Thank you Jakkie.

Published with permission

Affidavit of Corruption, fraud of Beaufort county Family court system

 

of Jacqueline Pidanick

 

To Who it May Concern;

 

This is a account and record of violations of the judicial system that has fogged my case and hurt my children. In my affidavit, Listed will be the event and laws broken by a string of characters that have hurt and fraudulent acted against the South Carolina Code.

 

In January 2014,I lived with Chris Maddaloni and we have a little girl Olivia Grace Maddaloni. I have another child with Roman Udvornocky, Jacob Udvornocky who is now 5 but at the time was 2 and Olivia a few weeks old. 

 

In January 2014 Chris became mad at me for leaving the house to go to a yoga class. when I returned he throw a recycle bin filled with glass at his sister because he was so mad he was watching Olivia for a hour.

 

Next day, Chris was mad at me for something else and throw the baby on the sofa. I grabbed her and my son and locked us in the bedroom once he cooled down I ran out of the house and called the police and reported it. I have numerous reports against Christopher Maddaloni.

 

In January 2014, 29th if i remember correctly was the night from hell. I had a migraine and put Olivia down and I went up stairs to lay down. I was awoke by my daughter’s heart wrenching scream . I ran to the entry way of the stairs as Chris was coming up them . He throw the baby at me and said “take your fucking child” . I placed her head on my chest to calm her down . It was dark and I followed him down the stairs as he is screaming and punching walls . As I passed Jacob’s door, I checked to see if he was asleep and he was . I then thought I could run out and knock on a neighbor door for help but my son I couldn’t leave him . Chris was so out of control. I knew I was going to die that night, I thought it was over .. I asked Chris ” did you feed her or change her?” He yelled no! I stated well that is probably why she is crying . I placed her on the bed as Chris entered the bathroom. He turned on the light and I noticed her whole left side of her face was black and blue. I said you hit her!!!!! He ran out and I saw not remorse not sadness I saw oh crap I’m caught on his face. Then to get away, I hit Chris and ran up stairs with the baby in arms to grab my cell phone . Right before I could grab it, Chris pushed me on the bed and tried to suffocate us as he stated ” you won’t ruin me”. I kept as much pressure as I could off of Olivia. He grabbed my cell and placed it in his pocket. I followed him down the stairs stating I loved him to calm him down and it will be ok.

 

I placed Olivia who was now asleep in her swing as my mind kept thinking of ways to escape. My phone went off and I stated to Chris a client needs a response. He throw my phone at me and I knew if I placed my phone to my ear I would be dead. I quickly texted Catherine Delong for help and get your husband call 911. Then switched on my voice recorder, I knew this would be the only way my family would know what happened to me. As Chris walked back and forth in rage out of control. He looked at me and said what are you doing and grabbed cell twisting it out of my hand placing it in his pocket again (this is kidnapping that Chris was not charged with nor child abuse due to corruption by Sargent Adams) . He then called his parents and they refused to come out to get Olivia to take her to the hospital and Chris would not let me get her help. His parents are very into themselves Chris even states something along those lines because now he is coming down from his anger.

 

I beg him let me call the police… He states “I can get help, I have violent rages and I can’t control myself… I can..” As he shakes his head ( prosecutor states this wasn’t a admission of guilt my law professor said it was!) . I said ” I know Chris I love you it will be ok.” He throw my cell phone at me and walked into the kitchen to clean up his mess. I called 911 and stated there was a accident. As Chris got farther away I stated, “ Help my boyfriend hurt our baby I have a 2 year old too, I think he’s going to hurt us help!“ ( God as I write this I cry … I truly thought this night was it … I thought my kids and I were going to die and I couldn’t save them). The police came and Chris fled the scene. They chased Chris down and arrested him for Domestic violence. I asked the Sargent later that night if Chris wasn’t guilty why would he flee? They refused to answer me. As I got my son up and ready and Olivia went to Er. I remained calm so that my 2 year old would remain calm. As I got to the Er. The first words out of the detective’s mouth (Sargent Adams) was you don’t look like a de-shoveled mom. I stated “I have to remain calm for Jacob my son”. The detective laughed. If you read my statement it is doesn’t make sense because I was in shock. I held Olivia and followed the nurse to the ct scan when she went limp. The nurse ran me to the doctor and removed me from the room. Have you ever held your child limp in your arms and you can’t hold her hand because you can’t go in the room!  

 

My two year old hung to my leg as I watched. Then she moved and I realized I wasn’t breathing. I passed Olivia to a friend that night Chris knew nothing of her to hide her not knowing if Chris was coming back. I could barely stand. I then called Roman Udvornocky which is Jacob’s dad to take him and told him the story.  

 

 As I returned home, the police were searching the house at 26 victory pt drive. As I was allowed to go back in the detective kept asking me if you thought you were in danger why were you here (Sargent Adams). I stated, ” I was trying to leave, I wasn’t working and I had no family . February when Chris was to be out of town I was going to run.” The detective then told me your going to go back right they all go back. I said ” not me ” He said “sure” as he laughed. The Beaufort county Sheriff’s department should be deeply disturbed by how the Sargent treated a victim, deeply.

 

  

Later as I played my tape I was told it was nothing and they were not charging Christoper Maddaloni with kidnapping and child abuse. ( they were covering it up).  I cried … I sat in my condo without furniture. I played picnic with the kids each night and slept with them in my bed to ensure they were safe. I worked 14 hours a day to pay a lawyer and to be torn apart by the court for being the victim. I was told it was my fault by those that were sworn to protect us. As the state v. MADDALONI trial began, Marshall Horton ( Chris’s lawyer) shook the prosecution’s Mr. Hall’s, hand and said ” we are playing golf this weekend right?” I was floored. Then the prosecution said there was a shuffle and that was how the baby got hurt. Judge Elizabeth Prince, Stated I take this very seriously after she stated he can’t by gun or leave country as his only punishment ( I later found out that wasn’t true, no governing body means Chris can buy gun local and can leave country because no one wrote down his so called sentence, Scary , trust me I even called the FDA and talked to a federal agent who thought it was messed up too and called it a cover up, July 2016).

 

 Our temporary hearing with judge Peter Fuge , he didn’t allow me to speak. He opened my divorce fills to gain evidence against me when I was asking to protect my child. Fuge reduced my support and called me a whining girl just after money and gave Chris MADDALONI now convicted on Criminal Domestic Violence due to my cd I threatened to play at the State trial, the ability to see Olivia without protection. This was with Christopher Maddaloni having a 15 year record of Domestic Violence and hurting his son Micheal Maddaloni for years. Chris immediately admitted guilt at the state trial.  Mr. Fuge gave Chris at temporary trial visitation without supervision and called him hitting the child a mistake. Chris Denys hitting the child but I have emails where Chris said he elbowed her or throw a bottle at her. The police said he had hit her.(Judge Fuge thought nothing of this) in the police report the officer stated in the police report from Jan 29th 2014, he saw four knuckle marks on the side of Olivia’s face placed there by her father. Yes if Chris hit her she would be dead but a quick jab the doctor claims would leave marks with low injuries and the police wrote it as such.

 

The following crimes have occurred:

 

PETER L. FUGE CORRUPTION ( Contains Regina Strickland GAL)

 

Peter L Fuge

Judge’s Oath

All Members of the Unified Judicial System in this state shall take the following oath of office: I

do solemnly swear that: I am duly qualified, according to the Constitution of this state, to

exercise the duties of the office to which I have been appointed, and that I will, to the best of

my ability, discharge those duties and will preserve, protect and defend the constitution of this

State and of the United States. I pledge to uphold the integrity and independence of the

judiciary. I pledge, in the discharge of my duties, to treat all persons who enter the courtroom

with civility, fairness and respect. I pledge to listen courteously, sit impartially, act promptly,

and rule careful and considerate deliberation. I pledge to seek justice, and justice alone.

 

Mr. Fuge violated the following rights to due process:

 

During my temporary hearing in 2014, April 17th, at 11 am, Mr FUGE allowed the plaintiff to talk and give more then the allotted so called evidence. I asked to speak and was told I could not. During this court case, Mr. FUGE went into my divorce files which is out of Mr. Fuge’s jurisdiction, to use against me instead of focusing on Christopher Maddaloni’s 15 years of Domestic violence charges. During the Temporary hearing Mr. FUGE would not allow the Domestic Violence laws in and Title 63 of South Carolina law states: Domestic violence must be considered during deciding custody and visitation .Mr. FUGE waved his hand to dismiss it. Violation of my Due Process Rights Amendment 14.

 

REGINA STRICKLAND G.A.L

 

Was the guardian ad litem for the FINAL ORDER of the court hearing for Maddaloni v. Pidanick.

1. She never investigated  
2. The past G.AL, Nick Felix claimed Chris Maddaloni to be dangerous and Regina Strickland did nothing to ensure safety of a infant.
3. Never called my witness until I had to push her and write letter after letter.
4. Said evidence did not exist when did. Cd where Christopher Maddaloni claims he has violent rages and can not control himself. He then states he can get help in the voice recording. Regina Strickland still did nothing to ensure safety of infant daughter. She still requested payment even though she did not do her job as to the standards of the G.A.L outlined in Article 7, private guardians ad litem.

 

    Section 63-3-830 Responsibility of a G.A.L

 

          MUST represent the best interest of the child

3. Conducting an independent, balanced, impartial investigation to determine facts. Including obtaining criminal history of Christopher Maddaloni and his abuse of alcohol and cocaine abuse. Since Ms. Strickland after numerous attempts by myself to obtain the G.A.L report, never returned emails or request for final report to be handed over to me. This demonstrates that the history of Christopher Maddaloni and the past G.A.L report claiming Mr. Maddaloni to be dangerous on top of a voice recording in Mr. Maddaloni’ s own words authenticated by Beaufort county sheriff department, stating he had violent rages and in a way blacks out during them, that Ms. Strickland did not do her job in which I had paid her for. Ms. Strickland still failed to place proper elements in place to ensure safety of a infant.

 

Which violates Section 63-3-830

         

       G.A.L MUST do a report on parties and provide to parties 10 days before hearing.

 

5. Have a voice recording of Chris Maddaloni stating he has Violent rages and can not control himself . Regina dismissed it. Asked for more money that day.
6. She sat with the abuser laughing and hanging out day of hearing, Mr. Udvornocky was deeply disturbed by this along with many members of opposing counsel.
7. I am a GAL and rule 1 is file a report of your findings. Regina requested money but no report was filed.
8. Asked for certification of completion of Chris Maddaloni finishing therapy, Regina is still unable to provide this. Maddaloni is in contempt. She returns no calls and only sends one letter without evidence completion.

 

During a Rule To Show Cause hearing , March 30th 2016

 

Again Mr. FUGE would not let the Domestic Violence Laws in the courtroom. When I was testifying he was what looked to be a grocery list Mr. FUGE was writing. At the end of the hearing, Mr. FUGE claimed to be quoting my words only I never said the words he claimed he was stating. He then claimed if I continued to go after my abuser, Mr. FUGE would take my child away. This is a crime and against my Constitutional rights, amendment 1 and 14.

 

I proceed with a suite against Mr. FUGE but due to undue stress from court and abuse from court I was forced to drop suite filed 2016 ( please see in exhibit). Mr. FUGE, I was told he had removed himself from my hearings and if I pressed he would take Olivia my little girl leaving her in the hands of a abuser of 15 years (documented).

 

1. FUGE DENIES MY 5th Amendment Rights

 

Mr. FUGE violated my 5 th Amendment rights to due process and a legal obligation to fair procedures. In 2014, Mr. FUGE denied me the ability to speak at my own hearing. Mr. FUGE acted outside his jurisdiction by going into my divorce files from 2013 to obtain evidence to use against me in a different hearing. He then made up evidence or reason to rule against me and rule for the abuser, Christopher Maddaloni.(convicted of CDV in criminal court)

 

1. FUGE DENIES MY 1st Amendment Right

 

Mr. FUGE denied my 1st amendment rights by attacking my use of media to gain help from abuse. Use of Media is my protected right. The 1st amendment states freedom of speech to express and use of media. The facts I posted and story I expressed were of true as I know them statements in which I reached out to officials for help. Mr. FUGE held me in contempt of exercising my 1st amendment right. Very disrespectful of Mr. FUGE for the United States Constitution to deny a citizen their rights. Mr. FUGE let the abuse from Chris Maddaloni continue due to Chris Maddaloni being a wealthy man.

 

1. FUGE DENIES MY 14th Amendment Right

 

Mr. FUGE would not let the following sections of South Carolina law into the court room:

 

Section 63-15-40 (a) States Criminal Domestic Violence must hold weight when discussing and considering visitation of the convicted parent.

 

Section 63-15-40 was denied by Mr. FUGE in both hearings 2014 and 2016, March 30 th.

 

Section 63-15-50 (2) states order of visitation to be supervised by another person or agency. Judge FUGE dismissed and chose freely to ignore South Carolina code, and has been known to do so by other attorneys.

 

Christopher Maddaloni was charged with Criminal Domestic Violence in 2014. Mr. FUGE stated Christopher Maddaloni with a 15 year history, drug abuse, alcohol abuse, called Mr. Maddaloni ‘s abuse to be just a simple mistake.

 

Transcript Violations for Mr. FUGE Hearing 2016, March 30th

 

Transcripts of that day were Changed by a Dana Hartley. Audio of that day was requested and I was denied November 2016 (please see in exhibit).

 

Transcript of July 25th ,28th 2016 by a Missy Brown was changed. Audio of that day was requested and denied November 2016 ( please see in exhibit).

 

FUGE in VIOLATION OF THE FOLLOWING:

 

Canon 1: A judge shall uphold the integrity and independence of the Judiciary. A judge should participate in establishing, maintaining and enforcing high standards of conduct.

Deference to the judgements and ruling of courts depends upon public confidence in the integrity and independence of judges. The integrity and independence of

judges depends in turn upon their acting without fear of favor. Although judges should be

independent, they must comply with the law including the provisions of the code.

 

Canon 2: Judge Shall Avoid Impropriety and the Appearance of Impropriety in all of the Judge’s Activities.

1. A. A judge shall respect and comply with the law and shall act at all times in a

manner that promotes public confidence in the integrity and impartiality of

the judiciary. Public confidence in the judiciary is eroded by irresponsible or improper conduct by judges.

1. b. A judge shall not allow family, social, political or other relationships to

influence the judge’s judicial conduct or judgement. Nor shall a judge convey or permit to convey the impression that they are in a special position to influence the judge.

 

Cannon 3: A judge shall Perform the Duties of Judicial Office Impartially and Diligently

1. B. Responsibilities: a judge shall hear and decide matters assigned to the judge except those which disqualification is required (Myself proceeding with a suite against him was a recusal stated by the lawyer and Judge Cely Brigmann stated Mr.FUGE recusal).
2. C. A judge shall be faithful to the Laws and maintain professional Competence in it.
3. D. A judge shall be patient dignified and courteous to litigants.
4. E. A judge shall perform judicial duties without bias or prejudice, a judge must refrain from speech, gestures or other conduct that could reasonably be perceived as sexual harassment
5. F. A PARTY HAS THE RIGHT TO BE HEARD

A Judge shall NOT, while a proceeding is pending or impending in any

court, make any public comment that might reasonably be expected to affect its outcome or impair the fairness of the trial (Fuge was said to have recusal). Administrative Responsibilities A judge shall diligently discharge the judge’s administrative responsibilities without bias, prejudice and cooperate other judges (Mr. FUGE stated he would remove my daughter if I proceeded to try to get help  against my abuser). I, Ms. Pidanick has never had a issue with the law or any problems with alcohol or cocaine unlike the opposing counsel, Christopher Maddaloni which as been arrested for Domestic Violence and harassment for 15 years, drug abuse and alcohol abuse. Mr. Horton has had issues with harassing a opposing counsel and was sued for such. Mr. Kiker has had numerous legal malpractice law suites over the years. Again I, Ms. Pidanick have nothing but is declared by Mr. FUGE the problem. Christopher Maddaloni is a wealthy man, I think it is pretty clear the fraud on the court that is transcending. Deeply saddened by the lack of respect for the law from these cast of characters and how they hurt child after child for the sake of money. They should know children have no price.

1. D. Disciplinary Responsibilities

A judge who receives information indicating a substantial likelihood that another judge has committed a violation of this code should take appropriate action. (Cely Brigmann, the other judge who followed Fuge’s corrupt ruling. Mrs. Brigmann was a new Judge and  like most feared the presiding Judge for fear of career).

1. E. Disqualification

A judge shall disqualify himself or herself in a proceeding in which the

Judge’s impartiality might reasonably be questioned, including but not limited to instances where: Impartiality might reasonably be questioned. Or the judge has a personal bias or prejudice concerning a party.

1. G. A judge has belief that another judge or lawyer may be impaired by drugs, alcohol or mental or emotional condition must take action (Cely Brigmann did not take action).

 

Marshall Horton Corruption

1. Mr. Horton Went after me as in a warrant for my arrest, without having an order signed, tried to have me arrested when I had no order in hand. Mr. FUGE signed a corrupt order by Mr. Horton who wrote a order outside the verdict for his own gain. Mr. Maddaloni his client paid lots of money to Mr. Horton and Mr. Horton did not want to let Mr. Maddaloni down. If you read the verdict of the transcript dated March 30th 2016, and the order by Mr. Horton you will read two different verdicts. Mr. Horton denied me a right to trial a federal offense for his so called “ethical previsions”.

 

2. Mr. Horton followed me out of Olivia’s daycare at low country day to see if I buckled child (Olivia) in correctly. Stood and watched me. Harassment, Mr. Horton was looking for some angle to use against me. In my order dated May 1st 2015, Mr. Horton can not harass me but he does and disregards the law. Since corruption is of fraud on the court in style and law, Mr. Horton does not fear repercussions and continues to act outside the law.

 

Fraud upon the court is fraud which is directed to the judicial machinery itself and is not found between parties or fraudulent documents, false statements and perjury. Which I have expressed in the affidavit by all parties involved. Usually and sadly once targeted any lawyer hired will participate which is seen when my former lawyer try’s to cover up his legal malpractice. These lawyers practiced malicious prosecution, which held myself in false litigation actions. It seemed to be the more fear for this Judge the more the fraud which I turn creates a fog of false orders which is seen in my situation. Next as in both Mr. FUGE and Mr. Horton evidence now becomes fabricated. Which means all parties in fear or gain of funds work together to deny your evidence. This was seen in my hearing on July 25 th. I am in school for law and my evidence was deemed fit. Some hoe my evidence was denied or barely allowed to admit. Bent Kiker still with holds my evidence from me. Over a course of time my evidence with fraud upon the court begins to get hidden by the Judge and opposing counsel with help from your own attorney. Another fact is material is not fabricated til trial where as you can see from the hearing of July 25 th 2016, Mr. Horton fabricated evidence and material misrepresentation to focus efforts away from the truth. Mr. Horton and Brent Kiker with held evidence from me which is extrinsic fraud, with holding and is associated with Fraud upon the court. The main point is to steer away from discovery which makes sense because when I asked Brent to do discovery he never answered and when I asked Brent Kiker to extend restraining order, Brent also created a fog to deter me from following up with the extension. I know this to be true since now in school for law. The clouded cover up is the biggest characteristic of the fraud which again is seen in my case. Mr. Kiker relied on attorney client privilege, excusable neglect and plausible Deniability. The easiest way to see in my case of fraud upon the court is any claim I brought was turned against me to create confusion which is what Mr. Horton relays upon. Attached are the transcripts and orders where the confusion created by Mr. Horton is apparent. Since Mr. Maddaloni is wealthy, this type of fraud is on the lower income of the two I had learned in school for the ease to cover up.

 

3. Mr Horton changed a citation of a order to Contempt when no contempt was placed on me. How embarrassing for Mr. Horton to try to be deceiving only to mess up the order. Again verdict from Mr. Horton’s order reads differently then verdict placed on me at the 2016 hearing by corrupt Judge. Still Mr. Horton attempts to manipulate order more for his own selfish gain, not up holding the code of law he took a oath to protect.

 

4. Mr. Horton who has written me numerous times as to his ethical stand point of complete truthfulness has repeatedly lied . In July 25th 2016, Mr. Horton added on to his affidavit of fees against me, the court case cost against Susan Maddaloni in magistrate court which I had been victorious in. To my knowledge, I was told Mr. Horton promised his clients he would win and lost, to recover cost he unethically placed fees from his loss inside another hearings affidavit of fees to unethically try to retrieve fees. Mr. Horton yet again was acting outside the color of the law.

 

In the same affidavit of fees Mr. Horton added fees for the trial against Mr. Maddaloni for a protection order. Nikki Haley 2015 Domestic Violence laws clearly states one can not retaliate for a hearing to obtain a protection order. This of course means you can no obtain fees lost. Again Mr. Horton place cost of this trial into yet again a different trial fee affidavit. Mr. Horton should be embarrassed that he calls himself highly ethical. Yes of course all the proof is attached in exhibit.

 

Mr. Horton as a lawyer is in violation of the following

 

Rule 1.11 Special conflicts of interest

(1) Since Marshall Horton is a magistrate judge in Beaufort S.C as I understand it, He should have been disqualified to represent a client within this jurisdiction without proper approval.  Rule 1.15 safekeeping.

(A)(b) A lawyer must keep your funds separate from others and my only place their own money in account for fees. Mr. Horton held in escrow my fees corruptly stolen from me but when ask for documents obtaining those funds there is backed out funds not related to my funds.

 

Rule 3.3 candor towards judge

 

 

• Lawyer Marshall Horton lied to judge repeatedly about findings of facts and used extreme means of manipulation to obtain false findings.

 

 

 

• Offer evidence that is known to be false. Facebook post was not mine and case was dismissed, Mr. Horton continue to use double jeopardy to try to bring about these issues, lying to the judge. Facebook post was cut and pasted without any connection to me or surrounded with a post type background. This is a federal offense to use a false post or any post to bully and Harass a victim of Domestic Violence or any person. Mr. Horton continued to Introduced evidence that was found to be false or before the date of the court order. The Judge was corrupt for admitting evidence.

 

 

This type of crime, using statements of truth against me, found in a place not given access to is call CYBERSTALKING. This “ is the use of the internet to stalk or harass  an individual. It includes FALSE accusations, defamation and slander. Also include threaten or bully to harass monitored person.” This is a desire to control , intimidate or influence a victim which is all characteristics of a person in which commits Domestic Violence( I studied Domestic Violence social-pathetic behavior for 6 months under a therapist). Christopher Maddaloni would attempt to use information or money even hurting the children in attempt to control me. The internet is used the same way. Cyberstalking is a criminal offense (another violation to add to Mr. Hortons list, and yet another contempt Mr. Maddaloni remains shielded from due to the “legal mafia”. This is punished by jail). Cyberstalking is a strategic offense since Christopher Maddaloni pays Mr. Horton to find things on the internet to use and twist against me, the opposing counsel fits the mold. Main point is to instill fear through legal actions of bad faith. This is obviously the current situation. This information is all found on the national department of justice website which encourages one to file a FBI report against all involved. That is how horrific this crime is that Mr. Horton freely participates in. My favorite statement from the department of justice states “ false victimization, the cyberstalker will claim that the victim is harassing him or her , this being Christopher Maddaloni. If you look at the hearing of July 25th 2016 and March 30th 2016, Mr. Maddaloni and Mr. Horton clearly demonstrates such claims. This is a great example of cybercrimes. This is addressed in the Violence Against Women Act, 2000. Again Mr. Horton is breaking the law and admits getting paid for it. He is also in violation of Federal law 47 U.S.C. Which was brought to Mr. Hortons attention during hearing July 25th 2016 by myself. Did Mr. Horton stop? No, he proceeded to break the law. A fourth degree charge is a sentence of 10 years and yet Mr. Horton disregards the law. The internet is protected by the 1st amendment which was just backed by the U.S Supreme Court.

 

(4) legal arguments: lied to judge about Facebook post and past evidence that was found to

be ungrounded. Also Cely Brigmann stated Judge Fuge was recused when he was supposedly not. This is grounds for a mis trial since fact was not retracted at time of hearing. Again this is a due process right the Beaufort county court violated.

 

(5) offering evidence, can prove the evidence in Cely Brigmann case was of past-dismissed

claims and is double jeopardy in which Horton built his whole case around faulty evidence

and the evidence was before the court order in question leaving it inadmissible evidence.

(8) lawyer must know evidence is false, yes Mr. Horton (Christopher Maddaloni’s) lawyer was providing evidence that was know to him to be false to him. Mr. Horton again is in violation.

 

(12) lawyer must report fraud. Mr. Horton was part of the fraud with Peter Fuge. Rule 4.4 respect the rights of 3rd party. Mr. Horton failed to report such violation which is a professional misconduct violation on Horton also.

 

Mr. Robertson was on my property to help keep me safe from Chris MADDALONI during

exchanges. Mr. Horton harassed Mr Robertson by stating he followed Chris Maddaloni when they both Mr. Maddaloni and Mr. Horton had no proof and wrote letters to Mr. Robertson lawyer trying to file a restraining order against Mr. Robertson without cause. Horton was in violation of final order dated May 1st 2015, Harassing a 3rd party being Mr. Robertson.

 

Rich Ulrich Private Detective

 

Title 40 Professions and Occupation

Section 40-18-20

Trustworthy, honesty business.

Rich, when he found out Mr. Horton was the opposing attorney, Rich stopped

charging me claiming he wanted to help but in actuality, Rich was not charging so

he can use what he learned to sell and or give to opposing counsel . Mr. Horton knew more than I ever told him when I realized it was Rich to my knowledge I stopped all communication. This put Olivia’s Life in  jeopardy.

 

Mr. Hall Prosecutor in State v Maddaloni

Rule 3.8 special responsibility of a prosecutor. The prosecutor must administer justice. Mr.

Hall shook Mr. Horton’s hand and Mr. Horton asked if they were going golfing just before hearing. Then told the Judge (Beth Prince) lied to by Mr. Hall covered for Chris Maddaloni stating there was a shuffle that hurt the baby. The police reports that baby had knuckle marks on side of face (see exhibit). Chris had 3 different stories given to police in police report.

 

(5) prejudice statements… Mr. Hall told me I was changing my story when I protested his account of actions. He tried to intimidate me from speaking the truth and aiding the cover up

 

Sgt. Adams

Refused to listen to my cd which caught Mr. Maddaloni in a confession that he had Violent rages and could not control them. He then states he needs help. I told Sgt. Adams that I have this recording. Sgt Adams states that he as in Chris is not being charged for child abuse or kidnapping when Mr. MADDALONI took my phone leaving me stuck and helpless also delaying medical attention to our daughter after Mr. Maddaloni hit her.I brought up recording to a number of police until Sgt Adams was forced to listen and Christopher Maddaloni then feared a trial and Recording to be heard. Mr. Maddaloni pleaded guilty. Sgt. Adams tried to cover up.

 

Brent Kiker Violations ( former lawyer )

 

Rule 1.1 Competence: Brent was not prepared on the laws of Domestic Violence or he participated in fraud to deceive. He did not ask the court to follow the laws for Domestic Violence one removed by the Judge, I believed he was scared of Mr. FUGE and lack of use of visitation laws, Brent, He chose to ignore me when my G.A.L training I took was in favor of pushing title 63 Domestic Violence laws. FUGE throw those laws out of court room, Brent needed to object. He didn’t even try. Horrible. I truly feel Brent was afraid to protest the corrupt Judge due to fraud.

 

Rule 1.1 (5),Brent Kiker would tell me that we would sit down and meet to discuss case and he never allowed me to because I feel it didn’t matter since Brent Kiker was only going easy on Mr. Maddaloni for a preplanned out verdict. Again Mr. FUGE didn’t listen to my testimony and was writing a grocery list at the time. It felt as if they were only going through the motions.  Brent always called last minute to prepare and never followed through with his course of actions he was hired for. (filing my motion RTSC which he agreed with and took money for)

 

Rule 1.1 (6) was violated because Brent was not aware of the Domestic violence laws of 2008 and he never tried to make himself aware therefore was not doing justice for his client.

 

Rule 1.2 (5) scope: Brent refused to file suit against Maddaloni and report FUGE even though he agreed FUGE was acting out of jurisdiction and was falsifying statements.

 

Rule 1.2 (10) Brent knew the order against me was fraud and the opposing lawyer was fraudulent but never addressed it or stopped it out of unlawfulness or fear.

 

Rule 1.3 Diligence: was not worried about working on my behalf, never followed

through with motions and was always last minute with prep, we were hindered and I the client had to prepare the trial on more then one occasion.

 

Rule 1.4 Communication

 

(1) Area of promptly informing client. I had asked Brent to appeal not do a

motion 59. Then Brent with held evidence consisting of transcript from State v Maddaloni and recordings along with paperwork. To this day Brent Kiker still with holds my evidence from me.

 

(2) Reasonable consult with client. Would never sit down with me and talk about decisions or outcomes, nothing. He failed to explain situations and options as if he was pushing a outcome. I question if he received a threat or pay off from opposing counsel. Mr. Horton would then be considered aiding a convicted criminal.

 

(3) Promptly reply for information. Still has not returned all evidence I have been asking for over the 6 months. Made an appeal process impossible, please see exhibit.

 

(B) No real explanation only his paralegal and I had to scream at her to get him

on the phone when the law states the lawyer must explain to an extent to

ensure the client understands. This was denied for me. Motion 59 was not

something I wanted to do. I wanted a supersedes but Brent was fraudulently working to help Mr. Horton because Mr. Hortons client was a millionaire and wanted the corrupt order not to be stopped.

 

The whole law, Rule 1.4 was denied. I at one point have proof I thought my

lawyer Mr. Kiker had dropped me has a client and I reached out to other lawyers. Mr. Kiker, would not return calls nor emails or show up at office for lengths of time. Mr. Kiker with held information at all times. One being, Mr. Horton named Brent Kiker the tier of fact and I stated that’s the judge not a lawyer but either lawyer would address what that meant.

 

Rule 1.5 FEES

(F) written agreement: Brent Kiker and I never had a written agreement and I have proof that I repeatedly asked for one and / or an invoice in which I never got but you better believe I was harassed for the money and when I was quoted a price for the filing of the RTSC motion (he never filed), Brent Kiker charged me 2,500 more then quoted and never filed my motion. I literally was running cash everyday to his door or checks so he would file it. I wrote and filled self.

 

Rule 1.6 Confidentiality

Brent allows Mr. Horton to know about my side of the case and repeatedly made it look like he, Brent was working when he would never ask certain questions to the opposing counsel that were

contempts against Mr. Hortons client during the trial but Mr. Horton some how knew

everything about me. In my hearing with Judge Brigmann, Horton admits to Brent telling all.

 

Rule 1.7 Identifying Conflicts of interest: Material Limitations

 

A conflict of interest exists when something holds back the lawyer from doing his job. Brent Kiker would not follow through with certain issues, like domestic violence laws or filling my suite or report Horton for acting unlawful or Judge Fuge, due to Brent’s career and probably some sort of kickback since what I personally learned fraud upon the court is driven from.

 

Rule 1.9 Duties to former clients to allow evidence and the clients paperwork to be returned was denied to me by Brent Kiker. See exhibit for text messages.

 

Rule 1.10 imputation of conflicts of interest

 

(3) When loyalty to the client is in question. Due to Mr. Kiker not addressing me when

contempts were sent to Kiker law firm, when Brent was not retained and then these letters were sent to me when it was to late, even though the letters were not valid contempts. Mr Horton was violating my rights by not sending these letters to me directly and Mr. Kiker violated my rights by not forwarding letters since he was not retained. Both parties failed to give timely notice by not allowing me access or knowledge of these letters in a timely fashion. This is also a characteristic of fraud.

 

(4) Brent Would not use the Domestic violence 2008 laws nor 2015 laws  in later court dates. In fact steered around certain questions so laws were not addressed in some cases. I feel this was done by Brent Kiker to avoid making Mr. FUGE upset since he would not allow Domestic Violence laws in the court room.  

 

Rule 1.16 declining or terminating representation

Brent failed to give me motions, letters from Fuge and letters sent from Marshall Horton stating contempt. This directly impacted my case by getting my appeal dismissed and being lead to believe a recusal had occurred. Also fired Mr. Kiker and he failed to remove himself as counsel for months.

 

(9) Brent was fired numerous times and refused to remove himself .

 

Rule 3.3 candor laws

 

(2) refused to push laws of domestic violence 2008. Law states the lawyer must fight for the client.

Rule 3.4 fairness to opposing counsel, a lawyer must not block clients right to evidence.

Brent Kiker would not give me the motion 59. I asked all evidence be given back and I have yet to receive the 2014 transcripts of state v. Maddaloni and the cd of Chris admitted violence. I had to over and over call, text, beg, stop by and was met with no response.

To ensure violations were understood, I felt it was in the best interest of my case to attach all laws broken. I have yet to correctly appeal each corrupt order due to the lack of cooperation in the Beaufort county clerks office who for months failed to send me the record on appeal. I have witness and tape recorded their denial which led me to make my own record. This is against the constitution and all due process laws. They are protecting the Judge due to a kick back system I know to be true.

 

Thank you

 

Jacqueline Pidanick

1.1.2017