The Florida Third District Court of Appeal upheld four separate orders removing Kerrin Friedman as personal representative of Bonny L. Wax's estate and trustee of three family trusts. Friedman had been explicitly instructed in 2025 to retain counsel because non-lawyer trustees litigating on behalf of a trust violate state rules. Instead of hiring an attorney, she persistently filed documents and appeared pro se across state, federal, and appellate courts, triggering her formal dismissal. The appellate panel determined that these continuous violations constituted valid grounds for removal and rejected her due process challenges.
Key points
Non-lawyer trustees who represent a trust in court proceedings commit the unauthorized pr…: Non-lawyer trustees who represent a trust in court proceedings commit the unauthorized practice of law under Florida statutes.
Florida courts maintain the statutory authority to remove personal representatives who ac…: Florida courts maintain the statutory authority to remove personal representatives who actively violate established judicial mandates.
Fiduciaries facing removal receive adequate due process when provided with appropriate no…: Fiduciaries facing removal receive adequate due process when provided with appropriate notice and an opportunity to be heard.
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Managing a deceased parent's estate and family trusts can involve complex legal responsibilities, particularly when disagreements arise among beneficiaries. A Florida daughter who continued representing her late mother's estate and three family trusts in court without a lawyer has now lost all four positions after an appeals court upheld her removal, finding that her actions violated established legal requirements.
In a November 12, 2026,
decision, the Florida Third District Court of Appeal affirmed four removal orders against Kerrin Friedman. The rulings removed her as personal representative of her mother Bonny L Wax's estate and as trustee of three family trusts. In Kerrin Friedman v. In Re: Estate of Bonny L Wax, available on Justia, the appeals court rejected her arguments that the probate court lacked authority to remove her and had denied her due process.
Daughter continued representing estate without a lawyer
The dispute involved four separate probate and trust proceedings in Miami-Dade County. Friedman was appointed personal representative of her late mother's estate and also served as trustee of three trusts connected to her siblings: the Bobbi Ring Trust,…
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