COURT OF COMMON PLEAS
WARREN COUNTY
CIVIL DIVISION

COMPLAINT FOR PROFESSIONAL TORT
MISAPPROPRIATION OF PROPERTY AND FUNDS;
CIVIL CONVERSION NEGLIGENCE

Defendants, Brenda Dunlap and Jackson C. Hedges were appointed by the Warren County Probate Court as joint and co-administrators of the Estate of Marion G. Lilley.

Stephen Lilley is entitled to the joint and survivorship funds which were originally represented by C.D. 4591 in the amount of $100,000.00.

Stephen R. Lilley
Plaintiff:

Vs.

BRENDA DUNLAP, Attorney / Magistrate
Lebanon, Ohio

JACKSON C. HEDGES, Attorney
Lebanon, Ohio

PATRICIA SUTTMANN, Attorney
Albuquerque, New Mexico

JACK C. McGOWAN, Attorney
Hamilton, Ohio

and

PAMELA LILLEY
Pickerington, Ohio
Defendants:

SECOND COUNT

22. Plaintiffs incorporate herein each and every allegation of the First Count as if repeated herein.
23. Defendant, Brenda Dunlap, (Dunlap) at all times relevant, was a licensed attorney at law practicing in the State of Ohio.
24. While Brenda Dunlap was acting as the court appointed administrator for the Estate of Marion G. Lilley, she, Dunlop, was also acting as the private lawyer for one of the beneficiaries, Pamela Lilley.
25. While Defendant Brenda Dunlap was acting as the court appointed administrator, she did not reveal that she was owed substantial sums of money from Pamela Lilley.
26. While Defendant Dunlap was acting as Pamela Lilley’s private lawyer, she conspired with Suttmann to obtain additional money from the guardianship to assist Pamela Lilley to pay substantial sums of money to Dunlap.
27. Dunlap, while serving as the administrator of the Estate of Marion G. Lilley, engaged in a conflict of interest as to beneficiary Stephen R. Lilley.
28. As a direct and proximate result of the malicious, devious, wrongful, grossly negligent acts of the Defendants, Plaintiff incurred substantial stress, medical and mental distress, emotional stress, depression, loss of enjoyment of life, financial loss and partial disability.