No. 2189 Disciplinary Docket No. 3
Annotate this Case
Download PDF
IN THE SUPREME COURT OF PENNSYLVANIA OFFICE OF DISCIPLINARY COUNSEL, Petitioner No. 2189 Disciplinary Docket No. 3 No. 107 DB 2015 Attorney Registration No. 202416 v. (Montgomery County) PATRICK JOSEPH BRADLEY, Respondent ORDER PERCURIAM AND NOW, this 151h day of September, 2016, upon consideration of the Verified Statement of Resignation , Patrick Joseph Bradley is disbarred on consent from the Bar of the Commonwealth of Pennsylvania, see Pa.R.D.E. 215, and he shall comply with the provisions of Pa.R.D.E. 217. Respondent shall pay costs to the Disciplinary Board pursuant to Pa.R.D.E. 208(9). A True Copy Patricia Nicola As Of 9/15/L016 ,---~ Attest: ( ·' ~ Jl.lr:V, • ,• I ~,'/AW Chief C~ . Supreme Court of Pen nsylva nia BEFORE THE DISCIPLINARY BOARD OF THE SUPREME COURT OF PENNSYLVANIA OFFICE OF DISCIPLINARY COUNSEL Petitioner No. 2189 Disciplinary Docket No. 3 No. 107 DB 2015 v. Attorney Registration No. 202416 PATRICK JOSEPH BRADLEY Respondent (Montgomery County) RESIGNATION BY RESPONDENT Pursuant to Rule 215 of the Pennsylvania Rules of Disciplinary Enforcement BEFORE THE DISCIPLINARY BOARD OF THE SUPREME COURT OF PENNSYLVANIA OFFICE OF DISCIPLINARY COUNSEL, : Petitioner No. 2189 Disciplinary Docket No. 3 No. 107 DB 2015 V. Attorney Registration No. 202416 PATRICK JOSEPH BRADLEY, Respondent (Montgomery County) RESIGNATION UNDER Pa.R.D.E. 215 Patrick Joseph unconditional Commonweal th Bradley, resignation of Esquire, from Pennsylvania in the hereby practice tenders of conformity with law his in the Pa. R. D. E. 215 ("Enforcement Rules") and further states as follows: 1. He is a formerly admitted attorney in the Commonwealth of Pennsylvania, having been admitted to the bar on or about July 18, 2006. July His attorney registration number is 202416. By Order Dated 10, 2015, Respondent was placed on temporary suspension pursuant to Pa.R.D.E. 208(f) (5) until further definitive action by the Court. 2. He desires to submit his resignation as a member of said 3. His resignation is freely and voluntarily rendered; he is bar. not being subjected to coercion or duress and he is fully aware of the implications of submitting this resignation. 4. consult He acknowledges that he is fully aware of his right to and proceeding. employ He counsel to represent has/~4.~, him in the instant consulted with and acted upon the advice of counsel in connection with his decision to execute the within resignation. 5. He investigation is aware into that there allegations that is he presently has pending an guilty of been misconduct, the nature of which allegations have been made known to him by service of a Petition for Rule to Show Cause Why Respondent Should Not Be Held In Contempt dated May 2, 2016, a true and correct copy of which is attached hereto, made a part hereof and marked Exhibit "A". 6. He acknowledges that the material facts upon which the complaint is predicated contained in Exhibit "A" are true. 7. He submits the within resignation because he knows that he could not successfully def end himself against the charges of professional misconduct set forth in the attached exhibit. 8. Statement He is fully aware that the submission of this Resignation is irrevocable and that he can only apply for reinstatement to the practice of law pursuant to the provisions of Enforcement Rule 218(b) and (c). 9. He is aware that pursuant to Enforcement Rule 215(c) the fact that he has tendered his resignation shall become a matter of 2 public record immediately upon delivery of the resignation statement to Disciplinary Counsel or the Secretary of the Board. 10. Upon entry of the order disbarring him on consent, will promptly comply with the notice, withdrawal, he resignation, trust account, and cease-and-desist provisions of Enforcement Rule 217 (a) , (b) , 11. will file (c) and (d) . After entry of the order disbarring him on consent, he a verified Enforcement Rule 217(e) 12. statement of compliance as required by (1). He is aware that the waiting period for eligibility to apply for reinstatement to the practice of law under Enforcement Rule 218(b) shall not begin until he files the verified statement of compliance required by Enforcement Rule 217(e) (1), and if the order of disbarment contains a provision that makes the disbarment retroactive to an earlier date, then the waiting period will be deemed to have begun on that earlier date. It is understood that the statements made herein are subject to the penalties of 18 Pa.C.S., Section 4904 (relating to unsworn falsification to authorities) . Signed this :)\~ day of ~~v WITNESS: 3 I 2016. IN THE SUPREME COURT OF PENNSYLVANIA In the Matter of PATRICK JOSEPH BRADLEY No. 107 DB 2015 File Nos. C2-15-968i C2-l6-40; C2-16-139; C2-l6-327; and C2-l6-402 Attorney Reg. No. 202416 (Montgomery County) PETITION FOR RULE TO SHOW CAUSE WHY RESPONDENT SHOULD NOT BE HELD IN COH'l'ENPT Petitioner, Office of Disciplinary Counsel, by and through Paul J. Killion, Chief Disciplinary Ciampoli, Jr., Disciplinary Counsel, Counsel, and Harold E. (hereinafter "Petitioner"), files the within Petition For Rule To Show Cause Why Respondent Should not be Held in Contempt and in support thereof avers as follows: l. Petitioner, Pennsylvania Judicial 2700, Box P.O. whose principal Center, 62485, 601 office Commonwealth Harrisburg, situated Avenue, Pennsylvania ............................ Exhibit A is at Suite 17106, is invested, pursuant Disciplinary power Enforcement and. duty misconduct to Rule of to any 207 of the (hereinafter investigate attorney all Pennsylvania Rules 11 Pa.R.D.E. 11 ) , matters admitted to with involving practice law of the alleged in the Commonwealth of Pennsylvania and to prosecute all disciplinary proceedings brought in accordance with the various provisions of said Rules. 2. Patrick Joseph Bradley ( "Respondent 1' ) admitted to was born on law in October 2, 1971. 3. Respondent was the practice of Pennsylvania on July 18, 2006. 4. The 2015-2016 Pennsylvania Attorney's Annual Fee Form Respondent filed on June 24, 2015, with the Attorney Registration Office listed Respondent's: a) Name and preferred Joseph Bradley, mailing address Bradley Law LLC, as Patrick PO Box 26587, Collegeville, PA 19426; b) Off ice Address as Bradley Law LLC 3801 Germantown Pike Suite 201 C, Collegeville, PA 19426; c) Telephone number as (484) 902-0123, fax number as (484) 902-0120; d) email address as pbradley@bradleylawllc.com; and e) Name of law firm through which he practiced as Bradley Law LLC. 2 A true and correct copy of Respondent's 2015-2016 Pennsylvania Attorney Annual Fee Form is attached as Exhibit "A". In 5. investigation regarding inter that alia, Respondent Respondent that had an commenced Petitioner 2015, February included converted, allegations, misapplied or misappropriated clients' advanced fees and expense retainers. 6. On June Issuance Of a Suspended 15, Rule Pursuant To To 2015, Petitioner filed a Show Cause Why Respondent Pa.R.D.E.208(f) (5) Petition for Should Not Be alleging, inter alia, that Respondent's blatant disregard of two subpoenas issued by this Honorable Petitioner's Court had materially investigation and delayed warranted and obstructed the temporary suspension of Respondent's license. 7. to Show On June 17, 2015, the Petition, and an Order and Rule why suspension Respondent issued by the should not be placed Disciplinary Board, on were temporary personally served on Respondent. 8. Respondent failed to file any response to the Order and Rule to Show Cause. 9. By Order dated July 10, 2015, this Honorable Court placed Respondent on temporary suspension pursuant to Pa.R.D.E. 208 (f) (5}, until further definitive action by the Court, and further ordered Respondent to comply with all the provisions of 3 Pa.R.D.E. 217. A true and correct copy of the July 10, 2015 Suspension Order is attached as Exhibit "B . 1' 10. Pursuant to Pa.R.D.E. 217{d) t the Order placing Respondent on temporary suspension was effective 30 days after entry; Respondent was immediately prohibited from accepting any new retainer or engaging as an attorney for another in any new case or legal matter of any nature; and Respondent could only wind up and complete matters which were pending on the date the Order was entered. 11. Under cover of a letter dated July 10, 2015, Elaine M. Bixler, Secretary of the Disciplinary Board provided Respondent with, inter alia: a. the suspension order; b. a copy of Pa. R. D. E. 21 7 and corresponding Board rules; c. Standard Guidance Lawyers who of have the been Disciplinary Board to Suspended Under Rule and Litigation (form 208(f); d. Non-Litigation DB-24} (form DB-23) Notices of Disbarment, Suspension or Transfer to Inactive Status; and e. Statement of Compliance (form DB-25). A true and correct copy of the July 10, 2015 letter is attached as Exhibit "C". 4 12. The July 10, 2015 correspondence was sent by certified mail and by first class regular mail to Respondent's preferred mailing address. The certified mailing was returned to the Secretary's Office by the post office marked "unclaimed." The regular mailing was not returned. 13. The effective date of Respondent's suspension was August 9, 2015. 14. On Respondent the effective became a date "formerly of Respondent's admitted suspension attorney." Pa.R.D.B. 102 (a) . 15. This Respondent. Honorable Jurisdiction retains Court arises from jurisdiction your Honorable over Supreme Court's inherent and exclusive power to supervise the conduct of attorneys who are its exclusive disciplinary officers. Rule jurisdiction of 103, Pa.R.D.E. your Honorable The Supreme Court extends to "[a]ny formerly admitted attorney, with respect to acts prior to suspension, disbarment, administrative suspension or transfer to retired or inactive status, or with respect to acts subsequent thereto which amount to the practice of law or constitute the violation of the Disciplinary Rules, these rules [the Rules of Disciplinary Enforcement] or rules of the Board adopted pursuant hereto." Pa.R.D.E. 201(a) (3). 16. prompt Pa.R.D.B. notice of 217(c} (1) his required suspension, 5 by Respondent to registered or provide certified mail, return receipt requested, or guardians) time of to all persons (or their agents to whom Respondent owed a Respondent's suspension or fiduciary duty at the at any time after his suspension. 17. prompt mail, Pa.R.D.E. notice of 217(c) (2) his required suspension, return receipt requested, by Respondent to registered or provide certified to all other persons with whom Respondent may at any time expect to have professional contacts under circumstances where there is a reasonable probability that they may inf er that Respondent continues to be an attorney in good standing. 18. Respondent's responsibility as a formerly attorney to provide notice required by Pa.R.D.E. admitted 217{c) (1} and (2) continues for as long as Respondent is suspended. Pa.R.D.E. 217{c). 19. Beginning prohibited on Respondent 9, August from 2015, accepting Pa.R.D.E any new 217(d) {l) retainer or engaging as an attorney for another in any new case or legal matter of any nature. 20 . Pa. R. D. E . 21 7 ( d) {2) requires a formerly admitted attorney to promptly cease and desist from using all forms of communication that expressly or implicitly convey eligibility to practice law in the state courts of Pennsylvania, not limited to professional titles, 6 including but letterhead, business cards, signage, websites, and references to admission to the Pennsylvania Bar. 21. Pa. R.D. E. attorney on 217(d}(3) temporary "promptly resign all executor, trustee, requires suspension appointments administrator, a under as formerly Pa.R.D.E. personal guardian, 20S(f) to representative, receiver, conservator, agent under a power of attorney, admitted or other fiduciary position." 22. In cases temporary suspension under Pa.R.D.E. Rule 208{f), of Enforcement 217(d) (3) requires a formerly admitted attorney to take all necessary steps to cancel or discontinue the next regular publication of all advertisements and telecommunication listings that expressly or implicitly convey eligibility to practice law in the state courts of Pennsylvania. 23. Pa.R.D.E. attorney, within suspension, 217(e} (1) ten days requires after the a formerly effective date admitted of the to file with the Secretary of the Board a verified statement and serve a copy on Disciplinary Counsel. 24. Respondent has not filed with the Secretary of the Board a verified statement pursuant to Pa.R.D.E. 217(e} (1). 25. been Prom August 9, 2015, until the present, Respondent has prohibited from practicing Pennsylvania. 7 law in the Commonwealth of 26. been From August 9, 2015, until the present, Respondent has prohibited from engaging in any form of activities in the Commonwealth of Pennsylvania, law-related except in full accordance with the stringent requirements of Pa.R.D.E. 2l?(j). 2?. As of March 30, 2016, Respondent continued to maintain an office at 3801 Germantown Pike, Suite 201 (c), Collegeville PA, 19426. 28. As of March 30, 2016, Respondent's office had signs of Bradley Law LLC Exhibit \\D" Richer, containing copies of photographs of Respondent' s displayed outside his office. Attached as is a Declaration of Auditor/Investigator Daniel G. signs outside his office taken on March 30, 2016. 29. Respondent has a website: bradleylawllc. com which he continues to maintain. 30. Respondent's website, inter alia: a) describes Respondent as Managing "Attorney, Member"; b) represents that to practice Respondent "Patrick J. law "works in Bradley is licensed Pennsylvania" exclusively with and that individuals with disabilities and related agencies"; c) states that "Bradley Law LLC was created in 2006 to respond to a adequate pressing need in Pennsylvania: legal services 8 and supports to individuals with special needs"; "Bradley Law LLC is a boutique firm with a concentrated focus on the service needs of individuals with disabilities and their families"; Bradley Law LLC specializes needs in: trusts needs. 1. creating that meet Guardianship 2. customized our clients proceedings special individual for persons with cognitive, intellectual and/or developmental disabilities. Private 3. Case Management/Care Management"; d) claims that "by developing a law firm with a concentrated focus of serving those with special needs, we are able to maximize our services and supports for the individuals and families we serve''; e) claims that "[f]or those seeking a knowledgeable, experienced goals attorney on your terms, who can work toward Bradley Law is the your right choice for you"; f) lists his American current Bar membership/affiliations Association and Pennsylvania as Bar Association; and g) identifies his office address as Bradley Law LLC 3801 Germantown Pike, Suite 201 C, Collegeville, 9 PA 19426; his mailing address as Bradley Law LLC, P.O. Box 26587, Collegeville, PA 19426; his phone number as (484) 902-0123; and his fax number as ( 484) 902-0120. A true and correct copy of Respondent's website pages are attached as Exhibit "E". 31. Pa.R.D.E. activities that 217(j) (1) Respondent supervision of a requires performs that be any conducted member in good standing of law-related under the Bar of the this Commonwealth. 32. Respondent does not have a supervising attorney as required by Pa.R.D.E. 217(j). 33. Subsequent to August 9, 2015, Respondent has performed law-related activities in the Commonwealth of Pennsylvania. 34. in the Subsequent to August 9, unauthorized practice of 2015, Respondent has engaged law in the Commonwealth of not been reinstated to the Pennsylvania. 35. To date, Respondent has practice of law and remains on temporary suspension. 10 I . RBSPONDJINT HAS ENGAGED IN THE WILLFUL UNAUTHORIZED PRACTICE OP LAW SUBSEQUENT TO BIS 'l'EMPORARY SUSPENSION WHICH WAS BASED UPON BIS BLATAN'l' DISRBGARD OP 'l'WO SUBPOENAS ISSUED BY THIS HONORABLE COURT (Ka:r:en Rubin2 A) 36. The allegations contained in paragraphs 1 through 35 are incorporated herein as if fully set forth. 37. On November 23, 2015, while suspended from the practice of law in this Commonwealth, Respondent met with Karen Rubin and her mother, May Ann Hindenach, at their Philadelphia home and discussed Respondent's representation of Ms. Rubin in connection with a Social Security matter. 38. 2015, By Engagement/ Retainer Agreement dated November 24, conditions upon services for issue inter Respondent, which [Ms. Bradley Rubin] and/or Medicaid alia, "set Law forth LLC will in connection with issue and any the social terms perform and legal [handling an SSI services related matters as needed]" A true and correct copy of the Agreement is attached as Exhibit "F". 39. Community Andrew Trust Coyle, of Trust Pennsylvania person with whom Respondent was Administrator (hereinafter, for The "ARCn), having professional Arc was a contacts subsequent to Respondent's suspension under circumstances where 11 there was a reasonable probability that Mr. Coyle would inf er that Respondent was an attorney in good standing. 40. Respondent never advised Mr. Coyle in any manner that Respondent is a suspended attorney. 41. Respondent never advised Ms. Rubin or Ms. Hindenach in any manner that Respondent is a suspended attorney. 42. In exchanged October, with Respondent's .November Mr. Coyle emails, "Attorney & October, November inter and December 2015, emails relating to alia, identified Respondent Ms. Rubin. Respondent as Counselor at Law." True and correct copies of the and December 2015 emails are attached collectively as Exhibit "G". 43. By Respondent services email to attached rendered correct copy of Mr. an to Coyle invoice Karen dated from Rubin, the December 28, December Bradley Law Beneficiary." 2015 28, 2015, LLC A "for true and email and invoice are attached as Exhibit "H". 44. By emails to Mr. Coyle dated February 17 and February 19, 2016, Respondent inquired as to whether Ms. Rubin's invoice would be paid. True and correct copies of the February emails are attached as Exhibit "I". 45. By email to Julianna Van Duyne-King, Respondent that on the Respondent Executive advice of 12 dated February Director counsel, for Ms. 19, ARC, 2016, advise.a Rubin's trust would not be paid because Respondent was suspended from the practice of law during the time period reflected on the invoice. A true and correct copy of the February 19, 2016 email is attached as Exhibit "J". 46. By email dated February 19, 2016, Respondent replied to Ms. Van Duyne-King's email as follows: Thanks for finally giving me the courtesy of a reply. As I know your office is fully aware, my office provides legal and non-legal services. Your office has hired my office is(sic) the past for multiple case management matters, at a nonlegal rate for non-legal services. My services to Ms. Rubin were non legal in nature. As I am sure you are also aware, non-legal services can be rendered in SSI cases. Now if you would feel more comfortable with my office changing the wording on the invoice please let me know. Otherwise, I' 11 expect the bill to be paid in full ASAP. Please advise, Regards, Patrick J. Bradley, JD. A true and correct copy of Respondent's February 19, 2016 email is attached as Exhibit "K". 47. By email February 19, invoice. 2016, A true to Mr. Coyle 10:10 a.m., and Ms. VanDuyne-King Respondent attached a and correct copy of the email dated "revised" and revised invoice are attached as Exhibit "L". 48. By email to Ms. Van Duyne-King dated February 19, 2016, 10:26 a.m., Respondent: a) inquired about the invoice; 13 status of his \'revised" b} advised that he would have to pursue the matter directly with the \\client" if ARC did not provide payment for services rendered to Karen; and c) advised that, if short order" , Respondent would have to pursue a claim for the theft of client could not services in "pay in the local Magisterial District Court. A true and correct copy of Respondent's February 19, 2016 email is attached as Exhibit ''M". 49. By email to Mr. February 23, 2016, Coyle and Ms. Respondent, Van Duyne-King, inter alia, dated inquired about the invoice. A true and correct copy of the February 23, 2016 email is attached as Exhibit \\N". B) 50. (Dakota Moyer) The allegations contained in paragraphs 1 through 35 are incorporated herein as if fully set forth. 51. By Engagement/Retainer Agreement dated July 14, 2014, Respondent, inter alia, : a) set forth the terms and conditions upon which Bradley Law LLC would perform legal services for Matt Moyer and Alexis Moyer; and b) confirmed that Respondent would assist the Moyers in obtaining a supplemental 14 needs trust and a payback for the Moyer, Dakota trust and would obtaining two benefit mirror also of their assist wills with son, them pour in over provisions to the supplemental needs trusts. A true and correct copy of the July 14, 2014 Agreement is attached as Exhibit ''0". By cover 52. letter dated January 21, Respondent 2015, provided Leslie Oakes and Mark Newell of the Governor's Office of General Counsel, Department of Human Services "Office of General Counsel") a Respondent the had (hereinafter drafted for "Moyer Trust") . copy of a special needs trust benefit A true (hereinafter, of Dakota and correct A. Moyer copy of the January 21, 2015 letter and Moyer Trust are attached as Exhibit "P" . By letter dated January 19, 2016, addressed to Bradley 53. Law LLC Patrick J. Bradley Esquire, Donna N. Brown, TPL Program Investigator, Special Needs Services") advised Trust that the Department Depository of Human Services' {hereinafter \\Dept. of Human had received the Moyer Trust and requested a trust approval letter from the Office of General Counsel. A true and correct copy of the January 19, 2016 letter is attached as Exhibit "Q". 54 . By facsimile dated February 5, 2016, Respondent provided Ms. Oakes and Mr. Newell a copy of Ms. Brown's January 15 19, 2016 letter and requested a review letter from the Office of General Counsel. A true and correct copy of the February 5, 2016 facsimile is attached as Exhibit "R". 55. Ms. Respondent Oakes was Respondent's and Mr. having Newell professional were persons contacts with whom subsequent to suspension under circumstances where there was a reasonable probability that Ms. Oakes and Mr. Newell would infer that Respondent was an attorney in good standing. 56. Respondent never advised Ms. Oakes and Mr. Newell in any manner that Respondent is a suspended attorney. 57. Respondent never advised the Moyers in any manner that Respondent is a suspended attorney. C) 58. (ANN KOZLOWSKI) The allegations contained in Paragraph 1 through 35 are incorporated herein as if fully set forth. 59. Special On or Needs about October Trust for 2, the Respondent 2015, benefit of drafted Anne a Kozlowski (hereinafter, "Kozlowski Trust"). 60. Respondent's drafting of the constituted the unauthorized practice of Trust Kozlowski law and "law-related activities" as defined in 217(j), Pa.R.D.E. 61. Respondent was appointed Kozlowski Trust. 16 as the Trustee of the 62. By cover letter dated October 12, 2015, Respondent provided the Kozlowski Trust and Special Needs Questionnaire to Ms. Oakes. letter, A true and correct Kozlowski Trust and copy of the October 12, Questionnaire are 2015 attached as addressed to Exhibit "S". 63. By letter dated November 20, 2015, Bradley Law LLC Patrick J. Bradley Esquire, Hilary Holmes, TPL Program Investigator, had received the provide a trust advised that the Dept. Kozlowski approval of Human Services Trust and requested Respondent letter from the Off ice of to General Counsel. A true and correct copy of the November 20, 2015 letter is attached as Exhibit "T". 64. By facsimile dated February 4, 2016, Respondent provided Ma. Oakes and Mr. Newell a copy of Ms. Holmes' November 20, 2015 letter and requested a review letter from the Office of General Counsel. A true and correct copy of the February 4, 2016 facsimile is attached as Exhibit "U". 65. her Respondent never advised Ms. behalf in any manner that Kozlowski or anyone on Respondent was a suspended attorney. D) 66. (Jennifer Cianciulli) The allegations contained in paragraphs 1 through 35 are incorporated herein as if fully set forth. 17 - 67. --~---------------------------- On November 19, 2015, Respondent entered the showroom of Keener Kraftsmen, LLC, a renovation and remodeling business in Pottstown, Pennsylvania. 68. Respondent approached employee Jennifer Cianciulli1 and: a) introduced himself as "Attorney, Pat Bradley"; b) asked to speak to "Chris"; c) advised seven that others "[Respondent's] are suing client and in [Chris] twenty a huge lawsuit"; and provided Ms. business d) Cianciulli ca.rd, Respondent's with identifying Respondent as "Attorney & Counsellor at Law." A true and correct copy of the card Respondent provided to Ms. Cianciulli is attached as Exhibit "V". 69. Respondent never advised Ms. Cianciulli in any manner that Respondent is a suspended attorney. E) 70. (James Crownover) The allegations contained in paragraphs 1 through 35 are incorporated herein as if fully set forth. 71 . On December 2, 2015, Respondent emailed James Crownover, a "new" Engagement/Retainer Agreement dated November 24, 2015. 18 72. The November 24,· 2015 inter Agreement, alia, "set forth the terms and conditions upon which Bradley Law LLC will perform legal services for [Mr. Crownover] in connection [with the drafting and registering a deed] " . A true and correct copy of the November 24, 2015 Agreement is attached as Exhibit "W". 73. By check # 154, dated December 6, 2015, Mr. Crownover provided Respondent with $446 .15. A true and correct copy of check #154 is attached as Exhibit "X 11 74. • On December 10, 2015, Respondent emailed Mr. Crownover and: a) requested him to sign the NEW retainer agreement; b) advised that the check for $446.15 had been deposited and requested an additional check for $81. oo; and c) identified himself as Patrick J. Bradley Attorney & Counselor At Law. A true and correct copy attached as Exhibit "Y 75. 11 of the December 10, 2015 email is • By check # 155, dated December 10, 2015, Mr. Crownover provided Respondent with $81. 00. A true and correct copy of check# 155 is attached as Exhibit "Z". 76. On January 11, 2016, Deeds of Huntingdon County, Recorder of Pennsylvania called Respondent, at which time, she: 19 Virginia Cooper, a) inquired about the status of a Deed to be recorded on behalf of Mr. Crownover; b) was advised working on by Respondent the document sending the deed that and to Mr. Respondent that he was would be Crownover in the near future; and c) agreed to email Respondent copies of previously recorded deeds. 77. having Ms. Cooper was professional suspension under a person contacts circumstances probability that Ms. with whom subsequent where Respondent Respondent's to there was was a reasonable Cooper would inf er that Respondent was an attorney in good standing. 78. Respondent never advised Ms. Cooper in any manner that Respondent is a suspended attorney. 79. Respondent never advised Mr. Crownover in any manner that Respondent is a suspended attorney. F) 80. Heather J. Revere (SCO Director of The Arc Alliance) The allegations contained in paragraphs 1 through 35 are incorporated herein as if fully set forth. 81. On April 20, 2016, Petitioner against Respondent from Heather J. Arc Alliance. A true and Revere, correct 20 received a copy complaint SCO Director of The of the Complaint Information Form and attached Statement of Complaint is attached as Exhibit "AA". 82. a member Ms. Revere's complaint alleged, inter alia, that "when of [her] supervisory team told a family that Mr. Bradley claims to represent that he is not currently a licensed attorney, Mr. Bradley contacted her to imply that he could file a slander lawsuit against her." Respondent's March 25, 2016 True and correct copies of emails attached as Exhibit "BB". 21 to The Arc Alliance are ROLES VIOLATED 83. Petitioner Respondent' s believes avers the ref ore and that conduct as described in paragraphs 1 through 8 2, supra, is a willful, continuing and direct violation of, inter alia, this Court's July 10, 2015 Order and conclusively establishes that Respondent is a danger to the public. 84. The aforementioned averments establish that: a) Respondent had knowledge of the Suspension Orderi b) Respondent had notice of his responsibilities under Pa.R.D.E. 217(j); c) Respondent has repeatedly violated RPC 5.5(a); RPC 8.4(d); 203(b) (4); 217{d}; continuously RPC 5.5(b)(l); Pa.R.D.E. Pa.R.D.E. Pa.R.D.E. and RPC 8.4(c); 203(b} (3); Pa.R.D.E. 217(c) (l)and(2), 217(e} (1) i Pa.R.D.E. Pa.R.D.E 217(j) (1); Pa . R . D . E . 21 7 {j ) (4 ) {i ) ; Pa . R . D . E . 21 7 {j ) ( 4 ) ( ii ) ; Pa.R.D.E. (j) (4) (iii); Pa.R.D.E. 217(j) (4) (iv); Pa.R.D.E. 217(j) (4) (v) i Pa.R.D.E. 217(j) (4) (vi) i Pa . R . D . E . ( j ) ( 4 ) {ix) ; Pa . R. D . E 21 7 ( j ) {4 ) {x) ; Pa.R.D.E. 217{j) (5). Respondent has: in violation profession conduct in More specifically, practiced law in a of the that involving 22 regulation of jurisdiction; dishonesty, and fraud, jurisdiction the legal engaged in deceit or misrepresentation; engaged in law-related activities without being supervised by a member in good standing of the bar of this Commonwealth; performed law-related services from an off ice that is not staffed by a supervisory attorney on a full-time basis; represented himself lawyer or person of similar status; as a had contact with clients beyond ministerial matters; rendered legal consultation negotiated or behalf a of received, or advice transacted client a with matter third clients; to for or parties; on and disbursed or otherwise handled client funds; and d) Respondent has knowingly violated Suspension Order and continues open and contemptuous manner. 23 this Court's to do so in an PRAYER FOR RELIEF WHEREFORE, Petitioner respectfully requests that your Honorable Court: 1. Order Respondent to immediately prepare and deliver to Petitioner a list of the names and addresses of all individuals or entities which he he is is a currently fiduciary, representing showing the or with dates, respect amounts to and circumstances of the entrustment and current balance thereof, as well as the banks and account numbers in which such funds are currently maintained; 2. Order that Respondent immediately file a Statement of Compliance in accordance with Pa.R.D.E. 217{e); 3. Issue a Rule on Respondent, Patrick Joseph Bradley, to Show Cause Why He Should Not Be Held in contempt of this Court by reason of his willful violation of this Court's Order dated July 10, 2015, returnable at a date, time, and place certain, and with a response to the allegations herein; and AND FURTHER, that after consideration of any response made by Respondent, your Court grant the following additional relief: 4. Order that Respondent, Patrick Joseph Bradley, be held in contempt of this Court by reason of his willful violation of this Court's Order dated July 10, 2015i 24 5. of Order the President Judge of the Court of Common Pleas Montgomery 217(g), County, in accordance with Enforcement Rule to take such further action and make further orders as may appear Respondent's necessary to protect clients or the fiduciary rights entities and interests with which he of is involved; 6. Order that controlled by him, any bank accounts held by Respondent or containing fiduciary funds, be frozen until further action by a court of appropriate jurisdiction; 7. Order that Respondent Patrick Joseph Bradley shall: a) fully comply with the provisions of Rule 217 of the Rules Supreme of Disciplinary Court of Enforcement Pennsylvania of the pertaining to disbarred attorneys; b) immediately by writing, notify of his suspension all - current clients, any services rendered subsequent were client for which to August 9, 2015, all persons or their agents or guardians to whom a fiduciary duty is or may be owed at any time after his suspension, and all other persons with whom Respondent may at any time expect to have professional where there is a contacts reason~ble 25 under circumstances probability that they may infer that Respondent continues as an attorney in good standing; c) immediately website cease desist bradleylawllc. com communication, signage, and including, letterhead and and but from using the all forms of limited to not business cards, that contain the term BRADLEY LAW LLC; d} be subject to a fine of $100 a day for each day from the date of this Order that he continues to be non-compliant with Pa.R.D.E. 217; e) Such other relief as the Court deems just and proper; and 8) Order that this matter be referred to the Disciplinary Board for a hearing to recommend the appropriate sanction. Respectfully submitted, OFFICE OF DISCIPLINARY COUNSEL Paul J. Killion, Chief Disciplinary Counsel A~ No. 20955 By: Ha:rolE:Ciampol i, Jr. , Disciplinary Counsel Attorney Reg. No. 51159 Off ice of Disciplinary Counsel District II Off ice 820 Adams Avenue, Suite 170 Trooper, PA 19403 (610) 650-8210 26 VERIFICATION I, under Harold the E. Ciampoli, penalties Jr. , provided in Disciplinary 18 Counsel, Pa.c.s. §4904 state (unsworn falsification to authorities) that: I am a Disciplinary Counsel of the Disciplinary Board of the Supreme Court of matter pursuant to Pennsylvania assigned to prosecute this the Pennsylvania Rules of Disciplinary Enforcement; I am authorized to make this verified statement; and The facts contained in the attached Petition for Rule To Show Cause Why Respondent Should Not Be Held in Contempt are true and correct to the best of my knowledge, information and belief. 5~/lb Date Ha~ampoli, Disciplinary Counsel District II Off ice Jr. IN THE SUPREME COURT OF PENNSYLVANIA In the Matter of PATRICK JOSEPH BRADLEY No. 107 DB 2015 File Nos. C2-15-968; C2-16-40; C2-16-139; C2-16-327 and C2-16-402 Attorney Reg. No. 202416 (Montgomery County) ORDER AND RULE TO SHOW CAUSE PER CURIAM: AND NOW, this day of 2016, the Petition for Rule to Show Cause Why Respondent Should Not Be Held in Contempt is granted, and a Rule is hereby entered upon Respondent to show cause why he should not be held in contempt for willful violation of this Court's Order dated July 10, 2015. Respondent is ordered to immediately prepare and deliver to Petitioner a list individuals or entities of he the is names circumstances of the addresses of all currently representing or with respect to which he is a fiduciary, and and showing the dates, entrustment and current amounts balance thereof, as well as the banks and account numbers in which such funds are currently maintained. Respondent is further ordered to file, within ten (10} days of the date hereof, a Statement of Compliance in accordance with Pa.R.D.E. 217(e). Respondent is further directed to file any Response to the Petition and to this Rule within ten (10) days of the date hereof and to timely serve a copy of said response upon the Office of Disciplinary Counsel. IN THE SUPREME COURT OF PENNSYLVANIA In the Matter of PATRICK JOSEPH BRADLEY No. 107 DB 2015 File Nos. C2-15-968; C2-16-40; C2-16-l39; C2-l6-327 and C2-16-402 Attorney Reg. No. 202416 (Montgomery County) ORDER PER CURIAM: AND NOW, this ---- day of - - - - - - 2016, an Order and Rule to Show Cause having been entered by this Court on Patrick Joseph Bradley, and upon consideration of the responses filed, it is hereby ORDERED that: A. Respondent, Patrick Joseph Bradley, be held in contempt of this Court by reason of his willful violation of this Court's Order dated July 10, 2015; B. The President Judge of the Court of common Pleas of Montgomery County, shall take appears such in accordance with Enforcement Rule 217 (g) , further necessary Respondent's to clients action protect or and the fiduciary make further rights entities with as interests and orders of which he is involved; C. him, Any bank accounts held by Respondent or controlled by containing fiduciary funds, shall be frozen until further action by a court of appropriate jurisdiction; It is further Ordered that Respondent, Patrick Joseph Bradley shall: 1. fully comply with the provisions of Rule 217 of the Rules Supreme of Court Disciplinary of Enforcement Pennsylvania of the pertaining to suspended attorneys; 2. file a Statement of Compliance in accordance with Pa.R.D.E. 217{e) within ten (10) days of the date hereof; and 3. immediately by writing, notify of his suspension all clients, any rendered subsequent current services were client for which to August 9, 2015, all persons or their agents or guardians to whom a fiduciary duty is or may be owed at any I I time after his suspension, and all other persons with whom the formerly admitted attorney may at any time expect to have professional under circumstances where there is a contacts reasonable probability that they may infer that he or she continues as an attorney in good standing. 4. be subject to a fine of $100 a day for each day that he continues to be non-compliant with Pa.R.D.E. 217. It is further Ordered that this matter be referred to the Disciplinary Board for a hearing to recommend the appropriate sanction. IN THE SUPREME COURT OF PENNSYLVANIA In the Matter of PATRICK JOSEPH BRADLEY No. 107 DB 2015 File Nos. C2-15-968i C2-16-40; C2-16-139; C2-16-327 and C2-16-402 Attorney Reg. No. 202416 (Montgomery County) PROOF OF SERVICE I hereby certify that I am this day serving a copy of the Petition For Rule To Show Cause Why Respondent Should Not Be Held In Contempt and all accompanying documents upon the person and in the manner indicated below, which service satisfies the requirements of Pa.R.A.P. 121: Attempted Personal Service as follows: Patrick Joseph Bradley Bradley Law, LLC 3801 Germantown Pike, Suite 201 Collegeville, PA 19426 Date c Harold E. Ciampoli, Jr. Disciplinary Counsel Attorney Reg. No. 51159 District II Office 820 Adams Avenue, Suite 170 Trooper, PA 19403 (610) 650-8210 PATRICK JOSEPH BRADLEY No. 107 DB 2015 File Nos. C2-15-968; C2-16-40; C2-16-139; and C2-16-327 EXHIBITS Exhibit A 2015-2016 Pennsylvania Attorney Annual Fee Form ExhibitB July 10, 2015 Order placing Ron Temporary Suspension Exhibit C July 10, 2015 letter from Disciplinary Board ExhibitD Declaration of Auditor/Investigator Daniel G. Richer Exhibit E Website pages fromBRADLEYLAWLLC.COM ExhibitF Engagement/Retainer Agreement dated November 24, 2015 Exhibit G October, November, and December 2015 emails exchanged between Respondent and Mr. Coyle ExhibitH December 28, 2015 email and invoice Exhibit I February 17 and February 19, 2016 emails from Respondent ExhibitJ February 19, 2016 email from Julianna Van Duyne-King to Respondent Exhibit K February 19, 2016 email from Respondent to Ms.Van Duyne-King Exhibit L February 19, 2016, 10:10 a.m., email and revised invoice from Respondent to Ms. Van Duyne-King and Mr. Coyle ExhibitM February 19, 2016, 10:26 a.m., email from Respondent to Ms. Van Duyne-King Exhibit N February 23, 2016, email from Respondent to Ms. Van DuyneKing and Mr. Coyle ExhibitO Engagement/Retainer Agreement dated July 14, 2014 Exhibit P January 21, 2015 letter and Moyer Trust ---------------- --------------------------- Page2 ExhibitQ January 19, 2016 letter from Donna Brown, TPL Investigator to Respondent re: Moyer Trust ExhibitR February 5, 2016 facsimile from Respondent to Ms. Oakes and Mark Newell of Governor's Office of General Counsel Exhibit S October 12, 2015 letter and Kozlowski Trust and Questionnaire Exhibit T November 20, 2015 letter from Hilary Holmes, TPL Program Investigator to Respondent ExhibitU February 4, 2016 facsimile from Respondent to Ms. Oakes and Mark Newell of Governor's Office of General Counsel ExhibitV Respondent's business card Exhibit W Engagement/Retainer Agreement dated November 24, 2015 ExhibitX Check # 154 dated December 6, 2015 ExhibitY December 10, 2015 email from Respondent to James Crownover ExhibitZ Check# 155 dated December 10, 2015 Exhibit AA ODC Complaint by Heather J. Revere received April 20, 2016 Exhibit BB Respondent's March 25, 2016 emails to the Arc Alliance 2015 • 2016 PA ATTORNEV'S ANNUAL FEE FORM lll.UE ON OR §l'ME JIJI.. Vt, 21l1~ NON·WANAll.i PENALII&§ ATTORNEY REGISTRATION OFFICE STATUS FEES Active uoo lnacllve ONE $1511 LATE f'f!EAFTERJUl..Y 31 PD 0 PENFll.002381040 $300 LATE FEE AFTER AUGUST 3t D s[!J[!](!J.oo' $100 REttJRNEO CHECK FE! www.padboard.org l".\IRIRMT !ITATtLot• - - ATTORNEY DATA 1.NAME ANO PllEFEMED MAll..IHG AOlll'lli!SS: 10#2024111 LJ t:.twct< "'" tor "'11l!lc 2.0l'FICI! AODf!li!U: BRA!Al!Y LAW U.C 38111 GERMANTOWN PK $TIS 201 C COW!Gt!\/IW!, l'A 111426 Palrlck ~h l!mlley llAADl.EV LAW U.C w Chtoek 00. fut PtlOOc P080X2S587 3. RES!llENCE ADDflER eot.1.iGl!lllW!. PA 111426 1131~\VAY COW!Gli!V1UE, PA 1i142!! 4. T£U!l>llONI!: (484} 902-0123 5. !UUI.: XXX.JO{.SC!JI FAX: 141!4) 902-01211 E-MAll.; 7. BIRTH OAT&:: 1lllll2tlll71 ~com 8. PA AllMISSION DATE: 0711812Dllll 5. COUNTY OF MAii.iNG ADDFIESS: Momgomery II. GENDER (Mil'}: MM 10. NAME OF LAW FIRM THROUGH \MilCH I PRACTICE: l!mlley Law u.c 11. NAME OF ORGAHIZATION THROUGH WHICH 1PRACTll:;I!.: {e.g. CORP. l.l!GAI. DEPT., GOVT l.liGAI. DEPT., l.liGAI. SERVlCI!., D.A.'1 OFFICE, PUllUC Ol!.FENOl!RJ 1:1, OTHER THAN nlE COMllONWl!ALTHOF PA, IJ$Tl!D ARE ALI. JURISDICTIOMI WHERE I HAllE El/ER BUN liC!!NSeD Tl;! PRACl1Cti! LAW: NONEINOT Af'Pi..ICJIB!.e W aTATEIFeDl!RAL COURT ACTIVIE AOMIN. INACTIVIE SUSI'. RETIReP RliBlGl'4EP IMINNDl!P DlllllARRliO l'INANCIAI. DATA 13. FOR THE PERIOP MAY 1, :1014 Tl;! PATE OF Flt.ING THiil FORM, NAME OF EACH 1'1NAN¢;1AL INl!Tll\fl10fC, ACCOUNT NUMlleR Al\lP LOCATlOH (Iii\' ST/\TE) OF: A) El/ERV ACCOUNT IMTHIN OR O!JTSIDE PA IN WHICH I Oil MY S!PlOYERILAW FIRM HEl..O MY CU!NT oA THIRD-PMTY FliNDll ilUllJECT 1'0 PA.llP.C. ua: II) EVERY ACCOUNT HQl.DING F\.INCS CIF A CLIENT OR THIRD P/\RTY {WHl'lTHll!ft OR ljOf ll!.ff!IJl!(;t TClfl>l\.R.P.£1, 1.1& ) ovea IMilCH I HAO ll0l.li OR llHAREO SIGWITIJRI!! A\JTHCllUTY OR /\UTHORIZATION tO TRANl!Fel\ FUNCS TCI OR FROM THI! ACCOUNT; ANO Cl l!!Yl!RY BUll!NESSIOPl!!l\ATING ACCOUNT MAIHTAINEP OR USED SY ME IN THE PR/\CTICE GF IJ<W. Sil6 F'l!.R.D.E. 21S(dl(1){111J • (VJ. D llONlfJllQT AFFUCA!ll..E HOl..Oll llANKlf!RtlKel\AGE NAME llAl!llC CODE 143 ACCOl.INt NUMllER tDBa!1k.NA llAl!llC PA LCICATION CLIENT (STATE) Fl.INllS ¥ PA !:lllAIJfB!'llNO& . lmNO!.!Wi:lm FllNM -!OLT11 /\CCOUHT -40<TA l!!XEilllPT ~Rl!.aTFORCUElml .OTHER AutH. !NII. ~RATING IOI.TA PROl'USIONAI. UAllllUTY INSURANCE I IMIN'f!\111, t!ITM&R INDIVIDLW.l.'I' O!l THRQUGH MY' FIAM.1'11- UAllll.ll'Y INtlt.iRANCll ~ fO Tllll l'llOlll$IOllS OF Al.II.II OF PROl'PlllCllAL-.icl IA{C) I DO NOT-14Nl'AOl'll811111NAL~~-I DO NOTH.illll!l'R!llATI! eu&ml:ANO~ NO~ Sl<l>C$URE TQ AC110N&(l.G.,AE'111W>. f!UIJ.,.TI!.11£1!WIOUllE CCM!llllil. ~FIJI.I.. 1'1!.11£111NT COIJlillll!l.,f!1C) OONOT-14N ~_,IW«!E:~TOTllllflR!IVllllOllllOI' U~,llU'l'IDO~l'l!IYA'ltQUllHl'SANDIOltAllOllSlllU!EXl'OllURETI:l~ACTl()N$. ceRTil'ICATION AND AGRHMINT !AMF-.wtANDlffCOMPIJNICllWTllAl.il.ll.11.0l'TllllPA!lUl.EllOFP!l_Cl:lN!lUCT_Tllll!W!CIUllGOF~AND OTHER flAlilPPt'f OF CIJfiNTllAND'Ml!DPEll$OllSANOTllll -&NANce OF lC!!.TAACll~NIOWTl!flAAl:I& W flflGMOING Tiii! -TOl!Y!lliPQ!l'lltlG OF CMillll!Ul'TS Qll TlllJlll' ACCOl.llml. ICl!R11F'I' !'NAT /\LI. ltMITA®OUNTlltNATl-AINAll!I iJi.illJ<lllll.l! INllTITUTIO!lll~ll\'Tllll ~COlll!T OF Pll!IN!m.-l'<:>ft TIE ~OFSUCl!~PU!lllUANTTOAA.R.llJ!.221 jlU!Llil1NGTO-Tllfl'l'Olll!llD!lAFTNO'llF!ClA~ANOtNATEAQHTIWSI' - ae!!N-MSUCl!TOTllll~INllTmfllC!lllNml:HITIS-lllNl10. I FU!lTlll!RCl!RTIFVTHAT1H&FllAll!I NOOU'l'IT-O!lllEl!S OFS\l!IPl!NSlllllO!l I l l -- M E l\SOF Tllll MTl!OFmB-.icATIONMIDTllAT Tllll INFOAMAT10NllllQlllQlll) IS TJWll.lf ANY STA-MADE ON 'MS FOl!tlillSFAUll!,l IW\l.IZl!I AM SWIJECf TOlllllCll'l.IHlll\'Tllll ~COIJllT. I HllAEllY MRllllTHAT ANY ACno11 !lf1l!ll1GliT - M l l l Y TIE PEIWS'll.V-~f!Jl!Ol'OAQUllHI' SICIJAITYFOA1lil!lle~ Ill' MONIEllPAll> l!Y1lil l'\INO MA llESUU OF"' Ml! MAY Ill! llllOUGWT IN Tllll COlll!T OF COMMON Pl.EM OF llLI.1lGHENY' -OAF1llt.Alllil.I' coumY. Exhibit A IN THE SUPREME COURT OF PENNSYLVANIA OFFICE OF DISCIPLINARY COUNSEL. Petitioner No. 2189 Disciplinary Docket No. 3 No. 107 DB 2015 v. Attorney Registration No. 202416 PATRICK JOSEPH BRADLEY, Respondent (Montgomery County}' ORDER PERCURIAM: AND NOW, this \ 10th day of July, 2015, upon consideration of the Recommendation of the Disciplinary Board dated July 2, 2015, it is hereby l•. ORDERED that Patrick Joseph Bradley is placed on temporary suspension . · pursuant to Pa.R.D.E. 208(f}(5), until further definitive action by this Court. It is further ORDERED that Respondent shall comply with the provisions of Pa.R.D.E. 217. This Order constitutes an imposition of public discipline within the meaning· of Pa.R.D.E. 402, pertaining to confidentiality. A True CoPY Patrlcla N1cora-----·· As Of 7/10{2015 ~~be~}V#&.! Supreme Court of Pennsylvania ........................... ,/ Jo$eph W. Farrell Executive Director Elaine M. Bixler Secretary of the Board Facsimile (717) 231-3382 www.ParJboard.org bers of the Board II K. Rosenberg Board Chair J neG. Penny Board Vice.Chair D vid E. Schwager • D ugtas W. Leonard {)\scll'LINA~y ~:!1!~~~2E!::..-.:+,lacey McCantia Lewis Brian John Cali OF THE :.</<?<> Lawrence M. Kelly • Stefanie B. Porges, M.D. P. Brennan Hart SUPREME COURT OF PENNSYLVANIA Andrew J. Trevelise David A. Fitzsimons Pennsylvania Judicial Center John F. Cordi$CO 601 Commonwealth Avenue, Suite 5600 Jame$ c. Haggerty PO Box 62625 • Non-Lawyer Members Harrisburg, PA 17106-2625 (717} 231-3380 July 10, 2015 "-4:--~ Patrick Joseph Bradley Bradley Law LLC PO Box 26587 Collegeville, PA 19426 RE: 110 Office of Disciplinary Counsel v. PATRICK JOSEPH BRADLEY (Montgomery County) No. 2189 Disciplinary Docket No. 3 No. 107 DB 2015 Attorney Registration No. 202416 Dear Mr. Bradley: The Prothonotary of the Supreme Court of Pennsylvania has forwarded to us a certified copy of the Order of that Court dated July 10, 2015 {copy enclosed), that " ... Patrick Joseph Bradley is placed on temporary suspension pursuant to Pa.R.D.E. 208(f)(5) , until further definitive action by this Court. It is further ORDERED that Respondent shall comply with the provisions of Rule 217, Pa.R.D.E ... " such action to take effect thirty days from the date.of the Order. For your guidance, compliance and information, I am enclosing the following: 1. Standard Guidance of the Disciplinary Board to Lawyers who have been Suspended Under Rules 208(f) and 214 Pa.R.D.E. 2. Rule 217 of the Pa.R.D.E. 3. Form DB-23, Nonlitigation Notice of Disbarment, Suspension or Transfer to Inactive Status. 4. Form DB-24, Litigation Notice of Disbarment, Suspension or Transfer to Inactive Status. 5. Form DB-25, Statement of Compliance. You are now required to comply with the Pennsylvania Rules of Disciplinary Enforcement and Disciplinary Board Rules as enclosed herewith. ye~truly yours, EMB/ms Enclosures cc: ~-~~ Elaine M. Bixler Secretary of the Board Prothonotary, Supreme Court of Pennsylvania, Western District Office Zygmont A. Pines, Esq., Court Administrator of Pennsylvania Ms. Kathryn J. Peifer, Administrator, PA Lawyers Fund for Client Security Hon. William J. Furber, Jr., P.J., Court of Common Pleas, Montgomery County Michael R. Kehs, Court Administrator, Court of Common Pleas, Montgomery County Mark Levy, Prothonotary, Court of Common Pleas, Montgomery County Michael E. Kunz, Clerk, U.S. District Court, Eastern District of Pennsylvania Tim y B. McGrath, Clerk, U.S. Bankruptc.r~urLEastem District of Pennsvlvania P I J. Killion, Chief Disciplinary Counsel arold E. Ciampoli, Disciplinary Counsel _ EXHIBIT c DECLARATION OF DANIEL G. RICHER I, DANIEL G. RICHER. hereby declare under penalty of perjury, to the following that: 1. I am an Auditor/Investigator with the Office of Disciplinary Counsel and have been employed in such capacity for approximately l 0 years. 2. On December 14, 2015, I went to 3801 Germantown Pike, Collegeville Pa, the address listed as Respondent's Office Address on the Annual Fee Form he filed on June 24, 2015. 3. 3801 Germantown Pike is the address of a strip mall known as Evansburg Village Shopping Center. 4. Located near the street, in front of the shopping center, is a sign listing the occupants of the buildings located in the shopping center. One of the listings on each side of the sign was BRADLEY LAW LLC. 5. Located on the outside, over the door to the front entrance for the offices at 3801 Germantown Pike, was a BRADLEY LAW LLC sign. 6. Inside the building on a wall adjacent to the entrance, was a Directory of Offices. The Directory reflected, among other tenants, BRADLEY LAW LLC 201C. 7. On the entrance door for Suite 20 l was a BRADLEY LAW LLC sign. 8. I encountered Respondent in the building. I advised Respondent that I was with the Disciplinary Board and that I was checking on the status of his law firm signs. 9. Respondent advised me that his signs reflected Bradley Law LLC and do not contain the term Firm. Respondent also represented to me that he was doing non-legal work. 10. After returning to my office on December 14th, I received an email Respondent had sent to me, as well as to Disciplinary Counsel Ciampoli. A true and correct copy of Respondent's December 14, 2015 email is attached as "Attachment I." I 1. On March 30, 2016, I returned to 3801 Germantown Pike, Collegeville, PA. The signs relating to BRADLEY LAW LLC described in the foregoing were still prominently displayed, as they had been on December 14, 2015. Photographs of the signs taken on March 30, 2016, are attached as "Attachment 2." I hereby declare, under the penalty of perjury and pursuant to 18 Pa. Con. Stat. Ann. §4904 relating to sworn falsification to authorities, that the foregoing is true and correct. 0u:J J~zo/b •---•-•••Iii-----• ~ate . EXHIBIT D Daniel G. Richer Auditor Richer, Daniel G. From: Sent: To: Cc: Subject: Patrick J. Bradley <pbradley@bradleylawllc.com> Monday, December 14, 2015 10:23 AM Richer, Daniel G. Ciampoli, Harold Office of Disciplinary Counsel - Follow Up from your 12/14/2015 visit to my office. Mr. Richer, As a follow up to your visit, I wanted to let you know I am sorry for not recognizing you. When you were in the waiting area, you had only stated that you were from the Office of Disciplinary Counsel and that we had met before but did not tell me your name nor did you show any ID or hand me a business card. That is why I had to catch up with you in the lobby to ask your name, as I had explained. It is very likely our last meeting was you making a brief stop in the doorway of my office to drop off a form or letter. As such, my last meeting with you was likely very limited to only a few seconds. It is also likely that I was on the phone when you had stopped by the office, so my apologies for not recognizing you. Unfortunately, your visit in the office today was quite brief in that you said you were looking at the status of my practice. That you were checking on the Bradley Law Firm. As I pointed out to you, the name of the company is Bradley Law LLC, and that it does not use the term "firm". I also informed you that I am not taking any legal clients. Rather, my office has a non-legal business side as well and always has and that the non-legal side is still open for business. That seemed to catch you off guard, based on your lack of reply and apparent confusion as to my statements. So I just am just checking in with you as there appeared to be some confusion on your part about that particular issue. I did not want issues to get confused at the ODC and for your office to believe that my business was solely limited to the practice of law. That would be an incorrect assumption. I hope this email helps clear things up. If you have any questions please do not hesitate to contact my office. Thank you for your time and attention to this matter. Patrick J. Bradley, JD Mailing Address: Bradley Law LLC P.O. Box 26587 Collegeville, PA 19426 Office location: Bradley Law LLC 3801 Germantown Pike Suite 201 C Collegeville, PA 19426 I .............................. Attachment 1 1 BRADLEY LAW LLC • About Us I Bradley Law LLC Pagel of 3 BRADLEY LAW Home About Us Our Services Contact Info Attorney Profile About Us Home About Us ABOUT BRADLEY LAW LLC services and supports to individuals with needs. Every year the number of individuals with an disability, as well as those with a mental health diagnosis (or both), continues to rise in "'""nn<:tm.r::m. 1 physical disabilities and the ever increasing numbers of the Add to that number those individuals with population and you can easily see that Pennsylvania's rapid expansion in all of these areas has overwhelmed the current available infrastructure, resulting in the need for increased legal services and supports directed to those with We're on your side! By developing a law firm with a concentrated focus of able to maximize our services and needs. we are those with for the individuals and families we serve. With direct interaction with the many level and state level human services systems, and for over 15 years, we have been in the trenches fighting for the very individuals and families who are most in need. Our up to the minute knowledge of the methods and practices of each local and state human services system nonsense approach each and every day to our clients and families what For those seeking a knowledgeable, v''""''"'"''""',... 0 our clients the We use our direct no need. who can work toward your on your terms, Law is the right choice for you. We can help. http://bradleylawllc.com/aboutus/ 4/15/2016 Our Services I Bradley Law LLC Page 1 of7 BRADLEY LAW Home About Us Our Services Attorney Profile Contact Info Our Services Home Our Services OUR SERVICES Bradley Law LLC is a boutique firm with a concentrated focus on the service needs of individuals with disabilities and their families. Bradley Law LLC in: 1. Creating customized special needs trusts that meet our clients individual needs. 2. Guardianship proceedings for persons with intellectual and/or developmental disabilities. 3. Private Case Management I Care Management. We service all accounts personally based on our client's needs. We specialists in non-legal fields as well as a maintain a vast network of outside resources that clients can SPECIALIZED LEGAL SERVICES: *Special Needs Trusts: (Drafting Payback and Supplemental Drafting and execution of customized trust documents. Trust Management Education. Pooled Trust Consultation & Registration Assistance Available. http://bradleylawllc.com/services/ 4/15/2016 Our Services I Bradley Law LLC Page 2 of7 *Guardianship: Uncontested I Contested. *Private Case Management I Care Customized concierge level case management I care management services individuals who need a direct hands-on Each client directs the to meet the needs of those and level of assistance they desire. LEGAL SERVICES 1. Initial Consultations • In Office • Out of Office (Mileage is calculated from office • Document Reviews (combined w/lnitial Consultations(IC)) • Document Reviews (combined w/lnitial Consultations(IQ) • Document Reviews (combined w/lnitial 2. Document Reviews (separate from an Initial Consultation or other matter) 3. Legal Analysis/Legal Research as an Individual Service or to supplement a Document 4. Situational Assessments (Education -Transition I Behavioral Health/ Intellectual ASD, 5. Legal Representation (Hourly) LEGAL DOCUMENT DRAFTING (ESTATE PLANNING): 6. Wills (New Wills) 7. Codicils (New Codicils} known as 9. Powers of Attorney (Durable/ Springing/ Limited/ Mental http://bradleylawllc.com/services/ 4115/2016 Our Services I Bradley Law LLC Page 3 of7 10. Special Needs Trusts (Payback & ORPHANS' COURT MATIERS (PETITION OR LITIGATION 11. Will Contests 12. Codicil Contests 13. Advance Directive Contest 14. Power of Attorney Contest 15. Special Needs Trusts Approvals (As Needed Only) with Petition Required). to Trust/ 16. Special Needs Trusts Modifications/ Terminations payments from Trust). 17. Other Special Needs Trust Related Matters. 18. Guardianship, Uncontested (18 and 19. Guardianship Review Hearing 20. Petition to Add New Guardian 21. Petition to Remove Guardian & Add Successor Guardian 22. Petition to Compel Accounting by Current Guardian or Previous Guardian 23. Resignation of Guardian OTHER LEGAL DOCUMENT DRAFTING: 24. Non-Judicial Settlement Agreements (related to Needs 25. Demand Letters (General Correspondence I Cease & Desist/ Initial I 26. Property Deeds 27. Settlement {Small http://bradleylawllc.com/services/ 4/15/2016 Our Services I Bradley Law LLC Page4 of7 28. Other legal Document Drafting {Contracts, MEDICAID; 29. Application Assistance 30. Denials 31. Re-certifications 32. Sheltering Assets to gain or maintain eligibility for Medicaid programs 33. Over payments I Undue Hardship SOCIAL SECURITY: 34. Supplemental Security income 35. Supplemental Security Income 36. Supplemental Security Income (SSI) - Appeals ADMINISTRATIVE LAW: 37. Fair Hearings and Appeals (Department of Public Welfare - Bureau of 38. County Administrative Entity Review 39. Unemployment Compensation Claims SOCIAL SERVICES SYSTEMS WORK: 40. County Level - Mental Retardation/ Intellectual Disabilities http://bradleylawllc.com/services/ 4/15/2016 Our Services I Bradley Law LLC 42. State Level -Autism I Autism 43. County level Page 5 of7 I Services 44. State level - Other Disability Systems I Waivers 45. Private Case Management SMALL CLAIMS COURT I MAGlSTERIAL DISTRICT COURT MATIERS: 46. landlord I Tenant Matters {Represent Tenant 47. Other Small Claims CIVIL LITIGATION (COMMON PLEAS 48. Civil litigation - Plaintiff (All cases reviewed and on a case 49. Civil on a case case basis.} case ESTATE ADMINISTRATION: 50. full Service 51. Unbundled OTHER LEGAL SERVICES: 52. Other Legal Services As Needed COMMUNITY & GROUP EDUCATION: http://bradleylawllc.com/services/ 4/15/2016 Our Services I Bradley Law LLC Page 6 of7 We offer community and group Contact us for more information and to schedule a session for your group. CONTACT US ONLINE WITH OUR CONTACT FORM HERE. Page last updated on 6/20/2014. Search Search RECENT POSTS Needs Trusts RECENT COMMENTS ARCHIVES 2014 CATEGORIES Special Needs Trust http://bradleylawllc.com/services/ Management 4/15/2016 BRADLEY LAW LLC Home About Us Our Services Attorney Profile Contact Info Attorney Profile Home ,, Attorney Profile ATTORNEY PROFILE Patrick j. Bradley Search Search Collegeville, Pennsylvania Managing Member, Bradley law LL C RECENT POSTS Bar Admission: Pennsylvania, 2006 Special Needs Trusts Tips Education: Juris Doctor Widener University School of Law Wilmington, Delaware RECENT COMMENTS Bachelor ofArts East Stroudsburg University East Stroudsburg, Pennsylvania Patrici< J. Bradley on Special Needs Trusts Tips Dave Weir on Special Needs Trusts Tips Professional Background: Mr. Bradley has over fifteen years of professional experience serving individuals with special needs and their families. Having gained over five years of civll service ARCHIVES experience at the county level in the local mental health/ mental retardation offices; combined with over five years as a professional advocate, Mr. Bradley Is thoroughly versed in many local human services systems in Pennsylvania: May2014 Developmental Disabilities (formerly Mental Retardation) Services System: CATEGORIES Mr. Bradley has extensive knowledge of and is well versed in the Pennsylvania developmental disabilities (formerly mental retardation) system including, but not limited to, many of the Medicaid Waivers, eligibility determinations (both for services and for Waivers), appeals related to denials, reductions or terminations in services. He has on in depth knowledge and familiarity with Individual Support Plans (ISP's) and the Prioritization of Urgency of Need for Services Form (PUNS Form) and related processes. Special Needs Trust Management Tips META Login Entries RSS Autism Services System: Comments RSS Mr. Bradley has extensive knowledge of and is well versed in the Pennsylvania adult autism services system including, but not limited to, the Adult Community Autism Program (ACAP), the Adult Autism Waiver (AA~ (for individuals with Autism, Autism Spectrum Disorders, Pervasive Developmental Disabilities and/or Asperger's Syndrome), WordPress.org eligibility determinations for ACAP and MW, appeals of denials, reductions or terminations in services. He has in depth knowledge and familiarity with Individual Support Plans (ISP's) and plan development and related processes. Behavioral Health {formerly Mental Health) Services System: Mr. Bradley has extensive experience assisting individuals and families to navigate both the complex child and adult behavioral health services system for Individuals seeking services in the home, at school or elsewhere in the community. Special Education System: Mr. Bradley has regularly assisted (and still continues to assist) numerous individuals and families in local school districts with various components of their Individualized Education Plans (IEP) and meetings for chl/dren ages 5 through 21. Having participated in many meetings, including mediations and other steps of due process, Mr. Bradley has sought and negotiated many successful outcomes for children and families. Before establishing Bradley Law LLC, Mr. Bradley served as a staff Advocate for the local Arc of Montgomery, Berks and Bucks Counties through its related companies (now called The Arc Alliance Advocacy Services). In addition to his advocate role, Mr. Bradley served as the Program Manager for the Arc's P.A.G.E. Program, providing financial assistance services to those in need. His prior roles with the Arc included an appointment as Project Coordinator for the Arc's two consecutive grants from The Pew Charitable Trusts, through their Programs Serving Vulnerable Adults. In addition to his previous role with the local Arc, Mr. Bradley had also served as a consultant and part time Trust Administrator for The Arc Community Trust of Pennsylvania, a local non-profit managing special needs trust for many individuals with varying disabilities throughout Pennsylvania. He concentrated on special projects for the Arc Community Trust and he has extensive experience and expertise with all aspects of Special Needs Trusts, including initial analysis, trust drafting and trust administration. Mr. Bradley provides presentations on topics of interest to individuals, families and providers in the southeast region and continues to regularly consult on advocacy services to individuals with disabilities and their families. Memberships/Affiliations: Current' Member- American Bar Association Member- Pennsylvania Bar Association Member- Arc of Pennsylvania, SAGA Committee Life Member- Delta Sigma Phi Fraternity Previous: Member- OPW, Office of Developmental Programs, Planning Advisory Committee Member- Montgomery County MR Employment Coalition Member- Montgomery County Right to Education Task Force Member· Trans Net, Persons With Disabilities Advisory Group Member- The Arc of Montgomery. Berks and Bucks Counties Alternate Member- Trappe Borough Zoning Hearing Board CONTACT US ONLINE WITH OUR CONTACT FORM HERE. Contact Info I Bradley Law LLC Page2 of4 l"'\rrtrc 11f"\11nc. RADLEY LAW !all From 10:00 a.m. to 2:00 p.m. staff is available to take your calls Home About Us rnrPrTl\J Our Services Attorney Profile Contact Info MAILING ADDRESS: Bradley Law LLC P.O. Box 26587 Collegeville, PA 19426 OFFICE LOCAT10N: Bradley law LLC 3801 Germantown Pike, Suite 201 C Collegeville. PA 19426 DIRECTIONS FROM THE EAST (PHILLY): Take the Interstate 76 W ramp to Valley 0.2mL Keep left at the fork, follow signs for 1-76 W/Valley/Forge and merge onto 1-76 w 16.7 mi. Take exit 327-328A-328B for US-202 N toward US-422 of Prussia/W Chester/Pottstown 0.1 mi. Take exit 328A on the left to merge onto US-422 W toward Pottstown 3.6 mL Exit onto PA-363 N/S Trooper Rd 2.7 mi. Tum left onto W Main St/Ridge Pike Continue to follow Pike 3.4 mi. Tum right onto Evansburg Rd 0.5 mi. Turn left onto Germantown Pike. Destination will be on the right 23 ft Evansburg Center. DIRECTIONS FROM THE WEST (READING): Take US-422 E toward Pottstown 30.0 mi. Take the exit toward Collegeville 0.4 mi. Turn left onto PA-29 N 2.6 mi. Turn right onto E Main St/Ridge Pike Continue to follow Ridge Pike 0.3 mi. Turn left onto Germantown Pike Destination will be on the left 0.9 mi. Evansburg Center DIRECTIONS FROM THE NORTH (ALLENTOWN): US-22 W 4.2 mi. Take the 1-476 exit toward Philadelphia/Scranton/Toll Rd 0.6 mt. Take exit 44-20 to merge onto l-476 S toward Toll road 26.7 mi. Take exit 31 for PA-63 toward Lansdale Toll road 0.8 mi. Turn right onto PA-63 W/ Sumneytown Pike 0.4 mi. Turn left onto Old Forty Foot Rd 3.1 mi. http://bradleylawllc.com/contactus/ 4115/2016 Contact Info I Bradley Law LLC Pagel of 4 BRADLEY LAW Home About Us Our Services Attorney Profile Contact Info Contact Info Home "'' Contact Info CONTACT INFO PHONE& FAX: 484-902-0123 .phone 484-902-0120 fax http://bradleylawllc.com/contactus/ 4/15/2016 .I nt Cop)' RAD LEY LAW. LLC UR SPECIAL NEEDS SOURCE IN PENNSYLVANIA November 24, 2015 DISTRICT If OFPICI OF DISCIPUNARY COUNSEL Karen Rubin 2340 E. Nonis St PhUadelphia, PA 19125 RE: ENGAGEMENT/ RETAINER AGREEMENT Dear Ms. Rubin, The Rules of Professional Conduct for attorneys in Pennsylvania require that we enter into a written agreement descrlbi11g the basis upon which y()u will be charged for prOfesslonal seMclt perfon:ried by our firm. 1'1111 letter arid agreement •'11 for:th "8 termt and ~~ upon which Bradley Law LLC will perform legal servfces for you tn wnnectiori wittttbe:;tnatteri discussed betow. In addition, because you are a new client Of our firm, I thought it WOUid be helpful to confirm the S<fOP8 of engagement and to provide you Witfl a general overview of our billing procedures; We are pleased With your decision to engage Bradley Law LLC to represent you and we look forward to working with you. SCope of Enaagement I understand from our recent discussion that your objectives are as follows: 1. Assist you in handling an SSI is&\.le andlor Medicaid issue. 2. Assist you with any eocial services related matters as needed. 3. Other matters as requested by you and agreed to between you and our office in writing. Although it Is always difficult at the outset of representation Of a client to describe With precision whal will be involved, it Is our understanding that we will provide all legal services reasonably required in connection with the matters described above. If the scope of our services is enlarged beyond that described above and if we determine that a fee arrangement different from that described in this lettar would be appropriate, we will reach agreement with you on a separate fee arrangement for the additional work. While this letter. is intended to deal with the specific legal services described above, these terms and condltioris will also apply to any additional legal services that we may agree to provide that are outside the initial scope of our representation. Fees. Distwrsementt a!)d Other Expense.Staffing Legal work varies greatly. Although we are often engaged by our clients to pet'form specific !!lnd limlted tasks, our primary role as legal advisors is to offer our knowledge, . experience and independent judgment. RecogniZlng this, ourfocus in charging for services is to anive at a fee that is fair and appropriate considering all the circumstances. / ([>LEASE REPLY TO MAILING ADDRESS) OFFICE ADDRESS: BMDLEY LAW U.C 3801 GERMANTOWN PlKE. COLLEGEVILLE. PA 19426 sum: 201 c (484) 901-0123 PHONE (434) 902-0120 FAX MAIUNG ADDRESS: BMDlfY LAW llC P.O. BOX 26587 •••lilPllW•l'W•flMIBIHJl"1rt•lllslwlrM••••fitlfOEVILU. PA 19426 Exhibit F Among the factors that we consider in establlshing a fae are the following: the tirru? (measured in tenths of an hour) devoted to a particular matter and the tawyers and paralegals .who worked oh that matter; the nature and complexity of the work performed; the expertise required to per(orm that.work; the novetty and difflculty of the legal. issues presented; the extent to which the urgency of the matter preempted other work; the extent to which the matter required special aDocation of firm resources and staff overtime; the result obtained; and the amount typicaly charged by comparable firms for the same or similar work. For the present, t will be principally involved In these matters. An hourly fee, which is also applicable In the event that unknown and/or unforeseen. circumstances arise which must be handled during and/or after the Initial matter(s) or in the event that legal services are terminated by either party to this contract before completion of the matter at hand, is applicable at an times in this matter, My current hourly billing rate is $248.00 for legal services. Brad. . Law LLC agreee to eubmlt tbt bHRnl ~ctattd'4tfl ~·~to 1"· Arc Community Trust of PA, the trustee of the Karen Rubin INT, for conskktratlan for payment. You understand that payment from the Arc Community Trust of PA is entlrety dependent on the trustee agreeing to such payment You agree to be Individually rnponsible for any balance not paid by the Arc Community Trust of PA. Anticipated Otb§r ExReosel(COSts!Fees Other anticipated expenses, costs and/or fees of the any hourly legal work wlll Include any and all court filing.fees, service of process fees, any and all professional and other witness fees, subpoena fees and any other expenses, costs or fees that arise before, during and after this matter. For court related costs we do not indicate a dollar amount as courts can change them at any time. You should understand that Bradley Law LLC operates as a.firm-a client who retains a particular lawyer in fact ~Ins the entire firm and has at their disposal all of the expertise and resources that the .firm can bring to bear upon their legal problem. Therefore, the fawyer who serves as your principal contact at the firm may seek assistance from or assign primary respontibilities for a project to another lawyer who has experience in ~ particµtar area involved and who is for that very .reason In a position to do the work al·~ 81.~· Sh.·1> assigning work within the firm, we strive to achieve the most efftctent mix of senlodty and expertise, with the goal of providing effective representation to our clients on an economical and cost efficient basis. You authorize us to Incur all reasonable costs and to retain any investigators, consu!tants, or experts necenary in our judgment, with your input; advice, and consent, to pursue your claims. loltiid Pavmeots/ Fyjyre PavmentstBillioa As a matter of firm policy, for all hourly matters, we require the initial hourly tegat fee payment and any applicable costs to be paid in full in advance of any work being completed. 2 You agree to a non~ndable Initial payment of $0.00 In eonnectlon with our representation. Unless otherwise specified, alt legal fees and costs are non- refundable. For: all hourly matters, the initial hourly legal fee payment is non-refundable. Subsequent request for payment of hourly legal fees may be either by account (for services already entered, as· applicable) or futur~ non- refundable payments request, or in retainer form as specified below. When applicable,. it 11 our practice to forward periodic statements regarding any balanees. due on a monthly basis. We expect our statements to be paid In full upon raceipt. · unless another arrangement has been discussed and agreed to la advance; We reserve the right to impose a .late charge not to exceed the maximum amount permitted by law on all · amounts not paid within 30 days. Our current late charge is 1 % (one percent) per month. Retainer As a matter of firm policy, we require you to pay a minimum retainer against which we will blfl all related costs and other fees. You a9rM to deposit $0..oo as a minimum retainer In eonneetl~n with our representation. We will charge all related costs and other fees and disbursements against the advance and credit them on our blHlng statements. If the costs and other fees and disbursements exceed the advance deposited with us, we will bill you for the excess and p:>nibly for replenishment of the advance payment. You hereby grant Bradley Law LLC a security interest in and lien in any deposits of funds held by us as security for the payment of these expenses. You agree that we will have the right to request additional deposits from time to time based on our estimates of future work to be undertaken. Jf you fall to pay any additional deposit requested, we will have the right to cease performing further work and to withdraw from the representation. It is ourpractice to forward periodic statements on a monthly batis. We expect our statements to .be paid In full upon receipt, unless another arrangement hat been discussed and agreed to In advance. We reserve the right to impose a late charge not to exceed the maximum amount permitted by law on all amounts not paid within 30 days. Our current late charge ii 1 ~ (one percent) per month. Duties and Resoonsibl!ities . We witf provide legal services to you In connecti9tl wltb this. fKlG~~t. You..are not . . relying on tis for, and we are not providing, any business, Investment. m~,ora~ :~.;. decisions and you Ire not relying on us for any investigation of the character or credlt·of· · · parsons with whom you.may be dealing. Effective legal representation requires a high level of cooperation between attorney and cilent. By signing thi$ letter, you therefore agree to cooperate with us,.to keep us fully Informed of all developments, and to perform your obligations under this letter. We, In tum, wlll rely on the information that you provide to us. We agree to provide the legal services reasonably required to represent you with respect to the matters described above and to take reasonable steps to keep you informed of our progress and to respond to your Inquiries. You also will make yourself reasonably available to attend meetings, discovery proceedings and conferences, hearings, and other proceedings. Your responsibilities will also include approving negotiation, discovery and litigation strategy; approving causes of action and parties to any litigation; and determining acceptable terms of any compromise, settlement, or agreement. 3 . In addition, you will be responsible for advising us whether any document we have prepared or received and sent to you for your approval or review reflects the principal terms of your proposed agreement, general litigation strategy, or other expectations, as the cue may be, General Provitloos Enclosed with this letter is a statement entitled General Provisions, which sets forth additional terms and conditions, all of which are incorporated into this letter and apply to our representation to the extent not expressly inconsistent with this letter. Lggal LlaQ.ili\Y lnsurangg . Please be advised that Pennsylvania Law does not require attorneys to carry legal lf•bllJtrJnsuranoe. Of.le to the naturt of our practice. Bradley Law LLC htJ·~ to~q regal liability insurance and pass the savings on to our cllants In the form of lower tegal fees. Cqnfllcts To determine if you are involved in any matter adverse to our firm or to our clients, we have checked your name through our computerized conflicts checking system. This search has not revealed any such matter or conflict. We therefore believe that we will have no conflict in representing you in his matter. Nonetheless, we ask you to conduct a similar Check personaDy andtor within your company to determine whether you believe U.t any matterl might exist in which our firm may· be adverse to you. Of course, if you discover any such matters, please let us know immediately. We are a. small firm, however we do represent many other individuals. It is possible that, during the time we are representing a client and at any time following the conclusion of our engagement, some of our present or future clients will be engaged in transactions, or encounter disputes, with you or your subsidiaries or affiliates. You agree that we may continue to represent, and may undertake in the future to represent, existing or new clients in any matter that is not substantially related to our work for you even if the interest of such clients in those matters are directly adverse. to you or to any of your subsidiaries or affiliates, and to that and you hereby consent to any such conflict. We agree, however, to obtain your advance consent In any instance in which, as a result of our representation of you, we have obtained proprietarJ, confidential, or other: information of. a non-public natura th•t. if known to ,uch other dient. could be used In any such other matter to your material disadvantage or to the mat,r1111 clsadVtrtt• . of any· of your subsidiaries or affiliates. · We encourage you to participate actively in the matters we are handling for you, because you are much closer to the details than we are and we want to be certain that our efforts are consistent with your goals. If at any time you have a question, comment or concern, or if we may be of service in another substantive area. I ask that you raise it with us at once so that we can address the matter without delay. If the foregoing is in accordance with your understanding of the terms and conditions upon which you will engage us and .the nature of our engagement, please confirm your acceptance and sign the enclosed duplicate copy of this letter in the space provided for this purpose below and return it to me at your earliest convenience. Upon your acceptance, these 4 . tenns and conditions shall apply retroactively to the date we first performed services on your behalf. This letter will not become effective and we will have no obligation to provide legal ·services until you sign and retum the copy of this letter along with the fee/retainer. We are· pleased to have this opportunity to be of service and to work with you. Thank you. Sincerely, PATRICKJ; BRADLEY · I/we have re$d. and understand the terms and conditions set forth in this letter (iridudlng the attached General Provisions) and agree to them. Accepted and agreed to this _ _ day of _ _ _ _ __, 20_. Karen Rubin 2340 E. Norris St. Philadelphia, PA 19125 · Enclosure CC: FILE s Genpl erovisions Except as modified by the accompanying engagement letter, the following provisiOns will apply to the relationship between Bradley Law LLC and our clients: 1. The time for which a client will be charged will include, but will not be limited to, telephone and office conferences with a client and counsel, wttnenest consultants, court personnel, and others; conferences· among our personnel; factual Investigation; legal research: respQr1dlng to client's requests to provide information to auditors In connection with reviews or audits of fmancqu. statements: drafting of letters, pleadings, brief&, arguments, and other documents; travel time; waiting time in the court. closings, or elsewhere; and time in depositions and other discovery proceedings. t"' 2. From time to time, intemat conferences on a client's matter will take place among our . personnet_ aru:U\w ~more "''Y ~d ~uch conferences. ft is ourtprifn~ ~ ~ faclfftates communication; Improves the quality of work, and ultim•fy ls mote erftdtnt.and · .economical. 3. In addition to our fees, we will be entitled to payment or reimbursement for disbursements and other expenses incurred on behalf of a client such as photocopying, messenger and delivery, air freight, computerized research, videotape recording, travel (including mileage, parking, airfare, lodging, meals and ground transportation), long distance telephone, telecopylng, postage, court costs, transcripts, and filing fees. To the extent that we directly provide any of these services, we reserve the right to adjust the amount we charge1 and any time or from time to time, as we deem appropriate, in light of our direct costs, our ..timated overhead allocable to.the services, and outside competitive rates. Unless special arrangements are m&Qe, fees and expenses·of other (such as experts, investigators, witnesses, consultants and court reporter$) ind other large disbursements (in excess of $250.00) will not be advanced by our firm and will be the responsibility of, and paid directly by, the client. 4. Although we may, for a client's convenience. fumish •timates of fees or expenses that we anticipate will be incurred on a Client's behalf, these estimates are subject to unforeseen circumstances and are by their nature inexact. We are not bound by any eatimates except as otherwise expressly set forth in the engagement letter or otherwise agreed to by us In writing. · •• . 5. Either at the beginning or during the course of our representation, we may express our opinions or beliefs concerning the matter or various courses of action and the results that might be anticipated. Any such statement made by an attorney or other empl~~~ of cu fim.t. is . intended to be an expression of opinion only, based on Information available to U8 at the time and Is not a promise or guarantee of any particular r•ult 6. A client shall have the right at any time to terminate our services and representation upon written notice .to the firm. Such termination shall not, however, relieve the client of the obligation to pay for all services rendered and disbursements and other expenses made or incurred on behalf of the client prior to the date of termination and for services rendered and expenses incurred aft~ such date to. the extent they are required to protect our client's Interest or as may be required by appropriate authorities. 7. We reserve the right to withdraw from our representation with our client's consent or without consent for good cause. "Good Cause" may include the client's failure to honor the terms of the engagement letter, the client's failure to pay amounts billed in a timely manner, the client~s 6 . J fanure to cooperate or follow our advice on a material matter, or any fa<!t or circumstance that · would, in our view, impair an effective attomey~client relationship or would render our continuing representation inappropriate, unlawful or unethical. If we elect to do so, the client. will take all steps necessary to free us of any obligation to perform further, inQluding the execution of documents (including forms for substitution of counsel) necessary to complete our withdrawal, and we will be.entitled to be paid for all services rendered and disbursements and other expenses made or incurred on behalf of the client prior to the date of withdrawal and for services rendered and expenses incurred after such date to the e~ent they are required to protect our client's interest or as may be required by appropriate authorities. · a. We .have found that our clients have become increasingly reliant upon various forms of electronic communication, such as e-mail. cellular telephones, other Internet communication, and electronic telefax (collectively, "Electronic Communications•), for the purposes of day-t~ay business communicatiof'.'S. We note, however, that Electronic Communications may be in~ lest 8'CUte that some Crtditienal methods of oommu • wired ~one and telefax, U.S. Mail and commercial cerrlers, for example) and I risk Of interception by unauthorized third parties. We understand that. because of the convenience and efficiency Of Electronic Communications, you are willing to accept the risk Of unauthorized Interception and authorize us to communicate with you (and with others with whom we have dealing in · connection with the matters we are handling for you) be means of Electronic Communications, unless you advise us In writing to the contrary. 9. Any controvel'fy, dispute, or claim arising out of or relating to our fees, expenses, performance Of legal services. obligations reflected in this letter, or other aspects of our. repr8!entation shall be resolved through binding arbitration in accordance with the rules then. in effect .Of or administered by the AAA. and judgment on the award rendered may be entered in any court having jurisdiction thereof. YOU ACKNOWLEDGE THAT BY AGREEING TO ARBITRATION, YOU ARE RELINQUISHING YOUR RIGHTS TO BRING AN ACTION IN COURT AND TO DEMAND A JURY TRIAL 10. Following the completion of this matter, the firm will not be precluded from accepting any other engagement on behalf of a client that may be adverse to you if such engagement is unrelated to the scope of our representation in this matter as described above and provided, of course, that any and all information that may be disclosed to the firm in the course of this matter shall not be disclosed to any former, current or future client of the firm. 7 Prom: Sent: Andrew Coyle Tuesday, December 08, 2015 4:04 PM 'Patrick J. Bradley' RE: Rubin, Karen - Follow Up re: card To: SubJect: Hi Pat, I wanted to let you know that Karen Rubin's PNC card has been loaded for the month of December '15. She tried to contact me today but unfortunately I was not able to answer her call at that time. I wanted to give you a heads up just fn case she calls you. I will continue to try to contact her as well. Thank you. Andrew 'Ato.drew "":'¥ '. l'banksifw all the info. l'bis helps me understand much better. l'lt check with Karen about whether she physically lost the card or if she still has It and just wants to loaded. t'll 9et bade to you on this. Patrick J. Bradley Attomey & Counselor At Law Mql!J.ag Address: Bradley law LLC P.O. Box26S87 ,PA19426 Qffk& l.omflon; Bradley law LLC 3801 Germantown Pike Suite 201C Collegeville, PA 19426 484-902-0123 phone 484·902-0120 fax pb@dfey@bragleylawJlc.com From: Andrew Coyle [millto;A~org] Sent: Wednesday, December 2, 2015 4:23 PM To~ Patrick J. Bradley ........................... subjecb RE: Rubin, Karen - Follow Up re: card 1 Exhibit G Hi Pat, l wasn't aware that Karen physically lost her card? If so, a new one would need to be ordered and it will take at least a couple of weeks for this to happen as the card needs to be ordered, thev ship it to us, and then we mail it to the beneflciarv. What I can tell you that I have gathered over the last few conversations with Karen ls ves, receipts have not been turned In over the past couple of months which is why the card has not been loaded. I have spoken to Karen and she did tell me all of her receipts were lost a couple of months ago around the time she was hospitalized? Before this, Karen was fairly reliable with returning most of her receipts and did a pretty good job overarl. What I am allowed to do once (per The Arc's regulations) Is send a letter to SSA explaining the situation and alerting them that $200 should be viewed as Income to the dient. I am only allowed to do this once as we do not want our beneficiaries abusing the process or risking losing their benefits over the PNC card program. After this Is done, it's like wiping the slate clean and we can reload her card again for $200 With the understanding that all receipts must be handed in on a monthly basis. I went ahead and did this for Karen but I am not sure if the card will be loaded for this month (December, '15} or next but I will find out In a couple of days. Please feel free to share this Information with Karen. I have tried to call her but her phone does not have voicemail. If you have any other questions let me know. Thank you. inistrator The Arc Community Trust of Pennsylvania 1012 West Ninth Avenue Sulte215 (pJ~'980 (f) 610-215-4688 Andrew, Iam wrltlhl~this to you at the request of Karen Rubin. ~111111::~~!'!',,:,,, Karen is asking where her card is? l can assume from what I was able to pt from her, that she did not submit receipts (or perhaps she bought something ineligible). Is the Are sending her a card? If so, do you have a timeframe? I understand It is hard to get info from her so If none of this sounds correct please forgive me on that. r11 wait to hear back from you. Thank you for your time and attention to this matter. Patrick J. Bradley 2 . Attorney & Counselor At Law Mail'111J. Mdmss: Bradley law LlC P.O. Box 26587 Collegeville, PA 19426 Oft§ IR$qJlpn: Bradley law LLC 3001 Germantown Pike Sulte201C Collegeville, PA 19426 484-902-0123 phone 484-902-0120 fax 3 From: Patrick J. Bradley <pbradley@bradleytawllc.com> To: MOndil)', November 30, 2015 2:06 PM Andrew Coyle bernesa@bradleytawllc..com RE: 2015--092 Rubin, Karen - Request for PNC Card Info Cc: Subject: Thanks I Patrick J. Bradley Attorney & Courl$efor At Law P.O. 8ox26S87 Collepvilfe, PA 19426 pbradley@bridltvlawllc.mm PNm: Andrew Coyle {mllll:p;A~org] Sent: Monday, November 30, 2015 1:56 PM To: Patrick J. Bradley SUbject: RE: 2015..()92 Rubin, Karen - Request for PNC Card Info Pat, Here is what we send our benefldaries for the PNC program. If you or Karen hive any other questions let me know. Thanks. Andrew Coyle MS Trust Administrator The Arc Community Trust of Pennsylvania 1012 West Ninth Avenue Suite215 King of Prussia, PA 19406 acoy!e@an;trust,ora (p) 484-61()..7980 (f) 610.265-4688 1 Andrew, Iwas trying to explain the Nmltations and requirements of the card to Karen Rubin. Could you please do me a favor and send me the same Info you sent to her when you sl1n a client up for the card? I want to show her the documents (she !mt hers)explalnlng the program terms and conditior1s. I don't need her SPecim:: info, just a copy of the info you send out so I can reference ft when I show her. Any help on this would be appredated. ii''" Patrick J. Bradley AttoMey It Counselor At Law )ii!:-"'*-; Bradley LawllC P.O. lox 26587 CollegeVile, PA 11426 Qffice Location: Bradtev law LLC 3191 Germantown Pike Suite 201 c Collegeville, PA 19426 484-902-0123 phone 484-902..0120 fax 2 From: Sent: To: Cc Subject: Patrick J. Bradley <pbradtey@bradleylawUc.tom> Tuesday, November 24, 2015 1:48 PM Andrew Coyle bemessa@bradleylawflc:.com RE: Rubin, Karen - Follow Up re: SSI Info Needed Thanksl Patrick J. Bradley Attorney & COUnsetor At Law · ntown Pike SUite201C Col~e, PA19426 484-902..0W·phone 484-902..0120 fax I Prel'IH Andrew Coyle [mailQ;A'a'~r.g} Sant: Tuesday, November 24, 2015 1~43 PM To; Patrick l. Bradley SlllJftd: AE: Rubln, Karen • Follow Up re: SSI Info Needed Mr. Bradley, I did recen a taJI yesterday from Ml. HtnderiM:h and I 1=•1ed bar. t-1~.tqd teft a messa1e this momi111 around 10:3.0am. The print out of 111 SNT activity from August 2013'Uft1- prennt was put in the maft today so they should receive lt later on tflis week. Thank you. Andrew Coyle MS Trtt.St Administrator The Arc Community Trtt.St of Pemsylvania 1012 West Ninth Avenue Suite 215 Ki111 of Prussia, PA 19406 acoyll@trgngt.prg (p) 484-680-7980 (f) 610-265-4688 1 Mr.Coyle, t am following up fram my meeting with Karen and her mom yesterday at Karen's house. Karen has an SSJ issue that needs to be addressed In order to keep getting SSI. As you may have already heard frqm M&1Mlndenadl, Karen's mom, Karen needs a print out of atl SNT KtMty.on aceountfrom Augustl013 through to today. I understand Ms. Hlndenach leftyo1.1 a messa,e and she wlll keep1rM Karen's sister Barb is Karen's rep payee and will be reaching out to SSA to tetflive them the necessary info. fllfoltow up with them later this week. ~Wyou1 hawt any questions please let me know. Thank you ftr your time and attention to this matter. PatrlckJ. Bradley Attomey & Counselor At Law MolQm. Address: Bradley Law LLC P.O. Box 26587 Collegeville, PA 19426 3801 Germantown Pike SUlte201C Collegevifle, PA 19426 484-902-0123 phone 484·902-0120 fax 2 Andrew If 5ft!!! Ft'Om: Sent: To: Subject: Patrick J. Bradley < pbradleyObradleylawllc.c:om> Monday, October OS, 2015 1:48 PM Andrew Coyle Re: Karen R. Vouthemanl Sent from my IPhone Patrick J. lradlev Attorney & Counselor At I.aw uwu.c P.O. 8oK26587 ColleieYllle, PA 19426 . '.;; ORflltoc:atton: ·~·~~~ emdll,taw u.c 3801 Germantown Pike SUite201.C Collqevllle, PA19426 484-902-0123 phone 484-902-0120 fax > On Oct S, 2015, at 10~50 AM, Andrew Coyle <ACovle@arc:truttorg> wrote: > >Hi Pat, Thanks for the messase. I just spoke to Karen. She is a little confused on how to use our PM•LI system so I ga~ her my direct extension whtc:h wlll hopefully cut.down on some of the confusion. Tau are. > >Andrew Coyle MS >Trust Administrator >The Arc Community Trust of Pennsyivania > 1012 West Ninth A.venue > Sulte215 > King of Prussia, PA 19406 > 1c:oy)e@arc:trust.om >(p)484-680-7980 > (f) 610-265-4688 > > <Wlnmalt.dat> 1 Subject: Bradley law LlC <quickbooks-ernail@intuit.com> Monday, December 28, 2015 12:48 PM Andrew Coyle pbradley@bradleylawllc.com Invoice from Bradley Law LlC Fellow Up Rag: Duely: Rag Status: Monday, December 28, 2015 1:11 PM Flagged From: Sent: To: Cc Follow Up DUE DATE BALANCE DUE 12/2812015 $690.03 Dear Mr. Coyle, Trust Administrator at The Arc Community Trtl$t of PA, The inVoice f<:1r •ewien rendered to Karen Rubin, Beneficiary ii attached. r tuwa alMl forwarded a copy to Karen RUbln (clo har molher • Mary Ann Hlndenadl). If you have eny quedons plene let me know. Please remit payment at your earliest convenl&nCEI. Thenk you for your busi11818 - we appreeiate it very much. Sincel91y, Bradley Law LLC ........................... , l Exhibit H Pagel of 4 ......., ...... .,.......,.KllllnmtMintllllla•---~ ,_ ................ ~---l:dt11111! , ---lllllld)~fttdckJ....., i atmamftl il ilt 1 li4sl!1aalllll!lllatllupllllfn11111tPshe: .. jlllrM .. nl"1DHllltllldllOllfNpllita.talll~• 12'1-Gl. . .ClmiRJ j ! Jtapmftlllll:lt---·-·---~i i Wmillil llll:afm'pm tocal Mt: (I l llill'O•BllflllHfllmir •.-.dllllilm&.. t- ,,........................,. .. l lllillllge •• I.., ,_,..._lllilllPI' ~Pmlllk , . ..., , ....... ,...... !...__.._.._....................... 1:a •• 1. .. ,. ......,lllilllPIL-Pmlllk J . . . . https:lloonnect.mtuit.comlportal/modulelpdIDooltemplatelprintframe.blml 1121/2016 Page2of4 .......,,... MlpC111tlllll•-111Mt1Hlllllll11n.-ma.. _ _. lill.~c-.d88M!BillllliJID.tl afRl!!p . . . . . . . - .. . . . . . . . . . . .Hlll'll• . .~°"41 ljlhldnMllT-at:Qmdw .................................. .....,.,, 1-.-................. -.. ...... , 2. pOI'11111. .. Palliilllc , , . . _ tVIM!IDtl ..... ..,,... tltp1'Cftinlill.MlildllUL(tdll) ldD ...-....... ·-....-........ ... ............................... ,,.._ -p~-.-. _ , -- Palliillfc ta•1'CTct. . . . . . . . . .. - _ , , . _ . ........., _....,... . . . . . . . . . . . . • . . . . ..,.. Mil. . . . . . MBpliullD~ra:Cul~b'..._. ....,..._.• ._.ron,..•t11i.11:1111<aa . . . . . . . . . (3. . .) -- ..................... 216pN!dld-ttllfile1h111waf1111P11-*fDML .~ ..,1'CT ................ _ ... ) lrl . . ..,.pmTM)-~, ..... https://oonnect.mtuitcom/portallmodule/pdIDocltemplatelprintframe.btml 1l21120l6 Page3 of4 ................ l:ttpmf._,~--------Nw ---~·min) utpmf u..11111111111c1uur..,thn•••...._. . . . . . . . . . . . . .lillllllWlllddl'oriClln& . . . . . . . . . . . . . . . . (lmillQc•Blml•PIUIJ 1MMllllDU.lilpllewiH.1 l . . . . . . . . . . . . . . .~.-1'1 lll&t'fl' r .................- .. . . .11rt ..... ..._..__(ldnl)•Plidtk.I.._ 4Jl8 .......... ..., .................. GI plfmall..,._J!Oltaw. He• lllllmldMRLAHll!d : flHll'lll11-Mlllr'°*I lllildt(lmlnl)•PlidtkJ .... . . . . . . . . . .,,...,,,(3 mini) ......,,...,,,........ ••1C'l'...,..m.Gllc•H-C!ftb!Ul!111! ~ ••iall,;1'19_..CI__, - ••Olm .,... _,._,.,,,...,.lllllilll)· M:ldcJ8ndllr ............., . ,. . . . . . AdW• GlllWl:Mlil1'AllGlfd, Cl 11llinl) I :.......... l 4tap 1C'I' Klilllln'aam. Ld m 11111 e.atClllld Is l·J8ndllr lrt-~·---Plldtk https:l/connectintoitoom/portallmodule/pdIDoc/template/printfnune.html 112112016 Page4 of4 .......... •••'-•Nnnr ..................... ........ ----·--- t11.a..-.-1111nd ..-n1111 llaflnfa1e:-..mnmt.m-..1m1 1a -~-, ~tlRtllrdll'dlllllor-a.baapPlfHCD~ td'lin-----·-**~--· lmedt111Kinttll~hllllJllh--L- Pallklk.I- 1811103 https://oonnectintuitoom/portaJ/modt.lle/pdfDoc/tempJate/pdntfmme.html 112112016 from: Sent: To: Subject: Andrew Coyle Wednesday, February 17, 2016 10:04 AM Julianna Van Duyne·King FW: Invoice from Bradley Law LLC From: Patrick J. Bradley [mallto;pbradley(pbradleylawtlc.com] lent: wednesday, February 17, 2016 9:11 AM To: AndNw Coyle Subject: FW: Invoice from Bradley Law LLC Andrew, ts the Arc Trust going to pay this Invoice? It has been over SO days. Please advise. Patrick J. Bradley, JD Mqiltu,Mdress: Bradley Law LLC P.O. Box 26587 Collegeville. PA 19426 Qffjcg lg£,atlon: Bradley .Law LLC 3801 Germantown Pike Suite 201 C Collegeville. PA 19426 484--902.0123 phone 484-902.0120 fax Front: Bradley Law U.C [mallto:quickbooks-email@intult.com] Sent: Monday, December 28, 2015 12:48 PM To: acoyleOarctrust.org ca pbradley@bradleylawlc.com Subjec.t: Invoice from Bradley Law LLC ........................... Exhibit I ,... ..... ii .. Andrew Coyle ·10: Friday, February 19, 2016 9:33 AM Julianna Van Duyne-King FW: Rubin, Karen - Follow Up ~ Hi Julie, Pat Bradley Just called me and left a message and then sent an e-mail. Just you a heads up, Thants, Andrew Andrew, lam following up from my phone message of this morning. I needed to hear back from your organization on when you will be paying the Karen Rubin billing. It has been some time now. Please advise. Patrick J. Bradley, JD jfgiling4t/dress: Bradley Law LLC P.O. Box 26517 Collegeville, PA 19426 OJ/if;e LocatiQ/I: Bradley Law LLC 380l Germantown Pike Suite201 C Collegeville, PA 19426 484-902...0123 phone 484-902...0120 fax No virus found in this message. Checked by AVG - www.av1.wm Version: 2015.0.6189 /Virus Database: 4.533111654 - Release Date: 02118/16 1 --Odjlnal MessaseFrom: Julflnna Van Ouyne-King {mailto;,MmDyyneKingfiarctrust.orsJ -~ Ffitty, February 19, 2016 9:39 AM To: •patlfdc J. Bndtev {pbradley@b@dleylawllc,com)' Cc: AndrewCoyte Subject: FW: Rubin, Karen - Follow Up Mr. Bradley, on the advice of counsel, Ms. Rubin's trust will not pay this bifl as you were suspended from the practice of law during the Interval shown in the invoice. Julianna Van Duyne-King, J.D., LL.M. executive Director The Arc Community Trust of Pennsylvania 1012 West Ninth Avenue Suite 215 King of Prussia, PA 19406 P: 610-265-4788 F: 610-265-4688 CONFIDENTIAL NOTICE: The Information contained in this communication is privileged and confidential and intended only for the use of the individuals to whom they are addressed. If you are not the intended recipient or received in error, you are hereby notified that any unauthorized disclosure of any kind or actions taken in regard to the information Is strictly prohibited. If you received this communication In error please reply to the sender and delete the message from your computer system. Thank you. From: Patrick J. Bradley lmailtoiRWJdley@l}radlmaw11,.comJ Sent: Friday, February 19, 2016 9:29 AM To: Andrew COyle Cc: bemasal!bradllwllytllc.com<matl\Q:bernesaabradlevlawllq;om> Subject: Rubin, Karen - Follow Up Andrew, I am following up from my phone message of this morning. I needed to hear back from your organization on when you will be paying the Karen Rubin billing. It has been some time now. Please advise. PatrlckJ.Bradley,JD Malling Address: Bradley Law LLC P.0. Box 26587 Collegeville, PA 19426 Office Location: .......................... Exhibit J From: Sent: To: Cc Subject: Patridc J. Bradley <pbradley@bradleylawllc.com> Friday, February 19, 2016 9;48 AM Julianna Van Duyne·King Andrew Coyte; bemessa@bradleylawllccom RE: Rubin, Karen • Follow Up Ms.Van Duyne Kins, Thanks for finally giving me the courtesy of a reply. As I know your office is fully aware, my office provides legal and non-legal services. Your office has hired my office is the past for multiple case management matters, at a non legal rate for non legal services. As I am currently suspended, I only provide non legal services. My services to Ms. Rubin were non legal in nature. As I am sure you are also aware, non-legal services can be rendered in SSI cases. Now If you would feel more comfortable with my office changing the wording on the invoice please let me know. Otherwise, itll expect the bill to be paid In full ASAP. Please advise, Regards, PatrickJ.Bradley,JD Malling Address: Bradley Law LLC P.0. Box 26587 Collegeville, PA 19426 Office location: Bradley Law llC 3801 Germantown Pike Suite 201 C Collegeville, PA 19426 484-902-0123 phone 484-902-0120 fax abradlev@bradley!awt1c.com ........................!. Exhibit K . . From: Bradley Law LLC <quickbooks-email@intuit.com> Friday, February 19, 2016 10:10 AM Andrew Coyle; Julianna Van Ouyne-King ()bradley@bradleylawlc.com Jnvoim from Bradley Law LLC sent To: Cc: SUbject: CUE OU&; DATE 13J'\L.Rn\..c 1212812015 $690.03 Dear 2015-092 Rubin, Karen I Hindenach, Mary Ann, Your Invoice ii attached. Pleale remit payment at your earu.t convenienca Thank you for your buaiNta - we apprecille it wry l'flUCh, Sincerely. Bradley Law LLC No virus found in this message. Checked by AVG - www.avg.com Version: 2015.0.6189 /Virus Database: 4533111654 - Release Date: 02118116 . . . . . . . . . . . . .!. . . . . . . . . ..-!. Exhibit L ----------------------------------------------------------- Page 1of3 . . . . .u.o PA•llllll7 cru•t1m ............ ·- , ............. 11111•cna ••a. !fl..,,,,. l'flllnil D4I BL 11'1 71 11•• PA $ 8 ... -,.. ...... ~ 10ll 0.11 .*.... ------~. Tlllldltilri-CllllllllldaallimfD-•m -···--- ...----...... ............ ... --TO'f~ .. ------~ .,. ~ . . . . . . . .11i1114-~,J . . . . Hllldtlflal l"lllfllllllifm.-.lllll!I Pll• ....ll----..... ~ -·---••M11.-.o•...... __. --~fllrptDClftl~-- . . t 1Jllilitn5 .......... g • • a.11_,,_, ldlllilllll _________ ,_,t a.a ..., ......... ,..J ..., ..., m.---alll::eml'flllnil---~ · - - - - . . . . - -.• ~J ·-~~~ ltU7 Millt. .111. 111 lh 1111lit.CnamdSMB --.DJ1 11111_.._. ___ D' ......;;lilUmlJllt ~·---!'IL--- lrDmCl'ldlli\biiil'llr f.-.l'l!lm • Caml'!llt ~-----Kil:art-~ lwm.D'm m11-. _..,.,_ • • . . . . . . . . . . • , , llJIJ. 211pCl9da.·~Ja.dllr https::/lconnect.intuitcom/portal/modulelpdfDoc/template/printframe.html 211912016 . Page 2 of3 ' ..... /~ 0:11 1Mp1C-.l*.~.tt1RM) .... 1•·------~~- ... AlmTUIL(I . . . 141p. R!uth:1'JIU1Ulh--.Wt.~ p 1e"" o.11.,._.._..aa,1&ta~ .... ....J...,. 1••~._,nima.~(ra 1~ ·----Wt .............,.-,.,.. . ......., .......,., 1ea.a1C'to._Klnm._11M&r_.•.,_ 111111 dll!Maidl11111••. . . . llcl&~ll#p * .... I lllllhcuua ~ 1UlllBH& 0:14 GM1111111-• ----·---·•-.(3--1 ....., .... -- MAI 11.17 1.,. . ..,,. .~-~ atlpo.:su, &11111#•--- · - - , N111rflilllm Alm1lw(NI·,...... .-. ,,..., -·~-~--· ·~ l*.llt dbl • h • · - - - · - - Klnm.(6-.. .............. ...., Bp1CTl*.Mlnd1 11f1ti11>••-Pk$ 1111111815 Plltllll*··· 1! Id' •...a• ...................._. ,.................... ·•· 1:11 _, t:•··--~---tlml-- Wllllllll NtDGlllllllll&IAlm1lw p l:llpdldlllll.Mlnd ... IAI 11111111111 Paty 1:11 ••• •Pa111a11r l:lla1CT._...,_._.11111Nl'alll •fm1•1~-----.--·--.•• -~flmlnJ-•• 1 I p_., https://oonnect.intuit.oom/portal/modulelpdIDoc/template/printframe.html 211912616 Page 3 of3 ...,, ......... ..... GlllCl..---111; .......,......, j\it1i~ O:Gll ---~---.. ~ :le~•M:rl::IU:ig~ 121818':• '"·-~---"-- ....... ••10f...-.m::m11'm -· 0:00 Ugd- 24.!ID 1in1-• ~------- ----·~-Clllilid..(aaa} O:OI 4tS1110J...-.m::m. U1111 .... .... .... .... .M.11 I .,.__. 111~-----KafmN!cw. C3 11'11111. . . . .,...., Nm.-.n --...-·•1••·-=-... Ugd• • TO andkllfd tlmilll adt ll!llil , . . . . . . . . .,,. . . . . ................._ ........... ...,., . . . . . .41. . . . . . . . . . . .. . . ........... .... • 111111bfllP!ldnlt91111hi14il M:l!I.. . . . ~ . . . . . . . . . . . . ~ ~-~ n11lbalslull~--..ftla.j ___......,____If,_,_ MU'ilaliM ~--. https:/lconnect.intuit.comlportallmodule/pdfDoc/template/prlntframe.html 211912016 Patrick J. Bradley <pbradley@bradleylawllc.com> Friday, February 19, 2016 10:26 AM Julianna Van Duyne·King Andrew Coyle; bemessa@bradleylawtlc.com RE: Rubin, Karen • Follow Up Ms. Van Duyne King, Thank you for your reply to this email. Any reply to my last email about the invoice? I sent the revised invoice with the case management wording so you can be more comfortable. So that you are aware, if your office does not wish to provide payment of services rendered to Karen, as it has done in the past, I will have to pursue the matter directly with the client. Please advise as I wtll then send them a letter that the trust does not want to pay and ask them to pay. So that you are also aware, If the dient cannot pay in short order (this bill is almost 60 days past due, and we could have avoided that.if your office had simply replied in December/January in a timely faShion) t Will have to pursue a claim for theft of services in the local Ma11sterial District Court, which wlll lntrease the costs by an additional $142.00 +/· for simply flinl the tlalm. There may be·a higher cost as the defendant would be a Philadelphia County defendant and·the constable might have to add a fee for a different county. Although I am quite sure you know this, Karen is a person with a disability. She hi$ a track record of Issues. I have consistently assisted her with her issues. Vour office knows this and has rendered past payments on the services I provided. Both she and I dearly had the expectation, especially since your office was in communication with my office durine the time frame In question, that your office would follow through with payment of the Invoice as it has rn the past. For Karen's sake, I hope you don't let her down on this because you are playing some kind of game based on an "issue" you and I had with a different client. Your office should not be playine sames with people's lives. I'll await your reply in short order. Regards, PatrickJ.Bradley,JD Malling Address: ............................ Exhibit M Bradley law llC P.O. Box 26587 Collegeville, PA 19426 Office location: Bradley law LLC 3801 Germantown Pike Suite 201C Collegeville, PA 19426 484-902-0123 phone 484-902-0120 fax pbradley@bradleylawllc.com --Original MessageFrom: Julianna Van Duyne-King [mailto:JVanDuyneKing@arctrust.org] Sent: Friday, February 19, 2016 10:00 AM To: Patrick J. Bradley Cc: Andrew Coyle; bernessa@bradleylawllc.com Subject: RE: Rubin, Karen - Follow Up Our counsel in this matter is Stacey McConnell of Lamb McErlane. Julianna Van Duyne-King, J.D., LL.M. Executive Director The Arc Community Trust of Pennsylvania 1012 West Ninth Avenue Suite 215 King of Prussia, PA 19406 P: 610-265-4788 F: 610-265-4688 CONFIDENTIAL NOTICE: The information contained in this communication is privileged and confidential and intended only for the use of the Individuals to whom they are addressed. If you are not the intended recipient or received in error, you are hereby notified that any unauthorized disclosure of any kind or actions taken in regard to the information is strictly prohibited. If you received this communication in error please reply to the sender and delete the message from your computer system. Thank you. -Original MessageFrom: Patrick J. Bradley [mailto:pbradley@bradleylawllc.com] Sent: Friday, February 19, 2016 9:50 AM To: Julianna Van Duyne-Klng Cc: Andrew Coyle; bernessa@bradleylawllc.com Subject: RE: Rubin, Karen - Follow Up Ms. Van Duyne King, Kindly advise my office as to who your counsel is. 2 Julianna Van Duyne·King From: Sent: To: Cc: Subject: Patrick J. Bradley <pbradley@bradleylawllc.com> Tuesday, February 23, 2016 9:56 AM Andrew Coyle Julianna Van Duyne-King; bemessa@bradleylawllc.com Rubin, Karen - Overdose Last Week Team Rubin, I received a call from Ms. Hlndenach regarding the case management bill. She will be contacting Andrew and requesting that it be paid from Karen's trust. Update on Karen as of today (2/23/16): Ms. Hindenach Indicated that Karen overdosed on her Abilify on Tuesday (2/16/16) went to ER (her sister Barb drove her and mom}. The ER stabilized her. They sent her home. She appeared stabilized for a few days. Then this past Saturday (2/20/16) she was running around manic. This continued through Sunday. Her mom tried to 302 her (again) on Sunday, (mom went to Episcopal Pysch) but the psych hospital denied the admit. Mom had her go to the psychiatrist Monday. They diagnosed her with Oystonia and suggested they (the psych) will give her Abilify shots (needs to be approved by health insurance first), and Cogentin. Mom has been hiding pills from Karen and giving them out when needed. (She ls still on pills for Cogentin and mom is giving them to her - 1 Abilify pill and ~ a Cogentln pill. On March 1st 2016 Karen is supposed to go for an Abilify shot. (Then may continue shots- not pills -depending on situation. *I observed from last interaction with Karen that she now has many tattoos all over her (several viewable on her neck). She is hanging/has been hanging with a much different crowd over the past 9 months or so. I'll wait to hear back from your office regarding the invoice. Thank you for your time and attention to this matter. Patrick J. Bradley, JD Mailing Address: Bradley Law LLC P.0. Box 26587 Collegeville, PA 19426 Qfjice Location: Bradley Law LLC 3801 Gennantown Pike ........................... ~. Exhibit N Suite 201 C Collegeville, PA 19426 484-902-0123 phone 484-902-0120 fax pbradley@bradleylawllc.com No virus found in this message. Checked by AVG - www.avg.com Version: 2015.0.6189 /Virus Database: 4537/11683 - Release Date: 02/23/16 2 Bradley Law, LLC Your Special Needs Source In.Pennsylvania July 14, 2014 Mr. Matt Moyer & Mrs. Alexis Moyer 75 Race Street Bechtelsville, PA 19505 RE: ENGAGEMENT/ RETAINER AGREEMENT Dear Mr; and Mrs. Moyer The Rules of Professional Conduct for attorneys in Pennsylvania require that we enter into a written agreement describing the basis upon which you will be charged for professional services performed by our firm. This letter and agreement sets for the tenm and conditions upon which Bradley Law LLC will perform legal services for you in connection with the matters discussed below. Jn addition, because you are a new client of our firm, I thought it would be helpful to confirm the scope of engagement and to provide you with a general overview of our billing procedures. We are pleased with your decision to engage Bradley Law LLC to represent you and we look forward to working with you. Scope of Engagement I understand :from our recent discussion that your objectives are as follows: 1. Assist you in obtaining one (1) supplemental needs trust and one (1) payback trust for the benefit of your son, Dakota Moyer. 2. Assist you in obtaining two (2) mirror wills with pour over provisions to the supplemental needs trusts. Although it is always difficult at the outset of representation of a client to describe with precision what will be involved, it is our understanding that we will provide all legal services reasonably required in connection with the matters descnDed above. If the scope of our services is enlarged beyond that described above and if we detennine that a fee arrangement different from that descn"bed in this letter would be appropriate, we will reach agreement with you on a separate fee arrangement for the additional work. While this letter is intended to deal with the specific legal services described above, these terms and conditions will also apply to any additional legal services that we may agree to provide that are outside the initial scope of our representation. ........................... Exhibit 0 Office Address: Bnldley Law LLC 3801 Germantown Pike, Suite 201 c Collepvitle, PA 19426 (Please Reply To Mailing Address) (484) 902..0123 phone (414) 902-0120 fax pbradley@bradleylawllc.com Malling Addnm: Bradley Law I.LC P.O. Box26587 Collegeville, PA 19426 Fees, Disbursements and Other Expenses-Staffing Legal work varies greatly. Although we are often engaged by our clients to perform specific and limited tasks, our primary role as legal advisors is to offer our knowledge, experience and independent judgment. Recognizing this, our focus in charging for services is to arrive at a fee that is fair and appropriate considering all the circumstances. Among the factors that we consider in establishing a fee are the following: the time (measured in tenths of an hour) devoted to a particular matter and the lawyers and paralegals who worked on that matter; the nature and complexity of the work performed; the expertise required to perform that work; the novelty and difficulty of the legal issues presented; the extent to which the urgency of the matter preempted other work; the extent to which the matter required special allocation of firm resources and staff overtime; the result obtained; and the amount typically charged by comparable firms for the same or similar work. For the present, I will be principally involved in these matters. The fees for each service are: l. My FLAT FEE for drafting and executing the two (2) special needs trusts (1 supplemental and 1 payback) is $650.00 total. 2. EXPENSES for mailing the payback trusts by priority mail to the 5 locations is $35.00 total. 3. My FLAT FEE for drafting and executing the two (2) Mirror Wills with pour over provisions to the supplemental needs trust is $325.00. As this matter involves a flat fee, an hourly fee is only applicable in the event that unknown and/or unforeseen circumstances arise which must be handled during and/or after the initial matter(s) or in the event that legal services are terminated by either party to this contract before completion of the matter at hand. My currently hourly billing rate is $245.00 for legal services. You should understand that Bradley Law LLC operates as a firm-a client who retains a particular lawyer in fact retains the entire firm and bas at their disposal all ofthe expertise and resources that the firm can bring to bear upon their legal problem. Therefore, the lawyer who serves as your principal contact at the firm may seek assistance from or assign primary responsibilities for a project to another lawyer who has experience in the particular area involved and who is for that very reason in a position to do the work as efficiently as possible. In assigning work within the firm, we strive to achieve the most efficient mix of seniority and expertise, with the goal of providing effective representation to our clients on an economical and cost efficient basis. You authorize us to incur all reasonable costs and to retain any investigators, consultants, or experts necessary in our judgment, with your input, advice, and consent, to pursue your claims. It is our practice to forward periodic statements on a monthly basis. We expect our statements to be paid in full upon receipt, unless another arrangement has been discussed and agreed to in advance. We reserve the right to impose a late charge not to exceed the maximum amount permitted by law on all amounts not paid within 30 days. Our current late charge is 1 % (one percent) per month. 2 Retainer AB a matter of finn policy, we require you to pay a minimum retainer against which we will bill all related costs and other fees. For the trusts and Mirror Wills, you agree to deposit $1010.00 as a minimum retainer in connection with our representation. We will charge all related costs and other fees and disbursements against the advance and credit them on our billing statements. If the costs and other fees and disbursements exceed the advance deposited with us, we will bill you for the excess and possibly for replenishment of the advance payment. You hereby grant Bradley Law LLC a security inter_est in and lien in any deposits of funds held by us as security for the payment of these expenses. You agree that we will have the right to request additional deposits from time to time based on our estimates of future work to be undertaken. If you fail to pay any additional deposit requested, we will have the right to cease performing further work and to withdraw from the representation. Duties and Responsibilities We will provide legal services to you in connection with this engagement. You are not relying on us for, and we are not providing, any business, investment, insurance, or accounting decisions and you are not relying on us for any investigation of the character or credit of persons with whom you may be dealing. Effective legal representation requires a high level of cooperation between attorney and client. By signing this letter, you therefore agree to cooperate with us, to keep us fully informed of all developments, and to perform your obligations under this letter. We, in tum, will rely on the information that you provide to us. We agree to provide the legal services reasonably required to represent you with respect to the matters described above and to take reasonable steps to keep you informed of our progress and to respond to your inquiries. You also will make yourselfreasonably available to attend meetings, discovery proceedings and conferences, hearings, and other proceedings. Your responsibilities will a1so include approving negotiation, discovery and litigation strategy; approving causes of action and parties to any litigation; and determining acceptable terms of any compromise, settlement, or agreement In addition, you will be responsible for advising us whether any document we have prepared or received and sent to you for your approval or review reflects the principal terms of your proposed agreement, general litigation strategy, or other expectations, as the case may be. General Provisions Enclosed with this letter is a statement entitled General Provisions, which sets forth additional terms and conditions, all of which are incorporated into this letter and apply to our representation to the extent not expressly inconsistent with this letter. 3 Legal Liability Insurance Please be advised that Pennsylvania Law does not require attorneys to carry legal liability insurance. Due to the nature of our practice, Bradley Law LLC has decided to forego legal liability insurance and pass the savings on to our clients in the form of lower legal fees. Conflicts To determine ifyou are involved in any matter adverse to our firm or to our clients, we have checked your name through our computerized conflicts checking system. This search has not revealed any such matter or conflict. We therefore believe that we will have no conflict in representing you in his matter. Nonetheless, we ask you to conduct a similar check personally and/or within your company to determine whether you believe that any matters might exist in which our firm may be adverse to you. Of course, if you discover any such matters, please let us know immediately. We are a small firm, however we do represent many other individuals. It is possible that, during the time we are representing a client and at any time following the conclusion of our engagement, some of our present or future clients will be engaged in transactions, or encounter disputes, with you or your subsidiaries or affiliates. You agree that we may continue to represent, and may undertake in the future to represent, existing or new clients in any matter that is not substantially related to our work for you even ifthe interest of such clients in those matters are directly adverse to you or to any of your subsidiaries or affiliates, and to that end you hereby consent to any such conflict. We agree, however, to obtain your advance consent in any instance in which, as a result of our representation of you, we have obtained proprietary, confidential, or other information of a nonpublic nature that, if known to such other client, could be used in any such other matter to your material disadvantage or to the material disadvantage of any ofyour subsidiaries or affiliates. We encourage you to participate actively in the matters we are handling for you, because you are much closer to the details than we are and we want to be certain that our efforts are consistent with your goals. If at any time you have a question, comment or concern, or if we may be of service in another substantive area, I ask that you raise it with us at once so that we can address the matter without delay. If the foregoing is in accordance with your understanding of the terms and conditions upon which you will engage us and the nature of our engagement, please confirm your acceptance and sign the enclosed duplicate copy of this letter in the space provided .for this purpose below and return it to me at your earliest convenience. Upon your acceptance, these terrµs and conditions shall apply retroactively to the date we first performed services on your behalf. This letter will not become effective and we will have no obligation to provide legal services until you sign and return the copy ofthis letter along with the fee/retainer. 4 Generai Provisions Except as modified by the accompanying engagement letter, the foUowing provisions will apply to the relationship between Bradley Law LLC an4 our clients: 1. The time for which a client will be charged will include, but will not be limited to, telephone and office conferences with a client and counsel, witnesses, consultants, court personnel, and others; conferences among our personnel; factual investigation; legal research; . responding to client's requests to provide information to auditors in connection with reviews or audits of financial statements; drafting of letters, pleadings, briefs, arguments, and other documents; travel time; waiting time in the court, closings, or elsewhere; and time in depositions and other discovery proceedings. 2. From time to time, internal conferences on a client's matter will talce place among our personnel, and two or more may attend such conferences. It is our experience that this practice facilitates communication, improves the quality of work, and ultimately is more efficient and economical. 3. In addition to our fees, we will be entitled to payment or reimbursement for disbursements and other expenSes incurred on behalf of a client such as photocopying, messenger and delivery, air freight, computerized ~ videotape recording, travel (including mileage, parking, airfare, lodging, meals and ground transportation), long distance telephone, tele-copying, postage, court costs, transcripts, and filing fees. To the extent that we directly provide any of these services, we reserve the right to adjust the amount we charge, and any time or from time to time, as we deem appropriate, in light of our direct costs, our estimated overhead allocable to the services, and outside competitive rates. Unless special arrangements are made, fees and expenses of other (such as experts, investigators, witnesses, consultants and court reporters) and other large disbursements (in excess of $250.00) will not be advanced by our firm and will be the responsibility o~ and paid directly by, the client. 4. Although we may, for a client's convenience, furnish estimates of fees or expenses that we anticipate will be incurred on a client's behalf, these estimates are subject to unforeseen circumstances and are by their nature inexact. We are not bound by any estimates except as otherwise expressly set forth in the engagement letter or otherwise agreed to by us in writing. 5. Either at the beginning or during the course of our representation, we may express our opinions or beliefs .concerning the matter or various courses of action and the results that might be anticipated. Any such statement made by an attorney or other employee of our firm is intended to be an expression of opinion only, based on information available to us at the time and is not a promise or guarantee of any particular result. 6. A client shall have the right at any time to terminate our services and representation upon written notice to the firm. Such termination shall not, however, relieve the client of the obligation to pay for all services rendered and disbursements and other expenses made or incurred on behalf of the client prior to the date of termination and for services rendered and expenses incurred after such date to the extent they are required to protect our client's interest or as may be r~quired by appropriate authorities. 6 7. We reserve the right to withdraw from our representation with our client's consent or without consent for good cause. "Good Cause" may include the client's failure to honor the terms of the engagement letter, the client's failure to pay amounts·billed in a timely manner, the client's failure to cooperate or follow our advice on a material matter, or any fact or circumstance that would, in our view, impair an effective·attomey-client relationship or would render our continuing representation inappropriate, ·unlawful or unethical. If we elect to do so, the client will take all steps necessary to free us ofany obligation to perform further, including the execution of documents (including forms for substitution of counsel) necessary to complete· our withdrawal, and we will be entitled to be paid for all services rendered and disbursements and other expenses made or inCurred on behalf of the client prior to the date of withdrawal and for . services rendered and expenses incurred after such date to the extent they are required to protect our client's interest or as may be required by appropriate authorities. 8. We have found that our clients have beoome increasingly reliant upon various forms. of electronic communication, such as e-mail, cellular telephones, other Internet communication, and electronic telefax (collectively, "Electronic Communication!>"), for the purposes of day-to-day business communications. We note, however, that Electronic Communications may be inherently less secure that some traditional methods of communication (hW:d wired telephone and telefax, T:J:S. Mail and commercial carriers, for example) and involve the risk of interception by unauthorized third parties. We understand that, b~use of the convenience and efficiency of Electronic Communications, you are willing to accept the risk of unauthorized intefception and authorize us to communicate with you (and with others with whom we have dealing in connection with the matters we are handling for you} be means of Electronic Communications, unless you advise us in writing to the contrary. . 9. Any controversy, dispute, or claim arising out of or relating to our fees, expenses, perfonnance of legal services, obligations reflected in this letter, or other aspects of our representation shall be resolved through binding arbitration in accordance with the rules then in effect of or administered by the AAA, and judgment on the award ·rendered may be entered in any court having jurisdiction thereof. YOU ACKNOWLEDGE TIIAT BY AGREEING TO ARBITRATION, YOU ARE RELINQUISHING YOUR RIGHTS TO BRING AN ACTION IN COURT AND TO DEMAND A JURY TRIAL. 10. Following the completion of this matter, the finn will not be precluded from accepting any other engagement on behalf of a client that may be adverse to you if such engagement is unrelated to the scope ~four representation in this matter as described above and provided, of course, that any and all infonnation that may be disclosed to the finn in the course of this matter shall not be disclosed to any former, current or future client of the firm. ,• ... 7 Bradley Law, LLC Your Sl*ill lbd&S-CO ta f'lm)t..U Janumy 21,2015 Lesley Oakes/Marie Newell Office of General Coumcl 801 Mu:Ut: Street SuitoSOSS Pbiladelpl>ia, PA 19107 RJI:: DAKOTA A. MOYER.SPECIAL NEEDS TRUST (OBli 93/PAYBACK) Dear Ms. Oakes/ Mr. Nowell, If you have any questions or conccms about the trust please do not hesitate to contact our ofti.ce. PJB:kaun Attacbmeot ec: M. Stokel- SSI Program Office Supervisor- SSA Office- Benes County Supervisor- OHS Berks Co. Assistance Otlice Supervisor- 'Ibin:l Party Liability Section Harrisburg FILE OGica~ ·----•lillillll•------·· ." BrldlqLawLLC llOI Oma un adfkc, SUiia 201 C CopffromDPWPEAPsyatem ~Rcplyli>Mtdia&Addlm) {414t!J02.0l2l~ (4M)90a.0120 fiui * Exhibit P ......., The Dakota A. Moyer Special Needs Trust (OBRA 93 I Payback) l AROO·B J. CHEATIQN or nm TRUSI 1.1 p§Jagtiop ofTrust.. ••••• l•••••""-:-.. , A-rc:fcrodtoasthe property listed in Schcdulo A (~;u.-. % llWniD'after rofemll to u the Trustees) to Iii trust, for the bcmeBt of Dakota A. Meyer (herolmdler rcfem:cl to 11 the Beneftdary). as specified heroin. 1.2 fntmt to Cmtt a Tmst. The Settlor intends that ti1 documatcreate an imwocablo spccill needs crust for the benefit of the Beneficiary, as specifie4 horein, durina the Benefldary1 s Ufedmc under andsubjcctto42USC1396p(dX4),61PS1414, and SS Pa.Code 178.?(t)(l). 1.3 Intent to Mm the Inm IrreypcabJe. Tbia tntst aball be irmocablo and cannot be revoked or cerminated by any party to the trust except as speclliod hereio. J.4 lAtmt to Maki She Tmst Swmlm;mal, This tmst sbaU be supplcmenta1 ill nature, lbat is, it shall supplement and not supplant any and all pl.lbliclgowmmental 'bcnetlts and/or pmgrams available to the Beaaficimy. Public:lpvcmmental benefits and/or pmpams shall include, but are aot limited to, Modicalcl (MA) programs and benefits, bdudblg Waiver fimdins; Supplemental ~ lncomD (Sst)'beaotlts and programs; federal. state and local/count)' housing progiaml; other programs, services and/or f\mdins as well as any other publicl7 or nonpublicly t\Jndcd services or supporta provided by any federal, state or local agency or public or non-public entity. 1.S Intent to MaQ the '[mg Qiartlionary. The Trustees shall have sole. absolute, unfettered and \llll'CStricted dis=tion to make. or not~ distributions under~ trust as specified bcroin. 1.6 Dt1o of She TW§L .Thia trust shall be known as the Dakota A. Moyer Special Needs Tnut (OBRA 93/Pay~).' ARTICLE u. PARTIES TO nm mus:r 2.1 Settlgra. 2 2.2 Trustees, 9[ TbcT~ I llmdcim1 2.3 £ 11=:'= Udlidll) , • Bcno&ciary, ~ta,.. MoJ• 5 I 1 Dakota A. Moyer i9 a resident of Penmylvania. ua r 2.4 Rrmindpan. The RemaJnderman under Ibis trust arc: A. The Natural lssuo of Dakota A. Moyer (as a class) B. ~. D. both•£•• Truatecs upon tho death, msigDadon or iacapaci&y of 1baD be I I I , Co-Successor Should only one of either resian m: otherwiac bo '11l8b1c to aervt:, 1M rwaainlDa Tmtee may call upon the Sncc:cssor Trustees to serve uCo-Trostecs along with the remaining Trustee. AR'OCLE UL TRUSI E&OPBR.TY . 3.1 loitia1 Trust Propmy. The property listed on Schedule A. (attached) shall setVe as tho initial trust property. I 3 Copy fn>mDPW P!AP s~ 3.2 Source oftbo Imst ProJ>erty. . . The source of the trust property is DlOllC)' from the Bcncfic:ahy• 3.3 Lfmilali~g on tbl Jnitial Tmst PJ'RDeltL Neither tho initial trust property. nor any interest or income lcmeratcd by tho initial trust propod:y. shall be comidored u tu mdlablo asset or resoaroo to the Benc6iary for any'purposes genmlly and spocifically for detmmining the Beu.6cfary•s clip'bility for any put. present and/or fbturc publiclgovcmmcntal benefits and/or paograms. 6RDCLB IY.@DmONS TO 4.1 nwrr PR.QPBB.IY PerJpjgd A. . . &o TUI Progeny. Any propcs;ty or mmdes in any naso-.ble fbtm that ii deemed acceptable by the Trustees"p11y be added to and become put oftho trust propcatJ. All addltiou, outside of acuw income or interest, shall be considered pripcipal, and shall be adckd to the property a.sauch. +.2 bm»ttol asmma gf Additiou io tho Trust PJ9.mm. Any person or eadty slmll be ponnlttcd to prtlSCDt propmty of monies to the Trustees for consideration for additioa to the Wit property. including tho Bmcficiary. 4.3 . No addidom to the trust property, nor any intoreat or lacomo goncratecl by any additions to the trust propoity ahalI be considezed as an avallablo asset or resomae to Cbc: ~for any purposes pnenUy and spcci&ally for dermnfning the Bemlficialy's oUp"bility tor any~ proscnt mdlorfuturc publidgovemmental benefits m.ul/or programs. No addidons lball be permitted after the Bc:neficlar)''s 6511t birthdayuulas pctmitted by then existing law. ABDCLB V. P0WBBB OE IBli SBIJ],,OBS S.1 LimiepdJ>owcq, The Settlors shall have all the powers of a Seu.tor over a ttust in Pconsylvania. ln addition to those powers, the Settlom Main only 1he powers listed in this ttust and only to the extent that the powers apcclficd herein do not affect or alter, in any manner, the irrevocable special needs uaturo ofthis mast. S.2 Llmitld Powa: U> Ammin& Succmor TOJ1tft(1l. The SeJt).ors shall have the power to appoint a S~r Trustee or Successor 4 Trustees only in Oie event tbat an the named Tnmees and named Successor Trustees arc otherwise unwilling or vnablc to pcrfcmn or continue to perform as Trustees and no other Saceuaor Tmstee has been nominated or otherwise identified u specified hcrdn. This riabt is not issiaaab1e and tenninates upon tho death or incapacity of both Setdors. Written nodce ofappointmcDt of a Suocasor Trustcc(s) must be provided to the then existing Trustees and Successor Trustee, u applicable. to provido adequate oppommlty "? lmll1F for a smooth tranaition to tho new appointee. . ABJ1CI.£ YI. POWEBS PF nmmwmms 6.1 Bgdloytm. The Trustees shall have alt the powom of a Trustee over a trust in Pennsylvania as well u any other powen nccossary, which abaU include tho power to hire any necessary profeaioaal or other scrrices, including but not Umlted to aay lepl or case maaapment services. to assist with the Olderly administration of Chis trust. nu provision shall be consttucd broadly and shall not be limited in any capaoity. 6.2 Is>IBI Djscretjog on Di$ibutions. The Trustees shall have sole, absolute, unfettered and unrestricted discretion to make or not mako any distributions under this trust, u speoified hcrciB. 6J POJIKto Malt dg Trust. lbe Trustees shall have the power to amend tho emst whoa it is m:ccssary to c:mum complfaneo with and ooatmmmcc to applicable WomI. slate and local laws, reguladonl and pmceduRs. u well the rcquirem.mts of any govcmmomal qency, as specified in the trust hcrciB. Any sudt amendment slmll not affect tho lmwocahle spacial na:d$naturc of ctds trust. 6.4 PQMC tg DMipatc a Cgmorate Ftduciarv Co:T~ Tho Trustoct, in their sole absolute and unfettered discreelon, shall have the power to amend the trust to include a coqioa non-profit Co-Tiustee, includin& but not limited w. Tho Al.o C-ornmunity Trust ofPA. Inc. or the Family Trust, Inc., for the purposes of assisting in the~- of the trust. Said coq>orate non-pro&t ea.Trustee shall have the·samc powcu and duties u a Trustco listed berci.n. 6.S Pgwer tg Cmte ID lruyocablc Dqdal band or Other Fgral Ammgammts. Tm Trustees may create an hrcvocablc Burial Fund or other funeral ammgements, including. but not limited to pro-paid arrangements, with funds &om the trwll property. This may also include the pwchase of a plot and a marker. ABDCLB VU. POWERS OF DIE BRNEFJCIARY 7.1 IJmitatjOQli . Tho Beneficiar,y shall have no now powers created under this trust document, but shall retain aU powers applicable under the law. 1.2 SpeciaJ Na a.usms. Tho BenoficitQ' may make special noeds requests ftom time to time, or on a regular basis, lo the Tmstccl. These requests a not binding mt the Truateea and at all tmaos shall be subject to the sole. absolute, unf'cltmed and muutrlctld discrcdon oftho Trustees. . . AR.DCLB YUL DJSTIWMJONS fROM 1J1B TRUST S.1 Dliributions OemrallL During the Ufedme of the Beneficiary, the Trustees may, in their sole, absolum. uatcttcl:ed. and unrclllicted. discreti.oD. and after comldcdng Article Vlll in its adircty, make or not maa dimibations &om the principal aadlor income of1hc uust property for tho special needs oftlle Beoeficiar:y, as speclfted herein. 8.2 Jptept of settlon R!pnlina Di&ibutions· It Is the in;teat of the Sottlom dmt tho ltvlt pcoperty, includin1 all principal, intorcstaml income. rbaD be used solely for tho lpCCia1 needs ofthe BeDdlciary, ancl as otberwisl specified herein. Tho spodal noeds of tho BonoticWy shall be II! ltem(s) or serrioc(s) 1bat ealml9C(s) or lmprove(s) the quality oflife ofthe BeneficitQ', subject to .ftutber limkatioD. or oxpansion, by law and fbrthor subject to the timitatiom of tho trust herdn. 8.3 J>pdog ofTrust. It is cbc inteDt of tho Sotllors that 1be uust property, including all principal. inrerai and income:. income need not last for tho entire Hfedmo of tho Beudcimy, and tl1at tJie trust property sbou14 not be managed or administered in such a manner. 8.4 Consideratipn ofJ!ubUc/OoYJmDMmtal Bwfils, · In coqjuaction with Seotkm 1.4, it is tho intent of the Scttlors to maintain the nwdmumlevol of public/~ benefits and/or poanms for the Beneftciary. At such, botQfC inf 4l*ibutimt of 1rUst property can be made, the Trustees must tab into consideration IA)' publiclgovcmmcntal bcnct1ta amllor programs that may be available to 'the Beneftciary and shall give conslclemll.on as to whether or not such distribution would atrcct tho Beneficiary's past. current or fUture eJiaibilty for such publicfgovemmont.al bencfdl aadlor programs. 6 a.s Relation to Disability, Before any dimlbution oftrust property can be made tho Trustees must take into cons&deraeion how 8UCb distribut.lOll relates to the Beneficiary's disability and pve consideradon to wbecher or not such distribution would enhance or improve tho quality of life ofthe Bcae6ciar:y. · 8.6 Compwadon of Trustees, The Trustees may be compensaled from the trust property on a regular basis for services nmdcred to or tbr the crust and/or to or for the Bcmeficimy. Compcmation au be llmited to actual eosts. aludiDa prevailing JRS mUcago 11tes at~ time ineurred, ud reasonable hourly rates fqt other services actually rendered. Por corporate Co-Trustees. if any, compensation sha1I be limited to the then existing fee schedule, u applicable. ARTICLB JX. 9.1 DV11ES OF lll~ Imst Mpipj!dr!tioo,, ~ · . The Trustees shall be responsible to administer this trust for the bonofit of the Beneficiary. · The Trustees shall moot fivm time to dmo, at a minimum of once mmually, w11h tho ~lmy. to diaouss ad determine & manapment strategy, aakins into aceoant the purpoa ud contents of this trust. that II qreeablo to all parties. 9.2 Pmcmdnedm o[AJJocgion ofJncpmp, . Tho Tmslocl shall defarmine what is considcrcd income and wllat is comiden:d principal of the tt:ust property. 9.3 . Dctgmlqatioq of Costs. Tho Trustees shall determine all costs, cxpcmos. taxcs an4 diaries in any form apinst the trust property u wol1 u whether to alJocato them apiast principal, interest or ineome of the trust property. 9.,4 . &aP1iDa .BlsmilJ.IRPWL As required bf applicable law, the Trustees are or may bo required to submit notice of ·any/all changes in pmies and/or amendmcncs to dais crust. applicable cDsburscmcncs fmm and actual termination of dais trust to tho following: A. The Berks County Assistance Of6c:o of the Commo~th of Pcnnsytvania•s _D~ of Public Welfare. B. CoPJ hm DPW Pl!AP 1ysttim Oft1eo or Ocneral Counsel Commmwealth of Pemllylvania Department of Public Welfare 7 :-- ---- 801 Market Street Sui1o505S PbiJadclplda, PA l9I07 C. · Thc·Soeial Security Administration oftice for Berks County, Pennsylvania D. S~l Propam Support Team Altel)don: ·Team Leador Mld.-Atlanti.c Program Servlcc Center 3rd rmcl Sp:ing Oanlca Stncts Philadelpbia, PA 19101 B. The Spedal Nocds Trust Depository Attention: Manager, TPL Sectioa P.O. Box '416 Hmbburg. PA 17105-1486 P. The Clerk of Orpbaas' Court of the Court of Common Pleas of Berks Cowtt.y, Pennsylvania (TrustH- or her SuccossorlR.c:maindctma G. H.~orhil~ L ,I ., ;Beacficisy) Remainderman) .J. K. ~rTrustoe) L. tar J Cacc:asor Trustee) 1.bo Tmsteu should only pNVido information to any odlCr publk/pvammental agency~ other entity administering pUblldpvcmmental benefits or program upon written rcqucst, or u odietwisc required by law. The Trustees shall sm,mit to the Bonofieilayt or the Bcneficiaryts legal repmeutative,.rmy and all requested doaumemadon upon writ1on request. Limi11tion ofIMt@es LiabUity. 9.5 No Trustees under this trust shall be held liable, at any time, for any act or failwe to act, or any act or faDurc to act of an ageat or any other pmoo. or entity'in coanectlon with the admirdatradoa of this trust or tho trust property, unless caused by a Trustee's gn)a nqligence or a willibl act in breach of trust. . . 8 9.6 SpessorTrustw. Ifany named Trustee ii unable or unwllliu1 to serve. the dscn remainin& Trustee. or Tl'llSleoS as ltpplicablc, may call upon the named Successor Trustee{s) to serve as CoTrustce with the n:maiains Trustec(s). The SUcccasor Trustee(s) sball USllme all powers and duties of a Trustee under this trust. 9.7 No Bond RemrimL No·botid ahaD be iequired of the original Trustees ororipm.I Sucoessor Trustee. bonver, bond may be rcqukcd of any cmporato non-profit CO-b'UStlO as the pardes see fit, or as nquired by applicable law. ABDCLB X. IBBMIN4TIQN OEDil TB.QST AND . EINAL Dii11UIUllQHOEDusI PROPBRty 10. l TcrmJPdgn Byenf& 'Jhls Trust shall terminate upon the occummco of any one of the following eondJtions: B. By order of a court or competent jurisdicdon. C. By determination of the Trustees that it is impractical to continue to administer this trust; l. Bccauso the priuoipal, income and interest Jim: been dopletcd to a · mlnfmal amount (under $2000.00) with no reasonable oxpoolation of lbture additions to the trust property; or %. Bocausc the trust can no longer meet tho Beno6ciary's special needs: or 4. Bacausc to do so would violate the terms ofthis trust. 10.2 FAI Qll1ribucion ofTnm Prqpcrty. Upon the tonnhmtlon of the trust, the Tmsteo shall: A.· Notify the Commonwealth of Pennsylvania and any applicable Medicaid agericy from any other state and shall reimburse the Commoawealth of ~lVadia, and any applbblc Medicaid ageoey ftom eay other state. for any valicl lien for medical assistance or other valid lien for eligible 9 bcne5fl received by the Beneficiary, but only to the extent iequired by then ox.isting law, 6:om the then remaining tmst property. Iftheco am licns &am multiple states and the amount remaining is insamcient to pay back each stat.c in its eatirety, the amount remaining shall be prorated between the states proportionate to the amount of the liens in question. After making u.y payback required in Section 10.2 A. above, Trustee sball: B. Distn"butc the rmnainin911'Ust property to the Beneficiary, if living. If tho Beneficiary is deccasecl and no disuibution is made per Scctioa t0.2 B. above. tho Trustee.shall: l. The entire remainin1 property, in equal 1bares, to Remaindcrmall A... in equal shares, per sthpes. Should there be no R.cmaindarmaa A.. th.ca all to Jk:matndcnnan B. and C. in equal Ibara., or, all to tho l1lfYivor ofthem. IfRemaindaman B. and C. prcdccease the tenninaUon of this trust. the all to Rmlainderman D. per sdrpes. IfRemaladerman D• ....!predcccasiiiiiiaiithoiiklmliiiaatiiionii~li1hisi'equalleavingper stirpel. to tmst e11ams no~ thea • a vi . 2. Should any Remaindemum or subsequent mnainder beneficiary be a minor, disabled or incapacitlted at the date of tho tamiaatioll offhf.s trust. the Tnistec(1). in tbolr aolo absolute discretion. may plaeo that persons share in trust. including a special needs trust, for tho .benefit ofdllt person. Tho terms of such tmst to be docided by the Tmstee(s) with tho exccpdon that all special needs ttusis shall be supplemental in nature and not contain or require a payback provision. 3. Should any Remaindenun or subsequnt balcficiary be age 65 or older, at tho dato of the tormiudon of Ibis trust. and be mcei'Ving Medicaid benefits in any form and such distribution would jeopardize such Mcdloaid. benefits. tho Tmstees, in their solo absolute discretion, may choose to 1r'Olt that Romainderman or subsequent beneficiary u having predoceasod the Btnofici8ry of this trust and diltdbute that Remaindcrmao.'s or subsequem bonotlclatTs lharc to the next applicable Rcmaiodcr:man or aubsequcnt beneficiary. 4. Should any Ttultle, or Successor Tmstee acting in the capacity of a Ttultle, be aR.emalnderman or subsequent~~ this trust upon tho date o!tcrmlnatlon of this tmst and eligible to taH a share u a Rcmainclmmm or subsequent beneficiary, and such pcmon, in their role u Tiustec, should choose to place their share in a speeial needs tmst, or should cboon to be m=atcd u having predeceased tho Beneficiary of this trust. said docislon by the~ or Successor Trustee aeting in the capacity of a Trustee. shall not constitute a · reauneiation. under Medicaid generally and specifically, by the R.mnaindmnan or subsequent beneficiary. S. his the intent of the Settlon that disbursement of the mnainina funds 10 in tbis Uust upon tbe termination of the trust not affect any R.ema.indennan's or subsequent bencfieiary•s elisibility for or receipt of public/govemmmtal bencfila such as those referenced in Section 1.4 herein. 103 QutlidlReyjew Mdlor AIPQDI Not Bemired. Any decision to tenmnate this trust and the actual termination of this b'Ult, under the tenns specified herein, shall not requho the approval of any non party or court to be valid. ARTICLE XL onJER eoNPmQNS QPON nm TBUSI 11.1 TgtSBm, The situs ofthis 1nlst shall always bo Pe&mS)'lvania. .11.2 AQnlicQlc Lg. Any matters iolated to this trust. either dircctly or indirectly, shall be govemed by thelawsof~ 11.3 Spendthrift PnwJsion, The interests, Ifany, of Ille Bae8clary in the 1n1st pmperty, includina any Principal, interest or ineome, shall not be subjoot.to the claims of thoir cndltors. or tho creditors of others. including creditors ofany spouao of a anarriod. Beu.cficialy• J10l' to legal pmcess, and may not bo volumarlly or invohmtmily alieaatod or~ 11.4 CoJies ofebo Trust Documgt. To the same extent as if it wen 111 odgioal. Ill)' porson or entity may rely upon a copy ofdds rrust, cerdfiod by a notary pub1lc to be a uuo copy ofthis trusc. 11.5 Changes in Pat1ig to Tnm ta be Reqorded, In .tbe intorc:s1s ofmaintainfns a complete record. all changes in parda to the trust sball bo rccOrdccl as rcquim1 in Section 12.2. 11.6 Hoo-lydjclal ~; Parties may make use of non-judicial scaJcments to !UOlve matters not otherwise provided for or specified hcr:cin. All non-judicial scttlemcnls shaU be in the roan of amendments and shall bo recorded as required in Section 12.2. Court approval shall not be required of any nOll-judicial settlement. l1 Copy from DPW PEAP SJ*lem · ABlJCLE XQ. AMENJ)MBN]'S TO IHB TRUST f.imftatiom, 12.1 . This trust shall not be amended~ as provided herein. or by order of a court of compcteotjurisdictioa. subject to the condition that any alteralion or amaadment that is likely to result in, or does remit in, a ebaage in the special needs scarus ofthis trust may be subject to iescisalon or modification so as to retain the special needs nature of Chis Cruse. In the intcmst ofmaintaining a complete record, all amoadments to the Crust shall be recorded. in wridng, and added to this trust document. AmendmealS to the crust sball have tbll ~ect and be considered part of the original trust document. A&DCLEXUI. AOBQMMIQIRW 13.1 Setdog's Aamppentto TrusL . The Sott1on, by sip.mg below at Seotlon 13.S. are admowlcdghag alrcement wlth all terms and conditions specified herein and qn:o to abide by llid terms and condieions, while tWillina the Scttlors's role in the management and administration of the trust 13.2 . Trustee's A.ammmt to Imst. The Trustees, by sisnins below at Socdon 13.S, IN aclc:nowlcd&ing qreement with all tezms ancl conditions specified herein IUld . . to abide by said - - ancl conditionS, while fbltllling the Tl\IStcc's role in the management and administiation of the trust 13.3 Cqug.tmwrts, 'Jbis TNSt Ap:emont may be signed in one or more counterparts. and each countetpart will bo comidcred IUl original Trust Agreement. All ofthe countcpa.dl will bo considered one document and become a binding agreement when one or mom of the COUDtaparts bavo boen signed by each of the pmdcs IUld dcUvcred to the other. 12 J 13.4 Dato of Creatiog. SclaeduleA. nio sum of Sl0.00. 14 0310513016 1:02 PX PAI (iJ000310003 ~8~9020120 pennsylvania DIPARTMINT OF HUMAN SERVJCES January 191 2016 BRADLEY LAW LLC PATRICK J BRADLEY ESQUIRE POBOX26587 COLLEGEVILLE PA 19426 R.e: Dakota Moyer (minor) as #: 1.2P.3347~P Incklent Date: 01/19/2015 Dear Attorney Bradley: The Department of Human Services' Special Need$ Trust CSNT) Depository has received the Dakota Moyer Special Needs Trust. Jn eccordance with 62 P.S. §1414(b)(4), before this trust can be a«epted end processed by the Speclal Needs Trust Depository, It must be reviewed and approved by the Department's Office of General Counsel. If you have already received a trust approval letter from the Office of General Counsel, please forward 1 copy of that letter to me. If not, you must submit the trust for approval to tM following address: Special Needs Trust Review, Departmant of Human Services, Offic:a of General eounseJ, Ste 6092, 801 Markets~ Philadelphia, PA 19107. Failure to provkle the Special Needs TnlSt Depository wltll ttae trust approval letter from the Office of General counsel may result In tbe termination of the trust beneficiary's Medlcal Assistance benefits. Once an approval letter has been received from the Office of General counsel, vou must forward a copy of the letter and a fully executed copy of the trust to the Special Needs Trust Depository. You must also send a copy of the fully-executed trust to the trust benefldary•s local COUntv Assistance Office (CAO). Please also provide to the Special Needs Trust Depository the Sodll SeaJrltv Number of the dlSabled trust beneftdary, the current balance of the trust, and the SOI.tree of the funding of the trust. tf you have any questions, please contact the SNT Depository at {717)772-6249. Thank you for your cooperation with the Department. Slncerely, ~1tb- I I Donna N. Brown TPL Program Investtgator 717-772-6606 717-772-6553 FAX eureau of Progr;mi ~ I OIVISlon of Third hl'\Y ~ I ~ Scctlrm ........................... PO IOX848G I~~ 1.7105-84ftl! Exhibit Q 02105/2018 1:02 Pl Fil BRADLEY UW LLC .&8.19020120 fill OOOll 0003 . BRADLEY LAW. LLC YOUlUPl!ClA&. NlilOS SOUl\CI IN l'INNSYf.YANl.A .[f!csh;nil:e transmittal To: ........ o.ru., l!sq. Fix: or Mark Newellt left· .. ottla ot CleQl1ll CvunRI .! . . . lb.et .. Suite 5055 Phlladalphla, PA 19107 2S...U•:tsnp 2S.5·SfSO.:.ss14 f From; . Re: . ~ J. . .,.,. . D~OTA ~YER (minor) CD#UUM730 lllClDBIT DATE: 1/19/2015 Cc: R/A Cl· For revtew Ms.. Oakes/Mr. Newell, For your review aryd consideration. Patrick J. Bradley con • 1 OFFlC! ADDIU!SS: CPLW! RIPLY TO MAtlJNG ADDlWSJ MAILING AOD~Sr IMDl.iY LAW LLC (484) 902-0123 PMON! IMOLW LAW U.C P.O. BC* 2'$17 3801 CiERW<NTOWN J'tKE. Surrt 201 C .COWGMW. PA 1'426 (484) 90:M>120 FAX ....lli!tillW>iiil.ftltiilililW>iiil.M.A.iiiilwiiUCiiiiCOiiiiM•••••ffi"'tc;MW. PA·1'426 Exhibit R BIW>LEY LAW UC Iii 000!!10003 BRADLEY LAW, Ltc YOUI\ SPlCIAL NEID$ SOURCI IN PINNSYLVANIA February 5, 2016 : ·Bt1lBY.FAdslMllJiONLJJ0215§8H554 .L.eslle Oakes, Esq•. or Mark Newell, Esq. Office of General Counsel 801 Market street SUie 5055. . ehifadelp~la, PA 19107 2,15-680-21&2 p . 215-~554f' RE: DAKOTA llOYER (mlnort CIS·# 120334730 ·INCIDENT DATE: 1/191Z01& .·oe.r t.its. ·Oakes/Mr. ~• . Attachec:fplease find a copy of a letter cur office received from Ma. Brown at Divisian of ·Thlrd·Party LiabRlty seeking the review letter from yaur office regarding the . payback trust submitted to your office for review for the indMdual referenced above. JHlf IS AN UNFUNQEQ IR.UST. NO bAltlUITllJIN INVOLYl!Q, ·· . Al=oHada}t ·we have not received a review Jetter from your office. I understand . your.office has a large backlog of these truat documents and .a reView of each document •kes time. It ts. also my understanding that your office, as a matter of process. carbon · ~the TPL section on au review letters when completed. . As both my office and the TPL omce wilt be notified upon the completion of the review, I wait to heat back from your offtces on this matter at that time. tf you haV. any questions please do not hesitate to contact me. . .· AlTACHMENT: . TPLLetter CC: Ma. Brown (by fax only) File (Pl.EASE REPLY TO MM UNG I.DOWS) BRADUY I.AW I.LC 3'01 a~ Pnd!. sum 201 e COU.eGEVILli. PA 1942lt MAIUNG ADDA.GS: (484) '°2-0123 PKONI (484) 902.0120 FAX l'IAAOt.EYfi91\IWJU!YJ.AWIJ.C.COM &IADUY LAW I.LC · P.O. SOX l6S87 COUWMl.U..PA JMZ6 Bradley Law, LLC Your Special Needs Source In Paulsylvallia October 12, 2015 Leslie Oakes, Esq. Office of General Counsel 801 Market Street Suite 5055 Philadelphia, PA 19107 RE: ANNE KOZLOWSKI SPECIAL NEEDS TRUST (OBRA 93/PAYBACK) SSN Dear Ms. Oakes, Attached for your review is a special needs trust drafted for the benefit of ANNE KOZLOWSKI an adult with disabilities. ANNE KOZLOWSKI is currently an SSDl/SSI and or Medicaid recipient. If you have any questions or concerns about the trust please do not hesitate to contact our office. V PA truly yours. KJ.8 EY'f.( ~ Attachment '/,.:. cc: M. Stokes - SSA Regional Office Supervisor - SSA Office - Limerick Supervisor ·DPW Montco. Co. Assistance Office Supervisor- Third Party LiabiJity Section Harrisburg Trustee FILE ........................... Exhibit S omce Mdlcss: BnldJcy Law LLC 3801 Omnaalown Pilce, Suite 201 c ~l'f.19426 (PICllSC Reply To Mailing Address) MllilingAddms: (414) 902..0123 pltone {414) 902..0120 raic ollnullcv@bradlcvlawlk:.com BracllcJ Law I.LC P.O. Dox26B7 Collclzcville. PA 19426 Anne Kozlowski Special Needs Trust (OBRA93/Payback) 1 ARTICLE I. CREATION OF THE TRUST 1.1 Degaration of Trust. I. ~inafter referred to as the Settlor) give the property listed in SchedulCA{attached}.10.Patriek J. Bradley (hereinafter referred to as the Trustee) to bold, in trust, for the benefit of Anne Kozlowski (hereinafter referred to as the Beneficiary), BS specified herein. t.2 Intent to Create a Imst. The Settlor intends that this document create an inevocable special needs trust for the benefit of the Beneficiary, as specified herein, during the Beneficiary's lifetime under and subject to 42 USC 1396p(d)(4), 62 PS 1414. and SS Pa.Code 178.7(t)(l). 1.3 Intent to Make tbe Trust htevocable. This trust shall be irrevocable and cannot be revoked or terminated by any party to lhe trust except as specified herein. 1.4 Intent to Make tl\I ]'rust SY.Dplemental. This trust shall be supplemental in nature, that is, it shall supplement and not supplant any and all publie/govemmental benefits and/or programs available to the Beneficiary. Public/govemmental benefits and/or programs shall include, but are not limited to, Medicaid (MA) progtamS and benefits, including Waiver funding; Supplemental Security Income (SSI) benefits and programs; federal, state and local/county homing programs; other programs, services and/or funding as well BS any other publicly or nonpublicly funded services or supports provided. by any federal, state or local agency or public or non-public entity. 1.5 Jntent 12 Make the Trust DisCJetionary. The Trustee shall have sole, absolute, wlfettered and unrestricted discretion to make, or not make. distributions under this trust as specified. herein. 1.6 TitleoftheTMt. This tnlst shall be known BS the Anne Kozlowski Spedal Needs Trust (OBRA93/Paybaek). ARTICLE II. PARilBS TO 'fHQ TRUSI 2.1 ,JJ Settlot. TheSettlo~ . . . . . . . . . . . . . . . . . . . . . . .lliml.......... 7is a resident of Pennsylvania. 2 2.2 Trustee. The Trustee, Patrick J. Bradley, is a person experienced in managing special needs trusts. Patrick J. Bradley is a resident of Pennsylvania. 2.3 Janeficiary. J The Beneficiary., Anne :Kozlowski, UTrcsident of Pennsylvania. is•llll••••••••• The Beneficiary is an adult with a disability; such disability having been agencies; the County Offices and affi.llates, the County Assistance Office and/or the Social Security Administration. establi~bcd by county. state and/or federal The Beneficiary bas been and is/may currently be the recipient of publicJgovemmental benefits and programs. It is reasonably expected that the Beneficiary will need to continue utiliring public/govemmen1al benefits and programs for the duration of the Beneficiary's lifetime due to the nature of the disability. The R.emainderman under this trust are: B.A. The Issue of Anne Kozlowski (as a class). c. 2.5 Successor Trustee. The Successor Tnistee upon the death, resignation or incapacity of Patrick J. Bradley shall bc(I. . . . . . . . . . .. The Trustee may call upon the Successor Trustee to serve as Co-Trustee along with them if they so desire. ARTICLE W· TRUST PROPERTY 3.1 Initial Trust Prqperty. The property listed on Schedule A. (attached) shall serve as the initial trust property. 3.2 SOUJ.'C£ of the Trust Property, The so~ofthe trust property is money from the Settlor. 3 3.3 Limitation go the; Initial Irust Property. Neither the inidal trust property, nor any interest or income generated by the initial trust property. shall be considered as an available asset or resource to the Beneficiary for any purposes genendly and specifically for determining the Beneficiary's eligibility for any past, present and/or future public/aovemmental benefits and/or programs... ARTICLE IV, ADDJIIQNS-IQ TRUST PRQPBRIY 4.1 Peanittcd Additions to Trust Pnmenx. Any property or monies in any reasonable fonn that is deemed acceptable by the Trustee may be added to and become part of the trust property. All additions, outside of actual income or interest, shall be considered principal, and shall be added to the property as such. 4.2 Permitted Sources of Mditions gp the Trust f!mperty 1 Any person or entity shall be permitted to present property or monies to the Trustee for consideration for addition to the trust property, including the Beneficiary. 4.3 Limitations on Additkma to the Trust Prqperty. No additions to the trust property, nor any interest or income generated by any additions to the trust property shall be considered as an available asset or resource to the Beneficiary for any purposes generally and specifically for doterminina the Beneficiary's eligi1>ility for any past, present and/or future public/govemmental benefits and/or programs. No additions shall be permitted after the Beneficiary's 65* birthday unless pcnnitted by then existing law. MDCLB V. POWERS Of DIE SBITLOR S. l General i!em: The Senior shall have all the powers of a Senior over a trust in Pennsylvania as well as any other powers necessary to assist with the orderly administration of this trust. 5.2 Limited Power to Appoint Successor Trustee(s1 The Senior shall have the power to appoint a Successor Trustee or Successor Trustees only in the event that all the named Trustees and named Successor Trustees are otherwise unwilling or unable to perfonn or continue to perform as Trustee and no other Successor Trustee has been nominated or otherwise identified as specified herein. This right is not assignable and terminates upon the death or incapacity of the Senior. Written notice of appointment of a Successor Trustee must be provided to the 4 then existing Trustee and Successor Trustees, as applicable, to provide adequate opportunity to arrange for a smooth transition to the new appointee. ARTICLE YI. POWERS OP TflE TRUSTEE 6.1 Broad Powers· The Trustee sbaU bave all the powers of a Trustee over a trust in Pennsylvania as well as any other powers necessary, which shaU include the power to hire any oecessuy professional or other services, including but not limited to any legal or case management services, to assist with the orderly administration of this trust. 1i 1 I I I This provision shall be construed broadly and shall not be limited in any capacity. 6.2 I Total Discretion on Dis1ributiom. The Trustee shall bavc sole, absolute, unfettered and unrescrictcd discrotion to make or not make any distributions under this trust, as specified herein. 6.3 Power to Amend the Trust. Tho Trustee shall bavc the power to amend the trust when it is necessary to ensure compliance with and confonnance to applicable federal. state and local laws, regulations and procedutes, as well tho requirements of any govemmomal agency, as specified in the trust herein. Aay such amendment shall not affect the irrevocable special needs nature of this trust 6.4 Power to Designate a Cqmoqrte fiduciary Co-TQ.VBee. The Trustee, in their sole absolute and unfettered discretion, shall have the power to amend the trust to include a corporate non-profit Co-Trustee, including, but not limited to, The Arc Community Trust of PA. Inc. or the Family Trust, Inc., for the purposes of assisting in the management of the trust Said corporate non-profit Co-Trustee shall have the same powers and duties as a Trustee listed herein. 6.S Power to Create an Irrevocable BurlaJ Fund or QdJe[ funeral Arrapgcmcnts. The Trustee may create an Irrevocable Burial Fund or other funeral arrangements, including. but not limited to, pre-paid arrangements, with funds from the trust property. Tlds may also include the purchase of a plot and a marker. Court approval sbaU not be required to create any such tund or arrangements so long as the total amount of such fund or arrangements does not exceed the then allowable Medicaid limits set by individual county assistance offices, or their successors. 5 '' l l I I I MDCI& VII, PQWBRS Of J'HB BEHEEJCIARY 7.1 Limitations. The Beneficiary sbaJI have no new powers created under this 1rUSt document, but shall re~ all powers applicable under the Jaw. · The Beneficiary. their lcpl guardian. their dcsignee or support team members, may make special needs requests ftom time to time, or on a replar basis, to the Trustee. These requests are. not binding on the Trustee and at all times shall be subject to the sole, absolute, unfettered and unrestricted discretion of the Trustee. A&DCL6 YIU, DISTRIBUTIONS FROM TfIE TRUST 8. I Distn'bptions Gegeqlly. During the lifetime of the Beneficiary, the Trustee may, in their sole, absolute, unfettcral aad unrestricted discretion, and after considering Article vm in its cndrety, make or not make dislributions from the.principal and/or income of the 1nJst propeny for the special needs of the Beneficiary, as specified herein. 8.2 Intent of Settlor R.eggjiu Qistributiogs, It is the intent of the Scttlorthat the trust property, including all principal, interest and income. sbaJl be used solely for the special needs ofthe Beneficiary, and as otherwise specified herein. The special needs of the Beneficiary sbaJl be m item(s) or service(s) that enbance(s) or impmve(s) the quality of life of the Beneficiary, subject to fbrther limitation, or expansion, by law and further subject to the limitations of the b'USt herein. 8.3 Duration of Trust. It is the intent of the Scttlor that the 1rUSt property, including all principal, interest and income. need not last for the entire lifetime of the Beneficiary, and that the crust property should not be managed or administered in such a manner. 8.4 Co.midmtivu of Public/Gmrnmental Benefits, In C()l\junction with Section 1.4, it is the intent of the Settlor to maintain the maximum level of public/govcmmcntal benefits and/or programs for the Beneficiary. As such, before any distribution of trust property can be made, the Trustee must talce into consideration any publiclgovcmmcntal benefits and/or programs that may be available to the Beneficiary and shall give consideration as to whether or not such distribution would affect the Bcneftciary•s past. current or future eligibility for such public/governmental benefits and/or programs. 6 8.S Relation to Disability. Before any dis1n'bution of trust property can be made the Trustee must take into consideration how such distribution relates to the Beneficiary's disability and give consideration to whether or not such distribution would enhance or improve the quality of life of the Beneficiary. 8.6 eom..Uon Qfirwm. The Trustee may be compensated &om the trust property on a replar basis for services rendered to or for the trust and/or to or for the Beneficiary. Compemation shall be limited to actual costs, including prevailing IRS mileage rates at the time incuucd, and reasonable hourly mes for other services actually rendered. For a corporate Co-Trustee, if any, compemation shall be limited to the then existing fee schedule, as applicable. ARTICLE IX. DUTIES OF TB.USM The Trustee shall be responsible to administer this trust for the benefit of the Beneficiary. The Trustee shall meet &om time to time, at a minimum of once annually, with the Beneficiary, to discuss and determine a manapment strategy, taking into account the purposes and contents of this trust, that is agreeable to all parties. 9.2 Qetmpinatigp of Allocation of Income. The Trustee shall determine what is considered income and what is considered principal of the trust property. 9.3 Determination of Cos The Trustee shall determine all costs, expenses, taxes and charges in any form against the trust property as well as whether to allocate them against principal. interest or income of the trust property. 9.4 Reporting Rem&immenY1 As required by applicable law, the Trustee is or may be required to submit notice of any/all changes in parties and/or amendments to this trust, applicable disbursements &om and actual termination of this trust to the following: A. The local County Assistance Office of the Commonwealth of Pennsylvania's Department of Public Welfare. B. Office of General Counsel Commonwealth of Pennsylvania Department of Public Welfare 7 801 Market Street SuiteSOSS Philadelphia, PA 19107 C. The local Social Security Administration office. D. SSIPropam Support Team. Attention: Team Leader Mid-Adantic Program Service Center 3nl and Spring Oarden Streets Philadelphia, PA 19101 E. The Special Needs Trust Depository Attention: Manager, TPL Section P.O. Box 8486 Harrisburg, PA l 710s-B486 F. The Clerk. of OJ:phans' Court of the County of residence of the Beneficiary. a. Anne Kozlowski (Beneficiary) H. , . . . . . . . . . . . . . . . . .. . •r I. •Patrick J. Bradley (Trustee/ or bis Successor) J. & D 'J !L[ I I The Tnistee should only provide information to any other pubUc/govemmental agency or other entity administering public/governmental benefits or programs upon written request, or as otherwise required by law. The Tnistee shall submit to the Beneficiary, or the Beneficiary's legal representative, any and all requested documentation upon written request. 9.S Limitation of Trustee Liabilitt. No Tnastee under this trust shall be held liable, at any time, for any act or failure to act, or any act or failure to act of an agent or any other person or entity in connection with the administration of this trust or the trust property, unless caused by a Trustee's gross negligence or a willful act in breach of trust. 9.6 Succgsor Irustee· If the named Trustee is unable or unwilling to serve, the named Successor Trustee sball serve as Trustee. Each Successor Trustee shall assume all powers and duties of a Trustee under this 8 ! 9.7 No Bond R.eq,uire4. No bond sball be required of the original Trustee or original Successor Trustee, however, bond may be required of any corporate non-profit co-trustee as the parties see tit. or as required by applicable law. ARTICLB X. TERMINATION OP nm TR.UST AND FINAL DISTBIBUTION OF TRUST PROPERTY l0.1 Imnination Eycng, This Trust sball terminate upon the occurrence of any one of the following conditions: A. The death of the Beneficiary. B. By order of a court of competent jurisdiction. C. By determination of the Trustee that it is impractical to continue to administer this trust; 1. Because the principal. income and interest have been depleted to a minimal amount (under $2000.00) with no reasonable expectation of future additions to the trust property; or 2. Because the trust can no longer meet the Beneficiary's special needs; or 3. Because to continue to do so would jeopardize the Beneficiary's current and/or future public/governmental benefits; or 4. Because to do so would violate the terms of this trust. J0.2 Final Distribution of Trust ProoertL Upon the termination of the trust, the Trustees shall: A. Notify the Commonwealth of Pennsylvania and any applicable Medicaid aacncy from any other state and shall reimburse the Commonwealth of Pennsylvania, and any applicable Medicaid agency from any other state, for any valid lien for medical assistance or other valid lien for eligible benefit$ i:eceived by the Beneficiary, but only to the extent required by then existing law, from the then remaining trust property. If there are liens from multiple states and the amount remaining is insufficient to pay back each state in its entirety. the amount remaining sball be prorated between the states proportionate to the amount of the liens in question. After making any payback required in Section 10.2 A. above, Trustees shall: B. ~- I Distribute the remainina trust property to the Beneficiary. if living. 9 Ifthe Beneficiary is deceased and no distribution is made per Section 10.2 B. above, the Trustees shall: C. Distribute the remaining trust property to the Remaindcrman identified in Section 2.4 as specified below: 1. The entire remaining property, in equal shares. to R.emaindcnnan A., Should there be no Remainder A., or should all ofR.emaindemlan A., predecease the termination of this trust, then all to R.emaindcrman B. Should Remaindcrman B. predecawe the termination of this trust, the all to R.cmainderman C., per stirpes. In the event some portion of the trust property does not vest in any Rcmaindermaa or their issUe, as specified herein, then that portion shall go to the intestate heirs of the Bencficiery of this trust, in equal shares, per sdrpes. 2. Should any Remainderman or subsequent remainder beneficiary be a minor, disabled or incapacitated at the date of the termination of this trust, the Trustee. in their sole absolute discretfon, may place that persons share in trust, including a special needs trust, for the benefit of that person. The terms of such trust to be decided by die Trustee with the exception that all special needs trusts shall be supplemental in nature and not contain or require a payback provision. 3. Should any Remainderman or subsequent beneficiary be ago 65 or older, at the date of the termination of this trust, and be receiving Medicaid benefits in any form and such distribution would jeopardize such Medicaid benefits, the Trustee, in their sole absolute discretion, may choose to treat that Remainderman or subsequent beneficiary as having predcceascd the Beneficiary of this trust and distribute that Remaindcrman's or subsequent beneficiary's share to the next applicable Remainderman or subsequent beneficiary. 4. Should any Trustee, or Successor Trustee acting in the capacity of a Trustee, be a Remainderman or subsequent beneficiary under this trust upon the date of termination of this trust and eli11'ble to take a share as a Remainderman or subsequent beneficiary, and such person, in their role as Trustee, should choose to place their share in a special needs trust, or should choose to be treated as having predeceased the Beneficiary of this trust, said decision by the Trustee, or Successor Trustee acting in the capacity of a Trustee, shall not constitute a renunciation, under Medicaid generally and specifically, by the Remainderman or subsequent beneficiary. S. [t is the intent of the Settlor that disbursement of the remaining funds in this tru&t upon the termination of the trust not atfcct any Remainderman's or subsequent beneficiary's eligibility for or receipt of public/governmental benefits such as those referenced in Section I.4herein~ 10 10.3 Outsidg Rmigy @!ldlor Approval Not Reqyjrccl. Any decision to tenninate this trust and the actual termination of this trust, under the terms specified herein. shall not require the approval of any non party or court to be valid, however, any applicable notice requirements shall be adhered to as appropriate. J\B,DCLE XI. 01HER CONJlITIQNS UPON 1llE TRUST 11.1 Trust Situs. The situs of this trust shall always be Pennsylvania. 11.2 Applicable I.aw. Any matters related. to this trust, either directly or indirectly, shall be governed by the laws of Pennsylvania. 11.3 SQsmdthdft Pmyilism. The interests, if any, of the Beneficiary in the trust property, including any principal. interest or income, shall not be subject to the claims oftheir creditors, or the creditors of others, including creditors of any spouse of a married Beneficiary, nor to legal process, and may not be voluntarily or involuntarily alienated or encumbered. 11.4 Cgpies of the Irust Document To the same extent as if it were an original, any petson or entity may rely upon a copy oftbis trust, certified by a notary public to be a true copy of this trust. 11.S Changes in Parties to Trust to be RccorAed. In the interests of main1aining a complete record, all changes in parties to the trust shall be rcc:orded as required in Section 12.2. 11.6 Non-Judicial Settlements1 Parties may make use of non·judicial settlements to resolve matters not otherwise provided for or specified herein. All non-judicial settlements shall be in the fonn of amendments and shall be recorded as required in Section 12.2. Court approval shall not be required of any non-judicial settlement. ARTICLE XU. 12.1 AMmiDMeNJ'S IO 1JlB TRUST Limitatioos, 'This trust shall not be amended except as provided herein, or by order of a court of competent jurisdiction, subject to the condition that any alteration or amen.dment that is likely to result in, or does result in, a change in the special needs status of this trust may be subject to rescission or modification so as to retain the special needs nature of this trust. 11 Please sign andtor date and .ratum to BrldeJ Law U.C 121 &nenclments to Trull tq be Recorded. In the intezest of maintaining a complete record, all amendments to the trust shall be recorded, in writing. and added to this trust document. Amendments to the ll'QJt Shall have full effect and be considered part of the original trust document. ARTICLE XIII. AQRREMENT TO TRUST 13.l Sc;,qtor•s Aarmnent to Trust. The Scttlor. by signing below at Section 13.S, is acknowledgins agreement with all terms and conditions specified herein and ape to abide by said terms and conditions, while fulfilling the Settlor1s role in the management and adminiatration. of the trust. 13.2 Trustee's A&mmmt to Trust. The Trustee, by signing below at Section 13.5, is acknowledging qreemeo:t with all terms and conditions specified herein and ape to abide by said terms and conditions, while fulfilling the Trustee's role in the management and administration of the trust. 13.3 Counterparts. This Trust Ap:ement may be signed in one or more counterpatts. IDd each counterpart will be considered an original Tnist Agreement. All of the cot111tel'p81tS will be considered one document and become a binding agrccmcnt when one or more of the counterparts have been signed by each of the parties and delivered to the other. 13.4 Date of Creation.. This trust shall be construed as having been originally created the 13.S Pa.rty SipajlU:Js. 12 t.,. ~ of day Selleclale A. The sum of $20.00. lJ -- , ------------------------------------- .. SPECIAL NEEDS TRUST QUESTIONNAIRE Beneficiary~ -+f-1.n,._.,Q. .,.l._,~k"'" o_:z. . ,. ........... S...... .. /al,i)""""' Jv.,,..__·- - - - - - - - BeneficlafY'a Social Security number. Beneficiary's date of birth. _ _.. What is the source of the funda that have been or will be U&•d to fund this trust Personal Injury CJ lnhttrttance CJ Other 0 If other. please specify: fwids f;-9.m benef icia;y Date of personal Injury, distribution of inheritance, or other applicable data that resulted in the funding of the trust. N/A - part of normal estate 2lanni1!9 Has this Special Needs "Frust been appr~by-th•Depaitment'a Office of General Counsel? Yes 0 or No CJ r ......e(ldin~ 0c:Jvbe£.. Datethetn.tstwas funded. Z, ZDI S- Amount placed In the trust. _ _ Please provlde the name, address and telephone number of the Trustee. Name: ~Lt~k..S]>t.Ad/"f Address: .3 80/ GctCnt sa/vtJ01 1(r_:e_ SU; k. 20/ C.. 6111.,,VJ Jk :?11, 1q1zv Telephone Number: Y8 l/- OJ(),:1.-0};;,_ 3 Please supply the name. address, and telephone number of the attomey or finn who wae retained for the personal Injury case, astate case or other matter: Patrick Bradley, Esquire Bradley Law LI..C Address: Bradler Law LLC 3801 Germantown Pike, Suite 201 P.O. Sox 26587 Collegeville, PA 19426 Collegeville, PA 19426 Telephone Number: 484-902-0123 {Phone) 484-902-0120 (Pax) 2 .. SPECIAL NEEDS TRUST QUESTIONNAIRE (confd) /Jn& /loz. '®Js k,./ Beneficlasy: ,., · Please supply tilt n11me, addreaa and telephone numbw of the attorney or finn who drafted the lrU8t, if different than the name and address on the cover letter. Name: ~--......_~-~~~--~~--~~--------- Address: _ _ _ _ BRADLEY lAWLLC. _.,.,,...__.e..Q ao_x_..,. . . ........ _________ COl..U!GIVlu.e. PA 11428 Telephone Number.-------------Please supply ~her pertinent informat1011 below: Jathauy d<.d~mom W•-4-h ~-.a.QQ ; DR.U>l.EY L<\W LLC November 20, 2015 "8:Anne~. CIS f! 480tOHU. !MMtenc Date: 10/02/201& Once an approval lattet las been rtcelved from thl Qtflcie of <kutand ~I, u must forward a eopy Of.1he.._. end a fuly ex'ec:utat copy. of• tNlt to thl $tld•l~1•11m1 Ttust Oepolttory. Y• rn••JIO sand a COD)' of chi fully~ . _ •'MtRllt benefldlf'Y's localC:OuntvlaJdra Offtce (CAO). . thll~ Trust Depository smat &emrttv Number of the CllMllad benaflletarr, thl cummt balara of thl b'ldt and thl source of chi func:Ung of chi tnst. d•• om If you Nave •llY q~,. _,..,.contact thl SNT ~et (717)772-62.4'. Thank you for your cooparaaon With the Department. Sinc:erely, a~ HHl'V~ TPL. Pqram kwestlQator 71 ?•172·670. 717-772.-iSSl FAX Exhibit T 1211412118 1:11 P» PAI 4841120120 Bradley Law. LLC YnrcSpHlllll ~lwm'I lnPvlu:~la a:nsmittal facsimil To: ....... OtftoaGf . . . . . . Coun-' .,~.,.. ~MUUJ1 zu.•e-u..1p 11.......... f Aom: Rt: o-.: P1Wklle :J. lnulley AID ICHIOwHI 1/4/10&1 · Pages: (111~1111..,... .-11) as•~•••• ~ha Mtfla/:1911 ti/A -------~'*"+"' ' Ms. Oakea/Mr. Newell, For your review· and consideration. Patrick J. er.dley co, fid Exhibit U ~MdR:!llft (~lluplfToMllilil'*I~• • I I • ...... ~ BRADLEY LUf LLC February 4. 2018 IE IX FACllMtLI QNLXIQ ms-sso:§!M Lelle omc.s, Elq. or Merk~,Elq. oa. of o.m.nr COtJnl8I 801 Market 8treet 8Ula&e55 PA 19107 21 .. . p 21MtM9$4f RI: Anne . cm• INCID Dear Ml. Oakael Mr. Newel. D AtlaohadJl•li,iitd acqpy of a leler our om.:..~-.. Ms. Hol.Ml8 at ofTNrd 1)8911ac:k trust :, . . ·~U.revfewlatter~·your;OITffe•,........tw ·to your Offtce for review for the indlvldual ~above. /AIJoftadlJ.,.. . . not~ arev!aw... your;o.flce. l undemtand yourofftoe .._ • ._.._.._._. · . · ·. tt~Wof •ohdGaumrllnt tallla Ima. It . . . mv·~ ..... Yo"f ~ •• ···llidtwof p'-· carbon eople8 the TPL sactfDn· on al review lellerl when complM&d. Aa bOl'l my Offtce .and 1h• TPL ofllce wll be nD8filM:I UIMft the·compldon of the review. I wait to hear lack ftom your oftla on this matter at tllltttme. AlTACHMEHT: cc: TPL Letter Ma. Hotmel (by fax only) File p.b 6103231032 ~!. . . . . . . . . . . . . . . . . . . . . . . .. Exhibit V BRADLEY LAW. LLC YOUR SPECIAL NEEDS SOURCE IN PENNSYLVANIA a. Crownover 171 Mercer St. Somerville, NJ 08876 James~ . . RE. · Dear Mr. Crownover, The Rules of Professional Conduct for attorneys in Pe ylvaniarequire that·we enter into a written agreement describing the basis upon which you will be charged for professional services performed by :our firm. This letter and agreement sets for the terms and conditions upon which Bradley Law LLC will perform .legal services for you in connection with the matters discussed below. In addition, because you are a new client of our firm, I thought it would be helpful to confirm the scope of engagement and to provide you with a general overview of our billing procedures. We are pleased with your decision to engage Bradley Law LLC to represent you and we look forward to w~ing~ou.faU( emeniL.. I understand from our recent discussion your .. ob(,//;.,"!,!::-.,,~ 1. Assist you in drafting a deed to transfer property from you to your son. 2. Assist you in·registering.the deed with the Recorder of Deeds in Huntingdon County, . Pennsylvania. 3. Other matte.rs s requested by you and agreed to between you and· our office in wr... iti_..,.... .... _ ..... I'.. though it is always difficult at the outset of re esen of a client to describe with· precision what witl be involved, it is our understanding that we wiU provide aU legal services reasonably required in connection with the matters described above. ·If the scope of our services is enlarged beyond that described ·above and if we determine that a fee ai.:rangement different from that described in this letter would be appropriate, we will reach agreement with you on a separate fee arrangement for the additional work. While this Jetter is intended. to deal with the specific legal services described above, these terrn!i .and condi.tions will also apply to any additional legal services that we may agree to provide that are outside the initial scope of our representation. Fees, Disbursements and Other Expenses-Staffing . . Legal work .varies greatly. Although we are often engaged by our. clients to perform specific and limited tasks, our primary role as legal advisors is to offer our knowledge, experience and (PLEASE REPLY TO MAILING ADDRESS) OFFICE ADDRESS: BRADLEY LAW LLC 3801 GERMANTOWN PIKE. SUITE 201 C COLlEGEVl~LE. PA 19426 MAILING ADDRESS: (484) 902-0123 PHONE (484) 902-0120 FAX BRADLEY LAW LlC a · '@ftffl fYf'Swlfr Ql'Mf E r Exhibit W P.O. BOX 26587 sg"EOEVILLE, PA 19426 . independentJud~ent. Recognizing this, our focus in charging for services is to arrive at a fee that is fa~r .and appropriate considering all the circumstances. Among the factors that we consider in e~tablishing a fee are the following: the time (measured in tenths· of an hour) devoted to a particular matter and thp 11;.wyers and i'aniJegal~Q. worked 011 that matter; the nature and comple~ity the ~Ork perfOJlltl~; the·ex:perti8e 'required to . perform·that work;thenovelty an~ difficulty of the leg~l issues presented;ihe extent to which the . . urgency of-the matter preempted other JVOrk; the exte4nt to which the 41.atter reqti~peeiait• . ··allocation of firm resources and staff o~ertimc; the result obtain'l:d; arm tlte aip<lint typically charged by comparable firms for the same o~ similar work. · ·· · "' ... ~ ~ of . ' For the present, I will be~rih~ipJUy·jnvo~ved in·~ ma~: T~· S:Citoreach servi~ are: . ' . 1. The FLAT FEE for-drafting the deed document is $375.00 total. 2,. The COSTS for the executing and filing of the deed·are anticipated to be $152.15. ·a. lfyou wilt not be signing in the office - mailing the deed to your home to have you · sign (in front of a notary) and return to my office is: . $5.05 Priority Mail to you. • ~Return postage to lny offi~ to be~paid by you. • I- • ~ .. . Ii · b.·· Filing wtth-thl: Recordetofbeeds Qfllluktingdon Codnty, PennsytV{(hia: . i ·~ .. • . .. • .· . . • ...... • . . to $94.00 (aprox) filing feCJrecording fee, $40.00 (aprox) UPI Number x two properties (both on same deed). $5.05 Postage by Priority Mail to Recorder of Deeds. $3.00 Return postage from Recorder of Deeds to my office. $5.-05 Postage by Priority Mail to your home. THE.FLA'!' FEES AND COSTS LISTED ABOVE ARE NON- REFUNl)ABLE AND MUST BE PAID IN ADVANCE OF ANY WORK BEING COMPLETED. Anticipated Other Expenses/Costs/Fees As this matt~r involves a flat fee, an hourly fee is only applicable in .the event that unknown and/or unforesee11 cir~stances arise which must be handled during and/or after the initial matter(s) · or in ttie evcm.t. that legal ~.ervices are terminated by either party to this contract before completion of the matter at hand. My currently hourly billing rate is $245.00 for legal services. You should · iinderstand that Bradley Law LLC operates as a firm-a client who retains a particularlawyer in fact retaiils the entire firm and has at their disposal all of the expertise and resources that the firm can bring bear upon their .legal problem. Therefore, the lawyer who serves as your principal contact at the firm may seek assistance from or assign primary responsibilities for a project to another lawyer who has ex~rience in tile particular area involved and who is for that very reason in a position to do the. work as e!i'iciently as possible. In assigning work within the firm, we strive to achieve the most efficient .mi~ of seniority and expertise, with the goal of providing effective representation to: our clients' on an economical and cost efficient basis. to. 2 i '. • You.authorize us to incur an reasonable costs and to retain any investigators, cons1.1ltants, or expertS i:iecess~ in.our judgment, with your input, advice, and consent, to pursue your claims. Initial Payments/ Future Payments/Billing . As a matter offlrm policy, for all flat fee matters, we require aU Jegal fees and costs to be . paid ·in full in· advanee of any work being completed. You agree to 1 non-refundable payment of $527.15 ($375.00 for fees and $152.15 for costs) in connection with our .representation. Unless e>therwise ·speeified, .all legal fees ·and costs are non- refundable. all · . :Foi ·baur.Jy ·matters, the initial hourly legal fee payment is non-refundable. Subsequent reqlleSt for payment of hourly legal fees may be either by account (for services already entered, as applicable) or.future non- refundable payments request, or in retainer form as specified below. When applicable, it is our practice to forward periodic statements regarding any balances due on a,month.ly basis. We ·expect our statements to be paid in full upon receipt, unless another arrangement has been discussed and agreed to in advance. We reser\te the right to impose· a late charge not ·to exceed. the maximum amount permitted by law on all amounts not paid within 30 days. · Our cui:rent late charge. is l % (one percent) per month. Retainer As a matter of firm policy, we require you to pay a mjnimum retainer against which we will bill all .related costs and other fees. You agree to deposit $0.00 as a minimum retainer in c~nnection:with our representation. We will charge all related costs and other fees and · dlsbu~tnents against the advance and credit them on our billing statements. If the costs and otherfees and disbur$ements exceed the advance deposited with us, we will bill you for the excess and possibly for replenishment of the advance payment. You hereby grant Bradley Law ·LLC a secilrity interest 'in and lien in any deposits of funds held by us as security for the payment of these expenses. You agree that we will have the right to request additional deposits from time to time based on our estimates of future work to be undertaken. If you fail to pay any additional deposit requested; we will have the right to cease performing further work and to withdraw from the ·representation. Duties and Responsibilities We' will provide legal services to you in connection with this engagement You are not relying on us for, and we are not providing, any business, investment, insurance, or accounting decisions and you are not relying on us for any investigation of the character or credit of persons with "."horn you· may be dealing. . · ..· ·Effective legal representation requires a high level of cooperation between attorney and .clfont..By signing this fotter,.you therefore agree to cooperate with us, to keep us fully.informed ofall developments, an~ to perform your obligations under this letter. We, in .tum, will rely on the information that you provide to us. We agree to provide the legal services reasonably required to represent you with respect to the matters described above and to take reasonable steps to k~ep you informed of our progress and to respond to your inquiries. You also wlll make yourself reasonably av.ailable-to ~t~nd meetings, discovery proceedings and conferences, hearlf!.gs, and other 3 --~---------------------------------- You.a1,1thorize us to incur all reasonable costs and to retain any investigators, consultants, or expertS ~ecessary in.our judgment, with your input, advice, and consent, to pursue your claims. Initial Payments/ Future Payments/Billing . As a matter offmn policy, for all flat fee matters, we require all legal fees and costs to be . paid in full in advance of any work being completed. You agree to a gon-refundgble pument of $527.IS ($375.00 for fees and $152.15 for costs) in connection with gur-representation. Unless other:wise·speeified, all legal fees.and costs are non- refundable. . . · · :For 'att ·hour:ly ·matters, the initial hourly legal fee payment is non-refundable. Sttb8equent request fOr payment of hourly legal fees may be either by account (for services already enterc!d, as applicable) or.future non- refundable payments request, or in retainer form as specified below. When applicable, it is our practice to forward periodic statements regarding a~y balances due on.a, monthly basis. We expect our statements to be paid in full upon receipt, unless another arrangement has been discussed and agreed to in advance. We reserve the right to impose a late . charge not to exceed. the maximum amount permitted by law on all amounts not paid·within 30 days . .: Our cui'.fent late .charge. is I % (one percent) per month. Reminer As a matter of firm policy, we require you to pay a minimum retainer against which we will bill all .related costs and other fees. You agree to deposit $0.00 as a minimum retainer in c~nne~on with our representation. We will charge all related costs and other fees and disbur~inents against the advance and credit them on our billing statements. If the costs and otherfees and disbursements exceed the advance deposited with us, we will bill you for the excess and possibly for replenishment of the advance payment. You hereby grant Bradley Law -LLC a secUrity interest in-and lien in any deposits of funds held by us as security for the payment of these expenses. You agree that we will have the right to request additional deposits from time to time based on our estiniates of future work to be undertaken. If you fail to pay. any additional deposit requ~ we will have the right to cease performing further work and to withdraw from · the ·representation. · · Duties and Responsibilities . We' will provide legal services to you in connection with this engagement. You are not relying on_ us for, and we are not providing. any business, investment,- insurance, or accounting decisions IU)d you.are not relying on us for any investigation of the character or credit of persons with whom you may be d<?aling. . ·Effective legal ·representation requires a high level of cooperation ~tween attom~y and -.client. By signing this letter, you therefore agree to cooperate with us, to keep us fully informed of.all ·developments, an~ to perform your obligations under this letter. We, in turn, will rely on the information that you provide to us. We agree to provide the legal services reasonably required to represent you with respect to the matters described above and to take reasonable steps to k~ep you informed of our progress and to respond to your inquiries. You also will make yourself reasonably av_ailab.Ie-~o li\ttend meetings, discovery proceedings and conferences, heari~gs. and other ·proceedi11gs. Your responsibilities will also include approving negotiation, discovery and litigation strategy; approving cause$ of action and parties to any litigation; and determining acceptable tenns of any compromise, settlement, or agreement. In addition, you will be responsible for advising us whether any document we have prepared or received.and sent to .you for your approval or review reflects the principal terms of your proposed agreement, general litigation strategy, or other expectations, as the case may be. General Provisions .EncloSed with this letter is astatement entitled General Provisions, which sets forth additionaltenns and.conditions, all of which are incorporated into this letter rum apply to our i:epresentation to the extent .not expressly inconsistent with this letter. Legal Liability Insurance Please be advised that Pennsylvania Law does not require attorneys to carry legal liability insurar:ice. Due to the nat4fe of our practice, Bradley Law LLC has decided to forego' legal liability insUrat'lcie and pass the savings on to our clients in the form of lower legid fees. Conflicts To.determine if you are involved in any matter adverse to our firm or to our clients, we have checked your name through our computerized conflicts checking system. This search has not revealed any such matter or conflict. We therefore believe that we will have no conflict _in representing you in his matter; Nonetheless, we ask you to conduct a similar check perso~ally and/or . within your.company to-determine whether you believe that any matters might exist in which 'our . finn may be adverse to you. Of course, if you discover any such matters, please let us know immediately•. . We are a small firm, however we do represent many other individuals. It is possible that, . during the tbt)'e·we are representing ~ client and at any time following the conclusion of our · engagef!'.lent, some of our present or future clients will be engaged in transactions, or encounter ·disputes, with 'you or your subsidiaries or affiliates. You agree that we may continue to represent, and may:undertake iri, the future to represent, existing or new clients in any hlatter that is not s·ubstantially · related to our work for you. even if the interest of such clients in those matters are direetly adverse to yoq or to any of your subsidiaries or affiliates, and to that end you hereby consent to any such conflict. We agree, ·however, to obtain your advance consent in any instance in which, .as a result of our representati~n of y~u, we have obtained proprietary. confidential, or other information of a non.public nature that, if known to sucb other client, could be used in any such other matter to your · matedal disadvantage or to the material disadvantage of any of your subsidiaries· or affiliates. : ·'We encourage yo~ to participate actively in the matters we are hand'ling for you, because you" are much clos~ to 'the details. than we are and we want to be certain that our efforts are consistent . with your goals. If at ally time you have a question, comment or concern, or if we may be of service in another_substantive area, I ask that you raise it with us at once so th~t we can address the matter without delay. 4 If the foregoing is in accordance with your understanding of the terms and conditions upon which you will engage us and the nature of our engagement, please confirm your acceptance and sign the enclosed duplicate copy of this letter in the space provided for this purpose below and return it to me at your earliest convenience. Upon your acceptance, these terms and conditions shall apply · retroacpvely to the date we first performed services on your behalf. ;· This letter will not become effective and we will have no obligation to provide legal services· until you sign and reiurn the copy of this letter along with the fee/retainer. We are pleased to have this opportunity to be of service and to work with you. Tha(lk you. Sincerely, PATRICK J. BRADLEY I/we have ~ad and understand the terms and conditions set forth in this letter (including the attached Gen~ralProvisions) and agree to them. . . . Accepted and agr:eed.to t.his ___ day of _ _ _ _ _ __, 20_ _. James ..B. Crownover 171.Mercer St Somervil~e;, N} .08876 Encfosme CC:· FILE. ' I , '. 5 General Provisions Except ~ modifi.ed by the accompanying engagement letter, the following provisions will apply to the relatipnship between Bradley Law LLC and our clients: . 1. the. time for which a· client will be charged will include, but will not be limited to, ·telephone ~d ·office .coQferences with a client and counsel, witnesses, consultants, court personnel, and others; conferences among our personnel; factual investigation;. legal research; respomling to-client's requests to provide information to auditors in connection with reviews or au<Jits of fi~ancial statements; drafting of letters, pleadings, briefs, a;rguments, and other documents; travel time; waiting time in the court, closings, or elsewhere; and time in depositions and.other discovery proceedings. 2. From ~~e to titl;le; internal conferences on a client's matter will take place among our -personnel, arid two or more may attend such conferences. It is our experience that this practice facilitates communication,, improves the quality of work, and ultimately is more efficient and economical. 3.:In addition to our fees, we will be entitled to payment or reimbursement for disbursements and other expenses incurred on behalf of a client such as photocopying, messenger and delivery, air freight, e0mputerized research, videotape recording, travel (including mileage, parking, airfare, lodging; meals and ground transportation), long distance telephone, tele-copying, postage, court costs,transcripts, and filing fees. To the extent that we directly provide any of these services, we reserve tile right to-adjust the amount we charge, and any time or from time to time, as we deem . appropriate, in light of our direct costs, our estimated overhead allocable to the services,· and outside competitive rates. Unless special arrangements are made, fees and· exp.enses of other (such as expe115~ investigators, witnesses, consultants and court.ieporters}.and other. large. disbursemel\ts (iq e~cess of$250.00) will not be advanced by O\ll' .firm and will be the re5ponsibility ·of, and paid directly by, the client. 4. Althotighwe may; fol;' a ~lient's convenience, furnish estimates of fees or·ex.~ses that we anticipate will be incurred on a client's behalf, these estimates are subject to unforeseen circumstances and are by their nature inexact. We are not bound by any est.imates except as. otherWise expressly set forth in the engagement letter or otherwise· agreed to by us in writing. may 5. Either at.the beginning or during the course of our representation, we express.our opinions 0r beliefs concerning the matter or various courses of action and the results that might be. antfoipated. Any Stich statement made by an attorney or other employee of our firm is intended to be an expression of opinion only, based on information available to us at the time an:d is not a promise or guarantee of any particular result. 6. A client sh8U have tl:ie right at any time to terminate our service$ and representation upon written notice to the· firm. Such termination shall not, however, relieve the client of the obligation to p,ay f~r all services rendered and disbursements and other exi)enses made or incurred on behalf · of tlle clie,i~ priQr to the date of termination and for services rendered and expenses incurred after such.date iothe ex.tent. they are reqUlred to protect our client's interest or as may be required by . appropriate authQ*ies.. 6 7. We £!!Serve the right to· withdraw from our representation with our client's consent or without c0nsent fo~ good cause. "Good Ca~e" may include the client's failure to honor the terms of the engagement letter> the .client's failure to pay amounts billed in a timely manner, the client's faililre to. cooperate or follow our advice on a material matter, or fact or circumstance that wollld; in our. view, impair eff~ctive attorney-client relationship .or would render our eontir).uing representation.inappropriate, unlawful or unethical. If.we elect to do so, the client wilrtake.all steps necessary.to free us of any obligation to perform further, including the execution dbcum~hts (including forms for substitution of coUns.el) necessary to cc>mplete our withdrawal, and; we will be entitled to be paid for all services rendered and disbursements and other.expenses µiade or incurred onbehalf of the client prior to the date ofwithdraw8.I and.for services.rendered and expenses incurred after such date to the extent they are required to protect · our client's interest or as may be required by appropriate authorities. any an of 8. We have found that our clients have become increasingly rel.iant upon various forms of · electronic commWtlcation, such as e-mail, cellular telephones, other internet communication, and eieetronic telefax (collectively, "Electronic Communications"), for the purposes of day-to-day business·communieations .. We note, however, that Electronic Communications may be inherently . leSs secure that some traditional methods of communication (hard wired telephone and telefax, U.S. Mail and ·qommercial carriers, for example) and involve the risk of interception by unauthorized third parties. We understand that, because of the convenience and efficiency of Electronic Cpmmunications, you are willing to accept the risk of unauthorized interception anQ, authi>rizeus to commwicate with you (and with others with whom we have dealing in: .. ~oimection with the m~ers \Ye· are handling for you) be means of Electronic C0mmµnications, · unleSs you a4vi~e us in ~ting to the contrary. 9. Any controversy, dispute, or claim arising out of or relating to our fees,_ expenses, performance of legal services, ·obligations reflected in this letter, or other aspects of our representation .shall be. i'esQlved through binding arbitration in accordance with the rules then in effect of o.r ad~inistered .by the· AAA, and judgment on the award rendered may be ente~d in any court havingjUrisdiction thereof. YOU ACKNOWLEDGE THAT BY AGREEING TO ARBITRATION, :Y:OU ARE RELINQUISHING YOUR RIGHTS TO BRING AN ACTION IN . COURT AND TO DEMAND A :JURY TRIAL. 10. Following the qoinpletion of this matter, the furn will not be precluded from accepting any · .other engagement on behalf of a client that may be adverse to you ifsuch engagement is Un.related to ~e .scope of our representation in this matter as described above and provided, of cow-Se,; that any and all information that may be disclosed to the firm in the course of this matter shall riotbe disclosed to any former, current or future client of the firm. 7 . JAMES·B. C~OWNOVER JOffi:'l P/CROwNOVER P..O:BOX213 . :l.54 . . METUaiEN, NJ 0884Q.oa13 DAT!l . /2...:.;_;,(o ~ts- 1 ~BROF B/(,fl/)?f+ l Aff/ L/£::_.., . I $:if'-f!i;,.i£ i . r<Jv 1r. bo tp}~r:fou::7i ~·r~J.J ~~. la· &.-:: I .. .. . . . INVESTORS EU: - . . . S~AVl~NGS~SAN~Kl~·~lf< • Wb .. . ... . . ·.~~·J!J ~~ ·i;~i;1~sr,. 4-i~~·- 1:22°l2?.20H•: \ .. / < / / ,. --·· --~ _ _ ,... r '. ' •1• ............ " ' 1 ......... . \ . .. ' Exhibit X On Thursday\~m§o~1:46 PM, Patrick J. Bradley <OOradley@bradleylawllc.com> wrote: Mr. Crownover.· Thank you for the update on the mailing addresses. I have made the necessary additions/changes in our database. I will start moving forward with the work, but will need you to sign the NEW retainer agreement that I sent out on 12/2/2015 by email, dated 11/2412015. This retainer has a final estimated tee at $527. 15 due to changes in the fees charged by the county as well as changes in my offices fees since the last time we discussed the matter. The check for $446.15 has been deposited. We will still .need a check fort~~· Please forward. that amount as soon as possible. I will forward a copy of the 1212/2015 email In case it did not arrive in your inbox or perhaps went to junk mail. I will send you a draft of the deed for your review within t e If you have any questions please let me know. I'll wait to hear back from you. Thank you for your time and attention to this matter. Patrick J. Bradley Attorney & Counselor At Law Mailing Address: Bradley Law LLC P.O. Box 26587 Collegeville, PA 19426 Office Location: Bradley Law LLC 3801 Germantown Pike Suite201 C Collegeville, PA 19426 484-902-0123 phone 484-902-0120 fax pbradley@bradleylawllc.com From: James Crownover [mailto:jamesbcrownover@yahoo.coml Sent: Thursday, December 10, 201511:16 AM To: Patrick J. Bradley; 'JOHN PHILIP CROWNOVER'; 'THOMAS CROWNOVER'; 'Rosemarie Grippo'; W3tfi Bob Crownover'; jameswtavlor@yahoo.com; 'JAMES B. CROWNOVER' ........................... Exhibit Y Exhibit z ~1< 1'•: t2i-2 7 203 ~·= b5 JB)fE 11 FonnDB-2 Rev. 07/14/11 APR 20 2016 THE DISCIPLINARY BO '1\ 1slSent tv Date COMPLAINT INFORMATION FORM ~Type or Print) Date: 4/rs[/ & A. COMPLAINANT~~ Your Name: Miss/Ms. (Last) Address: 3o~S (Street) 1-fe~htr Revtre, (First) J (MI) f(..;df f,·u_ f &j kvill~ PJ4 ,i (City) Telephone: Home: (Area Code) (Number) (State) 11L/o3 (Zip Code) ·Work: LJ(O - 3 82,,... (Area Code) (Number) 158-oz_ B. AITORNEY COMPLAlNED OF: Name: 13roc/l'1J= f0>/ri tk. (Last) County: (¥1) (First) Office Address: 32'Dl (Street) Telephone: Office: (>? Olltj()fVI~ . . GlcMard-.uJ1t P\ki, Su.1k. .Joi C 1 loJUlviltl, f"A lt:/1./2.(/ (City) 4 't'-1, ~ 0'2. -(!)I t-:5 (Area Code) (Number) (State) (Zip ) : Other: -------------------~---------~ (Area Code) (Number) C. PRIOR COMPLAINTS CONCERNING THIS MATmR QR THIS AITO&NEY: Have you previously filed a complaint concerning this matter or this attorney with the Disciplinary Board, a Bar Assogj.ation or its Fee Dispute Committee, any District Justice, Court, District Attorney or any other agency or office: _ _YES _V_NNO. If so, please identify the agency and specify the date and nature of your complaint and the action taken by tbe agency: ___________________________________________________________________________________ D. JNSTRUCTIONS: A written and signed statement of the facts must be filed with the Disciplinary Board before your complaint can be considered. Therefore, on tbe reverse side of this form, under STATEMENT OF COMPLAINT, please fully and completely set forth all of the facts and circumstances of your complaint. PLEASE BE SPECJFIC, referring to relevant dates, contacts you made with the attorney, the fee arrangement, amounts paid to the attorney and when, services to be perfonned, the names and addresses of other individuals involved in the legal matter, EXACTLY WHAT CONDUCT YOU BELIEVE IS UNETHICAL OR ILLEGAL, etc. PLEASE ATTACH COPIES OF ALL CORRESPONDENCE AND/OR DOCUMENTS RELATING TO YOUR CASE. If you send original documents and wish them returned to you, check here _ _. If you have not attached any documentation, please explain why: • • Exhibit AA E. STATEMENT OF COMPLAINT: (Note: Attach as many additional pages as necessary to fully set forth all of the relevant facts and circumstances surrounding your complaint). ldkc F. CONFIDENTIALITY Staff of the Office of Disciplinary Counsel (ODC) and the Board are required to maintain the confidentiality of complaints and related investigations and proceedings unless and until one of the exceptions to confidentiality, as set forth in Enforcement Rule 402, applies. ODC staff may interview the respondent-attorney or other persons who may have information that is relevant to your complaint, and may disclose information when disclosure is permitted or required by Court or Board Rules. G. IMMUNITY Enforcement Rule 209(a) provides that any person who communicates with Disciplinary Counsel or the Board relating to misconduct by a respondent-attorney or gives testimony before a hearing committee or special master in a proceeding conducted pursuant to the Enforcement Rules, shall be immune from civil suit based upon such communication or testimony. Yf15f /11 (Date) ~&b ~ (Your Signature) Achieve with us. Alliance Advocacy Services 4/15/16 Dear Disciplinary Board Counsel: I am writing to you to make a complaint against Patrick Bradley, Attorney ID #202416. Mr. Bradley has been suspended since 7/10/15 due to failure to comply with a subpoena (see attached document). The nature of my complaint is that Mr. Bradley continues to represent himself as a practicing attorney. The Arc Alliance provides services for individuals with Intellectual Disabilities and we have several individuals who Mr. Bradley claims to represent. Mr. Bradley sends our office scathing correspondence on behalf of his 'dients' who are under the impression that he is an attorney in good standing. The website for his services is bradleylawllc.com, and based on his website, he is the only practicing attorney in his firm. Neither his website nor the written correspondence that he engages in with our office makes reference to the fact that he is not a licensed attorney. In fact, his website states that he is licensed to practice law in Pennsylvania. When a member of our Supervisory team told a family that Mr. Bradley claims to represent that he is not currently a licensed attorney, Mr. Bradley contacted her to imply that he could file a slander lawsuit against her. I certainly understand that Mr. Bradley is able to provide other services to individuals and families. However, given these are some of our most vulnerable citizens that he is working with, it is becoming increasingly concerning to me that Mr. Bradley may not be fully disdosing his current status. I have included some examples of correspondence to show examples of the nature of this complaint. Please feel free to contact me at 610-382-5802 if you need additional information. Heather Revere The Arc Alliance sea Director Administrative Office: 3015 Ridge Pike+ Eagleville, PA 19403 + T 610.265.4700 + F 610.265.3439 Reading Office: 1829 Hew Holland RdSuite9+ Reading, PA 19607 + T 610.265.4700 + F610.603.0229 800.4 THEARC (800.484.32n) + www.TheArcAlliance.org · The Arc Alliance is affiliated with The Arc of Pennsylvania, The Arc of the United States, and The United Way of Berks County The Arc Alliance Mail - Slan~r per se - Slander per quod Page l of 2 ( ~ - ~·" The An;. · Colleen Farrell <cfarrell@thearcalliance.org> Alf'~ Slander per se - Slander per quod 1 message Patrick J. Bradley <pbradley@bradleylawllc.com> To: cfarrell@thearcalliance.org Fri, Mar25, 2016 at3:12 PM Ms. Farrell, I am sending this email to you on my own behalf. You may want to be very careful what you say to other people. "We have had issues with other clients in the pasr. Really? That sounds interesting. You may want to be very careful especially when you leave a digital voicemail detailing exactly what you said and about whom. A good attorney, especially one that is temporarily suspended, takes steps to inform their clients that they cannot provide legal services to them, however, as you noted in your recent voicemail, they can provide other services. So I am sure your message came as no surprise. An important point to understand generally is that when you make statements that are knowingly false and/or intentionally misleading (to lead a person to a different conclusion than what would be factual) about someone, to a third party, to spread the false statement and/or to intentional mislead someone - or you make such statements without checking to see if they are true- it can be slander. Filing suit for slander is relatively simple. I already sued one person for that (and that is a fact). It would only take me a moment or two to make changes to that complaint and file another slander complaint Let me know your thoughts. ........................ E~thibit BB https:/lmail.google.com/maiVu/O/?ui=2&ik=75c473190b&view=pt&q=label:scs-t.q.%20br... 4/15/2016 The Arc Alliance Mail - Slant!~r per se - Slander per quod Page 2 of2 ( Patrick J. Bradley, JD MaifingAddress: Bradley Law LLC P.O. Box 26587 Collegeville, PA 19426 Office Location: Bradley Law LLC 3801 Germantown Pike Suite201 C Collegeville, PA 19426 484-902..0123 phone 484-902..0120 fax pbradley@bradleylawllc.com https://mail.google.com/mail/u/O/?ui=2&ik=75c473190b&view=pt&q-label:scs-t.q.%20br... 4/1512016 Pagel of2 ·fhe Arc Alliance Mail - Attorney Client Privilege • < ( Colleen Farrell <cfarrell@thearcalliance.org> Attorney Client Privilege 1 message Patrick J. Bradley <pbradley@bradleylawllc.com> To: cfarrell@thearcalliance.org Fri, Mar 25, 2016 at 3:17 PM Ms. Farrell, I am writing to you with a brief note about attorney client privilege. So that you are aware, attorney client privilege protects the client. However, when the client then attacks the attorney {for any reason not related to a fee dispute), the privilege can and is frequently voided by the actions of the client. That means the attorney can then say anything they want about the client. As I am sure you are aware, having had a consultation with my office before, l always take detailed notes to make sure I understand everything my clients say. There is always a line that should not be crossed. I just thought you might want a refresher in attorney client privilege as I am starting to think someone may have crossed over the line. I want to let you know that I intend to fully defend myself against any personal allegations that come from any party. Thank you and have a great weekend. Patrick J. Bradley, JD https:/lmail.google.com/maiVu/Ol?ui=2&ik=75c473190b&view=pt&q=label:scs-t.q.%20br... 4/15/2016 . The Arc Alliance Mail - Attorq~y Client Privilege ( .. Page2of2 Mailing Address: Bradley Law LLC P.O. Box 26587 Collegeville, PA 19426 Office Location: Bradley Law LLC 3801 Germantown Pike Suite201 C Collegeville, PA 19426 484-902-0123 phone 484-902-0120 fax pbradley@bradleylawllc.com https://mail.google.com/mai1/u/O/?ui=2&ik=75c473190b&view=pt&q=label:scs-t.q.%20br... 4/1512016 lhe Are Al!lance Mm1 - Friday~ call ' Page 1of1 ( < Colleen Farrell <cfarrell@thearcalllance.org> Friday's call 1 message Fri, Mar 25, 2016 at 8:55 PM Reply-Ti To: Colleen Farrell <cfarrell@thearcalliance.org> Hi Colleen, Sony I missed your call on Friday, I was at doctors. I asked my, mother, to return the call out of courtesy to you. Colleen, you, must understand, that, we had, Pat Bradley, working with us since January. He's been handling Joe's SSI problem with the county. My mother and Sue handle that part. I have no comment on what my, mom, and, Sue, do regarding, Joe's, well being. They have my full support. We are a team. If there is something they feel, that, Pat, must handle that is our right. My mom is Joe's primary guardian. And, as such we work together to make sure, he, is safe. Amity as ,I, told you in our conversation on, Monday, is guilty of a lot of wrong. They didn't even put In for the 2 on 1 services that, Joe, needs. I hold them responsible for that. But, that is why, we, have, Pat. I am not familiar with the legal stuff. I know, Pat, very well. He's only doing what is right for Joe. Now, if my mom called, you, she was the one that could provide you with the information you need. You asked me to call, you, back. I was unable, and, I apologize! However, my, mom, is just like talking to me. On certain things! So, that is all I can tell you. I thank you for your call and opinion. I have nor does my mom have anything personal against anyone! All, we, want is what is BEST FOR JOEi And, I told you in our conversation that, Amity is not for himl If they did what they were suppose to do this wouldn't even be! Once again, I, thank youl But, I, understand, after my, mom, called you back, out of courtesy,. you, were not permitted to speak with her?? I am sorry for that! And, what goes on, Colleen, regarding, Pat, is between Pat and whomever? Not for, me, or my, mom, to be influenced. I say that with not sarcasm. I and, my, mom, must do what is right for, Joe. Anything that goes on, is between the parties involved! We are following directions from those we put our trust and confidence. And, Sue Moore, and Pat Bradley, have ours. - Thank you, https://mail.google.com/mail/u/Ol?ui=2&ik==75c473190b&view=pt&q=label:scs-t.q. %20br... 4/1512016
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.
