The Third District Court of Appeal in Florida has ruled in favor of Sasha Investments LLC, a judgment creditor, in a case against Staghorn Development LLC and others. The court's decision, issued on June 10, 2026, addresses the rights of creditors to obtain information about debtors' assets. This ruling is significant for creditors seeking to enforce judgments and for law firms involved in asset recovery.

The case, titled Sasha Investments LLC v. Staghorn Development LLC, stems from a multi-million-dollar default final judgment. The ruling affects not only the parties involved but also sets a precedent for future discovery disputes in similar cases.

Background

Sasha Investments LLC, a Missouri limited liability company, filed an eleven-count complaint in late 2023 against Staghorn Development LLC, 452 NLB LLC, and individuals John Lemkey and Mike Mallory. The defendants hired the law firm Sokolof Remtulla LLP to represent them. However, after entering a settlement agreement, the defendants failed to make the required payments, leading to a default judgment against them on April 2, 2025.

Following the judgment, the trial court ordered the defendants to complete a fact information sheet within 45 days. When they failed to comply, the court found them in civil contempt. Sasha Investments then sought documents from Sokolof Remtulla LLP, the defendants' former law firm, to aid in collecting the judgment. The law firm, however, moved to quash the subpoena, claiming attorney-client privilege and arguing that an in-camera review was necessary.

The Ruling

The Third District Court of Appeal, with Judge Miller writing the opinion, granted Sasha Investments' petition for a writ of certiorari. The court ruled that the lower court's orders shielding the law firm from producing documents constituted a departure from the essential requirements of law. The court stated, "the absence of an in-camera review precludes judicial oversight and the denial of relevant discovery, in turn, effectively precludes it from collecting on its judgment."

The court emphasized that the judgment creditor has broad rights to discover any assets the debtor might have that could satisfy the judgment. The ruling clarified that asset-related information held by a law firm is not automatically protected by attorney-client privilege. The court noted, "Asset-related information in the possession of a law firm is not automatically shielded by attorney-client privilege," allowing creditors to seek necessary information from non-parties.

Impact

This ruling has significant implications for judgment creditors in Florida. It reinforces the right of creditors to pursue discovery from third parties, such as law firms, to uncover assets that may be used to satisfy a judgment. The court's decision indicates that the privilege does not extend to asset-related information, which is crucial for creditors trying to recover debts.

Moreover, the ruling sets a precedent for how courts handle discovery disputes involving non-party law firms. The court's insistence on judicial oversight through in-camera reviews ensures that claims of privilege are not misused to obstruct legitimate discovery efforts. This decision could encourage more aggressive asset recovery efforts by creditors in similar situations.

What's Next

The law firm involved in the case may seek to appeal the court's ruling. While the court has granted the petition to quash the lower court's orders, the law firm retains the right to challenge the decision through appropriate legal channels. Details were not available in the court filing regarding any pending related cases.