong in the room. You earned it, wear it like a badge of honor.

3. Who inspires (or inspired) you and why? 
I am inspired almost daily by different individuals. My grandfather and uncle initially inspired me to be a lawyer. My stubbornness and pride inspired me to stick with it and not quit. My father and mother inspired me to have a good work ethic. The attorney in the office next to mine inspires me to work harder. My clients inspire me to continue learning. Finding inspiration in everyday life is what keeps me going.

Learn more about Carleen by visiting her attorney page.

 

Nicole CopsidasIn honor of Women’s History Month, we are spotlighting our female attorneys throughout March. Today’s insights on what it means to be a woman in law come from Associate Nicole Copsidas

1. What do you love about the legal field?
As a litigator, I enjoy the intellectual challenges that come with helping people resolve conflicts in a meaningful way.

2. What advice would you give the next generation of female lawyers?
Message to female lawyers (especially younger ones): Do not let self-doubt stand in the way of your success and do not be intimidated to share your ideas at a table full of men.

3. Who inspires (or inspired) you and why? 
Ruth Bader Ginsburg.  I admire her ability to lead with passion in a dignified manner.

Learn more about Nicole by visiting her attorney page