Mark A Christensen
108 S. Market St
P O Box 973
Bucyrus, OH 44820-0973
(419) 569 -5272
Come now Mark A. Christensen, Plaintiff, and brings this action for damages against the Defendant Shane M Leuthold, and Bradley S Starkey Co-Defendant, and in support hereof would respectfully show unto the Court the following facts and matters, to-wit:
Defendant, Shane M Leuthold, and Co-Defendant, Bradley S Starkey, are adult residents of the State of Ohio, Said defendant may be found for the service of process at his law office located at Whetsone Plaza, 1309 E. Mansfield Street, Bucyrus, Ohio, 44820, which is located in Crawford County, Ohio.
In January 2007, Defendant undertook to provide legal services for Plaintiff in connection with his Juvenile Court Trail, Domestic abuse trial, and Divorce, hereinafter \u201cLegal Matter\u201d. At all times Defendant held himself out as competent in the area of law dealing with the legal matter for which Plaintiff retained the services of Defendant. Plaintiff and Defendant acted under an attorney/client relationship in which Defendant undertook to represent Plaintiff.
And in August 2007, Co-defendant undertook to provide legal services for Plaintiff and Plaintiffs four children for defendant Shane M Leuthold and the domestic relations court of Crawford County, Ohio as Guardian Ad Litem.
Defendant and Co-Defendant were required to exercise the same legal skill as a reasonably competent attorney and to use reasonable care in determining and implementing a strategy to be followed to achieve the Plaintiff\u2019s legal goals. As a fiduciary of Plaintiff, Defendant and Co-Defendant was obligated to treat all information relating to a Plaintiff\u2019s representation as confidential and to zealously represent the Plaintiff and his children\u2019s interests, including the disclosure of any conflicts of interest that might impair the Defendant(s) ability to represent the Plaintiff.
In the course of handling the legal matter for the Plaintiff, Defendant(s) negligently failed to act with the degree of competence generally possessed by Attorneys in the State who handle legal matters similar to Plaintiff\u2019s. Plaintiff paid Defendant(s) a substantial amount of money for the sole purpose of representing Plaintiff in said legal matter.
By failing to explain to the Plaintiff that He was not going to attain monitored visitations with his four children until after the domestic abuse trial had concluded a verdict and that he would never see any of his children again since January 2 2007; and the juvenile court trial on February 2 2007 he would be absent and had attained permission from the parties involved and court for \u201cTime,\u201d to be granted, but was denied me which the juvenile court put on this trial to vote me guilty without an attorney present to represent me, then defendant Shane
By representing to the Plaintiff that he would assert an aggressive defense utilizing the volumes of evidence to squash all the perjury used against me in the Domestic Court of Crawford County which began on May 23 2007 along with use of all testimony of my witnesses given him to defend me. Defendant Shane Leuthold knew first hand having proved every allegation was in fact perjury in his defense of plaintiff in the Crawford County Civil Court on July 6 2007; and that when I asked defendant Shane Leuthold to get the children a Guardian Ad Litem assigned for their protection seeing them forced to perjure testimony in the May 23 2007 Domestic Court hearing and the civil court hearing electing to name Co-defendant Bradley S. Starkey he ignored my objections hiring the same attorney that voted me guilty in the juvenile court back on February 2 2007, defendant Shane Leuthold assured he was on good terms with the co-defendant and that he could and would do well for me and the children in this case, and that Mr. Starkey realized it was all perjury being used against me, and he would make sure I received all fathers rights under the law and they both agreed Debra Christensen should not have custody that they both knew something was wrong with her, nor did either Defendant or Co-Defendant ever advise such appointment was biased and against the Ohio Supreme Court Ethics as it was later found out to be, and Co-Defendant Brad Starkey knew by the law he should have declined such appointment having represented Crawford County Children Services as their Guardian Ad Litem in the Juvenile Court hearing, which violated all rules of the Ohio Bar Association in accepting the assignment; and Defendant Shane Leuthold representing at the December 7 2007 hearing in the Domestic Relations Court hearing that I had won the divorce based on the court ordered psychological results that had been ordered by the court for myself and Debra Hoover Christensen, showing Debra had multiple problems, but if I would agree and hurry and get counseling by Mansfield Counseling the domestic court wished me to receive to verify I was not any of what the perjured testimony tried to make of me, the sooner he would petition the court to go from the agreed upon supervised weekly visits, to full custody, and at no time did defendant(s) Shane Leuthold and Bradley Starkey ever advise me by agreeing to the divorce decree temporary terms that I would never see my children again and protect her by allowing visitations to never commence nor would they ever speak to me again so they would never have to amend any parts of the divorce to ever receive custody ever nor would they respond to Mansfield Counseling when asked what type of counseling the court wanted as my psychological showed no defects or problems needing any type of counseling services.
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