I.

II.

MISSISSIPPI COMMISSION ON JUDICIAL PERFORMANCE

660 North Street. Suite 104 Jackson. Mississippi 39202

PLEASE NOTE

TELEPHONE (8011369·1273

FAX (80"364-8277

In acc'ord~nce with Section 177A of the Mississippi Constitution of 1890, all procee~ingsbefore the Mississippi

Commission on Judicial Performance are confidential unless and until the Commission files a recommendation"

for discipline or retirement with the Mississippi Supreme Court Confidentiality shall attach upon the· filing of the complaint and shall include all' records, flies, and reports of the Commission.

PERSO~ISING COMPLAINT:.--,--. 1\ \ •

Name: l!kLco\ , ,~O\lc...e.. , -r-J\h....-...,....{\ ....... tO ....... €..=-__ _ (Last) 7 JE~r8t) (Middle)

Address: \'J'J ~ Or-\3:00$ .s+re::t . 'Ino.Dde.s j 1l t:... 1 L fr . 709-4 &

~reet, No .• Route) (City) (Zip)

Telephone No. 995) Co a L\ -1 ~ I a4 " rea Code)

PERSONt,G~T WHOM COMPLAINT IS ~\ Name: m C\;\ \ • J:fllb

. (Last) (First) T.

(Middle)

Address: ~50 () (roe) Street#,;J. , Colum b lfA f'A ~ . (Street, No .• Route) (Cltyt

Judicial Office Held: C.ba Q c. "€. \ \ 0 r. I 0 ~ C hgt] C-ery . 39'fJ9-dqb~

. (ZIp)

CmC+- D lSirlct III. ALLEGATIONS AND STATEM ENT OF FACTS:

Please state the facts and circumstances which you believe constitute judicial misconduct or disability. Include any details , na~es, dates, places, addresses, and telephone numbers which will assist the Commission in (ts eva­luation and investigation of this complaint Also include any documentation you may have.

Qlecse ~~e Q"fuch.e&.

- Continued On Reverse-I • ; .... ,.~ ••• ;~ .l '\ ~.;: )l' :~::; i ~~1.';"~!:'S. ~~I~'~.'~I? !I:'~-;

If additional space is required, continue on additional pages as needed and attach them to this co laint.

IV. I certify that the allegations and statements of fact set forth above are true and correct to the best of -my knowledge, information and belief and are made of my' se will.

~ .. /?U't;y ( Date)

NANINE MCCOOL

MISSISSIPPI COMMISION ON JUDICAL PERFORMANCE P.O. Box 22527 Jackson, Mississippi 39225-2527

Dear SirIMadam:

.Jlttomey at Law

June 13~ 2012

RE: The Honorable Deborah Oambrell Judge, Chancery Court, Marion County

I am an attorney in good standing, licensed to practice and practicing in Louisiana. I am not licensed to practice law, nor have I ever been licensed to practice, in Mississippi. I have never made an appearance as a party or otherwise, in a Mississippi proceeding.

On or about September 19,2011, I received a letter at my office in Mandeville, Louisiana, by regular mail, (attached) which contained a court pleading captioned as "In The Chancery Court Of Marion County, Mississippi, Michael T. Boyd PlaintiffVs. Raven S. Boyd (Maurer) Defendant, Cause No. 06-0136-0n-0." The pleading was titled as a "Show Cause Order" and it was directed to me.

I am not a party to this case. I have made no appearance in this case. I am not enrolled as an attorney in this case (nor could I be because I am not licensed). I have never been subpoenaed or formally called in any manner to appear in any capacity in this case. I do not live in Mississippi. I own no property in Mississippi. Despite its close geographic proximity, I hadn't even set foot in Mississippi for more than a year prior. At best, I flew over Mississippi last year on my way to North Carolina.

Under no credible theory of law could Judge Oambrell reasonably believe that she had personal jurisdiction over me such that she had the power or authority to order me into her court, or subject matter jurisdiction over any matter pending in a Louisiana court. Having failed to even properly serve me with the order, I further had no obligation to respond to it and I did not.

On or about October 3,2011, I received a notice from the Louisiana Disciplinary Counsel that Judge Oambrell had filed a formal complaint against me (attached). I responded to the complaint with my disciplinary counsel, as required by the Louisiana Supreme Court rules and the Louisiana Rules of Professional Conduct. That complaint is pending.

On October 13,2011, I received another letter at my office via regular mail that contained an order issued by Judge Gambrell that authorized my arrest and incarceration for an indefinite period of time (attached).

Judge Gambrell has clearly embarked upon a personal vendetta against me, and through me, my client, Raven Maurer, who I suspect is her real target. I represent Raven and her husband in proceedings in Louisiana. Raven also currently has a case pending before Judge Gambrell in Mississippi. Judge Gambrell is apparently of the mind that the Louisiana proceedings related to an adoption by Raven's current husband are infringing on her jurisdiction of a custody matter between Raven and her former husband in Mississippi. Judge Gambrell has apparently issued an order to that effect in Mississippi. She is, apparently, however, displeased that Raven's current husband has not abandoned the adoption proceeding in Louisiana.

Whatever her objections, Judge Gambrell nevertheless has no jurisdiction over the Louisiana adoption proceedings or Raven's current husband. She also has no jurisdiction over me or direct influence over my conduct as an attorney.

In her complaint against me to my disciplinary board, Judge Gambrell admits to engaging in ex parte communications with the Louisiana judge handling the adoption. She references these ex parte communications during the proceeding in Raven's case that took place last August, and appears to rely upon them in sanctioning Raven, and Raven's mother, who was neither a party to the case, nor served with any notice that she could be sanctioned. Judge Gambrell's treatment of Raven's mother during those proceedings is particularly deplorable because Raven's mother was appearing as a witness and was instead put on trial by Gambrell and then verbally sanctioned by Gambrell in her ruling. Gambrell's ruling in that matter, as evidenced by the transcript, again demonstrates her disregard for the limits of her jurisdiction­she is apparently unaware of any - and basic due process, such as reasonable notice and personal service, not to mention her obligation to act as an impartial fact finder ..

Judge Gambrell should be sanctioned for her conduct toward me; for failing to know or respect basic legal principles of jurisdiction and state sovereignty; for attempting to use her position and authority for an improper purpose; for attempting to use her position and authority to interfere with a judicial proceeding in another jurisdiction; for attempting to use her position and authority to intimidate and bully citizens seeking justice through appropriate legal methods; for abusing her position and authority and violating my constitutional rights by issuing a warrant for my arrest without due process or personal or subject matter jurisdiction, for abusing her position and authority to intimidate, bully and humiliate or attempt to humiliate a citizen appearing as a witness in her courtro ; for taking the role of an advocate in the proceedings, rather than as an impartial, object" e iased fact der.

JNMJdm

Enclosures

Cc: Richard Ducote, Esq.

· IN TIlE CHANCERY COURT OF MARION COUNTY. MISSISSIPPI

MICHAEL T. BOYD

VS.

PLAINTIFF

CAUSE NO. 06-0136-GN-G

RAVEN S. BOYD (MAURER)

TO:

SHOW CAUSE ORDER

Honorable Joyce Nanine McCool Attorney at Law 1772 Orlean Sl Mandeville, LA 70448 Louisiana Bar No.27026

DEFENDANT

'SEP 152011 CASS BARNES, CHANCERY CLERK

BY D.C.

You are commanded to appear before the Chancery Court of Marion County,

Mississippi on the 5th day of October, 2011 at 9:00 a.m. to show cause as to why you

should not be held in contempt of this Court's prior Orders by disclosing information

from a "~ed" Chancery Comt file or in the alternative, to disclose how audio

transcriptions came into your possession after they were placed under seal by the

Chancery Court of Marion County, Mississippi on May 22, 2008 by Court Order as well

as an Agreed Order executed on the ~ day of September, 2008 wherein the parties

agreed to withhold any video tapes or other records, made by the parties, or at their

behest, of the minor children, which are the subject of this litigation; This Order

prohibited the making of any audio or video recordings in an attempt to document

allegations set forth in the pleadings.

That it bas come to this Court's attention that the protected audio recordings are

being disseminated via social medial networks under the following accounts:

www.twitter.comlnaninemccool

www.change.orglpetitionsljustice-for-barley-and-zoey ~

This the J!Lday of September, A.D., 2011.

CHANCELLOR

LOUISIANA ATTORNEY DISCIPLINARY BOARD

OFFICE OF THE DISCIPLINARY COUNSEL 4000 S. Sherwood Forest Blvd.

Suite 607 Baton Rouge, Louisiana 70816

(225) 293-3900· 1-800-326-8022· FAX (225) 293-3300 September 30,2011

CERTIFIED MAIL - RETURN RECEIPT REQUESTED: 71969979 7490 0025 1720

Ms. Joyce N. McCool, Esq. 1772 Orleans st. Mandeville, Louisiana 70448

Re: RESPONDENT: Joyce Nanine McCool COMPLAINANT: Deborah J. Gambrell FILE NO.: 0028469

Dear Ms. McCool:

This office has received a complaint filed against you by Deborah J. Gambrell. The enclosed material contains allegations about your conduct which require the Office of Disciplinary Counsel to obtain a written response pursuant to Supreme Court Rule XIX, Section 4B(2). You are required to provide a substantive response, with documentation, to each allegation of misconduct within fifteen (15) calendar days from the date of receipt of this letter so that we can make an appropriate disposition as soon as possible. At this time, the Office of Disciplinary Counsel has not taken any position regarding the validity of the allegations.

We call your attention to Rule 8.1 (b)(c) of the Rules of Professional Conduct, as well as Louisiana Supreme Court Rule XIX, Section ge, which set forth your duty to respond to a request for information on a complaint filed with this office. Failure to supply the requested response within fifteen (15) days may necessitate the taking of your deposition pursuant to subpoena, at your cost. A failure to respond may also result in disciplinary action being taken _both on the merits and for failure to cooperate.

Your prompt action will be appreciated.

DSMljdh Enclosure

LtJ~s. · Damons.~ Deputy Disciplinary Counsel

(t) Tenth Chancery Court District of Mississippi

Barbara O. Parham Certified Court Administrator

P.O. Box 807 Hattiesburg. MS 39403-0807

(601) 545-6028 Fax: (601) 545HB080

bparham@co.forrest.ms.us

Sepb9nberlS,2011

(Forrest. Lamar. Marion, Pearl River & Perry Counties) Website: www.chancery10.com

Deborah J. Gambrell Chancellor-Place One Post Office Box 807

Hattiesburg. MS 39403-0807 (601) 545-6028

Fax: (601) 545-6080

Patsy Ainsworth Young Official Court Reporter

P.O. Box 1102 Hattiesburg. MS 39403-1102

(601) 582-2582 Fax: (601) 545-6080

patsyains@yahoo.com

Office of the Disciplinary Counsel Louisiana Attorney Disciplinary Board 4000 S. ShelWood Forest Blvd., Suite 607 Baton Rouge, LA 70816

~~nwq] SEP 1 9 2011

Re: Complaint Louisiana Attorney Joyce Nanine McCool Bar Number 27026.

To Whom It May Concern:

OFRCEOF DfSCIPUNARV COtJNS@.

I was appointed by Governor Haley Barbour to serve as Chancellor, Place One, of the Tenth Chancery District of Mississippi on January 11,2011, to replace the Honorable James H.C. Thomas, Jr., who passed away in October, 2010.

One of the cases that I inherited was that of Michael T. Boyd vs. Raven S. Boyd (Maurer); Cause No. 2006-0136 0-111; Chancery ComtofMarion County, Mississippi.

The litigation bas been contentious over the years. Therefore, Judge Thomas enjoined the parties from making allegations of sexual abuse and taking the minors to examjnations for the same or similar allegations of sexual abuse (Please see attached Order dated August 13, 2007). Thereafter, an Order to Seal File was entered on June 27, 2008 (please see attached Order).

The matter came on for hearing before me on August 16,2011, in the Chancery Courtroom of Lamar County, Mississippi. Since that time, I have been inundated with copies of a Petition to achieve justice for the minors, referred to in internet articles, and this mOlDing learned that a voice recording of the minor children, explajning the alleged assault, is now available to the public on "Change .org." This Court has only convened one hearing in this matter. Also, Judge Dawn Amacker of Slidell, Louisiana contacted me after she learned of the articles and the Petition. She was upset; as I was that a practicing attomey would attempt-to use social media in an effort to bypass the courts.

COMPLAINT

This file was "sealed" by the court, and Attorney McCool appears to be disclosing information from a sealed file in violation of the Court's Order. Also she may not be aware, that the signatories to the Petition she is circulating are participating in a conspiracy to intimidate a judicial officer, which is a felony in this state. (Miss. Code Ann. 97-9-55)

I direct your attention to the following websites:

www.change.orglpetitionsljustice-for-harley-and-zoey www.twitter.comlnaninemccool

The article on change.org contains a link to the twitter account, which contains the alleged audio recordings of the minors. This is Attomey McCool's twitter account

Please accept this as a formal complaint against Joyce Nanine McCool.

DLGJ: s

Enclosures

Cc: Honorable Dawn Amacker

.. -

.,' IN THE CHANCERY COURT OF MARION COUNTY THE STATe OF MISSISSIPPI

.. MICHAEL T. BOYD

VS.

RAVENW. BOYD

ORDER GRANTING

FILED· AUG 13 2007

CASE NO. 06-0136

DEFENDANT

MOTION FOR TEMPORARY EMERGENCY RELIEF

THIS'DAY, this cause came on for hearing on Motion for Temporary Emergency Relief

filed by the Petitioner, John D. Smallwood, Guardian A~ Litem, and. all parties having been

, noticed and after having been informed that the Defendant does not oppose the petition, the

Court finds that the Motion is well taken and should be and is hereby granted.

THEREFORE

IT IS HEREBY ORDERED AND ADJUDGED. that Raven Boyd, Wanda Phillips and

any persons acting on their behalf or at their direction are hereby enjoin'ed from making the same or simBar allegations of sexual abuse as to the minor chDdren of the parties herein.

IT IF FURTHER ORDERED AND ADJUDGED that Raven Boyd, Wanda Phillips and

any persons acting on their behalf or at their direction are enjoined from subjecting the minor

children to any more medical examinations for the same or similar allegations of sexual . . abuse.. ,J.11

SO ORDERED, this the.Ajday of Augu

PRESENTED BY: JOHN D. SMALLWOOD, ESQ.

FROM : IERRV LALJ 8S/231~iae 89:48

FAX Nl. : 6817363322 May. 23 2BBB 1B:69Ft1 P2

6~98ee~ l'lJCj.ER SU'~ '-" I"IE. 34

JUN 27 2008

"

IN THE CHANCERY COURT OF MARION COUNTY THE STATE OF MISSISSIPPI

° MICHAEl T. BOYD

vs. PLAINTIFF

CASE NO. 08-0138

DEFENDANT RAVENW. BOYD

on_TO RiAL fllel -lHIS DAY. May 22. 2008. this __ came on for hearing on Motion OI8lBl7U$,

'.. .

and the-COurt having heard fRm all counsel; the Court flnda that based upon the nature

of allegations made In pleadings flied 1ft thll matter and to protect the mln~; children In °

this mauer. the entJrefile .hall • aBlllld by the cleric and not made available to any

petaOn until further order 0' this Coult with notice or any suoh f9queat for diaclo8ure o. .

being gtven 10 both:parlfel· and the court appointed Guardian All LItem herein.

THEREFORE, ° !_

IT IS HEREBY ORDERED AND ADJUDGeD. that the entfr8 _in thI& matter

shall be eearect by the erelt unit1 fUJ1her order of thl8 Court.

SO ORDERED. this the 6yl\Ml~'lUUI

'''II

CLERK D.C.

.. FI~~Et OCT 112011

CASS BARNES CHAN IN THE CHANCERY COURT OF MARION COUNTY, MISS~IPPI :t (fRY CLau

MICHAEL T. BOYD PLAINTIFF

vs. CAUSE NO. 06 .. 0136-0N .. G

RAVEN S. BOYD (MAURER) DEFENDANT

ORDER OF CONTEMPT

THIS CAUSE THIS DAY, October 5, 2011, having come to Court to be heard

upon the Show Cause order wherein the said Joyce Nanine McCool was ordered to

appear and show cause as to why she should not be held in contempt of this Court's prior

Orders by disclosing infonnation from a "sealed" Chancery Court file or in the

alternative, to disclose how audio transcriptions came into her possession after they were

placed under seal by the Chancery Court of Marion County, Mississippi on May 22, 2008

by Court Order as well as an Agreed Order executed on the 2nd day of September, 2008

wherein the parties agreed to withhold any video tapes or other records, made by the

parties, or at their behest, of the minor children, which are the subject of this litigation;

This Order prohibited the making of any audio or video recordings in an attempt to

document allegations set forth in the pleadings.

The Court has learned that the protected audio recordings are being disseminated

via social medial networks under the following accounts: www.twitter.comlnaninemccool

W\\'\\,.change.orglpetitions/justice-for-harlcy-and-zoey.

After being called thrice in open Court the said Joyce Nanine McCool failed to

appear.

D.c.

..

IT IS THEREFORE ORDERED that the said Joyce Nanine McCool is in

contempt of this court for having failed to appear or respond and is hereby placed into the

custody of the Sheriff of Marion County, Mississippi for a period of ten (to) days where

she shall remain until further Order of this Court.

This the 6th day of October, A.D., 2011.