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IN THE SUPERIOR COURT OF MUSCOGEE COUNTY


STATE OF GEORGIA

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LINDA ELLIS,

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Civil Action File N3r4!911-; ,,';i .._.r,-iJtl

Petitioner

su_13_DM_409 iUi,::irtfil

vs.

COUFT

STALKING PROTECTIVE
ORDER

MATTHEW CHAN,
Respondent

PETITIONER'S RESPONSE TO DECLARATION


COMES NOW, LINDA ELLIS, as Petitioner and responds to Respondent's Declaration
Regarding Petitioner's Misrepresentations and Opposing Counsel's Professional Misconduct,
(hereafter "Declaration") as follows:

In as much as this case and all issues therein have been fully disposed ofby the Appellate
Courl in Respondent's favor and closed administratively, no response to Respondent's
Declaration is required; however, in order to preserve her rights with respect thereto, Petitioner
denies all inferences in the declaration as stated and reserves the right to more
the Declaration

fully respond to

if required by the Court.

Respectfully submitted this 16th day of September, 2015.


PA

M, SPROUSE,

Counsel for Petitioner


Georgia State Bar No: 730165

Avenue, 3'd Floor


Post Office Box 1 199
Columbus, Georgia 3 1902- 1 437
111

;;

1 Bay

7061324-0251

ewm@psstf.com

VERIFICATION AFFIDAVIT
STATE OF GEORGIA

COLNTY

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PERSONALLY APPEARED, before the undersigned ofEcer, duly authorized to


administer oaths, LINDA ELLIS, who states under oath that the information contained in the

within and foregoing PETITIONER'S RESPONSE TO DECLARATION the captioned matter


is true and correct to the best

rhis

ofAftiant's knowledge, information and belief.

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CERTIFICATE OF SERVICE
I certi$/ that I have this date caused a copy of this PETITIONER'S RESPONSE TO
DECLARATION to be served upon the following by regular mail to:
Matthew Chan
P.O. Box 6391
Columbus, GA 3 1917
Oscar Michelen
Cuomo LLC
9 East 38th St.
New York, NY 10016

This

16th day

of Septemb er,2015.
TUCK,ER/& FO&P, P.C.

Counsel for Petitioner


Georgia State Bar No: 730165
1 1 I 1 Bay Avenue, 3'd Floor
Post Office Box 1199
Columbus, Geor gia 3 19 02- | 437

7061324-025t