Professional Documents
Culture Documents
Federal Lawsuit
Federal Lawsuit
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COMPLAINT
TABLE OF CONTENTS
INTRODUCTION Page 3
PARTIES Page 8
FACTS Page 30
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Mr. D. Deaton, Ms. T. Peake, and minor children J.K.D., L.W.D., G.M.W., and
R.E.D., through the undersigned counsel, brings this action and alleges in support
INTRODUCTION
to the exploitation of this enterprise and a local business owner dedicated his
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the authority of her office to influence and dictate the outcome of cases not
assigned to her. Judge Patricia Stephens has been left unchecked, and the
citizens within this community are without access to litigate their claims and
without relief from the damage caused by this enterprise, described in detail
below, engaging in illegal acts. During her tenure, two judges she directly
supervised have thus far been removed from the bench of Jefferson County
4. Ten years ago, Judge Batiste was ordered suspended for three months without
pay from Jefferson County Circuit Court Domestic Relations Division for
ethical violations.
5. Seventeen months ago, Judge Blocton was removed from Jefferson County
Circuit Court Domestic Relations Division for bad acts and further disbarred
6. Both Judge Batiste and Judge Blocton were directly supervised by Judge
Patricia Stephens.
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8. Few litigants can withstand the physical, emotional, and financial harm
their children.
9. The Plaintiffs addressed and have acted upon their belief for pursuing all
possible, legal steps to protect their constitutional rights. Any parents daring
10. Ms. T. Peake and Mr. D. Deaton want to protect their children. The
Plaintiffs, including all the Plaintiff minor children, file this lawsuit to
private action that prioritizes cash, power, and influence over justice.
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11. The court has jurisdiction as this case involves claims arising from the
Constitution and laws from the United States pursuant to 28 U.S.C. § 1331
12. Federal courts have subject matter jurisdiction over RICO claims pursuant to
18 U.S.C. § 1964.
13. The Court has supplemental jurisdiction over Plaintiffs’ additional state law
1391(b)(2) and (3) as a substantial part of the events or omissions giving rise
to the claims stated herein occurred in the southern division of the Northern
District of Alabama and all Defendants are subject to this Court’s personal
THE ENTERPRISE
15. The Defendants, jointly and severely, and the co-conspirators conducted or
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U.S.C. § 1962(d).
Montgomery Lee, Judith Crittenden, Gary Lee, Thomas McKnight, Jr., Jay
Mashburn, Caroline Taylor, Kim Davidson, Heather Fann and Terri Miller
17. The entities operated by The Enterprise participants are: The Domestic
Relations Division of the 10th Judicial Circuit Court for Jefferson County,
Maryland Dredging, Inc., Hope for Healing, LLC, CPE Clinic, LLC, Bay
Area Christian Counseling, Crew Gentle Law, P.C., Crew Law Group,
Caroline O. Taylor P.C. The Wess Law Firm, P.C., and Hardy Law Firm,
LLC.
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multiple tribunals, offer and accept bribes, extort, and conceal information
from state and federal agencies, so that The Enterprise participants could
profit directly or in some other manner while depriving parents and children
19. As alleged in detail below, the defendants and The Enterprise used influence
under the color of state law, and the Defendants and the co-conspirators
PARTIES
20. Plaintiff Taylor Peake, (“Ms. T. Peake”), brings these actions, individually
on her own behalf and as mother and next friend of G.M.W., her minor
child. At all times relevant and material to this complaint, both were
21. Plaintiff Drew Deaton, (“Mr. D. Deaton”), brings these actions, individually
on his own behalf and as father and next friend of J.K.D., L.W.D., and
R.E.D., his minor children. At the time of this filing, the minor children are
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this complaint, the minor children lived with their father in Jefferson County,
22. Plaintiffs G.M.W., J.K.D., L.W.D., and R.E.D.1 are all minor children and
this action is being brought on their behalf individually. The claims alleged
by the minor children accrued while they all were minor children. All of the
the Presiding Judge of the Tenth Circuit of the Jefferson County Domestic
adult resident of Jefferson County, Alabama. As the presiding judge, she has
the duty and obligation to supervise the domestic relations judges in this
circuit, including the judges and court staff serving under her. Judge
Stephens acted inside and apart from the litigation process, including but not
limited to the following ways: (1) to gather evidence not before her court,
(2) to hold ex parte calls regarding cases before her court and refuse to
disclose the caller on the record, and (3) exited her chambers to participate
1 Pursuant to the Fed. R. Civ. P. 5.2, the minor children’s initials are used in place of names so as
to protect their privacy.
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with the consent and direction of Judge Stephens who personally knew
misconduct including The Enterprise and its actions. Mr. D. Deaton’s case
was transferred to her court and remains pending as of the filing of this
24. Defendant Agnes Chappell, (“Judge Chappell”), is recently retired from the
and Mr. S. Wyatt’s divorce and post-divorce custodial cases were assigned to
Judge Stephens as her presiding judge. Judge Chappell also had a duty to
supervise the staff assigned to her. Judge Chappell acted inside and apart
from the litigation process, including but not limited to the following ways:
advertisements against Ms. T. Peake’s attorney, and (3) to wield the prestige
of her office to designate her judicial successor prior to the election. The
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activity which occurred with the consent and direction of Judge Chappell
pattern and practice of misconduct including The Enterprise and its actions.
25. Defendant Alisha Ruffin May, (“Judge May”), is a judge of the Tenth Circuit
Jefferson County Court. Judge May served as the judge over a post custody
domestic relations case between Ms. T. Peake and Mr. S. Wyatt. The
activity which occurred with the consent and direction of Judge May, who
and practice of misconduct including The Enterprise and its actions. Judge
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Attorney Drennan is serving as the key witness for Ms. L. Deaton while
representing her custody case. The constitutional rights violations and other
with the consent and direction of Attorney Drennan separate, apart, and
which occurred with the consent and direction of Attorney Duncan separate,
Jefferson County, Alabama. At all times relevant hereto, GAL Brantley was
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states which occurred with the consent and direction of GAL Brantley
29. Defendant Everett Wess, (“GAL Wess”), is a licensed attorney through the
Alabama. At all times relevant hereto, GAL Wess was employed by and an
owner of Defendant The Wess Law Firm, P.C. The constitutional rights
which occurred with the consent and direction of GAL Wess separate, apart,
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through the Alabama State Bar. Attorney Gregory is an adult resident of the
which occurred with the consent and direction of Attorney Gregory separate,
licensed attorney through the Alabama State Bar. Attorney Montgomery Lee
Defendant Crittenden Partners and responsible for supervising the roles of:
criminal activity across states which occurred with the consent and direction
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litigation process.
states which occurred with the consent and direction of Attorney Crittenden
34. Defendant Gary Lee, (“Attorney Lee”), is a licensed attorney through the
Alabama State Bar. Attorney Lee is an adult resident of the state of Alabama.
Defendant Wallace, Jordan, Ratliff & Brandt, LLC. Defendant Gary Lee
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activity across states which occurred with the consent and direction of
attorney through the Alabama State Bar. Attorney McKnight, Jr. is an adult
pattern and practice of misconduct and criminal activity across states which
occurred with the consent and direction of Attorney McKnight, Jr. separate,
36. Defendant Jay Clark, (“Attorney Clark”), is a licensed attorney through the
Alabama. At all times relevant hereto, Defendant Jay Clark was employed
responsible for supervising the roles of: Defendant Gary Lee and Defendant
Thomas McKnight, Jr. Defendant Jay Clark conspired with his employees to
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states which occurred with the consent and direction of Attorney Clark
37. Defendant Renee Wilson, (“Ms. R. Wilson”), is an adult resident of the state
activity across states which occurred with the consent and direction of Mr.
R. Wilson.
states which occurred with the consent and direction of Mr. C. Wilson.
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activity across states which occurred with the consent and direction of Ms.
E. Goldman.
criminal activity across states which occurred with the consent and direction
of Ms. D. Maynard.
42. Defendant David Kellner, (“Mr. D. Kellner”), is an adult resident of the state
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criminal activity across states which occurred with the consent and direction
of Mr. D. Kellner.
and criminal activity across states which occurred with the consent and
44. Defendant Andrea Weiss, (“Ms. A. Weiss”), is an adult resident of the state
of Maryland. Ms. A. Weiss was Head of School for St. Anne’s Episcopal
School and responsible for supervising the role of Connie Coker when she
45. Defendant Connie Coker, (“Ms. C. Coker”), is an adult resident of the state
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Assistant Head of School and later became Interim Head of School for St.
46. Defendant Alan Blotcky, (“Dr. Blotcky”), is an adult resident of the state of
states which occurred with the consent and direction of Dr. Blotcky.
47. Defendant Wendy Crew, (“Attorney Crew”), is an adult resident of the state
of Alabama and licensed through the Alabama State Bar. At all times
Crew Law Group, including accepting and disbursing funds from Crew Law
Group Trust Account, Crew Law Group does not appear in the Alabama
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activity across states which occurred with the consent and direction of
the state of Alabama and licensed through the Alabama State Bar. At all
Crew Law Group. Crew Law Group does not appear in the Alabama
states which occurred with the consent and direction of Attorney Vineyard
49. Defendant Marcus Jones, (“Attorney Jones”), is an adult resident of the state
of Alabama and licensed through the Alabama State Bar. The constitutional
states which occurred with the consent and direction of Attorney Jones
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from September 2021 until January 2023. JA Brantley through her role in
minor child Plaintiffs and knowingly made false statements before the
presiding court in which she worked. The constitutional rights violations and
after stealing his client’s money in a family court case in Maryland. The
activity across states which occurred with the consent and direction of Mr.
C. Langrall.
52. Defendant Carolyn Wyatt, (“Ms. C. Wyatt”), is an adult resident of the state
misconduct and criminal activity across states which occurred with the
53. Defendant Gary Wyatt, (“Mr. G. Wyatt”), is an adult resident of the state of
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and criminal activity across states which occurred with the consent and
misconduct and criminal activity across states which occurred with the
state of Alabama and licensed through the Alabama State Bar. The
activity across states which occurred with the consent and direction of
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57. Defendant Heather Fann, (“Attorney Fann”), is an adult resident of the state
of Alabama and licensed through the Alabama State Bar. The constitutional
states which occurred with the consent and direction of Attorney Fann
58. Defendant Terri Miller, (“Ms. T. Miller”), is an adult resident of the state of
with its principal place of business in Birmingham, AL and was at all times
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61. Defendant Wallace, Jordan, Ratliff & Brandt, L.L.C. (“Wallace Jordan”) is a
MD and was at all times material to this complaint doing business in Anne
64. Defendant CPE Clinic, LLC (“CPE Clinic”) is a Domestic LLC with its
65. Defendant Hope for Healing, LLC (“Hope for Healing”) is a Domestic LLC
with its principal place of business in Annapolis, MD and was at all times
Maryland.
a Domestic LLC with its principal place of business in Bowie, MD and was
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County, Maryland.
Annapolis, MD. At all times material to this complaint, Bay Area Christian
68. Defendant Crew Gentle Law, P.C. (“Crew Gentle Law”) is a Domestic
69. Defendant Crew Law Group (“Crew Law Group”) is operated by Wendy
Crew with its principal place of business in Birmingham, AL and was at all
Alabama. Crew Law Group operates Crew Law Group Trust Account
receiving and disbursing funds from clients despite no record of Crew Law
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71. Defendant Alan D. Blotcky, Ph.D., LLC (“Alan D. Blotcky, Ph.D., LLC”) is
72. Defendant The Hardy Law Firm, LLC (“Hardy Law Firm”) is a Domestic
73. Defendant The Wess Law Firm, P.C. (“Wess Law Firm”) is a Domestic
74. Defendant Kim Davidson Law Office, LLC (“Davidson Law Office”) is a
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Defendant Entity
Attorney Drennan, Attorney Kirk.Drennan, P.C.
Duncan
Attorney Crittenden, Attorney Crittenden Partners, P.C.
Montgomery Lee, Attorney
Yarbrough, Attorney Gregory
Attorney Clark, Attorney Lee, Wallace, Jordan, Ratliff & Brandt,
Attorney McKnight, Jr. L.L.C.
Ms. A. Weiss, Ms. C. Coker St. Anne’s School of Annapolis,
Incorporated
Mr. C. Wilson, Ms. R. Wilson, Southern Maryland Dredging, Inc.
Ms. E. Goldman
Ms. D. Maynard Hope For Healing, LLC
Mr. D. Kellner Solace Family Counseling, LLC
Dr. Labellarte CPE Clinic, LLC
Ms. T. Miller Bay Area Christian Counseling
Attorney Crew, Attorney Crew Gentle Law, P.C., Crew Law
Vineyard Group
Ms. C. Taylor Caroline O. Taylor P.C.
GAL Brantley The Hardy Law Firm, LLC
GAL Wess The Wess Law Firm, P.C.
Attorney Davidson Kim Davidson Law Office LLC
Dr. Blotcky Alan D. Blotcky, Ph.D., LLC
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FACTS
75. Ms. T. Peake and Mr. D. Deaton both have a child or children from a
previous marriage.
76. Ms. T. Peake and Mr. D. Deaton were married on June 29, 2019.
77. During the trip to celebrate their wedding, all of the minor children bonded
parent’s home.
78. Over the next few weeks, Ms. T. Peake and Mr. D. Deaton learned of
additional facts that supported their concerns and sought relief from the
79. Instead of protecting the children, the follow series of illegal and unethical
events occurred.
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BACKGROUND
Defraud.
80. Attorney Montgomery Lee and her now husband, Attorney Lee, were
81. Attorney Lee’s divorce case took place in part before Judge Chappell’s
court.
82. At all times relevant, Judge Chappell was directly supervised by Judge
83. Attorney Montgomery Lee and Attorney Lee conspired together to litigate
against his then-wife, who was suffering from a breast cancer diagnosis.
thousands of dollars from her retirement account to Attorney Lee, while his
85. On November 22, 2016, Attorney Montgomery Lee signed the divorce
before the trial court in the Tenth Judicial Circuit Court of Jefferson County.
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86. On December 28, 2016, the trial court in the Tenth Judicial Circuit Court of
Attorney Lee.
87. At some time on or around January 2017, Judge Chappell took the bench at
88. At least on or before January 12, 2017 and on every date following, Attorney
State Bar and Attorney Lee’s ex-wife regarding the state of Attorney
89. Attorney Lee and Attorney Montgomery Lee worked together to request and
90. Judge Chappell entered an order for a Qualified Domestic Relations Order
on May 11, 2017 while Attorney Montgomery Lee was serving as counsel
91. Months following the entry of the order and leading up to the announcement
later admitted that they were dating on or before January 12, 2017.
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92. Firms Wallace Jordan and Crittenden Partners colluded to increase billings
gained from Attorney Montgomery Lee and Attorney Lee’s unethical legal
Custody Cases.
93. Attorney Montgomery Lee is the managing partner at the law firm,
Crittenden Partners.
96. Following this consultation and the divorce of Ms. T. Peake and Mr.
97. Crittenden Partners appeared as legal counsel for Mr. S. Wyatt on or around
August 2019.
98. The standard of care required Attorney Montgomery Lee to keep the
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101. But for their possession of the information gained in confidence, Mr. S.
Wyatt would not have been able to prevail against Ms. T. Peake in their post-
divorce litigation.
102. In fact, Mr. S. Wyatt alleged that no other attorney in Alabama could
possibly represent him except for the Crittenden Partners and further
104. On or around the same time, Crittenden Partners was also retained by Ms. L.
Deaton, but did not file a notice of appearance in the Deaton case.
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105. Instead, Crittenden Partners shared information between the two cases and
met with GAL Brantley and GAL Wess to attempt to co-mingle the cases,
106. Fearing collusion between the defendants, Ms. T. Peake filed with the
108. Attorney Montgomery Lee made false statements to the Alabama Court of
Civil Appeals, which The Alabama Court of Civil Appeals relied upon is its
opinion.
109. On or around April 30, 2021, The Alabama Court of Civil Appeals did not
hold any opinion that their representation was proper, instead they held, for
110. Following the ruling from the Alabama Court of Civil Appeals and their
false statements in multiple tribunals, Attorney Montgomery Lee and her co-
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111. Crittenden Partners recommended Mr. S. Wyatt seek additional legal counsel
112. Crittenden Partners referred Mr. S. Wyatt to Attorney Lee, their managing
partner’s husband.
114. Attorney Lee filed a lien in the original Peake/Wyatt divorce action against
115. Attorney Lee received multiple contingency based payments from Wallace
Jordan from the referral from his now-wife’s firm that directly benefitted the
Lee household.
their position as Officers of the Court to defraud the Plaintiffs of their money
117. Attorney McKnight, Jr. worked as co-counsel with Attorney Lee in these
pleadings and court appearance regarding Ms. T. Peake’s business and, upon
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118. Attorney McKnight, Jr. knew and directly acknowledged that this referral
119. Attorney McKnight, Jr. further knew that there was a dispute over the
conflicted nature of the legal representation and took no steps to resolve the
issue.
120. With unclean hands, Attorney McKnight, Jr., continued his representation
121. Wallace Jordan and their managing partner, Attorney Clark, were put on
notice of the conflict on multiple occasions, including but not limited to,
when Ms. T. Peake reported that Attorney Lee was refusing to facilitate
settlement offers in letters or emails sent on: April 28, 2022, July 11, 2022,
122. Wallace Jordan and Attorney Clark knew or should have known at all times
relevant that Attorney Lee was having romantic relations with his attorney,
Attorney Montgomery Lee, that represented him in his own divorce in front
of Judge Chappell.
123. Multiple attorneys at Wallace Jordan were receiving filings wherein these
issues were raised, but they made no attempts to stop or correct these
124. When Ms. T. Peake provided notice to Wallace Jordan, Attorney Lee,
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misconduct, Attorney Lee retaliated by, among other things, name calling
125. Then in August 2022 in further retaliation, Attorney Lee filed a motion
127. When faced with the possibility of a new judge given Judge Chappell’s
“Would the idea with that be that that's heard by Your Honor personally after
128. Attorney Lee knew that in front of a fair tribunal, who was not a participant
occur.
D. Court of the Judiciary Removes Nakita Blocton from Office for Bad Acts.
129. In 2018, Judge Blocton was assigned Mr. D. Deaton and Ms. L. Deaton
divorce case.
130. In 2019, Judge Blocton was assigned Mr. D. Deaton and Ms. L. Deaton’s
131. On December 10, 2021, in the Alabama Court of the Judiciary, Judge Nakita
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133. At all times relevant, Judge Blocton was directly supervised by Judge
wherein Mr. D. Deaton and minor children Plaintiffs L.K.D., L.W.D., and
135. This was allowed to occur at the hands and direct supervision of Judge
Stephens.
136. Blocton hired Attorney Robert Mackenzie as counsel for her case before the
fixer.
Conclusions in their final order entered on December 10, 2021, they stated
in part:
“This Court does find, however, that the Commission proved by clear and
This Court also finds that the Commission proved by clear and convincing
evidence that Judge Blocton engaged in a pattern of abuse of staff, attorneys, and
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litigants. For example, Judge Blocton referred to one employee as a "heifer” and
verbally abused and belittled another employee. Judge Blocton also ordered
employees to allow her to see their private cell phones so that information that
instructed them to provide to her their private login information to their work
computers.
including excessive, unproductive, and unnecessary late nights and weekends, and
she made repeated threats to fire employees in an attempt to intimidate them. Judge
Blocton also called an attorney, forcing the attorney to beg Judge Blocton not to
fire an employee who had spoken with a litigant about the harm she had suffered
This Court also finds that the Commission has proved by clear and convincing
evidence that Judge Blocton used several Facebook aliases to communicate with
the case.
This Court further finds that the Commission has proved by clear and convincing
evidence that, although she spent a substantial amount of time in her office, Judge
Blocton failed to promptly dispose of many of the cases assigned to her, and that
Judge Blocton is unable to effectively remedy her backlog of cases. Two judges
were specially appointed to handle Judge Blocton's backlog after she left office in
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Jefferson County have a high caseload, said that she was "appalled" by the number
of Judge Blocton's cases that had been pending for an inappropriate amount of time
without resolution.
The other judge testified that it was clear that Judge Blocton had not established an
effective way of handling cases, and he noted the adverse effect that the
and testified that the inordinate delays "gave a black-eye" to the judicial system.
This Court also finds that the Commission has proved by clear and convincing
evidence that Judge Blocton engaged in a pattern of dishonesty and deception. This
matter.”
E. Assault in an Uber.
138. On April 22, 2019, Ms. L. Deaton assaulted Mr. D. Deaton at an exchange of
139. Without invitation, Ms. L. Deaton launched herself into Mr. D. Deaton’s
Uber, grabbed his shoulder, and refused to leave the vehicle in front of the
children.
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140. Following this event, on June 17, 2019, Judge Laura Robinson in the District
Court of Maryland, District for Glen Burnie, found Ms. L. Deaton to be non-
assault.
141. Judge Laura Robinson in the District Court of Maryland stated from the
bench:
“In fact, on the video, what we do see is ostensibly -- I can’t see Mr. Deaton in the
van, but everybody agrees that’s him in the van, on the side of the van where Ms.
Deaton is. Ms. Deaton does have her leg up on the van….But it is very much a
position of dominance and so then we look at the contest with regard to Mr. Deaton
invocation of the right to remain silent on physically abusing Mr. Deaton and so
therefore, it’s an acknowledgment almost, tacitly that there has been a domestic
violence by Ms. Deaton to Mr. Deaton and that is the context of this interaction.
At some point, Ms. Deaton takes herself to the side of Mr. Deaton and this is where
I have a real problem with Ms. Deaton’s credibility. The video that was initiated by
the sister, Ms. Goldman, Ms. Deaton explained as what was being filmed was
excitement to greet the children. That was her characterization of their approach up
to the vehicle. I think that’s not a credible characterization, period. There was no
excitement to greet the children. If there was, there wouldn’t have been
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conversations about car seats and approaching the Uber driver about business
cards. This wasn’t filming the great reunion. That is not what happened.
And I have a problem in terms of credibility with the testimony describing it that
way. I also have a problem with the testimony of Ms. Deaton indicating that she
wanted a constructive relationship, that things were going wrong and that she
wanted to yield and olive branch. An olive branch doesn’t look like a video
recording asking an Uber driver about a business card, emails regarding child seats
and then walking over to the van on his side. That’s not an olive branch. And
additionally, that olive branch came in the context of an invocation of the right to
their olive branches. For all the reasons I’ve indicated, I do believe that Mr.
offensive physical touching and I do so find. The Court’s going to grant the
142. Ms. L. Deaton has a history of mental health issues, including but not
limited to, episodes of outrage that include outbursts and physical assault of
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143. Prior to and following this incident, Attorney Drennan would frequently
144. The Alabama court appointed GAL, GAL Brantley, would join in calling
to be more and more aggressive, which furthered the litigation and increased
145. Attorney Drennan, Attorney Duncan, and GAL Brantley were aware of and
and used this to rest control of the litigation from Ms. L. Deaton so as to
146. For example, Attorney Drennan and repeatedly stated that she reviews or
edits all of Ms. L. Deaton’s emails before they are sent to Mr. D. Deaton.
147. Ms. L. Deaton has confirmed that GAL Brantley is contacted and consulted
148. During Ms. L. Deaton’s sworn testimony on May 5, 2023, Ms. L. Deaton
had to attempt to count how many times the police had been involved in the
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151. The children were not sick, and Attorney Drennan was on-site with Ms. L.
152. Upon information and belief, Attorney Drennan took Plaintiff J.K.D. and
Deaton’s household.
154. Attorney Drennan assisted Ms. L. Deaton in removing J.K.D. and L.W.D.
155. At all times relevant, Attorney Drennan knew or should have known that this
156. Plaintiff children G.M.W. and R.E.D. attended South Highland Child
157. On August 27, 2019, Attorney Drennan and Ms. L. Deaton appeared at the
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158. Attorney Drennan’s actions were severe enough that school officials acted to
ensure all minor children were safe in rooms away from Attorney Drennan’s
screaming demands.
159. Upon information and belief, on August 27, 2019, Attorney Drennan was
161. Attorney Drennan alleged that she saw R.E.D. leave the preschool with her
father when she arrived, and S.H.C.D.C. clearly stated R.E.D. left with her
father.
162. Attorney Drennan did not explain why Mr. D. Deaton would not be allowed
163. Instead, Attorney Drennan, knowing the statement was false, misrepresented
164. Ms. L. Deaton later provided sworn testimony that as a legal guardian, Mr.
165. GAL Brantley knew at all times relevant that Ms. L. Deaton left the state
166. Almost two years after this incident, on August 25, 2021, Ms. L. Deaton
filed a lawsuit against the S.H.C.D.C. preschool for allowing the child’s
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167. At the time of this filing and at all relevant times prior, Attorney Drennan
matters.
168. It is unclear how Attorney Drennan is going to manage playing the role of
“key witness” and “attorney” in these issues affecting the minor children.
169. GAL Brantley was made aware and put on notice of Ms. L. Deaton’s claims
of severe mental anguish levied against the preschool, but GAL Brantley did
S.H.C.D.C. demands financial damages from the church preschool for Ms.
171. Regarding Ms. L. Deaton’s alleged claims, the Hon. Brown Green’s order
set of facts that would entitle Plaintiff to relief on her claims against the
GRANTED.
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172. Attorney Drennan continues to encourage and direct additional legal action,
173. Ms. L. Deaton filed her fourth (and third amended complaint) in her lawsuit
174. GAL Brantley was appointed as the guardian ad litem of the Plaintiff
children J.K.D, L.W.D, and R.E.D on August 29, 2019, by Jefferson County
previously.
or proven.
177. On December 10, 2021, Judge Blocton was removed from the bench for bad
acts while being directly supervised by Judge Stephens. Those bad acts
included but were not limited to, ex parte communication and the
178. In the proceedings before the Judicial Inquiry Committee, it was determined
that Judge Blocton and others had used social media and messaging apps to
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H. Children’s Testimony.
179. On August 30, 2019, the minor children J.K.D., L.W.D., and R.E.D. testified
180. The children’s testimony centered around actions that took place while they
181. This testimony was extremely concerning to the court and all in attendance.
182. Ms. L. Deaton alleged she was unaware of the events they described, but her
troubling events.
183. Attorney Drennan demanded the hearing continue with Mr. D. Deaton’s
counsel not present and out-of-state against what she knew to be a violation
184. Judge Blocton heard testimony over Mr. D. Deaton’s objection to his
186. Judge Blocton placed L.W.D. and Plaintiff R.E.D. with Mr. D. Deaton.
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189. Four years later, Ms. L. Deaton never scheduled an appointment or taken
190. Following Ms. L. Deaton’s assault on Mr. D. Deaton, GAL Brantley directed
to prevent Mr. D. Deaton from his physical custodial time with his children.
191. These incidents include, but are not limited to, the examples detailed below.
192. While the June 17, 2019 Maryland Court Ordered Protection From Abuse
193. On December 7, 2019, GAL Brantley demanded last minute changes to the
as a court appointed official, “U need to make the appt work for tomorrow.
It’s not optional and this will not be prolonged. If it's delayed, I’ll have to
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file something.” [sic] to demand Mr. D. Deaton take Plaintiffs L.W.D. and
195. GAL Brantley selected Ms. D. Malone for the mental health evaluation,
demanded Mr. D. Deaton make the appointment work, and ultimately GAL
196. On October 28, 2019, GAL Brantley acted under the color of the law to
R.E.D. without the possibility of obtaining a waiver from the minor children
197. On October 28, 2019 at 9:09 AM, GAL Brantley texted a threatening
demand on Ms. L. Deaton’s behalf: “Call and let the schools know that she
[Ms. L. Deaton] can pick them up after school is out. Not a request.” [sic]
198. Attorney Crittenden was previously ordered to be jailed for directing the
Relations Division under a previous presiding judge, and any attorney knows
or should know that directing the violation of a court order is not allowed by
law.
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Effects on G.M.W.
199. On September 10, 2019, Attorney Fann was appointed as a daily master by
200. Attorney Fann provided a report to Judge Chappell that her friend, Ms. C.
201. At no point was Ms. T. Peake informed of the cost nor necessity of Ms. C.
Taylor’s involvement.
202. Ms. C. Taylor was granted the ability to act as a defacto judge with very few
203. Upon information and belief, Attorney Fann and Ms. C. Taylor have a pre-
204. Through this unethical plot, Attorney Fann accrued even more professional
205. Judge Chappell then used her authority from the bench to force Mr. S. Wyatt
and Ms. T. Peake to pay approximately $15,000 for the unethical and
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206. Ms. T. Peake was not allowed an evidentiary hearing, as is required by law,
her invoices.
K. GAL Wess Accepts Bribe from Ms. C. Wyatt and Mr. G. Wyatt.
207. On October 28, 2019, Judge Chappell appointed GAL Wess as guardian ad
208. Ms. C. Wyatt and Mr. G. Wyatt bribed GAL Wess to serve as their de facto
209. GAL Wess’ conduct was directly in contrast to the wishes of the parents as
210. To date, GAL Wess has been ordered to receive approximately $80,000 in
211. At the Peake v. Wyatt post-divorce custody trial, GAL Wess colluded with
212. GAL Wess asked Judge Chappell to grant the relief Ms. C. Wyatt and Mr. G.
Wyatt were seeking, even though there was no claim from Ms. C. Wyatt and
213. While Judge Chappell acknowledged there was no claim from Ms. C. Wyatt
or G. Wyatt pending before her court, Judge Chappell granted the relief GAL
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214. On January 28, 2020, Mr. D. Deaton, Ms. L. Deaton, and GAL Brantley
215. GAL Brantley directed violations of the January 28, 2020 agreement of all
216. GAL Brantley objected to J.K.D. receiving the medical care her parents
217. GAL Brantley’s objection to the agreement of the parties further blatantly
requested, “this Honorable Court to include in its Order that the GAL fee’s
218. Mr. D. Deaton followed the agreement as written, but Ms. L. Deaton refused
219. Because of the work of The Enterprise, J.K.D. did not receive the therapy
220. Even when Mr. D. Deaton and Ms. L. Deaton agreed in writing, GAL
221. Mr. D. Deaton and Ms. L. Deaton agree this delay caused great mental and
222. GAL Brantley later acknowledged on the record that the continued litigation
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223. A final order, on the parties’ agreement, was not issued until May 12, 2021,
of the parties.
224. GAL Brantley continued profiting off Mr. D. Deaton and Ms. L. Deaton for
225. Mr. D. Deaton is not aware of the alleged work GAL Brantley performed.
M. GAL Brantley Substantially Profits from Scheme and Starts New Law
Firm.
226. GAL Brantley substantially profited financially by billing for the entire (2)
year period due to the delay caused by her own actions and objections to an
227. GAL Brantley was able to utilize this financial scheme to fund her own legal
228. Mr. D. Deaton has repeatedly and consistently requested a detailed invoice
229. As is shown repeatedly throughout this complaint, GAL Brantley, and the
other co-defendants who financially benefited from their actions, have yet to
be required to show full details of their billings nor sit for an evidentiary
hearing regarding their fees as is required by law, while receiving top cover
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230. GAL Brantley has a pattern and practice of violating the law.
231. When GAL Brantley was running for a judicial seat in Jefferson County,
acceptable uses.
233. On January 23, 2020, Mr. D. Deaton filed a motion to remove the GAL
234. On January 24, 2020, as a retaliatory motion and attempt to further muddy
the waters, GAL Brantley filed legal action against G.M.W. and Ms. T.
minor child) and his wife, even though neither parent alleged there was an
issue giving rise to a no contact order with Ms. T. Peake or with G.M.W.
Children.
235. GAL Brantley selected a medical provider, Ms. D. Malone, and directed Ms.
L. Deaton and Mr. D. Deaton to take the children only to her friend, Ms. D.
Malone.
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236. On September 23, 2019, GAL Brantley physically took control of Plaintiffs
L.W.D. and R.E.D. taking them into GAL Brantley’s vehicle and physically
237. On September 23, 2019, GAL Brantley took possession of and physically
238. On or about October 4, 2019, Ms. L. Deaton brought Plaintiff J.K.D to Ms.
objections of Mr. D. Deaton, GAL Brantley took it upon herself to direct the
delayed”.
241. Ms. D. Malone publicly produced healthcare reports on J.K.D., L.W.D., and
242. These reports included what Ms. D. Malone alleged the minor children said
243. Ms. D. Malone, GAL Brantley, Attorney Drennan, and Attorney Duncan
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245. Attorney Drennan and GAL Brantley demanded that there would not be an
parenting coordinator.
246. Upon information and belief, Southern Maryland Dredging, Mr. C. Wilson,
Ms. R. Wilson, and Ms. Goldman paid or caused to pay over a million
dollars in bribes and fees that came from state and federal awards to their
247. These bribes include hundreds of thousands of dollars just in the last year.
248. On or around February 2020, Ms. L. Deaton placed the J.K.D., L.W.D., and
options for the children or to exercise any other option that does not place
the entire burden on the taxpayers’ shoulders, while her family spends
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249. Ms. L. Deaton waived the children’s health insurance offered by her work,
dollars for the children to be placed on Medicaid while this fraud continues
today.
250. Upon information and belief, Southern Maryland Dredging, Mr. C. Wilson,
Ms. R. Wilson, and Ms. Goldman failed to disclose substantial gifts on their
respective taxes.
Maryland.
251. On or around the summer of the 2020, Ms. L. Deaton applied for J.K.D.,
252. Ms. L. Deaton did not discuss or disclose any of the applications with Mr. D.
253. After learning the children were to be enrolled in Annapolis Area Christian
School, Mr. D. Deaton contacted the school and, at first, was not able to get
254. Ms. L. Deaton did not take the children to Annapolis Area Christian School
255. In the summer of 2021, Ms. L. Deaton stated that J.K.D. was enrolled at St.
Anne’s School.
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257. Mr. D. Deaton filed an urgent motion with Judge Stephens regarding the
258. Later, Ms. L. Deaton acknowledged the changes in the children’s schedule
261. GAL Brantley and Attorney Davidson insisted the educational records were
not redacted in writing and made directives for Ms. L. Deaton’s benefit
262. It was later revealed, and Ms. L. Deaton admitted that the documents were in
fact redacted.
263. Southern Maryland Dredging, Mr. C. Wilson, Ms. R. Wilson, and Ms.
Goldman leveraged a family friend and staff member at St. Anne’s School,
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264. At all times relevant, Southern Maryland Dredging and Mr. C. Wilson did
not disclose these substantial gifts on their taxes, so the taxpayers would
265. On June 21, 2020, at approximately 6:30 PM, Attorney Gregory absconded
266. Attorney Gregory drove and spoke to G.M.W. alone in her car and then
267. On July 21, 2020, in an attempt to deprive Ms. T. Peake access to evidence
for trial, Ms. C. Wyatt threatened violence with a firearm on a process server
268. The process server, Ms. Teresa Ann Smith, submitted an affidavit on July 22,
269. In a stated effort to stop Mr. S. Wyatt’s obligation and agreement to pay
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expense.
270. Attorney Yarbrough and Attorney Gregory went so far as to ask Judge
271. Judge Chappell granted the relief Attorney Yarbrough and Attorney Gregory
requested and did not consider G.M.W.’s best interest against well settled
law.
272. Mr. S. Wyatt knew that Highlands School was the best school for G.M.W.
and has voluntarily agreed to send G.M.W. to Highlands School after many
273. Judge Chappell selected G.M.W.’s school as Homewood City Schools and
274. Judge Chappell further forced Ms. T. Peake to pay for half of G.M.W.’s
private school tuition against the agreement of the parties in the Final
prejudice.
275. Upon information and belief and on or around early 2020, GAL Wess
Judge Chappell.
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276. In his visit to Georgia, GAL Wess met with Mr. S. Wyatt’s girlfriend, who
278. The GAL in Georgia, who at all times relevant is also a Georgia State
279. Judge Chappell did not intervene to supervise GAL Wess or correct this
behavior.
280. At all times relevant, GAL Wess is a Judge in municipal court in the City of
the state of Maryland and entertained her for multiple days in an effort to
282. On May 5, 2023, Ms. L. Deaton provided sworn testimony that GAL
283. Ms. L Deaton did pay for GAL Brantley’s trip to Maryland.
284. GAL Brantley accepted this bribe and never reported it to the tribunal.
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285. GAL Brantley continued to serve as GAL after admitting that she directed
Ms. L. Deaton’s family during and following her all-expenses paid trip to
Maryland.
286. Upon information and belief, money obtained from state and federal
287. Attorney Drennan and Attorney Duncan hired a private investigator to obtain
video of minor child G.M.W. through a window and inside his custodial
home.
obtain video of G.M.W. through a window and to spy on his activities inside
of his home.
289. Rather than use this video for any lawful purpose, Attorney Drennan and
Attorney Duncan have sought to use this purported video as the source of
290. Despite multiple requests and attempts by attorneys, Attorney Drennan and
Attorney Duncan have refused to produce the video, while admitting they
have it.
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291. After Attorney Drennan and Attorney Duncan refused to produce the video
of G.M.W. inside of his home, the Plaintiffs received packages in the mail
292. Mr. D. Deaton inquired with Ms. L. Deaton as to what the packages
contained.
293. During the same time, Attorney Drennan, Attorney Duncan, and GAL
plea for help by sealing the certified transcript of the children’s testimony
multiple tribunals.
294. To distract from these crimes, Attorney Drennan represented the following to
a tribunal on August 30, 2019: “She [Ms. L. Deaton] sent modeling clay [to
the minor children] and Mr. Deaton accused her of trying to send a bomb [to
295. At all times relevant, Attorney Drennan knew this statement was false and
ploy to distract from the video she obtained of G.M.W. inside of his home
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296. Attorney Drennan was a participant in what caused this concern and
leveraged false statements to the tribunal to distract from her own bad acts
Children’s Testimony.
297. Upon information and belief, Mr. D. Kellner accepted money from Southern
298. Attorney Drennan and Attorney Duncan relied on the testimony by Mr. D.
Kellner to allege that Mr. D. Deaton made false claims expressing concern
299. Attorney Drennan, Attorney Duncan, and GAL Brantley litigated to seal the
300. GAL Brantley, GAL Wess, and Ms. C. Taylor released private information
regarding the Plaintiff children without the consent of Ms. T. Peake or Mr.
D. Deaton.
301. After unethically trading their clients’ confidential information, GAL Wess
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unconstitutional motions to increase the size of their claimed legal fees while
302. Ms. C. Taylor and GAL Wess colluded to file an emergency motion on
303. Ms. C. Taylor reviewed a draft of GAL Wess’ emergency motion as a non-
304. When Ms. C. Taylor discovered this was an issue, she refused to turn over
305. GAL Brantley and GAL Wess conspired on January 24, 2020, by filing
further line their pockets with the money from the Plaintiffs as ordered by
BB. Ms. C. Taylor and GAL Wess directed G.M.W. to See Dr. Mashburn:
306. Ms. C. Taylor directed Ms. T. Peake and Mr. S. Wyatt take G.M.W. to see
307. GAL Wess also recommended Dr. Mashburn and filed multiple motions
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308. Ms. C. Taylor and Dr. Mashburn exchanged medical referrals for minor
309. In email correspondence on July 30, 2020, Mr. S. Wyatt confirmed that he
was directed by Dr. Mashburn, Ms. C. Taylor, and GAL Wess to submit
310. In the same correspondence, Mr. S. Wyatt further confirms that Ms. C.
Taylor and Dr. Mashburn conspired to, and did, direct the restriction of
CC. Ms. C. Taylor, a Non-Attorney, acts as a Judge and Judge Chappell does
311. At all times relevant, Ms. C. Taylor received notice and knew that her
312. Even if a party did object, Judge Chappell ignored motions to her court for
followed.
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313. Ms. C. Taylor directed G.M.W.’s medical care at all times relevant during
314. Ms. C. Taylor also directed Ms. T. Peake and Mr. S. Wyatt’s medical care.
315. Ms. C. Taylor restricted Ms. T. Peake from reaching G.M.W. by phone
316. Each of these unconstitutional acts also resulted in additional profits for Ms.
C. Taylor and the rest of her friends working together as part of this
317. On October 29, 2019, at 3:57 PM, Ms. C. Taylor directed Ms. T. Peake to
file an objection through her lawyer if she disagreed with Ms. C. Taylor’s
318. On December 19, 2019, Ms. C. Taylor states that she, serving as a court
appointed Parenting Coordinator, does not think a call with the parents, Ms.
speak to her directly and try to address certain issues. Ms. C. Taylor further
stated that she spoke to Dr. Mashburn. Defendant Taylor stated she is ready
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that Dr. Mashburn, who had a duty to maintain privilege to G.M.W., agreed
319. On December 20, 2019, and continuing onto G.M.W.’s 5th birthday, Ms. C.
motion.
320. Judge Chappell placed restrictions on G.M.W. at Ms. C. Taylor and GAL
Wess’ request that stayed in place for years and directly prevented G.M.W.
access to his mother for his Christmas visitation with her and on the morning
321. Ms. C. Taylor further stated she sent her recommendations directly to Judge
Chappell, which if true, were sent to the Judge Chappell ex parte as there is
C. Taylor’s “orders” while increasing profits for herself and causing direct
harm to G.M.W.
324. There was never a period in time in which Ms. T. Peake was ordered to
receive any type of supervised visitation from any court for any reason.
325. There was never any evidence presented at any time before any court that
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Plaintiff Peake’s parental visitation with G.M.W. for the Christmas holiday
and on the eve of G.M.W.’s 5th birthday, Defendant Gregory insists Ms. T.
327. Judge Chappell did not set a hearing and no testimony was before her court
when G.M.W. was withheld from his mother over his Christmas visitation in
328. Judge Chappell entered an order, against well settled substantive and
procedural due process laws, directing the care of G.M.W. based on these ex
parte communications and filings before her court that offered no evidence.
his custodial birthday and Christmas visitation with his mother, Ms. T.
Peake.
331. Ms. C. Taylor responded by raising her fees and demanded a new contract
that included restricting the parent from gathering recorded evidence of Ms.
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332. Even after this was brought to Judge Chappell’s attention through multiple
filings and representation before her court, Judge Chappell did not set a
hearing to address the allegations that her order was based on.
333. Judge Chappell never altered her December 23, 2019 order.
334. Ms. C. Taylor stated in writing that if Ms. T. Peake did not consent to her
new agreement, on behalf of her minor child G.M.W., that Ms. C. Taylor
335. Ms. C. Taylor extorted Ms. T. Peake to sign a new agreement, increasing Ms.
C. Taylor’s fees, to ensure Ms. T. Peake would still be able to see and visit
336. Ms. C. Taylor stated she would coordinate visitation for Mr. S. Wyatt,
337. Ms. C. Taylor made clear that unless Ms. T. Peake agreed to the same
338. Ms. C. Taylor’s financial scheme was a blatant and successful effort to extort
339. On December 22, 2020, and again after, Ms. T. Peake raised concerns
regarding the nature of the personal relationship between Mr. S. Wyatt and
Ms. C. Taylor.
340. Ms. C. Taylor was directing the care of G.M.W. even after Mr. S. Wyatt
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341. Upon information and belief, issues have been raised by multiple litigants
of the father’s minor children without disclosing the nature of her personal
relationships.
342. Ms. C. Taylor refused at all times relevant, including as of the time of this
filing, to provide Ms. T. Peake with access to her child’s files or detailed
invoices.
343. As part of the ongoing conspiracy, Ms. C. Taylor continued litigating before
Judge Chappell that she was owed legal fees and additional “professional”
344. Judge Chappell set a hearing at Ms. C. Taylor’s request to assess additional
345. Ms. C. Taylor refused to testify under oath at the same hearing she requested
and further intentionally avoided service by a process server for the hearing.
346. Ms. C. Taylor was paid as a fact witness by Mr. S. Wyatt to testify in Judge
Chappell’s court.
347. Ms. T. Peake objected and moved to strike Ms. C. Taylor’s testimony after
she testified that she was paid $1500 to testify that day against the plain
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348. Ms. C. Taylor did not bring any of G.M.W.’s records to Court or provide
Requirement for the Same in Court Order; Following These Events, Mr. D.
349. On or around December 21, 2020, Attorney Davidson and GAL Brantley
worked together to prevent Mr. D. Deaton from seeing his children during a
350. After speaking to GAL Brantley, Attorney Davidson demanded that Mr. D.
351. Mr. D. Deaton was prevented from seeing his children, even though he was
entitled this time in the court order and proper notice was provided.
352. Mr. D. Deaton expressed concern with being prevented from seeing his
December 21, 2020, “Drew, as stated in an individual email. Leanne did not
ask for the verification of your employer. I want to make sure blame is
assessed in the correct place. I am the ONLY person who requested the
same. The issue was brought to my attention by both of you via email and
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text. I have not had a single phone call with either of you since the emails hit
my in box. I have only emailed with each of you and spoken to Slate (Dad's
attorney) and updated the GAL as you all have seen in the emails since this
354. On January 13, 2021, Ms. L. Deaton requested that Attorney Davidson
355. On or around April 13, 2021, Attorney Davidson and GAL Brantley worked
together again to prevent Mr. D. Deaton from seeing his children during a
356. After speaking to GAL Brantley, Attorney Davidson demanded that Mr. D.
357. Mr. D. Deaton was never permitted access to his children overnight, even
358. Following the attempts by Attorney Davidson and GAL Brantley to harass
Mr. D. Deaton was fired from his job during the pandemic causing
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Ms. L. Deaton and J.K.D. on the property of Mr. C. Wilson that occurred on
360. Mr. D. Deaton asked Ms. L. Deaton about what happened and followed up
361. Despite a text message from Ms. L. Deaton to J.K.D. apologizing for the
altercation, Ms. L. Deaton never addressed the altercation and said, “her
362. Ms. L. Deaton would not explain or acknowledge the altercation despite the
363. On September 25, 2021, Mr. D. Deaton asked J.K.D.’s then-counselor Ms.
364. Attorney Drennan made multiple statements on the records about how
entangled she was in Ms. L. Deaton’s life and her directives to Mr. D.
365. Attorney Drennan stated on the record that: “I [Attorney Drennan] read
every email that my client [Ms. L. Deaton] sends Mr. Deaton now...”
366. And, Attorney Drennan further stated: “He was kept informed because I read
the emails myself. He was kept informed. There was no questions, but I will
tell you, I don’t know if Mr. Deaton is harassing my client or if he just has a
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processing problem because my client will give him information, and three
days later, he will ask the same questions and say you never gave me this
Mr. C. Wilson while Mr. D. Deaton was on the phone with Plaintiff R.E.D.
368. Ms. L. Deaton could be heard telling R.E.D. to get off the phone.
369. On or around October 24, 2021, L.W.D. expressed concern about an incident
that occurred in Ms. Deaton’s home saying, “Whenever mom and [J.K.D.]
get in a fight I’m never allowed to go upstairs when it’s happening. Well, I
fights are pretty bad.” “That keeps going on to a while until J.K.D starts
crying and tells [Ms. L. Deaton] to go away.” “Yeah… one time she
slammed a door in the bathroom and a mirror broke. Fights between mom
and [J.K.D.] are pretty bad.” “One time mommy got mad at me and [J.K.D.]
and made us rake leaves for an hour.” [what are they usually over] “I don’t
know” [What happened to cause you to have to rake leaves] “Mom just got
upset because…mom was just having a bad day that day because she did
something that she shouldn’t have and then got upset about it and
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counselor, Ms. McNew stated, “Unfortunately I have not been able to make
plan goals. … At home, she can be uncooperative and isolative per her
mother.” [sic]
371. Considering the history of violence of Ms. L. Deaton, Mr. D. Deaton filed an
FF. Ms. Deaton’s Retaliatory Petition for Protection from Abuse Denied in
Investigation in Maryland.
372. On November 23, 2021, Ms. L. Deaton filed a frivolous and retaliatory
petition for protection in the state of Maryland which was denied on the
same day by Judge Donna M. Schaeffer, Circuit Court for Anne Arundel
County, Maryland because Ms. L. Deaton could not meet required burden of
proof.
373. Following the Maryland court’s denial of Ms. L. Deaton’s petition, GAL
is directly cited in the report that was presented to the tribunal in Maryland.
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374. Prior to and following being re-appointed to the case in Alabama, GAL
Maryland.
375. Ms. L. Deaton knows that GAL Brantley, Attorney Drennan, and Attorney
376. On December 15, 2021, Ms. L. Deaton sent a text message to Attorney
Drennan and GAL Brantley stating she received a call from a Maryland
Department of Social Services worker and provided the name of the worker.
377. Ms. L. Deaton further states that the minor children met with the Alabama
Department of Human Resources worker, who “has not sent over her notes”.
378. GAL Brantley previously told Ms. L. Deaton and Mr. D. Deaton that she
was close friends with the legal supervisor for the Alabama Department of
Human Resources.
379. On September 17, 2021, Attorney Drennan admitted on the record that she
380. On December 15, 2021, GAL Brantley reported to Ms. L. Deaton, but not
Resources, received an update from them, and she is certain that the
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381. On December 15, 2021, GAL Brantley further stated that the Alabama
382. The Department of Social Services state agent met with or spoke to Ms. R.
383. The Department of Social Services agent in Maryland never met with the
Human Resources representative to visit with the children one time and
385. The Department of Human Resources did not visit with or speak to Mr. D.
Deaton again following the one visit and GAL Brantley’s directives.
386. GAL Brantley was mentioned throughout the Department of Social Services
387. The report only contained what Ms. L. Deaton, Ms. R. Wilson, and GAL
388. On December 4, 2021, GAL Brantley states to Ms. L. Deaton that the
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389. Both Mr. D. Deaton and Ms. L. Deaton understood that GAL Brantley had
investigation.
390. The parents also further understood that GAL Brantley was shaping the
narrative and timeline of events, including what was reported to the tribunal
in Maryland.
391. On December 16, 2021, after the report was brought to Judge Shaem
Spencer, the District Court of Maryland for Anne Arundel County, Mr. D.
392. Mr. D. Deaton dismissed his claim before Judge Shaem Spencer and the
District Court of Maryland for Anne Arundel County after learning of the
conspiracy with GAL Brantley and sought to obtain more discovery on the
issue in Alabama.
393. Mr. D. Deaton immediately filed notice of this issue and conflict with GAL
394. A hearing was never set regarding these issues directly affecting the
children’s safety.
Jurisdiction.
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395. After receiving an Emergency Temporary Restraining Order from the State
396. Before the Maryland court, who were not participants in The Enterprise, the
judges held hearings, heard testimony, and made rulings in the best interest
of the children.
397. Judge Stephens held a conference call with the Maryland Court regarding
jurisdiction.
398. Mr. D. Deaton was not given notice of the date or time of the call with the
399. Maryland state court exercised emergency jurisdiction to protect the minor
children.
400. Judge Stephens never granted a stay and continued to exercise competing
401. Judge Stephens refused at all times relevant to stay the case or cease her
402. On November 30, 2021, Judge Stephens entered an order stating in part:
and "That the Father shall not enroll the children in school in Alabama
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pending further orders of the court." This order was entered on November
403. Judge Stephens entered this order denying Mr. D. Deaton the right to enroll
his children.
404. Judge Stephens directed prevented Mr. D. Deaton from prosecuting his
HH. GAL Brantley and Attorney Drennan Collude with Judge Stephens to
Eliminate J.K.D., L.W.D., and R.E.D.’s Christmas visitation with their father
405. On December 15, 2021, Ms. L. Deaton, GAL Brantley, and Attorney
Drennan discuss that if Judge Stephens does not want to suspend the
children’s visitation with their father, Mr. D. Deaton, that “maybe he can do
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408. Judge Stephens grants these motions without a hearing or any evidence
409. Ms. Deaton did not allow Mr. D. Deaton to see, visit, or speak frequently
II. Ms. C. Coker and Ms. A. Weiss Imprison J.K.D. and Withhold Her
410. On or around November 23, 2021, St. Anne’s School would not allow Mr. D.
Deaton access to his daughter, J.K.D., and instead held her on campus with a
411. On November 23, 2021 at 11:41 AM ET, Mr. D. Deaton sent an Emergency
St. Anne’s Episcopal School issued by District Court of Maryland for Anne
Arundel County on November 22, 2021 stating in part that Leanne Deaton
“Shall not contact the protected parties by any means.” and Leanne Deaton
"shall stay away from: School: Tracey’s Elementary School" and "School:
412. On November 23, 2021 at 11:43 AM ET, Ms. A. Weiss, Head of School for
email stating: “Got it. I will call you when the police arrive.”
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413. At all times relevant, St. Anne’s School never alleged that Mr. D. Deaton
created a disturbance.
414. Mr. D. Deaton did not enter the school at any time, but instead called St.
416. St. Anne’s School would not allow Mr. D. Deaton to enter the school or pick
up his daughter.
417. Ms. A. Weiss and Ms. C. Coker held J.K.D. on school property and refused
418. Even after Mr. D. Deaton produced an emergency court order, Ms. A. Weiss
and Ms. C. Coker still refused to allow Mr. D. Deaton to pick up his
daughter.
419. At the time Mr. D. Deaton arrived, Ms. L. Deaton was not at the school.
420. St. Anne’s School was provided notice that Mr. D. Deaton was picking up
J.K.D.
421. Ms. A. Weiss on behalf of St. Anne’s School acknowledged that Ms. L.
Deaton was not at the school, but still prevented Mr. D. Deaton access to his
daughter.
422. Ms. A. Weiss contacted Ms. L. Deaton and held J.K.D. at the school for over
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423. Tracey’s Elementary School, the public school where L.W.D. and R.E.D.
attend, acted on the clear language of the order, but St. Anne’s School
424. After multiple attempts by Mr. D. Deaton to get his daughter’s educational
records, on June 24, 2022, Ms. C. Coker and Ms. A. Weiss blatantly refused
425. Mr. D. Deaton and his counsel have attempted to reach any administrator at
426. At all times relevant, St. Anne’s School has refused to send records or allow
Mr. D. Deaton access to his child, while being paid by Ms. L. Deaton’s
Maryland Dredging.
427. On May 5, 2023, Ms. L. Deaton provided sworn testimony that: “He [Mr. D.
regardless.”
428. Despite Mr. D. Deaton being entitled to pick up J.K.D. from her school, Ms.
C. Coker and Ms. A. Weiss directly prevented Mr. D. Deaton from picking
up his child and instead falsely imprisoned J.K.D. on campus for over an
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429. Instead of allowing Mr. D. Deaton to pick up J.K.D. from school, St. Anne’s
School allows a known felon to pick up J.K.D. from school each day without
JJ. After being Convicted of Crimes and Refusing to Pay the Judgement
Ordered, Mr. C. Langrall Transports J.K.D. from St. Anne’s School to his
Records.
430. On May 5, 2023, Ms. L. Deaton provided sworn testimony that a known
felon, Mr. C. Langrall, picks up J.K.D. from St. Anne’s Episcopal School
each day.
431. It is undisputed that Mr. D. Deaton did not have knowledge of this
432. Ms. A. Weiss and Ms. C. Coker attempted to cover up this information in
433. Ms. A. Weiss and Ms. C. Coker were aware, or should have been aware, of
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434. St. Anne’s School refused Mr. D. Deaton access to these pick up and drop
off records against the court order to ensure they continued to receive
435. The undersigned attempted to contact St. Anne’s School requesting the
communication.
436. Ms. L. Deaton provided sworn testimony that Mr. D. Deaton should have
438. St. Anne’s School refused a parent and legal custodian from picking up
J.K.D. from school, but instead allowed a felon to pick up J.K.D. each day
and take J.K.D. to his personal residence to play Dungeons and Dragons.
439. Mr. C. Langrall family continues to pay St. Anne’s School after refusing to
KK. JA Brantley, the biological daughter of GAL Brantley and the Official
confidential Deaton case and pleadings from the Deaton case in Maryland
confidential documents from the Deaton case, in which her mother and co-
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what information she had receive or knew regarding his minor children and
his case.
442. On December 14, 2021, Judge Chappell stated on the record that she
stated in part her need to disclose the conflict regarding GAL Brantley and
443. Judge Chappell also mentioned the reported need to screen JA Brantley from
444. Following this disclosure that Judge Chappell made for the first time on
December 14, 2021 and after Judge Chappell failed to screen JA Brantley
from the case, three different parties before Judge Chappell asked her to
recuse.
Commission.
446. On December 15, 2021, Attorney Benita Jenkins filed a “Motion to Quash
447. JA Brantley alleges that she has “no personal knowledge pertinent to the
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448. At all times relevant, JA Brantley knew her statements before Judge
449. JA Brantley was working at the Jefferson County Circuit Court Domestic
Relations division and felt emboldened to make these false statements to the
450. In the same motion, JA Brantley acknowledges that Mr. D. Deaton “has a
matter, however, said right does not extend to the harassment of family
451. JA Brantley further acknowledges that Mr. D. Deaton has filed several
452. The next day, on December 16, 2021, Judge Stephens granted JA Brantley’s
before her court against substantive and procedural due process laws to
453. At the next hearing, GAL Brantley asks Judge Stephens to award her co-
resident and daughter, JA Brantley, legal fees from the Mr. D. Deaton in an
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454. Mr. D. Deaton and his counsel raised this issue as another example of GAL
455. On January 25, 2022, Dr. Labellarte took J.K.D. as a patient without Mr. D.
456. On February 8, 2022, Dr. Labellarte instructed Mr. D. Deaton that he did not
care or want his opinions as a father or to hear his concerns for his child.
457. Dr. Labellarte then referred J.K.D. to a therapist, Ms. D. Maynard, in which
458. J.K.D. was previously put on (4) different medications in 50 days without
Mr. D. Deaton’s knowledge, and J.K.D. began to harm herself until the
459. Dr. Labellarte was made aware of this history and put on notice of the issue
but advised that he did not care to hear Mr. D. Deaton’s concerns.
460. Dr. Labellarte prescribed medication to J.K.D. against Mr. D. Deaton direct
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461. Dr. Labellarte did not notify Mr. D. Deaton that he prescribed drugs, not
approved by the FDA that contain a black box warning for use with minors,
462. As of February 6, 2023, Dr. Labellarte continues to state that J.K.D. “is an
established patient with the practice. There should be no issue with the
463. At all times relevant, Dr. Labellarte has not reported his concerns for J.K.D.
in the state of Maryland to any appropriate authority that would give rise to
464. At the time of this filing, it is unknown and unclear to Mr. D. Deaton what
465. On May 5, 2023, Ms. L. Deaton stated one type of prescription drugs was
466. On May 15, 2023, Ms. L. Deaton reports that a different type of prescription
467. Dr. Labellarte has not provided Mr. D. Deaton with J.K.D.’s records or
MM. Ms. D. Maynard Diagnoses J.K.D. at age 12 and Then Refuses to Speak
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468. On or around April 6, 2022, Ms. L. Deaton hired Ms. D. Maynard on behalf
of J.K.D. without conferring with Mr. D. Deaton and without a referral from
469. J.K.D. had previously seen her primary care doctor’s office for mental/
470. Ms. D. Maynard expressed to Ms. L. Deaton and Mr. D. Deaton that she was
471. Ms. D. Maynard was also concerned with what Ms. L. Deaton expressed
472. After reviewing Ms. D. Maynard’s notes, Mr. D. Deaton asked about the
473. Ms. L. Deaton refused to disclose her reported concerns to Mr. D. Deaton.
474. Based in part on the concerns Ms. L. Deaton reported, Ms. D. Maynard
knowing the J.K.D. had previously seen Dr. Labellarte without Mr. D.
Deaton’s consent.
475. Ms. D. Maynard acknowledged that J.K.D. has expressed concerns with
477. Ms. D. Maynard disclosed privileged information from sessions with J.K.D.
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478. At all times relevant, Ms. D. Maynard has not reported her concerns for the
479. Ms. D. Maynard, without the consent of J.K.D. and Mr. D. Deaton, referred
both of their profits. Their respective companies received financial gain from
these referrals.
481. Mr. D. Deaton is concerned for his minor children, J.K.D., L.W.D., and
R.E.D., and attempted to set parenting sessions with Ms. T. Miller, Ms. D.
482. After these concerning diagnoses were sent via email from Ms. T. Miller and
483. On March 20, 2023, Ms. D. Maynard stated J.K.D. had diagnosis.
484. On March 21, 2023, Mr. D. Deaton asked Ms. L. Deaton if she canceled
485. Ms. L. Deaton responded on March 29, 2023, “Yes, with Dale’s permission,
it was canceled.”
486. On or around March 20, 2023, Ms. D. Maynard stated in writing that she is
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487. On or around March 21, 2023, without Mr. D. Deaton’s consent as a legal
488. During the same time period, Ms. D. Maynard refused to speak to Mr. D.
490. Once again, Ms. D. Maynard refused to communicate with Mr. D. Deaton or
his counsel.
NN. Dr. Blotcky, the Court Appointed Expert, Illegally Practices in Multiple
491. On or about February 22, 2022, Attorney Drennan had an off the record
Dr. Ackerson, the then court appointed psychologist, had a conflict due to
492. Ms. T. Peake had previously and voluntarily sat for a psychological
evaluation with Dr. Ackerson that was subject to a HIPAA Protective Order
chambers.
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493. There was no hearing before Judge Stephens to confirm any of these off the
494. On February 23, 2022, Judge Stephens entered an order setting aside her
495. On March 15, 2022, Attorney Duncan made an appointment with Dr.
496. Attorney Drennan and Attorney Duncan demanded that Dr. Blotcky would
497. Additionally, upon information and belief, Attorney Duncan demanded that
Dr. Blotcky discuss the sessions with them, set the order of the evaluations
with them, and provide Ms. L. Deaton’s evaluation to her by mail through
evaluation for Ms. T. Peake prior to Ms. C. Taylor’s directive that the
Drennan knew or should have known that Dr. Blotcky had a conflict.
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500. On June 24, 2022, Dr. Blotcky delivered his report to Attorney Drennan and
501. Against the APA guidelines and Judge Stephens’ order, Dr. Blotcky did not
protocol.
502. Dr. Blotcky does not have a license to practice medicine in the state of
Maryland.
503. Dr. Blotcky had multiple virtual interviews with Ms. L. Deaton, in violation
506. It is unknown who filled out the unsupervised test before it was returned to
Dr. Blotcky, but the test plainly does not reflect Ms. L. Deaton’s personality
507. After being asked about the way Dr. Blotcky practiced medicine in this case,
Dr. Blotcky admitted that the evaluations were not administered properly.
508. Dr. Blotcky did not take any steps to correct his report.
509. After this phone call regarding his violation of APA guidelines, Dr. Blotcky
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custody was not at issue but refused to amend or withdraw the claim.
510. Attorney Drennan advised Ms. L. Deaton to file a crossclaim against Mr. D.
Deaton that was filed on May 16, 2022, even though Attorney Drennan
knew at all times relevant that there had been no change of circumstance for
511. This crossclaim requested Judge Stephens awarded Ms. L. Deaton with “sole
Judge Stephens that custody should no longer be at issue, but did not alter,
513. Instead, Attorney Drennan attempted to cover up her bad acts with Dr.
Blotcky's report produced against APA guidelines insisting they were “no
514. On December 9, 2022, Attorney Drennan represented “Since that time, the
longer at issue before this Court. That as custody is not at issue between the
parties, Dr. Blotcky’s reports are no longer relevant nor material for the
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515. Judge Stephens entered an order denying Mr. D. Deaton the right to share his
children’s testimony with Dr. Blotcky that directly discredited Dr. Blotcky’s
report.
516. On May 5, 2023, while Ms. L. Deaton was sworn in and asked whose idea it
was to file a cross claim, Attorney Drennan directed her not to answer and
Mr. D. Deaton questioned this by asking: “If it's her idea, how is that –?”;
Attorney Drennan interrupted and stated again, “I'm telling you it invades
attorney-client privilege.”
against Mr. D. Deaton even though Attorney Drennan knew at all times
relevant that the crossclaim was without merit as no change had occurred
518. The crossclaim did however directly balloon Attorney Drennan’s profits that
PP. GAL Brantley Falsely Imprisoned J.K.D., L.W.D, and R.E.D. Against
Their Consent and Against the Consent of Mr. D. Deaton During Trial
519. On June 29, 2022, Ms. T. Peake and Mr. D. Deaton approached the
conference room where Plaintiff L.K.D., L.W.D., and Plaintiff R.E.D. were
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being held by GAL Brantley to take them home since they were not
520. Mr. D. Deaton and Ms. T. Peake observed GAL Brantley standing between
the Plaintiff minor children yelling and refused to allow the children to leave
521. Judge Stephens exited her chambers waving her arms and screaming about
allegations in the Deaton case regarding private matters of the children in the
523. After Judge Stephens left her chambers and while she was standing in the
can be seen in the same frame of the video when the assault occurs. There is
now a pending case of assault and other relief before Hon. D. Hatcher in
524. J.K.D., L.W.D., and R.E.D. were held in a closed conference room with a
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525. Attorney Duncan received text communication from GAL Brantley and
526. On the night of June 29, 2022 at or around 7:30 PM CT, GAL Brantley
did not allow J.K.D., L.W.D., and R.E.D. to leave the room.
527. GAL Brantley stated “No they are not going” [to leave] and “I was not about
528. On the same call on the night of June 29, 2022 at or around 7:30 PM CT,
529. And further stating: “I have had moments myself where I have even told
mom. This has been the most passive woman. Let me say one of the most
passive women I have had to deal with that has just pissed me off. And have
told her and I have told her attorney- I have told Jessica. She is milly-
moused, doesn’t stand up, gives in, and that’s why we are where we are
today. She’s the one who always gives in. She can’t stand up. She hasn’t
QQ. Judge Stephens Dismisses Mr. D. Deaton’s Custody Case with Prejudice
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530. On June 29, 2022, Judge Stephens directs that she is dismissing Mr. D.
Deaton’s custodial case with prejudice and instructs Attorney Drennan and
Attorney Duncan to continue with their crossclaim on the first day of trial.
532. Attorney Drennan further represented that she did not owe Mr. D. Deaton
deficiency was.
533. Attorney Drennan and Attorney Duncan previously refused to make copies
534. Mr. D. Deaton is left without an opportunity to raise his claims for custody
RR. Judge Stephens Conducts a Secret Phone Call About the Deaton Case.
535. On or around August 12, 2022, Judge Stephens had an off-the-record phone
call with a third party about Ms. L. Deaton and Mr. D. Deaton’s post custody
divorce case.
discussion with attorneys, after removing the court reporter from the call,
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537. As of the time of this filing, Judge Stephens has refused to disclose the
identity of the caller or the nature of the phone call on the record despite
538. It is clear from the limited amount Judge Stephens revealed that Judge
Stephens knew the caller, discussed the case, and then refused to reveal this
call on the record to prevent the parties from conducting discovery on her ex
SS. GAL Brantley Makes 17 False Statements to the Alabama State Bar.
539. On September 16, 2022, GAL Brantley knew she had to misrepresent and
suppress material facts to the Alabama State Bar to stay in Ms. L. Deaton
and Mr. D. Deaton’s post divorce custody case and continue improper
billing.
540. GAL Brantley made at least 17 false statements to the Alabama State Bar,
because GAL Brantley knew her actions were wrongful, willful, and
malicious.
542. The request came after GAL Brantley asked Judge Stephens to tax attorney’s
fees for her daughter and co-resident, JA Brantley, against Mr. D. Deaton.
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543. GAL Brantley was undeterred by the inherent conflict of interest of asking
for third party fees while simultaneously representing J.K.D., L.W.D., and
R.E.D, because GAL Brantley knew she would receive top cover from Judge
Stephens.
544. On January 25, 2023, Ms. T. Miller conducted medical testing and an
545. Ms. T. Miller reported the results were concerning on February 27, 2023 via
email. The test was administered at the end of the only month in the calendar
year when the court order for the custody schedule does not include parental
visitation for Plaintiff J.K.D, L.W.D., R.E.D. with their father. Ms. L. Deaton
546. Ms. T. Miller did not report the results of the report until February 27, 2023
UU. Judge Chappell Uses Public Property While on Duty During Business
547. During the 2022 judicial campaign for the Tenth Judicial Circuit of Jefferson
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duty to the voters of Jefferson County promoting her friend Carla Morton as
the next judge to take her seat against the plain language of the Canons of
Judicial Ethics.
548. Judge Chappell, against the plain language of the Canons of Judicial Ethics,
opposing Ms. T. Peake’s political speech and campaign efforts for her
549. Judge Chappell used taxpayer dollars on official time and on courthouse
Relations Court to sway the electorate to electing her friend, Ms. Carla
550. The campaign video depicting the above acts and Judge Chappell’s
judicial candidate and now Judge Adrienne Moffett Powell, who was Ms. T.
552. On or around April 2022, Judge Chappell’s reposted her support of the video
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553. Judge Chappell knew through rallies and public events that Ms. T. Peake
554. Judge Chappell was further put on notice through multiple requests for her
recusal.
555. At all times relevant, Judge Chappell refused to recuse and retaliated against
Ms. T. Peake.
556. Judge Chappell admitted on the record of a certified transcript that she did
not thoroughly review Mr. S. Wyatt and Ms. T. Peake’s case and asked the
Alabama Court of Civil Appeals for “help” in an outcry on the record of the
case.
557. After admitting she did not thoroughly review the case, Judge Chappell
awarded her friends, GAL Wess and the attorneys of Crittenden Partners:
requiring them to prove their fees or allowing Ms. T. Peake to question their
fees.
amount of the unproven legal fees after Ms. T. Peake and two other
559. Judge Chappell states in her order that Ms. T. Peake was taxed with legal
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560. Judge Chappell fails to acknowledge or state in her order that three separate
561. After Judge Chappell entered her order, Judge Chappell unofficially left her
VV. Judge Stephens Recuses from Ms. T. Peake’s custodial case. Then,
Judge Stephens Takes Evidence from Ms. T. Peake’s Case and Provides it to
562. Judge Stephens recuses from Ms. T. Peake’s custodial case on January 17,
2023.
563. For approximately one year prior to Judge Stephens recusal, Ms. T. Peake
had a motion and relief pending for the benefit of sealing her child’s records
564. On or around January 26, 2023, Judge Stephens asked Attorney Duncan and
case.
565. This evidence was not before Judge Stephens’ court, but somehow, Judge
566. Judge Stephens gathered evidence on multiple occasions that was not before
her court.
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567. Judge Stephens refused Ms. T. Peake access to an evidentiary hearing in her
court regarding G.M.W.’s records and further refused to transfer the case to
an unbiased court.
WW. Three Attorneys Conspire with Attorney Drennan and Attorney Duncan
568. On January 31, 2023, Attorney Jones swore to an affidavit that was filed
Civil Appeals.
569. This affidavit contains false statements that are disproved with video
and knew or should have known how inappropriate these actions were.
affidavit through Attorney Drennan that was filed with the Alabama Court of
572. This affidavit contains false statements that are disproved with video
573. On July 2, 2020, Attorney Crew and Attorney Vineyard received a payment
from Mr. D. Deaton to provide legal advice to him in this same case by
check made payable to Crew Law Group that was deposited in their Regions
Bank account.
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574. Upon information and belief, Crew Law Group is not a properly formed
legal entity.
XX. Judge Stephens Makes Four False Statements to the Alabama Court of
575. Judge Stephens elected to file a response brief to Mr. D. Deaton’s mandamus
which contained at least the four following unsupported and blatantly false
statements:
(1) Judge Stephens represented that, while Mr. D. Deaton was acting pro se,
both before the Court of Civil Appeals and in the trial court’s record and is not
even argued by the opposing party. Mr. D. Deaton has no knowledge of any such
offer.
mandamus, Judge Stephens abruptly scheduled a virtual hearing with counsel when
no motions or reason for a hearing was before the court. Though a court reporter
was scheduled, Judge Stephens would not permit the reporter into the virtual Zoom
“room,” then pressed counsel to proceed with the hearing without a reporter.
reporter was present and counsel was not aware of the purpose of the hearing. This
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request to record was denied. Judge Stephens then proceeded to disclose, without
detail, that she had received a call from someone discussing this case, its outcome,
recounted a summary version of the call, she terminated the hearing without taking
any questions or identifying the caller. Mr. D. Deaton’s counsel then filed a motion
to clarify the length of the call, identity of the caller, and other information so as to
investigate. This motion was denied. Mr. D. Deaton’s counsel then, at the next
scheduled in-person hearing, requested that the disclosure be placed on the record,
which also was denied. Then, after denying a motion to recuse based in part on the
shielding of the caller from disclosure, Judge Stephens falsely stated to the Court
of Civil Appeals that the purpose of the hearing was to “serve as a reminder that
this civil action was confidential and that neither party or attorney to this civil
action should be discussing this case in violation of this court’s order” and, more
directly and wrongly, “this Court held a hearing to remind the parties that the case
was confidential and there should be no discussion about the case.” At no point did
nature of the proceeding except in her response to Mr. D. Deaton’s petition, nor did
she ever expressly or impliedly state that the purpose of the disclosure was to make
court that “[i]f anything, the remarks show that one of the attorneys or parties may
have violated the orders of the court.” Again, no such statement was ever made
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prior to Defendant P. Stephen’s response brief, nor was the disclosure sufficiently
(3) Regarding this hearing, Judge Stephens further misrepresented that she
“relayed the comments to the parties in open court while all the parties were
present.” This was not so. The day before the hearing, the Court’s assistant emailed
all counsel informing them of the hearing and stating that “[o]nly the attorneys
need to be present.”
(4) Further, when Mr. D. Deaton raised as a basis for his petition that Judge
Stephens stated he “had an evil eye,” [sic] which appears in a transcribed record,
Judge Stephens’s response was that the court reporter “may have misheard” what
she said. (Stephen’s Resp. at 20) Prior to the mandamus, Mr. D. Deaton’s counsel
moved for recusal based in large part on this statement, which she did not address
or attempt to correct when summarily denying his motion. When his counsel later
orally moved for recusal, again mentioning this statement, she -again- did not
mandamus, which enclosed the written transcript demonstrating the statement, did
Judge Stephens claim it was an erroneous statement. Tellingly, Judge Stephens has
not attempted to correct this alleged error in subsequent proceedings following the
petition.
YY. Judge Stephens Orders Mr. D. Deaton’s Attorneys in State and Out of
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576. A dispute over records arose from Attorney Drennan and Attorney Duncan
alleging that Ms. L. Deaton’s mental health records could not be obtained
577. Attorney Drennan and Attorney Duncan knew at all times relevant that this
578. On May 5, 2023, Attorney Drennan admitted that she subpoenaed Mr. D.
579. Attorney Drennan did not follow any such procedure for Mr. D. Deaton’s
therapy records at that time as Attorney Drennan later alleged was required
by law.
relief for his minor children with proper evidence, and substantial increased
Circuit Court for Anne Arundel County entered an order denying Ms. L.
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Court for Calvert County entered an order denying Ms. L. Deaton’s Motion
health records.
583. Judge Stephens was required to give full faith and credit to the Maryland
584. Judge Stephens was required to accord the two Maryland Circuit Courts full
“It is further ordered that the Father and his attorneys in Alabama and
586. In the same March 1, 2023 Order from Judge Stephens, Judge Stephens
information.
587. The appointed special master contributed more money to Judge Stephens’
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588. Judge Stephens worked ex parte with Attorney Drennan and Attorney
589. Judge Stephens ordered Mr. D. Deaton and Mr. D. Deaton’s attorneys in
590. Judge Stephens further ordered Mr. D. Deaton’s attorneys 779 miles away in
591. Judge Stephens does not even hold a license to practice law in the state of
Maryland.
592. Judge Stephens knew or should have known she did not have jurisdiction
ZZ. Judge Stephens ejects T. Peake’s attorney from her courtroom multiple
593. On December 17, 2021, legal counsel for Ms. T. Peake was ejected without
any stated cause from a Zoom hearing in which she tried to represent Ms.
594. On June 29, 2022, legal counsel for Ms. T. Peake was ejected without any
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595. On January 17, 2023, Judge Stephens recuses herself from Ms. T. Peake’s
custodial case over her minor child through the presiding judge of the
AAA. GAL Wess Attempts to extort Ms. T. Peake to Cease Interfering with
596. On or around March 13, 2023, GAL Wess attempts to extort T. Peake to
cease interfering with T. Peake’s parental and custodial rights for $40,398.
597. GAL Wess attempted to extort Ms. T. Peake to pay $40,398 for his alleged
alleged fees.
598. GAL Wess submitted his demand through email on the night before a
hearing in which the Judge May stated on the record that she was dismissing
GAL Wess from his role as the GAL for G.M.W. after Mr. S. Wyatt and Ms.
from Judge Chappell’s chambers; Judge Chappell admits it was wrong but
599. In Ms. T. Peake and Mr. S. Wyatt’s custodial trial on or around November
2022, Attorney Yarbrough and Attorney Gregory admitted on the record that
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they removed Ms. T. Peake’s sealed medical records from Judge Chappell’s
600. Judge Chappell stated on the record that this was not the proper procedure,
evaluation in the case by Judge Chappell with Dr. Ackerson at least tacitly
602. On May 14, 2023, Attorney Gregory admits again to Judge May that
Judge Chappell’s chambers, but stated it was with permission from Judge
Chappell’s staff.
attorneys, including Attorney Lee, who expressly stated that he was not an
CCC. Judge May Refuses to Order Ms. T. Peake and Mr. S. Wyatt’s
Wess.
604. Judge May was assigned Ms. T. Peake’s custody case in January 2023.
605. At all times relevant, Judge May was directly supervised by Judge Stephens.
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606. Judge Stephens used the authority of her office to influence, if not dictate,
607. On March 14, 2023, Judge May heard post judgement issues for at least six
hours straight and agreed to legal briefing from Ms. T. Peake and Mr. S.
608. On the same day, the parents agreed for GAL Wess to be removed as GAL
609. After hearing the stipulations and an agreement from Ms. T. Peake and Mr.
S. Wyatt on the record before her Court on March 14, 2023, Judge May
denied all relief before her Court including Ms. T. Peake and Mr. S. Wyatt’s
stipulations.
610. This written order by Judge May was against her own stated concerns and
directives from the bench that at least one of the paragraphs from Judge
611. Upon information and belief, Judge Stephens directed actions in Ms. T.
612. Judge May was obligated to use her our judgement to decide the cases
before her, order stipulations of the party, and overturn rulings that clearly
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DDD. Despite His Dismissal as GAL, GAL Wess Continues to Litigate in the
613. On March 14, 2023, GAL Wess stated on the record that he understood that
he was dismissed from the Peake/Wyatt custodial case after Ms. T. Peake
and Mr. S. Wyatt agreed to his dismissal and Judge May directed it from the
bench.
614. On May 30, 2023, GAL Wess knowingly and without authority filed a
615. GAL Wess’ motion filed on May 30, 2023 with the Alabama Court of Civil
Assistance at Mr. D. Deaton’s Request for Help; GAL Brantley and Attorney
616. On April 8, 2023, Attorney Drennan and GAL Brantley colluded to threaten
result.
617. Attorney Drennan made at least 4 false statements to the minor children’s
(1) Attorney Drennan stated Mr. D. Deaton has a lack of authority to direct mental
healthcare treatment of his minor children. This is not true and at all times relevant
Attorney Drennan knew that was not true, as Mr. D. Deaton has joint legal custody
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of the minor children (in which she does acknowledge) and Ms. L. Deaton does not
(2) Attorney Drennan states the Mr. D. Deaton’s alleged lack of authority to direct
interfered with the girls’ mental health care which is why she was awarded such
authority”. This is not true and at all times relevant Attorney Drennan knew that
was not true. There has never been an evidentiary hearing wherein the Mr. D.
Deaton’s joint legal rights to the children's healthcare or the tie-breaking authority
was altered.
(3) Attorney Drennan states to the prospective Alabama counselor: that: “you have
not been recommended by the girls’ counselor nor their medical providers.” This is
not true and at all times relevant Attorney Drennan knew that was not true. Mr. D.
Deaton provided notice to the Defendant that he contacted the children’s doctor’s
office in Maryland and Alabama, and further that he contacted all of the counselors
“additionally there has been no recommendation that the girls seek additional
counseling outside of their current medical providers.” This is not true and at all
times relevant Attorney Drennan knew that was not true. In fact, the counselor
states that the minor child J.K.D. has not improved [in her care]. The counselors
for all of the minor children have sent many communications regarding getting the
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regarding additional help on the following dates: February 6, 2023, February 27,
618. Attorney Drennan was put on notice of these false statements on the same
day at 8:02 PM. At all times relevant, Attorney Drennan did not correct these
false statements.
619. Attorney Drennan further threatened to seek injunctive relief against the
620. The Deaton minor children still do not currently have access to counseling in
Alabama.
621. Ms. D. Maynard has been clear that J.K.D.’s symptoms have not improved
in her care and has encouraged the parents to seek additional help from the
child’s doctors.
622. Ms. T. Miller recommended a discussion with Plaintiffs L.W.D. and R.E.D.
623. On April 8, 2023, GAL Brantley sent one email to Mr. D. Deaton and Ms. L.
624. Six minutes later, GAL Brantley , under the color of state law, emailed the
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their actual stated advice) and further directed that the GAL Brantley was
opposed to this “last minute attempt before trial” to have the girls seen [by a
625. GAL Brantley works on behalf of the Judge Stephens’ court and makes the
of the court, Leanne makes decisions concerning the girls mental health and
she has been a true advocate for each of them.” and further states “I hope
interest.”
626. GAL Brantley was put on notice of this false statement on the same day at
8:02 PM.
627. At all times relevant, GAL Brantley did not correct her false statement.
628. GAL Brantley continues to speak on behalf of the Ms. L. Deaton, including
to state what she believes Ms. L. Deaton will sign as a release [and the
Defendant does sign a release for GAL Brantley] and further legally
629. GAL Brantley knew at all times relevant that Ms. L. Deaton does not make
all decisions concerning the minor children's mental health and further takes
a position under the color of state law as to what is in the minor children’
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objections and without any communication with their father, Mr. D. Deaton.
630. J.K.D., L.W.D., and R.E.D. were unable to see the counselor directly due to
FFF. Judge Stephens Enters an Order Denying Mr. D. Deaton his Right to use
Documents from his Case to Report the Criminal and Illegal Activity Detailed
631. Judge Stephens emailed Attorney Drennan, Attorney Duncan, GAL Brantley
and counsel for Mr. D. Deaton on April 25, 2023, stating she would be
632. Attorney Duncan objected via an email sent directly to Judge Stephens and
633. On April 30, 2023, at 7:16 PM CT, Judge Stephens entered the following
Plaintiff's Reply thereto. The Plaintiff's Motion was filed on 4/18/2023 at 4:52 P.M.
There being no objection by 04/25/2023, the Court emailed all parties at 11:44 AM
and requested a proposed order from the Plaintiff. The motion was filed eight days
before the Court asked for a proposed order. Defendant then emailed that they
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would file an objection and such was filed on 04/25/2023 at 12:45 PM. The
Plaintiff then filed a reply on 04/25/2023 at 1:45 PM. The Court was inclined to
grant the motion because there was no objection, however since there is an
objection filed some eight days after the motion, the court must now address the
motion and the objection. The Plaintiff's motion broadly and vaguely asks that the
seal be lifted for the limited purpose of providing documentation to state and
federal regulatory bodies. It is of note that "Counsel for both parties waived any
and all notice and consented to the record in this cause, all pleadings, Orders,
records, videos, recordings, documents, and transcripts from any and all hearings
or trials held in this cause being designated as confidential." The following order is
634. After inviting an objection via email, Judge Stephens denies Mr. D. Deaton
from using documents from his case to report criminal activity to state and
635. At all times relevant, Judge Stephens knew or should have known that her
636. In an effort to prevent the Plaintiffs from relief of their criminal activity,
Judge Stephens denied Mr. D. Deaton’s right to share information from his
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case, including his children’s testimony, with state and federal regulatory
bodies.
637. There is no grievance procedure or legal action available to the Plaintiffs for
638. Plaintiffs T. Peake and D. Deaton filed complaints with the Judicial Inquiry
Plaintiffs that they were without jurisdiction to hear the violations pled
herein.
639. Plaintiffs T. Peake and D. Deaton filed with the Alabama State Bar against
640. Ms. T. Peake and D. Deaton filed with the Alabama Court of Civil Appeals
and on cert to the Alabama Supreme Court, which they declined to review or
did not provide substantive opinions or relief to address this illegal activity.
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641. The relevant or applicable appellant courts and regulatory bodies have
regulatory complaints, and to the Presiding Judge of the 10th Judicial Circuit
of Jefferson County, have sought any relief from the illegal actions
complained of herein, all to no avail, and each refusing to review the issues
on the merits. Any further attempts to rectify these wrongs and prevent these
643. Further attempts and regulatory review of the above-mentioned issues have
Deaton to share documents from his case with state or federal regulatory
bodies. Judge Stephens directly denied Mr. D. Deaton the right to share
644. The co-defendants have been allowed to make unchecked, false statements
activity.
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CLAIMS
Count I
DEPRIVATION OF RIGHTS UNDER COLOR OF LAW
(U.S. Const. amend. I; amend. IV; amend. IX; amend. XIV;
42 U.S.C. § 1983; TITLE 18, U.S.C., Section 242)
(Against All Defendants)
forth herein.
646. The pattern and practice of misconduct at Jefferson County Circuit Court
Domestic Relations Division occurred with the consent and direction of the
disregarded the substantial risk of serious harm posed by the actions and
647. Defendants’ actions and inactions set forth above were deliberately
indifferent to the substantial risk they knew the Plaintiffs’ faced and were
objectively unreasonable.
constitutional rights as they received top cover from Judge Stephens, Judge
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649. Upon information and belief, benefits and favors were traded that deprived
650. The Enterprise and each of its members current and former, acted in concert
pursuant to the 1st, 4th, 9th, and 14th Amendments of the Constitution.
651. The Enterprise’s actions were under color of state law because there
652. The Defendant members of The Enterprise further acted under color of law
because of the pervasive nature of this scheme to increase profits and based
prevent harm and further to ignore the rule of law. The pattern of the The
within the color of state law, so as to lend the power and authority of the
653. The Defendants’ misconduct directly and proximately caused the serious
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654. By way of examples but not exclusion, The Enterprise violated the
following ways:
655. Judge Stephens prevented Mr. D. Deaton from ever calling GAL Brantley as
alleged fees.
656. Judge Chappell prevented Ms. T. Peake from every calling GAL Wess as a
fees.
657. GAL Brantley travelled out of state to the Ms. L. Deaton’s house in
Maryland and personally observed the children in their home after Ms. L.
Deaton, Mr. C. Wilson, Ms. R. Wilson, and Ms. E. Goldman paid her
directly.
658. Judge Stephens has entered orders denying Mr. D. Deaton his right to see or
speak to his counsel about evidence legally obtained through court subpoena
659. Judge Chappell refused to require Mr. S. Wyatt to produce a full set of
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660. In addition to the acts alleged above, The Enterprise also deprived the
661. In addition, the following acts also deprived the Plaintiffs access to a fair
662. Judge Chappell expressly retaliated for Ms. T. Peake’s right to seek appellate
review.
663. Judge Stephens eliminated Mr. D. Deaton’s Christmas visitation with his
children in 2021 without notice, without a hearing, and without any evidence
664. In addition to the acts alleged in the preceding paragraphs of Count I, The
665. In addition, the following acts also deprived the Plaintiffs access to a fair
667. The Defendant Judges receipt and provision of benefit and favors in
Enterprise.
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669. The 1st Amendment of the US Constitution guarantees citizens the right to be
670. Judge Chappell directly retaliated against Ms. T. Peake, affecting G.M.W.,
for Ms. T. Peake’s political speech and association with her attorney’s
judicial campaign.
671. Judge Chappell refused to recuse after openly campaigning with on the
672. Judge Chappell hosted a campaign video on public property, during office
673. Insulating and shielding their behavior from scrutiny by sealing their
674. These judges have become so zealous in protecting their shield of secrecy
that they exclude litigants and lawyers, who have every right to be before
them.
675. By example but not by way of exclusion, Judge Stephens has gone so far as
in her courtroom.
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676. Judge Stephens removed a court reporter from the room to prevent a record.
677. Judge Stephens removed Ms. T. Peake’s attorney from her courtroom on
children.
679. Judge Stephens allowed GAL Brantley to direct the medical care of J.K.D.,
L.W.D., and R.E.D. without Mr. D. Deaton’s consent and without allowing
680. Judge Chappell allowed Ms. C. Taylor, a non-attorney, to direct the medical
care of G.M.W. without Ms. T. Peake’s consent and without allowing her to
participate in the process of directing the care of her child, even when she
had final say on medical decisions pursuant to a state statue and the parent’s
agreement.
Count II
RICO
(Violation of RICO; U.S.C. § 1962(c))
(Against All Defendants)
forth herein.
682. Defendants are “persons” within the meaning of 18 U.S.C. § 1961(3) who
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1962(c).
rights and make false statements to multiple tribunals. All entities are
persons within the meaning of U.S.C. § 1961(3) and acted to enable the
under the color of law, bribing, or participating in fraud under the color of
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would have been if The Enterprise would have followed the law and their
Chappell, and Judge May’s involvement with The Enterprise that aided and
covered up these unethical acts against the rule of law. Accordingly, each
portion of The Enterprise benefited from the existence of the other parts.
688. The Defendants exerted control over the enterprise and have participated in
U.S.C. § 1501, honest services fraud under 18 U.S.C. § 1346, criminal fraud,
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mail fraud under 18 U.S.C. § 1341, wire fraud under 18 U.S.C. § 1343,
690. Defendants’ fraudulent scheme consisted of: (a) violating the Plaintiff
Parent’s rights to direct the care and upbringing of their children without a
that Plaintiffs depend on the honesty and integrity of the court and court
officers in Jefferson County, Alabama. The Plaintiffs also rely on state and
692. At all times during the fraudulent scheme, the Defendants and The
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pay the bill as ordered to see their children. The Defendants knew that the
never have been made if the true facts were known. The Defendants’
695. The Defendants’ motive in creating and operating the fraudulent scheme and
was designed to, and did, cause Plaintiffs to pay during the Defendants’
696. The Plaintiffs have been injured in their property by reason of these
to protect themselves that they would not have paid had the Defendants not
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697. The injuries to Plaintiffs were directly and proximately caused by The
rights and ordered to pay fees, thereby causing economic harm in the form
include both paying for more court ordered services than would have
otherwise occurred absent the RICO violations and/or paying more in legal
698. Above all, The Enterprise participants misled and deceived the Plaintiffs and
others who rely on their ethical conduct including the Plaintiffs. The
Defendants with the help of The Enterprise have led to Plaintiffs to pay
exorbitant and fabricated “fees” that would never have been made absent the
fraud.
699. Because of these violations of 18 U.S.C. § 1962(c), the Defendants are liable
to Plaintiffs for three times the damages sustained, plus the costs of this suit,
700. By reason of the foregoing, and as a direct and proximate result of the
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Count III
RICO CONSPIRACY
(Violation of RICO Conspiracy; U.S.C. § 1962(d))
(Against All Defendants)
forth herein.
the First, Fourth, Ninth, and Fourteenth Amendments to the United States
Constitution.
703. Section 1962(d) provides that it “shall be unlawful for any person to
conspire to violate any of the provisions of subsection (a), (b) or (c) of this
section.”
receive bribes in exchange for profits while wielding the power of the state.
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conspiring to violate 18 U.S.C. § 1962(c), but they were aware that their
ongoing fraudulent and extortionate acts have been and are part of an overall
707. As a direct and proximate result of Defendants’ and the Enterprise’s overt
708. The Defendants sought to and have engaged in the commission of and
predicate acts discussed extensively herein, including but not limited to:
c. Multiple violations of The Hobbs Act; and including but not limited to the
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Plaintiffs for three times the damages Plaintiffs have sustained, plus the cost
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Count IV
CIVIL CONSPIRACY
forth herein.
712. Defendants agreed and conspired among each other to act in concert to
conceal the true nature of the The Enterprise to the detriment of the
Plaintiffs.
complaint.
714. The Defendants intended that The Enterprise, their agreement, conspiracy,
and concerted actions would result in the wrongful acts and harm described
herein.
715. The Defendants each participated in a concerted, overt act or acts to further
their conspiracy.
716. The Defendants’ aim was to achieve an unlawful purpose or lawful purpose
by unlawful means.
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conspiracy, and concerted actions as described herein, the Plaintiffs have and
continue to be damaged.
Count V
ABUSE OF PROCESS
forth herein.
720. The Defendants, individually and through The Enterprise, held an ulterior
721. The use of the legal process as The Enterprise, as outlined in detail herein,
722. In doing so, the Defendants acted consciously and maliciously of the harm
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723. The Defendants’ actions in abusing the legal process for an unlawful purpose
did in fact cause harm to the Plaintiffs, including by not limited to,
unnecessary attorney fees, cost of court, lost wages, and mental and
Count VI
FRAUD
forth herein.
725. The Defendants, jointly and severely, independently and on behalf of The
statements, misrepresent the true facts, and conceal the facts, as outlined in
726. The nature and actions described in detail in this complaint required the
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728. The statements were made with intent to deceive and cover up the acts, and
the true facts. Such statements were made knowing or intentionally of the
731. The Plaintiffs actually and proximately suffered damages as a result of these
Count VII
UNJUST ENRICHMENT
(All Plaintiffs v. GAL Brantley, GAL Wess, Hardy Law Firm, and Wess Law Firm)
forth herein.
733. GAL Brantley, GAL Wess, Hardy Law Firm, and Wess Law Firm engaged in
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734. GAL Brantley, GAL Wess, Hardy Law Firm, and Wess Law Firm
manufactured fees for no legitimate purpose except to increase their own fee
claim.
735. GAL Brantley, GAL Wess, Hardy Law Firm, and Wess Law Firm exchanged
in these unethical and illegal acts, including but not limited to the following
by way of examples:
737. GAL Brantley signed an agreement of the parents and, for no legitimate
two years.
738. GAL Wess acted as legal counsel for Ms. C. Wyatt and Mr. G. Wyatt after
accepting their bribe but then also billed Ms. T. Peake and Mr. S. Wyatt for
739. GAL Brantley appeared in open court before Judge Stephens to request fees
for her daughter, JA Brantley, and then billed Mr. D. Deaton and Ms. L.
Deaton for the same time and services. When directed asked to withdraw for
this clear conflict, GAL Brantley refused and marched forward billing tens
740. GAL Brantley, GAL Wess, Hardy Law Firm, and Wess Law Firm knowingly
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legitimate fees earned in the respective cases with fellow participants from
The Enterprise.
741. As a direct and proximate result, GAL Brantley, GAL Wess, Hardy Law
Firm, and Wess Law Firm are each in possession of money, which in equity
and good conscience, is unearned, does not belong to them, and due to be
742. The funds paid by the Plaintiffs, which is currently in the possession,
custody, or control of GAL Brantley, GAL Wess, Hardy Law Firm, and Wess
Law Firm, were paid under protest, out of fear of retribution, and under
duress.
Count VIII
FALSE IMPRISONMENT
forth herein.
744. GAL Brantley falsely imprisoned and created the unlawful detention of
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745. On or about October 2019, GAL Brantley intentionally confined them to her
car and transported L.W.D., and R.E.D. using the authority of her position to
746. GAL Brantley's confinements caused all members of the Plaintiffs to suffer
emotional distress, financial loss, and time away from one another that can
never be recovered.
747. The Plaintiffs are entitled to relief, including damages, injunctive relief, and
attorneys' fees.
Count IX
FALSE IMPRISONMENT
(J.K.D., L.W.D., and R.E.D. v. GAL Brantley, Attorney Duncan, Judge Stephens,
forth herein.
749. GAL Brantley, Attorney Duncan, and Judge Stephens confined J.K.D.,
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750. On or about June 29, 2022, GAL Brantley, Duncan, and Judge Stephens
confined J.K.D., L.W.D. and R.E.D. without legal authority or consent from
Mr. D. Deaton.
emotional distress, financial loss, and time away from one another that can
never be recovered.
752. The Plaintiffs are entitled to relief, including damages, injunctive relief, and
attorneys' fees.
Count X
FALSE IMPRISONMENT
forth herein.
754. Attorney Gregory falsely imprisoned and created the unlawful detention of
G.M.W.
755. On June 21, 2020, Attorney Gregory confined and transported G.M.W.
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emotional distress, financial loss, and time away from one another that can
never be recovered.
757. The Plaintiffs are entitled to relief, including damages, injunctive relief, and
attorneys' fees.
Count XI
FALSE IMPRISONMENT
forth herein.
759. Attorney Drennan falsely imprisoned and created the unlawful detention of
760. On August 27, 2019, Attorney Drennan confined and transported J.K.D. and
suffer emotional distress, financial loss, and time away from one another that
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762. The Plaintiffs are entitled to relief, including damages, injunctive relief, and
attorneys' fees.
Count XII
FALSE IMPRISONMENT
(Ms. T. Peake and G.M.W. v. Ms. C. Taylor, Caroline O. Taylor, Attorney Fann,
forth herein.
764. Ms. C. Taylor falsely imprisoned and created the unlawful detention of
765. On or around December 20-22, 2019, Ms. C. Taylor made multiple false
766. Ms. C. Taylor alleged that she sent her concerns to Judge Chappell. If true,
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767. These confinements caused Ms. T. Peake to be unable to enter her home if
G.M.W. was present and for G.M.W. to be unable to interact with his
768. Ms. C. Taylor further demanded and directed under color state of law that
769. The actions, instructions, and directives of Ms. C. Taylor, in her own words,
were to have the same effect as judge’s orders, due to Attorney Fann and
770. Attorney Fann and Judge Chappell delegated these authorities and the power
of the state to Ms. C. Taylor illegally and then failed to supervise her actions.
771. The Plaintiffs to suffer emotional distress, financial loss, and time away
772. The Plaintiffs are entitled to relief, including damages, injunctive relief, and
attorneys' fees.
!151
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Count XIII
INVASION OF PRIVACY
Kirk.Drennan)
forth herein.
obtaining video of G.M.W., a minor child, through the window of his home,
Attorney Drennan and Attorney Duncan refused to turn over video of the
775. The invasion of Ms. T. Peake and G.M.W.’s privacy was intentional and
without consent.
776. The invasion of Ms. T. Peake and G.M.W.’s privacy was highly offensive to
a reasonable person.
777. As a direct and proximate result of the invasion of privacy, Ms. T. Peake and
G.M.W. has suffered damages, including but not limited to: mental anguish,
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Count XIV
INVASION OF PRIVACY
forth herein.
781. On or around November 2022, Judge Chappell admitted on the record of the
trial that the psychological evaluation of Ms. T. Peake should not have been
782. Attorney Yarbrough and Attorney Gregory admitted on the record that they
removed the psychological evaluation from under seal allegedly with the
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expressly represented that he did not represent Mr. S. Wyatt or Ms. T. Peake
784. The invasion of Ms. T. Peake’s privacy was intentional and without consent.
person.
786. As a direct and proximate result of the invasion of privacy, Ms. T. Peake has
suffered damages, including but not limited to: mental anguish, emotional
Count XV
INVASION OF PRIVACY
(Mr. D. Deaton and J.K.D. v. Ms. D. Maynard and Hope for Healing)
forth herein.
!154
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789. On March 20, 2023 Mr. D. Deaton states that “I do not agree and have never
agreed for you to discuss this with third parties. I do not understand why
you are copying an attorney in Alabama while refusing to speak with mine.”
790. Even after Mr. D. Deaton requests Ms. D. Maynard to cease sharing
[J.K.D.]'s ad litem, from time to time, when there is a need for an update,
that I deem important, in advocating for [J.K.D.]'s well being. This is under
my discretion.”
791. The invasion of J.K.D.’s privacy was intentional and without consent.
person.
793. As a direct and proximate result of the invasion of privacy, J.K.D. and Mr.
D. Deaton has suffered damages, including but not limited to: mental
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Count XVI
INVASION OF PRIVACY
forth herein.
795. On or around December 22, 2019, Ms. C. Taylor made claims about what
capacity.
796. Ms. C Taylor’s claims about what she alleged was happening in Ms. L.
that the neighbor supervise activities when the girls were present.
797. The invasion of J.K.D., L.W.D., and R.E.D.’s privacy was intentional and
without consent.
798. The invasion of J.K.D., L.W.D., and R.E.D.’s privacy was highly offensive
to a reasonable person.
799. As a direct and proximate result of the invasion of privacy, J.K.D., L.W.D.,
R.E.D. and Mr. D. Deaton have suffered damages, including but not limited
to: mental anguish, emotional distress, loss of privacy, and financial loss.
!156
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Count XVII
forth herein.
801. On or about December 2022 and again in May 2023, the Defendant violated
the Alabama Litigation Act by continuing to pursue a custody claim with full
custody modification.
802. The custody claim pursued by Attorney Drennan, Attorney Duncan, and
803. In fact, Attorney Drennan represented to the court that Kirk.Drennan was not
seeking a custody claim for full legal and full physical custody.
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804. After the above representation, Attorney Duncan was directly asked to
not seeking a custodial change on Ms. L. Deaton’s behalf, (2) after being
and (3) after being asked directly to withdraw the claim, Attorney Drennan
and Attorney Duncan still refused to amend or withdraw a claim that served
Plaintiffs.
807. As a direct and proximate result of Attorney Drennan, Attorney Duncan, and
suffered damages, including but not limited to, financial loss, emotional
distress, and the loss of precious time in their lives, which they will never be
able recover.
!158
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Count XVIII
forth herein.
Jr., Attorney Clark, and Wallace Jordan pursued litigation they knew to be
Jr., Attorney Clark, Wallace Jordan pursued and billed for emergency
litigation as to where G.M.W. should attend school, after both parents toured
the school, submitted an application fee to hold the child’s spot, and while
Ms. T. Peake held final say pursuant to an Alabama state statue on decision
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Jr., Attorney Clark, Wallace Jordan asked for Ms. T. Peake to be jailed by
Judge Chappell for selecting her child’s school after touring it with her co-
parent, Mr. S. Wyatt, and after Mr. S. Wyatt paid the application fee.
812. Mr. S. Wyatt did not oppose and still does not oppose G.M.W. attending his
current school.
increase litigation for their own profits. Despite these Defendant attorneys
advancing this school issue for years that caused hundreds of thousands in
damages to the Plaintiffs, Mr. S. Wyatt’s sworn testimony at trial did not
those alleged fees against Ms. T. Peake due to her associate with The
Enterprise.
815. To this date, G.M.W. remains enrolled in the same school as he was when
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damages, including but not limited to, financial loss, emotional distress, and
the loss of precious time in their lives, which they will never be able recover.
Count XIX
(Ms. T. Peake and G.M.W. v. GAL Wess and Wess Law Firm)
forth herein.
818. On March 14, 2023, Ms. T. Peake and Mr. S. Wyatt agreed for GAL Wess to
be removed.
819. Judge May directed GAL Wess’ removal from the bench, and GAL Wess
820. After being dismissed from the case, GAL Wess continued to litigate the
821. GAL Wess and Wess Law Firm, purporting to bring a pleading on behalf of
Peake’s appeal.
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822. GAL Wess knew or should have now his pleading had no basis in law or
fact.
823. GAL Wess knew and stated he knew he had been dismissed from the case.
824. Not for any legitimate purpose, but only to increase his profits, GAL Wess
and Wess Law Firm interfered and pursued further litigation in the Alabama
case.
825. As a direct and proximate result of GAL Wess and Wess Law Firm’s
damages, including but not limited to, financial loss, emotional distress, and
the loss of precious time in their lives, which they will never be able recover.
Count XX
(Mr. D. Deaton, J.K.D., L.W.D., and R.E.D. v. GAL Brantley and Hardy Law
Firm)
forth herein.
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827. GAL Brantley signed an agreement of the parents and, for no legitimate
two years.
828. GAL Brantley knew in 2019 that her objection and continual litigation
served no legitimate purpose except to expand her fees and harass the
829. In 2021, GAL Brantley appeared in open court before Judge Stephens to
request fees for her daughter, JA Brantley, and then billed Mr. D. Deaton and
830. GAL Brantley knew or should have known she could not pursue litigation on
her daughter’s (JA Brantley) behalf while billing Mr. D. Deaton and Ms. L.
831. When directly asked to withdraw for this clear conflict by an attorney, GAL
832. As a direct and proximate result of GAL Brantley and Hardy Law Firm’s
damages, including but not limited to, financial loss, emotional distress, and
the loss of precious time in their lives, which they will never be able recover.
!163
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Count XXI
DEFAMATION
forth herein.
834. The defamatory statements made, and harm delivered by Attorney Drennan
835. By way of example but not exclusion, Attorney Drennan has stated, “Mr.
Deaton has historically interfered with the girls’ mental health care which is
836. At all times relevant, Attorney Drennan knew her statement was false.
837. Attorney Drennan was put on notice of her false statement in pleadings and
scheduled.
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material to a third party separate, apart, and unnecessary from the litigation
process.
not limited to, financial loss, emotional distress, and the loss of precious
Count XXII
DEFAMATION
forth herein.
843. By way of example but not exclusion, Attorney Gregory met with GAL
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844. By way of example but not exclusion, Attorney Yarbrough made defamatory
remarks about Ms. T. Peake and directed her staff not to allow Ms. T. Peake
to set a conference call on her schedule at any time, while Ms. T. Peake was
harm to Mr. T. Peake’s reputation and directly caused damage to prevent the
material to a third party separate, apart, and unnecessary from the litigation
process.
damages, including but not limited to, financial loss, emotional distress, and
the loss of precious time in their lives, which they will never be able recover.
!166
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Count XXIII
DEFAMATION
forth herein.
849. Ms. C. Taylor knowingly made defamatory statements about three minor
850. By way of example but not exclusion, on or around December 22, 2019, Ms.
851. Ms. C. Taylor made these defamatory statements about J.K.D., L.W.D., and
R.E.D. to multiple third parties including attorneys and one of her neighbors.
852. Ms. C. Taylor defamatory statements created harm to J.K.D., L.W.D., and
R.E.D. reputation, including but not limited to their ability to make friends
material to a third party separate, apart, and unnecessary from the litigation
process.
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the Plaintiffs have suffered damages, including but not limited to, financial
loss, emotional distress, and the loss of precious time in their lives, which
Count XXIV
MALICIOUS PROSECUTION
forth herein.
857. Ms. C. Taylor acted without probable cause and with malice.
858. Ms. C. Taylor raised this claim for the purpose of harassing Ms. T. Peake
and G.M.W. and in an attempt to improperly further line their pockets and
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859. The prior proceeding ended in favor of Ms. T. Peake when Attorney John
Dana withdrew the claim after his client, Ms. C. Taylor, refused to testify in
860. Approximately one month prior, Ms. C. Taylor testified at Ms. T. Peake’s
861. As a direct and proximate result of Ms. C. Taylor and Caroline O. Taylor’s
damages, including but not limited to, financial loss, emotional distress, and
the loss of precious time in their lives, which they will never be able recover.
Count XXV
LEGAL MALPRACTICE
(J.K.D., L.W.D., and R.E.D. v. GAL Brantley and Hardy Law Firm)
forth herein.
Alabama.
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864. On or about August 2019 and again in November 2021, GAL Brantley
865. GAL Brantley failed to exercise the reasonable care and skill expected of an
866. By way of example but not exclusion, GAL Brantley signed an agreement of
867. Both Ms. L. Deaton and Mr. D. Deaton agree this period of delay caused
868. As a direct and proximate result of GAL Brantley’s negligence, the Plaintiffs
have suffered damages, including but not limited to: economic damages such
Count XXVI
LEGAL MALPRACTICE
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forth herein.
870. GAL Wess is an attorney licensed to practice law in the State of Alabama.
871. On or about October 2019, GAL Wess and Wess Law Firm accepted the
objections thereafter.
872. GAL Wess failed to exercise the reasonable care and skill expected of an
873. By way of example but not exclusion, GAL Wess charged to accommodate
874. By way of example but not exclusion, GAL Wess acted as legal counsel for
Ms. C. Wyatt and Mr. G. Wyatt after accepting their bribe but then also
billed Ms. T. Peake and Mr. S. Wyatt for the same time and services.
875. As a direct and proximate result of GAL Wess’ negligence, the Plaintiffs
have suffered damages, including but not limited to: economic damages such
Count XXVII
LEGAL MALPRACTICE
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Alabama.
877. It is well known within the Birmingham legal community that Attorney
Davidson suffers from substance abuse disorder and became known to Mr.
D. Deaton only after Attorney Davidson became involved in his case and
directed the actions of his children separate, apart, and unnecessary to the
litigation process and without authority to direct the actions she purported to
require.
878. Attorney Davidson was impaired to the extent that she could not render the
879. The Defendant failed to exercise the reasonable care and skill expected of an
880. As a direct and proximate result of the Attorney Davidson's breach of the
standard of care, Mr. D. Deaton, J.K.D, L.W.D., and R.E.D. have suffered
Count XXVIII
!172
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LEGAL MALPRACTICE
Alabama.
883. Attorney Fann failed to exercise the reasonable care and skill expected of an
885. As a direct and proximate result of the Attorney Fann's negligence, the
Plaintiff has suffered damages, including but not limited to: economic
damages such as attorney’s fees, lost wages and medical expenses; and non-
Count XXIX
LEGAL MALPRACTICE
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Alabama.
889. Following this consultation and the divorce of Ms. T. Peake and Mr.
890. Crittenden Partners appeared as legal counsel for Mr. S. Wyatt on or around
August 2019.
891. The standard of care required Attorney Montgomery Lee to keep the
these facts.
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894. But for their possession of the information gained in confidence, Mr. S.
Wyatt would not have been able to prevail against Ms. T. Peake in their post
divorce litigation.
895. In fact, Mr. S. Wyatt alleged that no other attorney in Alabama could
possibly represent him except for the defendants (Crittenden Partners) and
further litigated to keep them in the case. They remain involved in the post
896. As a direct and proximate result, Judge Chappell, entered an ordered against
Ms. T. Peake, causing damages including by not limited to: attorney fees,
Count XXX
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MALPRACTICE
Alabama.
898. Ms. C. Taylor directed the medical care of Ms. T. Peake and G.M.W., not for
the purpose of diagnosis or any medical treatment, but solely for use in
litigation.
899. By way of example but not exclusion, Ms. C. Taylor breached the duty of
care and then withheld G.M.W.’s file, including invoices, for no legitimate
purpose and at all times relevant prior to filing refused to produce G.M.W.’s
file.
900. As a direct and proximate result of Ms. C. Taylor and Caroline O. Taylor
P.C.'s negligence, the Plaintiff has suffered damages, including but not
limited to: economic damages, such as lost wages and medical expenses;
Count XXXI
!176
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MALPRACTICE
Alabama.
Alabama.
903. Dr. Blotcky and Alan D. Blotcky, Ph.D., LLC directed the medical care of
Ms. T. Peake and G.M.W., not for the purpose of diagnosis or any medical
904. By way of example but not exclusion, Dr. Blotcky breached that duty of care
APA protocol in his service to the court against a court order, and refusing to
905. As a direct and proximate result of Dr. Blotcky and Alan D. Blotcky, Ph.D.,
LLC’s negligence, the Plaintiff has suffered damages, including but not
limited to: economic damages such as attorney’s fees, lost wages and
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907. The Plaintiffs seek access to a proper and unbiased court to hear these issues
affecting minor children on their merits and further seek the following relief:
violated the First, Fourth, Ninth, and Fourteenth Amendments to the United States
Constitution;
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limited to, wages, bribes, kickbacks, salaries, fees, and any other monetary or non-
JURY DEMAND
!179
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!180
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(By US Marshall)
Patricia Stephens
2124 7th Ave N Ste 210
Birmingham, AL 35203-2729
Agnes Chappell
2124 7th Ave N Ste 230
Birmingham, AL 35203-2729
Amanda Duncan
201 Office Park Dr Ste 320
Mountain Brk, AL 35223-2424
Clotele Brantley
2885 Acton Rd Apt J
Birmingham, AL 35243
Everett Wess
1900 Crestwood Blvd Ste 110
Irondale, AL 35210-2056
Paige Yarbrough
1 Independence Plz Ste 305
Birmingham, AL 35209-2658
Deborah Gregory
1 Independence Plz Ste 305
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Birmingham, AL 35209-2658
Judith Crittenden
1 Independence Plz Ste 305
Birmingham, AL 35209-2658
Gary Lee
800 Shades Creek Parkway, Suite 400
Birmingham, AL 35209
Jay Clark
800 Shades Creek Parkway, Suite 400
Birmingham, AL 35209
Deegan Malone
2721 Jenny Ln
Vestavia Hills AL 35243
Alan Blotcky
529 Beacon Pkwy W #107,
Birmingham, AL 35209
Wendy Crew
2001 Park Pl Ste 550
Birmingham, AL 35203-2714
Christina Vineyard
2001 Park Pl Ste 550
Birmingham, AL 35203-2714
Marcus Jones
300 Arrington Blvd N Ste 200
!182
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Birmingham, AL 35203-3357
Madison Brantley
2885 Acton Rd Apt J
Birmingham, AL 35243
Carolyn Wyatt
1945 Indian Lake Dr.
Birmingham, AL 35244
Gary Wyatt
1945 Indian Lake Dr.
Birmingham, AL 35244
Caroline Taylor
1502 Roseland Dr
Birmingham, AL 35209
Kim Davidson
400 Vestavia Pkwy Ste 100
Vestavia, AL 35216-3750
Heather Fann
201 Office Park Dr Ste 320
Mountain Brk, AL 35223-2424
!183
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Kirk.Drennan P.C.
500 Office Park Dr Ste 100
Mountain Brk, AL 35223-2444
Renee Wilson
153 Sansbury Rd.
Friendship, MD 20758
Compton Wilson
153 Sansbury Rd.
Friendship, MD 20758
!184
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Erika Goldman
153 Sansbury Rd.
Friendship, MD 20758
Michael Labellarte
130 Admiral Cochrane Dr,
Annapolis, MD 21401
Dale Maynard
1831 Forest Drive, Suite F,
Annapolis, MD 21401
Terri Miller
102 Old Solomons Island Road
Suite 202
Annapolis, MD 21401
David Kellner
65 Old Solomons Island Rd #104,
Annapolis, MD 21401
!185
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Annapolis, MD 21401
Andrea Weiss
3112 Arundel on the Bay Rd,
Annapolis, MD 21403
Connie Coker
3112 Arundel on the Bay Rd,
Annapolis, MD 21403
Craig Langrall
6115 Franklin Gibson Rd.
Tracy’s Landing, MD 20779
!186