This Review has multiple parts, this is part 1; Follow the parts for all the facts. IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA Sandra Harmon Plaintiff Civil Action No.:____________________________ VS. William Orange III Defendant NOTICE OF COMPLAINT Plaintiff Sandra Harmon hereby files this Notice of Complaint, and in support avers as follows: JURISDICTION 1. This court has subject matter jurisdiction pursuant to Article Ill and USC 28;1332 Diversity of Jurisdiction. 2. Plaintiff, in this action reside in the State of South Carolina, and the Defendants residence is in the State of Georgia. PARTIES 1. Sandra O'Hara- Harmon, Plaintiff, and adult whose ..... 2. William Orange III, Defendant whose employment address is 1419 Newcastle Street, Brunswick, Georgia 31520. CLAIM 1. Mr. William Orange III, breached the agreement he entered with the Plaintiff in his Disclosure of Compensation of Attorney for Debtors agreement @ number 5, by abruptly telling the plaintiff that he quit as her attorney, solely due to Plaintiff disagreement with him on the current value of Plaintiff 2013 Toyota Siena Van, and his insistence of accepting the high end value noted by the opposing counsel. 2. Mr. William Orange III, has diverted the $3500 given to him to adjudicate Plaintiff Chapter 13 Plan by charging excessive fees, for services not rendered to the Plaintiff; as his compensation exceeds the reasonable value of services he rendered in the Bankruptcy case. 3. Despite Mr. William Orange abruptly quitting as my attorney in the Bankruptcy proceeding, throughout the term that he represented me as counsel, I displayed complete respect and kindness to Mr. Williams Orange III, respecting his age. His conduct continues to be one of racial bigotry. He is very demeaning and prejudicial toward me, Plaintiff as an African American, which made an Attorney -Client relationship impossible. FACTS SUPPORTING CLAIMS 1. On June 4, 2018, Plaintiff paid her filing fee, and submitted a Voluntary Petition for Individuals filing for Bankruptcy, and clearly specified a filing under Chapter 13. (See Plaintiff Exhibit No. 1); also completed online counseling 2. Thereafter, Plaintiff contacted a William Orange III, and hired him to take on the Chapter 13 Petition I filed because I didn't want to have to pursue the case, while having to teach throughout the school academic year. This meeting giving him all he needed was less than 30 minutes, as I had a limited number of creditors. 3. According to the court docket, on 6/18/2018, Defendant Orange filed a Disclosure of Compensation of Attorney for Debtor. 4. Specifically, the Disclosure of Compensation of Attorney document noted that Mr. Orange agreed to the sum of $3500 for handling of my Chapter 13 Case. 5. In return for the $3500 fee, Mr. Orange agreed to render legal services for all aspects of the bankruptcy case including the following: (See Plaintiff Exhibit No. 2) a. Analysis of the debtor's financial situation, and rendering advice to the debtor in determining whether to file a petition in bankruptcy; b. Preparation and filing of any petition, schedules, statement of affairs and plan which may be required; c. Representation of the debtor at the meeting of creditors and confirmation hearing, and any adjourned hearings thereof; d. [Other provisions as needed] 6. In the bankruptcy proceeding for which there exist a fee dispute, resulting in this current action, Mr. Orange neglected to note on his disclosure the following facts. a. Defendant did not represent the Plaintiff for all aspects of the bankruptcy proceeding, as he rudely quit the case prior to the confirmation hearing, resulting in the plaintiff submitting a motion to withdraw her claim on February 11,2019. (see Plaintiff Exhibit No. 3) b. Defendant did not prepare, pay a filing fee, make any corrections, nor file Plaintiff Bankruptcy Petition for Plaintiff. Plaintiff filed her own petition. c. Defendant did not render any advice regarding the type of petition to file, as the Petition clearly notes the filing of a Chapter 13. 7. Mr. Orange did provide the following services which did not equate to the total consumption of the total $3500 fee for which he stated to me he abruptly terminated the agreement via quitting as my counsel. 8. The Chapter 13 was to be for a period of 5 years, but Defendant quit the case within 8 months due to a disagreement over an appraisal cost of Plaintiff's 2013 Toyota Sienna Van. 9. He clearly stated to me the Plaintiff to go find another attorney because he quit, and hung up the phone on me the Plaintiff while I was talking to him. 10. Prior to the defendant terminating his representation of the Plaintiff, he provided the following services that does not necessitate him retaining the total amount of $3500. read more