Plaintiff Stephen R. Lilley seeks relief for certain conduct including conversion, fraudulent conveyance, tortious interference with a right to expectancy, fraud and misrepresentation, and other tortious conduct. Defendant Brenda Dunlap, Esq. is a licensed attorney in the State of Ohio. Defendant Patricia Suttman, Esq., a licensed attorney in the State of Ohio. The acts and transactions constituting the violations of state and common law complained of herein have occurred in Warren County, State of Ohio.

Stephen R. Lilley
Plaintiff,

-vs-

PATRICIA SUTTMAN
Adelante Development Center, Inc.
3900 Osuna Road, NE
Albuquerque, New Mexico 87109-4459

BRENDA DUNLAP
42 East Mulberry Street
Suite B
Lebanon, Ohio 45036

and

PAMELA LILLEY
13411 Capetown Avenue
Pickerington, Ohio 43147,
Defendants.

SUMMARY OF THE ACTION AND THE UNLAWFUL PLAN AND SCHEME

OF THE DEFENDANTS

This action is brought by plaintiff to redress the damage he has suffered damage as a result of defendants’ conversion, and misappropriation of monies and properties by unlawful means; the unlawful plan, scheme, and conspiracy entered into by the defendants, which plan, scheme, conspiracy had as it principal objective to unlawfully convert, misappropriate, take, waste and divert monies and property from Plaintiff Stephen R. Lilley and Marion G. Lilley; by misleading and deceiving, regarding necessary transfers of properties causing Plaintiff Lilley to suffer significant damages to loss of property and expenses by reason of the conduct of the defendants; defendants have interfered with financial agreements causing injury to Plaintiff Lilley; the conduct of the defendants was intentional and was done to obtain the property of Plaintiff Lilley, the defendants through a plan to convert funds, unlawfully took funds of Plaintiff Lilley; defendants have full knowledge that their conduct would cause damage to Plaintiff Lilley; defendants have converted and misapplied funds received from Plaintiff Lilley.

WHEREFORE, Plaintiff Stephen R, Lilley, hereby respectfully requests that this Court enter judgment in his favor and against all defendants as follows:

AN AWARD against defendants, jointly and severally, of punitive damages and exemplary damages of $1,000,000.

AN AWARD against defendants, jointly and severally, for judgment of fraudulent conduct in an amount in excess of $1,000,000.

Plaintiff Stephen R. Lilley was deprived of this ownership rights, including control of the asset and has made demands for the money owed which have gone unanswered. Defendants have converted the certificate of deposit for their own use, depriving Plaintiff of his funds.

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