Investigation of Former Professional Guardian Traci Hudson Report

DIVISION OF INSPECTOR GENERAL
Ken Burke, CPA

Clerk of the Circuit Court and Comptroller
Pinellas County, Florida
INVESTIGATION OF FORMER PROFESSIONAL

GUARDIAN TRACI HUDSON
Melissa Dondero, CPA, CIA, CIG, CIGA, CIGI, CITP, CRMA, CFS, CECFE
Inspector General/Chief Audit Executive
Investigative Team
Ava Sadowska, CIA, CIG, CIGA, CIGI, CFE, CFS, CECFE, CCA – Assistant Inspector General
James Nassiri, CIGI, CIGA, CECFE – Inspector General II
Jason Steckle, CIGI, CFE, CECFE – Inspector General II
Alan Weistock – Inspector General II
Lori Scott – Inspector General I
REPORT NO. 2022-20
NOVEMBER 10, 2022
Ken Burke, CPA
CLERK OF THE CIRCUIT COURT AND COMPTROLLER
PINELLAS COUNTY, FLORIDA
Division of Inspector General
510 Bay Avenue
Clerk of the County Court Clearwater, FL 33756
Recorder of Deeds Telephone: (727) 464-8371
Clerk and Accountant of the Board of County Commissioners Fax: (727) 464-8386
Custodian of County Funds Fraud Hotline: (727) 45FRAUD (453-7283)
County Auditor Clerk’s website: www.mypinellasclerk.org
November 10, 2022
Honorable Judge Pamela Campbell, Florida Sixth Judicial Circuit Court

Honorable Judge James Stearns, Florida Sixth Judicial Circuit Court
The Division of Inspector General’s Public Integrity Unit has completed an investigation of Traci
Bryanton Hudson (Hudson), also known as Traci Samuel, a former professional guardian (former
guardian). The investigation encompassed a complete review of 45 guardianship cases
assigned to Hudson during her tenure as a professional guardian from March 2, 2016, to
November 19, 2019.
The Florida Sixth Judicial Circuit Court, Probate and Guardianship Division (Court), had
concerns about the care and well-being of the person and property of Persons Subject to
Guardianship (PSTG), and appointed the IG:
“To investigate the actions of the former guardian, Traci Hudson AKA Traci Samuel
concerning the ward’s finances, medical care, and any other issue that affects the
ward’s welfare and best interests.”
This investigative report is a summary of a comprehensive examination of the 45 guardianship

cases assigned to Hudson. The allegation that Hudson’s actions resulted in misuse of the
PSTGs’ finances and affected the PSTGs’ welfare and best interests was Substantiated.
To determine whether the Court concerns were substantiated, we analyzed over 2,000
guardianship documents, including court and bank records, and interviewed parties with
knowledge of the facts.
Our investigation was performed according to the Principles and Standards for Offices of
Inspector General and The Florida Inspectors General Standards Manual from the Commission
for Florida Law Enforcement Accreditation.
Honorable Judge Pamela Campbell, Florida Sixth Judicial Circuit Court
Honorable Judge James Stearns, Florida Sixth Judicial Circuit Court
November 10, 2022
The Division of Inspector General uses the following terminology for the conclusion of
fact/finding(s):
• Substantiated – An allegation is substantiated when there is sufficient evidence to justify

a reasonable conclusion that the allegation is true.
• Unsubstantiated – An allegation is unsubstantiated when there is insufficient evidence
to either prove or disprove the allegation.
• Unfounded – An allegation is unfounded when it is proved to be false or there is no
credible evidence to support it.
We appreciate the cooperation shown by the successor guardians and all other individuals we
contacted during the course of this investigation.
Respectfully Submitted,
Melissa Dondero
Inspector General/Chief Audit Executive
cc: Honorable Judge Sherwood Coleman, Florida Sixth Judicial Circuit

Keela Samis, General Magistrate, Florida Sixth Judicial Circuit Court, Probate, and
Guardianship Division
Bama Tearney, General Magistrate, Florida Sixth Judicial Circuit Court, Probate, and
Guardianship Division
Ken Burke, CPA, Clerk of the Circuit Court and Comptroller
TABLE OF CONTENTS
INTRODUCTION 5
Abbreviations 5
Background 7
Allegation 16
Investigative Activity 16
TIMELINE OF EVENTS 18
INVESTIGATIVE CONCLUSIONS 20
INVESTIGATIVE CONCLUSIONS DETAILS 26
1. Guardian Submitted Altered Documents To The Court. 26

2. PSTG’s U.S. Savings Bonds Are Unaccounted For. 28
3. Guardian Commingled PSTG’s Funds With Her Personal Funds And Deprived The 29
PSTG Of Money.
4. PSTGs’ Jewelry Is Missing And Unaccounted For. 30
5. Guardian Overcharged The PSTGs For Time Worked. 32
6. Guardian Did Not Comply With Court Orders. 38
7. Guardian Did Not Responsibly Manage PSTGs’ Finances. 41
8. Guardian Mismanaged PSTGs’ Funeral Arrangements. 42
9. Guardian Did Not Resolve Code Enforcement Violations Which Resulted In Lien 44
Against A PSTG’s Property.
10. Guardian Paid Unusually High Sales Commissions From PSTGs’ Funds. 46
11. Guardian Abandoned PSTGs’ Mail At A UPS PO Box And At A PSTG’s Residence. 49
12. Guardian Employed Her Daughter To Perform Caregiver Services For The PSTGs 51
Without Disclosure And Approval From The Court.
13. Guardian Signed Affidavits That Designated Her As Power Of Attorney For PSTGs. 53
14. Guardian Did Not Deliver PSTG’s Will To The Successor Guardian. 54
15. Guardian Did Not File A Final Accounting And Trust Accountings. 54
16. Guardian Did Not Maintain 1099 Tax Forms in the PSTGs’ Records. 55
OBSERVATIONS 57
1. Guardian Did Not Maintain Clear And Accurate Guardianship Records. 57

2. PSTG’s Personal Property Value Was Not Listed In The Verified Initial Inventory And 60
Final Accounting.
3. Guardian Spent PSTG’s Limited Funds On Potentially Redundant Services. 61
4. Guardian Used Her Daughter’s Notary Service To Notarize Various Guardianship- 62
Related Documents.
5. Guardian Did Not Protect And Preserve PSTG’s Assets. 63
6. Guardian Was Not Involved In Consent To PSTG’s Medical Procedures. 63
7. Guardian Sold PSTGs’ Properties Below Market Value. 66
8. Guardian Did Not Comply With Order To Vacate. 72
9. Guardian Did Not Pay Off Credit Card Debt As Ordered By Court. 73
10. Guardian Did Not Explain Her Disagreement With A Medical Provider’s Opinion On 74
The PSTGs Capacity.
INTRODUCTION
Abbreviations
AACT Annual Accounting
AAR Adult Advocacy & Representation, Inc.
Court Florida Sixth Judicial Circuit Court, Probate and Guardianship Division
DFCCS Division of Funeral, Cemetery, and Consumer Services
DFS Florida Department of Financial Services
Dr. Doctor
ETG Emergency Temporary Guardianship
FAC Florida Administrative Code
FACT Final Accounting
FFC Florida Family Cremations, Incorporated
FGSI Florida Guardianship Services, Incorporated

Fla. Stat. Florida Statutes
FRS Florida Retirement System
GAPC Guardian Association of Pinellas County
GDN Guardianship
HUD Housing and Urban Development
Pinellas County Clerk of the Circuit Court and Comptroller Division of
IG
Inspector General
IRS Internal Revenue Service
LLC Limited Liability Company
MLS Multiple Listing Service
Florida Department of Elder Affairs, Office of Public and Professional
OPPG
Guardians
Public Integrity Unit, Division of Inspector General

Page 5
Introduction
Investigation of Former Professional Guardian Traci Hudson
PCPA Pinellas County Property Appraiser

PCSO Pinellas County Sheriff’s Office
PO Box Post Office Box
PSTG Person Subject to Guardianship
RIJ Right Internal Jugular
SAO Office of The State Attorney Sixth Judicial Circuit of Florida
SSA Social Security Administration
Sq. ft. Square Foot
UPS United Parcel Service
U.S. United States
VA OIG U.S. Department of Veterans’ Affairs Office of Inspector General

Page 6
Introduction
Background
Florida Guardianship
A guardianship is a legal proceeding where a court appoints a guardian to exercise the legal
rights of an incapacitated person. Guardianship is a last resort option for protecting at-risk
incapacitated persons who are most often elders. Guardianship is appropriate when there are
no other less restrictive options available.
Florida law allows both voluntary and involuntary guardianships. A voluntary guardianship may
be established for an adult who, though mentally competent, is incapable of managing his or her
own estate and who voluntarily petitions the court for the appointment of a guardian. An
involuntary guardianship may be established when the court declares an individual too impaired
to make decisions and grants the right to make decisions to another person.
In the case of a person with developmental disabilities, the court may appoint a guardian
advocate without an adjudication of incapacity. Such action may be taken if the person lacks the
decision-making ability to do some, but not all, of the decision-making tasks necessary to care
for themselves or property. In addition, the person may voluntarily petition for the appointment
of a guardian advocate.
§ 744.3215, Florida Statutes (Fla. Stat.) (2017), lists the delegable and non-delegable legal
rights which the court may remove from a person deemed incapacitated:
“(2) Rights that may be removed from a person by an order determining incapacity
but not delegated to a guardian include the right:
(a) To marry. If the right to enter into a contract has been removed, the right
to marry is subject to court approval.
(b) To vote.
(c) To personally apply for government benefits.
(d) To have a driver license.
(e) To travel.
(f) To seek or retain employment.
(3) Rights that may be removed from a person by an order determining incapacity
and which may be delegated to the guardian include the right:
(a) To contract.
(b) To sue and defend lawsuits.
(c) To apply for government benefits.
(d) To manage property or to make any gift or disposition of property.
(e) To determine his or her residence.
(f) To consent to medical and mental health treatment.
(g) To make decisions about his or her social environment or other social
aspects of his or her life.”

Page 7
Introduction
A guardian is a substitute decision-maker appointed by the court to make either personal and/or
financial decisions for an adult with mental or physical disabilities, or a minor, whose assets must
be managed by an adult. This fiduciary relationship is based on trust in which the guardian acting
in a fiduciary capacity must act in the best interest of those they serve. The court refers to a
Person Subject to Guardianship* (PSTG) as a “Ward.”
§ 744.361, Fla. Stat. (2015), delineates the powers and duties of a guardian, including:
“(1) The guardian of an incapacitated person is a fiduciary and may exercise only
those rights that have been removed from the ward and delegated to the guardian.
The guardian of a minor shall exercise the powers of a plenary guardian.
(2) The guardian shall act within the scope of the authority granted by the court
and as provided by law.
(3) The guardian shall act in good faith.
(4) A guardian may not act in a manner that is contrary to the ward’s best interests
under the circumstances….
(10) A guardian who is given authority over any property of the ward shall:
(a) Protect and preserve the property and invest it prudently… and keep
clear, distinct, and accurate records of the administration of the ward’s
property.
(b) Perform all other duties required of him or her by law.
(c) At the termination of the guardianship, deliver the property of the ward
to the person lawfully entitled to it.
(11) The guardian shall observe the standards in dealing with the guardianship
property that would be observed by a prudent person dealing with the property of
another.”
The Florida Probate Code Manual § 20.01 (2022), states:
“Guardians have a legal right and duty to protect their wards. A guardian is charged
with protecting the ward’s interest by managing the ward’s property or caring for
his person or both.”
*Pursuant to §744.102(22), Fla Stat. “ward” means a person for whom a guardian has been appointed. The term “ward” is antiquated and
considered derogatory, demeaning, and pejorative by many advocates throughout the country. Pinellas County Division of Inspector General
serves to protect the dignity and rights of persons who are incapacitated. Therefore, following best practices in guardianship, the Division of
Inspector General is using person centered language such as person subject to guardianship (PSTG) except when quoting or referencing Florida
Statutes, court documents, or other legal records containing the term “ward.”

Page 8
Introduction
A guardian who serves three or more PSTGs at any given time is a professional guardian.
Professional guardians must be registered with the Department of Elder Affairs, Office of Public
and Professional Guardians (OPPG), pass a criminal background check and fulfill bond and
educational requirements.
Florida law recognizes two categories of guardianship: plenary and limited adult guardianships.
In a plenary guardianship, a guardian is appointed to exercise all delegable legal rights and
powers of the PSTG once the court declares an individual incapacitated and unable to care for
themselves.
In a limited guardianship, a guardian is appointed when the court finds an individual lacks the
capacity to perform some, but not all, tasks necessary to care for their person or property and if
the individual does not have pre-planned, written instructions for all aspects of their life.
All adult, disabled, and minor guardianships are subject to court oversight. Chapter 744, Fla.
Stat., Florida Administrative Code 58M-2, and Part III of the Florida Probate Rules provide the
legal authority for guardianship and delineate duties and obligations of guardians, attorneys, the
court, and clerks, to ensure all parties act in the best interest of the PSTG.
Hudson’s Guardianship Business
On March 2, 2016, Traci Samuel also known as Traci Hudson (Hudson) (now known as Traci
Bryanton), became a professional guardian registered in Florida through the OPPG.
Hudson incorporated and registered Florida Guardianship Services, Incorporated (FGSI)

effective March 7, 2016. Hudson was the FGSI president, and Vernon Hudson II (who later
became her husband on August 25, 2018) was the vice president of this for-profit corporation.
As of November 19, 2019, FGSI occupied an office at 5030 78th Avenue North, Suite 8, in Saint
Petersburg, Florida. Hudson maintained a business Post Office Box (PO Box) 6500 at a United
Parcel Service (UPS) store at 4905 34th Street S. in Saint Petersburg, Florida, where she
received guardianship-related mail. The following staff worked at Hudson’s business:
1. Baylie Barber also known as Baylie Dressman (Barber), Hudson’s daughter

2. Stephanie Barnes
3. Jaclyn Gonzales
4. Talia Hudson (Vernon Hudson’s daughter)
5. Alecia Lyons
6. Laine Quattrocki
Chart 1 illustrates Hudson’s assistants’ earnings paid from PSTGs’ assets while employed at
FGSI.

Page 9
Introduction
Chart 1 - Total Disbursements to Hudson’s Assistants from PSTGs’ Assets
During the course of her business, Hudson frequently cooperated with the following individuals
and businesses:
• Keith Crosby (Crosby), Tax Preparer, West Coast Accounting and Financial Services,
Incorporated (Tax Services)
• David Menneke (Menneke), Funeral Director, Florida Family Cremations, Incorporated
(FFC), Former Guardian Association of Pinellas County (GAPC) Board Member (Funeral
Services)
• Antwan Shirley (Independent Contractor, Moving and Cleaning Services)
• Denise Povolish, Realtor, Luxury & Beach Realty, Former GAPC Board Member (Real
Estate Services)
• Quyen Trujillo, Realtor, Future Home Realty, formerly Charles Rutenberg Realty, Former
GAPC Board Member (Real Estate Services)
• Dale Smrekar, Appraiser, President, Downsizing Advisory Services (Personal Property
Appraisal Services)
• Dave Simpson, Appraiser, Owner of Bay Area Estate Sales and Services (Personal
Property Appraisal Services)
• Deeb Elder Law, P.A. (Florida Elder Law Attorneys)
• Nicolas Robinson, Esq. (Florida Elder Law Attorney)
• Hitchcock Law Group (Florida Elder Law Attorneys)

Page 10
Introduction
Statistical Snapshot of Hudson’s Guardianships
During Hudson’s tenure as a professional guardian, between March 2, 2016, and November 19,
2019, she was responsible for 45 guardianship cases in Pinellas County and Pasco County, with
a total initial asset value of $14,107,316.01, as reported in the PSTGs’ Verified Initial Inventories
to the Court.
Out of 45 guardianships, Hudson petitioned for her own appointment in 27 cases which, at that
time, was legally permissible. The breakdown of the types of Hudson’s guardianships is as
follows:
• 29 Plenary
• 13 Limited (including one limited to property only)
• 2 Guardian Advocate
• 1 Voluntary
Of the 45 cases, 5 were considered pro bono, meaning Hudson was not paid for the work she
performed during the guardianship.

Page 11
Introduction
Table 1 below lists all the PSTGs referenced in this report and their corresponding guardianship
case numbers. PSTGs are referred to by number rather than by name in this report.
Hudson's Guardianship Case List Hudson's Guardianship Case List

PSTG Case Number PSTG Case Number
PSTG 1 18-008218GD PSTG 23 2017-GA-000049
PSTG 2 16-004826GD PSTG 24 2017-GA-000043
PSTG 3 16-003908GD PSTG 25 19-011896GD
PSTG 4 02-003578GD PSTG 26 19-007053GD
PSTG 5 17-000320GD PSTG 27 18-006230GD
PSTG 6 18-011516GD PSTG 28 16-010362GD
PSTG 7 18-011518GD PSTG 29 17-010886GD
PSTG 8 18-000832GD PSTG 30 2005-GA-000062
PSTG 9 16-003688GD PSTG 31 2016-GA-000133
PSTG 10 17-002687GD PSTG 32 18-001065GD
PSTG 11 17-000275GD PSTG 33 18-005290GD
PSTG 12 19-001068GD PSTG 34 18-001327GD
PSTG 13 17-003866GD PSTG 35 17-004765GD
PSTG 14 19-008647GD PSTG 36 17-001845GD
PSTG 15 17-000110GD PSTG 37 17-003951GD
PSTG 16 17-008286GD PSTG 38 16-004952GD
PSTG 17 17-005688GD PSTG 39 17-000933GD
PSTG 18 07-000116GD PSTG 40 18-006272GD
PSTG 19 16-005655GD PSTG 41 16-010811GD
PSTG 20 18-000736GD PSTG 42 16-003317GD
PSTG 21 17-001275GD PSTG 43 18-007375GD
PSTG 22 17-001279GD PSTG 44 18-001263GD
PSTG 45 18-004732GD
Table 1 - List of PSTGs with the Corresponding Guardianship Case Numbers
Table 2 includes the length of each guardianship under Hudson, the amount of guardianship
fees paid to Hudson, and the amount of attorney fees paid to each guardianship attorney from
the PSTG’s assets. Please note, in some cases guardian fees and/or attorney fees were not
paid due to PSTG indigency or other circumstances and are indicated in the table with $0.

Page 12
Introduction
Length of
Guardianship Guardian Attorney
PSTG in Days Fees Paid Fees Paid
PSTG 1 433 $5,730.00 $28,518.49
PSTG 2 402 $0.00 $0.00
PSTG 3 822 $6,062.00 $4,907.50
PSTG 4 621 $10,344.00 $7,530.02
PSTG 5 655 $3,200.00 $0.00
PSTG 6 223 $0.00 $0.00
PSTG 7 218 $0.00 $0.00
PSTG 8 579 $14,064.00 $130,969.00
PSTG 9 1286 $22,242.00 $31,250.30
PSTG 10 963 $12,608.00 $14,667.98
PSTG 11 189 $1,375.00 $1,500.00
PSTG 12 193 $3,954.00 $10,283.09
PSTG 13 923 $12,020.56 $16,503.18
PSTG 14 40 $0.00 $0.00
PSTG 15 1007 $23,368.05 $31,477.32
PSTG 16 748 $0.00 $0.00
PSTG 17 831 $15,396.00 $15,192.53
PSTG 18 449 $2,136.00 $5,346.72
PSTG 19 1071 $5,945.00 $5,374.69
PSTG 20 572 $0.00 $0.00
PSTG 21 219 $0.00 $0.00
PSTG 22 1007 $21,418.79 $15,665.31
PSTG 23 952 $4,512.00 $5,258.34
PSTG 24 238 $5,325 $11,040
PSTG 25 666 $41,904.92 $237,646.37
PSTG 26 84 $0.00 $0.00
PSTG 27 466 $5,376.00 $18,569.00
PSTG 28 1198 $27,447.51 $16,964.30
PSTG 29 21 $3,390.00 $17,001.00
PSTG 30 477 $0.00 $0.00
PSTG 31 339 $8,365.00 $5,566.70
PSTG 32 629 $15,970.00 $15,802.14
PSTG 33 497 $7,884.00 $5,571.75
PSTG 34 597 $8,520.00 $17,628.10
PSTG 35 865 $17,070.00 $13,580.00
PSTG 36 1084 $19,594.20 $14,738.37
PSTG 37 923 $12,981.00 $13,105.50
PSTG 38 1014 $18,852 $18,381.59
PSTG 39 1015 $19,892.00 $12,716.70
PSTG 40 394 $0.00 $0.00
PSTG 41 664 $5,976.83 $7,669.44
PSTG 42 427 $2,943 $0.00
PSTG 43 176 $0.00 $0.00
PSTG 44 644 $12,936 $17,506
PSTG 45 543 $8,190.00 $11,343.22
TOTAL 27,364 $406,992.86 $779,274.79
Table 2 - Length of Guardianships and Fees Paid

Page 13
Introduction
Based on the information presented in Table 2, the IG Investigators calculated an average length
of guardianship under Hudson was 608 days and average guardian fees paid were $9,044.29.
Chart 2 below represents the PSTG’s Verified Initial Inventory of assets and the Final Accounting
(FACT) of the PSTG’s assets Hudson reported to the Court for each of the 45 guardianships.
The guardianships with no remaining assets are represented with no value in the Final
Accounting Of Assets column. Transfer balance indicates PSTG’s remaining assets at the
termination of the guardianship, which Hudson transferred to the successor guardian.
Chart 2 - PSTG’s Verified Initial Inventory of Assets and Final Accounting of Assets

Page 14
Introduction
Chart 3 presents the summary breakdown of disbursements from the PSTGs’ assets by expense
category.
Chart 3 - Breakdown of Disbursements from PSTGs’ Assets per Expense Category
At the end of Hudson’s tenure as a professional guardian in November 2019, she was
responsible for 27 guardianship cases in Pinellas County and Pasco County.
• On November 14, 2019, Hudson was arrested and charged with the exploitation of an
elderly person or disabled adult, Pinellas County case number 19-13778-CF-1.
• On November 19, 2019, the Court adjudicated an Order Accepting Resignation of The
Guardian and Revoking Letters of Guardianship.
• Hudson was in care, custody, and control of $9,921,783.66 in PSTGs’ assets at the time
of her removal.
• On November 19, 2019, Hudson voluntarily withdrew her professional guardian

registration from the OPPG.
• On November 25, 2019, Hudson dissolved FGSI.

Page 15
Introduction
Allegation
On April 25, 2019, the Division of Inspector General (IG) began cooperative investigative efforts
with the Pinellas County Sheriff’s Office (PCSO) and the Office of the State Attorney Sixth
Judicial Circuit of Florida (SAO) related to Hudson’s actions as a Power of Attorney. As a result
of the PCSO investigation, Hudson was arrested on November 14, 2019, and charged with the
exploitation of an elderly person or disabled adult, Pinellas County case number 19-13778-CF-
1.
The IG also received an anonymous phone call with information related to Hudson and services
she provided to elderly citizens in Pinellas County. Based on the information received, the IG
was concerned that Hudson might be engaging in the exploitation of the elderly. Therefore, on
May 2, 2019, the IG initiated a preliminary investigation into Hudson.
The Florida Sixth Judicial Circuit Court, Probate and Guardianship Division (Court), had
concerns about the care and well-being of the PSTGs and their property. Therefore, between
February 7, 2020, and February 26, 2020, the Court adjudicated orders appointing the IG “to
investigate the actions of the former guardian, Traci Hudson AKA Traci Samuel concerning the
ward’s finances, medical care, and any other issue that affects the ward’s welfare and best
interests” in all 45 guardianship cases.
Based on the preliminary information, the IG investigated an allegation that Hudson’s actions
resulted in misuse of the PSTGs’ finances and affected the PSTGs’ welfare and best interest.
Investigative Activity
During the course of the investigation, we performed the following to obtain evidence to conclude
on the allegation:
• Interviewed the successor guardians to ascertain any issues or concerns regarding the
guardianships.
• Analyzed all attorney and guardian fees to ensure the fees had Court orders and did not
exceed the Court ordered amounts. The analysis also focused on any activity that was
outside of the period stated on the Fee Petition, discrepancies in the fees listed on the
petition and the Guardian Activity log, duplicate entries, and any unusual fees requiring
further review.
• Reviewed the Inventories, Annual Accountings (AACTs), and FACTs to determine if there
were any issues or concerns involving the PSTGs’ financial affairs.
• Obtained the PSTGs’ bank records and performed a comparative analysis in order to
ensure the accountings filed reconciled with the bank records.

Page 16
Introduction
• Reviewed all Initial Plans, Annual Plans, Physician Statements, and other health-related
documents to determine if there were any issues or concerns involving the PSTGs’
medical care.
• Reviewed various guardianship related documentation in the Court file.
• Obtained the PSTGs’ federal tax records to determine if the PSTGs received any other
income not reported in the guardianship accountings.
• Collected and reviewed the PSTGs’ mail from Hudson’s abandoned PO Box located at
UPS Store #107 in St. Petersburg, Florida, to determine if the mail included any
documentation, which would have any financial or other significant impact on the PSTGs’
welfare and best interest.
• Reviewed the PSTGs’ abandoned mail accumulated at Hudson’s former PSTG 17’s
house, to determine if the mail included any documentation, which would have any
financial or other significant impact on the PSTGs’ welfare and best interest.
• Inspected original records and supporting documentation, including receipts at Hudson’s

attorney’s office to determine if there were any concealed or inconsistent financial and
medical records related to the PSTGs.
• Obtained records and supporting documentation from the title companies involved in the
sale of the PSTGs’ real property to ensure the information provided to the Court was
accurate.
• Interviewed the PSTGs, if practical, to ascertain any issues or concerns regarding the
guardianship.
• Interviewed witnesses with knowledge of facts.
• Attempted to interview Hudson.

Page 17
TIMELINE OF EVENTS
The following timeline illustrates the sequence of events prior to initiation and during the
investigation.
2020
• 02/07 to 02/26/2020 - Court
orders appointing IG to
investigate GDN cases
• 03/02/2020 - IG met with SSA

2019 • 03/04/2020 - IG visited UPS
• 05/2/2019 - IG Store
Investigation initiated
• 03/02 to 05/05/2020 - IG
interviewed successor
2016 • 05/07/2019
visited
- IG
FGSI, guardians
requested all
• 03/02/2016 - guardianship (GDN) • 03/05/2020 - IG met with VA
Hudson activity logs OIG
became a
professional • 10/17/2019 - IG • 03/18 to 03/25/2020 - Initial
guardian received outstanding requests for bank records sent
GDN activity logs out
• 03/07/2016 -
Hudson • 11/14/2019 - Hudson • 04/02/2020 - IG visited four title
incorporated was arrested companies
FGSI
• 11/19/2019 - Hudson • 06/03/2020 - IG interviewed
resigned, Letters of FFC’s Director & Hudson’s tax
GDN revoked, preparer
withdrew OPPG
registration • 09/30/2020 - IG contacted DFS
• 11/25/2019 - Hudson • 10/09/2020 - IG interviewed

dissolved FGSI guardian advocates
• 10/16/2020 - IG accompanied
DFS on FFC audit
• 10/30/2020 - IG met Hudson

and requested she provide GDN
case documents
• 12/08/2020 - IG followed up with

Hudson’s attorney on GDN case
documents request
• 12/29/2020 - Court hearing

regarding IG obtaining GDN
case documents

Page 18
Timeline of Events
2021
• 01/13 to 01/28/2021 - IG reviewed
GDN records at Hudson’s attorney’s
office
• 01/28/2021 - IG discovered
potentially altered PSTG 28’s GDN
appraisal document
• 02/04/2021 - IG interviewed PSTG

28’s son
• 02/10/2021 - IG met with the

appraiser Dale Smerkar, who 2022
prepared the original appraisal for
PSTG 28 • 01/11/2022 - IG
received all available
• 02/12/2021 - IG interviewed PSTG bank records
28’s daughter
• 03/18/2022 - IG Status
• 02/16/2021 - IG presented PSTG of Investigation Report
28’s case to the Assistant State Published
Attorney
• 09/16/2022 - IG
• 02/25/2021 - IG and PCSO completed a
detectives interviewed Smerkar and comprehensive review
obtained appraisals for PSTG 28 and of Hudson’s 45 GDN
PSTG 22 cases
• 03/10/2021 - IG and PCSO

detectives discussed PSTG 28 case
evidence with the Assistant State
Attorney
• 05/07/2021 - IG completed review of

remaining GDN documentation in
Hudson’s attorney’s office
• 06/29/2021 - Hudson arrested and

charged, case 21-06080-CF

Page 19
INVESTIGATIVE CONCLUSIONS
The Division of Inspector General uses the following terminology for the conclusion of
fact/finding(s):
• Substantiated – An allegation is substantiated when there is sufficient evidence to

justify a reasonable conclusion that the allegation is true.
• Unsubstantiated – An allegation is unsubstantiated when there is insufficient
evidence to either prove or disprove the allegation.
• Unfounded – An allegation is unfounded when it is proved to be false or there is no
credible evidence to support it.
During the course of the investigation, the IG Investigators determined the following facts to
conclude on the allegation:
On May 7, 2019, the IG Investigators visited Hudson’s office to obtain all Guardian Activity Logs
and annual accounting records for all of her cases through April 30, 2019.
On March 2, 2020, the IG team members met with a Social Security Administration (SSA)
Resident Agent-in-Charge who delivered a box of various correspondence addressed to PSTG
17, a former PSTG under Hudson’s care. PSTG 17 brought the box to the SSA office and
explained the correspondence was mailed to her residence. Upon initial review of 86 pieces of
mail, the IG Investigators noted the correspondence was addressed to various PSTGs in care
of Hudson and was postdated between September and November 2019.
On March 4, 2020, the IG Investigators visited the UPS Store in St. Petersburg where Hudson
maintained a PO Box. Per UPS Store management, Hudson abandoned the PO Box at the end
of December 2019 and did not inform the successor guardians or persons legally responsible
for the PSTGs’ assets about mail accumulating at the PO Box. The UPS Store management
agreed to provide the IG Investigators with all incoming mail. Between March 2020, and
September 2020, the IG investigators visited the PO Box 11 times and picked up 933 pieces of
correspondence. Per § 744.361(10)(c), Fla. Stat. (2015), a guardian who is given authority over
any property of the PSTG shall, at the termination of the guardianship, deliver the property of
the PSTG to the person lawfully entitled to it. See Investigative Conclusion Detail No. 11 for
further details.
On March 5, 2020, the IG Investigators met with a Special Agent with the U.S. Department of
Veterans’ Affairs Office of Inspector General (VA OIG), Criminal Investigations Division, to
discuss veteran PSTGs. The Special Agent confirmed Hudson was a fiduciary for three PSTGs
and was receiving a fiduciary fee for one, PSTG 17. Further inspection of VA documentation did
not reveal any discrepancies.
In March 2020, the IG Investigators submitted requests to 24 financial institutions for financial
records of all PSTGs formerly under Hudson’s care. While most requests were fulfilled within a

Page 20
Investigative Conclusions
year, the IG Investigators followed up nine times with Bank of America to obtain all available
outstanding bank records which were finally provided on January 11, 2022.
On April 2, 2020, the IG Investigators visited four title companies, Professional Title Solutions,
Achieve Title Services, Platinum National Title, and Equity National Title. The IG Investigators
requested documentation related to sales of the PSTGs’ properties while under Hudson’s care
and inquired about Hudson. Staff at the title companies were not familiar with Hudson. During
her tenure as a guardian, Hudson sold the properties of 12 PSTGs using the services of two
Realtors, Quyen Trujillo of Charles Rutenberg Realty and Denise Povolish of Luxury & Beach
Realty, both at the time board members of the GAPC. The IG Investigators reviewed all sales of
PSTGs’ homes and concentrated on five transactions that involved a subsequent re-sale in a
relatively short period of time with an increased resale amount.
These cases are as follows:
• PSTG 4
• PSTG 15
• PSTG 16
• PSTG 24
• PSTG 36
Table 3 below illustrates the history of the selected PSTGs’ real estate sales.

Page 21
PSTG 4 PSTG 15 PSTG 16 PSTG 24 PSTG 36

Not Not Not
Appraised Value $170,000 $55,000
applicable applicable applicable
Sale#1 Price $192,000 $35,000 $80,000 $34,750 $30,450
Sale#2 Price $230,000 $71,250 $135,000 $47,000 $37,000
% Increase from
20% 104% 69% 35% 22%
Sale#1
Days from Sale#1 17 112 35 0 0
Not Not
Sale#3 Price $75,000 $137,900 $57,984
applicable applicable
% Increase from Not Not
5% 193% 57%
Sale#2 applicable applicable
Not Not
Days from Sale#2 293 86 0
applicable applicable
Table 3 - History of the PSTGs’ Real Estate Sales
During the review, the IG Investigators noted three PSTGs were charged an unusually high sales
commission, and another PSTG’s property was sold three times in one day. Per § 744.359(2)(c),
Fla. Stat. (2015), waste or intentional mismanagement of a PSTG’s assets constitutes
exploitation by a guardian. Refer to Investigative Conclusion Detail No. 10 for further details
related to each sale.
On June 3, 2020, the IG Investigators interviewed Keith Crosby (Crosby), a tax preparer at West
Coast Accounting and Financial Services, Inc. Crosby met Hudson as a referral through the
GAPC. Crosby performed bookkeeping and payroll services for FGSI and tax preparation for
Hudson’s clients from 2016 through 2019 but advised she had no payroll in 2019. Crosby also

Page 22
prepared 1099 tax forms (1099s) for Hudson but advised only “two to four a year.” Crosby
voluntarily provided several 1099s he had on file for FGSI. The IG Investigators did not locate
any 1099s for FGSI staff in the files Hudson made available through her criminal defense
attorney Richard McKyton (McKyton). Per § 744.361(10)(a), Fla. Stat. (2015), a guardian who is
given authority over any property of the PSTG shall “keep clear, distinct, and accurate records
of the administration of the ward’s property.” Refer to Investigative Conclusion Detail No. 16 for
further details related to the 1099s.
On June 3, 2020, the IG Investigators interviewed David Menneke (Menneke), Director at FFC.
Menneke advised he was a member of the GAPC and knew Hudson through the organization.
He networked and provided funeral services to several guardians in the area. Menneke stated
Hudson would enter into a non-binding agreement with FFC to receive Court approval to
purchase cremation services for PSTGs under her care. Hudson, at times, did not return to
complete the necessary paperwork to bind the contract. The IG Investigators requested records
of all of Hudson’s PSTGs that had binding or non-binding contracts with FFC. The IG
Investigators waited several months, but Menneke had not produced the requested records.
On September 30, 2020, the IG Investigators contacted the Florida Department of Financial
Services (DFS) for assistance to obtain FFC records. Initially, the DFS Financial Specialist Kurt
Schuller (Schuller) conducted an audit of FFC. Based on the audit results, Schuller opened an
investigation into FFC. As a result of that investigation, FFC was sanctioned and fined by DFS.
In addition, the irregularities and overpayments the IG identified for PSTGs’ funeral services,
allowed the IG Investigators to coordinate refunds for several PSTGs. Per.§ 744.359(1), Fla.
Stat. (2015), a guardian may not abuse, neglect, or exploit a PSTG. A guardian has committed
exploitation when the guardian wastes, embezzles, or intentionally mismanages the assets of
the PSTG. See Investigative Conclusion Detail No. 8 for further details.
On October 30, 2020, the IG Investigators visited Hudson at her residence and requested
supporting documentation for all guardianship cases. Hudson called McKyton who stated he
was not familiar with the Court orders and wanted to review them before releasing any records.
McKyton directed Hudson not to speak with the IG Investigators.
On December 8, 2020, the IG Investigators followed up on the request for supporting

documentation. McKyton offered to provide the IG with “35 boxes of paper records,” but
subsequently demanded an unspecified amount of money to copy all the records. McKyton also
requested to know the line of questioning before Hudson would commit to an interview with the
IG Investigators.
On December 17, 2020, the IG Investigators spoke with Amanda Coffey (Coffey), Pinellas
County Managing Assistant County Attorney, regarding McKyton’s demands for payment for
providing Hudson’s guardianship records. Coffey confirmed the attorney must provide records
free of charge. The IG Investigators contacted Honorable Judge Pamela Campbell’s (Judge
Campbell) judicial assistant, who scheduled a hearing.
On December 29, 2020, Judge Campbell held a hearing with IG staff and McKyton. Also in
attendance at the hearing were Attorney Robert Thompson, Attorney Hamden Baskin, and

Page 23
Attorney Misa Everist-Tillman, successor attorneys to 12 PSTGs formerly under Hudson’s care.
Judge Campbell ordered McKyton to allow the IG Investigators access to Hudson’s guardianship
records.
The IG Investigators reviewed the guardianship records at McKyton’s office in January 2021 and
May 2021. During the inspection of Hudson’s guardianship documentation, the IG Investigators
noted:
I. One guardianship case where there were two appraisal reports of PSTG 28’s personal
property. One appraisal report listed the fair market value of the personal property as
$1,100, whereas the other property appraisal report listed an $8,250 value. The appraisal
report with the lower value ($1,100) contained blotches of white-out that could be noticed
throughout the paper document. The page numbers were whited-out, and so were other
items within the report. Per § 744.359(1), Fla. Stat. (2015), a guardian may not abuse,
neglect, or exploit a PSTG. A guardian has committed exploitation when the guardian
wastes, embezzles, or intentionally mismanages the assets of the PSTG. See
Investigative Conclusion Detail No. 1 for further details.
II. PSTG 33’s original Last Will and Testament was in the PSTG’s file. § 744.361(10)(c), Fla.
Stat. (2015), a guardian who is given authority over any property of the PSTG shall, at
the termination of the guardianship, deliver the property of the PSTG to the person lawfully
entitled to it. See Investigative Conclusion Detail No.14 for further details.
III. Two Affidavits:
• An Affidavit prepared for the Florida Retirement System (FRS) that designated
Hudson as Power of Attorney for PSTG 32, dated March 1, 2018, and notarized by
Barber. The guardianship was established on February 6, 2018, as an Emergency
Temporary Guardianship (ETG).
• An Affidavit for PSTG 44, dated June 7, 2018, designated Hudson as Power of
Attorney for PSTG 44 and was notarized by Barber. The guardianship was established
on February 13, 2018, as an ETG. It is unknown for what purpose this Affidavit was
used, as the IG Investigators did not find any other documents related to the Affidavit.
Signing a Power of Attorney document under penalty of perjury for a person under guardianship
is contrary to the provisions of the Affidavit. See Investigative Conclusion Detail No. 13. In
addition, § 117.107(11), Fla. Stat. (2006) prohibits a notary public from notarizing the signature
of a family member; see Observation No. 4 for further details.
On August 4, 2022, the IG Investigators reached out to McKyton requesting an interview with
Hudson, which he verbally declined over the phone. On August 8, 2022, the IG wrote a letter to
McKyton stating, “Please confirm, in writing, that Ms. Bryanton [Hudson] will not be available for
an interview with the Pinellas County Division of Inspector General.”

Page 24
In a letter to the IG, dated August 22, 2022, McKyton responded:
“If your office is requesting an interview of Ms. Hudson, we will comply with that
request where and when possible. As you know, Ms. Hudson has been charged
with eighteen (18) felony offenses, many of which concern allegations involving
her former Wards. Those charges remain pending at this time and, as such, it may
not be appropriate to interview Ms. Hudson concerning those criminal allegations.
However, I would anticipate that the criminal allegations/charges may be resolved
in the near future. Once that occurs, Ms. Hudson would be available for a full
interview by your office.”
Due to the judicial process timeframe and public interest, the IG decided it was not prudent to
wait for the conclusion of the active criminal cases to interview Hudson.
During the course of the investigation, we determined the facts described in the Investigative
Conclusions section to conclude on the allegation that Hudson’s actions resulted in misuse of
the PSTGs’ finances and affected the PSTGs’ welfare and best interest. Our investigation of the
allegation determined it was Substantiated.

Page 25
INVESTIGATIVE CONCLUSIONS
DETAILS
The results of the comprehensive review of all 45 guardianship cases are documented as
follows:
1. Guardian Submitted Altered Documents

To The Court.
During the investigative activities, the IG Investigators identified two guardianship cases where
the initial inventories Hudson filed with the Court did not contain all the personal property listed
in the property appraisal reports.
1. PSTG 28
The IG Investigators discovered two appraisal reports of the PSTG’s personal property
prepared for Hudson by Appraiser Dale Smrekar (Smrekar) under file No. DAS 658, dated
August 17, 2016. One appraisal report listed the fair market value of the PSTG’s personal
property as $1,100, and another appraisal report listed the fair market value of the PSTG 28’s
personal property as $8,250; both appraisal reports had the same date and file number. The
appraisal report with the lower value ($1,100) contained blotches of white-out that could be
noticed throughout the paper document. The page numbers were whited-out and so were
other items within the report.
The IG Investigators accessed the Odyssey court case management system and noted
Hudson filed the altered appraisal (value of $1,100) with the Court under case 16-010362-GD
on December 8, 2016, and again on May 17, 2019.
The original appraisal report (value of $8,250) found in Hudson’s files contained 19 pages and
52 photos of personal property, whereas the altered appraisal report submitted to the Court
was only 8 pages and contained no photos. The IG Investigators took photos of the altered
appraisal report and also scanned the document.
2. PSTG 22
The IG Investigators discovered Smrekar prepared a personal property appraisal report for
PSTG 22.
On February 25, 2021, the IG Investigators obtained a digital copy of the original appraisal
prepared by Smrekar. The date of the appraisal was March 7, 2017. The appraisal was for 14
pieces of jewelry, gold charm pins, a scrap gold item, and included color photos of the jewelry
items. The Fair Market Value of all the jewelry listed on the appraisal was reported as
$2,698.80. The appraisal included Hudson’s signature.

Page 26
Investigative Conclusions Details
The IG Investigators discovered the Verified Initial Inventory report submitted by Hudson did
not include any jewelry items from Smrekar’s appraisal conducted on March 7, 2017. The
Guardian Activity Logs submitted to the Court on July 11, 2017, did not mention anything
about an appraisal prepared by Smrekar or PSTG 22’s jewelry.
The IG Investigators obtained the PSTG’s bank records and found that Hudson wrote Check
No. 1005 to Smrekar for $300 on March 27, 2017, for appraisal services on behalf of PSTG
22.
The IG Investigators concluded the Verified Initial Inventory report filed on June 23, 2017,
pursuant to § 744.365, Fla. Stat. (2008), and Florida Probate Rule 5.620, did not include any
items from Smrekar’s appraisal prepared on March 7, 2017.
Furthermore, there was no mention of the jewelry or the appraisal prepared by Smrekar in the
subsequent AACT or elsewhere in the court docket, including PSTG 22’s husband’s (PSTG
21) accountings, for whom Hudson was also guardian.
On May 18, 2021, the IG Investigators presented the aforementioned findings, information, and
documentation to Assistant State Attorney Rene Bauer of the SAO and Detective Jason Beetz
(Beetz) of the PCSO. Detective Beetz’s criminal investigation was documented under case
number SO19-415881. As a result, on June 29, 2021, felony information was filed under Pinellas
County case number 21-06080-CF, charging Hudson with 16 offenses in the PSTG 28 and
PSTG 22 guardianship cases including:
• 1 count of Exploitation of an Elderly Person or Disabled Adult

• 10 counts of Grand Theft
• 1 count of Grand Theft From Person 65 Years of Age or Older
• 2 counts of Perjury In An Official Proceeding
• 2 counts of Perjury By False Written Declaration
§ 744.359, Fla. Stat. (2015), states:
“(2) A guardian has committed exploitation when the guardian:

(c) Wastes, embezzles or intentionally mismanages the assets of the ward.”

Page 27
2. PSTG’s U.S. Savings Bonds Are

Unaccounted For.
During the inspection of PSTG 15’s guardianship records, the IG Investigators could not locate
the PSTG’s United States (U.S.) Savings Bonds.
Hudson’s FACT indicated a $50 U.S. Savings Bond (serial number L332888468EE) and a
$10,000 U.S. Savings Bond (serial number X860787EE) which were transferred to the
successor guardian. The successor guardian’s Verified Initial Inventory did not reflect the U.S.
Savings Bonds were received.
Initially, Hudson filed a Safe Deposit Box Inventory on May 31, 2017, that contained the
aforementioned U.S. Savings Bonds. Hudson petitioned the Court to close the safe deposit box,
remove the contents, and store the contents for safekeeping.
The Verified Initial Inventory Hudson filed on July 28, 2017, listed the U.S. Savings Bonds for
$50 and $10,000 with a full asset value of $99.66 and $23,064.00, respectively. Hudson’s first
AACT filed on February 20, 2019, and the second AACT filed on October 24, 2019, listed the
$50 and $10,000 bonds as full value assets at $103.68 and $23,064.00, respectively.
Hudson resigned and was removed as guardian in November 2019. Hudson’s FACT filed on
December 7, 2021, listed the two bonds for $50 and $10,000 and stated one was surrendered
to the “successor guardian,” and one was surrendered to, “P.Clark.” The successor guardian,
Phyllis Clark (Clark), filed a Verified Initial Inventory on March 10, 2020, which did not list any
U.S. Savings Bonds. Also, in March 2020, Clark passed away, and Adult Advocacy &
Representation, Inc. (AAR) was appointed the new successor guardian. The Verified Initial
Inventory filed by AAR on October 1, 2020, did not list any U.S. Savings Bonds. In addition, the
first AACT filed by AAR on November 9, 2021, did not list any U.S. Savings Bonds.
The IG Investigators confirmed with Lona DiCerb of AAR that the guardian did not receive any
U.S. Savings Bonds from Hudson and was unaware of this issue until the IG Investigators
informed them. The IG Investigators used the U.S. Savings Bonds’ serial numbers to perform a
search query using Treasure Hunt, a U.S. Department of Treasury database that confirms
whether a U.S. Savings Bond has been redeemed. The Treasure Hunt query results as of June
23, 2022, indicated the U.S. Savings Bonds were not redeemed or cashed. Furthermore, the IG
Investigators confirmed with the Bureau of the Fiscal Service that, as of October 10, 2022, both
U.S. Savings Bonds were still outstanding.
The U.S. Savings Bonds are missing and unaccounted for. PSTG 15 is at a loss of assets with
a financial impact of at least $23,167.68 ($103.68 and $23,064).

Page 28
§ 744.361, Fla. Stat. (2015), states:
“(10) A guardian who is given authority over any property of the ward shall:
property.”
§ 744.359, Fla. Stat. (2015), states:
“(1) A guardian may not abuse, neglect, or exploit a ward.
(2) A guardian has committed exploitation, when the guardian:

(c) Wastes, embezzles, or intentionally mismanages the assets of the
ward.”
3. Guardian Commingled PSTG’s Funds

With Her Personal Funds And Deprived
The PSTG Of Money.
The IG Investigators collaborated with the PCSO in the criminal investigation of Elderly
Exploitation where Hudson is the named defendant (19-13778-CF-1). Through this collaboration
with the PSCO, the IG Investigators obtained Hudson’s personal bank records.
Hudson’s bank records listed Check No. 0002382903 from Omnicare Central Billing Center (a
pharmacy specializing in serving nursing homes) dated November 18, 2017, for $1,332.51 was
deposited on December 13, 2017, with another $1,000 check for fees for Annette Balnicky,
(Hudson was Power of Attorney for Balnicky, Elderly Exploitation case #19-13778-CF-1), for a
total deposit of $2,332.51. The Omnicare check was made payable to “[PSTG 15] c/o Traci
Samuel.” Hudson’s bank records do not list a disbursement for that amount going to the
Guardianship of PSTG 15 at any point in time. A financial review of all of PSTG 15’s accountings
noted the monies were not replaced at any point in time during the guardianship. A review of
PSTG 15’s SunTrust guardianship bank records reflected Check No. 1548 was written to
Omnicare on August 24, 2017, for $1,332.51. No further explanation regarding the purpose of
the check written to Omnicare was included in the AACT.
The IG Investigators obtained information from Omnicare that Check No. 0002382903,
deposited into Hudson’s personal account, was a refund from overpayment for medication.
As a result of her action, Hudson deprived the PSTG of $1,332.51.
§ 744.359, Fla. Stat. (2015), states:
“Abuse, neglect, or exploitation by a guardian.—

(1) A guardian may not abuse, neglect, or exploit a ward.

Page 29
(2) A guardian has committed exploitation when the guardian:

(a) Commits fraud in obtaining appointment as a guardian;
(b) Abuses his or her powers; or
ward.”
Florida Administrative Code (FAC) 58M-2.009, Standards of Practice (20)(b), states:
“(20) CONFLICT OF INTEREST: ESTATE, FINANCIAL, AND BUSINESS

SERVICES.
(b) Professional Guardians appointed guardians of the property shall not
commingle personal or program funds with the funds of Wards.”
§ 812.014, Fla. Stat. (2016), states:
“(1) A person commits theft if he or she knowingly obtains or uses, or endeavors

to obtain or to use, the property of another with intent to, either temporarily or
permanently:
(a) Deprive the other person of a right to the property or a benefit from the
property.”
4. PSTGs’ Jewelry Is Missing And

Unaccounted For.
During the review of guardianship case documentation, the IG Investigators identified two cases
where the PSTG’s jewelry was not accounted for.
1. PSTG 9
The IG Investigators obtained an original property appraisal report from Smrekar that listed
and itemized PSTG 9’s jewelry with a value of $1,513.60. On October 18, 2016, the Court
adjudicated an Order Authorizing Guardian To Sell, Abandon, or Donate Ward’s Personal
Property. The Petition for Authorization to Sell, Abandon, or Donate Ward’s Personal
Property corresponding with the Order specifically excluded PSTG 9’s jewelry that was listed
in the appraisal of personal property. The October 18, 2016, Court Order Authorizing
Guardian to Sell, Abandon, or Donate Ward’s Personal Property stated:
“The Guardian, TRACI SAMUEL, be and the same, is hereby granted authority
to sell, abandon, and/or donate the Ward’s personal property that is subject of
this Petition.”

Page 30
Said Petition filed on September 21, 2016, Section 11, stated:
“The Guardian does not seek to sell, abandon, or donate the Ward’s jewelry as
described and valued in the Appraisal Report at this time.”
However, the first AACT filed on November 16, 2017, and all subsequent accountings did
not list the jewelry as a remaining asset.
The invoice from Bay Area Estate Sales, who conducted the liquidation estate sale, did not
provide a breakdown of what was sold, donated, or hauled away. The successor guardian
did not list jewelry in the Verified Initial Inventory. The IG Investigators confirmed in a follow-
up interview with the successor guardian she did not receive PSTG 9’s jewelry. The
successor guardian referred the IG Investigators to PSTG 9’s niece who was the “go-to”
person in the family. The IG Investigators confirmed with PSTG 9’s niece jewelry was never
received by the family at any point in time. At the time of this report, the jewelry was still
missing with no justification, and the IG notified the Court.
2. PSTG 12
The appraisal of personal property in Hudson’s Verified Initial Inventory filed on July 10, 2019,
listed PSTG 12’s jewelry with a value of $1,355. The successor guardian’s Verified Initial
Inventory included the appraisal done by Bay Area Estate Sales with a handwritten note at
the bottom “where is jewelry.” The May 7, 2020, response from the successor guardian
associated with the Order Disapproving the inventory dated April 8, 2020, stated the jewelry
might be with PSTG 12. When COVID restrictions were lifted, the successor guardian was
to verify the whereabouts of the jewelry. As of this report, the location of PSTG 12’s jewelry
remains unknown. The IG Investigators confirmed with the successor guardian that jewelry
was never received from Hudson.
As a result of Hudson’s actions, PSTG 9 has been deprived of their property, and the Court has
inaccurate records regarding their personal property. In the case of PSTG 12, there is a dispute
between Hudson and the successor guardian as to the whereabouts of PSTG 12’s jewelry.
§ 744.361, Fla. Stat. (2015), states:
“Powers and duties of guardian.
(2) The guardian shall act within the scope of the authority granted by the court
and as provided by law.

Page 31
property.
(b) Perform all other duties required of him or her by law.
to the person lawfully entitled to it.”
§ 744.359, Fla. Stat. (2015), states:
“Abuse, neglect, or exploitation by a guardian.—
(1) A guardian may not abuse, neglect, or exploit a ward.

ward.”
§ 744.365, Fla. Stat. (2008), states:
“(1) FILING. – A guardian of the property shall file a verified inventory of the ward’s
property.
(2) CONTENTS. – The verified inventory must include the following:

(a) All property of the ward, real and personal that has come into the
guardian’s possession or knowledge.”
5. Guardian Overcharged The PSTGs For

Time Worked.
During review of the Guardian Activity Logs, the IG Investigators noted Hudson overcharged the
PSTGs for time worked.
The IG Investigators obtained all of Hudson’s Guardian Activity Logs for hours charged and paid
from the PSTGs’ assets during her tenure as a professional guardian. Since there was no system
that accumulated the data, the IG Investigators aggregated the Guardian Activity Logs into one
list and analyzed the information. The list included 10,732 entries.

Page 32
Hudson was a professional guardian from March 2, 2016, to November 19, 2019. Of 1,483 days
reviewed, we noted Hudson billed for and was paid for the following number of hours on the
following number of days:
Number
Hours Logged of Days
24 hrs or more 7
18 hours or more 83
12 hrs or more 256
8 hours or more 348
Up to 8 hrs 789
Total Days 1,483
Table 4 - Hours Logged per Day
The IG Investigators noted 7 days where the guardian billed over 24 hours total per day:
u be o
Hours
Date Logged
April 24, 2017 32.7
May 2, 2017 35.9
June 13, 2017 25.8
August 22, 2017 28.0
March 5, 2018 33.4
January 7, 2019 25.7
January 14, 2019 24.9
Table 5 - Dates and Hours Logged
The IG Investigators noticed an unusually high number of hours billed, 18 hours or more, on 83
days. An excessive number of hours reported daily suggests Hudson did not or could not
personally perform the tasks for which she billed. For instance, on May 2, 2017, Hudson logged
44 entries and 35.9 aggregated hours across 16 different cases. The activities listed included 14
phone calls and various conversations, 11 instances of travel, 8 instances of email exchanges,
10 instances of receiving and reviewing mail, and bill pay, and 1 instance of bank statement
review. The travel included:
• 2 instances of visiting the Pasco County Clerk’s Office

• 2 instances of visiting a UPS Store (exact address not provided)
• 1 instance of visiting PSTG’s home located in Clearwater
• 4 instances of visiting assisted living facilities (Jacaranda Manor in St. Petersburg, Arden
Courts in Largo, Pacifica Memory Care in Belleair, and Suncoast Retreat in New Port Richey)
• 1 instance of visiting St. Joseph‘s hospital in St. Petersburg
• 1 instance of visiting Largo Police Department

Page 33
The number of hours logged and tasks performed, including traveling to multiple locations in
Pasco and Pinellas Counties, confirm one person could not perform 35.9 hours of work within a
24-hour period.
Excessive hours can be the result of block billing or lumping together many activities but not
breaking them down into specific tasks or the time used such as billing multiple PSTGs to provide
the same service simultaneously. For instance, on May 25, 2017, Hudson charged 7 PSTGs a
total of 15.1 hours noting, “Traveled to/from SS office for appt regarding benefits.” On April 23,
2019, Hudson charged time to 12 PSTGs noting, “Traveled to CPA to sign receipt of filings.” The
total hours charged for these events was 8.8 hours, and the time charged to each PSTG varied
from 0.5 to 0.8 hours.
In addition, the IG Investigators noted the following billing issues:
1. During the review of PSTG 22‘s Guardian Activity Log filed with the Petition for Guardian Fees
dated July 11, 2017, the IG Investigators noted Hudson traveled to California to conduct an
inventory of PSTG 22‘s property. According to the Activity Log, on May 19, 2017, Hudson
traveled to Tampa International Airport at 4 a.m. and arrived at Los Angeles International
Airport at 10:30 a.m. local time. On May 21, 2017, at 10 p.m., Hudson landed back in Tampa.
The IG obtained copies of the itinerary from Attorney McKyton‘s office while inspecting
Hudson‘s guardianship records. The IG Investigators determined Hudson was traveling or out
of the area from Friday, May 19, 2017, at 4 a.m. to Sunday, May 21, 2017, at 10 p.m.
The IG Investigators examined other Guardian Activity Logs in Hudson’s other guardianship
cases for the period of May 19, 2017, to May 21, 2017, and noted the following:
In the Guardianship of PSTG 9, the Guardian Activity Log filed on November 16, 2017, listed
on May 20, 2017, Hudson traveled to and from Pacifica Assisted Living Facility (located in
Pinellas County, Florida) to “discuss new plan of care with nursing staff.” Hudson billed two
hours at $50 an hour for a total of $100. This Guardian Activity Log was filed with an affidavit
that was signed under oath, subject to penalties of perjury which stated:
“1. I have not submitted more than one bill for time spent simultaneously with
more than one ward
2. I have not billed my hourly rate for services provided to a ward by an individual
other than myself
3. I have managed the ward‘s estate in a reasonable and prudent manner.”
In the Guardianship of PSTG 13, the Guardian Activity Log filed on July 27, 2017, listed on
May 19, 2017, Hudson‘s activities as follows:
• “Traveled to/from Achieva Credit Union to Marshall assets” for 1.4 hours at a rate of
$50 per hour for a total of $70 (May 19, 2017)
• “Travel to/from Largo to meet Frank Pascoe” for 1.2 hours at a rate of $50 per hour
for a total of $60 (May 19, 2017)

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While no affidavit was submitted with the Guardian Activity Log, the Petition For Guardian
Fees was submitted “under penalties of perjury,” and at least $130 was billed to PSTG 13
and paid out.
In the Guardianship of PSTG 41, the Guardian Activity Log filed on August 30, 2017, listed
on May 20, 2017, Hudson “Traveled to/from Concordia Manor to check on ward and meet
with medical staff to inquire about nutritional status.” 2.1 hours at $50 per hour was charged
in the amount of $105. This Guardian Activity Log was filed with an affidavit that was signed
under oath and subjected to penalties of perjury.
2. In the Guardianship of PSTG 15, the Guardian Activity Log filed on April 12, 2018, reflected
8 hours billed for a total of $480 related to the sale, hearing, and documentation to/from the
attorney and the Realtor from August 19, 2017, through October 23, 2017. These fees were
consistent with the time frame of the sale of PSTG 15‘s real estate which was sold on October
24, 2017.
Guardian Activity Log Filed April 12, 2018

Hours
Date Activity Billed Amount
8/19/2017 Emails to/from Deeb regarding Diston property 0.3 $18
8/21/2017 Emails to/from Deeb regarding details surrounding offer on property 0.2 $12
Travel to/from Deeb to meet with Kim. Reviewed details surrounding
8/22/2017 1.5 $90
offer on property.
Multiple emails to/from realtor to discuss offer & petition for sale of
8/22/2017
property. 0.5 $30
Email received from Nick Robinson regarding details surrounding wards
9/1/2017 0.2 $12
property documents. **
9/1/2017 Calls to/from realtor regarding addendum for real property. 0.3 $18
9/5/2017 Email from Kim regarding necessary hearing for sale of property. 0.2 $12
9/5/2017 Email sent to realtor with notification of hearing for sale of property. 0.2 $12
Email received from realtor regarding upcoming hearing on sale of
9/18/2017 0.2 $12
property.
9/27/2017 Email received from Kim regarding hearing on sale of property. 0.3 $18
Reviewed appropriate material for following day hearing surrounding
10/1/2017 0.5 $30
sale of property.
10/2/2017 Travel to/from courthouse to attend hearing for sale of property. 2.3 $138
10/3/2017 Order to sell property received and reviewed. 0.2 $12
10/3/2017 Order to sell property sent to realtor. 0.2 $12
10/23/2017 Traveled to/from UPS to have closing documents notarized for property. 0.9 $54
Total 8 $480
Table 6 - 2017 Guardian Activity Log Excerpt
** An Order was entered substituting Terry Deeb for Nick Robinson on March 10, 2017. Robinson no longer
represented Hudson in this case after that date.

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The IG Investigators noted billing for real estate-related activity in the Guardian Activity Log
filed on February 7, 2019. The Guardian Activity Log reflected 8 hours spent and billed for a
total of $480 related to the sale, hearing, and documentation to/from the attorney’s office
from August 15, 2018, through October 24, 2018. The PSTG 15 did not own any other
property that could be sold. Therefore, the billing is not appropriate, redundant, and/or
questionable.
Guardian Activity Log Filed February 7, 2019

Hours
Date Activity Billed Amount
8/15/2018 Prepared and sent proposed contract for sale of property for client. 1.1 $66
Collected and sent additional information requested by Kim at Deeb
8/21/2018 Law regarding sale of client’s property. 0.7 $42
8/25/2018 Email to/from Kim regarding property contract. 0.3 $18
9/14/2018 Calls to/from Kim regarding hearing dates for sale of property. 0.3 $18
9/19/2018 Email to/from Kim regarding petition to sell property. 0.2 $12
9/21/2018 Email w/pictures to/from Kim regarding hearing preparation. 0.2 $12
Travel to/from Grand Villa, met with client and care team. Discussed
9/21/2018 2.3 $138
property sale, plan of care topics, client’s overall wellbeing.
10/2/2018 Travel to/from hearing – petition granted for sale of property. 2.5 $150
10/3/2018 Email to/from atty regarding order to sell property. 0.2 $12
10/24/2018 Email to/from Kim regarding closing on property. 0.2 $12
Total 8 $480
Table 7 - 2018 Guardian Activity Log Excerpt
As a result:
1. The PSTGs were overbilled for services Hudson logged in the Guardian Activity Logs as her
own work.
2. While Hudson documented she was working on PSTG 22‘s inventory in California, she
charged for activities conducted in Florida in at least three guardianship cases (PSTG 9,
PSTG 13, and PSTG 41) for a total of $335.
3. Hudson signed affidavits under penalty of perjury. Declaring that the facts stated in an
affidavit are true and correct, while the Affiant knows they are not, constitutes perjury. In
addition, signing a document under oath in an official proceeding that contains a false
statement or a statement the signer does not consider to be true, in regard to any material
matter, is a felony of the third degree.

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§ 837.02, Fla. Stat. (1997), states:
“Perjury in official proceedings.—
(1) Except as provided in subsection (2), whoever makes a false statement,

which he or she does not believe to be true, under oath in an official proceeding
in regard to any material matter, commits a felony of the third degree,
punishable as provided in s. 775.082, s. 775.083, or s. 775.084.
(2) Whoever makes a false statement, which he or she does not believe to be
true, under oath in an official proceeding that relates to the prosecution of a
capital felony, commits a felony of the second degree, punishable as provided
in s. 775.082, s. 775.083, or s. 775.084.
(3) Knowledge of the materiality of the statement is not an element of the crime
of perjury under subsection (1) or subsection (2), and the defendant’s mistaken
belief that the statement was not material is not a defense.”
4. PSTG 15 was overcharged $480 for guardian fees related to questionable, redundant
activity.
§ 744.361, Fla. Stat. (2015), states:
“Powers and duties of guardian.-

under the circumstances.”
(a) Protect and preserve the property and invest it prudently… and keep clear,
distinct, and accurate records of the administration of the ward’s property.”
FAC 58M-2.009 Standards of Practice, states:
“(22) PROFESSIONAL GUARDIANSHIP SERVICE FEES.

(b) Fees or expenses charged by a Professional Guardian shall be
documented through billings maintained by the Professional Guardian as
required by Section 744.108, F.S., which shall clearly and accurately state:
1. The date and time spent on a task,
2. The duty performed,
3. The expenses incurred,
4. The third parties involved; and,
5. The identification of the individual who performed the duty (e.g.,
guardian, staff, volunteer).”

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§ 744.20041, Fla. Stat. (2017), states:
“Grounds for discipline; penalties; enforcement.—

(1) The following acts by a professional guardian shall constitute grounds for which
the disciplinary actions specified in subsection (2) may be taken:
(a) Making misleading, deceptive, or fraudulent representations in or related
to the practice of guardianship.”
§ 744.359, Fla. Stat. (2015), states:
(2) A guardian has committed exploitation, when the guardian:

(c) Wastes, embezzles, or intentionally mismanages the assets of the ward.”
6. Guardian Did Not Comply With Court

Orders.
During the review of the guardianship cases, the IG Investigators noted Hudson was late filing
FACTs and was in indirect contempt of the Court.
On February 7, 2020, the Court issued an Order To File Final Accountings in 25 active cases
that stated:
“THIS CAUSE coming before the Court upon its own motion and the Court finding
from an examination of the file and records of the above-referenced case that the
following required documents are delinquent:
Petition for Discharge and Final Accounting due to guardian‘s resignation pursuant
to Rule 5.650.
ORDERED: That the former guardian TRACI HUDSON is required to file the above
listed documents within twenty (20) days per Florida Statute 744 and Rule 5.042(d)
and this file shall be reviewed by the Court in twenty (20) days. Any response to
this Order shall be in writing.”
Furthermore, on April 1, 2020, and on April 3, 2020, the Court issued Order of Indirect Civil
Contempt in 14 cases, that stated:
“ORDERED AND ADJUDGED the removed Guardian is adjudicated in willful civil

contempt of this court’s orders for failure to comply with the above reference orders
and to file a true, complete and final accounting of her guardianship and provide
copies of all records concerning the guardianship and the ward, and it is;
FURTHER ORDERED AND ADJUDGED the removed Guardian shall file the

Page 38
above referenced documents, on or before, April 15, 2020. The court reserves
jurisdiction to impose fines or sanctions for failure to comply with this court’s
orders.”
The Order to File ordered a FACT to be filed within twenty (20) days. Hudson was late in filing
the FACTs and adjudicated in willful civil contempt of the court in the following cases:
Number
of Days
Case Due Date File Date Late
1 PSTG 1* ^ 2/27/2020 4/15/2020 48
2 PSTG 4* ^ 2/27/2020 4/14/2020 47
3 PSTG 8*^ 2/27/2020 4/14/2020 47
4 PSTG 9* ^ 2/27/2020 4/14/2020 47
5 PSTG 10* 2/27/2020 4/13/2020 46
6 PSTG 12^ 2/27/2020 8/31/2020 186

7 PSTG 13* 2/27/2020 4/15/2020 48
8 PSTG 14 ^ 2/27/2020 4/15/2020 48
9 PSTG 15^ 2/27/2020 12/7/2021 649
10 PSTG 16* ^ 2/27/2020 4/13/2020 46
11 PSTG 17* 2/27/2020 4/14/2020 47
12 PSTG 19 ^ 2/27/2020 3/26/2020 28
13 PSTG 22 ^ 2/27/2020 4/13/2020 46
14 PSTG 25 ^ 2/27/2020 4/14/2020 47
15 PSTG 26 ^ 2/24/2020 4/14/2020 50
16 PSTG 27* 2/27/2020 4/14/2020 47
17 PSTG 28* ^ 2/27/2020 4/14/2020 47
18 PSTG 32 * 2/27/2020 4/13/2020 46
19 PSTG 33* 2/27/2020 4/13/2020 46
20 PSTG 35 ^ 2/27/2020 4/14/2020 47
21 PSTG 36 ^ 2/27/2020 4/14/2020 47
22 PSTG 37* 2/27/2020 4/13/2020 46
23 PSTG 39 2/27/2020 4/14/2020 47
24 PSTG 44* 2/27/2020 4/14/2020 47
25 PSTG 45 ^ 2/27/2020 4/14/2020 47

^ Case contained many discrepancies in the Final Accounting making the
accounting not true and incomplete. The case has outstanding order
disapproving aw aiting response.
* The Court adjudged an Order for Indirect Civil Contempt.
Table 8 - Final Accountings - Number of Days Late

Page 39
On October 30, 2020, the IG Investigators visited Hudson at her house and attempted to
interview her. At that time, Hudson stated the delay in providing the Court with the FACTs was
because she had “never done FACTs before,” and stated, “it was just too much for me to do.”
Hudson said in the past, she hired a paralegal to prepare all her accountings. Upon her
resignation, she could no longer afford assistance with preparing the FACTs. Hudson further
stated the multitude of boxed files and electronic document copies, such as bank statements,
made the FACT process very time-consuming for her.
As a result:
1. Hudson did not comply with the Court orders, Florida Probate Rule 5.650, and applicable
Fla. Stat.
2. The successor guardians could not file an accurate Verified Initial Inventory without
Hudson‘s FACTs filed first which led to delays in the judicial process.
3. Hudson not filing with the Court all required documentation may have resulted in the
successor guardian and the attorney conducting duplicative work to obtain the missing
documentation, causing unnecessary charges to the PSTG.
§ 744.467, Fla. Stat. (1997), states:
“Resignation of guardian.— Before entering an order discharging a guardian of the

property, the court shall require the guardian to file a true and correct final report
of his or her guardianship and to deliver to the successor guardian all property of
the ward, all records concerning the property of the ward or of the guardianship,
and all money due to the ward from him or her. A guardian of the person must
deliver to the successor guardian copies of all records of medical or personal care,
prior to being discharged. Before entering the order, the court shall be satisfied
that the interest of the ward will not be placed in jeopardy by the resignation.”
§ 744.511, Fla. Stat. (2006), states:
“Accounting upon removal.—A removed guardian shall file with the court a true,
complete, and final report of his or her guardianship within 20 days after removal
and shall serve a copy on the successor guardian and the ward, unless the ward
is a minor or has been determined to be totally incapacitated.”
Florida Probate Rule 5.650 states:
“(a) Resignation and Petition for Discharge. A guardian seeking to resign shall file
a resignation and petition for discharge….
(c) Final Report. A resigning guardian of the property shall file a final report
showing receipts, disbursements, amounts reserved for unpaid and anticipated

Page 40
costs and fees, and other relevant financial information from the date of the
previous annual accounting, and a list of assets to be turned over to the successor
guardian.”
7. Guardian Did Not Responsibly Manage

PSTGs’ Finances.
Hudson wrote checks on PSTGs’ accounts, which the banks subsequently returned due to
nonsufficient funds, causing overdraft and returned item fees charged to the PSTGs’ accounts.
Some checks were issued for caregiver/companion services and written to Hudson‘s daughter,
Baylie Barber.
The IG Investigators identified the following overdraft and returned item fees:
PSTG Overdraft
/Returned Item Fees
PSTG 13 $170
PSTG 15 $576
PSTG 16 $108
PSTG 26 $114
PSTG 39 $527
Total $1,495
Table 9 - Overdraft and Returned Item Fees
Hudson did not ensure there were sufficient funds in the PSTGs’ checking accounts, monitor the
PSTGs’ checking account balances, or reconcile the transactions.
As a result, the overdraft and returned item fees were wasteful expenditures of the PSTGs’
assets. Hudson also breached her fiduciary responsibilities by writing checks for caregiver
services to her daughter when the PSTG did not have sufficient funds available.
§ 744.359, Fla. Stat. (2015), states:

(a) Commits fraud in obtaining appointment as a guardian
(c) Wastes, embezzles, or intentionally mismanages the assets of the ward”

Page 41
§ 744.361, Fla. Stat. (2015), states:
property.”
8. Guardian Mismanaged PSTGs’ Funeral

Arrangements.
The IG Investigators noted several irregularities involving pre-need funeral service contracts with
FFC for PSTG 8, PSTG 16, PSTG 17, PSTG 18, and PSTG 28. A pre-need funeral service
contract contains preplanned and prepaid funeral arrangements. The Guardian must request a
cost estimate from the funeral home and obtain a Court order authorizing the payment. Once
the court authorizes the pre-need funeral services payment, the Guardian should sign a contract
and pay the funeral home.
The IG Investigators found Hudson obtained an Order Authorizing Guardian to Prepay Ward‘s
Funeral Expenses and entered into a pre-need arrangement with FFC for PSTG 8, PSTG 16,
PSTG 17, PSTG 18, and PSTG 28. Hudson paid FFC $1,031 for each PSTG but did not follow
through and complete the necessary contracts.
In PSTG 8‘s case, the IG Investigators also noted:
• Hudson‘s Verified Initial Inventory listed Assurant Prepaid Funeral Policy (Assurant
Policy) valued at $1,290.06. Hudson noted the document was found after the purchase
of the FFC pre-need funeral services.
• The successor guardian listed the Assurant Policy in the Verified Initial Inventory with a
value of $1,321.53 and obtained a refund from FFC for $1,031.
• PSTG 16‘s Verified Initial Inventory listed a Prepaid Funeral Arrangement with Serenity
Gardens Memorial Park valued at $1,533.05 and correspondence stating the PSTG
purchased two plots side by side with her husband in 1988. The contract was paid in full
on July 6, 1989.
• There was one Court order that authorized $1,031 to be paid to FFC for pre-need funeral
services dated February 5, 2018.
• Hudson paid twice for the pre-need and at-need funeral services:
1. Check No. 528 dated August 7, 2018 for $1,031 (pre-need funeral service)
2. Check No. 100 dated August 27, 2019 for $1,031 (at-need funeral service)

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• There was no record or indication of Hudson receiving a refund. Therefore, the IG

Investigators facilitated a refund of $1,031 to the successor guardian.
• The PSTG died on August 25, 2019, and FFC handled the funeral service.
• Hudson did not provide the successor guardian with the FFC information and the pre-
need arrangement documentation.
• The IG Investigator found that PSTG 28 relocated to Oklahoma where he died, and his
family did not use the FFC pre-need services. The IG Investigators facilitated between
FFC and the successor guardian a reimbursement for the cost of the unused pre-need
contract for $1,031.
The IG Investigators noted FFC did not place the required $149 Trust Administrative Fee into
the state trust per regulatory guidelines that govern the Division of Funeral, Cemetery, and
Consumer Services (DFCCS) for several PSTGs. Consequently, the IG Investigators
coordinated investigative activities with the DFCCS. The DFCCS issued an investigation report
on December 17, 2020, stating FFC:
• Entered into contracts that were submitted to the court for payment which misrepresented
the true nature of the contract
• Provided unapproved at-need contracts to the court which were for pre-need funeral
arrangements
• Entered into contracts not signed by the customer
• Failed to submit payment to the consumer protection trust fund and regulatory trust fund
for every preneed contract written
• Failed to maintain documentation that supports the fulfillment of contracts
• Failed to obtain a signed cremation authorization or a signed receipt for the cremains of
PSTG 16
An administrative penalty imposed by a Consent Order stated FFC should pay a $7,500 fine and
be placed on probation for 36 months. This sanction was executed on November 16, 2021, by
Mary Schwantes, Executive Director of the Board of Funeral, Cemetery, and Consumer
Services.
As a result of Hudson’s mismanagement of funeral arrangements, PSTG 16 was cremated and

charged for pre-need and at-need funeral services which was against the PSTG‘s wishes and
not in the best interest of the PSTG‘s family and estate. For PSTG 8, PSTG 17, PSTG 18, and
PSTG 28, Hudson did not have an executed contract for the funeral services. In addition, PSTG
8 already had prepaid funeral services. PSTG 28‘s successor guardian did not receive FFC pre-
need arrangements documents from Hudson, as the PSTG was relocated to Oklahoma where
the PSTG passed away and was buried.

Page 43
§ 744.359, Fla. Stat. (2015), states:
“(2) A guardian has committed exploitation when the guardian:

(c) Wastes, embezzles or intentionally mismanages the assets of the ward.”
§ 744.361, Fla. Stat. (2015), states:
“(13) Recognizing that every individual has unique needs and abilities, a guardian
who is given authority over a ward‘s person shall, as appropriate under the
circumstances:
(a) Consider the expressed desires of the ward as known by the guardian
when making decisions that affect the ward.”
9. Guardian Did Not Resolve Code

Enforcement Violations Which Resulted
In Lien Against A PSTG’s Property.
The successor guardian reported to the IG Investigators that PSTG 8’s property located at 3614
Gulf Blvd., St. Pete Beach, Florida, had been left unkept since June 2018, when the PSTG 8
was hospitalized, until December 2019 (18 months) when the successor guardian gained access
to the house. The successor guardian arranged for a locksmith to enter the home, as she did
not receive the house keys from Hudson. Once inside, the successor guardian observed spoiled
food in the refrigerator and “papers everywhere.” She found PSTG 8’s original Will and numerous
other important documents in the house. The successor guardian described the condition of the
house as “deplorable.” There were issues with the hot water heater and the telephone was still
working.
PSTG 8’s home was subjected to City of St. Pete Beach (City) code violations. The successor
guardian advised she and Attorney Hamden Baskin came to an agreement with the City of St.
Pete Beach to reduce the code enforcement fines from approximately $50,000 to $1,723. The
successor guardian resolved the debt with payment.
The IG Investigators obtained and reviewed a copy of the City Code Enforcement Report, Case
No. 20190201 (report), lodged on May 14, 2019, by PSTG 8’s family member. In the Category
of Violation field, the complaint listed “sub-standard property” and in the Description of Complaint
field stated “house an eyesore.”
According to the report, the property was cited for City Code Section 46-33, Enumerations,
Section 98-65, Unsightly Conditions, and Section 98-66, Residential and commercial property
maintenance.

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The Special Magistrate’s (a licensed attorney appointed by the City Manager and affirmed by
the City Commission to serve as a supplemental code enforcement process for the city) internal
notes from the City code violation report noted on July 9, 2019:
“Fines to start on 7/15/19 if property is not brought into compliance. Peyt [Code
Enforcement officer] spoke with guardian [Hudson] who is working on repairs. She
needs to contact judge for approval of funding [in order to make repairs].”
The internal notes further indicated the lien amount was calculated at $250 a day for
noncompliance for 183 days for a total lien amount of $45,750 (July 15, 2019, to January 14,
2020).
The notes indicated on January 14, 2020, a lien reduction application was submitted, and on
January 28, 2020, the lien was reduced from $45,750 to $5,548, and a Special Magistrate
hearing set for February 10, 2020.
The Special Magistrate further reduced the lien from $5,548 to $1,723, and the successor
guardian paid the lien with Check No. 1019 in the amount of $1,723 on February 10, 2020. On
March 31, 2020, the internal notes indicated the check cleared, the lien was paid in full, and the
case closed.
The IG Investigators reviewed the guardianship records and noted:
• The FACT for the period ending November 15, 2019, indicated Hudson made payments
for a window repair and awning removal on June 19, 2019, and a roof repair on August
14, 2019.
• On August 28, 2019, Hudson filed a Petition for Order Authorizing Repairs to Ward’s Real
Property that requested court approval to pay for repairs to resolve code enforcement
violations. The petition did not list any specific amount for approval.
• The Court approved the Order for repairs on August 29, 2019, but the FACT did not
indicate any disbursements for repairs after this date and the code enforcement fine
continued to be assessed daily through January 14, 2020.
According to the code enforcement report, the only documented communication between the
City Code Enforcement and Hudson was on July 9, 2019. While Hudson paid for window,
awning, and roof repairs, she did not resolve the code enforcement issues or communicate with
the City to satisfy the lien.
Hudson was responsible for the code violations to PSTG 8’s real property from July 15, 2019, to
November 19, 2019, and had a duty to act on the code enforcement violations that resulted in a
lien on the PSTG’s property at a loss to the PSTG of $1,723. As a result of Hudson’s inaction,
PSTG 8’s property accumulated $45,750 in code violations which led to a property lien in the
same amount. The negotiated lien in the amount of $1,723 was satisfied out of PSTG 8’s assets.

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§ 744.361, Fla. Stat. (2015), states:
property
(b) Perform all other duties required of him or her by law.”
§ 744.361(11), Fla. Stat. (2015), states:
“The guardian shall observe the standards in dealing with the guardianship
another.”
10. Guardian Paid Unusually High Sales

Commissions From PSTGs’ Funds.
The Guardian used the services of Quyen Trujillo (Trujillo), a Realtor, to obtain the estimated
value of PSTGs’ properties and list those properties for sale. Trujillo received above industry
standard commissions for the sale of PSTGs homes in the following three guardianship cases
assigned to Hudson (presented in chronological order):
1. PSTG 36 (deceased, guardianship case closed)
PSTG 36
8440 Fox Hollow Drive,
Property Address
Port Richey, Florida
Listing and Selling Agent Trujillo
Sale Price $30,450
Sales Commission $4,960
Sales Commission % 16.3%
Industry Standard Commission 6% $1,827
Difference in Commission $3,133
Table 10 - Commission Paid from PSTG 36’s Assets
On April 3, 2017, the PSTG’s property was listed for $25,000 in the Multiple Listing Service
(MLS) database and went under contract on the same day with a selling price of $30,450. The
listing and selling agent (dual agent) for the PSTG’s sale was Trujillo who received a flat rate
commission in the amount of $4,960, or approximately 16.3% of the sale price. According to
Redfin.com, the real estate fee is negotiable and typically is 6% of the home value. In addition,
dual agents often lower the commission fees. Redfin.com did not mention the flat fee
commission option as it is not customary in residential real estate property dealings. It should

Page 46
be noted Trujillo, at the time, was a board member of the GAPC, and Hudson was President
of the GAPC. The IG Investigators noted the Realtor’s commission was more than double the
industry standard of 6%. The Petition for Authority to Act and to Sell Ward‘s Real Property
was filed on April 17, 2017, stated, “The home is uninhabitable and needs repairs and
renovations” and that maintenance and upkeep would be a drain on the PSTG’s assets. The
PSTG’s income consisted of $551 to $554 per month in Social Security and $918.83 to
$953.33 per month in pension payments from their deceased spouse.
2. PSTG 24 (deceased, guardianship case closed)
PSTG 24
7714 Fox Hollow Drive,
Property Address
Port Richey, Florida
Listing and Selling Agent Trujillo
Sale Price $34,750
On April 3, 2017, the PSTG’s property was listed for $25,000 in the MLS database and went
under contract the same day with the initial sales price of $26,750. On or about April 27, 2017,
an addendum to the contract was executed that changed the purchase price to $34,750.
Trujillo was the listing and selling agent (dual agent) for the PSTG’s sale and received a flat
rate commission in the amount of $5,000, of which $4,960 was distributed to Trujillo and $40
to Charles Rutenberg Realty. The commission equates to approximately 14.4% of the sale
price of $34,750. The IG Investigators noted the Realtor’s commission was more than double
the industry standard of 6%. A Petition for Authorization to Sell Ward’s Real Property was filed
on May 25, 2017. The Petition stated the property was in deplorable condition and would need
renovations estimated at over $50,000. It further stated, “The Guardianship does not have
sufficient liquid assets to improve the Property.” The PSTG’s only income was Social Security
in the amount of $1,094 per month.

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3. PSTG 15
PSTG 15
955 51st St. N, Unit 207
Property Address
Saint Petersburg, Florida
Listing Agent Trujillo
Sale Price $35,000
Trujillo listed the home for sale in the MLS on August 15, 2017, and on October 24, 2017, the
PSTG’s property was listed and sold for $35,000. The listing agent Trujillo was paid a sales
commission of $5,305, or approximately 15.2% of the sales price, and the buyer’s agent was
paid $1,050 or 3% of the sales price. Overall, the total real estate commission charged to the
PSTG at the closing was approximately 18.2%, or $6,355. The IG Investigators noted the total
sales commission was three times the industry standard of 6%. A Petition for Authorization to
Sell Ward’s Real Property was filed on August 23, 2017. It stated there were many updates
and renovations needed, and the property should be sold “as is” so the PSTG would no longer
need to expend funds on the property. The PSTG’s only set income was Social Security
ranging from $508 to $644 per month. Other sources of income included varying amounts of
dividends and a John Hancock Long Term Care Insurance policy that paid $3,600 to $3,720
per month.
In all three cases, the IG Investigators noted no explanation for Hudson to pay excessive real
estate commissions from PSTGs’ funds.
The Guardian did not perform due diligence, was not a prudent investor, and did not work in the
best interest of the PSTGs. Three of Hudson’s PSTGs paid unusually high commission fees
without a documented reason.
The IG Investigators did not find any inappropriate connection between Hudson and the parties
involved in the subsequent sales.
§ 744.361, Fla. Stat. (2015), Powers and duties of guardian, state:
“(4) A guardian may not act in a manner that is contrary to the ward’s best interests
(a) Protect and preserve the property and invest it prudently… and keep clear,
distinct, and accurate records of the administration of the ward’s property.”

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11. Guardian Abandoned PSTGs’ Mail At A

UPS PO Box And At A PSTG’s Residence.
On March 4, 2020, the IG Investigators visited the UPS Store in St. Petersburg, where Hudson
maintained a PO Box. The UPS Store manager stated only Hudson and Barber picked up the
mail from the PO Box. Per the UPS Store manager, Hudson paid for the PO Box through
December 31, 2019, abandoned the PO Box at the end of December 2019, and did not contact
the store since then. The UPS manager kept the PO Box open to accommodate successor
guardians. Several successor guardians located the PO Box information themselves in the
PSTGs’ records and collected accumulated mail. During interviews with all successor guardians,
the IG Investigators determined Hudson did not inform the successor guardians or persons
legally responsible for the PSTGs’ assets about mail accumulating at the PO Box. The UPS
Store manager stated she would prefer to deal only with the IG office and provided a large box
of accumulated correspondence.
Between March 5, 2020, and September 4, 2020, the IG investigators visited the PO Box 11
times and picked up 933 pieces of correspondence postdated between December 2019 and July
2020. The IG Investigators provided PSTGs’ mail to their successor guardians. In addition, the
IG Investigators sent 41 checks, in the total amount of $30,052.37 (including 18 stimulus checks
at $1,200 each, worth $21,600), to successor guardians and other legally responsible persons
via certified mail. On September 4, 2020, the IG Investigators requested the PO Box closure.
The IG Investigators returned all remaining mail of individuals not under the Court order to the
Clearwater Post Office.
On March 2, 2020, the IG team members met with a SSA Resident Agent-in-Charge who
delivered a box of various correspondence mailed to PSTG 17, a PSTG formerly under Hudson’s
care. PSTG 17 brought the box of mail to the Social Security office and explained the
correspondence was mailed to her residence. Upon initial review of 86 pieces of mail, the IG
Investigators noted the mail was addressed to various PSTGs in the care of Hudson and
postdated between September and November 2019. Further, inspection revealed the mail
included notices from:
• Centers for Medicare & Medicaid Services

• American Association of Retired Persons
• Social Security Administration
• Agency For Health Care Administration
• Silver Script
• Department of Health and Human Services
• Sunshine Health
• TriCare
• Blue Cross Blue Shield
• WellMed

Page 49
There was also a copy of PSTG 17’s Florida Identification Card and a copy of a Social Security
check for $1,753 payable to Traci Hudson for PSTG 12. A handwritten note on the check
indicated the check was returned to Social Security on January 13, 2020.
During a short conversation with the IG Investigators on October 30, 2020, Hudson denied the
PSTGs’ mail was abandoned and claimed the UPS Store management did not allow her access
to the PO Box because she no longer was a guardian. Hudson stated her daughter, Barber, and
another employee were denied access to the PO Box as well. The IG Investigators contacted
the UPS Store after Hudson’s statement and could not confirm her statement with the UPS Store
management, as the manager interviewed previously left employment and attempts to contact
her went unanswered.
The Mailbox Service Agreement Hudson signed, states:
“Customer agrees that the Center may terminate or cancel this Agreement for good
cause at any time by providing Customer with written notice.”
Good cause is listed as:
“1) Customer abandons the Mailbox;

2) Customer uses the Mailbox for unlawful, illegitimate, or fraudulent purposes;
3) Customer fails to pay monies owed to the Center when due;
4) Customer receives an unreasonable volume of mail or packages;
5) Customer engages in offensive, abusive, or disruptive behavior toward other
customers of the Center of the Center’s employees; and
6) Customer violates any provision of the Agreement.”
On August 23, 2022, the IG Investigators visited the UPS Store again and spoke with an
assistant manager. The UPS Store was under new ownership and used new software.
Therefore, there was no documentation related to Hudson’s PO Box and no written cancellation
notice available. The assistant manager stated he began working at the store in March 2020 and
remembered one instance when the previous manager denied Hudson access to the mailbox;
however, this was at least four months after Hudson’s discharge. Nevertheless, Hudson was
responsible to deliver to the successor guardian all property of and records concerning the
PSTGs upon her resignation in November 2019.
Upon resignation, Hudson did not inform the successor guardians of the mail delivered to the
existing PO Box and mail accumulated at one PSTG’s residence address. In addition, Hudson
did not forward the PSTGs’ mail to the successor guardians or persons legally entitled to the
PSTGs’ property.
As a result, Hudson did not fulfill her responsibilities as delineated in § 744.361, Fla. Stat. (2015).
Successor guardians or persons legally responsible for the PSTGs’ assets did not receive
important correspondence and documentation or information of its whereabouts, including Social
Security and stimulus checks.

Page 50
§ 744.361, Fla. Stat. (2015), states:
property
§ 744.467, Fla. Stat. (1997), states:
“Resignation of guardian.—A guardian may resign and be relieved of his or her

duties after the notice that the court may require and notice to the surety on his or
her bond. Before entering an order discharging a guardian of the property, the
court shall require the guardian to file a true and correct final report of his or her
guardianship and to deliver to the successor guardian all property of the ward, all
records concerning the property of the ward or of the guardianship, and all money
due to the ward from him or her.”
12. Guardian Employed Her Daughter To

Perform Caregiver Services For The
PSTGs Without Disclosure And Approval
From The Court.
Hudson employed Barber to perform office duties at FGSI. Barber also performed caregiver or
companion services for the PSTGs for a fee. Hudson employed other staff who performed office
duties, caregiver, and companion services for the PSTGs and were alternatives to utilizing
Barber. Also, Barber’s employment was not disclosed to the Court and not approved by the
Court as required per FAC 58M-2.009, effective June 23, 2017.
In addition, during review of the PSTG 28 guardianship documentation, the IG Investigators

noted Hudson paid a significant sum of money to her daughter for care of the PSTG’s cat.
The guardianship accountings revealed, between August 25, 2016, and November 15, 2019,
Hudson employed Barber as a caregiver for PSTG 28. The IG Investigators completed a financial
review of PSTG 28’s bank records and noted Barber received $6,940 for caregiver services. Of
that amount, at least $6,130 was paid to Barber for cat care services.
The guardianship accounting records lacked receipts, invoices, and 1099s for the majority of
these expenses. The IG Investigators informed the SAO of these findings.

Page 51
Overall, from August 25, 2016, to December 3, 2019, Hudson paid Barber $50,292 for the
caregiver, companion, and office administrative duties from PSTGs’ funds. In addition, she
received compensation from Hudson’s FGSI business account.
Hudson did not go through the proper protocol to disclose to the Court that she employed her
daughter. Hudson did not obtain Court approval to employ Barber to provide services to the
PSTGs for a fee.
Employing a guardian’s family member to provide various services to PSTGs is contrary to FAC
58M-2.009 and may not have been in the best interest of the PSTGs.
§ 744.361, Fla. Stat. (2015), states:
under the circumstances.
property.”
FAC 58M-2.009, Standards of Practice, states:
“(16) CONFLICT OF INTEREST: ANCILLARY AND SUPPORT SERVICES….
3. Professional Guardians may not employ their friends or family to provide

services for a profit or fee unless no alternative is available and the
Professional Guardian discloses this arrangement to the court and the
services are provided at the going market rate. ”
§ 744.359, Fla. Stat. (2015), states:

ward.”

Page 52
13. Guardian Signed Affidavits That

Designated Her As Power Of Attorney For
PSTGs.
While inspecting guardianship records at Hudson’s attorney’s office, the IG Investigators
discovered an Affidavit prepared for the FRS that designated Traci Samuel Hudson as Power of
Attorney for PSTG 32, dated March 1, 2018, and notarized by Barber. The guardianship for the
PSTG was established on February 6, 2018, as an ETG, and Hudson became plenary guardian
on February 28, 2018. According to a note on the correspondence with the FRS, the Affidavit
was sent to the FRS on March 1, 2018.
During the inspection, the IG Investigators also discovered an Affidavit, dated June 7, 2018, and
notarized by Barber, that designated Traci Samuel Hudson as Power of Attorney for PSTG 44.
The guardianship for the PSTG was established on February 13, 2018, as an ETG, and Hudson
became plenary guardian on March 14, 2018. It is unknown for what purpose this Affidavit was
used, as the IG Investigators did not find any other documents where the Affidavit was used.
Hudson signed the Affidavits under penalty of perjury for persons under guardianship, which is
contrary to items 3 (b) and 6 of the Affidavit. Declaring the facts stated in an affidavit are true
and correct, while the Affiant knows they are not, constitutes perjury.
The Power of Attorney Affidavit, states:
“3.To the best of the Affiant’s knowledge after diligent search and inquiry:
b. Affiant’s authority has not been suspended by initiation of proceedings to

determine incapacity of the Principal or to appoint a guardian or a guardian
advocate for the Principal; and….
6. Affiant agrees not to exercise any powers granted by said Power of Attorney if
Affiant attains knowledge that it has been revoked, has been partially or completely
terminated or suspended, or is no longer valid because of the death or adjudication
of incapacity of the Principal.
Under penalties of perjury, I declare that I have read the foregoing affidavit and the
facts stated in it are true and correct to the best of my knowledge and information.”

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14. Guardian Did Not Deliver PSTG’s Will To

The Successor Guardian.
On January 28, 2021, during an inspection of Hudson’s guardianship records at her criminal
defense attorney’s office, the IG Investigators discovered PSTG 33’s original Will was in the
PSTG’s file. Hudson was obligated to turn over the Will and all other PSTG documentation to
the successor guardian within 20 days after her resignation on November 19, 2019.
Hudson did not timely deliver PSTG 33’s records to the successor guardian.
Without the PSTG’s Will, the successor guardian cannot properly plan the PSTG’s estate in
accordance to the PSTG’s wishes.
§ 744.467, Fla. Stat. (1997), states:
“Resignation of guardian.
A guardian may resign and be relieved of his or her duties after the notice that the
court may require and notice to the surety on his or her bond. Before entering an
order discharging a guardian of the property, the court shall require the guardian
to file a true and correct final report of his or her guardianship and to deliver to the
successor guardian all property of the ward, all records concerning the property of
the ward or of the guardianship, and all money due to the ward from him or her. A
guardian of the person must deliver to the successor guardian copies of all records
of medical or personal care, prior to being discharged. Before entering the order,
the court shall be satisfied that the interest of the ward will not be placed in jeopardy
by the resignation. The acceptance of the resignation shall not exonerate the
guardian or the guardian’s surety from any liability previously incurred.”
15. Guardian Did Not File A Final Accounting

And Trust Accountings.
On December 4, 2019, the Court adjudicated an Order Accepting Resignation of Guardian
Advocate in PSTG 23’s case. On February 14, 2020, the Court entered an Order to File and
Produce Required Documents to wit: Final Accounting. As of October 10, 2022, Hudson had not
filed the FACT with the Court.
Additionally, Hudson has not filed final trust accountings for PSTG 9 and PSTG 12. On April 23,
2018, Hudson was appointed successor trustee of the [PSTG 9] Trust and filed trust accountings
for 2018 and 2019; however, she did not file the final trust accounting. On August 27, 2019, the
Court appointed Hudson as Acting Trustee for [PSTG 12’s] Kenneth Charles McElroy Trust, and
Charles C. Moffat and Jean E. Moffat Revocable Trust. Therefore, a Trust Accounting from

Page 54
August to November 2019 should have been filed. As of October 10, 2022, Hudson had not filed
final trust accountings for the Trusts.
Not filing FACTs constitutes a violation of Fla. Stat. In addition, Hudson is not in compliance with
an Order to File and Order to Produce.
§ 744.467, Fla. Stat. (1997), states:
“A guardian may resign and be relieved of his or her duties after the notice that the
court may require and notice to the surety on his or her bond. Before entering an
order discharging a guardian of the property, the court shall require the guardian
to file a true and correct final report of his or her guardianship.”
§ 744.3678(a), Fla. Stat. (2006), states:
“Accounting upon removal. A removed guardian shall file with the court a true,
16. Guardian Did Not Maintain 1099 Tax

Forms In The PSTGs’ Records.
In a letter dated October 30, 2020, the IG requested Hudson provide all documentation and files
related to her guardianship cases including the following:
• “Copies of all timesheets and/or invoices (with the hourly rate, the number of
hours worked for each disbursement and expenses incurred) for companions
or caregivers who are service providers, independent contractors, or third party
providers.
• All 1099 and W-9 forms for all individuals paid during the guardianship.
• Copies of all burial preneed funeral contracts paid to Florida Family Cremations
with all supporting source documentation.
• Copies of all IRS Forms 1040 for all wards with all supporting source
documentation for all applicable years.
• Copies of supporting documentation for all real estate transactions for all wards
with proof of sale, name of agent, and date of transaction.”
The IG Investigators inspected Hudson’s guardianship records at her criminal attorney

McKyton’s office and did not observe any 1099 Tax Forms for the home care and other services
provided by FGSI staff to the PSTGs under Hudson’s care. During the IG Investigators’ visit,
attorney McKyton informed the IG Investigators that Hudson would only produce 1099s if the
Court compelled her. Since the 1099s were not provided as requested and not located during

Page 55
records inspection, the IG Investigators concluded Hudson did not maintain 1099s for all the
expenses of hiring caregivers and independent contractors. The IG Investigators had prior
knowledge that numerous Hudson staff members had performed independent contractor work.
Between 2016 and 2019, Hudson paid Barber $50,292 from the PSTGs’ assets. In 28
guardianships, payments were $600 or more per year. Table 13 contains a summary of
payments over $600 Hudson made to the assistants.
Barber Quattrocki Gonzalez Lyons

Total Paid $50,292 $35,551 $12,355 $25,293
Number of
Cases Over 28 19 8 17
$600 Paid Per
Years Paid 2016-2019 2017-2019 2018-2019 2018
Table 13 - Payments to Assistant Over $600 Per Year
Hudson did not keep clear, distinct, and accurate records as required in § 744.361, Fla. Stat.
(2015). While Hudson was not required to file 1099s with the Court, she had a statutory obligation
to retain the 1099 records.
Without clear and distinct records, the opportunity for fraud and waste exists.
§ 744.361, Fla. Stat. (2015), states:
property.”
Internal Revenue Service (IRS) website (irs.gov) instructions, state:
“File Form 1099-MISC for each person to whom you have paid during the year:
• At least $10 in royalties or broker payments in lieu of dividends or tax-

exempt interest.
• At least $600 in:
o Rents.
o Prizes and awards.
o Other income payments.
o Medical and health care payments.
o Generally, the cash paid from a notional principal contract to an
individual, partnership, or estate.”

Page 56
OBSERVATIONS
During the investigative activities, the IG Investigators made the following observations:
1. Guardian Did Not Maintain Clear And

Accurate Guardianship Records.
The IG Investigators examined all AACTs and FACTs Hudson filed with the Court and noted
multiple errors and discrepancies.
Of the 45 guardianship cases, the IG Investigators identified 22 cases that contained various
errors, omissions, and discrepancies when compared to the bank records. Some examples of
the significant errors, omissions, and discrepancies include:
I. AACT
• PSTG 8: The AACT for the period ending June 30, 2019, listed a $10,000 transfer on
April 18, 2019, from the Cadaret Grant brokerage account to the Wells Fargo account.
The Cadaret Grant statement does not reflect the transfer nor does the Wells Fargo
account bank statement, resulting in a $10,000 discrepancy.
• PSTG 45: The AACT for the period ending June 30, 2019, listed income/deposits for the
Wells Fargo account totaling $24,480.31; however, the Wells Fargo account bank
statement reflected $28,680.31 in income/deposits. The AACT only listed five pension
payments from Defense Finance Accounting Service, resulting in a $4,200 discrepancy.
The Order Disapproving entered on November 5, 2019, requested an explanation;
however, no response was received.
• PSTG 32: The AACT for the period ending February 28, 2019, listed Check No. 1592 for
$6,522.42 from the Achieva Credit Union account to the Cypress Palms care facility for
room and board, whereas the Achieva Credit Union account statement listed Check No.
1592 was to Nick Robinson for attorney fees on November 16, 2018.
• PSTG 10:
o The AACT for the period ending May 31, 2018, listed Check No. 122 for $1,200, from
the Fifth Third Bank account to the Imperial Palms care facility, whereas the Fifth Third
Bank account statement listed Check No. 122 was to Antwan Shirley for $1,200
(memo stated “apt 602 rent”) on June 3, 2017.
o The AACT for the period ending May 31, 2018, listed Check No. 2 for $1,100 from the
Fifth Third Bank account to the Imperial Palms care facility on July 8, 2017, whereas

Page 57
Observations
the Fifth Third Bank account statement reflected a cash withdrawal of $1,100 with
Traci Samuel’s signature on August 1, 2017.
Overall, the AACT discrepancies were noted as follows:
1. The AACTs understated income/deposits by a total of $4,200 compared to the bank

statements (1 case).
2. The AACTs overstated disbursements by a total of $9,820 compared to the bank
statements (2 cases).
3. The AACT payee differed from the bank statement/canceled check payee for a total of
$12,455.12 in disbursements (10 cases).
II. FACT
• PSTG 8: The FACT for the period ending November 19, 2019, did not report $5,634.11
in disbursements. The Wells Fargo account reflected various disbursements totaling
$5,634.11. However, these expenditures were not reported in the FACT, resulting in a
$5,634.11 discrepancy.
• PSTG 25:
o The FACT for the period ending November 19, 2019, did not report attorney fees.
The Morgan Stanley account bank statements reflected disbursements to Deeb
Elder Law on August 21, 2019, totaling $34,970.50, and on August 29, 2019,
totaling $978.31. The IG Investigators confirmed the attorney fees in the amount
of $35,948.81 were ordered by the Court on August 2, 2019. However, these fees
were not reported in the FACT, resulting in a $35,948.81 discrepancy.
o The FACT for the period ending November 19, 2019, listed Check No. 2314 for
$19 from the Bank of Tampa to Gandy Crossing, whereas the Bank of Tampa
account statement listed Check No. 2314 was to Gandy Crossing for $19,279.73,
resulting in a $19,260.73 discrepancy.
• PSTG 9:
o The FACT for the period ending November 19, 2019, listed $9,927.69 in
deposits/income, whereas the Wells Fargo account bank statements listed
$18,263.95 in deposits/income from July 1, 2019, through November 15, 2019,
resulting in a $8,336.26 discrepancy.
o The FACT for the period ending November 19, 2019, did not list a $35,000 transfer
the Court specifically allowed Hudson semi-annually from the Wells Fargo investment
account into the PSTG’s checking and savings accounts, resulting in a $35,000
discrepancy.

Page 58
Observations
• PSTG 12:
deposits/income, whereas the Wells Fargo account bank statements listed
$49,152.25 in deposits/income, resulting in a $3,578.84 discrepancy.
deposits/income, whereas the Chase account bank statements listed $8,370.54 in
deposits/income, resulting in a $3,103.49 discrepancy.
Overall, the FACT discrepancies were noted as follows:
1. The FACTs understated income/deposits by a total of $21,858.28 compared to the

bank statements (5 cases).
2. The FACTs understated disbursements by a total of $115,120.60 compared to the bank
statements (19 cases).
3. The FACT payee differed from the bank statement/canceled check payee for a total of
$815 in disbursements (4 cases).
Additional examples of errors that did not result in an overall under or over reporting of income
or disbursements on the accountings include:
• PSTG 28: The FACT for the period ending November 19, 2019, listed a $10,001.01
difference from the amended AACT for the period ending September 30, 2018, due to
incorrect reporting of IRS back taxes. Hudson noted in the amended AACT she was
unaware at the time of the inventory the PSTG had a payment plan set up with the IRS.
• PSTG 16: The FACT for the period ending November 15, 2019, incorrectly listed a
Regions Bank Line of Credit/Loan of $4,066.42 on Schedule C: Capital Adjustments
During Period. The Regions Bank line of credit was already satisfied using proceeds from
the real estate property sale on May 18, 2018.
• PSTG 25: The FACT for the period ending November 19, 2019, miscategorized attorney
fee payments from the Morgan Stanley account as a loss twice on line 5 ($109,759.01)
and line 10 ($85,757.92).
Hudson did not maintain true, complete, and accurate records of the PSTGs’ financial affairs,
which was not in the best interest of the PSTGs.
§ 744.361, Fla. Stat. (2015), states:
property.”

Page 59
Observations
§ 744.511, Fla. Stat. (2006), states:
“Accounting upon removal.—A removed guardian shall file with the court a true,
2. PSTG’s Personal Property Value Was Not

Listed In The Verified Initial Inventory
And Final Accounting.
The IG Investigators noted PSTG 14’s personal property value was not documented in the
guardianship accountings.
Hudson filed a Verified Initial Inventory and a FACT that did not report the value of the PSTG
14’s personal property, a mobile home located at 7100 Ulmerton Road, Lot 377, Largo, Florida
33771. The successor guardian obtained PSTG 14’s property value of $52,780 from the Pinellas
County Property Appraiser’s (PCPA) website using the property card data. Therefore, Hudson
provided the Court with inaccurate accountings for PSTG 14 since the PSTG’s Verified Initial
Inventory and the FACT were undervalued by $52,780.
§ 744.365, Fla. Stat. (2019), Verified Inventory, state:
“(1) FILING.—A guardian of the property shall file a verified inventory of the ward’s
property.
(2) CONTENTS.—The verified inventory must include the following:

(a) All property of the ward, real and personal, that has come into the
guardian’s possession or knowledge, including a statement of all
encumbrances, liens, and other secured claims on any item, any claims
against the property, any cause of action accruing to the ward, and any
trusts of which the ward is a beneficiary.
(b) The location of the real and personal property in sufficient detail so that
it may be clearly identified or located.
(c) A description of all sources of income, including, without limitation, social
security benefits and pensions.”

Page 60
Observations
3. Guardian Spent PSTG’s Limited Funds

On Potentially Redundant Services.
The successor guardian informed the IG Investigators PSTG 37 resided at the Seasons Belleair
Memory Care (Seasons) at a cost of $3,328 per month. The IG Investigators attempted to
contact Seasons several times to obtain PSTG 37’s invoices. However, Seasons did not
cooperate. The successor guardian’s Initial Guardianship Plan noted PSTG 37 did not
participate in many activities at Seasons and loved her naps. Seasons offers its residents various
levels of support with daily tasks, entertainment, activities, areas for socialization, and nursing
staff. Hudson sent PSTG 37 to Maria’s Adult Day Care and Home Care Assistance (Maria’s Day
Care) on a weekly basis at a cost of $155 for transportation and $69 for daycare per visit. In
addition, Hudson hired home care assistance from multiple care providers. The total amount
charged for Seasons, Marias’s Day Care, and home care assistance in the period of November
3, 2017, to July 12, 2019, was as follows:
Service Amount
Seasons $95,978.80
Maria’s Day Care $19,481.00
Home Care Assistance $35,925.72
Total $151,385.52
Table 14 - Amounts Charged for Services To PSTG
The home care services and Maria’s Day Care cost PSTG 37 $55,406.72 for the above noted
period. Seasons provide daily activities, socialization, and entertainment. Also, Seasons offers
its residents assistance with daily tasks and nursing staff. Therefore, having PSTG 37 attend
Maria’s Day Care and receive home care assistance may have been unnecessary due to similar
services being provided by Seasons.
As a result, the expenditure created a financial burden to PSTG 37 due to her limited income of
$797 per month and subsequently drained her savings. Amounts listed in the table below reflect
information as presented in the PSTG’s AACTs and FACTS.
Beginning Capital Ending
Source Balance Income Disbursements Gain/Loss Balance
Amended Inventory $300,492.79 N/A N/A N/A N/A
First AACT
5/10/2017 - 6/30/2018 $298,104.46 $12,387.38 $96,294.05 ($67,551.75) $146,646.04
Second AACT
7/1/2018 - 6/30/2019 $146,646.04 $9,601.50 $73,454.32 $0.00 $82,793.22
FACT
7/1/2019 - 11/19/2019 $82,793.22 $4,064.17 $23,593.23 ($63,264.16) $0.00
Table 15 - PSTG’s Assets Depletion

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Observations
§ 744.361, Fla. Stat. (2015), states:
“(11) The guardian shall observe the standards in dealing with the guardianship
another.”
4. Guardian Used Her Daughter’s Notary

Service To Notarize Various
Guardianship-Related Documents.
During the examination of the guardianship records, the IG Investigators noted several
documents Barber notarized for Hudson.
The IG Investigators located the following documentation Hudson signed and Barber notarized:
1. Power of Attorney document for PSTG 32 signed on March 1, 2018

2. Power of Attorney document for PSTG 44 signed on June 7, 2018
3. A closing affidavit for the closing of PSTG 4’s house signed on July 17, 2018
4. An affidavit for the Guardian Activity Logs for PSTG 22 filed on April 12, 2018
The IG Investigators did not identify any payments in the guardianship reports from Hudson to
Barber for these notary services.
Notarizing a document for the notary’s mother is a prohibited act per § 117.107(11), Fla. Stat.
(2006). Since the notary certificates were signed and sealed in violation of Fla. Stat., the validity
of the notary certificates is questionable. Therefore, it would be the Court’s decision to rule
whether or not the notarizations were valid.
Per § 117.107, Fla. Stat. (2006), Prohibited acts:
“(11) A notary public may not notarize a signature on a document if the person
whose signature is to be notarized is the spouse, son, daughter, mother, or father
of the notary public.”

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Observations
5. Guardian Did Not Protect And Preserve

PSTG’s Assets.
The IG Investigators identified an instance where Hudson spent PSTG 19’s funds on storage
fees for personal property not listed in the AACTs.
Hudson paid a total of $1,114.35 for PSTG 19’s U-Haul storage for the period of June 2019 to
November 2019 but did not list personal property in any of the AACTs. The successor guardian
received the U-Haul storage key from Hudson, retrieved PSTG 19’s belongings from storage,
and listed them in the Verified Initial Inventory with a value of $1,245.
As a result, Hudson did not protect and preserve PSTG 19’s assets and spent $1,114.35 of
PSTG 19’s funds on unnecessary storage fees for items worth $1,245.
§ 744.361, Fla. Stat. (2015), state:
under the circumstances.
property….
6. Guardian Was Not Involved In Consent

To PSTG’s Medical Procedures.
The IG Investigators noted there was no documentation that Hudson consented to PSTG 15’s
medical procedures, and PSTG 15 granted the consent even though she had her right to make
medical treatment decisions removed.
On February 15, 2017, the Court adjudged an Order Determining Capacity that removed PSTG
15’s delegable rights including the right to exercise consent to medical treatment. Upon review
of 69 pages of medical records obtained from Brett Almond, Medical Doctor (Dr. Almond),
Vascular Surgeon at Bay Surgical Specialists, there was no mention of Hudson or a court-
appointed guardian being involved anywhere in the progress notes. The progress notes
indicated, on at least two occasions, Bay Surgical Specialists obtained informed consent from
PSTG 15 to procedures involving a catheter into the Right Internal Jugular (RIJ). The IG
Investigators reviewed Bay Surgical Specialist’s progress notes which stated on February 11,

Page 63
Observations
2019, “[PSTG 15] returns for an unscheduled appointment,” and under Chief Complaint listed, “I
am having problems with my fistula/shunt.”
The Bay Surgical Specialist progress notes listed a visit that occurred on February 20, 2019,
and referenced surgical procedures that occurred on February 12 and February 13, 2019. In
addition, the doctor obtained informed consent from PSTG 15 for a procedure involving a
catheter and anesthesia that occurred on September 25, 2019. The progress notes stated, “The
patient returns to the office for removal of a tunneled catheter… After obtaining informed
consent, the area of the RIJ was prepped.” The medical records indicated the same procedure
occurred before with informed consent on May 22, 2017. In that instance, Hudson documented
the visit in the Guardian Activity Log filed on August 16, 2017. The log listed Hudson went with
PSTG 15 to Dr. Almond on May 22, 2017.
Regarding the February 11, 2019, visit, the Guardian Activity Log filed on October 9, 2019,
documented on February 12, 2019, Hudson traveled to St. Anthony’s Hospital to “check on
condition of client [PSTG 15] following surgery.” There is no documentation that Hudson
attended the surgeries that took place on February 12 and February 13, 2019. Furthermore,
there were no Guardian Activity Logs available that would have documented whether or not
Hudson attended the September 25, 2019, visit, as the last Guardian Activity Log was filed on
October 9, 2019, and covered the time from February 3, 2019, through August 29, 2019.
The IG Investigators were unable to obtain a statement from Dr. Almond’s office after several
attempts for an interview to verify that Hudson did not consent to the aforementioned medical
procedures.
Based on Dr. Almond’s medical notes indicating the patient’s informed consent and the lack of
documented evidence that Hudson was present, PSTG 15 may have made a medical decision
she had no legal right to make without a complete understanding of the procedure, its benefits,
and contraindications. Consequently, PSTG 15 may have made a decision that was not in their
best interest.
§ 744.3215, Fla. Stat. (2017), states:
“(3) Rights that may be removed from a person by an order determining incapacity
and which may be delegated to the guardian include the right:
(f) To consent to medical and mental health treatment.”
§ 744.3215, Fla. Stat. (2017), states:
“(1) A person who has been determined to be incapacitated retains the right:
(a) To have an annual review of the guardianship report and plan.
(b) To have continuing review of the need for restriction of his or her rights.
(c) To be restored to capacity at the earliest possible time.

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Observations
(d) To be treated humanely, with dignity and respect, and to be protected

against abuse, neglect, and exploitation.
(e) To have a qualified guardian.
(f) To remain as independent as possible, including having his or her
preference as to place and standard of living honored, either as he or she
expressed or demonstrated his or her preference prior to the determination
of his or her incapacity or as he or she currently expresses his or her
preference, insofar as such request is reasonable.”
Standards of Practice 58M-2.009 state:
“(6) INFORMED CONSENT.

(a) Decisions that Professional Guardians make on behalf of their Wards
under guardianship shall be based on the principle of Informed Consent.
(b) Informed Consent is a decision maker’s agreement to a particular course
of action based on a full disclosure of the facts needed to make the decision
intelligently.
(c) To have Informed Consent, a decision maker must have adequate
information on the issue, must be able to take voluntary action, and must
not be coerced.
(d) In evaluating each requested decision, Professional Guardians shall do
the following:
1. Have a clear understanding of the issue for which informed consent
is being sought,
2. Have a clear understanding of the options, expected outcomes,
risks and benefits of each alternative,
3. Determine the conditions that necessitate treatment or action,
4. Maximize the participation of Wards in understanding the facts and
directing a decision, to the extent possible,
5. Determine whether a Ward has previously stated preferences in
regard to a decision of this nature,
6. Determine why this decision needs to be made now rather than later,
7. Determine what will happen if a decision is made to take no action,
8. Determine what the least restrictive alternative is for the situation;
and,
9. Obtain written documentation of all reports relevant to each
decision, if possible.”

Page 65
Observations
7. Guardian Sold PSTGs’ Properties Below

Market Value.
The IG Investigators reviewed all documentation related to the sale of PSTGs’ real properties.
The documentation inspected included Petitions and Orders regarding the sale of the PSTGs’
homes, the residential contracts and addendums, real estate property appraisal reports, MLS
records, Pasco and Pinellas County property records, and closing statements. The IG
Investigators obtained copies of the residential contracts, Housing and Urban Development
(HUD) statements, and other supporting documentation from the title companies.
The guardianship case documentation that was inspected indicated issues concerning the sales
of the following PSTGs’ real properties:
1. PSTG 36, property located at 8440 Fox Hollow Drive, Port Richey, Florida.
On April 3, 2017, the PSTG 36’s property was listed for $25,000 on the MLS database by Quyen
Trujillo (Trujillo), Realtor, Charles Rutenberg Realty, Inc., and went under contract on the same
day.
Hudson entered into an “As Is” Residential Contract on April 3, 2017, to sell PSTG 36’s property
before obtaining Court approval, as the Petition to Sell the PSTG’s property was filed on April
17, 2017, and approved by the Court on April 19, 2017. However, of note, the “As Is” Residential
Contract included additional terms that stated, “This contract is contingent upon approval from
the court.”
The Petition for Authority to Act and to Sell Ward’s Real Property (Petition) stated PSTG 36
resided at an assisted living facility, and the real estate property upkeep was a drain on her
assets. Therefore, it was in the best interest of the PSTG to allow Hudson to sell PSTG 36’s real
property and use the proceeds for PSTG 36’s benefit. Hudson stated in the Petition the selling
price was $30,450, while the comparable sales as of March 23, 2017, ranged from $45,000 to
$88,000. According to Hudson, $30,450 was a reasonable cash offer because the home was
uninhabitable and needed repairs and renovations. The buyer was L&E Property Holdings, Inc.
as trustee of the 8440 Fox Hollow Drive Land Trust. Hudson requested expedited Court approval
because the buyer wanted to close on May 5, 2017. On May 3, 2017, 3 real estate transactions
occurred involving PSTG 36’s real property:
• Transaction #1: Hudson, on behalf of PSTG 36, sold the property to the trustee, L&E
Property Holdings, Inc., for $30,450.
• Transaction #2: The Land Trust, also known as 8440 Fox Hollow Drive Land Trust with
L&E Property Holdings, Inc., sold the property to Graystone Investment Group, LLC, for
$37,000.

Page 66
Observations
• Transaction #3: Graystone Investment Group, LLC, sold the property to Toshi Hiraoka for
$57,984 ($27,534 more than the initial sale price).
The IG Investigator, who also was a licensed Realtor, completed a review of comparable
properties sold in the same timeframe and noted a sales range of $40,000 to $88,000. Note the
minimum comparable sales price was $40,000, as opposed to the $45,000, which Hudson
erroneously listed in the Petition. Based on this information, PSTG 36’s listing price of $25,000
was undervalued. There were 3 sales of PSTG 36’s property on the same day with the final sale
at $27,534 over the initial sale price, which further supports the initial listing of $25,000 was
undervalued.
2. PSTG 24, property located at 7714 Fox Hollow Drive, Port Richey, Florida 34668.
On April 3, 2017, the PSTG’s property was listed for $25,000 in the MLS database by Trujillo.
The property went under contract on the same day with L&E Property Holdings, Inc. as Trustee
of the 7714 Fox Hollow Dr. Land Trust.
Hudson entered into an “As Is” Residential Contract on April 3, 2017, to sell PSTG 24’s property
before obtaining Court approval, as the Petition to Sell the PSTG 24’s property was filed on May
25, 2017, and approved by the Court on May 30, 2017. However, of note, the “As Is” Residential
Contract included additional terms that stated, “this contract is contingent upon the Approval of
the court.”
The Petition for Authorization to Sell Ward’s Real Property (Petition) stated PSTG 24 resided at
an assisted living facility and would not return to the home. The Pasco County Property
Appraiser’s Office reflected the “just value” was $56,770, the “assessed value” was $37,894,
and the “taxable value” was $12,394. Hudson stated in the Petition the property was in
deplorable condition with mold and sanitation issues, and structural and cosmetic issues. Trujillo
assessed the cost of repair and renovation would be approximately $50,000. An investor made
an initial offer of $26,750 on or about April 3, 2017. On or about April 27, 2017, an addendum to
the contract was executed that changed the purchase price to $34,750. No MLS photos were
taken of the property’s interior due to its condition. Hudson and Trujillo believed the offer of
$34,750 was likely the highest amount for which the property would sell in “As Is” condition, as
the guardianship did not have sufficient liquid assets to improve the property to increase its
marketability.
On June 6, 2017, the following 2 real estate transactions occurred involving PSTG 24’s real
property:
• Transaction #1: Hudson, on behalf of PSTG 24, sold the property, which was deeded in
a Land Trust to the trustee of L&E Property Holding, Inc., for $34,750.

Page 67
Observations
• Transaction #2: The 7714 Fox Hollow Drive Land Trust (L&E Property Holdings, Inc.) sold
the property to a Florida corporation, Torcana USA, Inc., for $47,000 ($12,250 more than
the initial sale price).
On August 31, 2017, a third transaction occurred in which Torcana USA, Inc. sold the property
for $137,900 to the Fala River Family Trust, with Frank S. Lee and Lily L. Chang listed as co-
trustees. The value of the property increased by $103,150 in 86 days since Hudson originally
sold PSTG 24’s property due to rehab work completed by Torcana USA, Inc.
The IG Investigators did not note any irregularities or discrepancies when compared to what
Hudson had filed in the guardianship case. There were 2 sales of PSTG 24’s property on the
same day, with the final sale at $12,250 over the initial sale price, which supports the initial listing
price of $25,000 was undervalued.
3. PSTG 15, property located at 955 51st Street North, Unit 207 Saint Petersburg, Florida
33710.
On August 15, 2017, the property was listed on the MLS by Trujillo for $35,000 and went under
contract in 7 days. The property was a 2-bedroom, 1-bath condominium unit with 1,110 heated
square feet (sq. ft.).
The Petition For Authorization To Sell Ward’s Real Property filed on August 23, 2017, stated
PSTG 15 resided in an assisted living facility, required 24-hour care, and could not return to the
property. The PCPA’s office listed the market value of the property at $27,414 and the sale
comparison value at $32,252. In addition, Hudson stated the comparable properties sold in the
range of $35,000 to $49,000.
Of note, Trujillo provided her own 1-page market analysis summary document to justify the listing
price, including 2-bedroom, 1-bath properties that sold for $40,750 and $45,000, respectively.
These sales both were over 90 days old. In addition, Trujillo listed PSTG 15’s condominium for
the minimum value related to a 1-bedroom, 1-bath condominium, 875 sq. ft., with a $40 per sq.
ft. value (875 sf. ft. x $40= $35,000). There were 2 such properties listed on Trujillo’s market
analysis document that sold on April 13, 2017, and May 15, 2017, for $35,000 ($40 per sq. ft.)
each. PSTG 15’s condo was 1,110 sq. ft. Therefore, the minimum value using Trujillo’s per sq.
ft. value should have been $44,400 (1,110 sq. ft. x $40 = $44,400), $9,400 more than the original
listing price.
The IG Investigator, who also was a licensed Realtor, located 2 comparable condominiums sold
in the same timeframe. Of those properties, 1 property sold for $74,000 ($39,000 more than the
subject condo), and the other sold for $69,900 ($34,900 more than the subject condo).

Page 68
Observations
The home closed on October 24, 2017, for a sale price of $35,000 to a husband and wife, Ken
and Kristen Chadbourne. The listing had several pictures which indicated the condominium had
old or removed carpeting, dated wallpaper, and older appliances.
The subject property was sold on February 13, 2018 (112 days after the initial sale). The new
MLS listing included multiple pictures of the unit and noted the property had new flooring, fresh
paint, a kitchen with all new cabinets, granite countertops, all new appliances, and a completely
remodeled bathroom. The list price was $74,900, and the condo sold on February 13, 2018, for
$71,250, less than 1 month after the re-listing. This was a $36,250 increase over the original
price received for PSTG 15’s property. Based on the improvements visible in the pictures listed
on MLS, the new sales price was justified and in line with the comparable properties. The
property was sold a third time for $75,000 on December 3, 2018.
The IG Investigator noted the comparable sales indicated PSTG 15’s home was listed under
value by at least $9,400. While the subject property’s initial listing revealed the need for updated
flooring and appliances, since the building is a condominium, any major structural issues and
repairs would be covered by the association leaving cosmetic repairs and desired updates to a
new buyer.
4. PSTG 16, property located at 2672 Braeburn Drive, Largo, Florida.
Initially, this property was listed by Denise Povolish (Povolish), Realtor, Luxury & Beach Reality,
Inc., for $60,000 and went under contract on December 30, 2017, before listing the property in
the MLS, with a proposed closing date of January 31, 2018. The IG Investigators obtained the
sales contract from the title company which listed the buyer as Davis Brooks (Brooks), and the
sale amount was redacted. At the time of the listing, Povolish was a GAPC Board Member and
Hudson was President of the GAPC. The selling agent was Brooks, who was also the listed
buyer. The IG noted the property entered a contract before Court approval. However, the
contract stated, “Contingent on Court approval.”
On January 2, 2018, the property was listed on MLS by Povolish for $60,000. The MLS reflected
the property went under contract with Brooks on January 3, 2018, which is different than the
original contract date of December 30, 2017. At the time of the contract, PSTG 16’s property
was in debt to 2 real estate mortgages, totaling $68,442.32, at closing, and PSTG 16 was
deemed indigent by the Court. The IG found that, while under a sales contract with Brooks,
Hudson filed a Petition to Abandon PSTG 16’s property on February 9, 2018. The Petition to
Abandon the Property was ultimately rescinded, and a second sales contract was prepared on
March 15, 2018. The second sales contract listed the property to be sold to Trust No. 2672,
Trustee Asset Services, LLC as trustee, as the buyer with a sales price of $80,000. The proposed
closing date on the contract was April 18, 2018. Hudson filed the Petition for Authorization to
Sell the PSTG’s property on April 19, 2018, and it was approved by the Court on April 24, 2018.

Page 69
Observations
In the Petition, Hudson stated PSTG 16 was residing in the nursing home and was not expected
to return home. The Petition did not include any information from the PCPA’s office regarding
the property value; however, the Petition mentioned disrepairs and code enforcement violations,
including potential squatters. A property appraisal dated December 22, 2017, completed by
Patricia Smith, represented the value of the property at $55,000.
PCPA records, the Title Company records, and guardianship records confirmed PSTG 16’s
house was sold on May 18, 2018, to Trust No. 2672, trust dated January 31, 2018, Trustee Asset
Services, LLC as Trustee for $80,000. After deductions such as 2 mortgages, settlement and
title charges, County taxes, and commissions, PSTG 16 received $3,588.76.
The IG found 3 commissions were paid at closing. The commissions totaled $6,070, or
approximately 7.6% of the sales price, as agreed upon in the sales contract:
• Luxury and Beach Realty (Povolish) $2,070

• Keller Williams of St. Petersburg Realty (Brooks) $2,000
• Azimuth Realty Group $2,000
After the sale of PSTG 16’s property, Trust 2672 UTD 01/31/18, Trustee Asset Services, LLC
sold the property on June 22, 2018, to Diana Riggs, for $135,000, $75,000 over the initial listing
price and $55,000 over the initial sale amount. The IG Investigators reviewed the City of Largo
permit records and did not find any documented home improvements that would require a city
permit and increase the property’s value.
Since the property of the PSTG 16 was sold 35 days after the initial sale with an increased value
of $55,000 with no substantial documented improvements, the IG Investigators identified the
original buyer, James Kasper of Trust Asset Services, LLC, and interviewed him. Kasper is a
real estate investor and licensed building contractor who regularly buys, renovates, and sells
properties for a living.
Kasper provided the following information:
• The 2672 Brae Burn deal was brought to him by Robert Melsom, a licensed real estate
broker.
• He had no knowledge of Povolish or Brooks and had no recollection of working with either
in the past.
• The initial sales price was $65,000 but was increased to $80,000 before closing. He
agreed to the increase because the deal was still profitable to him.
• The home had a lot of overgrowth outside and described the inside of the property as
“wet.” He performed the following: tree work, a garage door repair, cleaned the
overgrowth, cleaned out the home, and exterminated vermin. He described the house as
full of belongings and drug paraphernalia but “not quite a hoarder” house.
• Rather than rehabilitate the home, he was able to quickly flip it to another investor for a
profit.

Page 70
Observations
• Trust No. 2672 UTD 01/31/18 is wholly owned by Kasper and his company.
• He buys properties with his business partner in Trustee Asset Services, LLC, Christopher
Babcock, and places all his investment properties into trusts at the time of purchase as a
normal course of business.
• He had no prior knowledge of Hudson.
The IG Investigators noted that PSTG 16’s property was listed $80,000 and sold $55,000 under
value.
5. PSTG 4, property located at 301 41st Avenue North, Saint Petersburg, Florida 33703.
The property was listed on April 27, 2018, for $170,000 and sold on July 17, 2018, to Bay to Gulf
Holdings, LLC for $192,000.
The IG Investigators obtained copies of the residential contract, HUD statement, and other
supporting documentation from the title company, including email communications between
Hudson, the Realtor, and the title company. The IG Investigators did not note any irregularities
or discrepancies when compared to the documentation Hudson had filed in the guardianship
case.
PSTG 4’s home was professionally appraised by Stephen Larson, a Certified Residential
Appraiser, with an appraised value of $170,000. The PSTG’s home was in disrepair, with an
outdated kitchen, bathrooms, appliances, and poor curb appeal. The IG Investigator, a Realtor,
accessed similar properties in the MLS to compare to PSTG 4’s home. The nearby comparables
chosen for the analysis were valued at $249,900 and $270,000 due to being in a significantly
better condition than PSTG 4’s home.
The IG Investigators interviewed Kristie Jordan (Jordan), Achieve Title Services Office Manager,
who stated she had a long-lasting relationship with Bay to Gulf Holdings, LLC. Jordan described
Bay to Gulf Holdings, LLC, as a company specializing in real estate rehabs and flips of distressed
investment properties. Jordan stated she had never dealt with Hudson or Hudson’s Realtor,
Povolish, and was unaware of any transactions between Hudson and Bay to Gulf Holdings, LLC
in the past. Povolish was a listing and selling agent for this transaction and earned a 6%
commission on the original sale of PSTG 4’s home. The IG Investigators noted Barber notarized
2 affidavits within the Settlement Statement.
The IG Investigators determined Bay to Gulf Holdings, LLC sold the house directly to Gallagher
Services, LLC, on August 3, 2018 (within 17 days from the original sale and with no known
improvements), for $230,000, a $38,000 increase from the initial sale price of PSTG 4’s property.
The IG Investigators noted PSTG 4’s property was listed $60,000 under value although in
agreement with the professional appraisal.

Page 71
Observations
During our investigation, a Florida Department of Law Enforcement investigator provided the IG
Investigators with a tip that Hudson transferred the properties of persons she cared for into trusts
shortly before the properties were sold to a developer. In all the transactions listed above, the
IG Investigators did not find evidence to prove or disprove any inappropriate connection between
Hudson and the developers.
As a result, the Guardian acted in a manner contrary to the PSTGs’ interest which resulted in
PSTGs incurring losses due to undervalued sales of their real properties.
§ 744.361, Fla. Stat. (2015), state:
“(1) The guardian of an incapacitated person is a fiduciary and may exercise only
those rights that have been removed from the ward and delegated to the
guardian….
under the circumstances.”
8. Guardian Did Not Comply With Order To

Vacate.
During the review of the guardianship files, the IG Investigators noted Hudson did not reimburse
PSTG 32 for $2,922 in guardianship fees per a Court order to vacate.
On November 7, 2019, the Court approved Hudson’s Petition for Guardian Fees for the period
March 4, 2019, to September 30, 2019, in the amount of $2,922. Upon review of PSTG 32’s
Achieva bank records, the IG found Hudson wrote herself Check No. 1661 on November 13,
2019, in the amount of $2,922, and the check was cashed on November 15, 2019. The
handwritten note in the memo section of the check stated: “Fees: 3/4/19-9/30/19.”
On November 19, 2019, the Court adjudged an Order Vacating Order Authorizing Payment of
Guardian’s Fees and Costs, that stated:
“THIS CAUSE having come before the Court on review of the court file. An Order
Authorizing Payment of Guardian’s Fees and Costs was signed inadvertently on

Page 72
Observations
November 7, 2019 and it is ORDERED that the Order Authorizing Payment of

Guardian’s Fees and Costs signed on November 7, 2019 is hereby vacated.”
Since the order authorizing payment of guardian fees was vacated, the guardian fee payment
authorization was canceled, and the guardian was obligated to refund PSTG 32.
Upon further review of the successor guardian’s inventory and accountings, the IG Investigators
noted no refund for the revoked guardian fees from Hudson to the PSTG 32. There is no
evidence in the guardianship case records that Hudson returned the revoked Court order
guardian fees in the amount of $2,922.
As a result, PSTG 32 is at a loss of $2,922 since Hudson did not reimburse the PSTG 32
pursuant to the November 19, 2019, Court order that revoked Hudson’s Guardian Fees.
§ 744.108, Fla. Stat. (2015), states:
“(1) A guardian, or an attorney who has rendered services to the ward or to the
guardian on the ward’s behalf, is entitled to a reasonable fee for services rendered
and reimbursement for costs incurred on behalf of the ward.
(2) When fees for a guardian or an attorney are submitted to the court for
determination, the court shall consider the following criteria:
(a) The time and labor required;
(b) The novelty and difficulty of the questions involved and the skill required
to perform the services properly;
(c) The likelihood that the acceptance of the particular employment will
preclude other employment of the person;
(d) The fee customarily charged in the locality for similar services”
9. Guardian Did Not Pay Off Credit Card

Debt As Ordered By Court.
Upon inspection of PSTG 27’s guardianship records, the IG Investigators noted Hudson did not
comply with the Court order to pay off PSTG 27’s credit card debt.
Hudson petitioned the Court on June 5, 2019, to pay off PSTG 27’s credit card balance of
$16,580.59. On June 11, 2019, the Court adjudicated the order. However, Hudson did not pay
off the credit card by the time of her removal in November 2019. A credit card balance of
$15,805.07 remained, which included a $39.00 late fee and $119.94 in interest charges for
October 20, 2019 through November 19, 2019.

Page 73
Observations
Based on the October 20, 2019 through November 19, 2019 credit card statement reviewed, the
PSTG incurred unnecessary interest totaling $1,361.48 and $271.00 in late fees, a total of
$1,632.48 in 2019.
§ 744.446, Fla. Stat. (2002), states:
“(4) In the event of a breach by the guardian of the guardian’s fiduciary duty, the
court shall take those necessary actions to protect the ward and the ward’s assets.”
FAC 58M-2.009, Standards of Practice, (17)(g) states:
“Professional Guardians appointed guardian of the property shall manage the

estate only for the benefit of the Ward or as directed by the Court.”
10. Guardian Did Not Explain Her

Disagreement With A Medical Provider’s
Opinion On A PSTG’s Capacity.
The IG Investigators noted Hudson did not explain her stance on the physician’s opinion
regarding PSTG 15’s capacity.
Hudson elected to disregard the Annual Physician Statement filed by PSTG 15’s primary care
physician, Doctor Benjamin Abinales (Dr. Abinales), on July 3, 2019, by not pursuing restoration
of some or all of PSTG 15’s rights. Dr. Abinales indicated PSTG 15 had the capacity and
capabilities to exercise all rights. There is no record Hudson acted to restore PSTG 15’s rights
based on the Annual Physician’s Statement. Hudson did not explain, as required in the Annual
Plan Section 7, why she disagreed with the physician’s level of capacity evaluation.
Hudson previously objected to the restoration of PSTG 15’s rights on October 3, 2018, after the
Court motioned on its own to suggest capacity on October 1, 2018. During the hearing on the
Suggestion of Capacity, held on November 26, 2018, Hudson stated she felt PSTG 15’s health
would decline if PSTG 15 was able to consent to medical treatment. She explained PSTG 15
has several health issues and becomes overwhelmed and unable to comprehend the medical
information needed to make an informed decision regarding treatment. On November 27, 2018,
the Court adjudicated partial restoration of rights restoring PSTG 15’s right to make decisions
about the environment and/or other social aspects of life and the right to vote. Of note, the
successor guardian (AAR) filed a Suggestion of Capacity on September 10, 2021. The Court
ordered an Appointing Physician to assess PSTG 15 on November 22, 2021. However, the Court
adjudicated an Order Denying Restoration on January 19, 2022.

Page 74
Observations
Hudson not explaining her disagreement with the medical provider’s opinion on PSTG 15’s
capacity was contrary to the Annual Plan requirement as stated in § 744.3675, Fla. Stat. (2006),
and not in the best interest of PSTG 15.
§ 744.3675, Fla. Stat. (2006), states:
“Annual guardianship plan….

(3) Each plan for an adult ward must address the issue of restoration of rights to
the ward and include:
(b) A statement of whether the ward can have any rights restored.
(c) A statement of whether restoration of any rights will be sought.”
§ 744.3215, Fla. Stat. (2017), states:
“(1) A person who has been determined to be incapacitated retains the right:
(b) To have continuing review of the need for restriction of his or her rights.
(c) To be restored to capacity at the earliest possible time.”
§ 744.1012, Fla. Stat. (2016), states:
“(1) Adjudicating a person totally incapacitated and in need of a guardian deprives

such person of all her or his civil and legal rights and that such deprivation may be
unnecessary.
(2) It is desirable to make available the least restrictive form of guardianship to

assist persons who are only partially incapable of caring for their needs and that
alternatives to guardianship and less restrictive means of assistance, including,
but not limited to, guardian advocates, be explored before a plenary guardian is
appointed.”
Standards of Practice: 58M-2.009 state:
“(8) LEAST RESTRICTIVE ALTERNATIVE.
(a) When making a decision, Professional Guardians shall carefully

evaluate the ward’s resources and the alternatives that are available and
choose the one that best meets the personal and financial goals, needs,
and preferences of Wards under their guardianship, while placing the least
restrictions on their Wards’ freedoms, rights, and ability to control their
environments….
(d) The following guidelines apply in the determination of the least restrictive
alternative:
2. Professional Guardians shall strive to know their Wards’ goals and
preferences.

Page 75
Observations
3. Professional Guardians shall consider assessments of their

Wards’ needs as determined by specialists. This may include an
independent assessment of a Ward’s functional ability, health status,
and care needs.”
Standards of Practice: 58M-2.009 state:
“(21) TERMINATION AND LIMITATION OF PROFESSIONAL GUARDIANSHIP….

(b) Professional Guardians shall seek termination or limitation of the guardianship in the
following circumstances:
3. When a Ward expresses the desire to challenge the necessity of all or part of
the guardianship.”

Page 76

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DIVISION OF INSPECTOR GENERAL

Ken Burke, CPA

INVESTIGATION OF FORMER PROFESSIONAL

November 10, 2022

Honorable Judge Pamela Campbell, Florida Sixth Judicial Circuit Court

This investigative report is a summary of a comprehensive examination of the 45 guardianship

• Substantiated – An allegation is substantiated when there is sufficient evidence to justify

cc: Honorable Judge Sherwood Coleman, Florida Sixth Judicial Circuit

INVESTIGATIVE CONCLUSIONS DETAILS 26

1. Guardian Submitted Altered Documents To The Court. 26

1. Guardian Did Not Maintain Clear And Accurate Guardianship Records. 57

FFC Florida Family Cremations, Incorporated

FGSI Florida Guardianship Services, Incorporated

Public Integrity Unit, Division of Inspector General

PCPA Pinellas County Property Appraiser

Public Integrity Unit, Division of Inspector General

Public Integrity Unit, Division of Inspector General

(3) The guardian shall act in good faith.

The Florida Probate Code Manual § 20.01 (2022), states:

Public Integrity Unit, Division of Inspector General

Hudson’s Guardianship Business

Hudson incorporated and registered Florida Guardianship Services, Incorporated (FGSI)

1. Baylie Barber also known as Baylie Dressman (Barber), Hudson’s daughter

Public Integrity Unit, Division of Inspector General

Chart 1 - Total Disbursements to Hudson’s Assistants from PSTGs’ Assets

Public Integrity Unit, Division of Inspector General

Statistical Snapshot of Hudson’s Guardianships

Public Integrity Unit, Division of Inspector General

Hudson's Guardianship Case List Hudson's Guardianship Case List

Public Integrity Unit, Division of Inspector General

Public Integrity Unit, Division of Inspector General

Public Integrity Unit, Division of Inspector General

Chart 3 - Breakdown of Disbursements from PSTGs’ Assets per Expense Category

• On November 19, 2019, Hudson voluntarily withdrew her professional guardian

• On November 25, 2019, Hudson dissolved FGSI.

Public Integrity Unit, Division of Inspector General

Public Integrity Unit, Division of Inspector General

• Reviewed various guardianship related documentation in the Court file.

• Inspected original records and supporting documentation, including receipts at Hudson’s

• Interviewed witnesses with knowledge of facts.

• Attempted to interview Hudson.

Public Integrity Unit, Division of Inspector General

• 03/02/2020 - IG met with SSA

• 11/25/2019 - Hudson • 10/09/2020 - IG interviewed

• 10/30/2020 - IG met Hudson

• 12/08/2020 - IG followed up with

• 12/29/2020 - Court hearing

Public Integrity Unit, Division of Inspector General

• 02/04/2021 - IG interviewed PSTG

• 02/10/2021 - IG met with the

• 03/10/2021 - IG and PCSO

• 05/07/2021 - IG completed review of

• 06/29/2021 - Hudson arrested and

Public Integrity Unit, Division of Inspector General

• Substantiated – An allegation is substantiated when there is sufficient evidence to

Public Integrity Unit, Division of Inspector General

These cases are as follows:

Public Integrity Unit, Division of Inspector General