After the bankruptcy was discharged, Sullivan’s conduct in the case, as well as other disputes, became a matter for state professional regulators.
Between 2004 and 2007, the Florida Department of Business and Professional Regulation received three complaints against Sullivan in her accounting practice. The first dispute resulted in a 2004 administrative complaint that tracked the findings of the bankruptcy judge, accusing Sullivan of “knowingly misrepresenting facts.”
A 2006 administrative complaint accused Sullivan of preparing an “incomplete and incorrect” tax return for a client that contained “multiple errors,” and then failing to return many of the client’s records. In a settlement, regulators dropped a 2007 complaint that accused Sullivan of failing to repay a $70,000 loan, but placed Sullivan on probation, and ordered her to pay a $5,000 fine and $2,500 in administrative costs to resolve the 2004 and 2006 complaints.
Brieant attributes the professional discipline to an “orchestrated” vendetta by Walker and his lawyers. Sullivan, she said, settled the two cases “solely in the interest of stopping the endless and prohibitively costly litigation initiated by [the] debtor’s counsel.”
Sullivan did not register BEST with the state until early 2012. About that time, state lawmakers passed a law encouraging police to seek treatment for children who worked as prostitutes rather than prosecute them.
As child-welfare advocates devise strategies for treating the victims of trafficking, prosecutors have beefed up their efforts targeting the pimps. This summer, Miami prosecutors charged four men with luring foster children from a group home into prostitution — giving them cash and cellphones while they provided sexual favors at a Homestead brothel.
BEST has garnered what could become a significant piece of business: It is listed as a subcontractor on a $908,758 grant awarded by the U.S. Department of Health and Human Services to Atlanta-based Tapestri, which provides treatment and legal services to human-trafficking victims.
“From scratch, Ms. Sullivan, along with legal professionals and past and present law-enforcement officials, [has] designed a unique program aimed not only to assist directly the juvenile sex-trafficking victims but to facilitate the flow of important law-enforcement information to authorities in order to help attack the predatory exploitation of those who traffic children,” Brieant wrote.
BEST’s model differs from others in Florida and elsewhere: Rather than admitting the girls into sexual-abuse treatment programs, BEST supplies what it calls specially trained “coaches” to help the teens recover from their trauma. The group also provides to each girl a lawyer familiar with sex trafficking.
But in recent months, Sullivan and other leaders have drawn criticism. In July, the leader of There Is Hope for Me, a Coral Springs shelter, contacted DCF. The group’s president, Katarina Rosenblatt, emailed that a BEST representative discouraged her from contacting “ANYONE within law enforcement or working with the FBI or calling the [DCF] abuse hotline.”
State law requires most Floridians to call the hotline when they suspect a child has been abused or neglected.
Brieant said that never happened. “BEST has never told anyone, including any community providers, to call BEST first and not the police or the DCF hotline,” Brieant wrote.
Meetings with high-ranking DCF administrators, as well as leaders of Miami’s privately run foster-care agency, Our Kids, have done little to improve relations between BEST and the state.
In an email to a boss in Tallahassee, Jacobo, the DCF managing director in Miami, wrote:
• Sullivan has claimed that she is a “certified human trafficking coach” with a diploma from the Certified Coaches Alliance. But Tyson Elliott, DCF’s trafficking coordinator, who wrote that he contacted the alliance, said the group provides “certification in coaching, not in any specific field.”
• Though BEST’s website says the group operates a safe house or emergency shelter, Sullivan acknowledged that BEST refers its clients to a domestic-violence shelter run by another group.
• Sullivan had trouble providing any details about a “hotline” her group staffed for victims of human trafficking. “I wanted to know who answered the hotline and what training they were given before answering the hotline,” Jacobo wrote in her Sept. 5 email. “Ms. Sullivan wanted to know why I asked . . . She stated that lawyers answered the hotline. When I asked who, she would not say.”
Jacobo said two meetings with Sullivan “did nothing to alleviate my concerns and those of Our Kids. If anything, more questions are raised.”