BEFORE THE BOARD OF COMMISSIONERSON

GRIEVANCES AND DISCIPLINEOF

THE SUPREME COURT OF OHIO

In Re:

Complaint against

Gerald M. JacksonAttorney Reg. No. 0010039

Resnondent,

Cuyahoga County Bar Association

Relator.

Case No. 08-006

08

Findings of Fact,Conclusions of Law andRecommendation of theBoard of Commissioners onGrievances and Discipline ofthe Supreme Court of Ohio

CONSENT TO DISCIPLINE

This matter was considered by a Board hearing panel consisting of Martha L. Butler,

Lynn B. Jacobs, and Paul M. De Marco, Chair. None of the panel members is from the district

from which the Complaint originated or served on the probable cause panel that certified this

matter to the Board.

The panel was appointed by Entry filed on March 24, 2008. Within 60 days thereafter,

specifically on May 14, 2008, the parties timely filed an "Agreement of Relator and Respondent

Regarding Discipline by Consent Pursuant Section 11 of the Rules and Procedures of the Board

of Commissioners on Grievances and Discipline," a copy of which is attached hereto.

The Relator is represented by Donald McFadden, James Loeb, and Ellen Mandell. The

Respondent is represented by Richard Alkire.

R., LL ^^)? `'+ 2003

CLERK OF COURSUPREME COURi OF

TOHlO

By the attached Agreement, Exhibits, and Affidavit, Respondent admits to violating the

following disciplinary rules, stemming from his representation of one client in a domestic

relations case in 2003 and 2004:

DR 9-102(B)(3) (a lawyer shall maintain records of amounts billed and fundsreceived and shall render an appropriate accounting of times, fees, and expenses);

DR 1-104(A) and (B) (a lawyer shall inform the client and obtain a waiver if thelawyer does not maintain professional liability insurance).

In summary, Respondent undertook the client's representation in a domestic

relations matter in 2003. Respondent normally devotes less than 5% of his professional

time to such matters. He was discharged in 2004 after providing services for

approximately ten months. He failed to respond to the client's request for a complete

accounting of fees paid and time spent. Respondent turned over his file to successor

counsel in 2006. Despite having an hourly fee retention agreement with the client,

Respondent did not maintain contemporaneous time records. He also did not have

professional malpractice insurance during that time. He neither informed the client of

this fact, nor attempted to obtain a waiver from the client.

The parties stipulate that no aggravating factors are present. Mitigating factors

include that Respondent has no prior disciplinary record and no dishonest or selfish

motive; that he has cooperated in the investigation and made full and free disclosure to

Relator; that he has a good character and reputation; and that he is under counseling for

depression. Respondent's affidavit reports that he was admitted to the bar in 1972, and

that he has been engaged since then in the general practice of law, including representing

small business organizations and non-profit organizations, and handling simple estate

matters, with a small amount of domestic relations work.

2

PANEL RECOMMENDATION

The parties have agreed upon the sanction of a public reprimand. The panel

recommends acceptance of the Agreement consenting to discipline, including the

stipulated sanction.

BOARD RECOMMENDATION

Pursuant to Gov. Bar Rule V (6)(L), the Board of Commissioners on Grievances and

Discipline of the Supteme Court of Ohio considered this matter on June 5, 2008. The Board

voted to accept and adopt the agreement entered into by the relator and respondent. The

agreement sets forth the misconduct and the sanction of a public reprimand which is the

recommendation of the Board. The Board further recommends that the cost of these proceedings

be taxed to the Respondent in any disciplinary order entered, so that execution may issue.

Pursuant to the order of the Board of Commissioners on

Grievances and Discipline of the Supreme Court of Ohio,

I hereby certify the foregoing Findings of Fact, Conclusions

of Law, and Recommendation as those of the B

Board of Commissioners onGrievances and Discipline ofThe Supreme Court of Ohio

3

BEFORE THE BOARD OF COMMISSIONERSON GRIEVANCES AND DISCIPLINE OF

THE SUPREME COURT OF OHIO

IN RE:

Complaint against

Gerald M. Jackson,

Respondent,

Cuyahoga County Bar Association,

Relator.

FILED

MAY I 6 2008BOARD OF CO10AIISSIONEHS

ON GRIEVANCES & DISCIPLINE

Case No. 08-006

AGREEMENT OF RELATOR AND RESPONDENT REGARDiNG DISCIPLINE BYCONSENT PURSUANT TO SECTION 11 OF THE RULES AND PROCEDURES OF THE

BOARD OF COMMISSIONERS ON GRIEVANCES AND DISCIPLINE

I. AGREED STIPULATIONS

Relator filed a complaint against Respondent Gerald M. Jackson with the Board of

Cominissioners on Grievances and Discipline of the Slipreme Coiirt of Ohio (the "Board")

on February 11, 2008, which was certified by a probable cause panel. Respondent filed

an answer to the allegations on March 21, 2008, Relator and Respondent now enter into

this Agreement for Discipiine by Consent ("Agreement") pursuant to BCGD Proc. Reg. §

11 and stipulate to the admission of the following facts, violations of the Code of

Professional Responsibility, sanction, mitigating factors and exhibitsIi, ^^` ^^ ^

Additionally, Relator and Respondent recognize that the terms of this Agreement

are conditioned on acceptance of this Agreement by the Board and court pursuant to Gov.

Bar R. V(8)(D) and BCGD Proc. Reg. § 11, Consent to Discipline.

II. STIPULATED FACTS

1. Respondent Gerald M. Jackson was admitted to the practice of law in the

State of Ohio on May 6, 1972 and is subject to the Supreme Court Rules for

the Government of the Bar of Ohio and the Code of Professional

Responsibility. Respondent concentrates his practice on small business

organizations, simple estate matters and non-profit business organizations.

His domestic relations practice constitutes less than 5% of his total

professional time:

2. On or about September, 2003, Respondent was retained by Schaeffer

Greene (hereinafter "Greene") to represent Greene in a divorce action in the

Cuyahoga County Domestic Relations Court, being Case No. DR-02-290120,

captioned Greene v. Naylor. In connection with the Greene v. Naylorcase,

Respondent provided legal services at the rate of $225.00 per hour plus

costs.

3. Respondent was discharged by Greene on or about June .30, 2004 after

providing legal services for approximately ten months. By letter dated

January 9, 2006, Greene requested of Respondent a complete accounting of

fees paid and time spent. Respondent did not respond to this written

request. By January 9, 2006, Respondent had turned over his file for the

Greene v. Naylorcase to subsequentj^ounsel in August, 2004, who he

assisted Greene in locati

4. Respondent did not maintain contemporaneous time records despite having

an hourly fee retention agreement with Greene.

5. Respondent did not maintain professional Ilability insurance coverage during

the period of time in which he represented Greene and did not inform Mr.

Greene of this or obtain a waiver.

6. On July 3, 2007, at the request of Relator's Investigator, Respondent

provided a reconstructed, detailed description of time spent and expenses

incurred in connection with his representation of Greene, indicating total

hours of 104.9 at $225.00 per hour equaling $23,602.50.

7. In connection with the investigation of Greene's grievance, Respondent

documented payments made by Greene totaling $13,098.75, although

Greene claimed that he made payments in excess of $20,000.00.

8. When Respondent moved from his Lee Road office to its current location in

late 2005, the QuickBooks computer data associated with his bank accounts

was lost.

111. STIPULATED EXHIBITS

Exhibit I Engagement letter between Respondent and Greene (Exhibit A toRelator's Complaint).

Exhibit 2 January 9, 2006 letter from Greene to Gerald M. Jackson (Exhibit B toRelator's Complaint).

Exhibit 3 ProNational Insurance Company Declarations and Endorsementsindicating the existence of a primary professional liability policyeffective November 1, 2007 applicable to Respondent, Policy No.0HL0005352.

Exhibit 4 July 3, 2007 itemized time and expense log ap,pliCable toRespondent's representation of Greenej.. 4

3

Exhibit 5 September 21, 2007 email from Respondent to Relator's investigatordocumenting receipt of payments made by Greene in connection withRespondent's representation of Greene.

Exhibit 6 Supporting documentation from National City Bank relative to thereceipt of payments from Greene by Respondent,

Exhibit 7 Waivers from clients of Respondent concerning his lack of applicableprofessional liability insurance coverage.

Exhibit 8 Character letters.

IV. STIPULATED VIOLATIONS OF THE CODE OF PROFESSIONALRESPONSIBILITY AND STIPULATED SANCTION

9. Respondent failed to maintain records of amounts billed and funds received,

and failed to render an appropriate accounting of times, fees and expenses, in

violation of DR 9-102(B)(3).

10. Respondent neither informed Greene about the absence of professional liability

insurance, and he did not obtain and maintain a waiver from Greene, all in

violation of DR 1-104(A) & (B).

11. Relator and Respondent recorrimend that the Board impose a public

reprimand against Respondent.

V. STIPULATED MITIGATING FACTORS

12. Relator and Respondent stipulate that Respondent's conduct involved the

following mitigating factors as listed in BCGD Proc. Reg. § 10(B)(2):

(a) absence of prior disciplinary record;

(b) absence of dishonest or selfish motive;

(d) full and free disclosure to disciplinary board or cooperative attitude

toward proceedings; and

(e) good character and reputation.

4

tCz

13, Respondent attaches hereto (Exhibit 7) notifications and executed waivers

from other clients he represents to whom his current liability insurance

coverage does not apply.

14. In an effort to provide restitution to Greene, Respondent agrees to refund

Greene $1,500.00 of fees received in connection with his representation.

15. Relator and Respondent stipulate that none of Respondent's conduct

involves any aggravating factors as listed in BCGD Proc. Reg. § 10(B)(1).

Respectfully submitted,

nald P!'McFadden, Esq. (0002233)cFadden & Freeburg Co., L.P.A.

1370 Ontarlo Street, Suite 1700Cleveland, OH 44113216-662-0850 / Fax 216-373-9288www.mcfaddenlaw.us

eesohio.com

Ja es oeb, Esq. (0040943)Ba er & Hostettler LLP32 National City Center1900 East Ninth StreetCleveland, OH 44114216-661 •7674 1 Fax 216,696.0740jl oe b0ba ke rl aw. com

llen S. Mandell,Esq. 12026)1717 The Illuminating Building55 Public SquareCleveland, OH 44113-1901216-771-7080

Counsel for Relator

ard C. Alkire (0024816)Richard C. Alkire Co., L.P.A.250 Spectrum Office Building6060 Rockside Woods BoulevardIndependence, OH 44131-2335216-674-0550216-674-0104 (Fax)Counsetfor Respondent

5

Feb 26 08 12:28p Jackson Legal Services ' 16-561-1160 p.5

THE JACKSON LAW. COMPANYaa A LAL FrESSIONAIASSOCIATIOM A AT7UNYS AMD OUSElOS AT tAW

^• ^

Mr. R. Schaeffer Greene23356 West Ranch HitlSauthfield, MI 48034

re: Domestic Relations - Greene v. GreeneCuyahoga County Court Case Number DR02290120

Dear Mr. Greene:

This letter will confirm our prior discussion in which we agreed, at your request,to represent you in the above-captioned matter.

i '^s we explained to you, because of the nature of the matter, and because of thepossib^jty of the occurrence of presenily unpredictable and unforseen circumstances,we are not in the position to quote you a specific fee for our professionai services.However, we indicated to you that we woutd represent you on a hourly fee basis. Ourfee for legal services, including office and telephone consultations are $225.00 per hourand take into account interrupbons of other work. Each such hour is based upon actualwork on your particular case.

When we are requested lo leave our office in your behalf, you will be charged atthe same hourly rate, although we shaN minimjze travel experrses and courthouse time,if any whenever we are able. Any out-of-pocket expenses directly attributable to yourmatter, including travel expenses, will be charged to you at cost, in addition to the fee.This letter will also confirm receipt of $625.00 [9108/03) and $4,473.75 [9/0912003j,representing a total retainer $5,098.75, to be crediled against the fee(s).

We are pleased to represent you in this matter, and we assure you that we wjllpursue your matter as diligently and expeditiously as possible.

Very truly yours,

Gerald M. JacksonGMJ:ajrn

- EXHIBIT 1

3 6 7 3 1 _ r c H u n d A Sha kcr HGlghrs,UbioA da 120-510 5

Ph: 2 1 b• 75 2• 8 0 (10 A Pas :2 1 6- 7 12 -:1 0 4 6A c-maih,jlcla^c^i,yahuo.com

,q fNHId^

Feb 26 08 12:28p Jackson Lega! ServicesI • .

• M;. Gerald M. Jackson`(0010039(76.73 Lee Ro;hd ^

Mr', schae€t`er` ^'ree45497 Delmar Drlve

yacomb TWP, hlichigan 48044

,7anuaYy9, 2006 ',•;;^. -

SliakeY A1elgh't3,Ohi6=s ;44120-0.000- . •

Re: Case DR-02-290120 / sent via certified mail

Dear Mr. Jackson, .

I am requesting that you send me an itemized statementfor the feesthat were paid to you during the time in which you represented me.

specifically, list the service that you provided, hours spent on eacservice and your £ee for the service. Overall, this information isrequested so that I can verify and check your data against my recordand my cancelled check records for fees paid.

I am requesting to receive this document in 7 business days.

If you have any questions, please contact me during my business hou:.(8:00 am - 5:00 pm, M-F) at 586-336-1729:

I look forward to your prompt response.

e fer GreeneJ

EXHIBIT 2

p.6

ProiVationalfN{'IIRAM(,.l fPo1NNt

9 LawyerCare^,T1t1519ACLAIM$-

MAOE POUCY.PLEA3E RFr1n THE

POLICY CAREFULLY.

Primary Profcssional Llability Policy forLawyers and Law Firms

DECLARATIONS

Policy Number: OHL0005362

Flrst Named Insured and Address(#, Street, Town or City, County, Zip Code)3ackson Legal Services,lLC15925 Van Aken Blvd.

13-Po-jicy Period

Effective Date: ovember 01, 2007Suite 205Shaker Heights, OH 44120 Expiration Date: Navember 01, 2008

Retroactive Date: July 01, 200712:01 A.M. Standard Time at the addressof Ihe Named Insured as stated heraln.

®Producer Name

R. A. Greene & Associates, Inc.

56 Milford Dr. Suite 412Hudson OH 44236

.OLimit of Liability (Includes Claims Expenses)

$ 100,000 Each Claim$ 300,000 Aggregate

EDeductibie$ 0 Per Claim

[oPremium$ 1,326 Number of Lawyers: 1

©Forms Attached at tssue

See Schedule of Forms Attached

Remarks

Countersigned at Livonia, MI Issue Date November26, 2007

Authodzed z^ I 1^ Date 1 - 3 ,,,pFftepressntatlye

LCP101 (1/98) @1998 PraNational Insurance Company

EXHIBIT 3

Ft2ONATlONAL INSURANCE COMPANY

POLICY NUMBER: OHL0005352

NAMED INSUREO: Jaqkson Legal Services, LLC

FORMS LISTED BELOW ARE INCLUDED IN THIS POLICY

LCP100 0198 POLICY FORMLCP101 0198 DECLARATJONS

LCP200 0198 GENERAL PURPOSE ENDORSEMENTLCP201 0198 ENTITY EXCLUSION ENDORSEMENT

LCP204 0198 EXCLUSION OF A'iTORNEYS ENDORSEMENT

LCP215 0698 EMPLOYMENT PRACTICES DEFENSE ENDORSEMENT

LCP223 0702 PRACTICEGUARD ENDORSEMENT

LCPS01 0198 STATE AMENDATORY ENDORSEMENT - OHIO

PraNatianattlMqVMwCS CONl14F

IA LawyerCare®Primary Prcfeasional Liability Policy for Lawyers and LawFirms

GENERAL PURPOSE ENI]ORSt»MENT

FIRST NAMED INSURED Jackson Legai'Services, LLC

This endorsement, effective 12:01 A.M. November 01, 2007 forms a part of policy No. OHL0005862•

issued by ProNational Insurance Company.

(The attaching clause needs to be completed only when this endorsement is issued subsequent to the preparatlonof the Policy.)

This poticy shall not apply to claims arising from acts, errors•or omissions In the rendering of or failure to renderprofessional services by the Insureds listed in the schedule below that occurred prior to the Retroactive Dateshown in the scheduie below:

Jackson, Gerald M.

Name Retro Date

All other terms and conditions remaln unchanged.

This endorsement shall not be binding upon the Company unless countersigned by a duly authorized representativeof the Company.

Authorized Representative Date November 26, 2007

LCP200 (1/98) 01998 ProNational Insurance Company

PYoNatipctalfVYI'MAM(,r f41IIMhe

ff LawyerCare M

Yrimary Professional Liabitity Policy for Lawyers and Law Firms

ENTITY EXCLUSION ENDOI2SEMENT

FIRST NAMED INSURED Jackson Legal Services, LLC

This endorsement, effective 12:01 A.M. November 01, 2007 forms a part of policy No, OHL0005352

issued by ProNational Insurance Company,

(The attaching clause needs to be completed only when this endorsement is issued subsequent to the preparation ofthe Policy.)

This policy does not apply to claims made or suits brought by or against:

The Arts Academy

AII other terms and conditions remain unchanged.

This endorsement shall not be binding upon the Company unless countersigned by a duly authorized representativeof the Company.

Authorized Representative Date November 26, 2007

LCP201 (1198) 001898 ProNationat Insurance Company

ProNa.tionalIM4110A9[k (nmppl,l

f^^LawyerCar. e gPrimary Professional Liability Policy for I.awyers and I,aw Finns

EXCLUSION OF ATTORNEYS ENpOItBEMENj

FIRST NAMED INSURED Jackson Le al Services, LLC

This endorsement, effectNe 12:01 A.M. November 01, 2007 forms apart of policy No. OHL0005362

Issued by ProNational Insurance Company.

(The attaching olause needs to be completed only when this endorsement is issued subsequent to the preparation ofthe Policy.)

It is agreed that this policy does not apply to:

Novak, Robinalt & Scharf, LLP

All other terms and conditions remain unchanged.

This endorsement shall not be binding upon the Company unless countersigned by a duly authorized representativeof the Company.

Authorized Representative Date November 26, 2007

LCP204 ( 1198) 01998 ProNational Insurance Company

THE JACKSON LAW COtvtPANY.A LLGAL PROfESSIONALASSOCIATION ♦ AT70RNEYS AND COUNSELORS AT LAW

a AA

July 3, 2007

Mr. R. Schaeffer Greene45497 Delmar DriveMacomb TWP, MI 48044

- EXHIBIT 4

In Re: R. Schaeffer Greene vs. LeJoyce K. Naylor, Cuyahoga County Court ofCommon Pleas - Domestic Relations Division, Case DR 02-290120

Dates DESCRIPTION Time &--_ ....-... .._-..-. __ __ -. Expense

06/06/2003 DOCKET: PLTF'S MOTION TO WITHDRAW AS COUNSEL OF ---_ RECORD FOR PLTF...(W).. JUDITH S HUNT (0023961) 01/11/2006

06/13/2003 COMMUNICATION FROM LE JOYE NAYLOR STATING THAT SHE ---WILL REPRESENT HERSELF IN THIS CASE SINCE SHE CAN NOLONGER AFFORD THE FEES OF MR. AGING........LEJOYCENAYLOR PRO SE.

06/17/2003 DOCKET: BERNARD I. AGIN, ESQ., MAY WITHDRAW AS ---COUNSEL FOR DEFT LEJOYCE K. NAYLOR FOMR THE WIHTINCAPTIONED CASE...OSJ VOL 4152 PG 153 NOTICE ISSUED

07/31/2003 DOCKET: DEFT, LE JOYCE K. NAYLOR MTN FOR PLTF'S ATTY --TO WITHDRAW MS. HUNT, ATTY PRO SE (9999999) 01/11/2006- -- - --08/04/2003 DOCKET JUDGMENT ENTRY. .. MOTION OF JUDITH S. HUNT, ---ESQ., SHALL BE PERMITTED TO WITHDRAW AS COUNSEL FORPLTF RANDOLPH SCHAEFFER GREENE.....EXHIBIT A.....OSJ

--..-..- VOL 4176 PGS 0916-0921...NOTICE ISSUED08/21/2003 DOCKET: CASE REFERRED TO VISITING JUDGE JOSEPH E

CIRIGLIANO BY ADMIN JUDGE TIMOTHY M.FLANAGAN TORESOLVE ALL PENDING ISSUES...OSJ VOL 4185 PG 843NOTICE ISSUED

08/27/2003 DOCKET: SET FOR 09/10/2003 AT 01:30 IN CRTRM 1B BEFORE ---JUDGE JOSEPHE. CIRIGLIANO. 4

%^}S

X

r.-0i

08/00/2003 TELEPHONE CONFERENCE WITH R. SCHAEFFER GREENE; .5REVIEW COURT DOCKET

08/00/2003 TELEPHONE CONFERENCES WITH R. SCHAEFFER GREENE .509/08-10/2003 CLIENT MEETING IN OFFICE TO DISCUSS PENDING CASE, 3.5

SCHEDULED HEARING AND FEES; CLIENT LETTER OFREPRESENTATION; PREPARE CASE SETTLEMENT OUTLINE;ACKNOWLEDGE RECEIPT OF PAYMENTS:FEES EARNED: $625.00FUNDS DEPOSITED IN TRUST: $4,473.75

09/10/2003 COURT APPEARANCE: PREPARED AND FILED PLAINTIFF'S 4.5NOTICE OF APPEARANCE AND ORDER WITH SERVICE ON PROSE DEFENDANT WIFE, REVIEW CASE SETTLEMENTPROPOSALS WITH COURT AND DEFENDANT.

09/12/2003 DRAFT DOCUMENTS; REVIEW FILE; PREPARE AND MAIL 3.0CORRESPONDENCE TO DEFENDANT LAJOYCE NAYLOR IN RE:HER TELEPHONE MESSAGES SENT 9/10/2003, 9/11/2003 AND9/12/2003 REQUESTS FOR DOCUMENTS FROM PLAINTIFF

SCHAEFFER GREENE; TELEPHONE CONFERENCE WITHCLIENT

09/14/2003 TELEPHONE CONFERENCE WITH CLIENT .109/22/2003 FILE REVIEW; DRAFT DOCUMENT(S) : REVIEW MOTION FOR ---

ATTORNEYS FEE S10/0612003 TELEPHONE CONFERENCE WITH CLIENT'S PRIOR COUNSEL 3.5

AND MEETING WITH CLIENT PRIOR COUNSEL AND REVIEWCASE

10/11/2003 TELEPHONE CONFERENCE WITH CLIENT .110/18/2003 TELEPHONE CONFERENCE WITH CLIENT .210/31/2003 TELEPHONE CONFERENCE WITH CLIENT .411/08/2003 TELEPHONE CONFERENCE WITH CLIENT, COMPLETED .2

PARENT EDUCATION SEMINAR11/10/2003 COURT APPEARANCE 9:00AM PRE-TRIAL: 10AM, DEFT & 3.5

COUNSEL NOT PRESENT, PLT AND COUNSEL GO FORCOFFEE, RETURN TO COURT RM, MATTER RESET FOR PRE-TRIAL; MEETING WITH CLIENT.

11/19/2003 - RECEIVE AND REVIEW WITH FILE, ATTY. JOHN FRENDEN 1.5NOTICE OF APPEARANCE, MOTION FOR LEAVE TO FILECOUNTERCLAIM, COUNTERCLAIM FOR DIVORCE; TELEPHONECONFERENCE WITH CLIENT.

11/23/20003 TELEPHONE CONFERENCE WITH CLIENT; PREP FOR 5SETTELEMENT CONFERENCE

11/24/2003 COURT APPEARANCE: ATTY CONF HAD. SETTLEMENT 5.0NEGOTIATIONS; MEETING WITH CLIENT; TELEPHONECONFERENCE WITH CLIENT

11/25/2003 TELEPHONE CONFERENCE WITH CLIENT .211/26/2003 - PREPARE AND FILE DOCUMENTS - PLAINTIFF'S MOTION FOR 3.012/01/2003 TEMPORARY RESTRAINING ORDER, PRELIMINARY

INJUNCTION AND PERMANENT INJUNCTION AND MOTION TOSHOW CAUSE; SEND FACSIMILE SERVICE AND US MAILSERVICE SENTTO ATTORNEY FRENDON.

12/03/2003 RECEIVE AND REVIEW CORRESPONDENCE - ORDER .1DEFENDANT LEJOYCE NAYLOR IS RESTRAINED

12/14/2003 TELEPHONE CONFERENCE WITH CLIENT 312/17/2003 TELEPHONE CONFERENCE WITH CLIENT .112/22/2003 TELEPHONE CONFERENCE WITH CLIENT .112/23/2003 RECEIVE AND REVIEW - JUDGMENT ENTRY MOTION FOR 1.5

RESTRAINING ORDERS GRANTED. PLTF AND NEW PARTYDEFT NATIONAL CITY BANK ARE RESTRAINED FROMWITHDRAWING FUNDS NOW HELD IN ANY SAVINGS ACCOUNTWITH NATIONAL CITY IN THE NAME OF SCHAEFFER GREENEUNTIL FURTHER ORDER (NOT TO RESTRAIN BUSINESSACCOUNTS ; TELEPHONE CONFERENCE WITH CLIENT.

12/27/2003 PREPARE AND SEND FACSIMILE TO ATTORNEY FRENDON. .3

12/28/2003 TELEPHONE CONFERENCE WITH CLIENT 301/30/2004 RESEARCH & REVIEW DRAFTS FOR TRIAL BRIEF, JOINT 2.2

STIPULATIONS AND ALTERNATIVE SETTLEMENT PROPOSALS

2

3673 Lee Road, P. O. Box 202445, Shaker Heights, Ohio 44120-51082(216) 752-8000; H(216) 752-4046 0 E-Mail jlclawni yahoo.com

02I02/2004 FUNDS DEPOSITED IN TRUST: $4,00.00 ---02/17/2004 REVIEW FILE; RECORDS RESEARCH FOR ISSUANCE OF 3.0

SUBPEONA RESEARCH; PREPARE DOCUMENTS: MOTION FORTEMPORARY RESTRAINING ORDER, PRELIMENARY ANDPERMANENT INJUNCTION AND MOTION TO SHOW CAUSE -HARASSING PLT, VIOLATION OF 12/17/2003 ORDER.

02/24/2004 REVIEW FILE; TELEPHONE CONFERENCE WITH CLIENT; 1.5PREPARE DOCUMENTS - SUBPOENA FOR: LUBRIZOLCORPORATION, INTERNATIONAL MANAGEMENT, SPRINT,NEXTEL, VERIZON, SBC AMERITECH, MCI WORLD COM, AT&T,AND ALLTEL.

02/25/2004 TELEPHONE CONFERENCE WITH CLIENT; SUBPOENA FOR: .6ARCHIE GREEN, MANAGER HUMAN RESOURCES, AIR FOILS,INC.; REVIEW DEFT'S MOTION FOR RESTRAINAING ORDERPLTF & DEFT L& L PRODUCTS ONLY

02/25/2004 COURT APPREARANCE - DOCKET SUMMARY. FILE 2.0DOCUMENTS SUBPOENA FOR: LUBRIZOL CORPORATION,INTERNATIONAL MANAGEMENT, SPRINT, NEXTEL, VERIZON,SBC AMERITECH, MCI WORLD COM, AT&T, AND ALLTEL ;REVIEW DOCKET - LEJOYCE K NAYLOR GREENE MOTION FORSUPPORT PENDENTE LITE WITH NOTICE JOHN A FRENDEN;SUBPOENA FOR: ARCHIE GREEN, MANAGER HUMANRESOURCES

02/26/2004 RECEIVE AND REVIEW JUDGMENT ENTRY: MOTION FOR .5RESTRAINING ORDER GRANTED PLAINTIFF IS RESTRAINED &MOTION TO ADD NEW PARTY DEFT GRANTED. L & LPRODUCTS, INC IS ADDED

02/27/2004 CONFIRM LEJOYCE K. NAYLOR GREENE MOTION FOR 2.5CONTINUANCE; TELEPHONE CONFERENCE WITH CLIENT;PREPARE MOTION FOR SHARED PARENTING [NOT FILED -

..... --- _... _ __- -_CLIENT HOLD-------- -------- -- ..-------- - - _ _ _ -_;0212 i/2004 DOCKET: HEARING SET FOR 03/01/2004 AT 09:00 IN CRTRM 1 B

_. _.. .....--

BEFORE JUDGE JOSEPH E. CIRIGLIANO HAS BEENCANCELLED MO.# 122350 FILED ON 01/03/2003 MOTION FORPARTIAL RELEASE OF R.O. MO.# 159003 FILED ON 12/01/2003MOTION FOR PERMANENT INJUNCTION MO.# 159004 FILED ON12/01/2003 MOTION TO SHOW CAUSE NON-COMPLYW/RO&TPO

01/29/2004 TELEPHONE CONFERENCE WITH CLIENT .103/01/2004 DOCKET: CONTESTED TRIAL SET FOR 05/25/2004 AT 09:00 IN --

CRTRM 1 B BEFORE JUDGE JOSEPH E. CIRIGLIANO. MO.#122350 FILED ON 01I03/2003 MOTION FOR PARTIAL RELEASEOF R.O. MO.# 159003 FILED ON 12/01/2003 MOTION FORPERMANENT INJUNCTION MO.# 159004 FILED ON 12/01/2003MOTION TO SHOW CAUSE NON-COMPLY W/RO&TPO MO.#168215 FILED ON 02/27/2004 MOTION FOR PROTECTIVEORDER

03/02/2004 DOCKET: MATTER RESET BEFORE JUDGE CIRIGLIANO ON 5- --25-04 AT 9:00 RM 1-B... VOL 4280 PAGE 453... O.S.J. NOTICE

3

3673 Lee Road, P. O. Box 202445, Shaker Heights, Ohio 44120-5108Y(216) 752-8000; 2(216) 752-4046 0 E-Mail ilclaw(wvahoo.com

ISSUED03/03/04 REVIEW CLIENT FILE WITH CHILD SUPPORT CASE LAW AT 1.2

CLEVELAND LAW LIBRARY03/08/2004 DOCKET: GENERAL HEARING SET FOR 03/23/2004 AT 10:00 IN ---

ROOM 26 BEFORE MAGISTRATE MARIE M. HARTMANN.03/10/2004 PREPARE MOTION FOR TEMPARY CUSTODY [CLIENT-HOLD]; 1.5

PREPARE DRAFT NOTES FOR DISCOVERY, REQUEST FORADDMISSIONS AND PRODUCTION OF DOCUMENTS.

03/16/2004 TELEPHONE CONFERENCE WITH CLIENT AND JOHN 2.0FRENDEN'S OFFICE, PREPARE MOTION FOR CONTINUANCEOF HEARING SCHEDULED FOR MARCH 23, 2004, FAX SERVICETO ATTORNEY FRENDEN AND COPY CLIENT

03/17/2004 DOCKET: DEFT'S MOTIONF OR PROTECTIVE ORDER....(W)... ---JOHN A FRENDEN 0031512 01/11/2006 - UNKNOWN

03/18/2004 TELEPHONE CONFERENCE WITH CLIENT; PREPARE AND FILE .5MOTION FOR CONTINUANCE HEARING ON TEMPORARYSUPPORT AND MAINTENANCE.

03/20/2004 TELEPHONE CONFERENCE WITH CLIENT .103/23/2004 PREPARE AND FILE DOCUMENTS: PLAINTIFF'S MOTION TO 1.5

STRIKE DEFENDANT NAYLOR'S MOTION FOR PROTECTIVEORDER FILED MARCH 17,2004 AND MOTION TO CORRECT THERECORD OF PLAINTIFF'S PRIOR MOTION FOR CONTINUANCEOF SUPPORT HEARING (3123/2004); TELEPHONE CONFERENCEWITH CLIENT; PREPARE AND SENT LETTER VIA FACSIMILE TOATTORNEY FRENDON; PREPARE AND SEND E-MAIL TOCLIENT; RECEIVE AND REVIEW CLIENT'S E-MAILCORRESPONDENCE REGARDING THREATS AND RESPONSETO DEFENDANT'S MOTIONS

03124/2004 RECEIVE AND REVIEW E-MA1L COPY OF E-MAIL SENT TO 1.0CLIENT FROM DEFT WIFE - HIS DRUG PROBLEM AND STATINGCLIENT WANTS TO GO TO TRIAL AND NOT SETTLE ANDCLIENT'S E-MAIL TO DEFT WIFE DENYING DRUG PROBLEMETC; TELEPHONE CONFERENCE WITH CLIENT.

03/23/2004 DOCKET: GENERAL HEARING SET FOR 04/06/2004 AT 10 00 INROOM 26 BEFORE MAGISTRATE MARIE M. HARTMANN.

03/2512004 RECEIVE E-MAIL FROM J. NAYLOR .103/26/2004 REVIEW CHILD SUPPORT GUIDELINES & VISITATION

GUILDLINES RELATIVE TO CASE.03/29/2004 TELEPHONE CALL AND LETTER TO ATTORNEY FRENDEN'S .5

OFFICE REFERENCING PRIOR TELEPHONE CALLS TO HIMREQUESTING TIME TO SCHEDULE HIS CLIENT'S DEPOSITION.

03/30-31/2004 TELEPHONE CONFERENCE WITH CLIENT AND ATTY 1.0FRENDON, PREPARE AND FILE DOCUMENTS 03/31/30: MOTIONFOR CONTINUANCE; SCHAEFFER GREENE MOTION FORCONTINUANCE OF APRIL 6, 2004 GENERAL HEARING BEFOREMAGISTRATE HARTMAN, PLT TRAVELING OUTSIDE OF US FORWORK ENTIRE WEEK OF MARCH 29, 2004, SERVICE TO DEFT'SATTY VIA FAXON TEMPORARY SUPPORT AND MAINTENANCE.

04/01/2004 TELEPHONE WITH COURT/CLERK, PLT MOTION TO CON'T .1

4

3673 Lee Road, P. 0. Box 202445, Shaker Heights, Ohio 44120-5108`'(216) 752-8000; ®(216) 752-4046 0 E-Mail ilclaw@yahoo.com

04106/04 HEARING GRANTED; RESCHEDULED 04/20/2004.04/01/2004 DOCKET: HEARING SET FOR 05/25/2004 AT 09:00 IN CRTRM 1 B

BEFORE JUDGE JOSEPH E. CIRIGLIANO HAS BEENCANCELLED

04/01/2004 DOCKET: CONTESTED TRIAL SET FOR 07102/2004 AT 0900 INCRTRM 1B BEFORE JUDGE JOSEPH E. CIRIGLIANO.

04/02/2004 DOCKET: LEJOYCE K. NAYLOR GREENE MOTION FOR __CONTINUANCE HEARING ON TEMPORARY SUPPORT ANDMAINTENANCE JOHN A FRENDEN. [NO SERVICE RECEIVED?]

04/04/2004 TELEPHONE CONFERENCE WITH CLIENT .104/05/2004 DOCKET: HEARING SET FOR 04/06/2004 AT 10:00 IN ROOM 26 ---

BEFORE MAGISTRATE MARIE M. HARTMANN HAS BEENCANCELLE

04/05/2004 DOCKET: GENERAL HEARING SET FOR 04/20/2004 AT 1045 INROOM 26 BEFORE MAGISTRATE MARIE M. HARTMANN.

04/05/2004 TELEPHONE CONFERENCE WITH CLIENT 304/06/2004 DOCKET: JUDGMENT ENTRY...MAGISTRATE'S __

ORDER....MATTER RESET TO APRIL 20 2004.......OSJ VOL 4298

----PG 0362... NOTICE ISSUED

04J08/2004 - -RECEIVE AND REVIEW E-MAIL FROM CLIENT. 104/09/2004 TELEPHONE CONFERENCE WITH CLIENT; REVIEW FILE; 5

RECEIVE AND REVIEW DOCUMENTS SENT BY CLIENT.REGARDING UPDATES IN CASE INFORMATION AND MOTIONFOR TEMPORARY CUSTODY

04/10/2004 RECEIVE AND REVIEW: DEFENDANT'S ANSWER, AFFIDAVIT OF 1.5RESIDENTIAL PARENT; DRAFT DOCUMENTS: MOTION FORTEMPORARY CUSTODY, ANSWER OF DEFENDANT; RECEIVEAND REVIEW DOCUMENTS SENT VIA CLIENT - INCOME &EXPENSES; TELEPHONE CONFERENCE WITH CLIENT

04/13/2004 DOCKET: HEARING SET FOR 04/20/2004 AT 10:45 IN ROOM 26BEFORE MAGISTRATE MARIE M. HARTMANN HAS BEENCANCELLE

04/13/2004 DOCKET: GENERAL HEARING SET FOR 05/04/2004 AT 10:00 IN

----- ROOM 26 BEFORE MAGISTRATE MARIE M. HARTMANN.04/13/2004 DOCKET: JUDGMENT ENTRY......DEFT'S MOTION TO CONTINUE

GRANTED...MATTER RESET TO MAY 4 2004 AT 10 AM RM26...OSJ VOL 4301 PG 0771...NOTICE ISSUED.

04/15/2004 TELEPHONE CONFERENCE WITH CLIENT .404/16/2004 PREPARE SECOND MOTION FOR TEMPORARY RESTRAINING 2.0

ORDER, INJUNCTIVE RELIEF AND MOTION TO SHOW CAUSE[NOT FILED], AFFIDAVIT TO RELEASE FUNDS AND MOTIONFOR TEMPORARY RESTRAIING ORDER.

04/20/2004 TELEPHONE CONFERENCE WITH CLIENT .104/23/2004 TELEPHONE CONFERENCE WITH CLIENT ,105/01/2004 RETURN CLIENT TELEPHONE CALLS .205/03/2004 RECEIVE AND REVIEW E-MAIL FROM CLIENT - FORWARDED E- .4

MAIL OF DEFT WIFE, RE: JUSTIN ATTENDING SPACE CAMPAND WISHING CLIENT AND BRENDA WELL AT THE PLAY-OFFGAME, RETURN CLIENT TELEPHONE CALLS

3673 Lee Road, P. O. Box 202445, Shaker Heights, Ohio 44120-51082(216) 752-8000; 2(216) 752-4046 0 E-Mail ilclaw@cYahoo.com

05/04/2004 RETURN CLIENT TELEPHONE CALLS .205/07/2004 DOCKET: GENERAL HEARING SET FOR 05/18/2004 AT 10:45 IN --

ROOM 26 BEFORE MAGISTRATE MARIE M. HARTMANN.05/08/2004 REVIEW PORTIONS OF IRS PUBLICATION 504 [DIVORCE AND 1.5

SEPARATION WITH CLIENT FILE.05/14/2004 RETURN CLIENT TELEPHONE CALLS, AFFIDAVIT FOR MOTION .2

ON SUPPORT, DISCUSS INCOME & EXPENSE DATA5/17-18/2004 PREPARE DOCUMENTS: MOTION FOR SUPPORT PENDENTE; 3.0

RECEIVE AND REVIEW DOCUMENTS SENT FAXED VIA CLIENT- RELEASE OF FUNDS, INCOME & EXPENSE MODIFICATIONS,AND FINANCIAL DISCLOSURES, DISCUSS FACSIMILES [5/17] -SEVEN AND TWENTY PAGES FOR MOTION PREPARATION;FIRST DRAFT-FIRST REQUEST FOR PRODUCION OFDOCUMENTS.

05/19/2004 FILE SCHAEFFER GREENE ANSWER TO MOTION FOR 1.5SUPPORT PENDNETE LITE WITH AFFIDAVIT ATTACHED,SERVICE ON DEFT ATTY FRENDON.

05/19/2004 DOCKET: GENERAL HEARING SET FOR 06/08/2004 AT 10:00 IN_

ROOM 26 BEFORE MAGISTRATE MARIE M. HARTMANN.05/19/2004

__DOCKET: GENERAL HEARING SET FOR 06/08/2004 AT 10 00 INROOM 26 BEFORE MAGISTRATE MARIE M. HARTMANN.

05/25/2004 JOURNAL ENTRY IN FILE, MATTER RESET BEFORE JUDGECIRIGLIANO ON MAY 25, 2004 AT 9:00, RM 1-B

05/27/2004 TELEPHONE CONFERENCE WITH CLIENT .205/29/2004 RETURN CLIENT TELEPHONE CALLS .106/01-03/2004 RECEIVE AND REVIEW E-MAIL FROM CLIENT, AFFIDAVIT IN 1.5

THE MAIL, RETURN E-MAIL REGARDING THIRD FEDERAL S & LMTG; PREPARE AND FILE (06/03/2004) SCHAEFFER GREENEMOTION FOR CONTINAUANCE OF HEARING ON TEMPORARYSUPPORT AND MAINTENANCE SCHEDULED BEFOREMAGISTRATE HARTMAN FOR JUNE 8, 2004; PREPARE ANDSEND E-MAIL MEMO TO CLIENT REGARDING FILINGADDITIONAL DOCUMENTS; SERVICE ON DEFT ATTY06/01/2004.

--06/04/2004 -- --------- -- -RETURN CLIENT TELEPHONE CALLS06/07/2004 DOCKET: LEJOYCE K. NAYLOR GREENE MOTION TO RELEASE

AND DISTRIBUTE MARITAL FUNDS JOHN A FRENDEN 003151201/11/2006 - UNKNOWN

06/07/2004 TELEPHONE CONFERENCE WITH JUDGE'S SCHEDULER, MOT 8.0OF PLT FOR CONTINUANCE OF JUNE 8, 2004 HEARINGDENIED, HEARING TO GO FORWARD; TELEPHONECONFERENCE AND MEETING WITH CLIENT; PREPARE PLTMOTION TO ADD LUBRIZOL AS PARTY; PLT MOTION TORELEASE TRO ON WAGES WITH AFFIDAVIT, MOTION TORELEASE THE SUBPOENA OF PHONE RECORDS; SCHAEFFERGREENE MOTION TO RELEASE TEMPORARY RESTRAININGORDER ON WAGES; SCHAEFFER GREENE MOTION TORELEASE TEMPORARY; TRO ON WAGES

06/08/2004 COURT APPEARANCE: FILE SCHAEFFER GREENE MOTION TO 4.5

6

3673 Lee Road, P. O. Box 202445, Shaker Heights, Ohio 44120-5108B►'(216) 752-8000; 2(216) 752-4046 0 E-Mail jlclawnyahoo.com

ADD LUBRIZOL AS PARTY; MOTION TO RELEASE TRO ON THESUBPOENA OF PHONE RECORDS; SCHAEFFER GREENEMOTION TO RELEASE TEMPORARY RESTRAINING ORDER ONWAGES; SCHAEFFER GREENE MOTION TO RELEASETEMPORARY; TRO ON WAGES; RECEIVE AND REVIEWLEJOYCE K. NAYLOR GREENE OBJECTIONS TO MOTION FORCONTINUANCE; LEJOYCE K. NAYLOR GREENE MOTION TORELEASE AND DISTRIBUTE MARITAL FUNDS; ATTORNYCONFERENCE ON MOTION FOR TEMPORARY SPOUSAL ANDCHILD SUPPOT RECEIVE TELEPHONE MESSAGE FROM R.SCHAEFFER GREENE; E-MAIL FROM CLIENT.

06/17/2004 DOCKET: MAGISTRATE'S TEMPORARY ORDERES UNDER CIVILRULE 75 (N) ...DEFT'S MTN FOR SUPPORT PENDENTE LITE#168818 IS GRANTED... COSTS PASSED TO FINAL HRG... O.S.J.VOL 4336 PAGE 780-791... NOTICE ISSUED

06/17/2004 RETURN TELEPHONE CALLS OF CLIENT. 206/17/2004 DOCKET: GENERAL HEARING SET FOR 06/2112004 AT 03:30 IN --

CRTRM 1B BEFORE JUDGE JOSEPH.E. CIRIGLIANO.06/18/2004 DOCKET: LEJOYCE K. NAYLOR GREENE ADDENDUM TO DEFTS

RESPONSE TO PLTF'S MOTION TO RELEASE FUNDS .............JOHN A FRENDEN 0031512

06/18/2004__

RETURN TELEPHONE CALLS OF CLIENT, RECEIVE AND 2REVIEW CLIENT FAX

06/19/2004 RETURN TELEPHONE CALLS OF CLIENT. ,206/21-22l2004 COURT APP EARANC E:TELE PHONE CONFERENCE WITH 3.0

CLIENT; RECEIVE, REVIEW AND RESPOND TO CLIENT'S E-MAILREGARDING TEMPORARY ORDER, HELP ON THE HOUSE;COURT APPEARANCE SCHEDULED FOR 6/22/2004; RECEIVEAND REVIEW CLIENT'S FACSIMILE IN RE ADDITIONALSUPPORTIVE DOCUMENTATION FOR TOMMORROW'S

- - _ -HEARING; AND HIS CASE NOTES.

---06l00-00/2004 -------------- - --MEETINGS WITH CLIENT IN CLEVELAND;TELEPHONE 4_0_CONFERENCES WITH CLIENT, ATTORNEYS PHYLLIS BROOKS,CHERYL A. FLETCHER, JOYCE BARRETT AND ANDREW A.ZASHIN; TELEPHONE CONFERENCE WITH CLIENT AND L & LINDUSTRIES CEO - CLAUDE.

.06/23/2004 RECEIVE TELEPHONE MESSAGE FROM R. SCHAEFFER 1.3GREENE; RETURN TELEPHONE CALL AND LEFT DETAILEDMESSAGE; REVIEWED LAW ON SUPPORT, MAINTENANCE ANDJUDICIAL DISCRETION

06/24/2004 RETURN TELEPHONE CALLS OF CLIENT 5. .606/25/2004 RECEIVE AND REVIEW DEFT ADDENDUM TO DEFT REPONSE .2

TO PLAINTIFF'S MOTION TO RELEASE FUNDS.06/25/2004 DOCKET: NUNC PRO TUNC MAGISTRATE'S TEMPORARY ---

ORDER UNDER CIVIL RULE 75(N)...COSTS PASSED TO FINALHRG.-.(SEE JOURNAL)... VOL 4341 PAGE 242-249... O.S.J.NOTICE ISSUED

06/2812004 RETURN TELEPHONE CALLS OF CLIENT. .206/29/2004 PREPARE, FILE AND SERVE ATTORNEY FRENDON 1.7

7

3673 Lee Road, P. 0. Box 202445, Shaker Heights, Ohio 44120-5108W(216) 752-8000; R(216) 752-4046 0 E-Mail jlclaw(a?yahoo.com

REGARDING MOTION TO RELEASE TRO - SUBPEONA PHONERECORDS AND MOTION TO STRIKE; RECEIVE AND REVIEWBILLING FOR LEGAL RESEARCH FROM CLEVELAND LAWLIBRARY SEE SUMMARY OF EXPENSES),

06/29/2004 RECEIVE AND REVIEW CORRESPONDENCE FROM CLIENTREQUESTING TERMINATION OF LEGAL SERVICES FROMJACKSON LAW COMPANY LPA; DRAFT AND FILE MOTION TOWITHDRAW AS COUNSEL OF RECORD WITH SERVICE TO ATTYAND R. SCHAEFFER GREENE.

06/30/2004 RECEIVE AND REVIEW ADDENDUM TO DEFT RESPONSE T PLTMOT TO RELEASE FUNDS, PREPARE AND FILE MOTION TOSTRIKE DEFTS. "ADDENDUM TO DEFENDANTS. RESPONSE TOPTLFS. MOTION TO RELEASE FUNDS"; NOTICE OF DISCHARGE& WITHDRAWL AS COUNSEL & SCHAEFFER GREENE MOTIONTO STRIKE DEFENDANTS. NAYLOR'S MOTION FORPROTECTIVE ORDER FILED MARCH 17, 2004, set for 070204;RETURN TELEPHONE CALLS OF CLIENT.

--..66130/---2004 -OC -KET:C---------- -- -- AT 09 00 -I ND ONTESTED TRIAL SET FOR OS/23l2004CRTRM 1B BEFORE JUDGE JOSEPH E. CIRIGLIANO.

07/01/2004 COURT ORDER - VOL 4344 PG 0333 - "NOTICE OF DISCHARGEOF COUNSEL HAVING BEEN RECEIVED BY PLAINTIFF'SCOUNSEL TOGETHER WITH A MOTION FOR TO CONTINUEHEARING ON JULY 2, 2004 AT 9:00 A.M. AND FOR GOOD CAUSESHOWN, THE WITHIN SHALL BE RESCHEDULED FOR HEARINGAUGUST 23, 2004 AT 9:00 AM, NO FURTHER CONTINUANCES."

07/02/2004 MEETING WITH ATTY PHYLLIS BROOKS, DELIVER PLT FILES(2.0 HOURS)

07/02/2004 EXCHANGE E-MAIL WITH R. SCHAEFFER GREENEREGARDING, MATERIAL ON PRIVATE TUITION ISSUES FORTHE PARTIES CHILDREN; RECEIVE AND REVIEWCORRESPONDENCE FROM CUYAHOGA COUNTY COURT OFCOMMON PLEAS REGARDING DEFENDANT'S MOTION FORRECONSIDERATION; MATTER RESET FOR AUGUST 23, 2004

07/07/2004_

DOCKET: LEJOYCE K. NAYLOR GREENE MOTION FORRECONSIDERATION JOHN A FRENDEN 0031512 01111/2006 -SERVICE SHOWN TO GERALD M. JACKSON

07/09/2004 TELEPHONE CONFERENCE AND REVIEW OF E-MAIL FORATTORNEY CHERYL A. FLETCHER, OF DYKEMA GOSSETTPLLC, DETROIT, MI., MOTIONS, CERTIFICATION AND ORDERFOR APPEARANCE PRO HAC VICE; TELEPHONE CALL TO ATTYPHYLLIS BROOKS, DELIVER E-MAIL TO OFFICE OF ATTYPHYLLIS BROOKS. 1.5 HOURS

08104/2004 RECEIVE E-MAIL FROM CHERYL FLETCHER, ESQ. REGARDINGAPPEARANCE WITH PHYLLIS BROOKS ASSISTANCE;TELEPHONE CALL TO PHYLLIS BROOKS

08/05/2004 RECEIVE AND RETURN TELEPHONE CALL VIA RESIDENTIALPHONE FROM R. SCHAEFFER GREENE (0.1 HOURS

8

3673 Lee Road, P. O. Box 202445, Shaker Heights, Ohio 44120-5108W(216) 752-8000; 2(216) 752-4046 0 E-Mail jlclaw(lyahoo.com

08/06/2004 DOCKET: SCHAEFFER GREENE NOTICE OF APPEARANCE.PHYLLIS BROOKS 0015199

08/10/2004 RECEIVE AND RETURN TELEPHONE CALL VIA RESIDENTIALPHONE TO R. SCHAEFFER GREENE. (0.1 HOURS )

08110/2004 COURT FILE: MOTION FOR ADMISSION PRO HAC VICE FILEDBY L & L PRODUCTS, INC. VIA ATTYS. ERIC B. LEVASSEUR OFHAHN LOESER & PARKS LLP AND CHERYL A. FLETCHER OFDYKEMA GOSSETT PLLC OF DETROIT, MI

08/11/2004 DOCKET: JUDGMENT ENTRY ORDER GRANTING MOTION FORPRO HAC VICE ADMISSION OF CHERYL A. FLETCHER......L&L'SMOTION GRANTED AND MRS CHERYL A. FLETCHER ISALLOWED TO PRACTICE RELATING TO THIS ACTION...OSJ VOL4364 PG 0442....NOTICE ISSUED

08/11/2004_

RECEIVE AND RETURN TELEPHONE CALLS FROM R.SCHAEFFER GREENE (0.2 HOURS )

08/19/2004 RECEIVE AND RETURN TELEPHONE CALLS FROM R.SCHAEFFER GREENE (0.2 HOURS

08/23/2004 RECEIVE AND RETURN TELEPHONE CALLS FROM R. --SCHAEFFER GREENE 0. 2 HOURS

-- -^-08/24/2004 RECEIVE CC OF E-MAIL SENT BY R. SCHAEFFER GREENE TOPHYLLIS BROOKS, MONEY OWED TO IRS, TEMPORARYORDER,DYKEMA GOSSETT'S APPEARANCE 0.2( HOURS) ___

08/30/2004 R. SCHAEFFER GREENE E-MAIL TO PHYLLIS BROOKS;TELEPHONE CALL TO PHYLLIS BROOKS (0.1 HOURS )

09/03/2004 RECEIVE AND RETURN TELEPHONE CALLS FROM R.SCHAEFFER GREENE; RECEIVE COPY OF E-MAIL SENT TOPHYLLIS BROOKS (0.3 HOURS )

09/07/2004 EXCHANGE E-MAIL TO PHYLLIS BROOKS AND R. SCHAEFFERGREENE REGARDING SCHAEFFER GREENE FILE; RECEIVE E-MAIL RELATIVE TO GREENE HIRING MARY A. RABIN;TELEPHONE CONFERENCE WITH MARY A. RABIN OFFICE ANDSEND EMAIL THAT RABIN AND RABIN NOT AVAILABLITY TOSERVE AS COUNSEL. (0.5 HOURS)_

09/07/20D4 TELEPHONE CONFERENCE WITH JOYCE E. BARRETTRELATIVE TO REPRESENTATION OF R. SCHAEFFER GREENE0.2 HOURS )

09/08/2004 RECEIVE AND RETURN TELEPHONE CALLS FROM R.SCHAEFFER GREENE (0.2 HOURS )

09/09/2004 RECEIVE AND RETURN TELEPHONE CALLS FROM R.SCHAEFFER GREENE (0.2 HOURS)

09/1312004 DOCKET: SCHAEFFER GREENE ENTRY OF APPEARANCE.JOYCE E BARRETT

09/13/2004 DOCKET: SCHAEFFER GREENE REQUEST FOR ORAL HEARINGJOYCE E BARRETT

10/27/2004 RECEIVE AND RETURN TELEPHONE CALL VIA BUSINESSCELLULAR PHONE FROM R. SCHAEFFER GREENE (0.2HOURS )

12/06/2004 RECEIVE AND RETURN TELEPHONE CALLS FROM R.SCHAEFFER GREENE (0.2 HOURS )

10/14/2005 RECEIVE AND RETURN. TELEPHONE CALLS FROM R.

9

3673 Lee Road, P. O. Box 202445, Shaker Heights, Ohio 44120-5108W(216) 752-8000; 2(216) 752-4046 0 E-Mail ilelaw@yahoo.com

SCHAEFFER GREENE 0.2 HOURS

Subtotal Billable Hours Logged above: 94.9 HoursBillable Hours Not Logged above: Four 2Hr. meetings atBob Evans, Mayfield and Rt. 271 and one 2 Hr. meetingat Greene hotel conference room, Mayfield and Rt. 271 -10 Hours.

Total Hours: 104.9 @$225.00 per hour rate $23.602.50

Credit Courtesy & PromotionPayment(s) Client payment(s) *:

09/08-10/2003, $625.00 and $4,473.75 ( $5,098.75)02/02/2004, $4,000.00 ( $4,000.00)

Balance Please remit balanceDue--- -

* Receipts Verified as of July 3, 2007; accordingly, funds credited to this accountmay increased upon receipt of additional bank verifications.

10

3673 Lee Road, P. O. Box 202445, Shaker Heights, Ohio 44120-5108W(216) 752-8000; ®(216) 752-4046 0 E-Mail jlclawnyahoo.com

Yahoo! Mail -jlclaw@yahoo.conl Page 1 of 1

Ijq.140o,r MAIL

Date: Fri, 21 Sep 2007 11:19:29 -0700 (PDT)

From: jlclaw@yahoo.coni

Subject: Case #07-27 R. Schaeffer Greene vs. Gerald Jackson, Esquire

To: "Laurence A. Turbow" <turbowla@yahoo.corn>

Atty. Turbow,

I am writing you to provide you with additional accounting information relative to the above referenced matter.

National City Bank has provided detailed deposit information which is listed below for funds received from R.Schaeffer Greene from September 2003 through February 2004, totaling $13,098.75.

. Sept 08, 2003 - R. Schaeffer Greene, [ck #1354 National City] $ 625.00 - deposited into National CityJackson Law Co, LPA - Business Operating Acct #2335517;

Sept 10, 2003 - R. Schaeffer Greene, [ck #1358 National City] $4,473.75 - deposited into National CityBank, Jackson Law Co, LPA - lolta Trost Acct #2335402;

Jan 30, 2004 - R. Schaeffer Greene, [ck #1396 National City] $4,000.00 -deposited into National CityBank: Jackson Law Co, LPA - lolta Trust Acct #2335402;

Feb 02, 2004 - R. Schaeffer Greene, $4,000.00 - deposited into National City Bank: Jackson Law Co, LPA -Business Operating Acct #2335402.

Should you need any additional information please advise.

Kind professional regards,

Gerald M. Jackson

EXHIBIT 5

http://us.f541.mail.yahoo.com/ym/ShowLetter?box=Draft&Msgld=8769_0_ 17913_521 _5... 12/4/2007

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IRVING TREIBATCH1/2 01.7512 1120030909 0115594919+ 0000006250020080107660687 WS:MD14 OPR:MD3XIXTA3K JOBN7136

SHAKER TOWNE CTR/LEE-CHAGLOCATOR #8280CLEVELAND,OH

EXHIBIT 6

THE,IACKS9N LAW COMPANY L.P.A.kITCRNEVB AIIO COUSSELORS Ar I.Aw

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IRVING TREIBATCH112 017812 1120030909 0115594919+ 0000006250020080107660687 WS:MD14 OPR:MD3XIXTA3K JOBN7136

SHAKER TOWNE CTR/LEE-CHAGLOCATOR #8280CLEVELAND, OH

2/6 017613 11 n?20030911 0115176586+ 0000044737820070625660972 WS:MD15 OPR:LH3XIXTA3K JOBNCB4471

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IRVING TREIBATCH6/6 012188 1120040202 0116864085+ 0000040000020070625660972 WS:MD12 OPR:CB3XIXTA3K JOBNCB4458

SHAKER TOWNE CTR/LEE-CHAGLOCATOR #8280CLEVELAND, OH

(0

1SryM;1.*^'rriTiJiN:(?}Y.Ylirlh^if.q74M/v11f:^5/^N!M.141.yAJYfiiitl^lC(^PT'.Ul:H!/Alq

'.R. SCIIAEFFER CREEN[i 07N9: 399 L'pvrfelt L.n ':: I:, HfJldnu! Iigto; OH344143

:.404L()f]O4 24t' 53801033L0 L376 ,'00004000001'"^l^I,^AWt,J..^r.WGIW.{^:iry9f0. il:{ia:f%f::J17i:x:J'Jy:s,Y:i'^uCf.fil:in.tta^Ca•Ail'.1i:qK^^1:.+rtNAIISiKilsJ

IRVING TREIBATCH6!6 012188 1120040202 0116864085+ 0000040000020070625660972 WS:MD12 OPR:CB3XIXTA3K JOBNCB4458

LOCATOR TOWNE CTR/LEE-CHAG

CLEVELAND, OH

NOTICE TO CLIENT

Pursuant to Rule 1.4 of the Ohio Rules of Professional Conduct, I am required to notifyyou that I do not maintain professional liability (malpractice) insurance of at least$104,000 per occutrer,teqand $300,000 in the aggregate, applicable to your matter.

eralH"M. Jackson

CLIENT ACKNOWLEDGEMENT

I acknowledge receipt of the notice required by Rule 1.4 of the Ohio Rules ofPi-ofessional Conduct Ihat Gerald M. Jackson does not maintain professional liabilily(malpractice) insurance of at least $100,000 per occurrence and $300,000 in theaggregate, applicable to my matter.

nt's Signature

Date

EXHIBIT 7

NOTICE TO CLIENT

Pursuant to Rtile 1.4 of the Ohio Rules of Professional Conduct, I am required to notifyyou that I do not maintain professional liability (malpractice) insurance of at least$100,000 per occur^eqce and $300,000 in the aggregate, applicable to your matter.

CLIEN'I' ACKNOWLEDGEMENT

I acknowledge receipt of the notice required by Rule 1.4 of the Ohio Rules ofProfessional Conduct that Gerald M. Jackson (loes not maintain professional liability

^(malpractic ) insurance of at least $100,000 per occurrence and $300,000 in thegregate, a lipable to my matter.

^^^ /^lafQlrZ/^.C?2.1DtiI

u l' /li ' ^ L ^ ^c ^2S/^/^C nt s Signature

y k^Date

NOTICE TO CLIENT

Pursuant to Rule 1.4 of the Ohio Rules of Professional Conduct, I am reqttired to notifyyou that I do not maintain professional liability (malpractice) insurance of at least$100,000 per occurrence and $300,000 in the aggregate, applicable to your matter.

CLIENT ACKNOWLEDGEMENT

I acknowledge receipt of the notice required by Rule 1.4 of the Ohio Rules ofProfessional Conduct that (ierald M. Jackson does not maintain protessional liability(malpractiFe) insurance of at least $ 100,000 per occurrence and $300,000 in theaggregate, aNplicAble to my matter.

/'99dza77e AALClient's Signature

HhloeDate

NOTICE TO CLIENT

Pursuant to Rule 1.4 of the Ohio Rules of Professional Conduct, I am required to notifyyou that I do not maintain professional liability (malpractice) insurance of at least$100,000 per occttMnce and $300,000 in the aggregate, applicable to your matter.

CLIENT ACKNOWLEDGEMENT

I acknowledge receipt of the notice required by Rule 1.4 of the Ohio Rules ofProfessional C'onduct that (;eraid NI. J ackson does not maintain professional liability(malpractice) insurance of at least $100,000 per occurrence and $300,000 in theaggregate, applicable to my matter.

l %GO ^___ '7,7•Client's Signature

i5;12-e--e v

VIRGIL E. BROWN, JR.ATTORNEY AT LAW2136 NOBLE ROAD

CLEVELAND, OHIO 44112(216) 851-3304

FAX (216) 851-2900

May 2, 2008

Mr. Richard C. Alkire, Esq.Richard C. Alkire, Co., L.P.A.250 Spectrum Office Building6060 Rockside Woods BoulevardIndependence, Ohio 44131-2335

Re: Gerald Jackson, Esq.Case 08-006

Dear Mr. Alkire:

This letter is written to give you, and other interestedparties, my personal opinion of Attorney Gerald Jackson.

I have known Mr. Jackson for well over 20 years. I have hadthe opportunity to work with him on many legal matters,community events and various committees and projects. Hehas always been very professional and shown himself to be acredit to the Bar.

I have referred clients to him and would do so again in thefuture. I have personal knowledge that he is a good lawyerand an honest individual.

He deserves kind and understanding consideration in thismatter.

Please let me know if you have any questions.

S

^

VilfgilJ)%. Brown, Jr.VEB:s

EXHIBIT 8

Willie Mitchell^ ^ ^ ^ ^ ^ ^ ® 6000 Bear Creek Drive

^ tc m Apt 323MAY 6 Bedford Heights, Ohio 44146

May 5, 2008

ALKIRE

Richard C. Alkire, Esq.Richard C. Alkire, Co., L.P.A.250 Spectrum Office Building6060 Rockside Woods BoulevardIndependence, Ohio 44131-2335

RE: Cuyahoga County Bar Association vs. Gerald M. Jackson, Before the Board ofCommissioners on Grievance and Discipline, of the Supreme Court of Ohio, Case No.08-006.

Dear Mr. Alkire:

I am cun•ently an assistant prosecuting attorney for the Cuyahoga CountyProsecutors office. I met Mr. Jackson approximately ten yours ago while I was anassistant director of law for the City ofCleveland law deparhnent. Although he was theopposing attomey for a very contentious case, Mr. Jackson maintained professionalismduring the entire process. Since that first encounter Mr. Jackson has been a positive rolemodel and mentor to me.

I have completed many civil research projects for Mr. Jackson, during which timeMr. Jackson always encouraged and stressed that high quality and proficient work productbe accompanied with ethics and professionalism. Consequently, I was very surprised tolearn that Mr. Jackson may not have always maintained professional liability insurance.Knowing the positive character of Mr. Jackson I immediately thought that there musthave been some kind of nustake or oversight on Mr. Jackson's part. Mr. Jackson is astrong advocate of always following the rules to protect the client and to protect self.Notwithstanding his oversight regarding the professional liability insuranoe issue, I wouldnot hesitate to retain Mr. Jackson for legal work.

Thank you,

^U W,

Willie Mitchell216-926-3357

NOVAK ROBENALT & PAVLIK L.L.P.Attorneys at LawTower City Center Phone 216.781.8700

Skylight Office Tower - Suite 950 FacSimiie 216.781.9227

1660 West Second Street Direct Dial 216.348.8540

Cleveland, Ohio 44113-1498 E-Mail trobenalt@nrplaw.com

www.nrplaw.com

May 2, 2008

Via Fax ( 216) 674-0104 and Regular U.S. Mail

Richard C. Alkire, Esq.Richard C. Alkire Co., LPA250 Spectrum Office Building6060 Rockside Woods Blvd.Independence, OH 44131-2335

RE: Cuyahoga County Bar Association v. Gerald M. Jackson, Before the Board ofCommissioners on Grievance and Discipline, of The Supreme Court of Ohio,Case No. 08-006

Dear Mr. Alkire:

The purpose of my letter is to provide a character reference for Gerald M. Jackson as it relatesto the above-referenced grievance. I was first introduced to Mr. Jackson over eleven years agowhen I joined the firm of Rubensteln, Novak, Einbund and Pavlik as an associate. Mr. Jackson,at the time I joined the firm, had referred several active civil litigation matters wherein our firmsworked together as co-counsel.

After I became a partner in the law firm, which is now known as Novak, Robenalt & Pavlik LLP,in the year 2000, I worked more closely with Mr. Jackson as co-counsel on several civil matters.In my personal experience with Mr. Jackson, he has always been very responsive to clientrequests and attentive to client matters. Mr. Jackson's rapport with clients has also beenexcellent. As an example, in the most recent wrongful death claim that we worked on together,Mr. Jackson worked very well with the clients and his efforts proved instrumental as it relates tothe successful resolution of the matter.

Mr. Jackson has always, in my opinion, been a man of his word. When he tells you he will .perform a task, the task is always completed. We have investigated several potential mattersover the years and even though no fees were generated pursuant to a contingency fee contract,he has always demonstrated a willingness to do what was best for those clients and protect theclients' interests at any cost.

Richard C. Alkire. Esq.May 2, 2008Page 2

Although I don't know the exact circumstances that led to the filing of a grievance against Mr.Jackson, I know that he has recently obtained professional liability insurance as it relates to hispractice and that he deeply regrets his inattentiveness to this particular client. In my opinion,based on my discussions with Mr. Jackson, these were isolated incidents and he will endeavorin the future not to let this happen again.

It is my hope the Commissioners will also consider Mr. Jackson's excellent reputation in thecommunity, his public service and charitable endeavors when they hear this case.

Please call should you need any further information.

RespgctfaHq,

Thomas D. Robenalt

TDR:jis

BEFORE THE BOARD OF COMMISSIONERSON GRIEVANCES AND DISCIPLINE OF

THE SUPREME COURT OF OHIO

IN RE:

Complaint against

Gerald M. Jackson,

Respondent,

Case No. 08-006

Affidavit of Respondent

Cuyahoga County Bar Association,

Relator.

SS:

^N

Affiant, having personal knowledge of the following and competent to testify

thereto, having been duly sworn, deposes and says that:

1) He is the Respondent in the Complaint brought against him by the

N' Cuyahoga County Bar Association, Case No. 08-006.0NN

2) He was admitted to the bar of the State of Ohio on May 6, 1972.

3) He has never been the subject of a discipline proceeding prior to the one

asserted in the aforementioned Complaint.

4) He is and has been engaged in the general practice of law, including

representing small business organizations, simple estate matters and non-profit

business organizations, with a small amount of domestic relations work.

5) He admits to having committed a violation of DR 9-102(B)(3) (he failed to_

maintain complete records of all funds...of a client coming into the possession of the

lawyer and render appropriate accounts to his client regarding them.)

6) He admits to having committed a violation of DR 1-104(A) & (B) (he failed

to inform the client at the time of the client's engagement that he did not maintain

professional liability insurance, and he failed to obtain a signed copy of a notice of such

understanding signed by the client.)

7) In connection therewith, he admits that grounds exist for the imposition of

a sanction against him for such misconduct, and that the Agreement to which this

Affidavit is attached sets forth all grounds for discipline currently pending before the

Board of Commissioners on Grievances and Discipline of the Ohio Supreme Court.

8) Respondent admits to the material facts relevant to the misconduct listed

in the Agreement as set forth in Paragraphs I through 9, inclusive, of the Complaint.

9) He agrees to the sanction of a public reprimand to be recommended to the

Board of Commissioners on Grievances and Discipline of the Ohio Supreme Court.

10) Respondent states that the admissions made in this Affidavit and the

Agreement to which this Affidavit has been attached are freely and voluntarily given,

without coercion or distress, and that he is fully aware of the implications of the

admissions and agreement on his ability to practice law in Ohio.

2

11) He understands that the Supreme Court of Ohio has the final authority to

determine the appropriate sanction for the misconduct admitted by him.

t+^Sworn to and subscribed before me and in my presence this `I day of May,

2008.

E

-Ndary Public

RICFIARD G ALKIRE, eTrv.NOTARY PUBLIC . STATE OF OHIO

My Commission Has No Expiration DateSection 147.03 O.R.C.

3

CERTIFICATE OF SERVICE

A copy of the foregoing Agreement of Relator and Respondent Regarding

Discipline by Consent Pursuant to Section 11 of the Rules and Procedures of the Board

of Commissioners on Grievances and Discipline has been mailed by ordinary U.S. mail

this r`'(f"day of May, 2008 to the following counsel for Relator:

Counsel for Relator: Hearing Panel:

Ellen S. Mandell1717 The Illuminating Building55 Public SquareCleveland, OH 44113-1901

Donald P. McFaddenMcFadden & Freeburg Co., L.P.A.1370 Ontario Street, Suite 1700Cleveland, OH 44113

James LoebBaker & Hostettler LLP3200 National City Center1900 East Ninth StreetCleveland, OH 44114

Paul M. DeMarco, Esq., Chair151 Fourth and Vine TowerOne West 45th StreetCincinnati, OH 45202

Lynn B. Jacobs, Esq.3452 Chapel CourtToledo, OH 43615

Martha L. Butler3800 Granden RoadColumbus, OH 43214

Richard C. Alkire (#0024816)

Attorney for Respondent

13EFOliE'I'HE BOAI21) OF CONIMISSIONERSON GRIEVANCE ANI) DISCIPLINE

OFTHE SUI'RENIIs COUIrr OF 01110

In re:

Complaint against

GERALD M. JACKSON3673 Lee Road

RECEIVEDDEC 1 1 2007

BOARD OF COMMISSIONERSON GRIEVANCES & DISCIPLINE

) CO!•11'LAIN'1' ANll CEIt'I'I I ICA'I7:Sltaker I-leiglits, Ohio 44120

)(12ufe V Oftlte Supreme Cuurt Itules lorl2L•'SPONDGN'I', ) the (;overnment ottlie Iiar of Oliio)

)CUYAHOGA COUNTY BAR )ASSOCIATION 'FILEL-'526 SUI'GltlOlt AVENUESUITI? 1240 ) FEi"j ^ ^ 20OFC LL'VILANI), OI 110 44 1 14-1402 )

RELATOR.

BOARD OF CMMISSIONfcHSON GRIEVANCES ;& DISCIPLINF

Now comes the Rclatur and alleges tltat. GLRALI) M..IACKSON,

(Sup. Ct. Iteg. 1{0010039), an Attorney at Luw, duly adtnitled to (lie praclice ul' law• in the State

of Oliio is guilty of tlte following miscouduct:

1. Gcrald M. Jackson, hereinafter rel'r.rred to as Itespunilent, was aJntiltcd to the

practice of law on April 30, 1976, and as such is su6ject to tlte Suprcme Court Rules fbr thc

Govenitnent o1'tlic Bnrol'Oltio anJ lltc Coile ofprufessionul Itesponsibility.

2. On or about September, 2 003, 1Zespondcnt was retained by Sclmftcr Greenc to

represottt Mr. Greene iu a Jivorcc actiou in Ihe Cuyah%44a Cuuniy 11 mc;tic Rclatiuu, C'ourl,

being Case No. llli-02-290120 captioned Greene v. Naylor. (tah. A).

l

3. Legal scrvices wcre to be provided at the rate of $225.00 per ltour plus costs.

4. Respondent was disch.uged by Mr. Grccne on or about lunc 30, 2004, aficr

providing sotnc legal services.

5. By letter dated .lanuaiy 9, 2006, Mr. Grcenc requested of Respondent a complete

accounting of'tces paid and timc spent. Respondent did not respond to thc written requcst.

(L'xh. B).

6. Respondent did not maintain contemporancous titne records despite liaving an

hourly fce retention agecmcnt witli his client.

7. Respondent lias failed to ntaiutain records of amounts billed and funds reeeived

and fiuilcd to rcndcr an appropriate accounting of limc, lccs and expenses to Iiis clicnt as

reilucsted, in violation of' DR 9-1112(13)(3).

8. Respondent did not maintain professional liability insurancc coverage dtu'ing (hc

heriud ul' lime in which lie represcnted Schaticr Greene. (L'xh. C).

9. Respondent ncitlicr informcd Mr. Grecnc about the absence of prolcssional

liability insurance, nur did lie obtain and nlalnt'Jin a waivcr fi-om Itis clicnt, all in viulation uf 1)12

I-104(A)&(l3).

Respectfully submitted,I

CUYA1IOGA CO ASSOCIATION

^^d P. McFaddcn (0001233)

MCFADDEN & I'RL'G33URG CO., L.P.A.1370 Ontario St., Suite 1700Cleveland, Oliio 44113216-622-085021 6-622-0351 l:r.ruirla Idcui^i:mcl;iJJrnlam u,

arocs Locb (0040[3akcr & I lostettler LLI'3200 National City Ccntcr1900 East 9°i SureetCleveland, OI1 44114216-621-020021 G-G9G-0740 frujluejp @ybakcrlaw.cum

h1len S. Mandcll #0012026/(3ar Counsel

55 I'ublic Square Suite 1717Clcvel:mJ, Ohia 441 13-1901(216) 77 I -7080(210) 771-8404 faxcsmnndcllir^?c+uihlink.uct

CH.x'rt>:1Cn•r>:

7/te iexler.signcd Chairman qflhe Cm'altpgu C'omrlt' Beir:fssuc•iuliun C'er7iJied

Grievmrce C'omntillet Iterehv c•rrlrJies llwl Ellen Munlell, ./ume•.c Loeh, und Doi7uld

Mc•Fadden chrlv atuhrn•ized !o reprc-.cem Rrlalor in Ilteprvinises «nd hen•r ucrepled lhe

respo,t.,•ihiliry (,11„•osectni,1g the c•arnphrinl lo il.s c•urtclrrsiun. ;1%!rr im esNt,^uliott, Relator

helieves rectsunuhle c•curse e.risls to n'crinrl u he(irint, •• e'nmp/ctinl.

3:M e^^ 42007

r n!'''

(. r r ° , , .,•r.il, , .i.;

(fitlle V of i t : 't .

. RarAs.coc•iuliun

,1 t;ae Bar of Ohio.)

(4) (I) (fi) •/'he C'umpluinl: IVhc-rc- l;, d, 13v ff5r, ,r :'{;ued. A coniplaint shalltnean a lormal written complaint alleging misconduct or mental illness uf one who shallhe designated as thc Respondent. Six (6) cupics of'all such complaints shall be filcd inthe oflice of the Secretary of'the Board. Complaints liled by a Certificd (irievanceCommittee shall not be accepted fiir f iling tinless signed by onc or more nmmhers ol'IheBar of Ohio in good standing, who shall be counsCl lix thc Rclator, and supported hy acertiticate in writing signed by the I'resiclenl, Secretary or C'liairman ol'thc CertitiedGrievance Committce, wliich Certified Grievance C'ommittee shall be clecmed thcRelator, ccrtitying that said counsel are cluly authorized to rcprcunt said Relator in thepremises and have aecepted the respon,ihihty of prt>,ecntii,g me compl aint to conclusion.It shall constittite tltc authorization of'such counscl to rcprescnt said Rrlator in thepremises as fulfy and completely as il'designated anef appointed by orclcr ol'Ihc SupremeCourt of'Ohio with all privileges and innntinitics of an of'f irer ot'such Court. 'f'hccomplaint inay also, but need not, he signed by the person aggrievcd.

Complaints filed by the Disciplinary Counsel shall he filed in the name of'llisciplinary Counsel as Relator.

CJpon the filing ol'a complaint with the Secretary ol'the Board, Rclator shallt'orward a copy thereof a Disciplinary C'ounsel, to the Certified (;rievance Cotnmittce ofthe Ohio State Bar Association, to lhe local bar association and to anv CertiliedGrievance ('ommittee serving thr county ur counties in which the Rrspnndent resiclecland inaintains Iiis of'fice and lor the county fi-om which the complaint arose.

I f-IE ,JACKSON LAW COMPANY,.A LEGAt i'k;JFES>IONALr'i5SJCIA)ION A AnDR.NEYS AND COUNSELORS AT [AW

Mr. R. Schaeffer Greene23356 West Ranch HillSouthfield, MI 48034

re: Domestic Relations - Greene v. GreeneCuyahoga County Court Case Number DR02290120

Dear Mr. Greene:

This letter will confirm our prior discussion in which we agreed, at your request,to represent you in the above-captioned matter.

As we explained to you, because of the nature of the matter, and because of thepossibility of the occurrence of presently unpredictable and unforseen circumstances,we are not in the position to quote you a specific fee for our professional services.However, we indicated to you that we would represent you on a hourly fee basis. Ourfee for legal services, including office and telephone consultations are $225.00 per hourand take into account interruptions of other work. Each such hour is based upon actualwork on your particular case.

When we are requested to leave our office in your behalf, you will be charged atthe same hourly rate, although we shall minimize travel expenses and courthouse time,if any whenever we are able. Any out-of-pocket expenses directly attributable to yourmatter, including travel expenses, will be charged to you at cost, in addition to the fee.This letter will also confirm receipt of $625.00 [9/08/03] and $4,473.75 [9/09/20031,representing a total retainer $5,098.75, to be credited against the fee(s).

We are pleased to represent you in this matter, and we assure you that we willpursue your matter as diligently and expeditiously as possible.

Very truly yours,

Gerald M. JacksonGMJ:ajm

3(+7 t I rc Kuad ♦ SltaI.cr Ilqi^hls,OhioA 4 4 120-5 IUS1 b- 7j 2 - S U 11 0 A Fis I b- 7; 2 -.J 0 4 0 A c-nciil: jlil;nt;^i:yahoo.com

EXHIBIT

A^

Nlr. Gerald N. Jackson ( 00100.39), ... . . .3673 Lee Road -- ^'`Stiakar HeLijtits; Ohto:::44120-0000

^:^^:•-Mr: Schaeffer`GceeniEr95497 Delmar Drive

Re: Case DR-02-290120 / sent via certified mail

Dear Mr. Jackson,

I am requesting that you send me an itemized statetnent for the feesthat were paid to you during the time in which you represented nie.

Specifically, list the service that you provided, hours spent on eac

service and your fee for the service. Overall, this information is

requested so ttiat I can verify and check your data against niy record

and my cancelled check records for fees paid.

I am requesting to receive this document in 7 business days.

If you have any questions, please contact me duririg my business hour.(8:00 am - 5:00 pin, M-F) at 586-336-1729.

I look forward to your prompt response.

Schae fer Greene

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EXHIBIT

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