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INDIANA SUPREME COURT DISCIPLNARY COMMISSION

REQUEST FOR INVESTIGATION

COMPLAINT AGAINST THE LAWYERS

AFFIDAVIT OF KAY KIM

1.  We are living on the bottom unit at Village at Eagle Creek HOA. In 2009 there was atoilet overflow in the 2nd bathroom from the unit above ours. In 2010, we discoveredthat there were large patches of yellow on the ceiling of my master bathroom. InAugust 2011, water with mixture of excrement started leaking into our masterbathroom. The three leaks are unique and not related to one another.

2.  In 2009 under Case 49K05-0904-SC-2680, Perry SCC entered judgment of $1042.86for toilet over flow in favor of Kay Kim, Pro Se-Plaintiff.

3. 

In 2010 under Case 49K04-1009-SC-3527, State Farm Insurance Attorney Robert F.Ahlgrim Jr. represented Defendants Kyle and Shannon Love. In his reply he lied bystating that the 2010 Case is the same one as the 2009 Case. The Defenders knowingthe distinction of two Bathrooms by their descriptions mislead the Court also. In ourreply to their Motions, we explained that the 2010 Case (master bathroom) is not thesame as the toilet in the 2009 Case (2nd bathroom).

4.  In 2010 under Case 49K04-1009-SC-3527, Attorneys Lori A Coates, Richard ARocap, Michael Brown represented the Defendant, VECHOA and State FarmInsurance Attorney Robert F. Ahlgrim Jr. represented the other Defendant in theCase. The Case was continued numerous times in the Perry Township Small ClaimsCourt, Honrable Judge Robert S. Spear’s with own motions. The Defendant and theDefendant’s attorneys did not show few times on the Court’s hearing date but JudgeSpear would not grant default judgment to Kay Kim, Pro Se-Plaintiff.

5.  So Kay Kim, Pro Se-Plaintiff decided to ask the Perry Township Small Claims Courtto dismiss all defendants without prejudice so that she can file/attach her Complaintin the ongoing Civil Superior Court Case 49D14-1011-CT-048790. Attorney RobertF. Ahlgrim unprofessionally shared the false and misleading information andconspired with the other Attoneys, Lori A. Coates, Michael E. Brown, and Richard A.Rocap even though he is not representing their client.

6.  Kay Kim filed claims in the Civil Superior Court #1 under Cause No: 49D04-1011-CT-048790. The Defendant-VECHOA’s attorneys-Michael E. Brown, Casey R.Stafford, and Lori Coates for the Defendant, lied to the Court and asked for SummaryJudgment because the case is already ruled by the Perry Township Small ClaimCourt. This is a complete lie because their client is not a party of the 2009 Case.Never the less, the Judge Sherry K. Reid dismissed the case under the false pretence.

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7.  On August 5, 2011 there was a new leak in my Master Bathroom and Kay Kim filed aComplaint on August 8, 2011 in the Perry Township Small Claim Court under Case49K04-1108-SC-2739. For the Defendants-Shannon & Kyle Love’s attorney RobertF. Ahlgrim again conspired, lied, and claimed that the leak is the same as the onefiled in 2009. Attorneys Michael Brown, Casey R. Stafford, Lori A. Coates for the

Defendant-VECHOA presented the dismissal from the Civil Court’s case 49D14-1011- CT-048790 and again Attorneys Michael Brown and Lori A. Coates forthe Defendant- VECHOA conspired to lie to the Perry Township Small ClaimsCourt and told the Judge Robert S. Spear that the new Case is the same as the onedismissed in the Civil Superior Court.

8.  I am attached affidavit filed with the Small Claims Courts for your reference.Attorney Robert F. Ahlgrim intentionally lied to the Court and shared his lie andconspired with the other Attoneys who use the same lie to get a Summary Judgmentfrom the Civil Superior Court. Attorney Michael Brown for the Defendant-VECHOA

then used a Court Judgment issued under false pretence to mislead the Perry SmallClaims Court Judge in Case 49K04-1108-SC-2739. This case was dismissed withprejudice.

9.  All cases for in favor of the Defendant are on a appeal. We have to appeal in thehigher Courts because of their lies and conspiracy and there is no other recourse forus.

10.  Attorneys intentionally continue to conspires and lies in Court to further their cause.

I affirm under the penalties of perjury that the foregoing statements are true and accurate to thebest of my knowledge and belief.

Dated: September 08, 2011 _______________________Kay Kim, Pro Se-Plaintiff/Appellant