Florida State Bar 2016.8.31 Emergency Suspension Christopher M. Chestnut

IN THE SUPREME COURT OF FLORIDA
THE FLORIDA BAR,
Supreme Court Case No.

SC-
Petitioner,
The Florida Bar File No.
2017-00,098(4D)NES
v.
CHRISTOPHER M. CHESTNUT,
Respondent.
_____________________________/
PETITION FOR EMERGENCY SUSPENSION

This petition of The Florida Bar seeks emergency relief and requires the
immediate attention of the Court pursuant to R. Regulating Fla. Bar 3-5.2. The
Florida Bar seeks the emergency suspension of Christopher M. Chestnut, Attorney
No. 22409, from the practice of law in Florida based on facts that establish clearly
and convincingly that respondent appears to be causing great public harm as will
be shown by facts supported by the record and the affidavits of Anthony D. Jordan,
Sr., and Matisha Ward attached hereto and incorporated herein as follows:
1.
The filing of this Petition for Emergency Suspension has been
authorized by the Executive Director of The Florida Bar.

2.
Respondent, Christopher M. Chestnut, is and at all times hereinafter
mentioned, was a member of The Florida Bar and otherwise subject to the
jurisdiction and disciplinary rules of the Supreme Court of Florida.
3.
Respondent is currently the subject of nine bar disciplinary matters
which have been identified as:

A.
SC16-797, The Florida Bar File Nos. 2015-00,161(4B), 2015-00,505
(4C), 2015-00,565(4D), 2016-00,047(4C), 2016-00,193(4A) & 2016-00,229(4B);

B.
SC16-1480, The Florida Bar File Nos. 2016-00,473(4B) & 2016-
00,517(4D); and,
C.
The Florida Bar File No. 2017-00,098(4D) the instant file.
4.
The bars investigation of respondent reveals the following history:
A.
On September 26, 2014, The Florida Bar filed a four-count complaint
against respondent alleging among other things, lack of competence, candor,

diligence, and communication, solicitation, dishonesty, and excessive fee.
B.
In that case, although the bar voluntarily dismissed three counts,
respondent was found guilty of lack of diligence and communication.

C.
As a result, respondent received a public reprimand on October 8,
D.
Thereafter, on May 6, 2016, the bar filed a six-count complaint
2015.
(SC16-797) against respondent alleging egregious conduct involving among other

things, lack of competence, candor, diligence, and communication, solicitation,
dishonesty, failure to supervise, and excessive fee.
E.
Count I, TFB File No. 2015-00,161(4B), Lakay Smith, alleges that
respondent neglected Ms. Smiths Georgia case despite not being admitted in
Georgia and that he discontinued his representation in the case two weeks before
the statute of limitations expired.
F.
Count II, TFB File No. 2015-00,505(4C), The Florida Bar, alleges
that respondent schemed to defraud his own client out of settlement funds by
attempting to have two state court judges, unconnected to the proceedings, enter an
ex parte order authorizing his increased share of settlement funds obtained in a
federal case. Respondent also tried to coerce his client into retroactively agreeing
to his increased fee resulting in the client being forced to sue respondent in order to
get his money. In that case, after trial, the jury found that respondent committed
civil theft, breached his fiduciary duty, and exploited his client. Jury Finding
attached as Exhibit A.
G.
Count III, TFB File No. 2015-00,565(4D), Johnny Winthrop Powell,
alleges that respondent undertook to represent Mr. Powell in Maryland even

though respondent is not licensed in Maryland. And as a result of respondents
neglect and his failure to comply with Maryland law, Mr. Powells claims against
the state were barred and lost forever and the statute of limitations ran. Mr. Powell
sued respondent for malpractice in federal court resulting in a settlement.
H.
Count IV, TFB File No. 2016-00,047(4C), Andrew Levy, alleges that
respondent neglected Mr. Levys case for years and then discontinued his
representation close to the end of the statute of limitations.
I.
Count V, TFB File No. 2016-00,193(4A), Dr. John T. Hoehn, alleges
that after signing a letter of protection, respondent ignored his obligation to pay for
years and then only remitted a partial payment that was rejected.
J.
Count VI, TFB File No. 2016-00,229(4B), Kashara Taylor, alleges
that respondent neglected Ms. Taylors case for years resulting in its dismissal.
K.
The foregoing Counts, comprising SC16-797, are in active litigation
and scheduled for final hearing starting December 12, 2016.

L.
On August 16, 2016, the bar filed a new two-count complaint (SC16-
1480) against respondent alleging lack of competence, candor, and

communication, solicitation, dishonesty, failure to supervise, and excessive fee.
M.
Count I, TFB File No. 2016-00,473(4B), Anthony D. Jordan, Sr.,
alleges that respondent solicited two clients Ms. Berry and Mr. Jordan. When Mr.
Jordan declined respondents services, respondent caused Ms. Berry to file false
petitions with the Georgia probate court alleging that Mr. Jordans whereabouts
were unknown. This allegation was patently false since respondent had already
contacted Mr. Jordan and had signed him up as a client. As a result of respondents
conduct, Mr. Jordan was prevented from participating as guardian for his sons

wrongful death claim.
N.
When the Georgia probate court realized what respondent had done, it
entered its order finding that respondent:

although not a member of the State Bar of Georgia, was
practicing law in the state of Georgia and knew, or
should have known, that Ramona Berry was never going
to be individually entitled to any proceeds from the
wrongful death of Deidre Spear, that Ramona Berry was
never going to be a beneficiary of the Estate of Deidre
Spear because Ms. Spear died intestate and her only heir
was her minor son, and that Ramona Berry was not the
Personal Representative of the Estate of Deidre Spear on
either February 24, 2014 or February 25, 2014. The
contract with Universal Funds was negotiated between
Universal Funds and [respondent]. Ramona Berry never
defrauded, misrepresented or deceived anyone; she never
received any money and was not entitled to receive any
money from the wrongful death of her daughter in any of
the capacities listed on the contract of February 24, 2014
or February 25, 2014. The contract negotiated between
Universal Funds and [respondent] with a $3,050
origination/ processing fee and a 35.40% APR was
unconscionable under the circumstances even if Ms.
Berry had authority under any of the listed capacities,
which she did not. Copy of Georgia Probate Court order
attached as Exhibit B.
O.
As a result of respondents actions, Mr. Jordan filed his grievance
with the bar and his Affidavit which details the history of his case and respondents
wrongdoing. Copy attached as Exhibit C.
P.
In the Georgia Probate Court, Mr. Jordan also filed his Petition for
Removal of Conservator and for an Accounting. Copy attached as Exhibit D.

Q.
Count II, TFB File No. 2016-00,517(4D), Toni Washington, alleges
that respondent solicited Ms. Washington, undertook her representation, settled the
case without fully explaining the terms to his client, and disbursed funds without a
proper settlement statement causing the client to file her grievance.
R.
The foregoing Counts, comprising SC16-1480, are in active litigation
and scheduled for case management conference on September 22, 2016.

5.
In the instant case, TFB File No. 2017-00098(4D), on August 23,
2016, respondent was sued in Texas. That complaint alleges that respondent is
guilty of barratry, solicitation, civil conspiracy, joint enterprise & partnership
liability, agent and respondeat superior. Copy attached as Exhibit E.
A.
That complaint begins with
TO THE COURT AND JURY. THE DARKEST HOUR
IN ANY MANS OR WOMANS LIFE IS WHEN

THEY SIT DOWN TO SCHEME AND PLAN HOW
TO GET MONEY WITHOUT LAWFULLY EARNING
IT. THE CRIMNAL CONDUCT COMPLAINED OF
HEREIN DEMANDS A JURYS WRATH.
B.
The facts in this case are particularly egregious:
In Dallas, a woman was tragically killed by a pack of
dogs. While she lay dying in ICU, the womans daughter,

Matisha Ward, received a text from a previously
unknown Dallas City Councilwoman offering sympathy
and prayers. This same Councilwoman continued
6
contacting the daughter thereafter and eventually put

respondent on the phone to talk to the daughter who
declined his services. The record reveals that the
Councilwoman and respondent are college friends.
C.
Respondent is not admitted in Texas and he also misrepresented
himself as a Georgia attorney.

D.
The texts from the Councilwoman are part of the underlying record as
is the recording of respondent himself repeatedly offering his services to the

daughter. Transcript of respondents conversation with Ms. Ward is attached as
part of Ex. F.
E.
Both the texts and respondents recording were broadcast to the
general public in news stories that have garnered national attention.

F.
In that case, respondent has not denied the allegations.
G.
Instead, respondent is on record as saying I perceive it as Ms. Young
[the Councilwoman] trying to help a constituent who just lost her mom tragically
in a horrific death. . . . She was just following with the lady to see if I could help.
H.
And respondents conduct in that case was just a few days after the
bar filed SC16-797.

I.
In support of her complaint, Ms. Wards affidavit details the history of
her case and respondents wrongdoing. Copy attached as Exhibit F.
J.
Evidently, respondent does not understand The Rules Regulating The
Florida Bar, does not think the Rules apply to him, and/or is flagrantly disregarding
the Rules despite knowing that his conduct is being scrutinized.
6.
The foregoing Exhibits and the attached affidavits of Anthony D.
Jordan and Matisha Ward are used by the bar to support this Petition for
Emergency Suspension.
7.
By reason of the foregoing, respondent has violated the following
Rules Regulating The Florida Bar: 4-1.1 (Competence), 4-1.7(a)(2)(Conflict of

interests), 4-2.1(Adviser), 4-5.5(a) (Unlicensed practice of law), 4-7.18(a)(Direct
contact with prospective clients), 4-8.4(a)(Misconduct), and 4-8.4(c)(Conduct
involving dishonesty, fraud, deceit or misrepresentation).
WHEREFORE, based on the aforementioned facts, the bar asserts that
respondent has caused, is continuing to cause, and is likely to continue causing,
immediate and serious harm to clients and/or the public and that immediate action
must be taken for the protection of respondents clients and the public. Therefore,
pursuant to R. Regulating Fla. Bar 3-5.2, The Florida Bar respectfully requests this
Court to:
A.
Suspend respondent from the practice of law until further order of this
Court.
B.
Order respondent to accept no new clients from the date of this
Courts order and to cease representing any clients after 30 days from the date of
this Courts order. In addition, respondent shall cease acting as personal
representative for any estate, as guardian for any ward, and as trustee for any trust
and will seek to withdraw from said representation within 30 days from the date of
this Courts order and will immediately turn over to any successor the complete
financial records of any estate, guardianship or trust upon the successors
appointment.
C.
Order respondent to furnish a copy of the suspension order to all
clients, opposing counsel and courts before which respondent is counsel of record
as required by Rule 3-5.1(h) of the Rules of Discipline of The Florida Bar and to
furnish Staff Counsel with the requisite affidavit listing all clients, opposing
counsel and courts so informed within 30 days after receipt of the Courts order.
D.
Order respondent to refrain from withdrawing or disbursing any
money from any trust account related to respondents law practice until further
order of this Court, a judicial referee appointed by this Court or by order of the
Circuit Court in an inventory attorney proceeding instituted under R. Regulating
Fla. Bar 1-3.8, and to deposit any fees, or other sums received in connection with
the practice of law or in connection with the respondents employment as a
personal representative, guardian or trustee, paid to the respondent after issuance of
this Courts order of emergency suspension, into a specified trust account from
which withdrawal may only be made in accordance with restrictions imposed by

this Court. Further, respondent shall be required to notify bar counsel of The
Florida Bar of the receipt and location of said funds within 30 days of the order of
emergency suspension.
E.
Order respondent not withdraw any money from any trust account or
other financial institution account related to respondents law practice or transfer

any ownership of any real or personal property purchased in whole or in part with
funds properly belonging to clients, probate estates for which respondent served as
personal representative, guardianship estates for which respondent served as
guardian, and trusts for which respondent served as trustee without approval of this
Court, a judicial referee appointed by this Court or by order of the Circuit Court in
an inventory attorney proceeding instituted under R. Regulating Fla. Bar 1-3.8.
F.
Order respondent to notify, in writing, all banks and financial
institutions where the respondent maintains an account related to the practice of

law, or related to services rendered as a personal representative of an estate, or
related to services rendered as a guardian, or related to services rendered as a
trustee, or where respondent maintains an account that contains funds that
originated from a probate estate for which respondent was personal representative,
guardianship estate for which respondent was guardian, or trust for which
10
respondent was trustee, of the provisions of this Courts order and to provide all
the aforementioned banks and financial institutions with a copy of this Courts
order. Further, respondent shall be required to provide bar counsel with an
affidavit listing each bank or financial institution respondent provided with a copy
of said order.
G.
Order respondent to immediately comply with and provide all
documents and testimony responsive to a subpoena from The Florida Bar for trust
account records and any related documents necessary for completion of a trust
account audit to be conducted by The Florida Bar.
H.
And further to authorize any Referee appointed in these proceedings
to determine entitlement to funds in any trust account(s) frozen as a result of an

Order entered in this matter.
Respectfully submitted,
Carlos Alberto Leon, Bar Counsel

The Florida Bar
651 East Jefferson Street
Tallahassee, Florida 32399-2300
(850) 561-5845
Florida Bar No. 98027
cleon@flabar.org
11
ADRIA E. QUINTELA
Staff Counsel
The Florida Bar
Lakeshore Plaza II, Suite 130
1300 Concord Terrace
Sunrise, Florida 33323
(954) 835-0233
aquintel@flabar.org
/s/ John F. Harkness, Jr.
JOHN F. HARKNESS, JR.
Executive Director
The Florida Bar
651 East Jefferson Street
Tallahassee, Florida 32399-2300
(850) 561-5600
jharkness@flabar.org
12
CERTIFICATE OF SERVICE
I certify that this document has been E-filed with The Honorable John A.
Tomasino, Clerk of the Supreme Court of Florida with a copy provided via email
to Respondent, chris.chestnut@chestnutfirm.com, using the E-filing Portal and that
a copy has been furnished by United States Mail via certified mail No. 7016 0750
0000 3623 6563, return receipt requested to Respondent, whose record bar address
is Christopher M. Chestnut, 841 Prudential Drive #1220, Jacksonville, Florida,
32207-8329, and via email to Carlos Alberto Leon, Bar Counsel,
cleon@flabar.org, on this 31st day of August, 2016.
ADRIA E. QUINTELA
Staff Counsel
The Florida Bar
Lakeshore Plaza II, Suite 130
1300 Concord Terrace
Sunrise, Florida 33323
(954) 835-0233
aquintel@flabar.org
13
NOTICE OF DESIGNATION OF PRIMARY EMAIL ADDRESS
PLEASE TAKE NOTICE that bar counsel in this matter is Carlos Alberto
Leon, Bar Counsel, whose address, telephone number and primary email address
are The Florida Bar, Tallahassee Branch Office, 651 East Jefferson Street
Tallahassee, Florida 32399-2300, (850) 561-5845 and cleon@flabar.org.
Respondent need not address pleadings, correspondence, etc. in this matter to
anyone other than bar counsel and to Adria E. Quintela, Staff Counsel, The Florida
Bar, Lakeshore Plaza II, Suite 130, 1300 Concord Terrace, Sunrise, Florida 33323,
aquintel@flabar.org.
14
t ,
IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT

IN AND FOR ALACHUA COUNTY FLORIDA
EMANUEL BAKER, SR. and

JESSIE BAKER,
Plaintiffs,
Case No.: 2013-CA-3768

Division: 11 J 11
vs.
CHRISTOPHER M. CHESTNUT
and the CHESTNUT FIRM, LLC,
a Florida limited liability company,
Defendants.
VERDICT FORM
We, the Jury, return the following verdict:
1. Do you find from the greater weight of the evidence that the
Defendant, Christopher Chestnut, breached his fiduciary duty to the
Plaintiffs, Emanuel and Jessie Baker, in procuring representation of the
Bakers under the July 23, 2012, Contingency Fee Agreement?
YES_ _ _ __
NO
--~--
Please answer question #2
Defendant, Christopher Chestnut, or any other attorney working for The
Chestnut Firm, breached a fiduciary duty to the Plaintiffs, Emanuel and
Jessie Baker, in procuring representation of the Bakers under the September
1, 2012, Authority to Represent?
As to Christopher Chestnut:
/~--
YES_ _
NO- - - - -
As to any other attorney with the Chestnut Firm:

YES_ _\/...._
__
NO- - - - -
TFB Exhibit A
3. Do you find that the Defendant, Christopher .chestnut, or the

Defendant, The Chestnut Firm, LLC, committed any breach of fiduciary duties
to the Plaintiffs, Emanuel and Jessie Baker, other than those inquired about
in Question #1 and #2 above, which was the legal cause of damages to the
Bakers?
YES
"
NO- - - - -
As to the Chestnut Firm:

YES
NO
-----
If your answers to question #3 were NO, Please skip Question #4 and answer
question #5. If you answered YES to any part of question #3, Please answer
question #4
4. If you answered YES to any part of question #3, what is the amount
of any damages sustained by the Bakers?
5. Do you find from clear and convincing evidence that the Defendant,
Christopher Chestnut, or any other employee of The Chestnut Firm, committed
civil theft of the Plaintiffs, Emanuel and Jessie Baker, which was the legal
cause of damages sustained by them?
YES
NO
As to any other employee of The Chestnut Firm:

, YES
NO
If your answers to question #5 were NO, please skip question #6 and answer
question #7. If any part of your answer to question #5 was YES, please answer
question #6.
of damages sustained by the Bakers?
7. Do you find from clear and convincing evidence that Defendant,

exploitation of Plaintiff, Emanuel Baker?
YES
NO

YES
NO
question #8
of damages sustained by the Plaintiff, Emanuel Baker, and not already
accounted for in your answer to question #6?
9. Do you find from the greater weight of the evidence that The
Chestnut Firm, LLC~ld recover from the Bakers for quantum meruit?
YES
NO
-----
If your answer to question #9 was NO, please skip question #10 and date and
sign your verdict below. If your answer to question #9 was YES, please answer
question #10.
10. What is the amount of money that The Chestnut Firm should recover
from the Bakers for services provided and costs incurred?
1 483 1 33~ ,33
For Services Provided
For Costs Incurred
L\0~ 1 0C\;2,
Total Recovery
11
So say we all this
885
day of
Foreperson
q3
4 'd. c; .2C
. .,
IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT

IN AND FOR ALACHUA COUNTY FLORIDA
Case No.: 2013-CA-3768

Division: "J"
EMANUEL BAKER, SR. and

JESSIE BAKER,
Plaintiffs,
vs.
CHRISTOPHER M. CHESTNUT
and the CHESTNUT FIRM, LLC,
a Florida limited liability company,
Defendants.
VERDICT FORM
We, the Jury, return the following verdict:
Defendant, Christopher Chestnut, breached his fiduciary duty to the
Plaintiffs, Emanuel and Jessie Baker, in procuring representation of the
Bakers under the July 23, 2012, Contingency Fee Agreement?
YES- - - -
No_V..____
Defendant, Christopher Chestnut, or any other attorney working for The
Chestnut Firm, breached a fiduciary duty to the Plaintiffs, Emanuel and
Jessie Baker, in procuring representation of the Bakers under the September
1, 2012, Authority to Represent?
L_____
YES_ _
NO_ _ _ __
As to any other attorney with the Chestnut Firm:

YES_ _/_.__
__
NO_ _ _ __
..
3. Do you find that the Defendant, Christopher Chestnut, or the

Defendant, The Chestnut Firm, LLC, committed any breach of fiduciary duties
to the Plaintiffs, Emanuel and Jessie Baker, other than those inquired about
in Question #1 and #2 above, which was the legal cause of damages to the
Bakers?
YES
NO_ _ _ __
As to the Chestnut Firm:

YES
NO_ _ _ __
If your answers to question #3 were NO, Please skip Question #4 and answer
question #5. If you answered YES to any part of question #3, Please answer
question #4
of any damages sustained by the Bakers?
5. Do you find from clear and convincing evidence that the Defendant,
civil theft of the Plaintiffs, Emanuel and Jessie Baker, which was the legal
cause of damages sustained by them?
YES
v'
NO
As to any other employee of The Chestn'ut Firm:

,YES
NO
question #6.
of damages sustained by the Bakers?
7. Do you find from clear and convincing evidence that Defendant,

exploitation of Plaintiff, Emanuel Baker?
YES
NO
YES
NO
question #8
of damages sustained by the Plaintiff, Emanuel Baker, and not already
accounted for in your answer to question #6?
;.
...
9. Do you find from the greater weight of the evidence that The
Chestnut Firm, LLC~ld recover from the Bakers for quantum rneruit?
NO------
YES
If your answer to question #9 was NO, please skip question #10 and date and
sign your verdict below. If your answer to question #9 was YES, please answer
question #10.
10. What is the amount of money that The Chestnut Firm should recover
from the Bakers for services provided and costs incurred?
For Services Provided
For Costs Incurred
Total Recovery
So say we all this
day of
Foreperson
"
I.'
Probate Court of Fulton County

State of Georgia
Estate of
Minor
) Estate Number PC-2014-709

)
) Re: Petition to Compromise Doubtful

) Claim for Wrongful Death
Final Order
On June 4, 2014, Ramona Jean Berry was appointed as Conservator of
, the son of Deidre Spear and the grandson of Ramona Jean
Berry. Letters of Conservatorship issued to her on that date. On June 27, 2014, Ms.
Berry filed a Petition to Compromise a Doubtful Claim for the Wrongful Death of Deidre
Spear. After considering the pleadings, the supporting documents and the evidence
taken at the hearing held on September 3,2014, the Court finds as follows:
1. On February 6, 2014, Deidre Spear was killed in an automobile accident. On
February 7, 2014, Ramona Berry, individually, signed a contract for funeral services
with Gregory B. Levett & Sons Funeral Home & Crematory, Inc. The funeral home
recommended The Chestnut Law Firm, LLC, to Ms. Berry and told her the Chestnut
Law Firm would take care of everything. Ms. Berry was represented by Christopher
Chestnut; Mr. Chestnut is not listed in the Georgia State Bar directory as a member of
the Georgia State Bar.
2. Mr. Chestnut had Ms. Berry sign an authorization for the attorney to pay
Universal Funds from proceeds of claim and an acknowledgement of authorization on
February 24, 2014. The authorization referenced a Purchase Agreement dated
February 24,2014 between Ramona Berry and Universal Funds. Ramona Berry signed
"Individually and as Personal Representative and Beneficiary of the Estate of Deidre
Spear."
3. The referenced Purchase Agreement was not signed until February 25, 2014.
The Purchase Agreement provides that "(I)f no recovery of Proceeds is received under
Seller's Claim as a result of a verdict, judgment, award, or settlement, Seller shall have
no responsibility, obligation or duty to pay Buyer the Purchase Price, unless the Seller's
failure to recover Proceeds arises from or in connection with any fraud,
misrepresentations, deception, breach of warranty or failure to perform any covenant
TFB Exhibit B
contained in the Agreement by Seller, who will then be liable for Buyer's attorney's fees
or collection costs, as permitted by law."
4. Mr. Chestnut, although not a member of the State Bar of Georgia, was
practicing law in the State of Georgia and knew, or should have known, that Ramona
Berry was never going to be individually entitled to any proceeds from the wrongful
death of Deidre Spear, that Ramona Berry was never going to be a beneficiary of the
Estate of Deidre Spear because Ms. Spear died intestate and her only heir was her
minor son, and that Ramona Berry was not the Personal Representative of the Estate of
Deidre Spear on either February 24, 2014 or February 25, 2014. The contract with
Universal Funds was negotiated between Universal Funds and Christopher Chestnut.
Ramona Berry never defrauded, misrepresented or deceived anyone; she never
received any money and was not entitled to receive any money from the wrongful death
of her daughter in any of the capacities listed on the contract of February 24, 2014 or
February 25, 2014. The contract negotiated between Universal Funds and Christopher
Chestnut with a $3,050 origination/processing
fee and a 35.40% APR was
unconscionable under the circumstances even if Ms. Berry had authority under any of
the listed capacities, which she did not.
5. A minor child is entitled to recover for the wrongful death of its parent; the
minor is not responsible to pay debts of the estate of his deceased parent, including
burial expenses of the deceased parent.
6. The proposed Compromise Claim with State Farm, as insurer of the tort
feasor who drove his automobile into Deidre Spear, proposed a settlement of $100,000,
the limits under the policy.
7. One third of the recovery was sought to be paid to the Chestnut Firm,
$2,976.00 to Brenda Bates as attorney fees for representing Ramona Berry in the
Probate Court proceedings, $139.97 as expenses of litigation in reaching the settlement
with State Farm, and $20,299.00 for repayment of a loan to Universal Funds. The
attorneys knew, or should have known, that pursuant to Georgia law, the minor is not
responsible for any payment of any loan. Also the attorneys knew, or should have
known, that any portion of payment of attorneys' fees which does not relate to the
minor's estate is not recoverable from the minor.
8. The Court does find that a portion of the $100,000 policy limits should be set
aside for the benefit of the Estate of Diedre Spear. Accordingly, $20,693 shall be
allowed for the Estate of Diedre Spear for burial expenses, attorney fees and expenses
of administration, and the remainder of the $100,000 policy limits shall be allowed for
the Estate of
for the wrongful death of his mother.
Therefore, the Court approves the settlement of the minor's claim for the wrongful death
of his mother as follows:
a. Expenses:
(i)
Attorney's fees (Chestnut Firm) attributable to minor
(ii)
Expenses of litigation
(iii)
Ms. Bates' attorney fees attributable to minor
(iv)
Total of Expenses
b. Cash to conservatorship
c. Gross Settlement
d. Net Settlement
$49,519.03
$28,160.00
$
139.97
$ 1,488.00
$29,787.97
$49,519.03
$79,307.00
So ordered this 30th day of October, 2014.
JAN1ES BROCK
Exercising th~jurisdiction of the
'. Judge of the Probat~ COU~ as

ProvidtJd by Q.C;:,GA. ~J)-9-36;(c)
FLORIDA BAR
Complaint of Anthony D. Jordan against Christopher Chestnut
File No. 2106-00,473 (4A)
AFFIDAVIT OF ANTHONY D. JORDAN, SR.
State of Georgia
County of Fulton
Personally appearing before the undersigned attesting officer duly authorized to
administer oaths, Anthony D. Jordan, Sr., being duly sworn, deposes and states as follows:
1.
My name is Anthony Jordan. I am an adult and labor under competent to give this
Affidavit. All matters stated herein are within my personal knowledge.
2.
On March 12, 2008, when I was 19 years of age, Deidre Spear and I had a baby, who we
named
(hereinafter, "
").
3.
Ms. Spear and I lived together for approximately three years, but never married. She
maintained custody of our son,
up to the time of her death, on February 6, 2014, as the
result of a motor vehicle collision. In general, we had a cooperative co-parenting relationship

and I helped her quite a bit with housing and contributed financial support for our son.
4.
Prior to her death, Ms. Spear routinely relied upon her mother, Ramona Berry, and my
mother, Angela Jordan, to baby.sit and care for
; and, as such, Ms. Berry came to my
mother's home, located at 2571 Godfrey Drive, Atlanta, Georgia 30318, on numerous occasions
to either pick up or drop off A J.
TFB Exhibit C
'
'
c:
..),
At all relevant times, up to and including the present, I have maintained my permanent
residence address as my mother's home, located at 2571 Godfrey Drive, Atlanta, Georgia 30318.
On the day oflMs. Spear's death, I was told about it by my mother, who had received a
telephone call and been told about it by someone, As such, I went to the school to picked up my
son.
7.
Later that same day, Ms. Spear's boyfriend, Braxton Banks came to my mother's home at
2571 Godfrey Drive, with others, and asked to take
to Ms. Berry's home, promising that he
would be returned. ThiS did not happen and, instead, Ms. Berry insisted on keeping
with her
at her home and refused tcj even allow me to visit with him. I did not agree with this, but was
unable to legally obtain custody oflmy son until months later.
8.
Within a matter ofljust a few days after Ms. Spear's death, a man identifying himselflas a
funeral director called me and attempted to solicit me on behalfl ofl attorney, stating that unless I
agreed; Ms. Spear's body would have to be cremated and there would be.no funeral. This was an
older ma.fl, who stated that he was with the Gregory Levett & Sons Funeral Home in Decatur.
9.
I was next contacted by telephone by a woman, who identified herselfl as Pansy King and
attempted to solicit me fo hire an attorney named Christopher Chestnut. She explained that
money from a potential case could be used for Ms. Spear's funeral. She was very pushy and put
..
Page 2
pressure on me, stating that there would be no funeral ifl I did not agree. I indicated uncertainty
to her about this because I was not married to Ms. Spear and did not feel I had any responsibility
or obligation for her funeral.
10.
Next, after that telephone conversation, Eric Echols and Ms. King came to my mother's
house and stated that ifl 1 would just sign the paperwork that were presenting to me, the funeral
could go forward; and ifl I then decided not to pursue the potential case, they would shred the
paperwork. Under pressure and relying on their promise to shred the paperwork ifll decided to
not go forward, I did sign the blank Contingency Fee Agreement attached to the Affidavit ofl
Ramona Berry dated April 28, 2016, and submitted to the Florida Bar under cover oflChristopher
Chestnut's letter dated April 28, 2016, and possibly signed other paperwork as well.
11.
Shortly thereafter, I met personally with both Mr. Chestnut and Ms. King at a
McDonald's restaurant.near iny mother's home.
12.
After the McDonald's meeting, I discussed the entire matter in detail with my mother,
Angela Berry, and decided'! did not want to have anything to do with these people.
13.
As such, the next day~ I believe the very next day, I called Ms. King and told her
specifically that I had decided to not {io forward with the case and also specifically requested that
all oflthe paperwork I signed be shredded, as we had previously agreed. She responded that the
paperwork I signed would ;be shredded.
i4.
Page 3
The statements made in paragraphs 9 and 10 of the Affidavit of Ramona Berry dated
April 28, 2016 are absolutely false. Until March of 2016, 1 had no idea at all that Ramona Berry
had hired Mr. Chestnut or pursued a wrongful death action. At that time, I did seek out the
advice of attorney, who contacted the insurance company of the at-fault driver and was told the
policy limits had been paid, and was subsequently provided the supporting documentation by
attorney W. Curtis Anderson of the Downey & Cleveland, LLP, law firm of Marietta, Georgia.
15.
Likewise, I had no idea at all that Ramona Berry had filed and pursued two related Fulton
County Probate Court proceedings, on March 3, 2014 and on March 19;2014, with no notice to
me, while at same time unsuccessfully contesting my Petition for Legitimation and Custody in
the Fulton County Superior Court
16.
Specifically, on March 3, 2014, Ms. Berry filed a verified Petition for Letters of
Administration regarding her Deidre Spear. In such Petition, it was falsely asserted and
fraudulently misrepresented to this Court that my address was unknown to Ms. Berry.
17.
On March 19, 2014, Ms. Berry filed a verified Petition for Temporary Letters of
Guardianship of Minor, in which it was again falsely asserted and fraudulently misrepresented to
this Court that my address and whereabouts were unknown to her.
18.
Ori March 30, 2014, Ms. Berry was served with process in my prose Superior Court
proceeding against Ms. Berry in which I sought an Order of Legitimation of my standing as the
father of A.l, as well as Custody of
Page 4
19.
On both May 19, 2014 and June 24, 2014, Ms. Berry participated in hearings and was
present in open Court with me. The first hearing resulted in me being allowed visitation on my
son,
and the second hearing resulted in him being declared my legitimate son and I received
an award of his sole physical and legal custody.

20.
On June 4, 2014, Ms. Berry filed a verified Petition for Letters of Conservatorship of
Minor, in which it was again falsely asserted and fraudulently misrepresented to this Court that
my address was unknown: Additionally, the identity of a notabie relative of the Minor, Angela
Jordan, my mother and
's paternal grandmother was falsely and fraudulently withheld and
concealed from this Court.

21.
Given all the circumstances, it seems evident to me that Ms. Berry, either alone or in
conspiracy with others, illegally, intentionally and fraudulently kept her both her pursuit and her
actual recovery of money on accoU:nt of the death of Deidre Spear, supposedly for the benefit of
my son, secret from me.
22.
Finally, I want to respond to the Affidavit of Eric Echols, dated April 28, 2016, and
submitted to the Florida Bar under cover of Christopher Chestnut's letter dated April 28, 2016.
First, the Grievance form mailed to the Florida Bar at the end of February was prepared by both
me and my mother, and I did sign it. Second, when Mr. Echols calledme on April 13, 2016, 1
did not know who he was or why he was calling me, but assumed his job was to hassle me on
behalf of Mr. Chestnut; and, as such, I had no real interest in being cooperative with him. He
Page 5
.......
talked about a complaint being filed about some wrongdoing, but I did not even realize he was
talking about the Grievance form that we had mailed to the Florida Bar several weeks earlier. He
never mentioned the Florida Bar and I thought he was asking about some type ofia lawsuit being
filed, which I had not done. He also, of course, did not mention that he was surreptitiously
recording the conversation, which I consider very underhanded and dishonest. The only
important statements in the recording are the following:
"I haven't talked to Mr. Chestnut since I told him no about trying to get some type
of money out ofithe accident .... that was a long time ago and since something
about the the funeral and costs and bla bla bla. All I know is I told those guys no
a long time ago."
"The last time I spoke with these guys, didn't have anything to do with them .... I
told them no, I didn't want to pursue any kind ofilawsuit. I think it was for
wrongful death ... "
" ... so, what is the amount ofi money disbursed[?] And I want to know what
money, because ... How can I just learn ofimoney I don't know anything about?"
"If there's money out there and I'm the caretaker and I have full custody, then I
should have been notified ..."
"So, you're saying there's an estate set up? That's what you're saying? Because I
don't know anything about an estate. And by now, its been two years ago. I
should have known about an estate ... "
Sworn to and executed

this Jl( day ofiJune, 2016.
Notary Pubhc
My Commission expires:
tq
5~ ( ZAl1
Pag~.6
RECE1V[O
F lILTON COUN1 v
PROBATE COURT
IN THE PROBATE COURT OF FULTON COUNTY

2U16HAY /1
STATE OF GEORGIA
IN RE:
)
)
)
)
)
)
MINOR/WARD
PETITION
FOR REMOVAL
PH I: 40
ESTATE NO. PC-2014-709
OF CONSERVATOR
AND FOR AN ACCOUNTING
COMES NOW Anthony D, Johnson, Sr., as custodial parent acting on the behalf of his
son of tender years,
a minor ("Petitioner"), by and through
counsel, and respectfully shows as follows:

1.
Ramona Jean Berry ("Ms. Berry" or "Conservator"), the maternal grandmother of
("Minor"), on March 3, 2014, filed a verified Petition for Letters
of Administration regarding h"r deceased daughter, Deidre Spear - who had lost her life on
February 6, 2014 in a motor vehicle collision - in the related proceeding designated as Estate No.
PC-20l4-000528.
In such Petition, it was falsely asserted and fraudulently misrepresented to
this Court th~t the address of Anthony D, Johnson, Sr., the Minor's father ("Mr. Jordan" or
"Petitioner"), were u'1kr.owr, to Ms. Berry. Accordingly, based in part on the said false assertion
and fraudulent misrepresen,ation,
this Court on March 26, 2014 issued Letters of Administration
to Ms, Berry.
2.
In the present proceedi~g, ()n March 19,2014, Ms, Berry filed a verified Petition for
Temporary Letters of Guardianship of Minor, in which it was again falsely asserted and
TFB Exhibit D
fraudulently misrepresented to this Court that the address and whereabouts of Anthony D.
Johnson, Sr., the Minor's father, were unknown to her. Accordingly, based in part on the said
false assertion and fraudulent misrepresentation, this Court issued an Order for Service by
publication once a week for two weeks on March 19,2014, and then issued an Order providing
Temporary Letters of Guardianship to Ms. Berry on April IS, 2014.
3.
On June 4, 2014, Ms:Berry filed a verified Petition for Letters of Conservatorship of
Minor, in which it was again falsely asserted and fraudulently misrepresented to this Court that
the address ofPetitio:1er, tlie MInor's father, was unknown. Additionally, the identity of a
notable relative of the Minor, Angela Jordan, the paternal grandmother was falsely and
fraudulently withheld and concealed from this Court. In fact, the identity of Ms. Jordan, her
relationship to the Mir,or and her address were all well-known to Ms. Berry based upon their
having extensively cooperated together in care of the Minor. Accordingly, based in part on the
such false assertion and f~auduient misrt'presentation, as well as the said fraudulent concealment,
this Court (by and through Judicial Officer Jamt's Brock as duly acting Probate Judge) issued an
Order appointing Ms. Berry'as Guardian Ad Litem/Cons~rvator on J'une 27, 2014.
4.
Further, during the time perioo. prior to Ms. Berry's filing of her verified Petition for
Letters of Conservatorship \1fMinor, she had been served with process in'a pro se Superior Court
proceeding filed by Mr. Joh.nso'l agilinst"Ms. Berry in which he sought an Order of legitimation
of his standing as the father' of as well as custody of the Minor. Anthony Johnson v. Ramona
Berry; Fulton County SupeIior c.)urt; Ci'!il Action File No. 2104CV242280.
Ms. Berry was
served with process in this action:m March 30, 2014; and the Sheriffs Entry of Service
Page 2
document recited Mr. Jordan's address of2871 Godfrey Drive, Atlanta,. GA 30318 -
which was
and is the longstanding residence of Angela Berry, the mother ofMr. Johnson and paternal
grandmother of the Minor. A true and correct copy of the said Sheriff s Entry of Service is
attached hereto as Exhibit "A."
5.
On both May 19, 2014 and June 24, 2014, Ms. Berry participated in hearings and
presented in open Court with, first, a Temporary Order. on Petition for Legitimation and Custody
and, second, a Final Order onPetitioh for Legitimation and Custody. True and correct copies of
the said Orders are attached hereto as Exhibit "B" and Exhibit "C."
6.
On June 27, 2014, Ms. Berry filed a Petition to Compromise Doubtful Claim of Minor in
this proceeding. This Petitio:l falsely and fraudulently withheld and concealed from this Court
that her guardianship of the Minor rio longer included physical custody of the Minor; that the
Fulton County Superior Court had ordered she relinquish physical custody of the Minor; or that
the father, Mr. Johnson, had been legitimated and given physical custody of the Minor, and thus
under Georgia law was the proper individual to control any claims for the wrongful death of the
mother. Ms. Spear, and/or ti:>safeguard any recovery of money damages for the exclusive benefit
of the Minor.
7.
As was noted and/ci~otherwise suggested i.n the Final Order issued October 30, 2014 by
Mr. Brock as acting Probate Judge, an agreement between Ms. Berry and Universal Funds I was
negotiated 'or facilitated by attorney ClITistopher M. Chestnut, a Florida attorney, who at all
I Upon information and belief, Universal Funds was and is a "loan shark" type of pre-settlement funding
agency that makes loans at usurious interest and/or return rates to the unwary.
Page 3
relevant times was engaged in the unauthorized practice of law in the State of Georgia -
a quite
serious ethical violation and an evident act of fiduciary misconduct in the attorney-client
relationship; and this occurred prior to Ms. Berry having even been appointed as Administrator
of the Estate of Ms. Spear; and Ms. Berry would not ever in any event been entitled to any
portion of the proceeds of a wrongful death settlement, as the Minor was the sole individual
S 51-4-2
entitled to receive such proceeds. See, a.C.G.A.
(a).
8.
As such, at all relevant times, Ms. Berry made false representations to this Court and
fraudulently concealed relevant facts and information from this Court; intentionally attempted to
keep the existence of the proceedings of this Court secret from Mr. Johnson; and continued to
fraudulently conceal from this Court the status ofMr. Johnson even after he had been both
legitimated 'and made the custodial parel'l of the Minor.
9.
Likewise, at all relevaili times, because of the said false representations and fraudulently
concealments of Ms. Berry, Mr.Johnson
was deprived of any timely notice of and any
opportunity to participate in the proceedings before this Court.

COUNT ONE
BREACH-OF 'FIDUCIARY
DUTY
10.
Petitioner realleges ana reincorporates herein by reference Paragraphs 1 -
9 of this
Petition as if each were set forth fully hereinafter.
11.
Upon information and belief, as the Conservator, Ms. Berry has failed to administer the
Page 4
Minor's Estate in a good faith manner and to act in the best interests of the Minor, even though
almost two full years have passed since she was appointed.
12.
Upon infomlation and belief, as the Conservator, Ms. Berry has failed to file an Inventory
of the Minor's property or a plan for administering the property, as required by O.C.G.A. ~~ 293-21 (b) and 29-3-30.
13.
Upon information and belief, as the Conservator, Ms. Berry has failed to file any Annual
Returns, as required by O.C.G.A. ~~ 29-3-21 (b) and 29-3-60.
14.
Upon information and belief, as the Conservator, Ms. Berry has caused the Minor's
Estate be wasted and/or diminished.
IS.
Upon information and belief, as the Conservator, Ms. Berry has acted to advance her own
personal interest over the interest of the Minor's Estate and the Minor.
16.
The foregoing actions and failures constitute a material breach of the fiduciary duties
owed by Conservator to the Minor's Estate and the Minor.
COUNT TWO
REMOVAL
17.
Petitioner realleges and reincorporates herein by reference the allegations of Paragraphs I
through 160f this Petition as if each were set forth fully hereinafter.
Page 5
18.
Based upon the foregoing, Petitioner requests that this Court review the Conservator's
actions and failures to act as set forth herein, above, and, if appropriate, remove her from her
fiduciary position of trust and confidence.
COUNT THREE
ACCOUNTING
19.
Petitioner realleges and reincorporates herein by reference the allegations of
Paragraphs I through 18 of this Petition as if each were set forth fully hereinafter.
20.
Petitioner requests that this Court order the Conservator, Ms. Berry to provide this Court
with a complete and formal accounting of her activities regarding these matters, including but
not limited to the following: (I) a complete list of all assets and debts belonging to the Minor's
Estate at the time of its creation; (2) all receipts and marshaling of assets since Conservator
appointment; (3) all claims made against the Minor's Estate; (4) all expenses or debts of the
Minor's Estate paid or incurred by Conservator; (5) all disbursements from the Minor's Estate
made to any person or entity,'including
any trusts; (6) a list and complete description of all real
and personal property of the Mi,lor's Estate which has been sold or transferred since
Conservator's appointment, giving the particulars of each sale or transfer; (7) a list and
description of all real and personal property which is currently on hand and in the possession
and/or control of Conservator and its current status; (8) a list of all property of any kind or
description received by Conservator the Minor's Estate since the date of her appointment; and
(9) a list and description of all expenditu'res paid by the Minor's Estate for the support and
Page 6
maintenance of the Minor since Conservator's appointment.

COUNT FOUR
FORFEITURE OF FEES
19.
Petitioner realleges and reincorporates herein by reference the allegations of Paragraphs I
through 18 of this Petition as if each were set forth fully hereinafter.
20.
Petitioner shows that this Court should deny the Conservator, Ms. Berry, any fees for
serving in her position and if she has already paid herself fees, that the Court order her to
reimburse the Minor's Estate for all fees taken.
COUNT FIVE
EXPENSES OF LITIGATION
21.
Petitioner realleges and reincorporates herein by reference the allegations of Paragraphs 1
through 20 of this Petition as if each were set forth fully hereinafter.
22.
Finally, the actions of Conservator have been in bad faith and caused Petitioner to
undertake the unnecessary trouble and expense, to include but not be limited to the hiring
counsel and preparation of f!.lethis Petition to compel her compliance with Georgia law in
administering the Estate. Accordingly, Petitioner is entitled to judgment against Temporary
Administrator under O.C.G.A.
13-6-11 for reasonable attorney's fees and expenses incurred in
pursuing this matter, to include

but not be limited ,to the filing of this Petition.
,
WHEREFORE, Petitioner prays ~hat:
Page 7
(a)
Citation issue requiring Conservator to show cause at hearing before this Court on
a date certain why she should not be removed and replaced by an appropriate successor;
(b)
Conservator be cited to provide and a complete and formal accounting, as
described above;
(c)
ConservatOJ be denied all fees for her service and if she has already paid herself
fees, that the Court order hel to reimburse the Minor's Estate for all fees taken;
(d)
The Court issue a written Order that the Minor's Estate may not be used to defend
Conservator in this action;

(e)
Attorney" s fees and expenses be awarded to Petitioner and against Conservator;
(f)
Petitioner; Dn the behalf of the Minor, be granted any and all such other and
and
further relief as may be deemed just and proper.

This !7~ay
ofMa)', 2016.
DA VIn S. BILLS, P.C.
Georgia Bar No. 057132
1932 North Druid Hills Road

Suite 200
Atlanta, GA 30319
404-633-6000 (phone)
404-633-6400 (fax)
Attorney for Petitioner
Page 8
EXHIBIT "A"
'7)
SHERIFF'S
ENTRY OF SERVICE
SHERIFF'S ENTRY OF SERVICE
o
o
Onte Filed
COUNTY
Fulton
Georgia,
Plaintiff
VS,
Name und Address of Purty to be Served,
'L 10
jI\1.S. fJur.t.
I!j~
~L)
') 01
f-
~esfr;IUvJ
ff+lv.-..~
Defendant
GW,.
Garnishee
'
SHERIFF'S ,ENTRY OF SERVICE

Ihove Ihis day served Ihe defendanl~,
personallY with a copy
of the within action and summon~.

I have this day served the defcndant
tJ)
._by
copy of the action and summons at his most notorious place
leaving a
or ab0de in this County.
:>
a:o 0 Delivered
>-00
snme inlo hands of'
age. nbout
years; weight
defendant.
z
Q
--------------
pounds: height.
feet and
OboUl
inches. domiciled at the residence of
-----,--------_.----_._----------------------
Served the defendunl
<~ 0 by leaving
0..
,describcd as follows:
.:1
a copy of the within action and summons
with
corporatiun
_
~
u
in charge of the office and place of doing busines.s of said Corpomtion in the County.
...;:
I have this day served the above styled arfiduvit and summons on the defendant(s.) by posting a copy of the same to the door of the
2:
premises designated in said affidavit. and on the Silrne day of such posting by depositing a true copy of same in the United States Mail,
: 0
First Class in nn envelope properly addressed to the derendant(s) at the address shown in said summons, with adequate posloge affixed
u
~
thereon containing notice to lhe defendant's) to answer said summons at the plnce staled in the summons.
!0
o
Diligent search made rind dcfendant
not to be found in the jurisdiction of this court.

This
2> 0
day Of~~{).~,vt:~I1~, __
,20-llf__
'
DEPUTY'
SHERIFF DOCKET
PAGE
WHITE.CLERK
CANARY,PLAINTIFF
PINK-DEFENDANT
EXHIBIT "B"
ORIGrNAl
FILED IN OFFICE
IN THE SUPERIOR COURT OF FULTON CO
1)"
MAY 2 0 2014
STATE OF GEORGIA
yv
ANTHONY JORDAN,
OEPUTY CLERK
UPERIOR COURT
FULTON COUNTY. GA
Petitioner,
v.
DIEDRE SPEAR and RAMONA BERRY,

Respondent.
CIVIL ACTION FILE NO.

2014CV242280
TEMPORARY ORDER ON PETITION FOR LEGITIMATION AND CUSTODY

Petitioner
filed his Petition
for Legitimation
and Custody on February 14, 2014.
Spear is deceased but Petitioner added Respondent Berry as maternal

appeared at 60 Day Status Conference and both parties were pro se.
Based on the fact that Petitioner
is seeking legitimation,
grandmother.
Respondent
Both parties
the Court chooses not to make any
changes on the living arrangements of the minor child. However, after brief testimony from both
parties, the maternal grandmother, with whom the child has resided since the passing of his mother on
February 6,2014, stated she has no objection to allowing the Petitioner to visit with his child.
The Court has ordered a paternity test and a social services investigation.
If further investigation
is needed, the Court has informed both parties that a guardian ad litem may be appointed at the next
hearing date.
Therefore, the Court orders that Petitioner shall exercise visitation
Parenting Plan - Exhibit "A" beginning Friday, May 23, 2014.
according to the Simple
This Order shall remain in effect until further order of the court.
SO ORDERED, this 19'h day of May, 2014.
Magi~-i~-ia-I-o-~-?-:-'r------Fulton Superior Court/Family

Copy given in open Court to:
Anthony Jordan, Petitioner
Ramona Berry, Respondent
Division
.'
EXHIBIT A - PARENTING
The non-custodial parent is
The custodial parent is
.l>r.th
Oi'\'j
R ::u-no~ ~
PLAN
.::rocr d:>n.
(p"",-krn::>J 3r;>nc!rno().,( )
It is hereby recognized that:

a. A close and continuing parent-child relationship and continuity in the child's life will be in the child's
hest interest;
b. The child's needs will change and grow as the child marures;
c. Each parent shall make decisions regarding the day-to-day care of the child while the child is residing
with that parent, including any emergency decisions affecting the health or safety of a child. Decisions
that affect the other parent's parenting time shall be conununicated promptly; and
d. Both parents will have access to all of the child's records and information, including but not limited to,
education, health, extra-curricular activities, and religious communications.

The non-custodial parent shall be entitled to exercise parenting time with the minor child with the following
minimum provisions:
A.
On every I", 3", and 5'" friday of the month beginning after school on Friday (or at 6:00 p.m. when school
is not in session) until the following Sunday at 6:00 p.m.;
B.
During even numbered years (2008, 2010, etc.), the non-custodial parent shall have parenting time on the
holidays delineated below:
I. Martin Luther King's Birthday
2. Memorial Day
3. LaborDay
4. Thanksgiving Vacation from after school (In Wednesday until the following Sunday at 6:00 p.m.
5. Second week of Christmas Vacation from 2:00 p.m. on December 25 until 6:00 p.m. on New
Year's Eve.
C.
During odd numbered years (2009, 2010, etc.), the non-custodial parent shall have parenting time on the
I. New Years Day
2. Spring Break from after school on the Friday preceding the week of Spring Break until 6:00 p.m.
on the Sunday before school starts
3. July 4'"
4. Halloween
5. first week of Christmas vacation, including Christmas Day wltil2:00 p.m. on December 25.
D.
During even nwnbered years (2008, 2010, etc.), the custodial parent shall parenting time on the holidays
delineated below:
I. New Year's Day
2. Spring Break from after school on the Friday preceding the week of Spring Break until 6:00 p.m.
on the Sunday before school starts
3. July4'"
4. Halloween
5. First week of Christmas vacation, including Christmas Day until 2:00 p.m. on December 25.
E.
During odd numbered years (2009, 2011, etc.), the custodial parent shall have parenting time on the
1. Martin Luther King's Birthday
2. Memorial Day
,
3.
Labor Day
4.
5.
Thanksgiving Vacation from after school on Wednesday until the following Sunday at 6;00 p.m
Second wcck of Christmas vacation from 2;00 p.m. on December 25 until 6:00 p.m. on New
Year's Eve.
F.
The Mother shall have the minor child on Mother's Day.
G.
The Father shall have the minor child on Father's Day.
H.
The non-custodial parent shall have parenting time with the minor child for two consecutive weeks in the
sununer between June 15 and August 15. During this period, the custodial parent shall have the minor child
on the fIrst (I") weekend from 6:00 p.m. Friday until 6:00 p.m. Sunday. The non-custodial parent shall give
the custodial parent a minimum of thirty (30) days written notice of the intent to exercise this visitation.
I.
Holiday visitation shall take precedence over weekend visitation. If a Monday holiday coincides with a
parent's custodial weekend, then the custodial period shall be extended through 6:00 p.m. on that Monday
holiday.
EXHIBIT "C"
I\\"J .
,I
IN THESUPERIORCOURTOF FULTONCOUNTY
FilED IN OFFiCE
STATEOFGEORGIA
ANTHONYJORDAN,
Petitioner,
v.
DIEDRESPEARand RAMONA BERRY,
CIVILACTIONFILENO.
2014CV242280
Respondent.
FINAL ORDERON PETITIONFORLEGITIMATIONAND CUSTODY

Petitioner filed his Petition for Legitimation and Custody on February 14, 2014. Respondent
Spear is deceased but Petitioner added Respondent Berry as maternal grandmother. Both parties
appeared at 60 Day Status Conference and both parties were pro se.
The Court previously ordered a paternity test and the results show a 99.99% probability that
Petitioner is the biological father of the minor child,
. (See Exhibit "A")
Additionally, based on the social service report ordered by the Court and after hearing testimony from
both parties, the Court finds no reason why the Petitioner should not be granted physical custody of his
minor child.
I
i
I
I
I
Both parties agree that the Petitioner has always maintained contact with his child as the
parents lived together until approximately four (4) years ago and that the Petitioner has continued to
maintain regular visitation even after the mother passedaway in February 2014. Also, the parties agree
that the maternal grandmother should be able to maintain contact with her grandchild. While no
motion for grandparent visitation has been filed by the Respondent/Maternal Grandmother, the Court
encourages the parties to allow the minor child to continue his relationship with the maternal
grandmother through regular visits.
Basedon the foregoing, IT ISORDEREDAND ADJUDGEDthat:
1) The minor child,
legitimate child of Petitioner, Anthony Jordan;
male, DOB: 03/12/2008, is declared the
2) As the minor child's mother is deceased, the Petitioner is hereby declared to be the sole
physical and legal custodial parent of said minor child;
3) The Respondent will relinquish physical custody of the minor child to the Petitioner by 6
p.m. on Thursday, July 24, 2014.
Signature page to follow
I
i
SO ORDERED,<this 24th day of July, 2014.
Magistrat
udicialOfficer
Fulton Superior Court/Family

Copy given in open Court to;
Anthony Jordan, Petitioner
Ramona Berry, Respondent.
Division
Ac"'cou'ritIn"for.matiori
AccoiiflfNiJmoer: 107901~0
i'Uilt6ii;co;sbP.OObii:to.UR:r:
Acet Ref),:, ,20\~,CVi42280
A"CCl Ret'-2:'
l.oCt Ref 3,'
AtiliJita; 61'.,,0303
LaliCorjl On,e,#
COS:O,69.JS8
Rclationsh"ip
,~
,Chi.!,d
,!O,RIJ"~N;,m,ANtHpt'lYJ;l
AII'geQ FatlYe;
,J'ORDAJ';;'ANTHONY D
~ri"'''SiS
C
r,AFT
r PI
,0351356
16 17
17,
2,37
DNA'Ahal\Nl;is
THOl
IC'I
,6 9
I AF I 6,'9
PI I '3,62
IlilI:!'i!
0.75620'
9 1'1
10, 11
1'20'
.WA
15'W
'14; 17"
1,2~'
'PGA
,20,,24
'20,,26
4,11
Dateis)',Dr:awn_
o'iii62iiof4
'46~'286B,O
4ij.i~i8~9,Q BiRek
D65,rU9
14 'f6
15,"1,6
..
,3,86
D2,15)l,
26'29:
27,29,
-'1t30' "
,O'1,6$5j
HLJ7'
17'"1,6,,
lA8
.055616
11 12,
'12
~1.4,,1
06ioitiof4,
[),1~5;lH
102
t1~.J2:,
l.U
..
0.,1'65539.
,11,12
~l,:12',
2,09,
TPOX'
8, f1
'S,,9
0,75
C5Fj'PO
P,entaO
5 '1O.
'to 1'2
'2.44
,W
10, j2,
1,61
Conclusion:
Corntilned PaternitY lnde,,: 16.648 to 'f
F13AOl
'3,2,5'
F13~
7',9,
,6',:9:
j,03
.5,a.
,0,73'
'Pro'babiiity'ofPatemitr:
tPL
10
10,:13
1.41
;Penta',E
7'.'lf
,7' 6
, :F.E$Fp5'
n ~2
'10;'H
'2A6,"
P.tinla,G:
'9 1.4
..
9; 10
..
(1":46:'
99,9'9'Yo:(Prlor:ProbabHlty ~ 0:5)
ThC'alle'g~d.fattier, ANTHONY D, !ORDAJ'i. elllirtot,be e~~iudea,1lS,tite,blol6'gic8lfather,oj'the'ehild,;ANTH0NY,b,

JORDAN, iR, ;inte'
they.shareIgenet"ic markers, Using. fhe:.ab.ovc'syst,ems. t,b~'pro,bability ofpaterDity.'is,99;~9o/o,:as.C;OVlPa,te~hto1U1 un:tcst.ed,:.~Qt.eJa~d
ot
th~ B,I.Okpopulation,
m~
I :fhl?)Jrid~rs.igrled DiJetJor~.,\rp_on b~ing d\ily'sworri oil balli.. dCidePOse, RIid,sCb.t'C"tbllf.heaththc'.-idregoio$'rep'(j'ft'on.ihc<ac'a!,ysis

'01
. '.indiyi:du!}lsj signe.~by mys~lf, cw.d ~nder p.cqalties tQf.perjury'lt i~,iny.b~lie.f\'Uult-Uie.~9:ts,an91rest.iltS.
l
spedmc:ns'from :the above'

t~~,r~il\
,;io tlil"~deorre'
i,
'".,
Anlwuan M.. tysor
" 'certirythat
Michael W:Sch!Jli~derer.i'~.p;"t\1T
oJAI:riericaH~Hd.ingSJ
to.do so!' exe'cuted the foregoiD~,on belial~.ofth'C;.corporation.
d.Bt'~d:a.claio\l{lctlge4 'U:i~~
~~.(qf ~I;le) is ~ ~m~h~):i:~
qf I:.abora~oty qrpJjfaf!QD
eml?loyee being'authorized
Sqbscrioed Ili\d,swO'mt9 [or affitmed} before me thiS
._,IUI, 2 420.14
Laboratory Cotjfo'ratiori. ofAmcticfi,js

f'\:vtl1
Page'1 of.1'
lI'ee"redJtedby1hc-AASB
p.ers,enafly clll!lche'foreme'ihj,
arid thiit-as '~n
a cofP6ratiO'n,
.~tButlingto'tl"NC,
..
ANTWUAN,MTYSOR
NO't-ARY PUBliC
GUJtFCilRD COl:lN~Y:NC
My Cohnnissioil EXpire, 5:'1',2019
.~
----_.-
-_._-----,,,
--------~~~~~-------------------'--;-'-
'------_.- -------
CLIENT AUTHORIZATION
FUL TON 'CO S"UFEH4:0H COJ,JRT
n i v i os i. Q:>'I ':t1;Pi""f2':-p::::~.i.:d Only
:.~~~~~;~~~(
..
~
..
: .
t
Fe,Pl1. 't ~~
13"6 P,'Y'C.)l" ,Stt'E:f:!t .s~J

,cd 1.S.n h.11 GA
30303
( 40~. ) Go1.2>-"U509
t{tr:z CSZb
.AMouNT REC~IYED-$,-__
.C"ECK #
INT. ~
INT.
N:'''1~~.rks
p."ono -, "
HFP
LP,)JCDRP ACeT 4i=-'~, 1!)'tCfQ190

Pr'.(:).F it .Cel'l{:l?r: GAtl;lO
placeK
'
-in box
...
Ai./I
(1/1
XCOOE
:';<l>u~);'6q;e#-~9;fl4-~'it:<.~}.i,%z;8i:'- Spedmenbh Fileg

IFYes
'~"bbc'k:~ffG6~ft'#.
LabCarp Case
.. ".
. . ...
$~ND,ADQlfIONA(RE~~LtS;~QPIEnQI S~Eql\L.INSjRliqrllNS;
Nu'mq$f
SPEC'NlEN#
--"
flHn)clJY
,~'.
JC,fkin o'~~ll -,-
-.
': 'V.ll':eii~b~'
.
etti2i
-.. -'-.":-.-.-.-"
M:~'ricirlT.rriJr~~,.mj~i'.
:::;"":. -~
.
"':-r~cJ;b';~~~ri.".::.
:" '-",f'I{:j~~q~\\W,i;fi7.61r';::
;~;;i:~:~~d~:U';:~""P~i}>-~~~o,,;
..!~!~<;
...
_blh!:ri?Cr;~:I,"~~_;,~;~~~;.;!~
.~~~i~;~~~~w!
.. ~~
.
!
.?}1;vt
'SPECIMEN#
'J
~
H~
CJ
Y _
l _
B,-.,-G_
.-
.4!NVnOt'\.~ Jj.':5or-~
~_H'
..,
'-:'S~ jU\1,e- iZ,. ~'6Iq,
./'.
.....
fb.#~rf)
.~/io/'
~j,C,\iV
. - - - .. - ;': ''-''''''''l''''~''''~''~7~''.;;;_~.
;J:.~.''''-'-:,. ''1.' "'1: .:=.,.., ........
:::......
;I
I
I
,.
)(
~'.
".
,.
~
,..
~,
~
8< .
~
SPEGIME'N@ONTAINER5EAL~G
NO
. i:((!\CORP US~'ON~Y
..
SIGNS OF rAMPERlNGYES
Md
I HEREBYCERTIfYTHAT J REqIVEPT/'JE SP~~T

ll'-~GG~P AN[) TtieRSlS 1'49 E'lIDENc::ETliAT 11:l.E~Ac~~~,tVii
~EEN~Q~E!\!E~.I ~
PENAL'riESFOR PERJURY,THAl THE fOR . DING REPRESENTATIONIS TRUE.
SIGNAtURE:
DATE:~.__
~~_~
CIP:ClE6NE: F bEJl11.'TIX!'R
O\'!:lE~
0.:; - 03 -:10 14.
.uNDER
_
FILED
8/23/2016 5:51:33 PM
JOHN F. WARREN
COUNTY CLERK
DALLAS COUNTY
CC-16-04225-E
CAUSE NO. __________________________
IN THE COUNTY COURT
Plaintiff,
VS.
AT LAW NO. ______
TIFFINNI ARENA YOUNG AND
CHRISTOPHER MOORE CHESTNUT
DALLAS
COUNTY,
TEXAS
Defendants.
______________________________________________________________________
MATISHA WARD,
PLAINTIFFS ORIGINAL PETITION AND REQUESTS FOR DISCLOSURES

______________________________________________________________________
TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW, Plaintiff, Matisha Ward and files this Plaintiffs Original Petition and
Requests for Disclosure complaining of Defendants Tiffinni Arena Young and
Christopher Moore Chestnut and for causes of action, would respectfully show the Court
as follows:
TO THE COURT AND JURY
THE DARKEST HOUR IN ANY MANS or WOMANS LIFE IS WHEN THEY SIT
DOWN TO SCHEME AND PLAN HOW TO GET MONEY WITHOUT LAWFULLY
EARNING IT. THE CRIMINAL CONDUCT COMPLAINED OF HEREIN DEMANDS A
JURYS WRATH.
I. DISCOVERY CONTROL PLAN

Plaintiff intends to conduct discovery in accordance with a Level 3 discovery control
plan under Rule 190 of the Texas Rules of Civil Procedure.
II. PARTIES AND SERVICE
Plaintiff is a resident of Dallas County, Texas.
TFB Exhibit E
PLAINTIFFS ORIGINAL PETITION AND REQUESTS FOR DISCLOSURE--- PAGE 1
Defendant Tiffinni Arena Young may be served with citation by delivery to her at
her office located at Dallas City Hall or at her residence address of 4024 O.B. Crowe
Drive, Dallas, Texas 75227 or wherever she may be found.
Defendant Christopher Moore Chestnut is an individual who holds himself out to
the public as a wrongful death attorney licensed in Florida and Georgia. He may be
served with citation by delivery to him at 303 Peachtree Street, Suite 4150, Atlanta, GA
30308 or at 911 NE Blvd., Gainesville, Florida 32601 or wherever he may be found.
III. JURISDICTION AND VENUE
Jurisdiction is proper in this Court because the amount in controversy exceeds
the Courts minimum jurisdictional requirements. Venue is proper in Dallas County,
Texas pursuant to Texas Civil Practice & Remedies Code 15.002 because all or a
substantial part of the events complained about herein occurred in Dallas County,
Texas.
IV. CHEATS, HUCKSTERS AND AMBULANCE CHASERS
On information and belief, each of the named Defendants, and the
unincorporated business entities are actively involved in a criminal and civil conspiracy,
the object of which is to commit the crime of Barratry a/k/a ambulance chasing as
defined by Texas Penal Code Section 38.12:
38.12. BARRATRY AND SOLICITATION OF PROFESSIONAL
EMPLOYMENT.
(a) A person commits an offense if, with intent to obtain an economic benefit the
person:
(2) solicits employment, either in person or by telephone, for himself or for
another;
(d) A person commits an offense if the person:
(1) is an attorney, chiropractor, physician, surgeon, or private investigator
licensed to practice in this state or any person licensed, certified, or registered by a
health care regulatory agency of this state;

(F) involves coercion, duress, fraud, overreaching, harassment, intimidation,
or undue influence;
(f) An offense under Subsection (a) or (b) is a felony of the third degree.
(h) An offense under Subsection (d) is a felony of the third degree if it is shown on
the trial of the offense that the defendant has previously been convicted under
Subsection (d).
(i) Final conviction of felony barratry is a serious crime for all purposes and acts,
specifically including the Texas State Bar Rules and the Texas Rules of Disciplinary
Procedure.
Plaintiff is the biological daughter of Antoinette Brown who was attacked by a
pack of loose dogs in Dallas County on May 2, 2016. Ms. Brown did not survive her
wounds and died on May 9, 2016. While at her mothers bedside Defendant Young was
calling and texting Plaintiff and requesting the opportunity to meet with her in person.
Defendant Young requested to meet with Plaintiff at Baylor Hospital. Less than 3 days
after her mothers death and prior to her funeral service, Defendants Young and
Chestnut solicited Plaintiff by telephone. See Plaintiffs sworn Affidavit marked as
Exhibit 1 and the audio transcript of the call made to Ms. Ward which is marked as
Exhibit 2.
Defendants caused direct contact to be made with Plaintiff by telephone and in
person, for the express purpose of soliciting and providing professional legal services.
In Texas, solicitation for the express purpose of obtaining professional employment in
person, in direct violation of Texas Penal Code Section 38.12 and/or Texas Government
Code 82.0651, is a crime and is subject to civil penalties.
V. CAUSES OF ACTION-ALL DEFENDANTS
Count 1- VIOLATION OF TEXAS GOVERNMENT CODE 82.0651
Plaintiff incorporates by reference all the factual allegations contained in the

preceding paragraphs. Plaintiff belongs to a class of persons that Texas Government
Code 82.061 is specifically designed to protect. Plaintiffs injuries are of the type that
the statute was designed to prevent. The statute is one for which tort liability may be
imposed when violated and the penalties for such violation are set forth in the statute.
Defendants violated the statute without legal excuse. Therefore, Defendants are liable
to Plaintiff for violation of Texas Government Code 82.0651 and the penalties
associated therewith, including a $10,000.00 civil penalty plus attorneys fees and costs
of court.
Count 2-CIVIL CONSPIRACY
Plaintiff incorporates by reference the factual allegations contained in the
preceding paragraphs. Defendants combined to accomplish a lawful purpose by
unlawful means. Defendants had a meeting of the minds on the object and course of
action of their combination. Defendants committed an unlawful, overt act to further the
object and course of action of their combination.
Therefore, Defendants are liable to
Plaintiff for civil conspiracy. Moreover, since all the Defendants were involved in the
conspiracy, they are each jointly and severally liable to Plaintiff for statutory damages
and penalties.
Count 3-JOINT ENTERPRISE LIABILITY
Plaintiff incorporates herein all paragraphs set forth above for all purposes.
Defendants and/or co-conspirators are liable for the acts of all Defendants because at
the time of the illegal solicitation, Defendants and the co-conspirators were engaged in
a joint enterprise. Defendants and the co-conspirators had (1) an agreement to illegally
solicit Plaintiff who is a wrongful death beneficiary as a result of her mothers death; (2)
a common purpose in illegally soliciting personal injury victims; (3) a community of
pecuniary interest in that common purpose; and (4) an equal right to direct and control
the enterprise.
At the time of the illegal solicitation, it is the Plaintiffs belief that
Defendants were acting in concert and/or acting within the scope of a joint enterprise.
Count 4-PARTNERSHIP LIABILITY
Plaintiff incorporates herein all paragraphs set forth above for all purposes.
Defendants and their co-conspirators are jointly and severally liable for the acts of one
another because they operated as a partnership. Specifically, they:
(a)
Shared and/or had a right to share in profits of the business by way

of the illegal solicitation.
(b)
Expressed intent to be partners in the business by way of entering

into the agreement to illegally solicit personal injury victims.
(c )
Participated and/or had the right to participate in control of the

business by way of approval of the method of soliciting Plaintiff
and approval of actions of each other regardless of control.
(d)
Contributed and/or agreed to contribute money and/or property to

the business.
(e)
Shared and/or had the right to share gross revenues or proceeds of

their enterprise.
At the time of the illegal solicitation, Defendant Young, the solicitor making the
initial contact with Plaintiff was acting in the ordinary course of business and/or with the
authority of the partnership.
Count 5-AGENCY
preceding paragraphs. The Defendants intentionally conferred authority to their agent
and intentionally allowed said agent to believe that he/she had authority, or by lack of
due care allowed said agent to believe that he/she had authority. At and during the
term of the acts and/or omissions complained of herein, the acts committed by any
agent, representative, or employee of Defendants was done and occurred within the
scope of their agency. Therefore, the Defendants are liable to Plaintiff for their agents
and employees actions.
If Plaintiff is mistaken that the agent had actual authority, then Plaintiff alleges
that the agent had apparent authority to act on behalf of the Defendants.
Defendants
clothed their agent with apparent authority by sending her out to speak with the Plaintiff
on Defendants behalf. As a result of Defendants actions in clothing their agent in
apparent authority, Plaintiff believes that the agent was acting within the scope of their
authority in soliciting professional legal and medical services for Defendants.
Consequently, Defendants are now estopped from denying the authority of the agent to
solicit professional services on behalf of Defendants.
Count 6-RESPONDEAT SUPERIOR
preceding paragraphs. At and during the time of the acts complained of herein, said
acts of any employee or agent of Defendants occurred within the scope of general
authority and to accomplish the objectives for which the employee or agent was
employed. Defendants are therefore liable to Plaintiff for the acts and/or omissions of
any such employee and/or agent complained of herein under the doctrine of respondent
superior.
VI. DAMAGES

preceding paragraphs. Defendants acts described above, are in direct violation of
Texas Government Code 82.0651 and each of the Defendants are liable for the
damages set forth therein. Damages include an award of $10,000.00 to be assessed
against each named Defendant as set forth by the Texas Legislature as a penalty, plus
any actual damages in an amount to be determined by the trier of fact, and reasonable
and necessary attorneys fees for which Plaintiff now prays.
Defendants acts and/or omissions, when viewed from the standpoint of
Defendants at the time of said acts and/or omissions, involved an extreme degree of
risk, considering the probability and magnitude of the potential harm to Plaintiff.
Defendants had actual, subjective awareness of the risk involved in the above
described acts or omissions, but nevertheless proceeded with conscious indifference to
the rights, safety and/or welfare of Plaintiff.
Therefore, as a result of Defendants
wrongful acts and/or omissions, Plaintiff seeks to recover additional damages in the
form of exemplary damages in the amount of an additional $20,000.00 per Defendant
which said amount does not exceed the maximum amount permitted by applicable law
based on the amount of statutory damages.
Plaintiff now sues for recovery of monetary damages in an amount within the
jurisdiction of the Court. Pursuant to Rule 47 of the Texas Rules of Civil Procedure,
Plaintiffs in good faith plead the value of this case is over one hundred thousand dollars
($100,000.00) but less than five hundred thousand dollars ($500,000.00). Plaintiff
reserves the right to amend these amounts.
VI. REQUESTS FOR DISCLOSURE TO EACH NAMED DEFENDANT
Plaintiff hereby serves upon each named Defendant their Requests for
Disclosure pursuant to Rules 194.2 (a) through (k), and 194.4 of the Texas Rules of
Civil Procedure and request that each Defendant serve their answers and responsive
documents upon Plaintiffs counsel within 50 days of service.
VII. JURY DEMAND

In accordance with Rule 216 of the Texas Rules of Civil Procedure, Plaintiff
demands a trial by jury.
WHEREFORE, PREMISES CONSIDERED, Plaintiff requests that Defendants be
cited to appear and upon final trial Plaintiff be granted judgment, jointly and severally,
against Defendants for:
A. Statutory penalties as set forth in Texas Govt Code 82.0651 in the amount
of $10,000.00 assessed against each named Defendant;
B. Exemplary damages assessed against each named Defendant in the amount
of $20,000.00 or in an amount to be determined by a jury;
C. Reasonable and necessary attorneys fees and taxable court costs;
D. Pre-judgment and post-judgment interest at the maximum allowed by law;
Plaintiff further requests that she be awarded such other and further relief, both
at law and in equity, to which she may be justly entitled.
CARSE LAW FIRM
Tom Carse
State Bar No. 00796310
Carse Law Firm
6220 Campbell Road, Suite 401
Dallas, Texas 75248
Telephone: 972/503-6338
Facsimile: 972/503-6348
Email: service@carselaw.com
ATTORNEY FOR PLAINTIFF
AFFIDAVIT OF MATISHA WARD
STATE OF TEXAS
COUNTY OF DALLAS
On this day, Matisha Ward, appeared before me, the undersigned notary
public, and after I administered the oath to her, upon oath, she stated:
"I am over 21 years of age and capable of making this affidavit. All of my
statements herein are true, correct and they are within my personal knowledge.
1.
On or about May 2, 2016, my mother, Antoinette Brown was attacked by
several dogs. The injuries she received as a result of the attack ultimately led to
her death on May 9, 2016.
2.
On or about May 6, 2016 at approximately 4:49 p.m., I was at work when I
received a text message from Tiffinni A. Young. The text message stated that
Ms. Young had received information about me from a police officer at Baylor
Hospital. The text message stated that Ms. Young was praying for my family and
that she was saddened by what had happened to my mother. Ms. Young then
asked me to call her when I had a moment.
3.
I called Ms. Young on May 6, 2016. Ms. Young told me that the City of
Dallas had captured the dogs that attacked my mother and that they were going
to be put down. I asked Ms. Young if the City of Dallas had the dogs owner's
information. Ms. Young told me they did.
4.
At approximately 6:15 p.m. on May 6, 2016, I received another text

1
Page 1
message from Ms. Young asking me to call her.

5.
message from Ms. Young asking me to call her again.

6.
message from Ms. Young stating that the information she had previously
provided to me regarding the dogs capture and the dogs' owner's identity was
false and that she did not have any information on the case, but that someone
from the police department would be contacting me.
7.
At approximately 6:37 p.m., I replied to Ms. Young's text message. I was
very upset due to being provided with misinformation. I asked Ms. Young why
she would tell me that she had the information on the case if the information was
false. Ms. Young responded that she had obtained the information from someone
in her office. I told Ms. Young that they needed to make sure the information was
correct. Ms. Young apologized.
8.
At approximately 7:29 p.m. on May 6, 2016, I received a text message
from Ms. Young asking if I was available to meet with her at 7:30 p.m.
9.
On May 8, 2016 at approximately 10:27 a.m., I received a message from
Ms. Young telling me "good morning" and telling me that she was praying for my
mom, my siblings and my entire family.
10.
At approximately 10:32 a.m., Ms. Young offered to meet me at noon at
Baylor Hospital where my mother was hospitalized.

11.
I met with Ms. Young in the Robertson building. Ms. Young told me I had a
case but that she could not refer me to a lawyer because to do so was illegal.
Page 2
12.
On May 12, 2016, at approximately 5:47 p.m., I informed Ms. Young that I
had a lawyer.
13.
On May 13, 2016, 4 days after my mother passed, at approximately 8:39
p.m., Ms. Young sent me a text message that read "call me". I called Ms. Young
and she asked me to tell her the names of the attorneys I had spoken with. She
told me she had a lawyer sitting next to her and asked if I wanted to speak to
him. Ms. Young handed the telephone to a male who identified himself to me as
Chris Chestnut, an attorney with offices in Georgia and Florida. Mr. Chestnut
offered to meet with me for the purpose of providing legal representation in
connection my mother's wrongful death.
14.
I believe Ms. Young and Mr. Chestnut purposely acted together for the
purpose of unlawfully soliciting me for legal representation.

"Further Affiant sayeth not."
MAti MA~ / 1A.~Nl
Matisha Ward
SWORN TO and SUBSCRIBED before me on the /
rl-!:i. day
of July,
2016.
NORMALOPEZ
i'J MY COMMISSION EXPIRES
EXAS
February 25, 2018
Page3
Page 1
TIFFINNI:
MATISHA:
TIFFINNI:
Hey, how are you?
I'm good.
How are you?
I'm good.
Now, what -- tell me
what attorneys you've talked to.
MATISHA:
TIFFINNI:
MATISHA:
TIFFINNI:
I haven't talked to one yet.
Oh, you haven't?
No.
I have one sitting here.
Do you
want to talk to him?
MATISHA:
TIFFINNI:
Yes, ma'am.
Hold on one second.
Can you talk to her Chris?
CHRIS:
How are you doing?
MATISHA:
CHRIS:
I'm fine.
How are you?
I'm good, I'm good.
I was just
talking -- and I'm so sorry to hear about your mother.
Talking to Tiffinni here.
MATISHA:
CHRIS:
Yes, sir.
Is this a good time to talk to you?
My name's Chris Chestnut.

MATISHA:
CHRIS:
I'm a wrongful death lawyer.
Oh, yes, sir.
I'm out of Florida and Atlanta.

I
specialize in wrongful death cases.

about what happened.
She was telling me
That's a tragedy.
MATISHA:
Yeah.
Page 2
CHRIS:
It's absurd.
MATISHA:
CHRIS:
Yeah, it was messed up.
Yeah.
just don't understand.
MATISHA:
I mean, just goodness, I
So -- go ahead.
No, no, I -- yeah, I don't
understand that neither.
the Mayor was getting on TV.
know what to say about the situation.
Go ahead.
And then it's like, you know,
Like he really don't even
So, I mean, something need to be done
10
because, obviously, people kept trying to, you know, get
11
in contact with them to come and get them dogs and, you
12
know, all that stuff.
13
It shouldn't take for my mama to pass for
14
them to go out there and, you know, do their job.
15
that don't make any sense to me.
16
CHRIS:
17
MATISHA:
18
Right.
And I feel like somebody really
need to pay for what happened to my mom, you know --
19
CHRIS:
20
MATISHA:
21
Like
Right.
-- regardless of her life pass.
That did not have to happen to my mama.
22
CHRIS:
That's right.
23
MATISHA:
Just --
And I feel like somebody need to
24
pay me, I mean, because they took me -- they took my
25
mama away from her grandkids.
You know, like, we'll
Page 3
never see my mom again and they owe us that, you know.
That don't make sense to us.
CHRIS:
So we still can't --
And the way she died, you know, you
just can't -- that's just a horrible way, that's
just horrible, you know.
MATISHA:
I mean, it's ridiculous, the
wounds, I mean, the wounds that I seen for myself.
have a couple of them on my phone, you know.
didn't deserve that.
10
My mama
It was -- them dogs was fighting dogs.
11
know, ain't no stray dogs going to do that to nobody.
12
They're not just going to attack nobody the way they
13
attacked my mama.
14
know.
You know, it was to her bones, you
So, I mean, that's --
15
CHRIS:
16
MATISHA:
17
CHRIS:
18
MATISHA:
Wow.
That's uncalled for.
Yeah.
I mean, so that -- the owner need
19
to pay.
20
whoever the people is, they need to pay.
The Mayor need to pay.
21
CHRIS:
22
MATISHA:
23
CHRIS:
24
MATISHA:
25
You
The animal business,
Yeah.
They need to pay.
That's right.
So whatever I need to do to get
justice for my mama, then that's what I'm going to do.
Page 4
1
2
CHRIS:
Do you live in
Dallas, too?
3
4
Are you in Dallas?
MATISHA:
Yes, sir, I do, I stay off of 75,
635 and 75, North Dallas area.
CHRIS:
Yeah.
I tell you what, why don't
we do this then.
you can Google me to get the information here -- but
I'll call you tomorrow.
MATISHA:
10
11
I'm going to give you my cell phone --
CHRIS:
We can schedule a time.
MATISHA:
13
CHRIS:
representation.
15
you found a mortuary?
16
MATISHA:
21
22
CHRIS:
Have
She's actually going to get
Oh, Golden Gate, yeah, I know
Golden Gate.
MATISHA:
Yes, sir.
I have to go out there
tomorrow to fill out some more paperwork, so, yeah.
CHRIS:
23
Chris Chestnut.
24
association --
25
We need to do an investigation.
cremated at Golden Gate.
18
20
Okay.
Okay, because you do need
14
19
I can come
out maybe this weekend and meet with you.
12
17
Okay.
You tell them that you talked to
I do a lot of work with him and the
MATISHA:
Okay.
Page 5
CHRIS:
-- Golden Gate.
And so whatever
you-all need, you know, if you have any problem, you let
me know.
MATISHA:
CHRIS:
MATISHA:
Oh, no, he --
Chris Chestnut he'll know.
Yeah, he -- my mom and him grew
up with them.
CHRIS:
Did they?
MATISHA:
Yeah, I just found that out
10
recently that, you know, he and my mom, they grew up
11
together.
12
CHRIS:
Okay.
Yeah, so, all right.
13
name is Chris Chestnut.
14
text you my cell phone and I'll follow up with you
15
tomorrow.
16
MATISHA:
17
CHRIS:
So my
I'm going to get you -- I'll
Okay.
Okay.
But -- because part of -- part of
18
what we want to do is I want to make sure they preserve
19
pictures and things they take of your mom so when we
20
file a report --
21
MATISHA:
22
CHRIS:
23
Okay.
-- that there's evidence of how
bad --
24
MATISHA:
25
CHRIS:
And it is.
Because it was --
Page 6
MATISHA:
It is.
I have two of the
pictures in my phone, but they wouldn't allow me to take
any more.
CHRIS:
Yeah.
MATISHA:
But they -- it shows, you know,
some of them at the hospital before we actually took her
off of life support, you know, and they were -- it
was -- you know, I don't set that on nobody.
it's something out of a horror movie, that's how bad it
10
is.
You know,
That's how --
11
CHRIS:
I believe it.
Well, so let's make
12
sure before they cremate her, because the only thing
13
with the cremation is all the evidence -- you know --
14
MATISHA:
I'm not sure if they cremated her
15
yet, because they haven't called me and told me.
16
will probably have to call them tomorrow to see.
17
CHRIS:
18
MATISHA:
19
CHRIS:
So I
Okay.
But they should have pictures.
Find out, find out.
Just make sure
20
they take photos, especially if they're going to do an
21
autopsy.
22
MATISHA:
23
CHRIS:
24
MATISHA:
25
Yeah.
They did.
-- they'll take pictures.
Okay.
examiner take pictures of her?
So would a medical
Page 7
CHRIS:
They would have some photos, too,
but we can also ask them -- especially if --he'll take
pictures --
MATISHA:
Okay.
Okay.
Okay.
Okay, so I'm
going to go over there tomorrow and I'm going call them
in the morning to see if they can take them.
CHRIS:
Okay.
I'm going
That sounds good.
to text you my name and my cell phone number and get
back with you tomorrow.
10
MATISHA:
11
CHRIS:
12
14
CHRIS:
MATISHA:
I will.
We'll
Yeah, I appreciate that.
I'm
just -CHRIS:
19
MATISHA:
20
CHRIS:
That's a lot.
Yeah.
Hang in there.
I'll talk to you
tomorrow.
22
MATISHA:
23
CHRIS:
25
I will.
I'm sorry about your mother.
18
24
Okay.
Okay.
talk tomorrow.
16
21
If you need anything --
I'm here, just will text you my phone number.

MATISHA:
17
Okay.
All right.
13
15
Okay?
Okay.
Okay.
All right.
Tiffinni will
call you back.
MATISHA:
Okay.
Okay.
Okay.
Thank you.
STATE OF TEXAS
COUNTY OF DALLAS
On this day, Matisha Ward, appeared before me, the undersigned notary
public, and after I administered the oath to her, upon oath, she stated:
"I am over 21 years of age and capable of making this affidavit. All of my
statements herein are true, correct and they are within my personal knowledge.
1.
On or about May 2, 2016, my mother, Antoinette Brown was attacked by
several dogs. The injuries she received as a result of the attack ultimately led to
her death on May 9, 2016.
2.
On or about May 6, 2016 at approximately 4:49 p.m., I was at work when I
received a text message from Tiffinni A. Young. The text message stated that
Ms. Young had received information about me from a police officer at Baylor
Hospital. The text message stated that Ms. Young was praying for my family and
that she was saddened by what had happened to my mother. Ms. Young then
asked me to call her when I had a moment.
3.
I called Ms. Young on May 6, 2016. Ms. Young told me that the City of
Dallas had captured the dogs that attacked my mother and that they were going
to be put down. I asked Ms. Young if the City of Dallas had the dogs owner's
information. Ms. Young told me they did.
4.
TFB Exhibit F
Page 1
message from Ms. Young asking me to call her.

5.
message from Ms. Young asking me to call her again.

6.
message from Ms. Young stating that the information she had previously
provided to me regarding the dogs capture and the dogs' owner's identity was
false and that she did not have any information on the case, but that someone
from the police department would be contacting me.
7.
At approximately 6:37 p.m., I replied to Ms. Young's text message. I was
very upset due to being provided with misinformation. I asked Ms. Young why
she would tell me that she had the information on the case if the information was
false. Ms. Young responded that she had obtained the information from someone
in her office. I told Ms. Young that they needed to make sure the information was
correct. Ms. Young apologized.
8.
At approximately 7:29 p.m. on May 6, 2016, I received a text message
from Ms. Young asking if I was available to meet with her at 7:30 p.m.
9.
On May 8, 2016 at approximately 10:27 a.m., I received a message from
Ms. Young telling me "good morning" and telling me that she was praying for my
mom, my siblings and my entire family.
10.
At approximately 10:32 a.m., Ms. Young offered to meet me at noon at
Baylor Hospital where my mother was hospitalized.

11.
I met with Ms. Young in the Robertson building. Ms. Young told me I had a
case but that she could not refer me to a lawyer because to do so was illegal.
Page 2
12.
On May 12, 2016, at approximately 5:47 p.m., I informed Ms. Young that I
had a lawyer.
13.
On May 13, 2016, 4 days after my mother passed, at approximately 8:39
p.m., Ms. Young sent me a text message that read "call me". I called Ms. Young
and she asked me to tell her the names of the attorneys I had spoken with. She
told me she had a lawyer sitting next to her and asked if I wanted to speak to
him. Ms. Young handed the telephone to a male who identified himself to me as
Chris Chestnut, an attorney with offices in Georgia and Florida. Mr. Chestnut
offered to meet with me for the purpose of providing legal representation in
connection my mother's wrongful death.
14.
I believe Ms. Young and Mr. Chestnut purposely acted together for the
purpose of unlawfully soliciting me for legal representation.

"Further Affiant sayeth not."
MJA!X MA~ / 1A~Nl
Matisha Ward
SWORN TO and SUBSCRIBED before me on the /
+!:i_
day of July,
2016.
,~'1il\'i'
NORMA LOPEZ
!~X,i'J MY COMMISSION EXPIRES
'-~...~.if-'
Februru25
f/lf.1~-..~
-1
' 2018
EXAS
Page3

Florida State Bar 2016.8.31 Emergency Suspension Christopher M. Chestnut

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Florida State Bar 2016.8.31 Emergency Suspension Christopher M. Chestnut

Uploaded by

Copyright:

Available Formats

IN THE SUPREME COURT OF FLORIDA

THE FLORIDA BAR,

Supreme Court Case No.

PETITION FOR EMERGENCY SUSPENSION

The filing of this Petition for Emergency Suspension has been

authorized by the Executive Director of The Florida Bar.

Respondent, Christopher M. Chestnut, is and at all times hereinafter

Respondent is currently the subject of nine bar disciplinary matters

which have been identified as:

SC16-797, The Florida Bar File Nos. 2015-00,161(4B), 2015-00,505

(4C), 2015-00,565(4D), 2016-00,047(4C), 2016-00,193(4A) & 2016-00,229(4B);

SC16-1480, The Florida Bar File Nos. 2016-00,473(4B) & 2016-

The Florida Bar File No. 2017-00,098(4D) the instant file.

The bars investigation of respondent reveals the following history:

On September 26, 2014, The Florida Bar filed a four-count complaint

against respondent alleging among other things, lack of competence, candor,

In that case, although the bar voluntarily dismissed three counts,

respondent was found guilty of lack of diligence and communication.

As a result, respondent received a public reprimand on October 8,

Thereafter, on May 6, 2016, the bar filed a six-count complaint

(SC16-797) against respondent alleging egregious conduct involving among other

Count I, TFB File No. 2015-00,161(4B), Lakay Smith, alleges that

Count III, TFB File No. 2015-00,565(4D), Johnny Winthrop Powell,

alleges that respondent undertook to represent Mr. Powell in Maryland even

Count V, TFB File No. 2016-00,193(4A), Dr. John T. Hoehn, alleges

Count VI, TFB File No. 2016-00,229(4B), Kashara Taylor, alleges

The foregoing Counts, comprising SC16-797, are in active litigation

and scheduled for final hearing starting December 12, 2016.

1480) against respondent alleging lack of competence, candor, and

Count I, TFB File No. 2016-00,473(4B), Anthony D. Jordan, Sr.,

entered its order finding that respondent:

As a result of respondents actions, Mr. Jordan filed his grievance

Removal of Conservator and for an Accounting. Copy attached as Exhibit D.

Count II, TFB File No. 2016-00,517(4D), Toni Washington, alleges

The foregoing Counts, comprising SC16-1480, are in active litigation

and scheduled for case management conference on September 22, 2016.

In the instant case, TFB File No. 2017-00098(4D), on August 23,

That complaint begins with

TO THE COURT AND JURY. THE DARKEST HOUR

IN ANY MANS OR WOMANS LIFE IS WHEN

The facts in this case are particularly egregious:

In Dallas, a woman was tragically killed by a pack of

dogs. While she lay dying in ICU, the womans daughter,

contacting the daughter thereafter and eventually put

Respondent is not admitted in Texas and he also misrepresented

himself as a Georgia attorney.

is the recording of respondent himself repeatedly offering his services to the

Both the texts and respondents recording were broadcast to the

general public in news stories that have garnered national attention.

In that case, respondent has not denied the allegations.

Instead, respondent is on record as saying I perceive it as Ms. Young

bar filed SC16-797.

In support of her complaint, Ms. Wards affidavit details the history of

her case and respondents wrongdoing. Copy attached as Exhibit F.

Evidently, respondent does not understand The Rules Regulating The

The foregoing Exhibits and the attached affidavits of Anthony D.

By reason of the foregoing, respondent has violated the following

Rules Regulating The Florida Bar: 4-1.1 (Competence), 4-1.7(a)(2)(Conflict of

Order respondent to accept no new clients from the date of this

Order respondent to furnish a copy of the suspension order to all

Order respondent to refrain from withdrawing or disbursing any

which withdrawal may only be made in accordance with restrictions imposed by

other financial institution account related to respondents law practice or transfer

Order respondent to notify, in writing, all banks and financial